NC0004375_Owner Name Change_19951010

NPDES DOCUMENT 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:
October 10, 1995
This document is printed on reuse paper - ignore any
content on the reYerse side

Slate of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
Michael A. Teague, Ph.D.
Clariant Corporation
P. O. Box 669246
Charlotte, North Carolina 28266
Dear Dr. Teague:
In accordance with your request received August 9, 1995, the Division is forwarding the
subject permit modifications. The only change in this permit regards the facility name. Please
insert the enclosed pages and discard the old sheets. All other terms and conditions in the original
permit remain unchanged and in full effect. This permit modification is issued pursuant to the
requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement
between North Carolina and the U. S. Environmental Protection Agency dated December 6, 1983.
If any part of this modification is unacceptable to you, you have the right to an adjudicatory
hearing upon written request within thirty (30) days following receipt of this letter. This request
must be in the form of a written petition, conforming to Chapter 150B of the North Carolina
General Statutes, and filed with the Office of Administrative Hearings, Post Office Drawer 27447,
Raleigh, North Carolina 27611-7447. Unless such demand is made, this decision shall be final and
binding.
If you have any questions concerning this permit, please contact Sue Thomas at telephone
number [phone], extension 538.
TEX
L7 E 1- I N 1=1
October 10, 1995
Subject: Permit Modification -Name Change
Clariant Corporation, #NC0004375
(formerly Sandoz Chemicals Corp.)
Mecklenburg County
Sincerely,
Original Signed By
David A. Goodrich
A. Preston Howard, Jr., P.E.
cc: Central Files
Mooresville Regional Office, Water Quality Section
Permits and Engineering Unit
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

Permit No. NC0004375
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL MANAGEMENT
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1,
other lawful standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Clariant Corporation
is hereby authorized to discharge wastewater from a facility located at
Mt. Holly Plant
NC Highway 27
north of Charlotte
Mecklenburg County
to receiving waters designated as the Catawba River in the Catawba River Basin
in accordance with effluent limitations, monitoring requirements, and other conditions set forth in
Parts I, II, and III hereof.
This permit shall become effective October 10, 1995
This permit and the authorization to discharge shall expire at midnight on August 31, 1996
Signed this day October 10, 1995
Original Signed By
David A. Goodrich
A. Preston Howard, Jr., P.E., Director
Division of Environmental Management
By Authority of the Environmental Management Commission

A
Permit No. NC0004375
SUPPLEMENT TO PERMIT COVER SHEET
Clariant Corporation
is hereby authorized to:
1. Continue to operate a 3.9 MGD wastewater treatment facility ((mtfall 001) consisting of two
basins for biological waste treatment, stormwater equalization basin for nonalkaline wastewater,
stormwater equalization basins for alkaline wastewater, gravity secondary clarifiers, acid
neutralization, gravity primary clarifiers, air stripper, sludge dewatering, effluent polishing pond,
staged discharge facility including effluent storage, and post aeration, and, treat herbicide
manufacturing wastewater, with discharge to the acid sewer and thence to the 3.9 MGD treatment
plant described under outfall 001 (outfall 002), at a site located at Mt. Holly Plant, NC Highway
27, north of Charlotte, Mecklenburg County (See Part III of this Permit), and
2. After receiving an Authorization to Construct from the Division of Environmental Management,
construct additional facilities necessary for the pretreated pesticide manufacturing wastewater
discharge and, relocate outfall 001 discharge point with no change in limitations required, and,
3. Discharge from said treatment works at the location specified on the attached map into the Catawba
River which is classified Class WS-III waters in the Catawba River Basin.

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DIVISION OF ENVIRONMENTAL MANAGEMENT
July 14, 1993
MEMORANDUM
TO: Greg Nizic
THROUGH: Don S
FROM: Ruth Swanela k�5
SUBJECT: Sandoz Chemicals Corp
NPDES No. NC0004375
Mecklenburg County
Catawba River (030834)
•
I have reviewed Sandoz Corporation's request for a permit modification for the total phenols limit.
A review of the existing information indicates that the modification should not have detrimental
effects on water quality, and the limit should be revised to 3.91b/day. Taste and odor problems at
water supply intakes are caused by chlorinated phenols, and many of these are limited through the
OCPSF guidelines.
If you have any questions, please call me at extension 503.
cc: Mike Parker, MRO
Central Files

DIVISION OF ENVIRONMENTAL MANAGEMENT
MEMORANDUM
To:
From:
Subject:
June 14,1993
Ruth Swanek
Instream Assessment Unit
Greg Nizich !v
Permits and Engineering
Permit Modification
NPDES Permit #NC0004375
Sandoz Chemicals Corp
Mecklenburg County
Please review the attached request from Sandoz Chemicals Corp. for a permit
modification to the total phenols limit in their existing permit. Please advise if additional
information is required.
Enclosure
cc: Rex Gleason, Mooresville Regional Office
( au-p)Cetkp) -4- (pw)(CLO) (0d)(Cd)
(iit,t(N)(0) (u.040c1.5)(CA), Lio.Dcf5)0. .IA51 )
CtA) i�q ,tl.� � 3q Ibld

MEMO
DATE: 211u193
TO: r vor SUBJECT: Sandoi- chefbis JtA'+T
�l l archer of & s dox, came. r n 1oda . Their phcnb1
hm1 f (loco babe.d on 76)16 ram- 31)Qa Loc. do nom
(C1005 bato24 on re tecQ &rn Min. �.olan d WO. .iZ #)eic-
av ' ason 1 cannot c han a l.* rnd ?
of o L 4-e rn 5 a*f ack. d leer. Sandoz.
West utiformuLd
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cftsc�ss u)tts-h you chef bast. inAn
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From:
��..
North Carolina Department of Environment,
Health, and Natural Resources �,��p,�,

a
SANDOZ CHEMICALS CORPORATION
4000 MONROE ROAD, CHARLOTTE, NC 28205
WILLIAM M. ARCHER, III
EXECUTIVE DIRECTOR
ENVIRONMENTAL AFFAIRS
TEL. [phone]
FAX [phone]
Cam-,
44- e'ic 1-43
a
A SANDOZ;
June 4, 1993
Mr. Dennis Ramsey
Assistant Chief of Operations
N. C. Div. Of Environmental Management
P. O. Box 29535
Raleigh, N. C. 27626-0535
Subject: NPDES Permit No. NC0004375
Request for modification of permit
Dear Mr. Ramsey:
Sandoz Chemicals Corporation hereby requests a modification of its NPDES Permit
NC0004375 to modify the effluent total phenols limit. Specifically, we request that the total
phenols mass limit be modified to a value determined using the 30Q2 of the receiving stream.
Our current NPDES permit, issued in July, 1991, includes a total phenols discharge monthly
average limit of 1.8 pounds per day that is based on the minimum daily average river flow of
the Catawba River.
The total phenols limit is based on meeting a 1 ug/1 total phenols standard in the river
to protect water supplies from objectionable taste and odors (aesthetic quality). North Carolina
Water Quality Standards specify that aesthetic quality is to be protected using the 30Q2 flow of
the receiving stream. Because the receiving stream, the Catawba River, is flow regulated and
an official 30Q2 flow was not available during permit issuance in 1991, the flow criteria used
to calculate the total phenol allocation for our permit was the minimum daily average flow of
the river, 329 cfs. Acting on our request, USGS has now established a 30Q2 flow for the river
of 716 cfs using flow data from 1977 through 1992 (copy enclosed). Based on this new
information, we request that our permit be modified to base our total phenols mass limit on the
30Q2 flow of 716 cfs. This new flow basis translates into a total phenols monthly average limit
of 3.9 pounds per day for us.
In addition to total phenols, the permit also contains OCPSF based limits for eight
individual phenolic compounds and monitoring requirements for five others. These requirements
would be unchanged by our modification request.

. SANDOZ
We have discussed the possibility of modifying the permit phenols limit with Richard
Bridgeman of the Regional Office. He recommended that, given the new 30Q2 information, we
request a permit modification through your office. Please contact me if you need additional
information or have any questions.
Sincerely,
4-
William M. Archer
enc.
cc: Ms. Ruth Swanek w/enc.
N. C. Div. of Environmental Management
P. O. Box 29535
Raleigh, N. C. 27626-0535
cc: Mr. Rex Gleason w/enc.
N. C. Div. of Environmental Management
P. O. Box 950
Mooresville, N. C. 28115

•
+_
United States Department of the Interior
GEOLOGICAL SURVEY
WATER RESOURCES DIVISION
Post Office Box 30728
Raleigh, North Carolina 27622
Mr. J. Paige Straley
Corporate Environmental Manager
Sandoz Chemicals Corporation
P.O. Box 669246
Charlotte, North Carolina 28266
TAKE
I
MI RKA_
® =I •
February 2, 1993
Dear Mr. Straley:
In response to your September 8, 1992, request for low -flow data for the Catawba River
at North Carolina Highway 27, I have enclosed an estimate of the 30-day, 2-year low
flow computed from the Duke Power Company Mountain Island Lake discharge data (1977-
1992) which you provided with your letter of December 7, 1992. The estimate is adjusted
for intervening drainage.
In addition to the normal variations caused by'weather, the estimation of low flows on
regulated streams is highly dependent on regulatory patterns and reservoir operations.
The enclosed estimate is developed from the most recent 16 years of discharge data and
reflects reservoir operations from that period. No level of accuracy is assigned to the
computed statistic.
The U.S. Geological Survey provides timely water -resources information and data through
a variety of scientific and technical publications and data reports. For many years,
the Survey also has processed special requests for water -resources information free of
charge. Because of the increase in volume of special requests along with budget
reductions imposed by the Gramm -Rudman -Hollings Budget Deficit Reduction Act, the
Survey will no longer be able to process special requests free of charge.
A charge for accessing and processing information has been assessed to partially offset
these costs. Your requested data and an invoice covering processing costs for these
data are attached. Please forward the original bill with your check to the U.S.
Geological Survey, MS 271, 12201 Sunrise Valley Drive, Reston, Virginia 22092.
#212

These data are preliminary and subject to revision pending approval for
publication by the Director of the U.S. Geological Survey, and are made
Available through our cooperative program of water -resources investigations
With the North Carolina Department of Environment, Health, and Natural
Resources.
If you have any questions regarding this information, please contact us.
Sincerely,
obert bl�fi R.
oR. Mason, Jr.
Hydrologist
Enclosures
Copies to: Mr. John N. Morris, Director
Division of Water Resources
North Carolina Department of
Environment, Health, and
Natural Resources
Raleigh, NC
Mr. Steve Bevington
Division of Environmental Management
North Carolina Department of
Environment, Health, and
Natural Resources
Raleigh, NC
A.E. Fogleman, WRD
Raleigh, NC

ap
1
'REQUEST NO: 91545
SOURCE: INDUSTRY
SITE NO: 1 DATE: 2/ 4/93
ACTION: EXISTING
STATION NUMBER: 0214280800 TYPE STATION: 20
STATION NAME: CATAWBA R AT NC 27 AT MT HOLLY, NC
LOCATION: AT NC 27 AND 0.6 MI E OF MT HOLLY, NC
LATITUDE: 351752 LONGITUDE: 810014
QUADRANGLE NUMBER: F14SE
COUNTY CODE: 071
STATE CODE: 37 DISTRICT CODE: 37
HYDROLOGIC UNIT CODE: 03050101 NRCD BASIN CODE: 030833
DRAINAGE AREA: 2003.00
AVERAGE FLOW:
7Q10 MIN FLOW:
(SUMMER)
30Q2 MIN FLOW: 716. ['A]
7Q10 MIN FLOW: [ ]
(WINTER)
7Q2 MIN FLOW: [ ]
NOTES:
[A] Estimate is based on records collected at or near the site.
[B] Estimate is based entirely on runoff observed at nearby streams.
[C] Estimate based on procedures given in Open -File Report 90-399
"Low -Flow Characteristics of Streams In North Carolina"
[D] Estimate based on procedures given in Open -File Report 90-399 and
in conjuction with records collected at or near the site.
1
***** These data are provisional pending approval by the Director,USGS ******
REMARKS:
REQUESTOR--SANDOZ CHEMICAL CORPORATION
Entered by: AF
Fee charged: 125

Pay s',
Solilt.
t r/i �lf ,/2 .4f ►14
Eno" lClvtah
7(Ke
Teat
State of North Carolina
Department of Environment, Health and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor George T. Everett, Ph.D.
William W. Cobey, Jr., Secretary
January 27, 1992
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. W. M. Archer
Sandoz Chemicals Corporation
PO Box 669246
Charlotte, NC 28266
Subject: NPDES Permit No. NC0004375
Sandoz Chemicals Corporation
Mecklenburg County
Dear Mr. Archer:
Director
In accordance with your Petition for Contested Case Hearing filed on August 7, 1991, we
are forwarding herewith a modification to the subject permit. This modification is to delete the
mercury limit in the permit and to replace it with a monthly monitoring requirement. Attached
are revised effluent pages for outfall 001 only. These sheets should be placed in the permit and
the current outfall 001 sheets discarded.
All other terms and conditions contained in• the original permit remain unchanged and in
full effect. These modifications are issued pursuant to the requirements of North Carolina General
Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the U. S.
Environmental Protection Agency dated December 6, 1983.
If any terms or conditions adjudicated that were resolved by this modification are
unacceptable to you, you should notify us within thirty (30) days following receipt of this letter.
Unless such demand is made, this decision shall be final and binding. If this permit modification
is acceptable, Sandoz Chemicals Corporation must complete the attached Notice of Withdrawal of
Petition form within 30 days of receipt of this modification and submit one copy to the Attorney
General's Office as specified on the withdrawal form and one co to this division.
Pollution Prevention Pays
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]
An Equal Opportunity Affirmative Action Employer
%;s i s
ize ; v,q don -e
16Y our ah}orhey

Mr. Archer
• Page Two
If you have any questions concerning this permit, please contact Mr. Dale Overcash at
telephone number 919/733-5083.
-1.1g.,
cc: Mr. Jim Patrick, EPA
Mooresville Regional Office
Mecklenburg County Department of Environmental Protection
Permits and Engineering Unit
Compliance
Central Files
George T. Everett
,84,1
.

A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL Permit No. NC0004375
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from
outfall(s) serial number 001. Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristics
Flow
BOD, 5 Day, 20 °C*****
Total Suspended Residue
NH3 as N
Dissolved Oxygen
Fecal Coliform
Total Phosphorus
Total Nitrogen (NO2+NO3+TKN)
OOD
MBAS
Manganese
Lbs/day.
Discharge Limitations
Monitoring
Units (specify) Measurement
Mon. Avg. Daily Max Mon. Avg, Daily Max. Frequency
3.9 MGD Continuous
852.0
976.0
651.0
2236.0
2928.0
977.0
Daily**
Daily**
Daily**
Daily**
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Requirements
Sample *Sample
Type Location
Recorder I or E
Composite E,U,D
Composite E
Composite E,U,D
Grab E,U,D
Grab E
Composite E
Composite E
Composite E
Composite E
Composite E
* Sample locations: E - Effluent, I - Influent, U - Upstream at NC Highway 27, D - Downstream at I-85
Upstream and downstream samples for BOD5, NH3 as N, dissolved oxygen, temperature, conductivity, and pH shall be collected three times
per week during June, July, August, and September and once per week during the remaining months of the year.
** Daily is defined as every day except Saturday, Sunday, and legal holidays.
*** Chronic Toxicity (Ceriodaphnia) P/F at 1.8%; March, June, September, and December; See Part III, Condition D.
* ** * See Part III, Condition E.
***** Staging Requirements (Applicable April 1 - October 31) - See Part III, Condition F.
+ Weekly average limit
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored daily at the effluent, upstream, and
downstream by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL Permit No. NC0004375
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from
outfall(s) serial number 001. (Continued)
Effluent Characteristics
Iron
Chlorides
Sulfate
Mercury
Conductivity
Temperature
Total Phenols
Chronic Toxicity***
Pollutant Analysis****
4-chloro-3-methylphenol
2-methylphenol
4,6-dimethylphenol
Pentachlorophenol
2,4,5-trichlorophenol
Lbs/day,
Discharge Limitations
Other Units (specify)
Mon. Avg. Daily Max Mon. Avg. Daily Max.
1.8
3.6
Monitoring
Measurement
Frequency
Monthly
Monthly
Weekly
Monthly
*
Daily**
Weekly
Quarterly
Annually
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Requirements
Sample *Sample
Type Location
Composite E
Composite E
Composite E
Composite E
Grab U,D
Grab E, U, D
Grab E
Composite E
E
Grab E
Grab E
Grab E
Grab E
Grab E

EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL
During the period beginning on the effective date of the permit and lasting until expira
Permittee is authorized to discharge from outfall serial number 001. (Continued) Such
shall be limited and monitored by the permittee as specified below:
NC0004375
tion, the
discharges
Effluent Characteristics Mon. Avg. Daily Max. Measurement Sample *Sample
lbs/day lbs/day Frequency Type Location
Acenaphthene** 0.39 0.50 Quarterly Grab E
Acrylonitrile 1.69 4.30 Quarterly Grab E
Benzene 0.75 2.70 Quarterly Grab E
Carbon Tetrachloride 0.32 0.67 Quarterly Grab E
Chlorobenzene 0.31 0.57 Quarterly Grab E
1,2,4-Trichlorobenzene 1.20 2.46 Quarterly Grab E
Hexachlorobenzene 0.26 0.49 Quarterly Grab E
1,2-Dichloroethane 1.20 3.71 Quarterly Grab E
1,1,1-Trichloroethane 0.37 0.95 Quarterly Grab E
Hexachloroethane 0.39 0.95 Quarterly Grab E
1,1-Dichloroethane 0.39 1.04 Quarterly Grab E
1,1,1-Trichloroethane 0.37 0.95 Quarterly Grab E
Chloroethane 1.83 4.72 Quarterly Grab E
Chloroform 0.37 0.81 Quarterly Grab E
2-Chlorophenol 0.62 1.95 Quarterly Grab E
1,2-Dichlorobenzene 1.57 3.32 Quarterly Grab E
1,3-Dichlorobenzene 0.62 0.90 Quarterly Grab E
1,4-Dichlorobenzene 0.31 0.57 Quarterly Grab E
1,1-Dichloroethylene 0.28 0.44 Quarterly Grab E
1,2-trans-Dichloroethylene 0.37 0.95 Quarterly Grab E
2,4-Dichlorophenol 0.77 2.22 Quarterly Grab E
1,2-Dichloropropane 2.69 4.05 Quarterly Grab E
1,3-Dichloropropylene 0.51 0.77 Quarterly Grab E
2,4-Dimethylphenol 0.36 0.71 Quarterly Grab E
2,4-Dinitrotoluene 1.99 5.03 Quarterly Grab E
2,6-Dinitrotoluene 4.40 11.28 Quarterly Grab E
Ethylbenzene 0.65 2.20 Quarterly Grab E
Fluoranthene 0.47 1.20 Quarterly Grab E
Methylene Chloride 0.70 1.57 Quarterly Grab E
Methyl Chloride 1.51 3.34 Quarterly Grab E
Hexachlorobutadiene 0.35 0.86 Quarterly Grab E
Naphthalene** 0.45 0.50 Quarterly Grab E
Nitrobenzene 0.48 1.20 Quarterly Grab E
2-Nitrophenol 1.23 2.08 Quarterly Grab E
4-Nitrophenol 2.17 3.74 Quarterly Grab E
2,4-Dinitrophenol 2.15 3.71 Quarterly Grab E
4,6-Dinitro-o-cresol 1.55 5.50 Quarterly Grab E
Phenol 1.56 2.70 Quarterly Grab E
Bis(2-ethylhexyl)phthalate 1.81 4.91 Quarterly Grab E
Di-n-butyl phthalate 0.48 1.00 Quarterly • Grab E
Diethyl phthalate 1.43 3.57 Quarterly Grab E
Dimethyl phthalate 0.33 0.83 Quarterly Grab E
Benzo(a)anthracene** 0.31 0.50 Quarterly Grab E
Benzo(a)pyrene** 0.40 0.50 Quarterly Grab E
(Continued)

Effluent Characteristics
3,4-Benzofluoranthene**
Benzo(k)fluoranthene**
Chrysene**
Acenaphthylene**
Anthracene**
Fluorene**
Phenanthrene**
Pyrene**
Tetrachloroethylene
Toluene
Trichloroethylene
Vinyl Chloride
Total Cyanide
Mon. Avg. Daily Max. Measurement Sample *Sample
lbs/day lbs/day Frequency Type Location
0.40
0.39
0.39
0.39
0.39
0.39
0.39
0.44
0.39
0.53
0.37
1.82
7.39
0.50
0.50
0.50
0.50
0.50
0.50
0.50
0.50
0.99
1.63
0.95
4.70
9.01
*Sample Location: E-Effluent
**These parameters are water -quality limited.
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
E
E
E
E
E
E
E
E
E
E
E
E
E

MEMORANDUM
TO:
DIVISION OF ENVIRONMENTAL MANAGEMENT
September 26, 1991
Dale Overcash
THROUGH: Trevor Clements
FROM:
SUBJECT:
Ruth Swanek
Sandoz Chemical Company
NPDES No. NC0004375
Permit Adjudication
Mecklenburg County
I have reviewed Sandoz' petition filed with the Office of
Administrative Hearings. The mercury limit may be dropped as it
was based on one reading at detection level. However, the facility
must continue to monitor for mercury in its effluent, and the
monitoring should be done using the EPA approved method with the
lowest detection level (currently at 0.2 ug/I).
If you have any questions, please contact me at extension 503.
cc: Rex Gleason

Memorandum
To:
Division of Environmental Management
September 17, 1991
Trevor Clements,
Assistant Chief for Technical Support
Technical Support Branch
From: Donald Safrit, Supervisor
Permits and Engineering Unit
Subject: Sandoz Chemical Company
Permit No. NC0004375
Mecklenburg County
B
RECEIVED
SEP 1 8 1991
TECHNICAL SUPPORT BRANCH
As per current procedures, please review the attached petition filed with the Office of
Administrative Hearings. Please evaluate the objections raised by the permittee and
provide me with your comments within ten (10) working days (based upon your receipt
If you have any questions regarding this matter, please do not hesitate to contact Dale
Overcash at 733-5083.
cc: Office of the Attorney General
Permits and Engineering Unit
Dale Overcash

'l
STATE OF NORTH CAROLINA
COUNTY OF MECKLENBURG
FILED
OFF!CE of
AUGIu 8 A:11'
IN THE OFFICE OF
ADMINISTRATIVE HEARINGS.
91 EHR 0746
SANDOZ CHEMICALS CORPORATION )
Petitioner )
NOTICE OF.CONTESTED CASE
_pAv• AND ASSIGNMENT
N. C. DEPARTMENT OF ENVIR4�PCIVA
MAC��RYG.S. �150B-23, 33 (b) (4)
AND NATURAL RESOURCES J. M. KUSZAJ)
Respondent )
NOTICE IS HEREBY GIVEN that a petition for aacontested
cas
hearing pursuant to G.S. 150B-23(a) was filed in acceptedby the
Office of Administrative Hearings on August 9,
1991. In accordance
with G.S. 150B-23(a) and 26 NCAC 3 .0003, Robert Roosevelt
Reillin yis
judge Administrative Law Judge,has been assigned to preside
case. The administrative law may be contacted by mail at P. O.
Drawer 27447, Raleigh, N.C. 27611-7447, and the telephone .number is
919/733-2698.
The Respondent shall submit within 10 days a copy of the
document constituting agency action which caused the filing .of the
Petition.
A copy of any document or other item filed with the Office of time
Administrative Hearings should be sent to the other
orty ifthe address
of filing. If a party changes his mailing address
is incorrect, the Office of Administrative Hearings must be notified
of the new or corrected address.
OTE:
You may receive an Order fo searing Statements to
ich you must respond within 30 days.
This the %r day of , 1991.
Julian_ Mann, III
Chief Administrative Law Judge
Jaittallt___
Ddan C. Farrar
Chief Hearings Clerk
P.O. Drawer 27447
Raleigh, N.C. 27611-7447
919/733-0926

-2-
On this date mailed to:
James M. Kuszaj
Ogletree Deakins Nash Smoak
and Stewart
P. 0. Box 31608
Raleigh, NC 27622-
Attorney for Petitioner
William W. Cobey Jr., Sec.
N. C. Department of Environment, Health
and Natural Resources
Attention: John Hunter
512 North Salisbury St.
Raleigh, NC 27611-
Respondent

LAW OFFICES
OGLETREE, DEAKINS, NASH, SMOAK & STEWART
4101 LAKE BOONE TRAIL
POST OFFICE BOX 31608
RALEIGH, NORTH CAROLINA 27622
NORTH CAROLINA TELEPHONE [phone]
ATTORNEY GENE2AL'S OFFICE FAX [phone]
AHr; n 9 1,391
JAMES M. KUSZAJ, PH.D.
P A R T N E'F.NVIRONMENTAL PROTECTION SECTION
RECEIVED
August 9, 1991
John C. Hunter, Esquire
Registered Agent
Office of General Counsel
Department of Environment, Health & Natural Resources
Archdale Building, Room 1442
512 North Salisbury Street
Post Office Box 27687
Raleigh, North Carolina 27611
Dear Mr. Hunter:
AUG 09:1991I
df-
OTHER OFFICES:
GREENVILLE, SOUTH CAROLINA
WASHINGTON, D. C.
ATLANTA, GEORGIA
COLUMBIA, SOUTH CAROLINA
NASHVILLE. TENNESSEE
ALBANY, NEW YORK
Re: Petition for Contested Case
Enclosed is a copy of a Petition for a Contested Case Hearing. The
undersigned represents Petitioner in this matter.
Sincerely,
OGLETREE, DEAKINS, NASH,
SMOAK AND STEWART
72) .
es M. Kuszaj
Sfate Bar #14006
4101 Lake Boone Trail, Suite 511
Post Office Box 31608
Raleigh, North Carolina 27622
[phone]
•

STATE OF NORTH CAROLINA
• COUNTY O F. (1) Mecklenburg
(2)Sandoz Chemicals Corporation
Petitioner,
(Your Name)
VERSUS
(3)Dept. of Environment, Health &
Natural Respondent. Resources
(The State Agency or Board about which you arc
complaining)
)
)
)
) PETITION
) . FORA .
) CONTESTED CASE HEARING
I hereby ask for a contested case hearing as provided for by GS. ISOB-23 because the Dept. of Environment
(4) Health & Natural Resources has (briefly state facts showing how you believe you have
(name of agency)
been harmed by the state agency or board)
issued Petitioner NPDES Permit No. 000.4375 with permit conditions that are
arbitrary, capricious and not required by law.or regulation. Petitioner's specific
objections to the permit include but are not necessarily limited to the following:
($ E E ATTACHMENT)
(if more space it needed. use additional sheets and attach)
(5)
(Check all that apply)
Because of these facts. the agency has:
X deprived me of property;
ordered me to pay a fine or civil penalty; or
—has otherwise substantially prejudiced my rights; and based on these facts the agency has
exceeded its authority or jurisdiction;
X acted erroneously;
failed to use proper procedure;
—X—acted arbitrarily or capriciously; or
X failed to act as required by law or rote.
VERIFICATION
I. the undersigned, first being duly sworn, say that this petition is true to my own knowledge. except as to matters
stated on information and belief. and as to those, 1 believe there to be true.
SWORN TO AND SUBSCRIBED BEFORE ME
(11)
(12)
(13)
o/f/D
(7)
Title of person 4icthorired to administer oaths
(14) My Commission Expires: (0 i 219)
(15) (Seal)
(6)
el2/q/
LILk
Your Signature
(8). Y•i.Ce president Operations
Sandoz Chemicals Corporation
(9) 4000 Monroe Road, Charlotte, NC 28205
Your Address
(10) Area Codc Z04) 331-7088
• Your Telephone Number
Mail the original and one copy to the Office of Administrative Hearings, P. O. Drawer 27447, Raleigh. N.C.
27611-7447 and mail a copy to the State agency involved.
NORTH CAROLINA
i - ATTORNEY GENE.",AL'S OFFICE
tk - (revised 02-27-91) t! ! r n 9 1991
ENVIRONMENTAL PROTECTION SECTION
- RECEIVED
..
H-06

Attachment
I) Insufficient time is allowed for Petitioner to install control equipment to meet
the limits for 2,4-Dinitrophenol and 4-Nitrophenol, and
41
2) The limit for Mercury is unnecessary because Petitioner does not discharge
Mercury.
Pursuant to G.S. 150B-3, the filing of this Petition stays the September 1, 1991 effective
date of NPDES Permit No. NC0004375.

a.
CERTIFICATE OF SERVICE
I certify that this Petition for a Contested Case Hearing has been served on
the parties named below by hand delivering copies thereof to the offices of
A
Dean C. Farrar
Chief Hearings Clerk
Office of Administrative Hearings
Post Office Drawer 27447
Capehart-Crocker House
424 North Blount Street
Raleigh, North Carolina 27611-7447
John C. Hunter, Esquire
Registered Agent
Office of General Counsel
Department of Environment, Health & Natural Resources
Archdale Building, Room 1442
512 North Salisbury Street
Post Office Box 27687
Raleigh, North Carolina 27611
This the nto day of C.,
, 1991.
')19. ktk.
James M. Kuszaj
Attorney for Petitioner
State Bar Number 14006
Ogletree, Deakins, Nash, Smoak & Stewart
4101 Lake Boone Trail, Suite 511
Raleigh, North Carolina 27607
[phone]

TO:
FROM:
SUBJECT:
DATE:
SANDOZ CHEMICALS CORPORATION
MT HOLLY PLANT
ENVIRONMENTAL AND SAFETY DEPT.
MEMORANDUM
MJ Smith, WM Archer, E. Coleman
JP Straley
Effluent testing for 2,4 DNP and Hg
August 2, 1991
Here are the results from four weeks of effluent testing, Tuesday
and Thursday grab samples, for 2,4 DNP, 4-nitrophenol, and Hg. The
testing was done in April and May, 1991. I received the last piece
of this data from General Engineering Labs recently --unacceptable
turnaround, and I warned them that this was the case.
The news on the Hg front is encouraging: none detected at 0.5 ppb
limit in all samples. With this kind of result, we should stay in
good compliance with the new permit, and potentially be able to
modify the permit to eliminate the Hg testing after one year's
worth of data.
The news on the 4-NP front is good. No hits above 100 ppb
(detection limit).
The news on the 2,4 DNP is that we will see spikes if we do not
pretreat. This should come as no surprise.
date
4-16
4-17
4-23
4-25
4-30
5-1
5-7
5-9
2,4 DNP conc. (ppb)
< 500
798
< 100
1547
601
4140
< 100
< 100
Call me if there are any comments.

SANDOZ CNEMICALS CORPORATION
4000 MONROE ROAD, CHARLOTTE, NC 28205
WILLIAM M. ARCHER, III
DIRECTOR
ENVIRONMENTAL AFFAIRS
TEL. [phone]
FAX [phone]
Subject: MT. HOLLY NPDES
ISSUED: JULY 12, 1991
8:1/
SANDOZ
Dr. James M. Kuszaj
Ogletree, Deakins, Nash, Smoak
P.O. Box 31608
Raleigh, NC 27622
Dear Jim:
As we discussed by phone, Sandoz Chemicals wishes to request an adjudicatory
hearing pertaining to two parameters contained in the new Mt. Holly permit. The items of
concern are the limits for 2,4-Dinitrophenol and the inclusion of Mercury in the permit as a
limited parameter.
We have known for some time that installation of an improved pretreatment system
would probably be necessary in order to meet the new limits for 2,4-dinitrophenol.
However, the type and size of the unit would depend on what limits were ultimately given
in the issued permits.
Because of the length of time that it has taken to issue a renewed permit (over 3/
years since application) and because of changes in rules, policies, and personnel at the
State, there has been considerable uncertainty in what the final permit limits would be.
Only in the last few months did we have any confidence that the numbers being proposed
represented the final limits.
Based on these limits we completed the design and pilot testing of a new carbon
pretreatment system to replace an older less efficient carbon treatment procedure.
Equipment has been ordered that should be delivered in September and installed by late
October or November. We have requested a Special Order by Consent from the Region
and from Raleigh. Raleigh has indicated it is a Regional decision to issue an SOC, and the
Region has been unwilling to issue an SOC unless an actual permit violation has occurred.
Paige Straley's letter to Rex Gleason (see attached) confirms this position.

r
i
•
r
Page 2
Dr. Kuszaj
Thus our reason for adjudicating the 2,4-Dinitrophenol limit is that we believe
reasonable time should be allowed after permit limits are finalized for the permittee to take
actions necessary for compliance. The appropriate mechanism to provide this time is a
Special Order by Consent.
The Mercury limit is one which we believe should not be included in the permit at
all. Mercury was added based on one effluent analysis collected for application renewal in
1987. Mercury was detected at 1.7 .ug/1 at that time. We have .pot detected Mercury in
analyses in 1990 and 1991, and believe it should be deleted from the permit. The attached
letters to DEHNR detail our concern.
Please let me know if this is sufficient information for Fling the adjudicatory
hearing request.
WMA/jsh
Attachment
Cc: W. Rankin
A. Donnarumma
M. Smith
P. Staley
M. Teague
Sincerely,
/47-Zia
William M. Archer

State of North Carolina
Department of Environment, Health and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor George T. Everett, Ph.D
William W. Cobey, Jr., Secretary Director
July 12, 1991
Bill Archer
P. O. Box 669246
Charlotte, NC 28266
Dear Mr. Archer.
Subject: Permit No. NC0004375
Sandoz Chemicals Corporation
Mecklenburg County
In accordance with your application for discharge permit received on September 1 , 1987,
we are forwarding herewith the subject state - NPDES permit. This permit is issued pursuant to
the requirements of North Carolina General Statute 143-215 .1 and the Memorandum of
Agreement between North Carolina and the US Environmental Protection agency dated December
6, 1983.
If any parts, measuretnent frequencies or sampling requirements contained in this permit are
`unacceptable to you, you have the right to an adjudicatory hearing upon written request within
thiitty (30) days following receipt of this letter. This request must be in the form of a written
petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed with the
Office of Administrative Hearings, Post Office Drawer 27447, Raleigh, North Carolina 27611
-7447. Unless such demand is made, this decision shall be final and binding.
Please take notice this permit is not transferable. Part II, E.4. addresses the requirements to
be followed in case of change in ownership or control of this discharge.
This permit does not affect the legal requirements to obtain other permits which may be
required by the Division of Environmental Management or permits required by the Division of
Land Resources, Coastal Area Management Act or any other Federal or Local governmental permit
that may be required.
If you have any questions concerning this permit, please contact Ms. Rosanne Barona at
telephone number 919/733-5083.
cc: Mr. Jim Patrick, EPA
Mooresville Regional Office
OriginalsignedBy
Donald Safrit for
George T. Everett
Pollution Prevention Pays
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

Permit No. NC0004375
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL MANAGEMENT
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1,
other lawful standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Sandoz Chemicals Corporation
is hereby authorized to discharge wastewater from a facility located at
Mt. Holly Plant
NC Highway 27
north of Charlotte
Mecklenburg County
to receiving waters designated as the Catawba River in the Catawba River Basin
in accordance with effluent limitations, monitoring requirements, and other conditions set forth in
Parts I, II, and III hereof.
This permit shall become effective September 1, 1991
This permit and the authorization to discharge shall expire at midnight on August 31, 1996
Signed this day July 12, 1991
Orieral Signed
8y
Donald
George T. Everett, Director
Division of Environmental Management
By Authority of the Environmental Management Commission

Permit No. NC0004375
SUPPLEMENT TO PERMIT COVER SHEET
Sandoz Chemicals Corporation
is hereby authorized to:
1. Continue to operate a 3.9 MGD wastewater treatment facility
basins for biological waste treatment, stormwater equalization {basin foutfall or consisting of two
stormwater equalization basins for alkaline wastewater, gravity secondarycla�rifi rs wastewater,
neutralization, gravity primary clarifiers, air stripper, sludge dewatering, ffluent d
staged discharge facility including effluent storage, and post aeration, and,treat herbicide
bdpond,
manufacturing wastewater, with discharge to the acid sewer and thence to the 3.9 Dt
plant described under outfll 001(outfall 002), at a site located at Mt. HollyMGD treatment
27, north of Charlotte, Mecklenburg County (See Part III of this Permit), Plant, NC Highway
), and
2. After receiving an Authorization to Construct from the Division of Environmental
construct additional facilities necessary for the pretreated pesticide manufacturin Management,
discharge and, relocate outfall 001 discharge point with no changelimitations in g w.water
regred, and,
3. Discharge from said treatment works at the location specified on the attach
River which is classified Class WS-III waters in the Catawba River Basin map into the Catawba

A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL Permit No. NC0004375
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from
outfall(s) serial number 001. Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristics Discharge Limitations Monitoring Requirements
Lbs/day, Units (specify) Measurement Sample, *Sample
Mon. Avg. Daily Max Mon. Avg, Daily Max. Frequency Type Location
Flow 3.9 MGD Continuous Recorder I or E
BOD, 5 Day, 20 °C***** 852.0 2236.0 Daily** Composite E,U,D
Total Suspended Residue 976.0 2928.0 Daily** Composite E
NH3 as N 651.0 977.0 Daily** Composite E,U,D
Dissolved Oxygen Daily** Grab E,U,D
Fecal Coliform Monthly Grab E
Total Phosphorus Monthly Composite E
Total Nitrogen (NO2+NO3+TKN) Monthly Composite E
OOD Monthly Composite E
MBAS Monthly Composite E
Manganese Monthly Composite E
* Sample locations: E - Effluent, I - Influent, U - Upstream at NC Highway 27, D - Downstream at I-85
Upstream and downstream samples for BOD5, NH3 as N, dissolved oxygen, temperature, conductivity, and pH shall be collected three times
per week during June, July, August, and September and once per week during the remaining months of the year.
** Daily is defined as every day except Saturday, Sunday, and legal holidays.
*** Chronic Toxicity (Ceriodaphnia) P/F at 1.8%; March, June, September, and December, See Part III, Condition D.
**** See Part III, Condition E.
***** Staging Requirements (Applicable April 1- October 31) - See Part III, Condition F.
+ Weekly average limit
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored daily at the effluent, upstream, and
downstream by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL Permit No. NC0004375
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from
outfall(s) serial number 001. (Continued)
Effluent Characteristics
Iron
Chlorides
Sulfate
Mercury
Conductivity
Temperature
Total Phenols
Chronic Toxicity***
Pollutant Analysis****
4-chloro-3-methylphenol
2-methylphenol
4,6•dimethylphenol
Pentachlorophenol
2,4,5-trichlorophenol
j.bs/day,
Mon. Avg Pally Max
0.022+
1.8
3.6
Discharge Limitations Monitoring Requirements
Other Units (specify) Measurement Samale *Sammie
Mon. Avg, Daily Max. Freauency TXoe Location,
Monthly Composite E
Monthly Composite E
Weekly Composite E
2.4 u g / I Weekly Composite E
* ' Grab U,D
Daily** Grab E,U,D
Weekly Grab E
Quarterly Composite E
Annually E
Quarterly Grab E
Quarterly Grab E
Quarterly Grab E
Quarterly Grab E
Quarterly Grab E

A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL Permit No. NC0004375
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from
outfall(s) serial number 002. Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristics Discharge Limitations Monitoring Requirements
Lbs/day1 Units (specifyl Measurement Sample *Sample
Mon. Avg, Daily Max Mon. Avg, Daily Max. Frequency LW. Location
Flow Batch Recorder E
Total Suspended Residue 22.0 73.0 Weekly Composite** E
CCD 108.0 156.0 Weekly Composite** E
BOD, 5 Day, 20 °C 19.0 89.0 Weekly Composite** E
*Sample locations: E - Effluent, I - Influent
** Composite samples may be done as grab samples if the discharge is on a batch basis.

EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL NC00,
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge from outfall serial number 001. (Continued) Such discharges
shall be limited and monitored by the permittee as specified below:
Effluent Characteristics Mon. Avg. Daily Max.
lbs/day lbs/day
Acenaphthene**
Acrylonitrile
Benzene
Carbon Tetrachloride
Chlorobenzene
1,2,4-Trichlorobenzene
Hexachlorobenzene
1,2-Dichloroethane
1,1,1-Trichloroethane
Hexachloroethane
1,1-Dichloroethane
1,1,1-Trichloroethane
Chloroethane
Chloroform
2-Chlorophenol
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
1,1-Dichloroethylene
1,2-trans-Dichloroethylene
2,4-Dichlorophenol
1,2-Dichloropropane
1,3-Dichloropropylene
2,4-Dimethylphenol
2,4-Dinitrotoluene
2,6-Dinitrotoluene
Ethylbenzene
Fluoranthene
Methylene Chloride
Methyl Chloride
Hexachlorobutadiene
Naphthalene**
Nitrobenzene
2-Nitrophenol
4-Nitrophenol
2,4-Dinitrophenol
4,6-Dinitro-o-cresol
Phenol
Bis(2-ethylhexyl)phthalate
Di-n-butyl phthalate
Diethyl phthalate
Dimethyl phthalate
Benzo(a)an thracene* *
Benzo(a)pyrene**
0.39
1.69
0.75
0.32
0.31
1.20
0.26
1.20
0.37
0.39
0.39
0.37
1.83
0.37
0.62
1.57
0.62
0.31
0.28
0.37
0.77
2.69
0.51
0.36
1.99
4.40
0.65
0.47
0.70
1.51
0.35
0.45
0.48
1.23
2.17
2.15
1.55
1.56
1.81
0.48
1.43
0.33
0.31
0.40
0.50
4.30
2.70
0.67
0.57
2.46
0.49
3.71
0.95
0.95
1.04
0.95
4.72
0.81
1.95
3.32
0.90
0.57
0.44
0.95
2.22
4.05
0.77
0.71
5.03
11.28
2.20
1.20
1.57
3.34
0.86
0.50
1.20
2.08
3.74
3.71
5.50
2.70
4.91
1.00
3.57
0.83
0.50
0.50
Measurement Sample *Sample
Frequency Type Location
Quarterly Grab E
Quarterly Grab E
Quarterly Grab E
Quarterly Grab E
Quarterly Grab E
Quarterly Grab E
Quarterly Grab E
Quarterly Grab E
Quarterly Grab E
Quarterly Grab E
Quarterly Grab E
Quarterly Grab E
Quarterly Grab E
Quarterly Grab E
Quarterly Grab E
Quarterly Grab E
Quarterly Grab E
Quarterly Grab E
Quarterly Grab E
Quarterly Grab E
Quarterly Grab E
Quarterly Grab E
Quarterly Grab E
Quarterly Grab E
Quarterly Grab E
Quarterly Grab E
Quarterly Grab E
Quarterly Grab E
Quarterly Grab E
Quarterly Grab E
Quarterly Grab E
Quarterly Grab E
Quarterly Grab E
Quarterly Grab E
Quarterly Grab E
Quarterly Grab E
Quarterly Grab E
Quarterly Grab E
Quarterly Grab E
Quarterly Grab E
Quarterly 'Grab E
Quarterly Grab E
Quarterly Grab E
Quarterly Grab E
(Continued)

g it: Characteristics Mon. Avg. Daily Max. Measurement Sample *Sample
lbs/day lbs/day Frequency Type Location
3,4Benzofluoranthene** 0.40 0.50 Quarterly Grab E
Benzo(k)fluoranthene** 0.39 0.50 Quarterly Grab E
- Chrysene** 0.39 0.50 Quarterly Grab E
Acenaphthylene** 0.39 0.50 Quarterly Grab E
Anthracene** 0.39 0.50 Quarterly Grab E
Fluorene** 0.39 0.50 Quarterly Grab E
Phenanthrene** 0.39 0.50 Quarterly Grab E
Pyrene** 0.44 0.50 Quarterly Grab E
Tetrachloroethylene 0.39 0.99 Quarterly Grab E
Toluene 0.53 1.63 Quarterly Grab E
Trichloroethylene 0.37 0.95 Quarterly Grab E
Vinyl l Chloride 1.82 4.70 Quarterly Grab E
Total Cyanide 7.39 9.01 Quarterly Grab . E
*Sample Location: E Effluent
**These parameters are water -quality limited.

•
< Part HI Permit No. NC0004375
D. The effluent discharge shall at no time exhibit chronic toxicity in any two consecutive toxicity
tests, using test procedures outlined in:
1.) The North Carolina Ceriodaphnia chronic effluent bioassay procedure (North Carolina Chronic
Bioassay Procedure - Revised *September 1989) or subsequent versions.
The effluent concentration at which there may be no observable inhibition of reproduction or
significant mortality is 1.8% (defined as treatment two in the North Carolina procedure document).
The permit holder shall perform quarterly monitoring using this procedure to establish compliance
with the permit condition. The first test will be performed after thirty days from issuance of this
permit during the months of March, June, September, and December. 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 TGP3B. Additionally, DEM Form AT-1 (original) is to be sent to the following address:
Attention:
Environmental Sciences 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 sample must be measured and reported if chlorine is employed for
disinfection of the waste stream.
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 quarterly in the months specified above.
Should any test data from this monitoring requirement or tests performed by the North Carolina
Division of Environmental Management indicate potential impacts to the receiving stream, this
permit may be reopened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum
control organism survival and appropriate environmental controls, shall constitute an invalid test
and will require immediate retesting (within 30 days of initial monitoring event). Failure to submit
suitable test results will constitute noncompliance with monitoring requirements.
E. The permittee shall conduct a test for pollutants annually at the effluent from the treatment
plant. The discharge shall be evaluated as follows: 1) A pollutant analysis of the effluent must be
completed annually using EPA approved methods for the following analytic fractions: (a)
purgeables (i.e., volatile organic compounds); (b) acid extractables; (c) base/neutral extractables;
(d) organochlorine pesticides and. PCB's (e) herbicides; and (f) metals and other inorganics. The
Annual Pollutant Analysis Monitoring (APAM) Requirement Reporting Form A and
accompanying memo, to be provided to all discharges affected by this monitoring requirement,
describes the sampling and analysis requirements and lists chemicals to be included in the
pollutant analysis. This monitoring requirement is to be referred to as the "Annual Pollutant
Analysis Monitoring Requirement" (APAM).

2) Other significant levels of organic chemicals must be identified and approximately quantified.
For the purpose of implementing this requirement, the largest 10 GC/MS peaks in the purgeable,
base/neutral extractable, and acid extractable fractions (or fewer than 10, if less than 10
unidentified peaks occur) for chemicals other than those specified on the APA Requirement
Reporting Form A should be identified and approximately quantified as stated in the APAM
Reporting Form A instructions. This part (item 2) of the APAM requirement is to be referred to as
the "10 significant peaks rule".
F. Staging Requirements (Applicable April 1- October 31)
The operating day runs from 7:00 am to 7:00 am. Each day, the permittee will calculate a running
daily average stream flow as determined by turbine operation at Mt. Island Dam, leakage at the dam
(80 cfs), and the 7Q10 flow of Dutchman's Creek (15 cfs). Effluent release is to be controlled
such that projected release of BOD and ammonia, using the most recent analytical values for these
parameters, will not exceed the value given in the following formulas:
(1) When the daily river flow is calculated to be < or = 175 cfs: BOD5 + 0.54(NH3-N) <= 566.4
lb/day
(2) When daily average river flow is calculated to be > 175 cfs but < or = 250 cfs: BOD5 +
0.54(NH3-N) <= 1044 lb/day
The attached additional DMR sheet shall be used to monitor compliance with BOD and NH3
staging requirements during the summer (April 1- October 31)

State of North Carolina
Department of Environment, Health, and Natural Resource
Division of Environmental Health
Western Regional Office • Moore III
Black Mountain, North Carolina 28711
[phone]
James G. Martin, Governor
William W. Cobey, Jr., Secretary
June 28, 1991
MEMORANDUM
TO: Mr. M. Dale Overcash, P.E.
NPDES Permits Group Leader
Discharge Permits Unit
Division of Environmental Management
�2L6
FROM: Richard K. Rowed; Director
Division of Environmental Health
SUBJECT: Draft National Pollutant Discharge
Elimination System Permit
Sandoz Chemicals Corporation
Mecklenburg County
Permit No. NCR0004375
Richard K. Rowe
Division Director
RECEIVED r �
JU14 27 1991
CENTRAL FILE COPY
Reference is made to the above mentioned Draft National Pollutant Discharge
Elimination System Permit. We have reviewed this permit application and determined
that the existing discharge is approximately 2.5 miles upstream of the City of
Belmont's Raw Water Intake. The proposed relocation of the discharge point further
upstream would provide additional dilution time.
We concur with the issuance of this permit provided the facility is operated
and maintained properly, the stated effluent limits are met prior to discharge, and
the discharge does not contravene the designated water quality standards.
Copies of the results of the wastewater discharge priority pollutant analyses
• should be provided to the Division of Epidemiology on a routine basis so that the
Division's toxicologists can assess the health risks to downstream water users and
make recommendations on the next renewal of this permit.
If we can be of further assistance, please contact us.
RKR/EDH/ab
cc:
An Equal Opportunity Affirmative Action Employer

DIVISION OF ENVIRONMENTAL MANAGEMENT
June 11, 1991
MEMORANDUM
TO: Dale Overcash
THROUGH: Trevor Clement
FROM: Ruth Swanek ram-`=
SUBJECT: Sandoz Draft Permit Objections
NPDES No. NC0004375
Mecklenburg County
I have reviewed the May 23 letter submitted by Sandoz Chemicals
Corporation concerning its draft NPDES permit. Technical Support
has reviewed the mercury limit on numerous occassions, and still
believes the limit should remain in the permit. The limit will be
reviewed upon request of the facility after twelve months of data
have been submitted. If the facility disagrees with this permit
requirement, it should adjudicate the permit.
If you have any questions, please contact me at extension 503.

SANDOZCHEMICALS
Sandoz Chemicals Corporation Michael J. Smith
P.O. Box 669246 Plant Manager
Charlotte, North Carolina 28266 Mount Holly Plant
704.827.9651 or 704.822.2709
Fox 704.822.6529
TO: Paige Straley
FROM: Mike Smith
DATE: June 11, 1991
SUBJECT: New NPDES Permit - WMA Memo 6-7-91
Paige, please follow up on Bill's memo, particularly in
regard to the DNPE.
By copy of this memo, I am asking Reg Cranford and Keith
Parrott to advise of the future demand for DNPE and the
possibility of elimination of this product.
After you have some data on the NAA, let's review and
discuss our action plan.
Mike
aj
cc: W. Archer
R. Cranford
K. Parrott
A. Donnarumma

SANDOZ CHEMICALS CORPORATION
4000 MONROE ROAD, CHARLOTTE, NC 28205
WIWAM M. ARCHER, III
DIRECTOR
ENVIRONMENTAL AFFAIRS
TEL. [phone]
FAX [phone]
Subject: NEW NPDES PERMIT
SANDOZ
To: M. Smith
P. Straley
Cc: A. Donnarumma
M. Teague
R. Cranford
K. Parrott
In recent discussions at the Plant about our new NPDES permit, two production processes
were discussed that could impact waste constituents entering the system for treatment. These are
the AMXA process and the DNPE process.
As I understand, the AMXA process is slated to restart soon. The NAA intermediate step
of this process contributes a large quantity of acid to our system. This will show up as increased
hazardous waste generated and will produce significant amounts of gypsum sludge. There is also
evidence that this process contributes significant levels of biologically refractory organics to the
system. GC/MS analyses several years ago showed relatively large GC peaks that were identified
as two isomers of nitromethoxy aniline. (See Attached) These compounds likely originated from
the NAA process. Although not limited in the permit, these compounds may show up on our
APAM analyses. The AMXA process (along with DCMA crude) have been correlated with
ceriodaphnia chronic toxicity, though cause and effect have not been established. This information
is provided to ensure that the potential waste impacts of this production are considered in the
decision to restart this process. As a precaution, I also recommend that NAA filtrate from a lab
batch be analyzed for OCPSF organics to be sure this process will not contribute any of these
permit limited pollutants to the WWTP.
The DNPE process produces some DNP as a byproduct. This DNP is dissolved in the
alkaline filtrate that goes to the sewer. Because of the new low DNP limit, this process should not
be run again until a pretreatment procedure is established. A suitable pretreatment may consist of:
Acidifying filtrate to precipitate DNP
Filter out DNP (possibly for reuse)
Send acidified filtrate through DNP carbon system
Any pretreatment procedure would need to be verified analytically.
ieee,
Bill

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5ANDOZCHEMICALS
Sandoz Chemicals Corporation
P.O. Box 669246
Charlotte, North Carolina 28266
704.827.9651
FAX: [phone]
Mr. Dale Overcash, Supervisor
Permits Branch
NC Division of Environmental Management
P.O. Box 27687
Raleigh, NC 27611-7687
RE: Sandoz Chemicals Corporation, NPDES
Dear Mr. Overcash:
RECEIVE
MAY 24 1991
PERMITS & ENGINEERING
May 23, 1991
No. NC0004375
We have received the draft permit dated Apr
like to make the following comments:
RECEIVED
JUL 27 1991
CENTRAL FILE CORY
it 29, 1991 and woula
First, we would like to express our appreciation of your office's
cooperative attitude. Our previous comments have been received
with an open mind and incorporated into the permit where
appropriate. We are grateful for your consideration.
Sandoz has conducted a sampling program to measure the 2,4
dinitrophenol (2,4-DNP), 4-nitrophenol (4-NP), and mercury (Hg)
concentrations in the WWTP mixed liquor in order to check our
status with reference to the new permit. These show potential non-
compliance with respect to 2,4-DNP. The 4-NP and Hg data suggest
compliance with the proposed limits.
However, we again request that the State drop the proposed Hg
limitation. Five samples, taken in April and May 1991, showed no
detectable Hg at 0.5 ppb detection limit. Sandoz does not use Hg
in any processes, nor is Hg present in our caustic soda (a common
source of fugitive Hg). In your letter dated April 3, 1991 you
mentioned that Hg was quantified at 0.5 ppb (detection limit 0.5
ppb) on July 24, 1989. This was the middle analysis of a five-day
series. Our effluent plant has a retention time of three or four
days, and the fact that the prior and following analyses were
"below detection" argues that the finding of 0.5 ppb Hg was a
random instrumental variation. We think that a statistical
consideration of the record supports our contention that Hg is not
present in our effluent, and thus should not be present in the
permit.
Sandoz also questions the redefinition of the Hg monthly average to
a "weekly average limit". This part of the permit is inconsistent
with the definitions of concentration measurements on page 2 of 14.
Given a monitoring frequency of once per week, a weekly average has
the same effect as a daily maximum. A true monthly average, on the
other hand, is the average of four weekly samples, and is
consistent with the permit definitions.

RECEIVE
MAY 24 1991
Mr. Dale Overcash
PERMrrS & ENG! JEERING page two
May 23, 1991
We urge you to again review the carefully reasoned discussion of
our Hg limits in Mr. Archer's April 16, 1991 letter. We do not
believe the Hg limit is justified, but if it is to be imposed, we
sincerely believe that the appropriate discharge limitation should
be based on a monthly average.
Mr. Archer's April 16 letter suggested that a Special Order of
Consent (SOC) might be an orderly route to full compliance without
incurring an actual event of non-compliance. The Mooresville
Regional Office has indicated that they are unwilling to submit an
SOC on our behalf previous to the issuance of the permit. If
possible, we ask that the State, through Mr. Dennis Ramsay's
office, provide an SOC petition previous to the issuance of the
permit.
Sandoz policy is to operate in continuous compliance with all
environmental permits. We hope that your office, and Mr. Ramsay's
office, can be of help to us. In any case, Sandoz will continue to
search for alternatives which will allow continuous compliance.
Again, thank you for your consideration of our comments.
Sincerely,
A
Paige' Straley, /PE
Environmental Manaager
cc: MJ Smith
WM Archer
D Ramsey
R Gleason
file: wwtp\govt\npdes06.e91

Division of Environmental Management
May 3, 1991
MEMO TO: Dale Overcash
FROM: Rex Gleason
PREPARED BY: Michael Parker V
SUBJECT: Draft Permit Comments
Sandoz Chemicals Corporation
NPDES Permit No. NC0004375
Mecklenburg County
This office has conducted a review of the letter dated
April 9, 1991 from Mr. William Archer, Sandoz Chemicals
Corporation concerning the subject Permit and offers the
following comments and recommendations.
Upon reissuance of the Permit, Sandoz anticipates that
non compliance will occur with one or more proposed
parameters which are not contained in the current permit.
Because permit violations are only foreseen, this Office
does not feel that issuance of a Special Order by Consent is
appropriate at this time. Sandoz will have ample opportunity
to enter into a Consent agreement if and when they have
demonstrated an inability to comply with the proposed
effluent limitations.
With regard to Sandoz's request to modify the proposed
Mercury limit of 0.022 lb/day (daily maximum) to a monthly
average, no objection is offered provided concurrence from
Technical Support is received.
If you have any questions, please advise.
MLP/mlp
RECEIVED
JUL 27 1997
CENTRAL FILE COPY

State of North Carolina
Department of Environment, Health and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor George T. Everett, Ph. D.
Director
William W. Cobey, Jr., Secretary
(APR 2 9 1991
Dear Applicant:
Please find attached a DRAFT Permit and a public notice that have been prepared for
your facility by the Division of Environmental Management (DEM). I encourage you to review
these documents very carefully to ensure thorough understanding of the information, conditions,
and requirements contained therein. In completing your review, please be aware of the two
procedure changes described below that become effective on February 1, 1990.
The subject permit expiration date may reflect a period of less than five years. The
DEM has implemented a new NPDES permitting schedule that is directed toward organizing
permit issuance and review by major river basins within the State. The revised schedule will
allow the DEM to focus its resources on more efficient and effective NPDES permitting, and
allow for greater consistency in developing pollutant discharge limitations throughout each
river basin. In order to place the subject NPDES Permit within the proper cycle for its
corresponding river basin, it may be necessary to shorten the life of the permit to less than the
maximum allowable five year term as defined by North Carolina General Statute 143-215.1
(c) (5). In most cases, once a permit has been brought into the proper basin cycle, future
permits will be issued for the maximum five year period.
All questions or comments pertaining to any portion of the DRAFT Permit should be
directed to Mr. Dale Overcash of the NPDES Permits Group at the address or telephone number
listed below prior IQ the "Schedule to Issue" date in the public notice. Once a permit is issued,
except for typographical or technical errors, the permit may be appealed only through the legal
process. Such appeal would need to be made in the form of a written petition in accordance with
Chapter 150E of the North Carolina General Statutes and filed with the Office of Administrative
Hearings, PO Drawer 11666, Raleigh, NC 27611 within 30 days of permit issuance.
Thank you in advance for your cooperation in these matters.
Sincerely,
Steve W. Tedder, Chief
Water Quality Section
JULRECEIVED
2 7 1991
Pollution Prevention Pays
CENTRAP.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]L f�� COPY.
An Equal Opportunity Affirmative Action Employer

DIVISION OF ENVIRONMENTAL MANAGEMENT
April 22, 1991
MEMORANDUM
TO: Dale Overcash
THROUGH: Trevor Clements
FROM: Ruth SwanekK5
SUBJECT: Sandoz Draft Permit Objections
NPDES No. NC0004375
Catawba River (030834)
Mecklenburg County
I have reviewed the draft NPDES permit comments recently sub-
mitted by Sandoz and offer the following comments:
Compliance Schedule
Permits and Engineering should respond to this issue.
Mercury Limit
Sandoz may be given the option of receiving its mercury
concentration limit (2.4 ug/1) as a daily maximum value and its
loading limit (0.022 lb/day) as a weekly average. The facility
will be required to monitor' for mercury daily (e.g. Monday through
Friday). If Monday's sample, meets the weekly average limit of
0.022 lb/day,: then no more analyses are required for the week. If
Monday's sample exceeds the weekly average, then samples must be
analyzed for all days, and the weekly average and daily maximum
limits met. For compliance purposes, any concentration which is
less than detection should bd averaged in as zero for a given day.
Sandoz also stated inAts letter that the mercury limit should
be based on average river fldw since it is based on human health
criteria. At present, DEM only computes limits based on the aver-
age river flow if the parameter being limited is a carcinogen and
there is no corresponding aquatic life criteria that is more
stringent for that parameter.
If you have any questions or comments please contact me at
extension 503.
cc: Julia Storm

SANDOZCHEMICALS
Sandoz Chemicals Corporation
P.O. Box 669246
Charlotte. North Carolina 28266
704.827.9651
FAX: [phone]
Mr. Rex Gleason
NC Division of Environmental Management
P.O. Box 950
Mooresville, NC 28115
April 16, 1991
RE: Proposed pre -issuance SOC for Sandoz Chemicals' NPDES
permit.
Dear Mr. Gleason:
This letter is to document our telephone conversation of this date.
In our telephone conversation I informed you that Sandoz would very
likely not be able to meet all the parameters in our upcoming NPDES
permit renewal. I asked if the Regional Office was inclined to
bring a pre -issuance SOC before the Environmental Management
Commission.
You replied that the Regional Office policy was not to enter into
the SOC procedure until an actual permit violation had occurred.
Since the existing permit does not limit the parameters Sandoz
believes may cause a violation under the new permit, your opinion
was that there existed no cause to initiate an SOC.
It is Sandoz Chemicals Corporation policy not to violate any
environmental permit or regulation. Therefore, we will continue to
search for alternatives whereby we may avoid a violation.
If there are any questions, please do not hesitate to call me at
704 822 2701.
Sincerel
J. Paige traley, PE
Environmental Manager
cc: MJ Smith
WM Archer
file: wwtp\govt\npdes04.d91

SANDOZ CHEMICALS CORPORATION
4000 MONROE ROAD, CHARLOTTE, NC 28205
WILLIAMM. ARCHER, III
DIRECTOR
ENVIRONMENTAL AFFAIRS
TEL. [phone]
FAX [phone]
APR 1 0 1991
PERMITS & ENGINEERING
(324.1t.
Apr159,1991
SANDOZ
�)A-1ef/1ilQt�.
Mr. Dale Overcash, P.E.G•
42*
N.C. Div of Envir. Mgm. 4y
Supervisor, NPDES Permits Hod:. .t
512 N. Salisbury Street - J2
Raleigh, NC 27611 41,4144/4
j�
Re: NPDES Permit No. NC0004375
Sandoz Chemicals Corporation, Mecklenburg County
Dear Mr. Overcash:
to 11)14-11J"i`x
/,
Sandoz has received and reviewed the proposed NPDES Permit for our Mt. Holly
Plant. We appreciate the modifications that have been made in response to our comments on
the previous draft. As we have discussed with you by phone, two issues still remain
troublesome from our perspective.
One issue is the need for a compliance schedule or Special Order by Consent (SOC)
to allow time to install an improved pretreatment unit for 2,4,-dinitrophenol process wastewater
(which also contains some 2-nitrophenol and 4-nitrophenol). While we have conducted
treatability testing to learn the type of treatment we need, we have been hesitant to invest in
equipment until after the permit has been finalized, because a stricter limit might require
different equipment. We will need about 8-12 months from now to receive and properly install
the necessary equipment.
From talking with you, it is our understanding that a compliance schedule cannot be
included in the permit for OCPSF parameters. We have also talked with Mr. Mike Parker of
the Mooresville Regional Office and have been told that a SOC is not normally written for
situations where noncompliance is only foreseen. Instead, he indicated that the State could
issue a letter stating that it would not take enforcement action for some period of time. This
is not acceptable to Sandoz, because any exceedances would still be considered noncompliance
of the permit. By copy of this letter to Mr. Rex Gleason, we request that the Region
reconsider a SOC for this situation.
The second issue of concern to Sandoz is the Mercury limit. We appreciate the State's
willingness to reconsider the limit after one year. However, we have concerns about the setting
of this limit that is so close to the analytical detection limit for Mercury. We fear that a false
positive from instrument noise could result in a permit violation of the 0.022 Lb/day daily
maximum limit. As stated before, we believe the fact that we did not de ercury in
(-eve)
Ju, 27 1997
CENTRAL"it Copy

any samples we analyzed in 1990 is ample justification for deleting mercury as a limited
parameter. If limitations are retained, we believe that at the very least the 0.022 Lb/day limit
should be a monthly average rather than a daily maximum.
There are several justifications for changing the Mercury requirement. First, a monthly
average would greatly reduce the chances of a false positive detection causing a permit
violation. The cold vapor AA method, while capable of low detection, is subject to
considerable variability from instrument noise and interfering constituents which would make
it susceptible to false positives. Secondly, the State Mercury Water Quality Standard is
misleadingly listed as an aquatic toxicity standard, when it actually was derived from human
health considerations of fish consumption. The EPA criteria document explains that the 0.012
ug/1 criteria is to prevent unacceptable Hg bioaccumulation in fish tissue for human
consumption. The document also indicates that the 0.012 ug/1 value assumes bioaccumulation
for methylmercury, but that wastewater discharges are normally Mercury II, according to the
EPA document. A reasonable application of the Standard would be to set a daily maximum
limit based on a true aquatic organism toxicity criteria using the 7Q10 river flow. The 0.012
ug/1 limit could then be applied as a chronic human health toxic using the mean annual river
flow. If application of the Mercury Standard in this manner is complicated by its being listed
under aquatic toxicity in the State rules, the State should at the very least use its discretion to
apply the 0.012 ug/1 standard as a monthly average.
The draft permit did not specify a term for the permit. With the amount of effort that
both sides have invested in this permit, we request that it will be issued for the normal five
year duration.
Sandoz appreciates your consideration of these comments.
Sincerely,
William M. Archer
Cc: Mr. Rex Gleason
N.C. Div. of Envir. Mgm.
P.O. Box 950
Mooresville, NC 28115
RECEIVED
JuL z7
CENTRAL
At FILE COPY

State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor George T. Everett, Ph.D.
William W. Cobey, Jr., Secretary Director
April 3, 1991
Mr. J. Paige Straley
Sandoz Chemicals Corporation
PO Box 669246
Charlotte, NC 28266
Subject: NPDES Permit Application
NPDES Permit No. NC0004375
Sandoz Chemicals Corporation
Mecklenburg County
Dear Mr. Straley:
Reference is made to your letter of February 25, 1991 containing comments on the draft permit
for NPDES permit application NC0004375. The Division of Environmental Management (DEM)
has reviewed the comments in this letter. The items are addressed in the following :
(1) The word "north" refers to the plant location and is not a road direction. Also, the
Department of Transportation considers odd -numbered roads as north -south roads.
(2) The words "air stripper" have been added to the process description. The word "continue"
has been deleted with reference to the herbicide wastewater.
(3) The word "daily" has been defined on the effluent pages as every day except Saturday,
Sunday, and legal holidays.
(4) Upstream and downstream monitoring for phenols has been dropped.
(5) The total phenols limit will be left as 1.8 lb/day monthly average, 3.6 lb/day daily max.
The Division's Planning Branch is presently evaluating the State phenol standard and has
requested that monitoring for 4-chloro-3-methylphenol, 2-methylphenol,
4,6-dimethylphenol, pentachlorophenol, and 2,4,5-trichlorophenol using EPA method 604
be added to the permit. Monitoring should be done on a quarterly basis.
(6) Limits for 2-chlorophenol, 2,4-dichlorophenol, 2-nitrophenol, 4-nitrophenol,
2,4-dinitrophenol, 4,6-dinitro-o-cresol, and phenol have been corrected to account for
limits negotiated to include water from groundwater remediation.
(7) The daily maximum for chloroform has been corrected to 0.81 lb/day. ‘\15)
Pollution Prevention Pays
U�v 0 a
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] ` � CQ
An Equal Opportunity Affirmative Action Employer CEtat

(8)
(9)
The mercury limit was included in the permit as an effluent sample collected on 7/24/89
indicated a concentration of 0.5 mg/l. However, the Division will reevaluate the mercury
limit requirement upon request after one year of effluent monitoring in which the data
indicates that this parament can be dropped.
The flow frequency measurement has been changed to "batch", and the sample type as been
defined as " composite, or grab if the discharge is on a batch basis". The pH limit and
statement about floating solids and visible foam have been deleted. The limitation for
"Organic Pesticide Chemicals has been deleted. The combination of sludge generated from
the biological treatment of the waste with waste sludge from the main activated sludge
waste treatment plant for dewatering and disposal should be discussed with Ms. Carolyn
McCaskill, the supervisor of the State Engineering Review Group at 919/733-5083 ext.
540. This group is responsible for evaluation and permitting of sludge disposal plans.
(10) If results using the EPA approved analytical procedure having the lowest detection level
achieveable results in a result of "less than detectable", this result is considered as in
compliance. The result is not in compliance if a test with a higher detection level is used.
(11) The chronic toxicity language will remain the same. Toxicity questions may be discussed
with Mr. Ken Eagleson at 919/733-9960.
(12) The word "synthetic" has been deleted from special condition D. (annual pollutant analysis)
(13) Sludge disposal information is not included in NPDES permits. Sludge disposal is handled
separately in non -discharge permits.
A revised copy of the permit draft is attached. This draft also reflects the change of discharge
point requested on March 27, 1991. Please contact Rosanne Barona or me at 919/733-5083 to
discuss this letter.
Sincerely,
i( (It
M. Dale Overccaas1T
Supervisor, NPDES Permits
cc: Mooresville Regional Office
Technical Support Branch
Ms. Carolyn McCaskill
Permit File
,U, 2:7 'OSA
CENSRL FILE COPY

Permit No. NC0004375
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL MANAGEMENT
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1,
other lawful standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Sandoz Chemicals Corporation
is hereby authorized to discharge wastewater from a facility located at
Mt. Holly Plant
NC Highway 27
north of Charlotte
Mecklenburg County
to receiving waters designated as the Catawba River in the Catawba River Basin
in accordance with effluent limitations, monitoring requirements, and other conditions set forth in
Parts I, II, and III hereof.
This permit shall become effective
This permit and the authorization to discharge shall expire at midnight on
Signed this day
George T. Everett, Director
Division of Environmental Management
By Authority of the Environmental Management Commission
v
EW
3 u, 21 1991
CENTRAL FILE COP'

Permit No. NC0004375
SUPPLEMENT TO PERMIT COVER SHEET
Sandoz Chemicals Corporation
is hereby authorized to:
1. Continue to operate a 3.9 MGD wastewater treatment facility (outfall 001) consisting of two
basins for biological waste treatment, stormwater equalization basin for nonalkaline wastewater,
stormwater equalization basins for alkaline wastewater, gravity secondary clarifiers, acid
neutralization, gravity primary clarifiers, air stripper, sludge dewatering, effluent polishing pond,
staged discharge facility including effluent storage, and post aeration, and, treat herbicide
manufacturing wastewater, with discharge to the acid sewer and thence to the 3.9 MGD treatment
plant described under outfall 001 (outfall 002), at a site located at Mt. Holly Plant, NC Highway
27, north'of Charlotte, Mecklenburg County (See Part III of this Permit), and
2. After receiving an Authorization to Construct from the Division of Environmental Management,
construct additional facilities necessary for the pretreated pesticide manufacturing wastewater
discharge and, relocate outfall 001 discharge point with no change in limitations required, and,
3. Discharge from said treatment works at the location specified on the attached map into the Catawba
River which is classified Class WS-III waters in the Catawba River Basin.
RECEIVED
JUL A99'
CENTRAL FILE COPY

A. ( ). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL
Permit No. NC0004375
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from
outfall(s) serial number 001. Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristics
Discharge Limitations
Units
Mon. Ava%
Flow 3.9 MGD
BOD, 5 Day, 20 °C
Total Suspended Residue
NH3 as N*""
Dissolved Oxygen
Fecal Coliform
Total Phosphorus 2 c.- crt
Total Nitrogen (NO2+NO3+Tlf) G CJ
CCD r' t.D rn
Lbs/day,
Mon, Avg, Daily Max
MBAS
D
Manganese a cco rn
Tr.* Sample locations: E - Effluent, I - Influent, U - Upstream at NC Highway 27, D - Downstream at I-85
Upstream and downstream samples for BOD5, NH3 as N, dissolved oxygen, temperature, conductivity, and pH shall
852.0
976.0
651.0
2236.0
2928.0
977.0
(specify)
Daily Max.
Monitoring Requirements
Measurement
Frequency
Continuous
"
Daily*
Daily"
Daily**
Daily'"
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Type
Recorder
Composite
Composite
Composite
Grab
Grab
Composite
Composite
Composite
Composite
Composite E
Sample *Sample
Location
IorE
E,U,D
E
E,U,D
E,U,D
E
E
E
E
E
be collected three times
per week during June, July, August, and September and once per week during the remaining months of the year.
** Daily is defined as every day except Saturday, Sunday, and legal holidays.
*** Chronic Toxicity (Ceriodaphnia) P/F at 1.8%; March, June, September, and December; See Part III, Condition D.
,k*** See Part III, Condition E.
***** Staging Requirements (Applicable April 1 - October 31) - See Part III, Condition F.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored daily at the effluent, upstream, and
downstream by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

A. ( ). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL
Permit No. NC0004375
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from
outfall(s) serial number 001. (Continued)
Effluent Characteristics
Iron
Chlorides
Sulfate
Mercury
Conductivity
Temperature
Total Phenols
Chronic Toxicity***
Pollutant Analysis""
4-chloro-3-methylphenol
2-methylphenol
4,6-dimethylphenol
Pentachlorophenol
2,4,5-trichlorophenol
c,
Lbs/day,
Mon, Avg. Daily Max Mon. Ava.
rn
1.8
0.022
3.6
Discharge Limitations
Other Units (specify)
Monitoring
Jl bsurement
Daily Max. Frequency
Monthly
Monthly
Weekly
2.4 u g / I Weekly
*
Daily**
Weekly
Quarterly
Annually
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Requirements
Sample
Type
Composite
Composite
Composite
Composite
Grab
Grab
Grab
Composite
Grab
Grab
Grab
Grab
Grab
*Sample
J_ocation
E
E
E
E
U,D
E,U,D
E
E
E
E
E
E
E
E

A. O. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL Permit No. NC0004375
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from
outfall(s) serial number 002. Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristics Discharge Limitations Monitoring Requirements
1.,bs/day. Units (specify) Measurement Sample *Sample
Mon. Avg. Daily Max Mon. Avg, Daily Max, Frequency Type Location
Flow Batch Recorder E
Total Suspended Residue 22.0 73.0 Weekly Composite** E
CCO 108.0 156.0 Weekly Composite" E
BOD, 5 Day, 20 °C 19.0 89.0 Weekly Composite'* E
*Sample locations: E - Effluent, I - Influent
** Composite samples may be done as grab samples if the discharge is on a batch basis.
L rrt
r rn
co

EFFLUENh LIMITATIONS AND MONITORING REQUIREMENTS FINAL NC0004375
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge from outfall serial number 001. (Continued) Such discharges
shall be limited and monitored by the permittee as specified below:
Effluent Characteristics Mon. Avg. Daily Max. Measurement Sample *Sample
lbs/day lbs/day Frequency Type Location
Acenaphthene** 0.39 0.50 Quarterly Grab
Acrylonitrile 1.69 4.30 Quarterly Grab
Benzene 0.75 2.70 Quarterly Grab
Carbon Tetrachloride 0.32 0.67 Quarterly Grab
Chlorobenzene 0.31 0.57 Quarterly Grab
1,2,4-Trichlombenzene 1.20 2.46 Quarterly Grab
Hexachlorobenzene 0.26 0.49 Quarterly Grab
1,2-Dichloroethane 1.20 3.71 Quarterly Grab
1,1,1-Trichloroethane 0.37 0.95 Quarterly Grab
Hexachloroethane 0.39 0.95 Quarterly Grab
1,1-Dichloroethane 0.39 1.04 Quarterly Grab
1,1,1-Trichloroethane 0.37 0.95 Quarterly Grab
Chloroethane 1.83 4.72 Quarterly Grab
Chloroform 0.37 0.81 Quarterly Grab
2-Chlorophenol 0.62 1.95 Quarterly Grab
1,2-Dichlorobenzene 1.57 3.32 Quarterly Grab
1,3-Dichlorobenzene 0.62 0.90 Quarterly Grab
1,4-Dichlorobenzene 0.31 0.57 Quarterly Grab
1,1-Dichloroethylene 0.28 0.44 Quarterly Grab
1,2-trans-Dichloroethylene 0.37 0.95 Quarterly Grab
2,4-Dichlorophenol 0.77 2.22 Quarterly Grab
1,2-Dichloropropane 2.69 4.05 Quarterly Grab
1,3-Dichloropropylene 0.51 0.77 Quarterly Grab
2,4-Dimethylphenol 0.36 0.71 Quarterly Grab
2,4-Dinitrotoluene 1.99 5.03 Quarterly Grab
2,6-Dinitrotoluene 4.40 11.28 Quarterly Grab
Ethylbenzene 0.65 2.20 Quarterly Grab
Fluoranthene 0.47 1.20 Quarterly Grab
Methylene Chloride 0.70 1.57 Quarterly Grab
Methyl Chloride 1.51 3.34 Quarterly Grab
Hexachlorobutadiene 0.35 0.86 Quarterly Grab
Naphthalene** 0.45 0.50 Quarterly Grab
Nitrobenzene 0.48 1.20 Quarterly Grab
2-Nitrophenol 1.23 2.08 Quarterly Grab
4-Nitrophenol 2.17 3.74 Quarterly Grab
2,4-Dinitrophenol 2.15 3.71 Quarterly Grab
4,6-Dinitro-o-cresol 1.55 5.50 Quarterly Grab
Phenol 1.56 2.70 Quarterly Grab
Bis(2-ethylhexyl)phthalate 1.81 4.91 Quarterly Grab
Di-n-butyl phthalate 0.48 1.00 Quarterly Grab
Diethyl phthalate 1.43 3.57 Quarterly Grab
Dimethyl phthalate 0.33 0.83 Quarterly Grab
Benzo(a)anthracene** 0.31 0.50 Quarterly Grab
Benzo(a)pyrene** 0.40 0.50 Quarterly Grab
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
t'LQftVto
JUL 2 7 1991
CENTI* FILE COPY
E
E
(Continued)

Effluent Characteristics Mon. Avg. Daily Max. Measurement Sample *Sample
lbs/day lbs/day Frequency Type Location
3,4-Benzofluoranthene** 0.40 0.50 Quarterly Grab E
Benzo(k)fluoranthene** 0.39 0.50 Quarterly Grab E
Chrysene** 0.39 0.50 Quarterly Grab E
Acenaphthylene** 0.39 0.50 Quarterly Grab E
Anthracene** 0.39 0.50 Quarterly Grab E
Fluorene** 0.39 0.50 Quarterly Grab E
Phenanthrene** 0.39 0.50 Quarterly Grab E
Pyrene** 0.44 0.50 Quarterly Grab E
Tetrachloroethylene 0.39 0.99 Quarterly Grab E
Toluene 0.53 1.63 Quarterly Grab E
Trichloroethylene 0.37 0.95 Quarterly Grab E
Vinyl Chloride 1.82 4.70 Quarterly Grab E
Total Cyanide 7.39 9.01 Quarterly Grab E
*Sample Location: E-Effluent
**These parameters are water -quality limited.
RECEIVED
JUL 27 1991
CENTRAL FILE COPY

Part III Permit No. NC0004375
D. The effluent discharge shall at no time exhibit chronic toxicity in any two consecutive toxicity
tests, using test procedures outlined in:
1.) The North Carolina Ceriodaphnia chronic effluent bioassay procedure (North Carolina Chronic
Bioassay Procedure - Revised *September 1989) or subsequent versions.
The effluent concentration at which there may be no observable inhibition of reproduction or
significant mortality is 1.8% (defined as treatment two in the North Carolina procedure document).
The permit holder shall perform quarterly monitoring using this procedure to establish compliance
with the permit condition. The first test will be performed after thirty days from issuance of this
permit during the months of March, June, September, and December. 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 TGP3B. Additionally, DEM Form AT-1 (original) is to be sent to the following address:
Attention:
Environmental Sciences 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 sample must be measured and reported if chlorine is employed for
disinfection of the waste stream.
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 quarterly in the months specified above.
Should any test data from this monitoring requirement or tests performed by the North Carolina
Division of Environmental Management indicate potential impacts to thezreceiving stream, this
permit may be reopened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum
control organism survival and appropriate environmental controls, shall constitute an invalid test
and will require immediate retesting (within 30 days of initial monitoring event).fit
ef�tpi�
suitable test results will constitute noncompliance with monitoring requirements.
JUL Zi1991
E. The permittee shall conduct a test for pollutants annually at the effluent fribigwit p' �t�, nt
plant. The discharge shall be evaluated as follows: 1) A pollutant analysis of the effluenttl�stt$
completed annually using EPA approved methods for the following analytic fractions: (a)
purgeables (i.e., volatile organic compounds); (b) acid extractables; (c) base/neutral extractables;
(d) organochlorine pesticides and PCB's (e) herbicides; and (f) metals and other inorganics. The
Annual Pollutant Analysis Monitoring (APAM) Requirement Reporting Form A and
accompanying memo, to be provided to all discharges affected by this monitoring requirement,
describes the sampling and analysis requirements and lists chemicals to be included in the
pollutant analysis. This monitoring requirement is to be referred to as the "Annual Pollutant
Analysis Monitoring Requirement" (APAM).

2) Other significant levels of organic chemicals must be identified and approximately quantified.
For the purpose of implementing this requirement, the largest 10 GC/MS peaks in the purgeable,
base/neutral extractable, and acid extractable fractions (or fewer than 10, if less than 10
unidentified peaks occur) for chemicals other than those specified on the APA Requirement
Reporting Form A should be identified and approximately quantified as stated in the APAM
Reporting Form A instructions. This part (item 2) of the APAM requirement is to be referred to as
the "10 significant peaks rule".
F. Staging Requirements (Applicable April 1- October 31)
The operating day runs from 7:00 am to 7:00 am. Each day, the permittee will calculate a running
daily average stream flow as determined by turbine operation at Mt. Island Dam, leakage at the dam
(80 cfs), and the 7Q10 flow of Dutchman's Creek (15 cfs). Effluent release is to be controlled
such that projected release of BOD and ammonia, using the most recent analytical values for these
parameters, will not exceed the value given in the following formulas:
(1) When the daily river flow is calculated to be < or = 175 cfs: BOD5 + 0.54(NH3-N) <= 566.4
lb/day
(2) When daily average river flow is calculated to be > 175 cfs but < or = 250 cfs: BOD5 +
0.54(NH3-N) <= 10441b/day
The attached additional DMR sheet shall be used to monitor compliance with BOD and NH3
staging requirements during the summer (April 1 - October 31)
VED
JUL. 271991
CENTRAL FILE COPY

Additional DMR Sheet for Sandoz
EFFLUENT
NPDES Permit No. NC0004375 Discharge Month Year
Sandoz Class 4 Mecklenburg County
Operator in Responsible Charge (ORC):
Certified Laboratory:
Person(s) Collecting Samples:
Check if ORC has changed
I certify that this report is accurate and
and complete to the best of my knowledge.
River Allowable Actual
Qw Flow BOD5 NH3 BOD+.54NH3 BOD+.54NH3 Comp?
Date Time, (mod) (cfs) (lb/d) (lb/d) (lb/d) (lb/d) Case (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
25
26
27 (�
28 RECE VED
29
30
31 JUL 27 199
Average CENT
Case 1: River Flow <= 175 cfs BOD5 + 0.54NH3 <= 566.4 lb/d �L Fr C�PY
Case 2: 175 cfs<River Flow<= 250 cfs BOD5 = 0.54NH3 <= 1044 lb/d
Case 3: Riv. Flow>250 cfs, BOD5<=852 lb/d (mo avg), BOD5<=2236 lb/d (dly max)
NH3<=651 lb/d (mo avg), NH3<=977 lb/d (dly max)

DEPARTMENT OF ENVIRONMENT HEALTH AND NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL MANAGEMENT
FACT SHEET
APPLICATION FOR
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
PERMIT TO DISCHARGE TREATED WASTEWATER
Application No. NC0004375 Date 4/3/91
1. SYNOPSIS OF APPLICATION
Applicant's Name
Sandoz Chemicals Corporation
Applicant's Address
PO Box 669246
Charlotte, NC 28266
Facility Address
NC Highway 27
north of Charlotte
Type of Operation
Manufacture and process dyes and organic chemicals
Design Capacity of Facility
3.9MGD
Applicant's Receiving Waters
Receiving Stream: the Catawba River
Classification: WS-III
Sub -Basin: 03-08-34
RECEIVED
JUL 27 1991
CENTRAL FILE COPY

See Attachment A for a map showing the discharge location (s).
Description of Wastewater Treatment Facilities
The 3.9 MGD wastewater treatment facility (outfall 001) consists of two basins for biological
waste treatment, stormwater equalization basin for nonalkaline wastewater, stormwater
equalization basins for alkaline wastewater, gravity secondary clarifiers, acid neutralization, gravity
primary clarifiers, air stripper, sludge dewatering, effluent polishing pond, staged discharge
facility including effluent storage, and post aeration, with herbicide manufacturing
wastewaterdischarge to the acid sewer and thence to the 3.9 MGD treatment plant described under
outfall 001 (outfall 002). The company will relocate the discharge approximately 2200 feet
upstream.
Summary of Existing Wastewater Treatment Plant Operation
See Attachment B (for operating facilities).
Type of Wastewater (as reported by applicant)
2 % Domestic
98 % Industrial
PROPOSED EFFLUENT LIMITATIONS
See attached copy of Effluent Page (s) from Draft Permit.
3. MONITORING REQUIREMENTS
The applicant will be required to monitor regularly for flow and those parameters limited in
Section 2 above with sufficient frequency to ensure compliance with the permit conditions.
Frequency, methods of sampling, and report dates will be specified in the final permit.
4. EFFECTIVE DATE OF PROPOSED EFFLUENT LIMITS
(AND COMPLIANCE SCHEDULE IF APPLICABLE)
5. PROPOSED SPECIAL CONDITIONS WHICH WILL HAVE A
SIGNIFICANT IMPACT ON THE DISCHARGE
(1) Chronic Toxicity Limit
RECEIVED
J U L 2 7 1991
CENTRAL FILE COPY

(2) Pollutant Analysis
(3) Staging Requirement
6. BASIS FOR PROPOSED EFFLUENT LIMITS
An EPA -approved model was used to assign limits for BOD5, ammonia nitrogen, and
dissolved oxygen to protect the dissolved oxygen water quality standard in the receiving stream.
The water quality standard for dissolved oxygen is stated in 15 NCAC 2B .0211. The total
suspended solids limit is based on guidelines contained in 15 NCAC 2B .0400.
The pH and fecal coliform limits are based on water quality standards contained in 15 NCAC 2B
.0212.
The toxicity limit is based on the instream wastewater concentration. The COD, BOD5, TSS, and
organic pesticides limits for outfall 002 are contained in 40 CFR Part 455 Subpart A - Organic
Pesticide Chemical Manufacturing. See attached calculations. The sulfate and mercury limits are
based on water quality standards.
Many limits were assigned based on the "Organic Chemicals and Plastics and Synthetic Fibers
Category (OCPSF) - Subpart I -Direct Discharge Point Sources That Use End -of -Pipe Biological
Treatment". See attached calculations. However, if the water quality limit was more stringent
than the limit from the abovementioned category, water quality limits were applied for those
OCPSF parameters.
7. REOUES FED VARIANCES OR AL 1'ERNATIVES TO REQUIRED STANDARDS
8. DISCUSSION OF PREVIOUS NPDES PERMIT CONDITIONS
The previous NPDES permit contained the following limitations (expressed as monthly
averages):
BOD5 + .45 (NH3-N) 2667 lbs/day
BOD5 + .45 (NH3-N) 4749 lbs/day
TSS 976 lbs/day
Phenols 1.8 lbs/day
Fecal Coliform 1000/100 ml
Dissolved Oxygen (minimum) 5 mg/1
RECEIVED
JUL 27 1991
CENTRAL FILE COPY

•
The NPDES Permit expires on: 3/10/88
9. THE ADMINISTRATIVE RECORD
The administrative record, including application, draft permit, fact sheet, public notice,
comments received, and additional information is available by writing the Division of
Environmental Management, Water Quality Section, P.O. Box 27687, Raleigh, North
Carolina 27611. The above documents are available for review and copying at the
Archdale Building, 9th Floor, Water Quality Section, Permits and Engineering Unit, 512
North Salisbury Street, Raleigh, North Carolina 27611 between the hours of 8:00 a.m. and
5:00 p.m. Monday through Friday. Copies will be provided at a charge of 10 cents per
page.
10. STATE CONTACT
Additional information concerning the peanut application may be obtained at the above
address during the hours stated in item No. 9 by contacting: Rosanne Barona at (919)
733-5083.
11. PROPOSED SCHEDULE FOR PERMIT ISSUANCE
Draft Permit to Public Notice - 5/1/91
Permit Scheduled to Issue - 6/15/91
12. PROCEDURES FOR THE FORMULATION OF FINAL DETERMINAAcEIVED
J U L 27 1991
a. Comment Period
CENTRAL FILE COPY
The Division of Environmental Management proposed to issue an NPDES Permit to this
applicant subject to the effluent limitations and special conditions outlined above. These
determinations are tentative and are open to comment from the public.
Interested persons are invited to submit written comments on the permit application or on
the Division of Environmental Management's proposed determinations to the following
address:

DIVISION OF ENVIRONMENTAL MANAGEMENT
WATER QUALITY SECTION
POST OFFICE BOX 27687
RALEIGH, NORTH CAROLINA 27611
All comments received within thirty days following the date of public notice will be
considered in the formulation of final determinations with regard to this application.
b. Public Hearing
The director of the Division of Environmental Management may hold a public hearing if
there is a significant degree of public interest in a proposed permit or group of permits.
Public notice of such a hearing will be circulated in newspapers in the geographical area of
the discharge and to those on the Division of Environmental Management's mailing list at
least thirty days prior to the hearing.
c. Appeal Hearings
An applicant whose permit is denied, or is granted subject to conditions he deems
unacceptable, shall have the right to a hearing before the Commision upon making written
demand to the Director within 30 days following issuance or denial of the permit.
d. Issuance of the permit when no hearing is held
tECEI Y ED
JUL 27 1991
CENTRAL FILE COPY
If no public hearing or appeal hearing is held, and after review of the comments received,
the Division of Environmental Management's determinations are substantially unchanged,
the permit will be issued and become effective immediately. This will be the final action of
the Division of Environmental Management.
If a hearing is not held, but there have been substantial changes, public notice of the
Division of Environmental Management's revised determinations will be made. Following
a 30-day comment period, the permit will be issued and will become effective immediately.
This will be the final action of the Division of Environmental Management unless a public
or appeal hearing is granted.

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?ECEIVED
JUL 27 1991
CENTRAL FILE COPY

NECEIVED
JUL 271991
CENTRAL FILE COPY

,ia11fgt .r11.<1!,.
A. ( ). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL
Permit No. NC0004375
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from
outfall(s) serial number 001. Such -discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristics
Discharge Limitations Monitoring Requirements
Units
Mon. Avg.
Flow 3.9 MGD
BOD, 5 Day, 20 °C
Lbs/day.
Mon. Avg. Daily Max
Total Suspended Residue
NH3 as N
Dissolved Oxygen
Fecal Coliform
C,
Total Phosphorus z C
Total Nitrogen (NO2+NO3+T41)
rT► t-D 1�t
* Sample locations: E - Effluent, I - Influent, U - Upstream at NC Highway 27, D - Downstream at 1-85
Upstream and downstream samples for BOD5, NH3 as N, dissolved oxygen, temperature, conductivity, and pH shall be collected three times
per week during June, July, August, and September and once per week during the remaining months of the year.
** Daily is defined as every day except Saturday, Sunday, and legal holidays.
*** Chronic Toxicity (Ceriodaphnia) P/F at 1.8%; March, June, September, and December; See Part III, Condition D.
**** See Part III, Condition E.
***** Staging Requirements (Applicable April 1 - October 31) - See Part III, Condition F.
+ Weekly average limit
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored daily at the effluent, upstream, and
downstream by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
COD
MBAS
Manganese
852.0 2236.0
976.0 2928.0
651.0 977.0
(specify)
Daily
Measurement
Sample *Sample
Type Location
Max. Frequency
Continuous
Daily**
Daily**
Daily**
Daily**
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Recorder 1 or E
Composite E,U,D
Composite E
Composite E,U,D
Grab E,U,D
Grab E
Composite E
Composite E
Composite E
Composite E
Composite E

A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL
Permit No. NC0004375
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from
outfall(s) serial number 001. (Continued)
Effluent Characteristics
Iron
Chlorides
Sulfate
Mercury
Conductivity
Temperature
Total Phenols
Chronic Toxicity***
Pollutant Analysis****
4-chloro-3-methylphenol
2-methylphenol
4,6-dimethylphenol
Pentachlorophenol
2,4,5-trichlorophenol
Lbs/day.
Discharge Limitations
Other Units (specify?
Mon. Avg. Daily Max Mon. Avg. Daily Max.
0.022+
1.8
3.6
2.4 ug/I
Monitoring
Measurement
Frequency
Monthly
Monthly
Weekly
Weekly
Daily**
Weekly
Quarterly
Annually
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Requirements
Sample
Type
Composite
Composite
Composite
Composite
Grab
Grab
Grab
Composite
Grab
Grab
Grab
Grab
Grab
*Sample
Location
E
E
E
E
U,D
E,U,D
E
E
E
E
E
E
E
E

A. O. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL Permit No. NC0004375
During the period beginning on the effective date of the permit and lasting until expiration, the Pennittee is authorized to discharge from
outfall(s) serial number 002. Such discharges shall be limited and monitored by the perinittee as specified below:
Effluent Characteristics Discharge Limitations Monitoring Requirements
Lbs/day. Units (specify) Measurement Sample *Sample
Mon. Avg. Daily Max Mon. Avq. Daily Max. Frequency Type Location
Flow Batch Recorder E
Total Suspended Residue 22.0 73.0 Weekly Composite** E
GAO 108.0 156.0 Weekly Composite" E
BOD, 5 Day, 20 °C 19.0 89.0 Weekly Composite" E
*Sample locations: E - Effluent, I - Influent
** Composite samples may be done as grab samples if the discharge is on a batch basis.

EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL NC0004375
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge from outfall serial number 001. (Continued) Such discharges
shall be limited and monitored by the permittee as specified below:
Effluent Characteristics Mon. Avg. Daily Max.
lbs/day lbs/day
Acenaphthene**
Acrylonitrile
Benzene
Carbon Tetrachloride
Chlorobenzene
1,2,4-Trichlorobenzene
Hexachlorobenzene
1,2-Dichloroethane
1,1,1-Trichloroethane
Hexachloroethane
1,1-Dichloroethane
1,1,1-Trichloroethane
Chloroethane
Chloroform
2-Chlorophenol
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
1,1-Dichloroethylene
1,2-trans-Dichloroethylene
2,4-Dichlorophenol
1,2-Dichloropropane
1,3-Dichloropropylene
2,4-Dimethylphenol
2,4-Dinitrotoluene
2,6-Dinitrotoluene
Ethylbenzene
Fluoranthene
Methylene Chloride
Methyl Chloride
Hexachlorobutadiene
Naphthalene**
Nitrobenzene
2-Nitrophenol
4-Nitrophenol
2,4-Dinitrophenol
4,6-Dinitro-o-cresol
Phenol
Bis(2-ethylhexyl)phthalate
Di-n-butyl phthalate
Diethyl phthalate
Dimethyl phthalate
Benzo(a)anthracene**
Benzo(a)pyrene**
0.39 0.50
1.69 4.30
0.75 2.70
0.32 0.67
0.31 0.57
1.20 2.46
0.26 0.49
1.20 3.71
0.37 0.95
0.39 0.95
0.39 1.04
0.37 0.95
1.83 4.72
0.37 0.81
0.62 1.95
1.57 3.32
0.62 0.90
0.31 0.57
0.28 0.44
0.37 0.95
0.77 2.22
2.69 4.05
0.51 0.77
0.36 0.71
1.99 5.03
4.40 11.28
0.65 2.20
0.47 1.20
0.70 1.57
1.51 3.34
0.35 0.86
0.45 0.50
0.48 1.20
1.23 2.08
2.17 3.74
2.15 3.71
1.55 5.50
1.56 2.70
1.81 4.91
0.48 1.00
1.43 3.57
0.33 0.83
0.31 0.50
0.40 0.50
Measurement
Frequency
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Sample *Sample
Type Location
Grab E
Grab E
Grab E
Grab E
Grab E
Grab E
Grab E
Grab E
Grab E
Grab E
Grab E
Grab E
Grab E
Grab E
Grab E
Grab E
Grab E
Grab E
Grab E
Grab E
Grab E
Grab E
Grab E
Grab E
Grab E
Grab E
Grab E
Grab E
Grab E
Grab E
Grab E
Grab E
Grab E
Grab E
Grab E
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
=EIVED
2 7 1991
CENT*L FILE COPY.
(Continued)

Effluent Characteristics Mon. Avg. Daily Max. Measurement Sample *Sample
lbs/day lbs/day Frequency Type Location
3,4-Benzofluoranthene** 0.40 0.50 Quarterly Grab E
Benzo(k)fluoranthene** 0.39 0.50 Quarterly Grab E
Chrysene** 0.39 0.50 Quarterly Grab E
Acenaphthylene** 0.39 0.50 Quarterly Grab E
Anthracene** 0.39 0.50 Quarterly Grab E
Fluorene** 0.39 0.50 Quarterly Grab E
Phenanthrene** 0.39 0.50 Quarterly Grab E
Pyrene** 0.44 0.50 Quarterly Grab E
Tetrachloroethylene 0.39 0.99 Quarterly Grab E
Toluene 0.53 1.63 Quarterly Grab E
Trichloroethylene 0.37 0.95 Quarterly Grab E
Vinyl Chloride 1.82 4.70 Quarterly Grab E
Total Cyanide 7.39 9.01 Quarterly Grab E
*Sample Location: E-Effluent
**These parameters are water -quality limited.
RECEIVED
J U ! 27 1991
CENTRAL FILE COPY

DIVISION OF ENVIRONMENTAL MANAGEMENT
March 20, 1991
MEMORANDUM TO: Dale Overcash
FROM: D. Rex Gleason-7)
PREPARED BY: Michael L. Parker
SUBJECT:
Draft NPDES Permit
Sandoz Chemicals Corporation
NPDES Permit No. NC 0004375
Mecklenburg County, North Carolina
RECEIVED
MAR 25
1991
PERMITS & ENGINEER/NC
The staff of the Mooresville Regional Office has reviewed
the comments submitted by Mr. J. Paige Straley, Environmental and
Safety Manager, Sandoz Chemical Corporation, regarding the
subject draft permit, and offers the following comments/ recom-
mendations. Our response follows the numerical listing as set
forth in Mr. Straley's letter.
Item No. 1 - Highway 27 may appear on a map as going
east/west, however, all odd -numbered roads are considered by
DOT to be north/south.
Item No. 2 - The word "air stripper" should be included in
the wastewater treatment plant description. The word
"north" should also remain.
Item No. 3 - Mooresville Regional Office staff have no
objection to including a definition for "Daily".
Item No. 4 - Defer comment to Technical Support.
Item No. 5 - Ditto Item No. 4
Item No. 6 - Ditto Item No. 4
Item No. 7 - Ditto Item No. 4
Item No. 8 - Provided Technical Support concurs, analysis
for mercury can be made for a period of one year and at that
time, if analytical data does not reflect the presence of
this metal, the parameter may be deleted.
RECEIVED
JUL 27 1991
CENTRAL FILE COPY

Mr. Dale Overcash
Page Two
March 20, 1991
Item No. 9 - (A.) Recommend continuous flow recording
remain.
(B.) Defer comment to Technical Support.
(C.) Ditto Item (B.)
(D.) No objection to the deletion of this
statement.
(E.) Ditto Item (B.)
(F.) No objection to the change as requested
by Sandoz.
Item No. 10 - Defer comment to Technical Support
Item No. 11 - Defer comment to Aquatic Toxicology
Item No. 12 - Defer comment to Technical Support
Item No. 13 - It is inappropriate to address the method of
sludge disposal in the NPDES Permit.
If you have any questions regarding this matter, please
advise.
MLP:se
RECEIVED
JUL 27 1991
CENTRAL FILE COPY

LAW OFFICES
• OGLETREE, DEAKINS, NASH, SMOAK & STEWART
4101 LAKE BOONE TRAIL
POST OFFICE BOX 31608
RALEIGH, NORTH CAROLINA 27622
TELEPHONE [phone]
FAX [phone]
JAMES M. KUSZAJ, PH.D.
PARTNER
William M. Archer, III
Director Environmental Affairs
Sandoz Chemicals Corporation
4000 Monroe Road
Charlotte, North Carolina 28205
OTHER OFFICES:
GREENVILLE, SOUTH CAROLINA
WASHINGTON, D. C.
ATLANTA, GEORGIA
COLUMBIA, SOUTH CAROLINA
NASHVILLE, TENNESSEE
ALBANY, NEW YORK
Re: Mt. Holly NPDES Draft Permit
Dear Bill:
I have reviewed the draft NPDES Permit for the Mt. Holly plant and have
the following observations and comments:
1. Compliance Schedule or Special Order on Consent
If the Mt. Holly plant cannot meet any of the new NPDES permit limits
when the final permit issues, any Special Order on Consent or compliance schedule
should issue at the same time as the final permit. Therefore, the time to raise the
issue of a compliance schedule or Special Order is in your comments on the draft
permit. You can request the Department to incorporate into the final permit a
schedule of compliance to meet applicable effluent standards and limitations or
water quality standards pursuant to 15A NCAC 2H .0112(b)(2). As we have
discussed previously, there is some question whether the Department can use a.
compliance schedule. However, it would be better to raise the issue in the draft
permit, and let the Department take an official position, which we can legally
challenge if necessary. If the Department refuses to use a compliance schedule, you
should insist that any Special Order be written so that it issues simultaneously with
the final permit.
2. Other OCPSF Permits
According to the Department, there are approximately 12 facilities in North
Carolina that are subject to the OCPSF effluent guidelines. However, the
Department has issued only one final OCPSF permit to date. The Department
issued that permit to the Dupont facility in Bladen County (Attachment 1).

William M. Archer, III
Sandoz Chemicals Corporation
March 15, 1991
Page 2
3. Term of the Permit
The Department has adopted a new schedule for reviewing permits
accordingto majorjriver basins. Therefore, when your permit issues, the t
expiratin date ay reflect a permit term of less than five years. Your comments on
the draft permit should specifically request that the permit be issued for the full five
years authorized by the Department's regulation.
4. Outfall Relocation
Enclosed as Attachment 2 is a memorandum recommending approval of the
proposed outfall relocation.
5. Phenol Water Quality Standard
Enclosed as Attachment 3 is a memorandum from Julia Storm to Trevor
Clements discussing the Department's position on the water quality standard for
phenol.
Enclosed as Attachment 4 is a memorandum prepared by Richard
Bridgement discussing phenol analytical protocols. The memorandum suggests that
phenol concentrations may be the cause of repeated failure of the chronic toxicity
test.
6. Permit Limits Approaching Limits of Detection
For those paramters with permit limits approaching the limits of detection,
you may want to consider suggesting some type of re -analysis to verify that any
reported number is real rather than due to analytical error.
If you have any questions, please call.
Sincerely,
OGLETREE, DEAKINS, NASH,
SMOAK AND STEWART
,,;70
3'esM.
Kuszaj
uszaj
JMK/lg

DIVISION OF ENVIRONMENTAL MANAGEMENT
March 11, 1991
MEMORANDUM
TO: Rosanne Barona
THROUGH: Trevor Clement 2�
FROM: Ruth Swanek `tZC 3
SUBJECT:• Sandoz Draft Permit Objections
NPDES No. NC0004375
Catawba River (030834)
Mecklenburg County
I have reviewed the draft NPDES permit comments recently sub-
mitted by Sandoz and offer the following comments to each of the
facility's numbered items:
1-3) Permits and Engineering should address these issues.
4) The instream phenols monitoring requirement may be
dropped.
5) I talked to Julia Storm about the phenols limit given to
Sandoz. The North Carolina standard is based upon the taste and
odor problems caused by chlorinated phenols and may be overly res-
trictive as a total phenols limit. Therefore, the phenols limit
may be dropped. However, Julia indicated that a phenol limit
should be added based on protecting 300 ug/1 instream during 30Q2
conditions. The resulting limit was less restrictive than the
effluent guideline limit and should not change. Julia also indi-
cated that DEM needs more data to characterize the effluent, and
that in lieu of a phenols limit, monthly effluent monitoring for
4-chloro-3-methylphenol, 2-chlorophenol, 2,4-dichlorophenol, 2,4-
dimethylphenol, 2,4-dinitrophenol, 2-methlyphenol,
4,6-dimethylphenol, 2-nitrophenol, 4-nitrophenol, pentachlorophe-
nol, phenol, and 2,4,5-trichlorophenol using the EPA Method 604
should be required. (Note: some of these compounds are already
limited through effluent guidelines). In addition, monthly efflu-
ent monitoring of total phenols should be required. Finally, Julia
stated that a specific reopener should be placed in Sandoz' permit
which states that if the effluent monitoring shows that toxic,
human health, or organoleptic levels are exceeded, specific limits
may be put in the permit.
6) The individual phenolic compounds should receive the
effluent limits calculated using the OCPSF guidelines. However,
the limits cited by Sandoz in its letter are not equivalent to

those calculated by Lula. The initial effluent limits were:
Dly Max (#/d) Mo. Avg. (#/d)
2-chlorophenol 1.72 0.55
2,4-dichlorophenol 1.97 0.69
2,4-dimethylphenol 0.63 0.32
2-nitrophenol 2.08 1.23
4-nitrophenol 3.74 2.17
2,4-dinitrophenol 3.71 2.14
4,6-dinitro-o-cresol 4.87 1.37
Phenol 2.70 1.56
The Permits and Engineering Unit should check its files to see if
there is a reason why the limits listed by Sandoz are different
from those originally calculated.
7) .The daily maximum chloroform limit should be 0.81 lb/d.
8) The mercury limit was included in the permit since an
effluent sample collected on 7/24/89 indicated a concentration of
0.5 ug/l. DEM will not waive the mercury limit at this time.
However, if after one year of effluent monitoring the data indicate
that the limit may be dropped, the State will reevaluate the
requirement upon request. A year of effluent monitoring is needed
to establish a representative data base which reflects seasonal
variation.
9) Permits and Engineering should address this issue. How-
ever, you should note that the pH limit for outfall 002 is based on
federal guidelines and should not be dropped.
10) Permits and Engineering should address this issue.
11) Ken Eagleson should address this issue.
12) Permits and Engineering should address this issue. Julia
Storm may be able to offer some insight to the wording.
13) Permits and Engineering should address this issue.
If you have any questions or comments, please contact me at
extension 507.

SANDOZCHEMICALS
Sandoz Chemicals Corporation
P.O. Box 669246
Charlotte, North Carolina 28266
704.827.9651
FAX: [phone]
Feb 25, 1991
Ms. Rosanne Barona
NC Dept. of Environment, Health, and
Natural Resources
Division of Environmental Management
P.O. Box 27687
Raleigh, NC 27611-7687
0.
•
• . r
FEB 26 7991
RE: Sandoz Chemicals Corporation draft NPDES permit, NC0004375.
Dear Ms. Barona:
Sandoz is pleased to have received the draft permit. The permit is
generally in agreement with previous versions, and with informal
discussions between Sandoz and the DEM. However, there are items
warranting further review within the permit.
We believe that a meeting between DEM and Sandoz to discuss the
permit would be appropriate, and we will be in contact with your
office to set up mutually agreeable appointment in the near future.
Our comments are presented below, numbered for reference:
1. On the cover sheet of the permit, please substitute "west" for
"north." The NC Highway 27 is an east -west road.
2. In the plant description, add the unit process "air stripper"
within the description of the wastewater treatment plant. This
unit pretreats groundwater before it enters the activated sludge
basin. It is located adjacent to the basin and is operated only by
the WWTP personnel. We also ask that the word "continue"V be
omitted. This implies that we now are treating the herbicide
wastewater, which is not the case. A, :in the cover sheet, please
substitute "west" for "north."
3. Under the Effluent Limitations And Monitoring Requirements
(ELMR) we note that the use of the word "daily" is not defined. In
our previous permit, daily was defined to mean every day except
Saturday, Sunday, and legal holidays. We would like to continue
this definition in the new permit. We remind you that the plant
has several days detention time, so that rapid fluctuations which
might otherwise cause the plant to go out of compli anc�ae�
anticipated or likely. RECEIVED
4. The ELMR section also requires that upstream and do • st4 al 119 i
j sampling for phenols. Using the 4-AAP method and theO t-
available in the river, we believe that such analysis wu>3T "ti t1-� OPY
detect phenol. Recall that the water quality standards for phenols
are based on a one ppb guideline, two orders of magnitude less than

.1-761-8;1
g MG1)

R. Barona
page two
Feb. 25, 1991
the detection limit for phenol with the 4-AAP test. We therefore
request that the upstream/downstream monitoring requirement for
phenol be dropped from the permit.
5. Also with regard to phenols, it was our understanding from a
meeting in February, 1990 that the State had agreed to leave the
total phenols limit unchanged in our renewed permit and to not
duplicate this limit for individual or combined phenols covered
otherwise by the OCPSF standards. Sandoz pointed out last year
that "total phenolics" in the NC Water Quality Standards is an
aesthetic parameter that is to be limited based on a 30Q2 stream
flow. The 1 ppb criteria adopted by North Carolina was derived by
EPA from organoleptic data. With respect to such data, EPA states
"criteria derived solely from organoleptic data are based upon
aesthetic qualities only". 45 Fed. Reg. 79318. In establishing
standard maximum contaminant levels, EPA clearly identified taste
and odor as aesthetic parameters when it stated that it was
concerned about "expected aesthetic effects (primarily taste and
odor)". 54 Fed. Reg. 22062. Since a limit based on 30Q2 would be
considerably higher than our current limit, we see no justification
for reducing the current limit of 1.8 lb/day monthly average and
3.6 lb/day daily maximum, monitored monthly.
6. In the OCPSF portion of the proposed permit there is a
duplicative application of the aesthetic standard to the OCPSF
phenolic parameters. In addition to phenol, the total phenols
analytical procedure measures several substituted phenols (and as
has been our experience, some non -phenolic compounds) as phenol.
These substituted phenols must be present at higher concentrations
in ppb than phenol to equal the same mole concentration as phenol
since they have much higher molecular weights. Also, the taste and
odor perception varies with the particular phenolic compound. For
instance, the EPA criteria for 2,4-dimethylphenol is 400 ppb based
on taste and odor, some 400 times greater than for phenol itself.
The criteria summary for dinitrophenol does not even mention taste
and odor concerns in setting a criteria of 70 ppb. For these
reasons, we believe that the OCPSF phenols (both individually and
combined) should be limited solely on the basis of BAT and BPJ.
These limits were negotiated with NC DEM over a year ago, and are
given again below:
2-chlorophenol
2,4-dichlorophenol
2,4-dimethylphenol
2-nitrophenol
4-nitrophenol
2,4-dinitrophenol
4,6-dinitro-o-cresol
phenol
Daily Max. Monthly Avg. (lb/day)
1.95 0.62 /. 7 ; 7 yci "J G%
2.22 0. 77 14/ Q -t I,g / 0,6`I
0.71 0.36 0.430 032 4u wQ
3.'/f.Cr-
3.71 E 2.17 w� 1 r•$ ��b� 3
3.71 itiL 2jrl .1991 2. 15 u pi,e l /4
1.55 u, 0 /, i f i, 3'7
2. 7 CENIRAI ME COP`- . 56 v; 0 i, F q S
Nof *QJ .-CI

R. Barona
page three
Feb. 25, 1991
7. There appears to be a typographical error in the OCPSF table
concerning chloroform. The daily maximum should be 0.81.
8. The ELMR section regulates Hg at 0.022 lb/day, daily maximum.
Sandoz does not use Hg in any process at Mt. Holly. Hg detected at
trace levels in the past is believed to have derived from caustic
soda manufactured in the mercury cell process. We no longer
purchase such caustic. We analyzed secondary clarifier effluent
for Hg on June 7,14,and 21 of 1990. All samples were below
detection (0.2 ppb). We believe the inclusion of Hg in the permit
is not warranted given that the apparent historic source of Hg has
been eliminated.
9. We have several comments on the ELMR for discharge 002.
First, the ELMR requires continuous flow recording. However, the
waste is generated as a discrete step in the batch -type process,
and the volume of each batch is accurately known. VWe request that
the flow frequency measurement be changed to "batch". Second, this
waste may be treated in a batch -type process, which will make
composite samplin difficult and unnecessary. We request that the
sample type be deignated as "composite, or grab if discharge is on
a batch basis". Third, we suggest that pH should not be regulated,
since the effluent will flow to the pant acid sewer, which itself
almost always has a pH less than 6. NFourth, the requirement that
there be no floating solids or foam should be deleted, since the
discharge will flow into a plant sewer rather than the natural
waters of the State. %/Fifth, the discharge limitation for "Organic
Pesticide Chemicals" should be deleted. This term is defined in
40CFR455.21(c) as "the sum of all organic ingredients listed in
455.20(b) (emphasis added) which are manufactured at a facility
subject to this subpart." Norflurazon is not included in this
list, and thus the Organic Pesticide Chemical limitation does not
apply to the Norflurazon wastewater discharge. Last, we ask that
the permit state that sludge generated from biological treatment of
the waste is allowed to be combined with waste sludge from the main
activated sludge waste treatment plant for dewatering and disposal.
10. The ELMR mass discharge limitations give rise to low-ppb
analytical problems. The chemical matrix in the plant effluent is
complex, and it has been our experience that very low instrumental
analysis detection limits are not always attainable. To avoid
noncompliance from such factors, Sandoz requests that if results
are "less than detectable" from a properly executed analysis, then
such results be considered compliance.
RECEIVED
JUL 27 1991
CENTRAL FILE COPY

R. Barona
page four
Feb. 25, 1991
11. In part D (chronic toxicity) of the permit, we believe that
the reopener clause should be modified by omitting the word
"potential." Actual impacts can be readily ascertained if the
State has reason to believe they exist, and the loose and undefined
nature of the word "potential" is unacceptable to Sandoz without
further definition.
12. In the "10 significant peaks" portion of part D, Sandoz
believes the use of the word "synthetic" to describe organic
chemicals is inappropriate, and should be omitted.
13. Sludge disposal is not addressed in the permit. Sandoz would
like to mention in this regard that sludge disposal is accomplished
through our on -site sludge landfill, permitted under DEM permit no.
16528.
Although our comments are detailed, we trust that DEM will find
them straightforward. We look forward to our upcoming discussions.
If there are any questions, or if we may be of service to you in
any way, please do not hesitate to contact myself at 704 822 2701
or Mr. W.M. Archer at 704 331 7088.
Sincerely,
Paig Straley,
Environmental and
cc: MJ Smith
WM Archer
M Teague
W Rankin
Safety Manager
file:wwtp\govt\npdes03.b91
RECEIVED
JUL 27 1991
CENTRAL FILE COPY

DIVISION OF ENVIRONMENTAL MANAGEMENT
February 15, 1991
MEMORANDUM TO: Dale Overcash
FROM: D. Rex Gleason
PREPARED BY: Michael L. Parker7e
SUBJECT:
Proposed Outfall Relocation
Sandoz Chemicals Corporation
NPDES Permit No. NC0004375
Mecklenburg County, North Carolina
Based on this Office's review of Sandoz's request to
relocate their existing outfall, the following comments/
recommendations are offered:
The proposed outfall location is approximately 2200 feet
upstream of the existing discharge location. Receiving stream
characteristics are essentially identical at both locations, and
there does not appear to be any upstream uses which may be
compromised as a result of this change. Information received
from Technical Support indicates that a new waste load allocation
does not appear to be necessary.
It is, therefore, recommended that the proposed outfall
relocation be included in the subject Permit which is currently
being renewed.
If you have any questions, please advise.
MLP:se

DIVISION OF ENVIRONMENTAL MANAGEMENT
February 12, 1991
MEMORANDUM
TO: Rosanne Barona /�/
THROUGH: Trevor Clements i/ v
FROM: Ruth Swanek
SUBJECT: Sandoz' Proposed Relocation
NPDES No. NC0004375
Mecklenburg County
I have reviewed Sandoz' proposal to move its discharge point
approximately 2200 feet upstream in the Catawba River, and antici-
pate no problems with the relocation. If this is the only change
proposed by the facility, no new WLA is needed.
Please contact me at extension 507 if you have any questions
or comments.

.*
MEMO
DATE•
SUBJECT: S
e63 75
/Ytbt.) W L rF
-�
North Carolina Department of Environment,
Health, and Natural Resources

. ` SANDOZCHEMICALS
Sandoz Chemicals Corporation
P.O. Box 669246
Charlotte, North Carolina 28266
704.827.9651
FAX: [phone]
Rosanne Barone
NC Division of Environmental Management
P.O. Box 27687
Raleigh, NC 27611-7687
February 11, 1991
RE: Sandoz Chemicals Corporation NPDES Permit. NC004375.
Dear Ms. Barone:
I understand that you requested that we provide you with the
latitude and longitude for our requested alternative discharge
point to the Catawba River.
We rechecked the USGS topographic map to determine the alternative
coordinates, and we found that there had been a mistake made in the
coordinates given for the existing discharge. Please change the
latitude and longitude for the existing discharge point as follows:
latitude:
longitude:
35 degrees 17 minutes 00 seconds
81 degrees 00 minutes 25 seconds
The coordinates for the proposed alternative discharge point are as
follows:
latitude:
longitude:
35 degrees 17 minutes 21 seconds
81 degrees 00 minutes 22 seconds
Again, what I am suggesting is that the re -issued NPDES permit
contain reference to both points as approved discharge points so
that if we decide to change to the upstream discharge point there
will be only minor permitting work involved.
If there are any questions, please do not hesitate to contact me at
704 822 2701 or Mr. John Casisa at 704 822 2708.
Sincer ly,
. Paite Straley/ PE
Environmental Manager
cc: J. Casisa
WM Archer
file: wwtp\govt\npdes02.b91

SANDOZCHEMICALS
Sandoz Chemicals Corporation
P.O. Box 669246
Charlotte, North Carolina 28266
704.827.9651
FAX: [phone]
Rosanne Barone
NC Dept. Environment, Health,
and Natural Resources
Division of Environmental Management
P.O. Box 27687
Raleigh, NC 27611-7687
February
RE: Sandoz Chemicals Corporation. NC004375.
Dear Ms. Barone:
i
As we discussed in a telephone conversation on February 1, 1991,
Sandoz is considering moving its wastewater discharge point
upstream approximately 2200 feet. I am enclosing several xerox
copies of a USGS topo map showing the proposed move. The positions
shown on the map were located by using a Mecklenburg County aerial
survey map as a reference.
Position one is the existing discharge point and position two is
the proposed discharge point. In either case the discharge point
comes after both the final sampling point and the discharge
Parshall flume. We also note that there are no intervening
discharges or confluences to the river between the existing and
proposed discharge point.
We suggest that the proposed change would have no effect on our
NPDES permit, and that the permit renewal which is now under
preparation contain appropriate reference to position number two as
an approved alternative discharge location. Sandoz understands
that a separate engineering review would be required for the new
discharge structure.
Thank you for your consideration. If there are further questions,
or if I may be of assistance to you in any way, please do not
hesitate to call me at 704 822 2701.
Sincerely,
2Thf.
Paid Straley, PE
Environmental Manager
cc: WM Archer
MJ Smith
G Cassada
file: wwtp\govt\npdes01.b91

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