NC0004375_More Information (Received)_19890503

NPDES DOCIMENT SCANNING COVER :SHEET
NPDES Permit:
NC0004375
Clariant Corporation
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Owner Name Change
Additional Information Received"
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
May 3, 1989
This document is prirated on reuse paper - ignore any
content on the reirerse side

f.)1
SANDOZCHEMICALS
Mallard Creek Research Center
P.O. Box 669304
Charlotte, North Carolina 28266
704.547.0632
Telefax: 704.547.5588
May 3, 1989
Mr. D. Rex Gleason
Water Quality Regional Supervisor
North Carolina Division of
Environmental Management
Post Office Box 950
Mooresville, NC 28115
2
fYi
Environmental Services
and
Product Safety Deportment
2304 W.T. Harris Boulevord
Charlotte, North Carolina 28213
RECEIVED
111:/1Y 8 1999
PERMITS & ENGINEERING
Re: Sandoz Chemicals Corporation, Mount Holly Plant
NPDES 0004375
Dear Mr. Gleason:
Enclosed is information concerning a powdered carbon storage silo
that Sandoz intends to install at our Mount Holly Plant. The
silo and feed system will give us the capability to add a
carbon/water slurry to our biological treatment system, if
needed, to aid the treatment process.
As I mentioned in our recent telephone conversation, Mr. Arthur
Mouberry, Supervisor of DEM Permits and Engineering in Raleigh
indicated that, contingent on your concurrence, no authorization
to construct was necessary for installation of this vendor -
supplied unit. Based on your concurrence over the phone, I am
sending you a description of the system for documentation in your
files.
The system should be installed in a few months. I will notify
you when installation is completed. Thank you for your
assistance in this matter.
Sincerely,
William M. Archer
Environmental Manager
cc: Mr. Arthur Mouberry, w/o attachment
Attachment
RECEIVED
JUL 271991
CENTRAL FILE COPY

SANDOZCHEMICALS
Mallard Creek Research Center
P.O. Box 669304
Charlotte, North Carolina 28266
704.547.0632
Te l efa x : 704.547.5588
March 30, 1989
Ms. Lula M. Harris
North Carolina Division of
Environmental Management
Post Office Box 27687
Raleigh, NC 27611-7687
Re: NPDES Permit No. NC 0004375
Sandoz Chemicals Corporation
Mecklenburg County
Dear Ms. Harris:
t
cAuk
Environmental Services
and
Product Safety Department
2304 W.T. Harris Boulevard `' L
Charlotte, North Corolino 28213
RECEWED
APR 03 1989
PERMITS & ENGINEERING
JUL 2 7 1991
ED
CENTRAL EILEenv In response to your request of February 13, 1989, compiled
the attached information on the composition of influent streams
to the wastewater system. The layout of the plant storm water
collection and process sewer system prevents the compilation of
meaningful separate storm water data. The majority of the rain-
water that falls around the immediate plant area, travels dcross-
pavement to one of many surface rains a ead into the pro
sewer lines. Thus, in addition to the traditional difficulties
of sampling storm run-off because of variation related to
precipitation duration and intensity, there is also the problem
of not having any appropriate place to take representative
samples.
The plant influent information that I"m submitting represents the
combined process wastewater and storm water data that was
collected by EPA when they were developing the BAT guidelines for
the industry. Although this information is several years old, it
is the best available. The following changes have occurred since
the sampling which should be noted.
1) 0-Dichlorobenzene and are no longer used
at the plant. The groundwater will become the primary
source for o-dichlorobenzene to the system once
recovery begins.
2) Pretreat has been added for the nitrophenols and
improved for the phenol, reducing influent

Ms. Lula M. Harris
March 30, 1989
Page two
RECEIVED
APR 03 1989
concentrations of these compound; from the piabduction
facilities. Pretreatment does nct affect inputs frpm
precipitation run-off which will`be quite variable
and sporadic.
3) Plant procedures and equipment have been improved which
have generally reduced the discharge of priority
pollutants, particularly solvents, to the sewer.
The groundwater recovery system will include water from two
source areas. Approximately 80% of the water will be removed
from downgradient of the wastewater treatment basins. This water
will be pretreated in an air stripper unit to remove
approximately 96% of the volatile solvent constituents, including
o-dichlorobenzene. The phenolic compounds should not be
significantly reduced. The remaining water will be from several
small areas around the production facility. This water will not
be pretreated.
Wells SP8A, SPEC, SP9, SP9A, SP10, and SP10A are in the area that
will be pretreated. Well SPEC is screened somewhat deeper than
the extraction system will operate; however, as water is
withdrawn, the deeper water represented by SP8C should migrate
toward the extraction system.
Well monitsaring results given in the _last_ t_ ba 1_e -epresent the
most recent water quality data from the areas that will not be
pretreated. These wells were generally analyzed for a set of
indicator parameters that include the predominant contaminants.
A BOD test has been run on groundwater from one of these areas
close to the wastewater basins that we believe represents a
typical value for the site's groundwater. The BOD result on that
sample collected on March 22, 1989 was 89 mg/1.
If you have any questions about this data, or if more information
is needed, please contact me.
Sincerely,
;71
atAt,,,,_ . 61,_
, , /
c 1A-A___
William M. Archer
Environmental Manager
Attachments
' ECAt,V
ED
LIL 21 19Q1
CENTRAL Fitt cop),.

INFLUENT BOD DATA FOR 1988
Monthly Average - Mg/1
4 "± ao0�
January 644 Mg/1 p7"-yi
February 838 Mg/1 /os'y-
March 839 Mg/1 /63 s)ete
April 312 Mg/1 zDa
-May 621 Mg/1 024141'/
June 764 Mg/1 V^'J
July 562 Mg/1 /r)/7\Y,
August 672 Mg/1 29 —7,P
September 402 Mg/1 19 My/e
October 675 Mg/1 07.7,Ky/,
November 532 Mg/1�
December 656 Mg/1 3/0, ,e
trEcE/
ceNT R4L FitE copy

DIVISION OF ENVIRONMENTAL MANAGEMENT
March 6, 1989
MEMORANDUM
To: Dale Overcash
From: Ken Eagleson
Re.: NPDES Permit Chronic Bioassay Requirement as Proposed by:
Sandoz Chemical Corporation, NPDES NC0004375
Mecklenburg County
In their letter dated January 17, 1989, Sandoz Chemical Corporation has provided proposed
NPDES permit limitations for DEM review. Concerning the whole effluent chronic toxicity
requirement, Sandoz proposes a quarterly screening test to be conducted at 1.8% effluent
concentration. They suggest that upon a test "failure" for two (2) quarters, a third sample be taken
within 30 days. If the third sample fails, they indicate a willingness to conduct an instream benthic
study in order to determine instream impact attributable to the discharge. Should that study
determine that the discharge causes an instream impact, they point out that, at that time toxicity
reduction evaluations would be initiated by the facility.
The facility proposes to employ the chronic toxicity test as a screening tool, however the Division
considers the chronic pass/fail methodology as a final decision element in assuring protection of
water quality standards. The eventual requirement is that a facility be able to achieve compliance
with a permit requirement that will accomplish this regulatory goal. As with other NPDES
facilities that are receiving whole effluent chronic toxicity requirements in their permit, Sandoz
Chemical Corporation would be required to demonstrate no observable inhibition of reproduction
or significant mortality in test organisms exposed to the effluent instream waste concentration. In
addition, the current permit language for this requirement specifies that should any single quarterly
monitoring indicate a failure to meet specified limits, then monthly monitoring will begin
immediately until such time that a single test is passed. Upon passing, this monthly test
requirement will revert to the quarterly schedule. Therefore, as the facility suggests, an increased
monitoring frequency is accounted for in the present permit language. The instream benthic
assessment proposed by Sandoz will not be considered a compliance evaluation tool. Should you
have any questions, please feel free to contact me.
cc: Trevor Clements

SANDOZCHEMICALS
Mallard Creek Research Center
P.O. Box 669304
Charlotte, North Carolina 28266
704.547.0632
Telefax: 704.547.5588
March 6, 1989
Mr. Dale Overcash
North Carolina Department
Resources and Community
Division of Environmental
Post Office Box 27687
Raleigh, NC 27611
Re:
of Natural
Development
Management
Sandoz Chemicals Corporation
NPDES Permit Renewal
NC0004375
Dear Mr.Overcash:
Cam . 1, ,
tom?
A uQ(
Environmental Services (k-L
and
Product Safety Department
2304 W.T. Harris Boulevard
Charlotte, North Carolina 28213
RECEIVED
JUL 27 1991
CENTRAL FILE COPY
Enclosed are several amended pages to the NPDES renewal
anz,liratinn for the Sandoz Chemicals Corporation, Mount Holly
Plant. As discussed in my letter to you on January 17, 1989,
several changes have occurred at the facility since our renewal
application was originally submitted in September, 1987.
Anticipated changes in production capacity and flows were
described in that letter. In addition, new treatment facilities
have been completed since September, 1987, that are not reflected
in the original flow diagram. The pages amended include pages I-
1, I-2, I-3, II-3, II-4 and the flow diagram. A breakdown of the
revisions on these pages is given below:
Page I - 1 Change in my mailing address and phone number,
the previous application date and a new
certification signature.
Page I - 2 Revised flows for portions of items 7 and 8.
Page I - 3 Revised flows for portions of item 9. Provided
an issue and expiration date for our RCRA
permit. Provided a revision to the additional
information in item 12 which deletes our
request for different summer/winter flows.
Page II - 3 Production capacity for Norflurazon will change
as the result of planned modifications to the

Mr. Dale Overcash
March 6, 1989
Page four
production facility. Production capacity is
claimed confidential business information and
provided on a separate sheet.
Page II - 4 The Waste Abatement Practices (items 15 a and
b) have been revised and expanded to reflect
plant upgrade.
Flow Diagram A new flow diagram reflects the revised flows
and treatment plant modifications.
Other pages in the application have not changed from our 1987
submittal. The non -amended pages in sections I and II of Form C
are included in this package for ease of review.
If you have any questions, please contact me.
Sincerely,
� ` )4.
Gc/.
s�
William M. Archer
Environmental Manager
RECEIVED
r 1991
CENTRAL FILE Cppy

N. C. DEPT. OF NATURAL RESOURCES AND COMMUNITY DEV.
ENVIRONMENTAL MANAGEMENT COMMISSION
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
APPLICATION FOR PERMIT TO DISCHARGE WASTEWATER
STANDARD FORM C — MANUFACTURING AND COMMERCigAL
FOR AGENCY USE
MAR 1 0 1989
•
SECTION 1. APPLICANT AND FACILITY DESCRIPTION i-S RING
Unless otherwise specifled on this form all Items are to be completed. I( an Item Is not applicable Indicate 'tdA.'
AOOITIONAL INSTRUCTIONS FOR SELECTED ITEMS APPEAR IN SEPARATE INSTRUCTION BOO'CLET4AS !Nib' ,Si C. RE? TO
BOOKLET BEFORE FILLING OUT THESE ITEMS.
1. Legal Name of Applicant
(see Instructions)
2. Mailing Address of Applicant
(see instructions)
Number & Street
' City
State
Zip Code
3. Applicant's Authorized Agent
(See Instructions)
Name and Title
Numoer & Street Address
City
State
Zip Code
Telephone
4. Previous Application
If a previous application for a
National or Federal discharge per-
mit has been made, give the date
of application. Use numeric '
designation for.date.
Please Print or Type
Sandoz Chemicals Corporation
P.O. Box 669246
Charlotte
North Carolina
28266
Mr. William M. Archer, III
Environmental Manager
P. 0. Box 669304
Charlotte
North Carolina
28266
704.
547-5601
Area Number
• Code
78 12 1
YR MO
DAY
' CENT 9 f
87/09/0tPk 754,
F/L .,.
apk
I certify that 1 am familiar with the Information contained In this application and that to the best of my knowledge and belief sucn Information
Is true, complete, and accurate.
Ray H. Ankers
Printed Name of Person Signing
102 r
Tozr
Vice President, Operations
Title
3
YR MO OAY
Sig(y6tura or Applicant or Authorized Agent Date Application Sinned
North Carolina General Statute 143-215.6(b)(2) provides that: Any'person who knowingly 'makes
any false statement: representation, or certification in any application., record, report, plan,
or ether document files or required to be maintained under Article =1 or regulations of the
_,_ronmental Management Commission implementing that Article, or -.:bo falsifies, tampers with,
or-o--:ly renders inaccurate any recording or monitoring device or method required.to be
Aerated cr ra i.-taxied urlder Article 21 or regulations of the Env ronr:ental Management Ccsi_ssio_
fmmlementing that Article, shall be guilty of a misdemeanor `pUnis,-.able by a fine net to eaceec•
S10,000, or by tmprisonment not to exceed six months, or by both. (IS U.S.C. Section 1001 provide
a punishment by a fine of not more than $10,000 or imprisonment not more than 5 years, Or -both,
for a similar offense.)

S. IraellIty/Activity (see Instructions)
Give the name, ownership, and
physical location of the plant of
other operating facility where Olt-
charge(s) does of will occur.
Name
Ownership (Public, Private or
Both Public and Private)
Check block If Federal Facility
and give GSA Inventory Control
Number
Location
Street & Number
City
County
State
6. Nature of Business State the
nature of the business conducted
at the plant or operating facility.
7. Facility Intake Water (see instruc-
tions) Indicate water intake volume
per day by sources. Estimate
average volume per day in thousand
gallons per day.
Municipal or private water system
Surface water
Groundwater
Other.
Total Item 7
•If there Is Intake water from
'other,' specify the source.
8. Facility Water Usa Estimate
average volume per day In thousand
gallons per day for the following
types of water usage at the facility.
(see Instructions)
Noncontact cooling water
Boller feed water
Process water (Including contact
cooling water)
Sanitary water
Other*
Total Item 8
•If there are•discharges to
'other,' specify.
If there Is 'sanitary' water use, give
the number of people served.
FOR AGENCY USE
Sandoz Chemicals Corporation
Mount Holly Plant
[PUB (33PRV ❑BP9
FED
N.C. Highway 27 West
ril"4 Charlotte
€ Mecklenburg
North Carolina
Manufacture and Processing of Dyes and Organic Chemicals
107k., '?Ago thousand gallons per day
thousand gallons per day
330 (Contamina ed water for treat-
',) thousand gallons per day men only)
thousand gallons per day
200
1071 ' 3020
Stormwater runoff
100
toss
100 thousand gallons per day
ato'^ 2460
60
Asmkuc, thousand gallons per day
thousand gallons per day
300
3020
thousand gallons per day
thousand gallons per day
thousand g•lions per day
thousand gallons per day
bkt
i ,. DEL)
� 7,,9Q
RA( rat
C
oPr
(includesezroundwater and
corwt
�}EWater treatment filter backwash
r
400
p•o kl served
• 1-2

9. Alt Facility Discharges and other
Losses; Number and Discharge (yes
Instructions) Volume Specify the
number of discharge points and the
volume of water discharged or
lost from the facility according to
the categories below. Estimate
average volume per day In thousand
gallons per day.
Surface Water
Sanitary wastewater transport
System
Storm water transport System
Combined sanitary and storm
water transport system
Surface Impoundment with no
effluent
Underground percolation
Well Injection
Waste acceptance firm
Evaporation
Consumption
Other•
Facility discharges and volume
Total Item 9. 12941
• If there are discharges to 'other,'
specify. 109m1
10. Permits, Licenses and Applications
List all existing, pending or denied permits, licenses and applications related to discharges from this facility (see instructions).
109a1
1011b1
103c1
10141
110
2.
FOR AGENCY USE
Number of
Discharge
Points
1
109a2
101b2
101e2
109d2
109a2
10112
10942
109112
10912
10912
109k2
10912
Total Volume Used
or Discharged,
Thousand Gal/Day
2780
200
20
20
30 )0
Sludge Landfill
109a1
10911
10121
109111
10911
10911
109k1
Issuing Agency
For Agency Use
Type of Permit
or License
ID Number
Date
Filed
YR/MO/DA
Date
Issued
YR/MO/DA
Date
Denied
YR/MO/DA
Expiration
Date
YR/MO/DA
(a)
(0)
(c) Id)
fa)
0)
• '(9)
I rh)
NCDNR©
NUDES I NC0.0.04375
78/12/1
83/5/13 1
188/3/10
I
NCD
III
RCRA NCD001810365
83/8/4
88/9/1
193/8/31
I
I
I
.t
din
V
En
11. Maps and Drawings
Attach all reauired maps and drawings to the back of thls application.(see Instructions)
12. Additional Information
112 Item Number
Information
v` ilr
earn, Fi (1s9;
�E COP)/
9
Values represent potential annual flow quantities for 1990. We
request continuation of 3.9 MGD discharge rate to allow discharge
of stored effluent.
1-3

STANDARD FORM C — MANUFACTURING AND COMMERCIAL
SECTION II. BASIC DISCHARGE DESCRIPTION
FOR AGENCY USE
Complete tnis section for each discharge indicated in Section 1, Item 9, that is to surface waters. This includes discharges to municipal sewerage
systems in which the wastewater does not go through a treatment works prior to being discharged to surface waters. Discharges to wells must
be described where there are also discharges to surface waters from this facility. SEPARATE DESCRIPTIONS OF EACH DISCHARGE ARE
REQUIRED EVEN IF SEVERAL DISCHARGES ORIGINATE IN THE SAME FACILITY. All values for an existing discharge should be repre-
sentative of the twelve previous months of operation. I1 this is a proposed discharge, values should reflect best engineering estimates.
ADDITIONAL INSTRUCTIONS FOR SELECTED ITEMS APPEAR IN SEPARATE INSTRUCTION BOOKLET AS INDICATED. REFER
Ti') BOOKLET BEFORE 1- 1: LING OUT THESE ITEMS.
1. Discharge Serial No. and Name
a. Discharge Serial No.
(see instructions)
b. Discharge Name
Give name of discharge, if any,
(see instructions)
c. Previous Discharge Serial No.
If previous permit application
was made for this discharge (see
Item 4, Section I), provide previ•
ous discharge serial number.
2. Discharge Operating Dates
a. Discharge Began Date It the
discharge described below is in
operation, give the date (within
best estimate) the discharge
began.
b. Discharge to Begin Date I1 the
diScharw has never occurred but
is planned for some future date,
give the date (within best esti-
mate) the discharge will begin.
C. Discharge to End Date If dis-
charge is scheduled to be discon-
tinued within the next 5 years,
give the date (within best esti-
mate) the discharge wilt end.
3. Engineering Report Available
Check if an engineering report is
available to reviewing agency upon
request. (see instructions)
4. Discharge Location Name the
political boundaries within which
the point of discharge is located.
State
County
(if applicable) City or Town
5. Discharge Point Description
Discharge is into (check one):
(see instructions)
Stream (includes ditches, arroyos,
and other intermittent watercourses)
Lake
Ocean
Municipal Sanitary Wastewater
Transport System
Municipal Combined Sanitary and
Storm Transport System
201a
201b
201c
202a
202b
202c
203
204a
204b
204c
205a
001
Treated Wastewater
001
76 06
YR MO
YR MO
N/A
Y R MO
Kt
North Carolina
Mecklenburg
Charlotte
®5TR
❑LKE
❑OCE
❑MTS
❑MCS
ceiviR4L F�` 499/
COpj.
204d
204a
204f
Agency Use
This section contain, 9 paf$e,.

DISCHARGE SERIAL NUMBER
001
Municipal Storm Water Transport
System
Welt (Injection)
Other
If 'other' is checked, specify
6. Discharge Point — Lat/Long Give
the precise location of the point
of discharge to the nearest second.
Latitude
Longitude
7. Discharge Receiving Water Name
Name the waterway at the point
of discharge.(see instructions)
If the discharge is through an out -
fall that extends beyond the shore-
line or is below the mean low
water line, complete Item 8.
8. Offshore Discharge
a. Discharge Distance from Shore
b. Discharge Depth Below Water
Surface
9. Discharge Type and Occurrence
a. Type of Discharge Check
whether the discharge is con•
tenuous or intermittent.
(see instructions)
b. Discharge Occurrence Days per
Week Enter the average num-
ber of days per week (during
periods of discharge) this dis-
charge occurs.
c. Discharge Occurrence —Months
if this discharge normally
operates (either intermittently,
Or continuously) on less than
a year -around basis (excluding
shutdowns tor routine mainte-
nance), check the months dur-
ing the year when the discharge
is operating. (see instructions)
:omplete Items 10 and 11 if "inter-
iittent" is checked in Item 9.a.
)therwise, proceed to Item 12.
0. Intermittent Discharge Quantity
State the average volume per dis-
charge occurrence in thousands of
gallons.
11. Intermittent Discharge Duration
and Frequency
a. Intermittent Discharge Duration
Per Day State the average
number of hours per day the
discharge i5 operating.
b. Intermittent Discharge
Frequency State the average
number of discharge occur-
rences per day during clays
when drscnarging.
2050
20ta
20Sb
207a
2070
2088
20ib
2088
20Sb
20,c
210
211a
211b
❑ STS
❑ WEL
❑OTH
FOR AGENCY USE
35 DEG 16 MIN 45 SEC
81 DEG 00 MIN 31 SEC
Catawba River
For Agency Use
Major
Minor
Sub
N/A
feet
N/A feet
(con) Continuous
❑ (int) Intermittent
% days per week
EJAN FE.B
JAY EJUN
SEP ®OCT
N/A
207c
gjMAR
]JUL
gjNOV
For Agency Use
303e
APR
]AUG
® DEC
thousand gallons per discharge occurrence.
NL' hours per day
N/'Aischarge occurrences per day
12. Maximum Flow Period Give the
time period in which the maximum
flow or this discharge occurs.
212
From N/A to
month month
11-2

DISCHARGE SERIAL NUMBER
001
13. Activity Description Give a
narrative description of activity
producing this clIscharge.(see
Instructions)
14. Activity Causing Discharge For
each SIC Code which describes
the activity causing this discharge,
supply the type and maximum
amount Of either the raw material
consumed (Item 14a) or the product
produced (Item 14b) in the units
specified in Table I of the Instruc-
tion Booklet. For SIC Codes not
listed in Table I, use raw material
or production units normally used
for measuring productton.(see
instructions)
a. Raw Materials
FOR AGENCY USE
213a1 Manufacturing and processing of dyes and organic
chemicals, and manufacture of an agricultural herbicide.
Maximum Unit Shared Discharges
SIC Code Name Amount/Oay (See Table I) - (Serial Number)
214a (1)
(2)
(3)
(4)
(5)
b. Products
21
SIC Code
Name
lite
jJ` /� lycf
Maximum CENTR4L FIDE Shared Discharges
Amount/Day (See Table i) Opj(Serial Number)
(1)
(2)
(3)
(4)
(5)
2865
P.esnad sOrg.
emica
400
1000 lbs
001 .
2879
Ag. Herbicide
-•
1000 lbs
001
*See attached Confidential Answer Sheet.
1I-3

15. Waste Abatement
a. Waste Abatement Practices
t,escrlbe th4 waste abatement
loaf fir eR t,•,r:O row this discharge
with a brief narrative. (sec
instnlctinns)
b.
Waste Abatement Codes
Using the codes listed in Table
II of the Instruction Booklet,
describe the waste abatement
processes for this discharge in
the order in which they occur
215a
215b
DISCHARGE SERIAL NUMBER
FOR AGENCY USE
Narrative: and non - acidic .ims.te[. aterg_ ani.storm ter
are collected separately. The acidic wastewater is neutralized
and combined with non -acidic wastewater for gravity c.larifica-
ation. Sludge is dewatered by beLt filter and landfilled on -
site. The combined wastewater is treated in an extended
aeration activated sludge system with sludge recycle from
secondary clarifiers.
Discharge fluantity is controlled auto-
matically depending on the minimum river flow by pumping excess
effluent to a 300 million gallon storage facility. Stored
effluent must return through the activated sludge system
to discharge.
(1) FS1PAR (2) F.SFGRF (3) ECOUNT
(4) EOTHFR (5) hFCOVF (6) OMON1 T
(7) PEQUAL (8) FSCREE (9) PSEDIt4
00) CNEUTR (J1) CFHADJ (1•,) BACTTV
(13) BPOLTS (1a) SLANDO II,) SOTHER
(16) MPOSTA (in MOTHEN (18)
(19) (20) , (21)
(22) (23) (24)
(25)
Cppr.
prior
11-4

DISCHARGE SERIAL NUMBER
001
16. Wastewater Characteristics
FOR AGENCY USE
Check the box beside each constituent which is present in the effluent (discharge water). This determination Is to be based on actual analysis
or best estimate.(see instructions)
Parameter
216
y
4,
Parameter
.2164.,
Present
Color
00080
X
Copper
01042
Ammonia
00610
X
Iron
01045
X
Organic nitrogen
00605
X
Lead
01051
Nitrate
00620
X
Magnesium
00927
X
Nitrite
00615
X
Manganese
01055
X
Phosphorus
00665
X
Mercury
71900
X
Sulfate
00945
X
Molybdenum
01062
X
Sulfide
00745
Nickel
01067
Sulfite
00740
Selenium
01147
Bromide
71870
X
Silver
01077
Chloride
00940
X
Potassium
00937
X
Cyanide
00720
Sodium
00929
X
Fluoride
00951
X
Thallium
01059
Aluminum
01105
X
Titanium
01152
Antimony
01097
Tin
01102
Arsenic
01002
Zinc
01092
Beryllium
01012
Algicides*
74051
Barium
010(17
Chlorinated organic compounds*
74052
X
Boron
01022
Pesticides*
74053
Cadmium
01027
X
Oil and grease
00550
X
Calcium
00916
X
Phenols .
32730
Cobalt
01037
Surfactants f
47
38260 �OF
X
Chromium
01034
Chlorine Jul 0
50060 r
�£NTR
Fecal coliform bacteria
74055
X
Radioactivity* 1. 9?
74050 A( Par p„
*Specify substances, compounds and/or elements in Item 26.
,Y.
Pesticides (insecticides, fungicides, and rodenticides) must be reported in terms of the acceptable common
narnes specified in Acceptable Common Names and Chemical Names for the Ingredient Statement on
Pesticide Labels, 2nd Edition, Environmental Protection Agency, Washington, D.C. 20250, June 1972, as
required by Subsection 162.7(b) of the Regulations for the Enforcement of the Federal Insecticide,
Fungicide, and Rodenticide Act.
II-5

DISCHARGE SERIAL NUMBER
17. Description of Intake and Dhcharge
FOR AGENCY USE
- .;
For each of the parameters listed below, enter In the appropriate box the value or code letter answer called for.(see Instructions)
In addition, enter the parameter name and code and all required values for any of the following parameters If they were checked in Item 16;
ammonia. cyanide, aluminum, arsenic, beryllium, cadmium, chromium, copper, lead, mercury. nickel, selenium, zinc, phenols, oil and grease.
and chlorine (residual).
IInfluent
Paramet r and Code
•
Effluent
Untreated Intake
Water
(Daily Average)
In -Plant Treated
Intake Water
• (Daily Average)
w Daily Average
Minimum Value
, Observed or
Expected During
Discharge
Activity
•
Maximum Value
N Observed or
Expected During
Discharge Activity
Frequency of
-• Analysis
,. Number of
Analyse;
Sample Type
Flow*
Gallons per day
00056
pH
Units
00400
.
Temperature (winter)
°F
74028
.
Temperature (summer)
°F
74027
•
Biochemical Oxygen Demand
(BOD 5-day)
mg/1
00310
-
Chemical Oxygen Demand (COD)
mg/1
00340
.
.
Total Suspended (nonfilterable)
Solids
mg/1
00530
Specific Conductance
micromhos/cm at 25° C
00095
Settleable Matter (residue)
ml/1
00545
*Other discharges sharing intake flow (serial numbers).(see instructions)
H-6

DISCHARGE SERIAL NUMBER
001
17. Description of Intake and Discharge
For each of the parameters listed below, enter In the appropriate box the value or code letter answer called for.(see instructions)
In addition, enter the parameter name and code and all required values for any of the following parameters If they were checked In Item 16;
ammonia, cyanide. aluminum, arsenic, beryllium, Cadmium, chromium, Copper, lead, mercury, nickel, selenium, zinc, phenols, OII and grease,
and chlorine (residual). Equalized Feed
i
FOR AGENCY USE
1
Parameter and Code
217a
Influent
Effluent
Untrea take
cr
(Daily Average)
In -Plant Treated
N Intake Water
(Daily Average)
u
bo
ii
AA
(3)
Minimum Value
Observed or
Expected During
Discharge
Activity
Maximum Value
—, Observed or
Expected During
Discharge Activity
Frequency of
v+ Analysis
Number of
Analyses
Sample Type
Flow'
Gallons per day
00056
—
—
1.5
0.5
4.6
CONT.
365
—
pH
Units
00400
6.0-9.3
—
6.5
8.0
CONT.
365
—
Temperature (winter)
°F
74028
—
—
43
37
50
7/7
365
G
Temperature (summer)
'F
74027
—
—
77
72
84
7/7
365
G
Biochemical Oxygen Demand
(BOD 5-day)
mg/1
00310
513
—
6
6
1
38
5/7
26C24#
Chemical Oxygen Demand (COD)
mg/1
00340
890
—
90
27
258
1/7
5224#
Total Suspended tnonfilterable)
Solids
mg/1
00530
38
—
10
1
40
7/7
365
24#
Specific Conductance
micromhos/cm at 25° C
00095
,-•
3000
7000
1/30
12
2441
Settleable Matter (residue)
ml/1
00545
—.
—
<.1
<. 1
< . 1
7/7
365
G
'Other discharges sharing intake flow (serial numbers).(see instructions)
,iO4; ctlifeh
;27 7o
Cc* R41 f)zECv97
flpr

DISCHARGJ RIAL NUMBER
17. (Cont'd.)
Equalized Feed
FOR AGENCY USE
Parameter and Code
2r4
Influent
Effluent
_ Unit make
Cr
tl),uly Average)
In-PI,in: Treated
E-; Intake water
(Daily Average)
w Daily Average
Mininwm Value
Observed or
Fxpcctcd During
Discharge
Activity
Maximum Value
Observed or
Expected During
Discharge Activity
o+
Frequency of
Analysis
Number of
Analysis
i=
v
(8)
-
-
6.9
0.1
25.3
5/7
260
244
Anmunia NH3-N, mg/1
Phenol, mg/1
—
-
0.12
0.03
0.30
2/30
23
G
Aluminum, mg/1
-
-
0.6
0.6
0.6
1
24w
Cadmium, mg/1
-
-
0.010
0.010
0.010
1
240
Mercury, ma/1
-
-
0.0017
0.0017
0.0017
1
24*
Chromium, Copper, Nickel, and Zinc may be present in trace quantities in treatment
system in€luent.
1 B. Plant Controls Check If the fol-
lowing plant controls are available
for •1is discharge.
Alternate power source for major
pumping facility.
Alarm or emergency procedure for
power or equipment failure
Complete item 19 if discharge is
from cooling ano/or steam water
generation and water treatment
additives are used.
19. Water Treatment Additives If the
discharge is treated with any con-
ditioner, inhibitor. or atgicide,
answer the following:
a. Name of Material(s)
b. Name and address of manu-
facturer
c. Quantity (pounds added per
minion ga!Ions of water treated).
211
219.4
21$b
:lie
APS
ALM
Polymer as a clarification aid
Various
5
l'‘10•;tivED
z, 1907
N - 4 Fat. Copy.
I1-7

DISCHARGE SERIAL NUMBER
001
FOR AGENCY USE
d. Chemical composition of these
additives (see Instructions).
,:l 0Q
Complete items 20-25 If there is a thermal discharge
(e.g., associated with a steam and/or power generation
plant, steel mill, petroleum refinery, or any other
manufacturing process) and the total discharge flow is
10 million gallons per day or more. (see instructions)
20. Thermal Discharge Source Check
the appropriate Item(s) indicating
the source of the discharge. (see
instructions)
Boiler Blowdown
Boiler Chemical Cleaning
Ash Pond Overflow
Boiler Water Treatment — Evapora-
tor Blowdown
Oil or Coal Fired Plants — Effluent
from Alr Pollution Control Devices
Condense Cooling Water
Cooling Tower Blowdown
Manufacturing Process
Other
21. Discharge/Receiving Water Temper-
ature Difference
Give the maximum temperature
difference between the discharge
and receiving waters for summer
and winter operating conditions.
Summer (see instructions)
Winter
22. Discharge Temperature, Rate of
Change Per Hour
Give the maximum possible rate of
temperature change per hour of
discharge under operating con-
ditions. (see instructions)
23. Water Temperature, Percentile
Report (Frequency of Occurrence)
In the table below, enter the
temperature which Is exceeded 10%
of the year, 5% of the year, 1% of
the year and not at all (maximum
yearly temperature). (see instructions)
Frequency of occurrence
a. Intake Water Temperature
(Subject to natural changes)
b. Discharge Water Temperature
24. Water Intake Velocity
(see Instructions)
2S. Retention Time Give the length of
time, In minutes, from start of
water temperature rise to discharge
of cooling water. (see instructions)
220
221a
221b
222
223s
223e:
224
223
Primarily Cationic Polymer
N/A
❑ BLBD
❑ BCCL
❑APOF
❑ EPBD
❑OCFP
❑ COND
❑ CTBD
❑ MFPR
❑ OTH R
N/A
of
N/A of/hour
N/A
10%
5%
1%
Maximum
of
of
of
of
of
of
of
of
N/A feet/sec.
N/A minutes
£NTRRZ par 9gT
Copy.
II-8

DISCHARGE SERIAL_ NUMBER
FOR AGENCY USE
26. Additional Information
226
001
Item
Information
3
Modification of the wastewater treatment facility is required under
RCRA. A Basis of Design Report for these modifications developed by
Engineering -Science of Atlanta is available from William M. Archer,
Environmental Manager, Sandoz Chemicals Corp., Mount Holly Plant,
P.O. Box 669246, Charlotte, N.C. 28266. Drawings and specifications
will be submitted in the near future for a permit to construct from D
15
Sandoz requests that the renewed permit limits be based on the minimu
daily average river flow of 329 cfs as is the current permit.
16
No chlorinated organic priority pollutants were detected in therecen
analysis (see attached results). Test results preceded by less than
(<.) symbol represent parameter detection limit. Low ppb levels of
o-dichlorobenzene have been detected in past sampling.
ilk
til
COPY_
11-9

CONFIDENTIAL ANSWERS
The following information is Confidential Business information:
Item No. 214b (3) on Page II-3. 12

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R — /�9

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
William W. Cobey, Jr., Secretary
January 26, 1989 •
Mr. W. M. Archer, Manager
Environmental Services
Sandoz Chemical Corporation
P. 0. Box 669246
Charlotte, North Carolina 28266
Subject: Request for Alternative "Total Phenols" Method
Dear Mr. Archer:
R. Paul Wilms
Director
The Water Quality staff and Laboratory Section of the Division of
Environmental Management reviewed your request to use the GC/MS
Analysis for individual phenols as an alternative to the "Total
Phenols" colorimetric procedure for NPDES compliance monitoring.
Based upon their review and recommendations, I am authorizing you to
use the requested GC/MS procedure in accordance with acceptable EPA
methodology with the following conditions:
1. The total phenols analyzed shall include the eleven
priority pollutant phenols and all other "identifiable"
phenols in each sample.
2. Identifiable shall be defined as a spectra with a "fit of
greater than 700" or greater than 70% match in a given
sample.
3. The detection limit of the eleven priority pollutant
phenols shall be reported for each nondetected phenol.
4. The total phenols reported, as an NPDES requirement, shall
be the sum of the concentrations for each of the eleven
priority pollutant phenols and the identifiable phenols
detected, plus the sum of the detection limits for the
nondetected phenols.
P.O Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

Mr. W. M. Archer
January 26, 1989
Page Two
If you have any questions concerning this approval, please contact
Bob DeWeese of the Raleigh Central Office at 919/733-5j83.
Sincer
R. Paul Wilms
RPW:BDW/am
cc: Chuck Wakild
Dennis Ramsey
W. B. Edwards

Biitz!kr.11DIOZCHEMICALS
MEMO
CORPORATM
MMV I MOMMENTAL.. SERV I CE8
PRODI.JCT 8AFETY DEPARTMEt4T
TO: Paige Straley cc: Ray Mockridge, Mike Smith
FROM: Bill Archer
DATE: January 17, 1989
SUBJECT: NPDES Permit Renewal
Attached is the proposed permit that has been drafted and sent to
the State for discussion purposes. This is the best we can hope
for. Realistically, we can expect a pass/fail Bioassay limit, at
1.87. effluent concentration, a sulfate limit of 150,000 - 250,000
lbs/day, a manganese limit and a mercury limit included in the
permit, in addition to all the priority pollutant organics. We
also will get a COD limit if we accept Bldg. 45's waste.
There is some incentive to obtain a permit quickly before new
water quality standards are adopted. As we have discussed we
should begin gathering data on current treatment system
effectiveness for these new parameters to determine where we
stand and what system improvements might be needed.

J,cL
a
SANDOZCHEMICALS
Mallard Creek Research Center
P.O. Box 669304
Charlotte. North Carolina 28266
704.547.0632
Telefax : 704.547.5588
j anuar'•r 17, 15a ;'
Mr. Dale Overcash
North Carolina Department
Resources and Community
Division of Environmental
Post Office Box 27687
Raleigh, NC 27611
Re: b
of Natural
Development
Management
Sandoz Chemicals Corporation
Proposed NPDES Permit Renewal
NC 0004 375
Dear Mr. Overcash:
Environmental Services
and
Product Safety Department
2304 W.T. Harris Boulevard
Charlotte, Nortic Carolina 28213
r
Sandoz has developed the enclosed proposed NPDES permit
limitations for your review. At the present time, we stil._1__..wish__
r, t-;ur,7svp_fihe FpF vari,ance.s-_for which ch we have filed.; hoe'r, er We
think it- would be beneficial to both parties to proceed with
permit development. This 'letter describes the derivation of
proposed limits based on BPTJBAT concentrations and Best
Professional Judgment (BPJ) for discussion purposes only. Limits
based on proposed FDF winter concentrations are also provided.
Please consider this letter confidential as it contains
production information that is company confidential.
The oo_taL 1 w used as the basis for developing the flow based
limits is 2.44 MGD. This represents a somewhat 2.-saj,ggaiL
pros ect.ion of wastewater fliitraim that ,l i tRd 10. the permit
renewal application, the result of added production capacity and
demand. A breakdown of this flow is as follows:
1. Process wastewater (organic chemicals) 1.85MGD
2. Sanitary wastewater
3. Contaminated groundwater
0_O6MGD
. t .33MGD
4. Storm water runoff 0.2OMF fi
Process flow is entitled to mass limitations based on specialty
organic chemicals categorical limitations. The flows listed in
2, 3 and 4 are eligible for additional mass limitations based on

Mr. Dale Ove rc a s h
January 17, 1989
Page two
best professional judgment of the permit writer. Since the storm
water collected around the production facility and the
contaminated groundwater withdrawn for treatment will contain
many of the same constituents as the process wastewater and will
be subjected to the same treatment processes, the BPJ limits
appropriate for these flows should in most instances be
equivalent to the OCPSF limitations. One exception to this is in
the case of four (4) phenolic compounds limited under non-FDF
BAT.
Phenol and 2, 4--dinitrophenol wastes (which also contains 2-nitro
and 4-nitrophenol) are pretreated in the production plants before
they are discharged to the plant sewer. The noun a
surface runoff would not be pretreated for phenolics in this
manner, /Since BAT limits are based on a combination of in -plant
treatment followed by end -of -pipe biological treatment (see
Federal Register Volume 52 - pages 42538 - 42539), the non -
process wastewaters that are not pretreated by in -plant treatment
can justifiably be given higher than OCPSF BAT limits using best
professional judgment./Using an estimated minimum pretreatment
efficiency of 957. for phenol and 707. for nitrophenols, a BPJ
value has been derived by adjusting the BAT concentrations to
account for the lack of pretreatment and applying that
concentration to the 0.53 MGD stormwater and groundwater flow.
The final effluent limit is the sum of the BPJ number and the
straight BAT ai Iowanr:e for the process flow. Additional specific
limits and rationale are provided later in this letter.
The following flows are considered non -contaminated, non -process
and do not apply toward mass calculations.
Non contact cooling - 0.1MGD
Boiler blowdown & condensate - 0.1MGD
Water filter backwash - 0.3MGD
In addition' to organic chemical manufacturing, the plant also
produces the herbicide Norflurazon. Our renewal application
listed production at 8,000.pounds per day. A planned expansion
in mid 1989 will i.nr re sQ the ,L2,OOQ pounds per day. This
operation represents a small part of the overall plant production
and less than five (5) percent of the plants process wastewater.
BPT limits for pesticide manufacturing based can production of

Mr. Dale Overcash
January 17, 1989
Page three
Y
ke-v' Cyr -
att.. ,S
12,000 pounds per day are as 1 ui lows:
Daily Maximum 7,0 Day Average
COD 156 108
BOD 88.8 19.2
TSS 73.2 21.6
Organic Pesticide Chemicals - This limitation is not
applicable to-Norflurazon manufacturing.
Sandoz proposes applying these pesticide limitations in the
following way. Since the organic chemical manufacturin• cate•or
has no COD limits, an• e pes icl•e contribution to the overall
`plant production is small, COD should not be a limited rarameter.
This is consistent with 15-NCAC 28.0406(1) (a) which does not
require application of industrial limitations to municipal wastes
when the industrial waste accounts for less. than 10% of the total
flow. We propose monitoring COD weekly. The BOD and TSS masses
allowed should be added to BOD and TSS limits calculated from
non -pesticide process flows. While Norflurazon is not regulated
as an organic pesticide chemical under 40 CFR 455, we are
proposing periodic monitoring of our effluent for the Norflurazon
Compound.
The following is a parameter by parameter discussion of our
proposed permit limits.
Flow - No change is proposed from the existing permit.
BOD5 - This is calculated as:
Non-FDF . FDF
lb/day lb/day
avq max avq max
Process flow (1.85 MGD @BPT conc) = 694✓ 1851 926 2777
�.� 0 /4 '
Sanitary waste @30/45 limits = 15 23 15 2
BPJ for stormwater and grdw ter = 199•✓ 57.0 265 796
Pesticide limits = 19 ✓ 89 ✓ 19 89
TOTAL BOD 927 2493 1225 3685

J
i
Mr. Dale Overcash
January 17, 1989
Page four
TSS - Since the TSS calculated by using the process flow is
higher than the limit in the existing permit, we propose the
existing limits continue.
NHL YN" -- We propose converting the concentration limit of 20 mg/1
• to mass limits using a flow of 2.8 MGD for an average limit and a
flow of 3.9 MGD for a maximum limit.
Fecal Coliform - We propose measuring for fecal coliform in the
,,'secondary clarifier effluent. Samples taken downstream of this
point can be influenced by Canada geese and other wildlife in the
area.
total Phenols - No change in the limit is proposed; however, we
do propose a change in the analytical method. It has been our
experience that the total phenols calorimetric test is subject to
interferences. We propose substituting the sum of the taste and
odor causing priority pollutant phenols (calculated as phenol)
for the calorimetric total phenols test.
MBAS, Mercury, Sulfate, and Manganese - All four (4) of these
compounds were detected in the effluent analysis performed for
the renewal application. Assuming a maximum effluent flow of 3.9
MGD and a minimum daily average river flow (of 329 CFS1, the
concentrations of these four (4) compounds sWnuld represent the
following percent (/) of the water quality ° standard in the river:
MBAS - 6.9%.
Mercury - 15.5/.
Sulfate - 24.67.
Manganese . 17.6%
Since the ML38E. value is less than 10%. it is not included in the
proposed permit. Since mercury, sulfate and manganese values are
all less than 25% and actual average effluent flow will be well
below 3.9 MGD, we .pr_o.pose_.a._._mon l tQi jag_r w i remeni_._nrz.l_}�_ f-_or these
parameters.
Chronic Bioassay - We propose that the chronic bioassay test be
run at 1.8% dilution (3.9 MGD effluent flows 329 river flow) as a
screening tool quarterly. If the test is failed for two (2)
quarters a third sample will be taken within 30 days. If this
sample also fails the test then an in -stream benthic study,
similar to that conducted at the plant in 1986 by DEM Water
Quality Section, will be performed to determine if the aquatic
life is being impacted by the discharge. If so, additional
toxicity reduction studies will be conducted. We have not
developed any specific language at this time to accomplish this.

Mr. Dale Overcash
January 17, 1989
Page five
Other options may be available, such as using a 1% dilution
factor for the test combined with a permit condition that
effluent be restricted to no more than 1% of the river flow based
on a moving average.
BAT Limits - These are calculated in the following manner as
described previously:
For _p_heno__1_,__. _nitr_ophenjzl_s 4- itrQphenoi and
^2,_24-dinitrophenol,-
Non-•FDF :
(1.85 MGD x BAT Conc. x 8.34) + (0.53 MGD x (BAT Conc./P) x
8.34) where P=.05 for phenol, .3 for nitrophenols
FDF:
lff
I� .
8 --'MGD x FDF Conc. x 8.34
For all other compounds -
(1.85 MGD + 0.53 MGD) x BAT x 8.34
In addition to proposing final permit limitations, we are also
proposing upstream and downstream sampling that is uniform year
round. Other parts of the permit such as staging requirements
and priority pollutant testing are not specifically addressed in
our proposal at this time. We do as - that upnt and_bAss
proyi.s ons as described _in .4OCFR122.43 hR included in the permit,
As mentioned earlier, some production and flow conditions have
changed somewhat since our renewal application was initially
submitted. We wi t revised e I i ati n in
the near future to reflect these changes.
Sandoz anticipates that new permit conditions will require some
modification to our existing treatment system. We wish to
discuss with the Division, various mechanisms and schedules for
completing any modifications necessitated by new permit
limitations while not exposing the company to fines and
penalties.

Mr. Dale Overcash
January 17, 1989
Page six
We look forward to hearing from you after you have reviewed this
information. We will be happy to meet with you at the plant site
or in Raleigh to further discuss and develop this permit. Please
contact me at (704)547-56O1 if you have any questions.
Sincerely,
• /1
/3 / r
j
/ • ��i� '0 ia-
William M. Archer
Environmental Manager

EFFLUENT
CHARACTERISTICS
✓Flow
vh`+O D 5
.,k.Total Suspended
,vi=t 6 7 NH3 as N
,,Dissolved Oxygen
v►'QlFecal Coliform
d. k:
Total Phosphorus
LvTota1 Nitrogen
(TKN -+- NO2 -+- NO3)
DISCHARGE LIMITATIONS
Lbs/Day Other Units
;Daily Avg:Daily Max ; Daily Avg ;
;927(1225);2493(3685);
Solids; 976 ; 2928
467 : 651
-Norflurazon
1
Total Phenols
Sulfate
Manganese
temperature
Lu dxc Chronic Bioassay*
7 COD 1 ..2 et-i•‘.c:
Priority Pollutants
v,pH
1.8 ;
3.9 MGD
,
5.0 mg/1
; 1000/100
,
* The ceriodaphnia chronic bioassay will be used as
The test will be run in a 1.8% effluent sample.
C = Secondary clarifier effluent
BOD number in ( ) is FDF winter limit
MONITORING REQUIREMENTS
Sample
Daily Max Frequency Type ;Location:
,
;ContinuouslRecording
5.0 mg/1
;Daily
;Daily
Weekly
;Daily
ml ; 2000/100 ml ;Monthly
;
111
Monthly
Monthly
Monthly
;Monthly
;Monthly
;Composite
;Composite
;Composite
;Grab
Grab
;Composite
;Composite
;Grab
;Grab
Composite
Quarterly :Composite
':Daily
;Quarterly
;Weekly
;Annually
0 >6, <9 ;Daily
a screening test.
Grab
Composite
;Composite
:Grab?
Grab
I or E ;
E
E
E
, E
' E
E
E
' E E ,

A. () . CATAVBA RIVER MONITORING REQUIREMENTS
'4
•
NPDES No. NC0004375
During the period beginning on the effective date of the Permit and lastin until
Permittee shall monitored the river as specified below: g expiration the
•
Effluent Characteristics
Monitoring Requ:iremeb is
Measurement Sample
Frequency Type
Upstream
Hwy 27
i3GD5 2/month Grab -I-
NH3 as N 2/month Grab + +
Dissolved Oxygen 2/month Grab + +
pH 2/month+
Conductivity Grab +
2/2/monthGrab + + Temperature + Grab +
Sample Locations ;a;
At or
Near 1-85
M 3
* + Denotes monitoring required at specified locations.
p (i:: I,G,, r�

Effluent
characteristics
Effluent Emitations
BAT (lb/M1ay)
Maximum
Maximum -- � for
one d.ay -average
Acenaphtheoe .1. 1 7 O. 44
• 4.8 1.9!
Benzene 2. 7 ' 73
Carbon Tetrachloride... t) . 75 0 . 36
ChIocoben2 ene ..__.__..__ O. 56 i ) . 3
1,2,4-
T .._._ 2 .' 78 . 35
1-1-exachlorobenzene.___.. 0. . 56 c i
1,2-Did*xDethane ...__. 4. 1;' 1. 35
1,1,1-Trichloroethane .. 1 . 07 0.42
Hexachlcroethane 1.0 ! 0. 42
1,2 thane 1. 17 O. 44
1,1,1-Trichloroe thane 1. 07 O.42
Chlon:ethane J 32 2 06
Chloroform 0.91 0. 42
21 1. 95 0. 6 2
1,2-Dichbrobenzene... _ . 2 4 1.
1,3-Dichlorobertzene} . 87 c . 6i
1,4-Dicklorobenzene... c). 56 c). •_
1,1-Dichlor oettry4ene0.5 0 .
1,2-b-a.ns-
Dichloroethylene 1. 07 O. 42
2, 4-Dichlorophenol 2.22 0. 77
1,2-Dichloropropane ..-4.5 7 3.04
1,3-
Dichloropropylene 0.87 O.58
2,4-Dimethyiphenol 0. 71 0 . 36
2,4-Di nitrotoluene 5.6 6 2.24
2,6-Dinibotoluene 12. 72 5.06
Ethyibenzene 2.14 O.64
Fluoranthene 1. 35 0. 5
Bis(2-
Cblorotsopropyf)
ether 1 5. 07 J. 9%
Methylene Chloride 1. 77 O. . 79
Methyl Chloride 3. 77 1. 71
Hexachlorobutadiene0 . z 7 O. 4
N a.ph thaiene 1. 17 0.4 4
Nitrobenzene // 1. 5 � u 5 4
2-Nitrophenol '2.08(2.74} ✓1.23(1.63)--
4-,N itrophenol i. . 7 4 (4.9 ) $ . 17 (2.8 6 )
2,4-Dinitrophenol . 71(4.88) //2. 15 (2.82 )
4,6-Din'rtro-o-cresol 5 . 1. 5
Phenol 2 . 7 i (1, 5.�) 1 .5f (0.89 )
Bis(2-ethyihexyi) , r t�� ✓ G
phthalate 5. 54 .7.
Di-n-butyl phthalate 1 . 1 = 0.54
Diethyl phthalate 4.03 1. 61
Dime thy' phthalate O. 9377.R
Benzo(a)anthracene .. 17 O. 44 /
Benzo(a)pyrene 1.21 O.46
Numbers in () are FDF winter limits

Effluent
characteristics
Effluent limitations .
BAT . (Jb/do.y).
Maximum Maximum
for
for -any monthly
one day average
3,4•
-
Benzofluoranthene
Benzo(k)fluoranthene
Chrysene
Acena,phthylene
Anthracene
Fluorene
Phenanthrene
Py: ane ...«.....
Tetrachloroethyiene
Toluene ..�
Trichloroene
Vinyl Chloride
Total Cyanide
1.21
1.17
1.17
1.17
1.17
1.17
1.17
1.11
1.59
1.07
23.82
0.4c
0.44
O. 44
0. 44
O. 44
0. 44
O. 44
0.5
0. 44
O. 52
O. 42
^. 06
e.34.
7
Sampling Frequency Mono thly_for Phenolics, Annually for All Other Compounds
,/Sample Type - Grab

SANDOZCHEMICALS
Sandoz Chemicals Corporation
P.O. Box 669246
Charlotte, North Carolina 28266
704.827.9651
Telex 810.649.2224
Mr. Dennis Ramsey
Asst. Chief for Operations
Div. of Environmental Management - Water Quality Section
512 N. Salisbury, St., P. 0. Box 27687
Raleigh, North Carolina 27611
Re: Sandoz Chemicals Corporation, Mount Holly Plant
NC 0004375
Dear Mr. Ramsey:
As I discussed with you and Mr. W. B. Edwards of the
Division a few weeks ago, Sandoz has reason to believe that the
standard method procedure used for analyzing phenols in the Mount
Holly Plant's effluent is subject to positive interferences from
non -phenolic compounds. We have completed a two week study that
demonstrates this. By way of this letter and attached
information, Sandoz hereby requests DEM's permission to utilize
the sum of GC/MS analyses for individual priority pollutant •
phenols in place of the nonspecific "total phenols" colorimetric
procedure for its NPDES compliance monitoring.
The current total phenols procedure is based on a reaction
between 4-aminoantipyrine and most common phenolic compounds to
create a red compound that is measured by spectrophotometer. The
procedure does not detect certain para-substituted phenols and is
subject to both positive and negative interferences. It has been
our experience at the Mount Holly Plant that this total phenols
colorimetric test often significantly overstates the actual level
of phenolic compounds in the treatment plant effluent.
We understand that a facility located in Western North
Carolina had similar difficulty and has been allowed to change
analytical procedures to analyze for specific phenols. In
discussing possible alternative methods with Mr. W. B. Edwards of
the Division, he indicated that a GC or GC/MS procedure for
individual phenols would be technically appropriate provided that
the method detection limits are low enough such that the total of
the individual limits are not significantly greater than the
colorimetric method detection limit.
Sandoz performed a two week study to compare colorimetric
phenol results with GC/MS results, and to determine what
detection limits could be achieved. The study was conducted as
follows. Each weekday morning for two weeks an effluent grab
sample was collected, preserved and transported to the onsite
Sandoz laboratory. The sample was split into four_ 50 0 ml

2
portions. All four portions were distilled as specified in EPA
standard method 510. Two portions were analyzed by the
4-aminoantipyrine method. The other two 500 ml portions were
combined and shipped on ice to General Engineering Labs in
Charleston, S. C. for GC/MS analysis. General Engineering
extracted the samples with methylene chloride under acid
conditions and concentrated the extract. All parameters on the
first seven samples were analyzed by capillary GC/MS except for
dinitrophenol and dinitromethylphenol. A derivatization and
capillary GC/ECD method was used for these two compounds to
achieve lower detection limits. GC/MS was used for all compounds
on the last three samples. GC/MS detection limits were reduced
on the last three samples by increased extract concentration and
by increased injection columns.
You will notice that the 2,4 DNP, 2 and 4 nitrophenol, and
phenol increase on October 26 through 28. We experienced a spill
in the manufacturing area and so did see actual phenol at the
wastewater treatment plant. Due to our controlled discharge
system, Sandoz did not violate our NPDES permit. However, we
view this incident as being a positive control in the data set.
It illustrates that in spite of any matrix effects, actionable
levels of priority pollutant phenols are detected by GC/MS in
agreement with the standard method.
There are two other trends in the data which are useful to
review. First, note that the difference between the standard
method determination and the GC/MS determination is marked. This
trend is even more pronounced when 2-methyl-4,6-dinitrophenol,
2,4-dimethylphenol, 2,4-dinitrophenol, and 4-nitrophenol are
subtracted from GC/MS total. These compounds are not detected by
the standard method technique. We suggest that this difference
represents a positively interfering substance in the organic
matrix which distills over in the standard method procedure.
The second trend is merely to point out that the standard
method determination tends to overstate (S.M./G.C. = overstate-
ment factor) the total phenols concentrations. When the
para-substituted phenols are subtracted, the overstatement is
more severe. Please see the accompanying data table for detail.
Based on the study, Sandoz believes that total phenols as
analyzed by GC/MS are a more appropriate measure of the level of
taste and odor causing phenols in the Mount Holly effluent than
colorimetric phenols. Not only is the GC/MS method free of
positive and negative interferences, but it also measures those
para-substituted phenols that are not measured by the
colorimetric method. Sandoz requests DEM's permission to measure
total phenols by analyzing the method 510 distillate by
extraction and capillary column GC/MS. The total phenols
reported on the monthly monitoring report would then be the sum
of the concentrations for each of the detected eleven priority
pollutant phenols, plus the sum of the detection limits for
non -detected phenols.

3
We would greatly appreciate your prompt attention to our
request. Please contact me if you have any questions.
Sincerely yours,
o‘
W. M. Archer, Manager
Environmental Services
WMA:aj
Attachments
cc: W. B. Edwards
Rex Gleason

GENERAL ENGINEERING LABORATORIES
Environmental Engineering and Analytical Services
Molly F. Greene
President
George C. Greene. P.E.. Ph.D.
Vice President
SC Registration No. 9103
CERTIFICATE OF ANALYSIS
Laboratory Certifications:
FL E87156/87294
NC 233
SC 10120
VA 00151
NACIP Approved
Client: SANDOZ CHEMICALS CORPORATION
HIGHWAY 27. WEST
CHARLOTTE , NC 28214
Contact: MR. PAIGE STRALEY
cc/ic: SI'IDC/PP4
Released b
Parameter
Sample ID : SEPT001 SEPTOO2 PPT003
10/17/88 10/18/88 1 0/1 9/R8
Lab ID : 88100978 88100979 88100980
Sample Type : 12 12 12
Date Received: 10/20/88 10/20/88 10/20/88
Collected by : SNDC SNDC SNDC
CRAI,
Page No.: 1
PP Acid Ext. by Method 8270
CHLOROPHENOL (2) <5 ppb <5 ppb <5 ppb
DICHLOROPHENOL (2,4) <5 ppb <5 ppb <5 ppb
DINITROPHENOL(2-METHYL-4,6) 19 ppb 7 ppb 5 ppb
DIMETHYLPHENOL (2,4) <5 ppb <5 ppb <5 oob
DINITROPHENOL (2,4) 124 ppb 26 ppb 8 ppb
NITROPHENOL (2) <5 ppb <5 ppb 6 pob
NITROPHENOL (4) <5 ppb <5 ppb <5 ppb
P-CHLORO-M-CRESOL 12 ppb 13 ppb 14 ppb
PENTACHLOROPHENOL <5 ppb <5 pob <5 ppb
PHENOL <5 ppb <5 ppb <5 ppb
TRICHLOROPHENOL (2,4,6) <5 ppb <5 ppb 11 ppb
SAMPLE PREP - ACID COMPOUNDS YES YES YES
2040 Savage Road • Charleston, SC 29414 / P. O. Box 30712 • Charleston, SC 29417
Phone [phone] • FAX [phone]

GENERAL ENGINEERING LABORATORIES
Environmental Engineering and Analytical Services
Molly F. Greene
President
George C. Greene, P.E., Ph.D.
Vice President
SC Registration No. 9103
CERTIFICATE OF ANALYSIS
Laboratory Certifications:
FL E87156/87294
NC 233
SC 10120
VA 00151
NACIP Approved
Client: SANDOZ CHEMICALS CORPORATION
HIGHWAY 27 WEST
CHARLOTTE
Contact: MR. PAIGE STRALEY
cc/fc: SNDC/PP4
Parameter
Sample ID
, NC 28214
: SEPTO04
10/20/88
Lab I D
Sample Type :
Date Received:
Collected by :
88101222
12
10/26/88
SNDC
Released b
SEPT005 SEPT006 SEPT007
10/21/88 10/24/88 10/25/88
88101223 88101224 88101225
r
12 12 2
10/26/88 10/26/88 10/26/88
SNDC SNDC SNDC
PP Acid Ext. by Method 8270
CHLOROPHENOL (2)
DICHLOROPHENOL (214)
DINITROPHENOL(2-METHYL-4,6)
DIMETHYLPHENOL (2,4)
DINITROPHENOL (2,4)
NITROPHENOL (2)
NITROPHENOL (4)
P-CHLORO-M-CRESOL
PENTACHLOROPHENOL
PHENOL
TRICHLOROPHENOL (2,4,6)
SAMPLE PREP - ACID COMPOUNDS
<5 ppb <5 pob <5 ppb
<5 ppb <5 ppb <5 ppb
8 ppb 7 ppb 19 ppb
<5 ppb <5 ppb <5 ppb
19 ppb 18 ppb 30 Grob
<5 ppb <5 pob <5 ppb
<5 ppb <5 pob <5 ppb
<5 ppb <5 ppb <5 ppb
<5 ppb <5 ppb <5 ppb
<5 ppb <5 ppb <5 prlb
<5 ppb <5 ppb <5 ppb
YES YES YES
<5 pob
<5 ppb
9 ppb
<5 ppb
10 ppb
<5 ppb
<5 pob.
<5 pet,
<5 ppb
<5 pob
<5 p p b
YES
2040 Savage Road • Charleston, SC 29414 / P. O. Box 30712 • Charleston, SC 29417
Phone [phone] • FAX [phone]

GENERAL ENGINEERING LABORATORIES
Environmental Engineering and Analytical Services
Molly F. Greene
President
George C. Greene, P.E., Ph.D.
Vice President
SC Registration No. 9103
CERTIFICATE OF ANALYSIS
Laboratory Certifications:
FL E87156/87294
NC 233
SC 10120
VA 00151
NACIP Approved
Client: S,ANDOZ CHEMICALS CORPORATION
HIGHWAY 27 WEST
CHARLOTTE , NC 28214
Contact: MR. PAIGE STRALEY Released b
cc/fc: SNDC/PP4
Parame ter
Sample ID : SEPT008 SEPT009 8 TO10
10/26/88 10/27/88 10/28/88
Lab ID : 88101473 88101474 88101475
Sample Type : 12 12 12
Date Received: 10/31/88 10/31/88 10/31/88
Collected by : SNDC SNDC SNDC
PP Acid Ext. by Method 8270
CHLOROPHENOL (2) <2.0 ppb <2.0 .ppb <2.0 ppb
DICHLOROPHENOL (2,4) 3.8 ppb 15 ppb 4.7 ppb
DINITROPHENOL(2-METHYL-4,6) <10 ppb <10 ppb <10 ppb
DIMETHYLPHENOL (2,4) 2.0 ppb <2.0 ppb <2.0 ppb
DINITROPHENOL (2,4) 830 ppb 2860 ppb 3510 ppb
NITROPHENOL (2) 37.2 ppb 97 ppb 51 ppb
NITROPHENOL (4) <10 ppb 16.6 ppb 8.0 oob
P-CHLORO-M-CRESOL <2.0 ppb <2.0 ppb <2.0 ppb
PENTACHLOROPHENOL <10 ppb <10 ppb <10 ppb
PHENOL 855 ppb 4130 ppb 5030 ppb
TRICHLOROPHENOL (2,4,6) <2.0 ppb <2.0 ppb 2.3 ppb
SAMPLE F'REP - ACID COMPOUNDS YES YES YES
2040 Savage Road • Charleston, SC 29414 / P. O. Box 30712 • Charleston, SC 29417
Phone [phone] • FAX [phone]

SANDOZ 'TOTAL PHENOLS' COMPARISON
NOV. 17,1988
TABLE I. SANDOZ 'TOTAL PHENOLS" COMPARISON
DATE: 17 18 19 20 21 24 25 26 27 28
STND. METHODS (ug/1): 0.20 0.17 0.27 0.26 0.41 0.30 0.245 1.915 7.35 8.57
GC/MS (ug/1): 0.195 0.086 0.074 0.072 0.070 0.940 0.064 1.764 7.147 8.630
STND METHODS LESS GC/MS (ug/1): 0.01 0.08 0.20 0.19 0.34 0.21 0.19 0.15 0.20 (0.06)
STND METHODS / GC/MS: 1.0 2.0 3.6 3.6 5.9 3.2 3.8 1.1 1.0 1.0
STND. METHODS (ug/1): 0.20 0.17 0.27 0.26 0.41 0.30 0.245 1.915 7.35 8.57
GC/MS* (ug/1): 0.042 0.043 0.051 0.035 0.035 0.035 0.035 0.912 4.258 5.100
STND METHODS / GC/MS* (ug/1): 4.8 4.0 5.3 7.4 11.7 8.6 7.0 2.1 1.7 1.7
GC/MS* = GC/MS LESS: 2-METHYL 4,6-DNP
2,4 DMP
2,4 DNP
4 NP

GENERAL ENGINEERING LABORATORIES
Environmental Engineering and Analytical Services
Molly F. Greene
President
George C. Greene, P.E., Ph.D.
Vice President
SC Registration No. 9103
November 16, 1988
Mr. Paige Straley
Sandoz Chemical Corporation
PO Box 669246
Charlotte, North Carolina 28266
Laboratory Certifications:
FL ES7156/87294
NC 233
SC 10120
VA 00151
NACIP Approved
Dear Mr. Straley:
Please find enclosed herewith the Certificates of Analysis for the ten Sandoz -
Charlotte samples that were analyzed by General Engineering Laboratories for low levels of
priority pollutant phenols.
Thesampleswere received in three separate batches. The first batch included three
samples that were identified as follows:
• SEPT001 - GEL 88100978
• SEPT002 - GEL 88100979
• SEPT003 - GEL 88100980
This batch of samples was analyzed for all of the priority pollutant phenols, excluding
dinitrophenol and methyl-dinitrophenol, using GC/MS EPA Method 8270. Dinitrophenol
and methyl-dinitrophenol were analyzed by Gas Chromatograph/Electron Capture Detector
after a derivitization procedure described in EPA Method 8040.
The second batch included four samples that were identified as follows:
• SEPT004 - GEL 88101222
• SEPT005 - GEL 88101223
• SEPT006 - GEL 88101224
• SEPT007 - GEL 88101225
This batch of samples was analyzed for all of the priority pollutant phenols, excluding
dinitrophenol and methyl-dinitrophenol, using GC/MS EPA Method 8270. Dinitrophenol
and methyl-dinitrophenol were analyzed by Gas Chromatograph/Electron Capture Detector
after a derivitization procedure described in EPA Method 8040.
After consideration that you need a cumulative priority pollutant phenol detection limit
of between 50 and 70 µg/L, and after numerous problems and interferences encountered in
the GC/ECD method, our GC/MS Group Leader refined the GC/MS method for analysis of
these compounds to give a cumulative detection limits of 54 p.g/L. The third batch of these
samples was analyzed using only a refined EPA Method 8270 (GC/MS). The second batch
included four samples that were identified as follows:
• SEPT008 - GEL 88101473
• SEPT009 - GEL 88101474
• SEPT0010 - GEL 88101475
2040 Savage Road • Charleston, SC 29414 / P. O. Box 30712 • Charleston, SC 29417
Phone [phone] • FAX [phone]

Surrogate spikes were added to Batches 1 and 3 only. The surrogate spike recoveries
are included in the raw data package...
All raw data from the GC/MS analyses, as well as the GC analyses, are included in
this package. Raw Quality Control data are also included in the package. The required
GC/MS tune reports are a part of this data package.
If you have any questions concerning these data or the methodologies, please do not
hesitate to call me. We look forward to working with you on future projects.
Very ly yo
4 /,
othy . 'Shields 1/'
ager o • pecial Projects
encl
fc:sndc111688
GENERAL ENGINEERING LABORATORIES
2040 Savage Road •Co1e3 SC ? / Charleston, SC 29417
Phn(80) SS68171 FAX [phone]

41- PRO
OCT 12 1988
MEMORANDUM
d i,a4 5 " ( �e�ioNj
UNITED STATES ENVIRONMEN 'AL PROTECTIONALL
AGENCY
WASHINGTON, O.C.�.2Q460
OFFI
0 C T 1 f 1988
OFFICE OF
IWATEFi
I
SUBJECT: Questions and Answers Regarding the OCPSF Effluent
Limitations Guidelines
FROM: James arirector
Off' of Water Enforcement and Permits (OWEP)
TO:
Regional Water Management Division Directors
NPDES State Directors
The final rule establishing effluent limitations guidelines,
pretreatment standards, and new source performance standards for
the organic chemicals, plastics, and synthetic fibers (OCPSF)
point source category (the "guideline") was promulgated on
November 5, 1987 and became effective on December 21, 1987.
There has been and will be increased concern over the
implementation schedules and permit requirements. The purpose of
this memorandum is to provide you a list of questions and answers
(Q's & A's, as attached) which are most frequently asked by
permit writers and permittees regarding the guideline. The areas
of concern which are covered by the Q's & A's are given below:
Question No.
1 - 3 Applicability of the Guideline
4 - 6 Calculation of Permit Limits
7, 8 Monitoring Requirements
9 - 11 Promulgation and Implementation
of the Guidelines
12 Disparity of Limitations between
Subparts I and J
13 Whole -effluent Toxicity Testing of
OCPSF Effluent
14 Metals in OCPSF Streams
15 - 18 Fundamentally Different Factors (FDF)
Variance Requests
By providing these answers, we hope many issues and
challenges will be eliminated before the permits are drafted.
OCT 2,1 1,88

2
If you have any questions or comments, please contact me or
James Gallup, Chief of the Technical Support Branch at
[phone].
Attachment

- QUESTIONS AND ANSWERS (Q'S & A'S) REGARDING
THE ORGANIC CHEMICALS, PLASTICS, AND SYNTHETIC
FIBERS (OCPSF) EFFLUENT LIMITATIONS GUIDELINES
QUESTIONS REGARDING THE APPLICABILITY OF THE GUIDELINE
Ouestion 1 - Do the OCPSF pretreatment requirements apply to
discharges from compounding and formulation
processes?
Answer:
No. The OCPSF pretreatment standards do not apply to
wastewater discharges from compounding and formulation processes.
However, if such wastes mix with regulated OCPSF wastewater prior
to treatment, the combined wastestream formula (CWF) would
allocate allowances for any unregulated wastestreams. In
circumstances where there are no regulated wastestreams present,
pollutants may be present in the discharge from formulation
processes in amounts that warrant control under local limits.
Ouestion 2 - Are auxiliary establishments primarily engaged in
performing support services such as research and
development activities exempt from the OCPSF
requirements?
Answer:
OCPSF facilities which engage in support service activities
such as research and development, pilot plant, technical
services, and laboratory bench scale operations are subject to
the OCPSF requirements if such operations are conducted in
conjunction with and related to existing OCPSF manufacturing
activities at the plant site [40 CFR 414.11(b)]. However, if the
auxiliary establishment is located at a physically separate site
from the OCPSF manufacturing facility, then the OCPSF
requirements would not be applicable as long as the product
manufactured at this auxiliary site is not sold. That is, the
sale of the product would make the auxiliarysite's operation a
commercial manufacturing facility subject to the OCPSF
regulations.

Qugstion 3
Answer:
At a facility where the primary production activity
is not regulated by the OCPSF pretreatment
requirements, would a wastestream resulting from
the production of small quantities of
intermittently produced specialty chemicals subject
the facility to the OCPSF pretreatment
requirements?
The OCPSF Pretreatment Regulations provide no exemption for
intermittently produced, small quantity production. In the event
that a facility's primary production activity is not regulated by
the OCPSF requirements but an auxiliary product, such as a
specialty chemical is manufactured which does fall under the
OCPSF requirements, and both wastestreams are mixed prior to
treatment, then the combined wastestream formula applies.
However, for facilities that combine regulated and nonregulated
wastestreams after treatment but prior to the monitoring point
(usually at the sewer connection to the public sanitary sewer), a
flow weighted average (FWA) or more stringent approach must be
used to adjust Categorical Pretreatment Standards. In the
preamble to the June 12, 1986 proposed rules (51 FR 21462), EPA
clarified when CWF and FWA must be used.
QUESTIONS REGARDING THE CALCULATION OF PERMIT LIMITS
Ouestion 4 - How is "process wastewater" defined in the
guideline?
Answer:
Process wastewater has been defined in 40 CFR 401.11(q) as
"any water which, during manufacturing or processing, comes into
direct contact with or results from the production or use of any
raw material, intermediate product, finished product, by-product,
or waste product." The Development Document for Effluent
Limitations Guidelines and Standards for the OCPSF Point Source
Category further describes, "OCPSF process wastewater discharges
are defined as discharges from all establishments or portions of
establishments that manufacture the products or product groups
listed in the applicability sections of the regulation and also
in Appendix III -A of this document, and are included within the
following ... SIC major groups: 2865, 2869, 2821, 2823, 2824..."
(p. 1I1-20). Please refer to Section V.A. (p. V-1) of the
Development Document for examples of process wastewater.
Noncontact cooling waters, utility wastewaters, general site
surface runoff, ground waters, and other nonprocess waters
generated on site are specifically excluded from the definition
of process wastewater discharges.

3
Ouestion 5 - What procedure will be followed for determining
permit limitations for plants which fall within
more than one of the guideline subcategories?
Answer:
For best practicable control technology currently available
(BPT) limits, a facility whose production activities fall within
two or more subcategories should follow a procedure pursuant to
Section VI.A.1 (p. 42533) of the preamble of the OCPSF
regulations. The preamble states, "[i]n applying the limitations
set forth in the regulation, the permit writer will use what is
essentially a building-block approach that takes into
consideration applicable subcategory characteristics and the
proportion of production quantities within each subcategory at
the plant. Production characteristics are reflected explicitly
in the plant's limitations through the use of this approach."
Section IX.E (p. IX-10) of the Development Document further
describes the procedure as follows (assuming that all
subcategorical process wastewaters are discharged into the same
outfall): First, calculate the subcategory proportion by
dividing the annual production rate (lbs/yr) for each
subcategorical activity by the facility's total OCPSF production
rate. Next, multiply each subcategory proportion by the BPT
concentration limits to get the weighted concentration for each
subcategory. Then, add all the weighted concentrations to get
the total OCPSF concentration limit. Finally, calculate the
OCPSF mass limits by multiplying the total OCPSF concentration
limits by the facility's total OCPSF process wastewater flow.
In some cases, non-OCPSF process streams and/or other
nonprocess streams contributing to the same outfall may require
additional concentration limits based on the permit writer's best
professional judgment (BPJ). A flow -weighted approach should
then be used to calculate the final concentration limit on the
permit. The final mass limit on the permit can be calculated by
multiplying the final concentration limit by the total flow
discharged from that outfall.
For best available technology economically achievable (BAT)
limits, the procedure for calculating the mass limits in Subparts
I and J of the OCPSF rules should be followed whether a facility
falls into a single subcategory or multiple subcategories.
Ouestion 6 - How does the permit writer determine the proper
"flow" figure to use in calculating permit limits?
Answer:
EPA believes, in general, that the long-term average process
wastewater flow taken from a representative production year is
the appropriate value to use for the mass limits calculation. It
would be within the permit writer's discretion to consider
i �i�s was REv�sE� �N FED. RED,. Jury �, 1993 p. 3CD872, PNNVAI
�}vERA6e scow 15 NOu1 "el) ) Pe FEQA6q pvEfZ 4 3-5 *IR 'F RioD.

various data in determining a proper long-term average flow for
each facility, e.g., the highest monthly average flow during the
past twelve (12) months or the highest yearly mean of the twelve
monthly average flows during the past five (5) years. The
selected flow will *then be used to calculate both the daily
maximum and monthly average mass limits.
In cases where the process wastewater flow claimed by the
industry may be excessive, the permit writer may develop a more
appropriate process wastewater flow for use in computing the mass
limits. Significant factors, such as the component flows, the
facility's water conservation practices, and the barometric
condenser use at the process level, should all be considered in
developing the appropriate process wastewater flow. Section
XIV.A (p. 42566) of the preamble to the regulation has a detailed
discussion on this matter.
In situations where flow varies significantly from day-to-
day, the permit writer may also take this into consideration. In
some special instances, the permit writer may find that a tiered
permit is warranted due to the variability of production and
resulting changes in flow conditions. In these cases, the permit
writer should use discretion to develop a case -by -case
determination with appropriate supporting documentation and
rationale. In any event, the permittee is responsible for
demonstrating to the permit writer the need for special
consideration of flow variations in the permit.
QUESTIONS REGARDING THE MONITORING REQUIREMENTS
Ouestion 7
Answer:
- What will be the required monitoring frequency for
toxic pollutants regulated by the OCPSF guidelines
that are not expected to be present at levels of
concern?
The NPDES regulation (40 CFR 122.48(b)) requires that each
permit specify monitoring frequency sufficient to yield data
which are representative of the monitored activity. In
establishing monitoring frequencies, many factors are considered
by the permit writer. The monitoring scenario assumed for cost
estimation during the development of the effluent limitations
guidelines is one of the factors most commonly considered by the
permit writer. Other typical factors include design capacity of
treatment facility, type of treatment method used, significance
of the pollutants, and nature and sensitivity of the water
quality standards of the receiving water. For OCPSF facilities,
as for all other facilities, EPA has decided that the appropriate
monitoring scheme is best determined on a case -by -case basis. •
EPA refrains from setting inflexible monitoring frequencies in

national regulations to allow permit writers to establish
frequencies that are appropriately tailored to the facility. The
minimum monitoring frequency for toxic pollutants which are not
expected to be present at levels of concern may be monthly or
quarterly, but in no case shall it be less than once per year as
required in 40 CFR 122.44(i)(2) for direct dischargers. For
indirect discharges, the minimum monitoring and reporting
frequency is twice per year as prescribed in 40 CFR 403.12(e)(1).
Section X.4 (pp. 42557-8) of the preamble to the regulation has a
detailed discussion on this matter.
Ouestion 8 - Does the NPDES "boilerplate" language requirements
(40 CFR 122.41(a)(1)) trigger the Duty to Comply
with all OCPSF toxic limits even if the permit is
not modified to incorporate the new limits?
Answer:
No. The OCPSF regulations do not include "Toxic Pollutant
Effluent Standards and Prohibitions" as prescribed in 40 CFR Part
129, Subpart A. Consequently, the "boilerplate" language does
not encompass the new OCPSF toxic regulations. The limits for
toxic pollutants in the OCPSF regulations must be included in
permits for them to become enforceable.
QUESTIONS REGARDING THE PROMULGATION AND IMPLEMENTATION OF THE
GUIDELINES
Ouestion 9 - Will best conventional pollutant control technology
(BCT) be promulgated in the future and if so,'will
NSPS be made more stringent in the future?
Answer:
All BCT's are reserved in the final regulation as described
in III.A.3 (p. 42525) of the preamble. NSPS for conventional
pollutants (BOD5, TSS, and pH) are presently equivalent to the
limits established for BPT. The States may develop BCT limits
more stringent than BPT by using BPJ at this time. When a BCT
analysis is done in the future, if it is determined that BCT
limits should be more stringent than BPT, then the technology
basis for NSPS limits will be re -assessed.

6
Ouestion 10 - Will the dischargers be expected to begin
purchasing and installing treatment before the
final permit limits are determined?
Answer:
The statutory deadline for direct dischargers to comply with
BAT is March 31, 1989; the deadline for indirect dischargers to
comply with pretreatment standards for existing sources (PSES) is
November 5, 1990. EPA believes that dischargers should begin now
to conduct studies to determine whether additional treatment is
necessary and, if so, what additional treatment should be
considered. In many cases, the decision to purchase and install
treatment equipment can be made after these studies and
dischargers should proceed with purchasing and installing
treatment equipment whether their permits contain final limits or
not.
If some direct dischargers are unable to determine final
permit limits, then they should meet with the permitting
authority to determine final permit limits and reasonable
compliance schedules, thereby avoiding delays in purchasing and
installing treatment equipment.
EPA'S pretreatment program requires OCPSF indirect
dischargers to prepare baseline monitoring reports within 180
days after the effective date of the pretreatment standards that
assess compliance and provide detailed schedules showing major
events leading to construction and operation of additional
treatment. If an indirect discharger has a question about their
applicable pretreatment standards, they should consult their
control authority.
Ouestion 11 - Are Permitting Authorities to be given any specific
deadlines for reopening the non -expiring OOPS'
permits to incorporate the new guideline?
Answer:
EPA is preparing guidance which urges permitting authorities
to accelerate compliance with the new guideline for OCPSF
facilities. The guidance would assist permitting authorities in
determining when and how to implement the guideline using all
available authorities and permitting tools. One approach would
be to reopen the permit and incorporate new guidelines pursuant
to the reopener clause or the States general authority. Other
possible approaches are to notify OCPSF facilities that immediate
compliance will be expected upon reissuance of the permit, and to
use section 308 authority to request the submission of compliance
plans.

EPA recently conducted a compliance assessment in selected
Regions to estimate the number of OCPSF permits that can be
reopened and the number of OCPSF facilities which need additional
treatment for compliance with the guidelines. The assessment
indicated that many existing permits have either specific
reopener clauses or the permitting State has a general regulation
to reopen the permit upon promulgation of new effluent
limitations guidelines. The assessment also revealed that the
majority of OCPSF facilities currently discharge pollutants at
levels which exceed the new BPT and/or BAT guidelines.
QUESTIONS REGARDING THE DISPARITY OF LIMITATIONS BETWEEN SUBPARTS
I AND J
Ouestion 12 - Why are there a number of BAT and NSPS limitations
for toxic pollutants, e.g., nitrobenzene, which
allow higher effluent concentrations for
dischargers that do not use end -of -pipe (Non-EOP,
Subpart J) biological treatment than those using
end -of -pipe (EOP, Subpart I) biological treatment?
Answer:
In developing technology -based guidelines for BAT and NSPS,
EPA used performance data that properly reflected the type of
treatment used, based upon the facilities' particular wastewater
characteristics. In the case of nitrobenzene, the BAT limits for
the EOP biological treatment subcategory were derived from a data
base of four plants using the combination of steam stripping and
activated carbon. adsorption plus EOP biological treatment,
whereas BAT limits for the Non-EOP biological treatment were from
a data base of two plants using the combination of steam
stripping and activated carbon adsorption alone. (See Tables
VII-45 & 64 of the final Development Document.) These two sets
of data were evaluated independently and resulted in the
different limitations for these two subparts. Therefore, the
difference between nitrobenzene limits in Subparts I and J was an
inevitable result of this development procedure for technology -
based limitations. Please refer to VI.C.4.d, pp. 42543-4, of the
preamble for a general discussion of this particular issue.
The facilities in the EOP biological treatment subcategory
are the ones which have installed, or will install, end -of -pipe
biological treatment to comply with BPT limits. The facilities
in the Non-EOP biological treatment subcategory are the ones with
low enough levels of BOD5 in their wastestreams which do not need
end -of -pipe biological treatment to comply with BPT limits. (See
p. 42538, VI.C.1 & 2 of the preamble.) In the future, those
plants that have lower levels of BOD5 (and no end -of -pipe
biological treatment) will most likely choose to manufacture new
chemicals that will also have lower BOD5 levels and require no

end -of -pipe biological treatment. However, a plant may choose to
manufacture a new product or products as a result of the higher
effluent limits in the Non-EOP biological treatment subcategory
for selected pollutants. If the plant can comply with its permit
for all limited pollutant parameters, it is the plant's
prerogative to manufacture the new product(s).
Furthermore, the BAT limitations in these two subcategories
are technology -based. If a State feels that certain toxic
limits, e.g., nitrobenzene, are too lenient, more stringent
limitations based on State Water Quality Standards or more
stringent provisions of the State law can be imposed.
QUESTIONS REGARDING WHOLE -EFFLUENT TOXICITY TESTING OF OCPSF
EFFLUENT
Ouestion 13 - Should most OCPSF permits contain whole -effluent
toxicity controls?
Answer:
Yes. Under sections 308 and 402 of the Clean Water Act, EPA
or a State may require permittees to provide chemical, toxicity,
and in -stream biological data necessary to assure compliance with
water quality standards. EPA's Policy for the Development of
Water Quality -based Permit Limitations for Toxic Pollutants (49
FR 9016, March 9, 1984) calls for the use of "an integrated.
strategy consisting of both biological and chemical methods to
address toxic and nonconventional pollutants from industrial ...
sources." The Policy specifies, "[w]here there is a significant
likelihood of toxic effects to biota in the receiving water, EPA
and the States may impose permit limits on effluent toxicity...."
As we have stated in the memo of February 8, 1988, discharges
from OCPSF facilities often contain an exceptionally wide variety
of pollutants. All potentially toxic pollutants discharged from
OCPSF facilities cannot be inexpensively identified by chemical
methods, but it is feasible to examine the whole -effluent
toxicity and instream impacts using acute and/or chronic toxicity
testing rather than attempt to identify and limit all toxic
pollutants. For the reasons given above, EPA anticipates that
whole -effluent toxicity controls, including acute or chronic
toxicity limits and/or biomonitoring requirements, will be needed
in most cases for OCPSF facilities. Acute or chronic toxicity
limits or monitoring requirements are dependent upon available
dilution and species sensitivity. Toxicity limits may be imposed
for the facilities at the discretion of the permit writer on a
case -by -case basis.

QUESTIONS REGARDING METALS IN OCPSF STREAMS
Ouestion-14 - Are complexed metal -bearing wastestreams exempt
from the standards for metals only, or is the
wastestream also exempt from the organic and
cyanide limits?
Answer:
The exemption for complexed metals in 40 CFR 414.11(f) refers
to the exclusion of the standards for metals only. The exclusion
applies only for the metals listed in Appendix B as complexed for
the product/process in question. In addition, the wastestream is
not exempt with regard to toxic organics and cyanide
requirements.
QUESTIONS REGARDING THE FUNDAMENTALLY DIFFERENT FACTORS (FDF)
VARIANCE REQUESTS
Ouestion 15 - What will be the effect of imposing OCPSF limits on
a permittee which has filed an FDF variance
request?
Answer:
Section 301(n)(6) states that "an application for an
alternative requirement under this subsection [i.e., FDF] shall
not stay the applicant's obligation to comply with the effluent
limitation guideline or categorical pretreatment standard which
is the subject of the application." This provision applies to
the FDF variance requests for BAT, BCT, and PSES. In addition,
the NPDES regulation does not provide for staying the applicant's
obligation to comply with the effluent limitation guideline for
BPT. The guideline regulation requires compliance with PSES by
November 5, 1990, while BPT and BAT limits are enforceable only
when they are incorporated in NPDES permits. Permitting
authorities can use enforcement discretion, when appropriate,
for the permittees which have filed FDF variance requests and are
not in compliance with their permit requirements.
Ouestion 16 - What impact will section 301(n)(2) of the Clean
Water Act, which requires submission of a request
within 180 days of the date of establishment or
revision of a limitation, have on FDF filing
deadlines?
Answer:
The existing State NPDES regulations require submission of a
BPT, BAT, and/or BCT FDF variance request by the close of the
comment period on the draft permit which incorporates the

10
guideline -based limitations at issue. At this time, the existing
EPA NPDES regulations also contain this requirement. The,
existing EPA general pretreatment regulations require submission
of a FDF.variance request within 180 days of the effective date
of the standard from which relief is being requested or within 30
days after a categorical determination.
As indicated in the memo of February 8, 1988, EPA will
consider BAT FDF variance requests submitted by OCPSF facilities
to be timely if the request is submitted to the NPDES permitting
authority by May 3, 1988. This requirement is based specifically
on the language of section 301(n)(2). The conference report.
indicated that the FDF variance provisions were to be self -
implementing. 132 Cong. Rec. H10567 (daily edition October 15,
1986). Note, however, our regulations at 40 CFR 123.62 provide a
process for revisions to conform State programs to federal
requirements and references as one such instance when controlling
federal statutory authority is modified or supplemented. The
preamble to the OCPSF regulation also noted that the statute
overrode existing EPA FDF regulations to the extent there were
any inconsistencies. 52 Fed. Reg. 42566 (November 5, 1987). EPA.
will be changing the NPDES (and general pretreatment) regulations
to conform them to the statutory requirements. To the extent
that the State NPDES regulations would provide any filing
deadline which would be after May 3, 1988, the more stringent
federal provision, section 301(n)(2), which requires submission
no later than May 3, 1988, would control.
Ouestion 17 - Why is there an apparent inconsistency in filing
deadlines between BPT and BAT/PSES and what is the
filing deadline for BPT FDF variance requests?
Answer:
Section 301(n), on its face, only applies to BAT, BCT, and
PSES FDF variance requests. EPA will continue to consider and
evaluate BPT FDF variance requests in accordance with the
existing NPDES regulations, since there is no superseding
statutory provision. Accordingly, BPT FDF variance requests must
be made by the close of the public comment period on the draft
permit. EPA intends to eventually change the regulations for BPT
FDFs to make them consistent with section 301(n). Moreover, EPA
had strongly encouraged that BPT FDF variance requests from the
OCPSF guidelines be submitted along with BAT and PSES variance
requests on or before May 3, 1988.

11
Ouestion 18 - Is the language in 40 CFR §125.31(a)(1) which
requires a request for relief from a "national
limit which is applied in the permit...."
inconsistent with the existing regulatory and/or
statutory filing deadlines?
Answer:
The provision in 40 CFR §125.31(a)(1) is one of the decision
criteria that is used in deciding NPDES FDF variance requests,
not an application requirement. The intent of this provision is
to require that there be an applicable national effluent
guideline for the pollutant for which relief has been requested
which is applicable to the facility. To the extent that any
applicant claims that this provision allows submission of a FDF
variance request after issuance of the permit containing the
limitations, the application deadline in section 301(n)(2) would•
supersede this provision.

DIVISION OF ENVIRONMENTAL MANAGEMENT
July 8, 1988
MEMORANDUM
TO: Dale Overcash
Rex Gleason
FROM: Randy Dodd �C-(D�
THRU: Trevor Clemen
Steve Tedder
SUBJECT: Sandoz Fundament lly Different Factor Request
Sandoz has submitted an FDF request, as summarized below: (monthly
averages):
Parameter WLA Basis Request
BOD_, (IUD) 538 * BAT 714
2-nitrophenol (ug/1) 41 BAT 82
4-nitrophenol (ug/1) 72 BAT 144
2-4-denitrophenol (ug/1) 71 BAT 142
phenol (ug/l) 55 ** WQ 45
-t.i L
* There is a staging requirement as well (see attachment).
** This is the water quality limit based on minimum daily average release
(329 cfs) and the WS standard (1 ug/1). The BAT limit is 15 ug/1.
Please note that the phenols are listed in 0208(b) as substances requi-
ring special attention, and that 0211(e) states that specific phenolic
compounds may be given a different limit if it is demonstrated not to cause
taste and odor problems and not to be detrimental to other best usage.
As long as staging requirements for BODS and NH3-N, the previously
submitted monitoring plan and other WLA requirements, and a reopener allow-
ing for revision of these limits based on monitoring results, FDF variance
should be acceptable for protecting aquatic life. DHR should be consulted
as well.
Please advise if questions.
RD/gh
cc: Ken Eagleson

SANDOZCHEMICALS
Sandoz Chonsiads Corporation
P.O. Box 669246
Charlotte, North Carolina 28266
704.827.9651
Telex 810.649.2224
April 12, 1988
Mr. Arthur Mouberry
Supervisor Permits & Engineering
NC Division of Environmental Management
PO Box 27687
Raleigh, NC 27611
Re: NPDES Permit NC0004375
Dear Mr. Mouberry:
In response to your letter of March 24, 1988, the following
information is provided. Sandoz Chemicals Corporation, Mount
Holly Plant does not produce any of the metal -bearing waste
streams listed in Appendix A of 40 CFR Part 414, but does employ
several of the processes listed in Appendix B. In reference to
cyanide bearing waste streams listed in Part 414, Appendix A,
Sandoz does not currently have synthesis processes involving any
of these waste streams but does perform mixing/blending and
repackaging operations for disperse dyes and for organic pigments
listed in this group. It is unclear whether this non -
manufacturing processing is to be considered when determining
what processes are performed at our facility.
Please contact me if you need additional information.
Sincerely,
z,(//i/e-a,--, Ctte
William M. Archer
Environmental Manager
WMA:aj
cc: Mr. Dale Overcash

NPDES WASTE LOAD ALLOCATION
Modeler
Date Rec.
PERMIT NO.: NCO() 0 y376-
FACILITY NAME• 4P/dr, (`firm Corp
Facility Status: ( EXISTII j PROPOSED
(circle one)
Permit Status' RENEW Ai7 MOOWICA17ON UNPE9M1TI ED NEW
(circle �
Major Minor_
Pipe No:
60 1
Design Capacity (MGD):
Domestic (% of Flow):
Industrial (% of Flow)•
St. e
3, 5
O.0iv44c/)
%l C0nw.nilsf
z.b
Comments: CO4 4. //rd /rote
6/no", : 9$-/7S / /7r-.�5a / a5-0-Ja9 efs
/(G , /?rt ces
r4. 3d ? el;
RECEIVING STREAM: ! e, ��iuCr
Class: :,)5 ELI-
Sub-Basin•
03 0b 3 4/.
Reference USGS Quad: (please attach)
County- Mee L/r.r hul
Regional Office: As Fa
(circle one)
Requested By: 7707n43 J aris
Ra Wa Wi WS
Date:
Prepared By-
d� h (J' c_. - Date:
Reviewed By: •-'tiAgDate:
BS
is 5?
23
Drainage Area (mil) /�
9Q10-(cfs) - Winter 7Q10 (cfs) 30Q2 (cfs)
M /v 31-7Q10 ro.^
Avg. Streamflow'cfs)• 321
Toxicity Limits: IWC % (circle one) Acute / Chronic
Instream Monitoring:
Parameters
Upstream
Downstream
Location
Location
Effluent
Characteristics
,.�..•.,r\-1y-- / •r,,..�_:..,
b.-t i _„fv1q-�; , , ti,
BOD5 {DO
3-38
14f .Z
3AN---
NH3 N (. ,yi)2;)
2,.6)
(U
P,�'S
D.O. (mg/I)
5 (.
j ;
TSS (-.ip.)
• 6 s I
2_189
RC
F. Col. (/100m1)
i 6° o
w q
pH (SU)
6 -9
(3-`j
BAT/
(i-c) L 1
73
lug
1A-r-
c i1.)
C= rya, ,.; c Pes-‘,'c.,
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A
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�
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I
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Y i e {--� ✓ i. tom? OC
Comments:` �2�`'; $,..._
043-
Psi
20 4 es.'c
e.i

FOR APPROPRIATE DISCHARGERS, LIST COMPLETE GUIDELINE LIMITATIONS BELOW
Effluent Characteristics
Monthly
Average
Daily
Maximum
Comments
f-/{id;-«l4g, ,'--- Clo' 11,,
/S 5 / f y
A /dc, 7
GO 0
3 3
y/ 7
/30/7,r
a LI LI
6 3
7-.5 s
3 0 4
?q,'?
D1 o. ;c. 1)45 14;ade4
0. 006 S
D, 0 3 6
P.,0,(5 A2'//, 6
, 41
'e , /ed
/-'
6-- 9
G—f
,
t c , (2. j 0 )
SS S
d `l ` .
,.,±• c.Z
_cG.-r ( )
U. i (
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... C J-I')
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c�
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j <- _
1�-"+"\9-Y. ill. o..� Q
Y,,,c -
-.,ti:.
, 1r):_, I) i_
, ' ,. .
Type of Product Produced
Lbs/Day Produced
Effluent Guideline Reference
A/e' .ar1
51`<-
Ss 7 j
4r000
'140/0ao
ay G
/UGGiZ
1-/S S . L y
/3,47
C 6 /SG)
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,5rc__
a28-l25+
,
4.1640
`/0C//L
4-/4l, Cr-3
/3//7
(ii/S/i7)
/00w...,!7c, /AJ(
D. a&

NPDES WASTE LOAD ALLOCATION
PERMIT NO.: NCOO 0 'I3 7C
FACILITY NAME• �2n Z C Coin, A A /44v//c'
Facility Status: OEMSI NG,. PROPOSED
(circle one)
Permit Status: F.NEWAL MODIFICATION UNPERMrTTED NEW
(circle one)
Major Minor
Pipe No• (:%ci
Design Capacity (MGD)• �c y
Domestic (% of Flow)- ? 67°
Industrial (% of Flow): 9��e
Coiments• �evc416 c .N.,,cr 3• ! A,/
etsto €i 2,to /via/-' r 6a6./�ed /.7G nire �ec
J
6 /!w fL /75) i?S -ds� r d5,-3AI
RECEIVING STREAM: r,; �•-c,w.her
Class- GUS 2
/Ji
G �S
Sub -Basin• 03 6,0
3 y
Reference USGS Quad• (please attach)
County:
Regional Office: As Fa
(eirels owe)
Ra Wa Wi WS
Requested By: '��° �' G ��'s Date- %/L / k 7
Prepared By• Date -
Reviewed By: Date:
Z`' Pe LP/m
2
Drainage Area (mi )
7Q10 (cfs)
Modeler
Date Rec.
#
Avg. Streamflow (cfs)•
Winter 7Q10 (cfs) 30Q2 (cfs)
Toxicity Limits: IWC % (circle one) Acute / Chronic
Instream Monitoring:
Parameters
Upstream Location
Downstream Location
Effluent
Characteristics
Summer
Winter
BOD5 (mg/I)
NHj N (mg/1)
D.O. (mg/1)
TSS (mg/1)
F. Col. (/100m1)
pH (SU)
Comments•

FOR APPROPRIATE DISCHARGERS, LIST COMPLETE GUIDELINE LIMITATIONS BELOW
Effluent Characteristics
Monthly
Average
Daily
Maximum
Comments
an;cs
Cold
/6,9G 4411-7
'/ A
4/Ar.—
/3oD5
icsf
aa8
7-55
.Gv
3 76
/-/crb�;cts
Gv /.)
7 a
/U 4/
i 55
/11, "-1
</fi, Se
6f10,,,`� ,,<s4;,<.Pe
G, o / '/
G, U�
Gyre_ r (.(w 1.
phGHO l
/ G .ut, /A
Type of Product Produced
Lbs/Day Produced
Effluent Guideline Reference
S.rC ,2s4,5
a, ,,.,, .r /Jy
yGu000 /646,,,.
F-/v ci= i?
,i /--/
,;2
3
/3:4T
(e) c-i
7i G �Zb %CI
/ /e,i �,'cirt
�`/ GuU %6 1 �a
`/0 G,c,
-/ .S-,
2 2
,& P %
( /�ts ,4 ;d l.�
7

Request No. :4238
?emit Number
Facility Name
Type of Waste
Status
Receiving Stream
Stream Class
Subbasin
County
Regional Office
Requestor
Date of Request
Quad
Wasteflow
5-Day BOD
Ammonia Nitrogen
Dissolved Oxygen
TSS
Fecal C'oliform
pH
COD
Organic
WASTELOAD ALLOCATION APPROVAL FORM
NC0004375
SANDOZ CHEMICAL CORP.
HERBICIDES, ORGANIC DYES,
EXISTING
CATAWBA RIVER
WS-III
030834
MECKLENEURG
MRO
THOMAS CHRIST
9/25/87
F14SE
MISCELLANEOUS
Drainage Area (sq mi)
Average Flow (cfs)
Summer 7Q10 (cfs)
Winter 7Q10 (cfs)
30Q2 (cfs)
RECOMMENDED EFFLUENT LIMITS
Mon Avg
(mgd): 3.9 (S)
(kg/d): 244
(mg/1): 20
(mg/1): 5
(kg/d): 309
(#/100m1): 1000
(SU): 6-9
(kg/ d) : 33
Pesticides(kg/d): .0065
Manganese (mg/1): 0.84
Da. Max
2.6 (W)
663
20
5 (min)
992
6-9
47
.036
MONITORING
Upstream (Y/N): Y Location: NC 27
Downstream (Y/N): Y Location: I-85
COMMENTS
MBAS (MG/L) 8.4 WQ TOXICITY REQUIREMENTS ATTACHED. TOXIC WQ
SULFATE (MG/L) 4190 WQ REQUIREMENTS BASED ON 95 CFS. CATEGORICAL
MERCURY (UG/L) 3.3 WQ LIMITS FOR PRIORITY POLLUTANTS ATTACHED.
RECOMMEND, ABOVE LIMITS IN ADDITION TO MAINTENEANCE OF CURRENT STAGING REQUIRE-
MENTS FOR BOD AND NH3 TO AVOID DOSING DURING PERIODS OF MINIMUM RELEASE.
REF.: HERBICIDES 455.24 SAT (6/86) ORGANIC DYES 414.83 BAT OW6-7)
NOTE 1 KG= 2 . 2 LB.
cr'Fc�rs ti�+ci. a 3E Qv^soe
: 2015
9 5 = MLV,. . 5. .,.k.
95 + - ctc
/i/l v
Memo
C04-^colA see
f, 57/eve_
-re ;Je-re(2Iica3_n) saL.ece 5
ucrRkOt-3 occoNC 5EASc A-1.-
Recommended by
Reviewed by:
Tech. Support Supervisor
Regional Supervisor
Permits & Engineering
o.ao Date
date
AiDate
Date 2/2510.
Water Quality Section Chief Date
RETURN TO TECHNICAL SERVICES BY
J rilU 2 8A938

icy
• Facility Name c G { Permit # 60 0 3 2S
CHRONIC TOXICITY TESTING REQUIREMENT (MONTHLY)
The effluent discharge shall at no time exhibit chronic toxicity using test procedures outlined in:
1.) The North Carolina Ceriodaphnia chronic effluent bioassay procedure (North Carolina Chronic
Bioassay Procedure - Revised *February 1987) or subsequent versions.
The effluent concentration at which there may be no observable inhibition of reproduction or
significant mortality is A % (defined as treatment two in the North Carolina procedure
document). The permit holder shall perform monthly monitoring using this procedure to establish
compliance with the permit condition. The first test will be performed within thirty days from
issuance of this permit. Effluent sampling for this testing shall be performed at the NPDES
permitted final effluent discharge below all treatment processes.
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 parameter
code 'IrP3B. 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 of the effluent toxicity saniple iniist be measured and reported if chlorine is employed for
disinfection of the waste stream.
Should any test data from this monitoring requirement or tests performed by the North Carolina
Division of Environmental Management indicate potential irnpacts 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 kited document, such as minimum
control organism survival and appropriiate environmental. controls; shall constitute an invalid test
and will require immediate retestin
g(w1thin.30 days of initial monitoring event). Failure to submit
suitable test results will constitutes failure ofpermit condition.
7Q10 cfs . :.
Permited Flow 3 . al MGD
IWC% (� o
Basin & Sub -basin o3®g
Receiving Stream C�.���,��� ,
County C c ���.Date 3 to j c-T
**Chronic Toxicity (Ceriodaphnia) P/F at i0 %, See Part 3 , Condition G.
Recommended by:

U %1 WWIgj
0/= MoN
43/cd f;t1 / TrC4l7MCM
c<ec,4„„
/1''r"17s - s � /3 0 7
NC000/376
c5,¢NUD Z
1, K /46r)
IJ2-
/'Io d f•S S 6•00, S 'Pwry, T I
Effluent
characteristics
- Acenaphthene
- Acrylonitrile
-Benzene
-Carbon Tetrachloride
- Cttbenzene
1,2,loro4-
Trichlorobenzene
- Hexachlorobenzene
/-1;2-Dichloroethane
-1,1,1-Trichloroethane
Hexachtoroethane.__
1,2-Dichloroethane
�1,1,1-Tnchloroet have
�Chloroethane
-Chloroform _.._........-
- 1,2-Dichlorobenzene
- 1,3-Dichlorobenzene
-1,4-Dichlorobenzene
- 1,1-Dichtoroethylene
- 1,2-trans-
Dichloroethylene .:
-2,4-Dichlorophenol
- -1,1,3-
pr 2-Oichtoroopane
Dichtoropropylene --
- 2,4-Dimethytphenol
- 2.4-Dinitrotoluene
- 2.6-Dinitrotoiuene
- Ethylbenzene
- Fluoranthene ....-
- Bis(2-
Chloroisopropyf)
ether
- Methylene Chloride
- Methyl Chloride
- Hexachlorobutadiene.
- Naphthalene
- Nitrobenzene _--..._.
- 2-Nitrophenol.--.__
ophenol ..._._....._..
- 2,4-Dinitrophenol....--_
- 4,6-Dinitro-o-cresol _....
- Phenol
- Bis(2-ethylhexyl) .
phthalate .
- Di-n-butyl phthalate
- Diethyl phthalate..__
- Dimethyt phthalate...._
- Benzo(a)anthracene
Benzo(a)pyrene
3.4-
Benzofluoranthene
- Benzo(k)fluoranthene •
Chrysene
- Acenaphthylene
- Anthracene
- Fluorene
- Phenanthrene
- Pyrene
- Tetrachloroethylene
- Toluene...._
- Trichloroethyiene
- Vinyl Chloride
�Gk �i /� Total Chromium
Maximum
for any
one day
59
242
136
38
28
140
28
211
54
54
59
54
268
46
98
163
44
28
25
54
• 11z
230
44
36
285
641
108
68
757
89
- Total Copper
4- Total
/gyp 67e. .cr°C �� -Total Lead
- Total Nickel
- Total Inc*
•
•
190
49
59
68
69
124
123
277
26
279
S7
203
47
I 59
61
61
59
59
59
59
59
59
67
56
80
Maximum
for
monthly
average
22
96
37
18
15
68
1S
. -68
21
21
22
21
104
21
31
77
31
15
16
21
39
o. 31
•7 /
0.96
0..23
0• / S
3./3
a,4y
o.Sq
153 / -ZA
29 C:)• 3
18 Q•
113 /, 3-
255 3• /
32 p , 3-7
22.36,
• 301
40
,,o/
d . 41 7
86 /. 0 0
2° o•a6
f ci • 3 /
27 Q,�
72 U,657
71 0, 6S
715 -/. 4/7
103
22 3 /
23 c3.3 a
23
22
22
22
22
22
22
25
22
26
21
104
All units ere micrograms per liter.
Total Zinc for Rayon Fiber Manufacture
that uses the viscose process end Acrylic
Fiber Manufacture that uses the zinc chloride/
solvent process is 6,796 µg/I and 3,325 µg/I
for maximum for any one day and maximum
for monthly average. respectively.
0.3a
0,3
0,36
o,la
0, 5 /
3. as
c•cierl-
C• oho
G.36
o. p0
0 • 36-
0• //
•b6-a
dsO •5
C,• //
rJ '• 8 /
a./5
O •o9S
D.6c
/• 35
0 . / 7
a . /3
/• Go
o•a/
G 4j 6
o•//•.
D /,?,
G ,y
Q• 36
O, 35-
o •y/
0 ,go
O .sy6
O-/y
O--/3.
O•/0
O , / ?
o-/a
0, /3
U5 k 35L
ft. lob t 3.
MG,

DIVISION OF ENVIRONMENTAL MANAGEMENT
December 17, 1987
MEMORANDUM
TO: Steve Tedder
FROM: Randy Dodd
THRU: Trevor Clements C
SUBJECT: Sandoz IWC Recommendation
Please find attached a brief summary of release data from Mountain
Island Lake provided to Technical Services for the month of October, 1987.
The major conclusion is that release _above 100 cfs occurred for 4 hours or
less on 16 days during the month. Also of interest is the fact that minimum
daily average release either did not meet or marginally met the 329 cfs
requirement. Daily average flows were typically heavily influenced by
short-term (2-4 hours) turbine operation. USGS reports that water resource
conditions were near or above average for October in the Piedmont and moun-
tains.
The previous commission minutes regarding the alternative flow allow-
ance for Sandoz does not appear to make specific reference to whether the
allowance is for both conventional and toxic pollutants. The existing
phenol limit is based on the minimum daily average flow. (The minimum
instantaneous release was recommended by Operations.)
The IWC (based on 3.9 mgd) at minimum instantaneous release is 6.0%;
at minimum daily average, the IWC = 1.8%. Sandoz is requesting a summer
flow of 3.9 mgd and a winter flow of 2.6 mgd. Federal Guidelines require
Sandoz to meet categorical limitations on 58 priority pollutants.
Based on this information, it is my recommendation that the test con-
centration be set at 6.0% in order to protect for short-term exposure.
Attached is a draft WLA for your review.
Please advise if questions.
Attachment
RD:gh
cc: Dale Overcash
Rex Gleason
Ken Eagleson

Catawba River Flow Below Mountain Island Dam
October 1987
Daily Daily
Day 11 hours < 100 cfs Avg (cfs) Day # hours < 100 cfs Avg (cfs)
1 6 356 16 4 331
2 1 96 17 2 313
3 2 319 18 2 328
4 3 322 19 3 318
5 3 409 20 3 300
6 9 535 21 2 315
7 14 2105 22 6 319
8 19 2299 23 2 325
9 6 984 24 4 306
10 8 534 25 4 305
11 0 94 26 4 342
12 17 3515 27 12 1275
13 10 3052 28 11 1273
14 4 346 29 14 1640
15 4 302 30 4 321
31 3 306

Recommended Compliance Reporting Form
(1) (2) (3) (4) (5) (6) (7) (8) (9)
Allowable Actual In
Mtn. Island Effluent BOD+xNH31. BOD5 NH3N BOD+xNH31 comp?
Day Ilour Release (cfs) flow (mgd) (#Ihr) (m; /1) (0/hr) (mg/1) (0/hr) (#/hr) (Y/N)
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
Sum:
Avg:
Min:
Max:
Hourly allowable BOD5 and NH3 requirements attached.
Daily allowable BOD-, = 1462 0/day.

Recommended Instream Self -Monitoring
East Bank approx. At or near Immed. above
Upstream 1 mile downstream I-85 Belmont intake
Sum/Win Sum/Win Sum/Win Sum/Win
BOD5 W/ M W/ M W/ M W/ M
NH3N W/ M W/ M W/ M W/ M
D01 W/BW W/BW W/BW W/BW
pH W/BW W/BW W/BW W/BW
Conductivity W / BW W / BW W / BW W / BW
Temperature,. W / BW W / BW W / BW W / BW
Phenols W / W W / W
Surface and bottom DO, temperature, and conductivity shall be reported.
W = Weekly
M = Monthly
BW = Biweekly

Sandoz Draft WLA
Background
On June 11, 1981, the EMC approved the use of the minimum daily average
release of 314 cfs from Mountain Island dam (+ 15 cfs of runoff) as the
design streamf low for Martin Marietta (Sodyeco division) for determining
effluent limitations. The approval was subject to continued agreement by
Duke Power to meet the release, and staff requirements for developing a
control release regime. Staff subsequently issued a permit which included
equations outlining allowable BOD, and NH_;-N levels under different releases
from the dam. The equations were based on application of a state-of-the-art
dynamic water quality model (RECEIV-II). While staff and the consultants
for Sodyeco (Chas. T. Main) acknowledged the applicability of the RECEIV-II
model to the issue and system, several substantial uncertainties remained
after application because of the model's considerable data requirements.
Staff concluded that the model was "reasonable", but that a water quality
model had not been calibrated to the system.
Sodyeco subsequently developed a complex staging system to meet the
discharge requirements. The wastewater system generally removes BOD, and
NH3-N to very low levels in the summer. Winter performance is not as good,
with BOD, and NH3-N levels typically between 10 and 20 mg/1.
There is currently one station (shared by Sandoz and Mt. Holly) in the
sag zone. Self -monitoring (as well as ambient monitoring) at this location
has not indicated contraventions of the DO standard.
Since permit issuance, federal guidelines have been promulgated for
organic chemicals and pesticides. The regulation for flow design criteria
(0206) was modified in 1985.

A wasteload has been drafted which includes: 1) effluent guideline
limits for BOD, TSS, pH, COD, organic pesticides, and fifty-seven organic
chemicals; 2) water quality limits for toxicity, fecal coliform, manganese,
MBAS, sulfate, mercury, and phenols based on the minimum instantaneous
release, and maintenance of the current BOD and NH3-N staging equations.
Along with the WLA, a simplified staging flow chart has been developed.

Potential Modifications to
Draft WLA and Permit
I. Drop alternate staging flow chart as requirement and present as
suggestion.
2. Require submittal of self -monitoring information in a format which
can easily be interpreted for compliance purposes. Include annual
compliance reports.
3. Require more extensive instream self -monitoring, particularly for
DO during critical periods.
4. Require engineering assessment of ammonia sources (and a waste
reduction plan for ammonia).
5. Require performance of an intensive survey and modeling study to
demonstrate that alternative flow designation provides better
protection of water quality.

DIVISION OF ENVIRONMENTAL MANAGEMENT
January 13, 1988
MEMORANDUM TO: Steve Tedder
FROM:
PREPARED BY:
SUBJECT:
D. Rex Gleason
Thurman Horne
Review of Draft Waste Load Allocation
(Request No. 4238)
Sandoz Chemical Corporation
NC 0004375
Mecklenburg County, North Carolina
The staff of the Mooresville Regional Office -Water Quality
Section has reviewed the subject draft Waste Load Allocation and
offers the following comments and recommendations:
1. It appears that there is no proposed limitation for
phenol. Phenol is known to be present in significant
concentrations in this wastewater. It is recommended
that a phenol limit be established based on water
quality standards.
2. The Mooresville Regional Office supports the reasoning
behind the proposed simplified staged discharge
requirements, but we doubt it will survive the
challenge that Sandoz will more than likely make. The
current staging requirement, albeit confusing, was
developed after considerable negotiation with Sandoz
and was essentially a mutually accepted settlement of
their objections during the last round of permit
renewal. Sandoz has made a considerable investment in
installing the necessary equipment and computer
programs to function under the current staging
scenario. It is doubtful that they will be willing to
give up easily on something they "won" with great
difficulty. Considering the efforts they have
extended they can present a very strong case on their
behalf if they do choose to contest the change.
3. Much less important, but still worth noting, is that
the proposed limits appear to be based on BPT and not
BAT as indicated.

•
Steve Tedder
Page Two
January 13, 1988
4. We recommend that the proposed limitations and staging
requirement be given to Sandoz so that they can
prepare their comments and recommendations prior to
drafting the permit.
If you have any questions or need any additional
information, please advise.
JTH:se

EQUATION 1:
EQUATION 2:
Discharge
By
Equation 2
No
Begin
7 A.M.
Is stream4iow
329 cfs
Yes
Cease
Discharge
Summer
BODS + 0.45 (NH_;-N) < 111.1 1#/hr avg.
222.2 it/hr max.
BOD + 0.54 (NH:,-N) < (A) 4i/hr avg.
2 (A) ##/hr max.
Flow (cfs)
95 to 175
175 to 250
250 to 329
A (#/hr)
23.6
43.5
84.5
Yes
Discharge
By
Equation 1
aS
Winter
BOD , + 0.5 (NH3-N) < 197.9 Itfhr avg.
395.8 #t/hr max.
BOD , + 0.31 (NH,-N) < (B) #/hr avg.
2 (B) ##/hr max.
B (#/hr)
54.2
99.8
150.3

•
6
Discharge by
Equation #2
r
Sandoz Chemicals
Staged Discharge Requirements
Flow Diagram
Discharge by
Equation #2
(as allowed for
flow of 95-175 cfs)
Are any turbines operating?'
it 7 A.M.?
Yes'
/3 Begin 1st day
f month @ 7 A.M.
•
Are any turbines
operating?
A
Yes
Is this the
last day of
the month?
STOP
Yes
Discharge by
Equation #'T
it 7
P
. M. ?
m
Are any turbines
operati g?
Yes
it 7 A.M.?
Yes
Calculate Daily Flew —from
Yes s7 A.M. to 7 P.M.
Is the daily flow greater
than 329 cfs?

Discharges are to be released in accordance with the following:
Staging .Requirements Y.
If at least one turbine at Mt. Island Dam is operating at the beginning of each discharge day, 1301)5 and NH3-N
can he released in accordance with Equation No. 1 until. 7:00 Y.M. if no turbine;: re in operation at. 7:00 A.M.,
8005 and NH3-N can he released in accordance with Equation No. 2, as defined below.. unti 1 turbine operation
begins.' When at least one turbine at Mt. Island Dam begins operating, HOD, and NII;-N can be released in accord-
ance with Equation No. 1 until 7:00 P.M. If at least one turbine begins c,peration :after 7:00 Y.M., 1s0D5,,nd NH3-N
can be released in accordance with Equation 1. At 7:00 P.M. the total daily strei,o flow during the 7:00 P.M.
period will he determined as follows: A 24-hour average discharge rate will he crlculated which will include the
minimum instantaneous flow quantity plus 15 CPS 7Q10 from Dutchman Creek (i.e. if. 30 x 106 ft3 was released by
one turbine from 7:00 A.M. to 7:00 P.M., the 24-hour average would he (30 x )06 80 + 15) = 442). if the 24-
3600 x 24 -
hour average flow rate is greater than or equal to 329 CFS, ROD5 and N113-N can he dis^harged from 7:00 P.M. to
7:00 A.M. in accordance with Equation No. 1. If the 24-hour average flow rate is leg; than 329 U1'':i, 110I)5 and
NH3-N can be discharged from 7:00 P.M. to 7:00 A.M. in accordance with Equation No. If at least one turbine
begins operation after 7:00 P.M., RODS and NH3-N can he released in accordance with 1c nation 1.
• EQUATION NC). 1
Summer (11 Winter(2)
RODS + 0.45(N113-N)< 111.1 lhs/hr. avg. H0D5 + 0.5 (NH3-N)< 197.9 lbs/hr. avg.
(333.3 lhs/hr. max.) (593.7 lbs/hrr. max.)
i
I?QIIATION NO. 2 HODS + 0.54(NH3-N)< (A) lhs/hr.
RODS = RODS discharge rate, 1hs/hr.
NH3-N = N113-N discharge rate, lbs/hr.
Discharge Day begins at 7:00 A.M.
80D5 1 0.31 -',4H-1-N)e. (Ii) 1bs/hr.
,4>
A and 13 are defined below (The hourly rates will he calculi ted
dividing daily discharge by 24)
A (lh/hr) . 13 (lb/hr)
Flow: CFS Avg. M_ax. Avg. Max.
95 to 175 23.6 47.2 54.2 108.4
175 to 250 43.5 87.0 99.8 199.6
250 to.329 H4.5 169.0 150.3 300.ti
et,A4 2y u 111.( '.( LiY = 2_664 TV (46,

NC0004375 Sandoz Effluent Monitoring
BODs (mg/1)
NH3-N (mg/1) Phenol (ug/1)
11/87 15 10.2 737
10/87 12 7.5 120
9/87 2 0.78 83
8/87 1 0.6 77
7/87 2 1.0 60
6/87 4 3.1 160
5/87 4 19.4 80
4/87 4 18.6 151
3/87 7 14.0 240
2/87 13 14.2 230
1/87 13 8.5 280
12/86 17 11.7 70