NC0044725_Draft Permit_19861204

NPDES DOCUMENT SCANNING COVER SHEET
NC0044725
LMAC WWTP
NPDES Permit:
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Owner Name Change
.Draft
Permit
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
December 4, 1986
This document its prirsted on reuse paper - ignore any
content on the reYerse side

GSA
December 4, 1986
GSX Corporation
Chemical Services Group
P O. Box 210799
100 Executive Center Drive
Santee Building, Suite 128
Columbia, South Carolina 29221
[phone]
STD. tic T.
A/Zt17ti/ /21.
Mr. Page Benton
N.C. Department of Natural
Resources and Community Development
Division of Environmental Management
512 North Salisbury Street
Raleigh, NC 27611
DEC 1 1 1986 4S
PERMITS & ENGINEERING
RE: Review of Draft NPDES Permit for the Laurinburg-Maxton
Airport Commission Wastewater Treatment Plant
Dear Mr. Benton:
We have enclosed our comments regarding your original draft
of the LMAC NPDES permit. We look forward to discussing
these with you at our 3:30 meeting next Wednesday,
December 10, 1986.
Sincerely,
GSX CORPORATION
Nelson V. Mossholder, Ph.D.
Director of Technical Services

Effluent Limitations and Monitoring Requirements
Comments on First Table of Draft Permit (Page M3)
On the basis of observed toxic effects to freshwater organisms and
established standards for fresh surface waters in North Carolina, the
discharge limitations for total residual chlorine, sodium and chloride
appear somewhat more conservative than necessary. Using the NCDEM
(July 1986) procedures, the lowest LC50 found for chlorine (0.23 mg/1,
96 hour RBT, Basch, 1971) would yi,eld,a.no-effect-chronic-1evel of
0.01 mg/1 or a discharge limit of :7;: 1. The North Carolina
promulgates Administrative Code (NCAC, 1986)romultes no chlorine standard
9
other than 2.0 mg/1 for trout waters (15 NCAC 2B.0211). The only LC50
found for sodium (1,640 mg/1, 48 hour Daphnia magna, Biesinger and_
Christensen, 1972) would yield...a no -effect -chronic -level of*?:,,mg/1 or
a discharge limit of about $O 000 1b/day. There is no NCAC standard
for sodium. For chloride, the only NCAC standard is 250 mg/1 for
Class WS Waters. If this were applied to the LMAC discharge,
allowance for dilution would yield an effluent limit of about 184,000
lb/day.
Recommendation
The discharge limitations for chlorine, sodium, and chloride should be
no more restrictive than 1.7 mg/1, 4000 lb/day, and 184,000 lb/day,
respectively.��r;=.,
Comments on Chemical List (Pages 1-6)
The list of chemicals presented on pages one through six of the draft
permit is reproduced with our comments added on the following pages.
The notation NA indicates that GSX will not be accepting D, F, or K
waste codes associated with these constituents at the Laurinburg
facility. In addition, there are other chemicals, such as some drugs,
for which there is no indication that the GSX facility would be
receiving them. Certain chemicals on the list are noted as being
unstable in water (USEPA, 1982 et seq.) and at least one (asbestos) is
a solid. There also appears to be several instances of typographical
errors, duplicative entries, non-standard chemical notation,
contradictory limits, and limits that are less than published
detection limits.
Although time was not available to review toxicity data for all
chemicals listed, some specific concerns were noted. In general,
allowing for a dilution factor of 176 (from 7Q10 river flow of 135 cfs
plus LMAC discharge of 1 MGD), daily maximum end of pipe limits are
consistently more conservative than calculated water quality standards
for those chemicals for which the North Carolina Department of Natural
Resources and Community Development (NRCD) has determined No -Effect -
Chronic -Levels (NRCD, April 1986 and October 1986). Similarly, end of
pipe limits are consistantly more conservative than established North
Carolina Water Quality Standards (NCAC, 1986). It seems reasonable,

since Water Quality Standards are based upon chronic toxicity values
(15 NCAC 2B .0208), that when there are no overriding health concerns,
the monthly average end of pipe limits should be established to pro-
vide an Instream Waste Concentration at 7Q10 flow conditions equal to
established Water Quality Standards or No -Effect -Chronic -Levels. It
also should be noted that the June 19, 1986 ammendments to the Safe
Drinking Water Act mandates the establishment of Maximum Contaminant
Levels (MCLs) for 83 contaminants. As these MCLs are promulgated,
end -of -pipe limits should be adjusted to reflect instream waste
concentrations equal to the MCLs.
For some chemicals, such as noted for 2,4,6-Trichlorophenol and
Cobalt, the end -of -pipe limits given are not adequate to assure
protection of human health or the environment.
Many of the compounds listed will be limited on the RCRA permit for
the GSX facility. Repeating these substances on the LMAC NPDES permit
would be an unnecessary redundancy unless water quality standards are
more stringent.
Recommendations
Only those chemicals expected to be received or discharged by the
industries discharging to the LMAC WWTP, that reasonably may be
expected to survive in aqueous solution, and that are not already
limited in the GSX RCRA permit should be included on this list.
For most of the $ubstanRcps on the 1 i stk'
its,
} J _,�' - , ..J,! .. '`/O..y �Y �I •�l .hp. v. �?r R �•}
% '� 1 i' • i �� • ; i '�'i i i - ! 6.
6 a.��ti:3�:�'S+`r•• .. i � ' `' ' � �... `
Remove duplicative entries from the list.

A(1).EFFU. NT LIMITS MONITORING REQ. FINAL(CUNT)
CN311 CFL
ETU OF PIPE 'Elio OF PIPE
LIMIT (ig/I)
LIMIT (µg/1)
t10tiT1-LY AVG
OA I LY MAX
I
I
1, 1, 1-TR1 -__
14492.751
21739. 131
1, 1, 2, 2-TETI &OROETHANE 1 811
./mow/�pI -� 4 ,12266.
875456190.2271
�'+
1, 1,2-TR Iate/.n) 1,2,2-T{ 1F1jUORRIE 0E!, ' •2■1+3,68. 12! 1052. 11
1,1, 2-TR I CILOROETI•IAtE
44.281
66.411
1,1-0104.0ROETHAtt
42028.991
63043.481
1 , 1-0 104.CROETWLEHE ; 44.201
66.301
1,1-oICH.O 1
1
1, 1-0 IGILOROIVIliftiE 1
1
1,1-01 at 507.2'S1
760.871
1,1-01 rET}IYLHYORAZ !PE
1', 12481ZOFERVLETE
1, 2, 4-TR I CHLORo6EtQENE
2934.781
4402.17
1, 2-0 I eRono3-a1-0f )PRo r1E
I
I
1, 2-018AOtlOttETHRE I
1,2-0 ICHLOROBENZETE
228260.871
342391. 301
1, 2-01 1
27.901
41.85r
1,2-o1DNLo&oETNY.
307246.381
760869.371
1,2-010LOROPROPPtE
405.801 '
608. 70
1, 2-0IREmn..- M * Z 1 tE
• 1 2-01 PIEVLHYORR2 I tE
3.26
4.89
1, 2-0MTH IIOL IE
1, 2.34-o I EPDXYBIfTR E 1
i
1, 3-01 D Li IOBE1QZD€ 1
228260. 871
342391. 301
ph k iLL )Vor ,g-ccePT 1.) -sre .
repetitive with following item, methyl
typographical error?
unstable in water - should be removed
NA - should be removed from list
ene chloride & methylene
chloromethyl chloride
from list
duplicated on next line
below published detection limit of 20 ug/1 (EPA, 1984, p. 191)
unstable in water - should be removed from list

1, 3-0I GLOROPROPETE .
1,4-0101.
1, 4-010XAtE
1, 4-IfFTFIQQU 1110t
141APT LR11 I IE
2, 6-0 I Di.0ROPfET101_
2, 4, 5-TR 1 CHLOROPI•EHOL
2, 44, 6-TR I CHLOROPI€J1OL '
74
2, 4-01 fETHYLPHE1i0L
z-4-e1n+118a►-11318L
34347. 831 81521. 74
30 79710. 141 45869565.221
2173.911 3260.871
1
1118478.261
I 127.461 191.201
1 1159 : 421_ 1739. 131
1 72 6 Z 1 1 A_06L
r �7s'�T vw s
7608.70� ttot� 0 l
x�,__.__521-
1 745652. 17
2, 4-01 I1 I TROTOLUETIE
2,6-0INITROTOLUE
2- P!COL IIE
8. 19
12.28
2--ACETVL.At1 I ti0PLUOR 1 HE
2-QLORO TIfYL V 111YL ETHER
2--CFLORO PTFALE E
127536 2.321 191304 3.48
2-1:1LOROF'HE110L
2-4£T}M.--f 2R 101 tE
4347.831
6521.74
2-111 TROPIEI I01.
173913.041 260869.57
NA - should be removed from list'
limit not sufficient to protect against 10-6 cancer risk level
of 1.7 ug/1 (CAG, 1985)
2-11 I T1 PR0P1 E
3,3'-0ItETHOXVBeiz 101tE
3, 3-0111ETHYLBENZ10111E
3, 3-01 C}&OR08812101 tiE
3, 5-01 C1ifTIOL
3-1£THYLCHOi ffl1Et E
1.52
2.28

A(1).EFFL1. NT LIMITS MONITORING REQ. F1t*L(CONT)
CHEM I CAL
Ella OF PIPE .
ETID OF PIPE '
LIMIT 04/1)
LIMIT (4,tg/1)I
DAILY mix I
MONTHLY AUG
-
1 t
4, 6-0I t1I L
833. 331
1230. 001
4-4 • I S(2-CiLOROAN I T RE
1 1
4-BROMOPHENYL ETHER
'
4-NITROPHEHOL
32246.38
48369.57I
I
7,12-O I IA 1AN T}f ACENE
ACoWHf € E
1
THYL.EHE
IACENAPH
ACETO11 I TR I LE
1 1521739. 13
2282608.701
ICROLE I N
297.101
445.651
ACRYLAM I DE
507246.381
76O869.571
ACAYLOM I TR 1 L.E
1 1.061
1.591
ALDRIN
I 0.141
0.221
ALPHR, eETR,DE LTA,_ & c
f 1
ALUM I N
1 .
At1 I THOLE
I
I
ANILIt£
I 3804347.831 5706521.741
AMTHIRACENE1
• 2.031 3.041
ANTIMONY
1 1014.49
1521.74E
3434.781
1
ARSENIC
1 3023.19
_
ARSENIC PEiTOXIDE
• 1
1
ARSENIC TRIOXIDE
1
1
ASBESTOS
I
1
AURAMIPE
!
1
i
ionizes; test is duplicative with arsenic
ionizes; test is duplicative with arsenic
a.solid - should be removed from list

RZRSER I tE 1 1 i
BAR I U1 1 67028.991 100543.481
Beentmaiam
1 0.221 0.331
BENZENE
{ 94.201 141.301
BEMZIDINE
1 0.01!
0.021
BENZO(A )PYRENE
0.22. 0.33
BEii20(B)FLLRORANTFETE
I
B _
.!
BENZ0TR I CH.OR I DE 1
21195.651
1195.65E
2173.91 !
BETQYL CHLORIDE 1 14130.43
BERYLL I U1 797.10
B I S(2-ETHYL HEXYL) PHTHALATE 1449.28,1
B I S(CH..OROETHOXY) tEil•IANE i
1 1
BISM-LOROETHYLXTHER
0.94
1.411
B 1 S(0I CH.ORO I SOPROP L) ETI EB
1
BORRTE
.
1
BR'I00I CH_oROiETHAtE
1
GOAD
105072.46
157608.70'
BROMOPIENYLPIENYL ET14=RS
i
BUTAtiO I C AC ! 0 _
1
BUTYL OCTAt10L
1
CADMIUM
144.93
217.39
CALCIUM
csminic AC I D1 ETHYL ESTER
_
CARBON 0 I SULFATE
299955.071
434792.611
434782.611
tSSON D I SU.F I DE
289855.07
CARBON TETRACHLORIDE
19.49
29.24
limit is below published detection level of 0.08 ug/1
(EPA, 1984, p. 71)
represented by benzo (a) pyrene
unstable in water - should be removed from list
NA - should be removed from list
typographical error?

A(1).EFFLL NT LIMITS MONITORING REQ. FINAL(CONT)
CHEM I CFI,. -
1613 OF PIPE
END OF PIPE 1.
lUNIT (WI)
notf tY AVG
LIMIT (µg/I)j
DAILY MAX
1
_
CHLORAMBUCIL
O'L0
10.
289855072461 0.43
CH.OR I NATED CRESOLS
I
€
CH_OR I HATED NAPHTHALENE
I
1
CI&ORONRPHAZ 1 NE
CH.OROACETALDE}M)E
!
17500.001 26250.001
CHLCROBENZEKE
1 467391.301
1
CHLOROETHANE
1
1
C>•LORO m'& ETHER
869565.22! 1304347.831
CHLOROFORM
1
36.231 54.351
C LORMETH
CH.OROtETH NE
CHLOROMETHYL BENZENE1
1
1
CH.OROI'1ETFM. METHYL ETHER
1
i {
CHLOROMETHYL ETHER
i
CH. ETHER
1
1
CH I U1
3623. 191 5434.781
CHRYSENE
0.221 . 0.331
COBALT
j
72463.771 108695.651
COPPER
1086.961 1630. 431
CYAN 1 DE
362.32! 543.48!
CYCLOPHOSPHAf1 I DE
i
t
ppp
0.43! 0.65
unstable in water - should be removed from list
duplicative with next item
ChV of 55.5 ug/1 would require limit of 9768 ug/1 (after
Biesinger and Christensen, 1972)

DOE
1 13.04i 19.571
ODT
' 0.07246376812!
1811.59
0. 11 !
2717.391
0I41-BUTYL PHTHALATE
01-f1-OCTYL. PHTHALATE
,
0144-PROPYLMITROSAMIHE
I
0 I BEMZO(A )Af1TFAACEIiE
1
01 BEH20(A, I )PYRE]£
'
1 •
D I CHL
8695.65
13043.48
DICiLORD EJQIDIhE
1.521
2.281
DICHLOROBROMOMETHAKE
J
D 1 CHLOR001 FLUOROMETFANE
I
DICILOROPROPRE
1 405.801
608.70
0 l C1•LOROPROPANOL
1 i
D I CiLOROPROPETtE
1 Z2282.611
33423.911
DIELDAIN
1 0.071
0.11i
DIETHYL PHTHALATE
188403.801
282608.701
DIETHYLSTIBESTROL
1
1
01HYDROSHFROLE
1
OIMETHYL PHTHALATE
119565.22
179347.831
D I METHYLAi1 I rn zo9EMZEME
OIMETHYLCRABAMOYLCHLORIDE
1
0I tETHYLS1JLFRTE
DINITROBENZETE
DIMITROCRESOL 1
01 PI€1YLFi1 I HE
0 I PHEJMJ IVCFiAZ I t'E
3.261 4.89
EHD06ULFAM
3.62i 5.43
NA - should be removed from list
unstable in water - should be removed from list

A(1) .EFFLUENT LIMITS MONITORING REQ. FINAL (COI IT )
CHEMICAL
1 END OF PIPE 1 Ef D OF PIPE
ILIMIT (lLq/1)
LIMIT (lig/I )I
'DAILY
MONTHLY Alai
mix 1
I
1
EI'IM
0.14 0.221
EP I CH.OROHYDR I N
256. 161 384.241
ETHAKETH 10!1 I OE
_ '•
ETHYL. rE HRESULFONATE
!
1
ETHNLBENZENE
23550.721 35326.09�
ETHYLENE D I CH_OR I DE
1 21557971.011 32336456.521 .
ETHYLENE 0X 1 DE
1 1
ETHYLENE THIOUREA
! 1
EYHYLEIE 0 I BROM I DE
10.030231884061 0.051
FLUORENE
1 0.221 0.331
FLUORIDE
130434.781 19 ;652. 17
FLUOROANTHENE
• 105.65i 203.481
FORMALDEHYDE
1702.901 2554.351
FORMIC ACID
• 5072463.771 7608695.65i
GLYCIDYLADEHYDE
HARDNESS, TOTAL
• 72463?6.81
10869565.221
HEPTACHLOR
0.29
0.431
HEPTACHLOR EPDXIDE
HEXACHLORMENZENE
1 1.521 2.28
HEXAC}LOROBUTAo IENE
1 46.381 69.57
HEXACHLOROCYCLOHEXAME
5.80
8.701_
F EXACH.OROCYCLOPENTAD 1 ENE
25.36 i
38.041
}}LT}
178.621 267.93
unstable in water - should be removed from list
gas, unstable in water - should be removed from list
unstable in water - should be removed from list
NA..- duplicative with Lindane but has different limits -

imumuint
1
I tflE110(1, 2,3-Oc )PY ENE
IrDEHOPYAENES
72463.771
108695.65
IRON
IRON DE) TRAM
1
I SUBUTFMOL
(
ISOFROLE•
_
t
I•
1 SOOCTFNOL
ISOPHORONE
i
423913.04
635869.571
KEPO E
LASIOCAFPINE
`L RO
1811.59
2717.391
LEAD ACETATE
f
LEAD PHOSPHATE
LEAD STATE
I
1
L 1 PDANE
0.721
1.091
n-CRES0L
1
17028.901
25543.481
11-XYLE E
797.101
1195.651
MANGANESE
_
289.86
434.78
tBAS
36231.88
54347.83
MELPHA AN
I
mERCUAY
1.45
2.171
METHOXVCit.OR
2.171
. 3.261
1524456.521
163043.48
METHYL CHLORIDE
1016304.35
METHYL ETHYL KETONE
108605.65
METHYL MERCURY
METlMBRON I DE
represented by Ideno (1,2,3-dc) pyrene
cannot be analyzed as specific compound
ionizes; test same as lead
11
11 11 11 11
- duplicative with Hexachlorocyclohexane but different
limits -
total Hg suggested - methylmercury analysis is very
complex

AC1).EFFLUENT LIMITS MONITORING REQ. FINAI.CCANT)
C}EM I CAL
!MD OF PIPE
MO OF PIPE
LIMIT (µg/I)
1LI11IT Cµg/I )1
i
MONTHLY AVG
rDA I LY MAX
i
I
METHYLENE G-LOR I DE
I
144.93
;
217.391
METHYLENE CHLOROMETHYL CHLOR 1 DE
1
i
METHYL. I Oo I DE
1
N-METHYL-H' -NITRO--H•-N I TROSOGUAN 1 NE
N-NI UREA
j
N--N 1 Ui ET} E
11-11 I TROSO-tf-t'ETYLURER
N-NITROSO01 1 NE
t
i
M-MITROS00I IME
I
i
I4-HITROSOoI ETHIlt1.11M ItE
{
{
t1-M I TfOSO01 ETHYLAM I t E
N--N I TROS00 I METHYLAM I NE
1
0.07
0. 1
N-f1 I TROSOP 1 PER I D I NE
'
1
N-NITROSOPYRROLIOINE
1
I1-11 I TROSOSTErHYLIJ I NAM I ME
_
HAPTHALENE
25000.001
37500.00I
M I CAL
3623.191
5434.781
N I TROBENZEtE
2.321
3.481
N1TROSAMINES
0-CRESOL
35869.571
53804.35
0-TOLUIOINE
0 -TOLU I o I NE HYDROCHLOR I DE
OIL s GREASE
1
replicated on next line and with 1,1-Dichloromethane
below published detection limit of 0.15 ug/1 (EPA, 1984,
p. 86)
below published detection limit of 3.6 ug/1 (EPA, 1984,
represented by specific compounds above p. 109)
unstable in water - should be removed from list

P-a& SOL
1 115.941 173..211
P-CREEL
14492.751 21739. 131
P-TOLUIDINE
P-XYLEPE
57971.011 86956.52
PARATHION
2.901 4.35
PENTAC L
152. 17
228.261
PHENACET 1 N
P
s
PHENOL2463.771
3696.65.
PHENOLIC
n. 46I 108.701
PHENYLENEDIAMINE
20797. 101 31195.651
PRORATE
2.17
3.26
PHOSPHOROOITHIOIC ACID ESTERS
,
PHOSPHOROTHIOCIC ACID E5tttss
PHTWLIC ANHYDRIDE
i
POLYCHLOR I F* TE) 0 I P EHYL ETHERS
1
I
PYRENE
0.221
0.331
PYRIDINE
7246.38,
1
10869.57
AESEAPIKE
i
SACCHARIN AND SALTS 1
I
SAFRO E
_
SE1.EN1 I UM
724.641
1086.96
S I LIVER
724.641
1086.961
_
STREPTOZOTOC 111
SULFATES
18115042.03
27173013.04
SULFIDE
48.551 72.83
M1MAC}&OROETH4'LII1E
NA - should be removed from list
NA - should be removed from list
below published detection limit of 0.27 ug/1 (EPA, 1984,
p. 117)

R(1).EFFLUENT LIMITS MONITORING REQ. FINAL(c01iT)
CNEM I CFL
ENO OF PIPE
LEND OF PIPE J
LIMIT 001)
LIMIT (µg/1)I
DAILY MAX
MONTHLY AUG
r i
THALLIUM
1 1014.491
1521. 74.
THIOCYANATE
I
i 1
THIOUREA
I
TOLUENE
797.101
1145.65'
TOLUENE 0115DCYAHRTE
[
1
TOLUENE-2,4 DIAMIME
i
+
TOXf €JE
0.941
1.41 !
TRICNLOROETHYLENE
188.411
282.611
TRICHLOROFLUOROMETHRHE
760869.57
1141304.351
TR I CIL OROPHEHOLS
TRICNLOROPR Pa1E•
TR I HALOt1E11tES
URANIUM
URHAD I UF1
1 . 1
V l NYL CiLOR I DE
1.091
1.631
2I NC
1 3623. 191
5434.781
I l
unstable in water - should be removed from list
NA, other than 2,4,6,-Trichlorophenol - chemical category
should be removed from list

Toxicity Reopener
Recommendation
This paragraph states that the permit "shall be modified, or revoked
and reissued..." if it is indicated that "detrimental effects may be
expected..." In consideration of the positive intent at the beginning
of the sentence, we suggest that the end be rewritten to read
"detrimental effects are occurring in the receiving stream as a result
of this discharge."
Limitations Reopenei
Comment
Paragraph H is poorly written and may result in a misinterpretation of
intent.
Recommendation
It is recommended that paragraph H be rewritten as follows:
"This permit may be modified, or revoked and reissued, to
incorporate new limitations in the event the discharge of an
industry is connected to this treatment works that causes a change
in the wastewater characteristics entering the treatment works
that results in a demonstrated adverse impact on the Lumber
River."
Toxicity Limitations and Monitoring Requirements
Comments
Five effluent concentrations approximating a geometric series around
the Instream Waste Concentration (IWC) should be adequate to assure
that the Ceriodaphnia Chronic Value (ChV) does not fall within the
immediate range of concentrations surrounding the 7Q10 IWC. However,
since values below the IWC will not provide any additional information
if the ChV is greater than 1.4%, we suggest that the 0.4% test con-
centration be replaced with a 12% concentration. By this modifica-
tion, should toxic effects persist in the diluted effluent, there
would be a greater chance of observing a Lowest -Observed -Effect -
Concentration (LOEC). While this will not increase the precision of
the test, it will increase the likelyhood that the true value of
No -Observed -Effect -Level (NOEL) can be estimated, and will provide
additional information in the form of an early warning of any
variation in chronic toxicity before such toxicity reaches a level of
concern to the Lumber River.
The inclusion of a single exposure treatment in 95% effluent with
Ceriodaphnia seems both unnecessary and superfluous when weekly
chronic tests are being conducted simultaneously. Any acute toxicity

that would affect Ceriodaphnia in the Lumber River would show up at
the 7Q10 IWC as well as at the two or three higher concentrations in
the geometric concentration series. Since the test would fail if
either reproduction or survival at the 1.4% effluent concentration was
significantly different from results obtained from control organisms
at the same concentration, and chronic mortality that is detected over
the full seven day test is a more rigorous endpoint than 20% mortality
at 95% effluent after only 48 hours, we propose that the 95% "control
exposure treatment" be eliminated from the testing requirements.
The present draft permit requires survival tests for acute effects at
high effluent concentrations with both Ceriodaphnia dubia and
Pimephales promelas. However, no more than 20% mortality in at least
95% effluent after 48 hours exposure is allowed for Ceriodaphnia,
while no more than 10% mortality in 100% effluent after 96 hours is
allowed for the fathead minnow. There is no ecological nor toxi-
cological justification for having different survival requirements for
fish and crustaceans in a mixed waste effluent.
We also feel that the survival requirements for acute effects are set
at unnecessarily conservative levels in the present draft permit.
This conclusion is based in part on input received from the North
Carolina Department of Natural Resources and Community Development
(NRCD). In the GSX Pretreated Wastewater Discharge Permit Applica-
tion, the Bioassay Testing Protocols outlined on page 5-6 proposed 50%
survival as an acceptable value in effluent concentrations greater
than 90%. This proposal was drafted to be consistent with all of our
previous discussions with NRCD representatives. Furthermore, in the
September 1985 toxicity examination report for the Laurinburg/Maxton
Airport WWTP prepared by NRCD, LC50 values ranging from 71% to 89% for
Da hnia pulex and 100% for the fathead minnow led to the conclusion
t at, during either 7Q10 or average stream flows, "the effluent is not
predicted to cause any significant damage to biological communities in
the Lumber River." Since an observed mortality of 50% in an average
effluent concentration as low as 80% is considered by NRCD to be
"negated by the dilution received as it enters the Lumber River," it
seems reasonable that the draft LMAC NPDES Permit should require no
more than 50% mortality in at least 90% effluent after 96 hours of
exposure using the fathead minnow in monthly daily renewal toxicity
tests.
Summary of Recommendations on Toxicity
Limitations and Monitoring Requirements
1. Use effluent concentrations of 0.7, 1.4, 3, 6, and 12% for the
Ceriodaphnia survival and reproduction test.
2. Eliminate the 0.4 and 95% effluent concentrations from the
Ceriodaphnia test.

3. Require no more than 50% mortality in at least 90% effluent after
96 hours of exposure in the Pimephales promelas survival test.
Biological Monitoring
Comments
Specific requirements also occur in Section A(1) of the permit, as a
footnote to the first table. The last sentence in paragraph K is not
clear and is too open for a wide range of interpretation.
Recommendations
Assure that there are no redundancies or contradictions between
Section A(1) and paragraph K, and include in paragraph K all specific
monitoring and reporting requirements.
Permit Reopeners
Recommendations
We suggest that the wording of the first sentence be modified as
underlined in the following: "This Permit may be modified, or
alternatively revoked and reissued, to incorporate new effluent
limitations and monitoring requirements into this permit if a problem
is identifed in the event:"
To make clear that Items 8 and 9 following the above opening sentence
refer to promulgated standards only, we suggest that the phrase "safe
drinking water levels" is changed to read "Safe Drinking Water
Standards" in each case.

References Cited in Review
Basch, R. E. 1971. In -situ investigations of toxicity of chlorinated
municipal wastewater treatment plant effluents to rainbow trout (Salmo
gairdneri) and fathead minnows (Pimephales romelas). Complt. Rept.
Grant 38050G22, USEPA, Water Quality Office, as ington, D.C.
Biesinger, K. E. and G. M. Christensen. 1972. Effects of various
metals on survival, growth, reproduction, and metabolism of Daphnia
magna. Jour. Fish. Res. Bd. Canada 29(12):1691-1700.
Carcinogen Assessment Group (CAG). 1985. Relative carcinogenic
potencies among 55 chemicals evaluated by the Carcinogen Assessment
Group as suspect human carcinogens. In: Office of Health and
Environmental Assessment, September 1985. Health Assessment Document
for Nickel. EPA/600/8-83/012F. U.S. Environmental Protection Agency,
Washington, D.C.
CRS Sirrine, Inc., Environmental Division. January 28, 1986. GSX
Pretreated Wastewater Discharge Permit Application. GSX Corporation,
Columbia, SC.
North Carolina Department of Natural Resources and Community
Development (NRCD). September 1985. Laurinburg/Maxton Airport WWTP
Toxicity Examination, NPDES #NC0044725. NRCD, Water Quality Section,
Raleigh, NC.
North Carolina Department of Natural Resources and Community
Development (NRCD). April 1986. No -effect chronic levels for aquatic
toxicity: Organic compounds found near Ashland Chemical Site in
Raleigh, North Carolina. NRCD, Division of Environmental Management,
Water Quality Section, Raleigh, NC.
North Carolina Department of Natural Resources and Community
Development (NRCD). October 1986. No -effect chronic levels for
aquatic toxicity: Organic chemicals found in effluents from hazardous
waste treatment facilities in and near Buffalo, New York. NRCD,
Division of Environmental Management, Water Quality Section, Raleigh,
NC.
North Carolina Division of Environmental Management (NCDEM). July
1986. Procedures for Calculating Aquatic Life -Based Water Quality
Standards for Toxicants in North Carolina. NCDEM, Water Quality
Section, Raleigh, NC.
State of North Carolina Administrative Code (NCAC). February 1, 1986.
15 NCAC 2B .0100 - Procedures for Assignment of Water Quality
Standards [and] 15 NCAC 2B .0200 - Classifications and Water Quality
Standards Applicable to Surface Waters of North Carolina. Department
of Natural Resources and Community Development, Division of
Environmental Management, Environmental Management Commission,
Raleigh, NC.

U.S. Environmental Protection Agency. July 1982 et seq. Test Methods
for Evaluating Solid Waste. SW-846. USEPA, Office of Solid Waste and
Emergency Response, Washington, D.C.
U.S. Environmental Protection Agency. October 26, 1984. Guidelines
establishing test procedures for the analysis of pollutants, 40 CFR
Part 136. Reprint version, March 1985. USEPA, Office of Research and
Development, Washington, D.C.

1' H ARS UN LE/ i .L APT VeRm1-r t1 rfri '57ANDAkb"
N5 ' ,,
w i T `•N o �rnn1 D Ak..b"
TABLE 3
,Jor- APP�i c'Aj DJ J?r ' %��/ /il/•7�
LIST OF CHEMICALS FROM RCRA D, F, t WASTE CODES
OR THE PRIORITY POLLUTANT LIST THAT OCCUR
ON PART A OF GSX RCRA APPLICATION
�► N s'1cenaphthylene (1)
'lcetonitrile
✓Acrolein (1)
�Acrylaride
✓Acrylonitrile (1)
✓�4ldrin (I)
/Aniline
Antimony, total(I)
j
Lead (1)
✓Lindane (1)
4-1Iercury (1)
Methyl chloride (1)
- Methyl ethyl ketone
Alfethylene chloride (1)
'faphthalene (1)
'2-trans -Dichloroethylene 4-'1,4-Naphthoquinone
.."Arsenic. (1) . v2,4-Dichlorophenol._(1) '-Nickle, total (.1).
'• Benzo(a)anthracene(i) �-2,6-Dichlorophenol ~�� -Nitrobenzene (1) -
' Benzene (I) _ 1,2-Dichloropropane (1) _ v4-Nitrophenol (1)
--blenzidine (1) Al '1ichloropropano1 ,'R-Nitrosodieethylaeine (1)
.� vBenzo(a)pyrene (1) N5 A--1,3-Dichloropropene (1) .. 'N-Nitrosodi-n-propylaoine (I) . .
) N4 ✓Benzo(b)fluoranthene(1) ✓Dieldrin (1) .--Phenol (1)
s1enzyl chloride. .. .-!Diethyl phthalate (1).. _ _ .... vPhenylenediaaine__...._.. .
N3 'llis(2-chloroethoxy)rethane (1) '1inethyl phthalate (1) z--Phorate
..)is(2-chloroethyl) ether (I) 44,4-Disethylphenol .(1) . _.Nj. ./..-Phosphorodithioic acid esters
/0 ,.,8is(2-chloroisopropyl)ether (1) Dinitrobenzene NS YPhosphorothioic acid esters
.elis(2-ethYlhexyl)phthalate. (1) .41,6-Dinitro-o-cresol (1) _ „ NS..._'-Phthalic anhydride _ .__,
✓Brorofora (1) 2,4-Dinitrophenol (1) N✓.2-Picoline
Tk-IBroeophenyl .phenyl ether..(11.... 14-Djnitrotoluene. (1.)..__.. _4:::pyridine_.w...___.,_„__ ,
—Cadrius (1) • , t v2,6-Dinitrotoluene (1) `�Seleniue (1)
'Carbon disulfide. .... 'Di-n-octyl phthalate (1) '1ilver. .(1).._ .....
y sine 1,1,1,2-Tetrachloroethane
1
"'Carbon tetrachloride (1) Ns
r!Chlordane (1).__. _._ _.. _. ..- 1,2-Diphenylhydrazine (1)_____ .__ .. �1,1,2,2-Tetrachloroethane (1)
p-Chloro-e-cresol (1) -Endosulfan-alpha (1) YTetrachloroethylene (1)
_ . _. _ . -v/ -Endosulfan-bet
. ✓Chlorobenzene (1) � �. a (1)--� �• • . • --• .... �ihalItus, total PI_
Endrin (1) `Toluene (1)
.DNS .✓Chloroethane(1) �pichlorohydrin __ ...._,u. ??,Toluene-2,4-diasine _
�2-Chloroethyl vinyl ether (1) ✓Fthylene dibroaide N5 o-Toluidine
'ihlorofora (1) ''Ethylene dichlorL _ .
N) /0 '2-Chloronaphthalene (1) oranthene (1)
v
� � ` � � 'foxaphene {!)
Q
rim e y _ , P_} 41 .y �....,A-Lh _Tricltloroethane (1)
rorric acid cc',q am /4 �i1;1,2-Trichloroethane (1)
�Neptach1or (1) ..._.._../,4,&-i' ✓ iichlaroethylene (1)
texachlorobenzene (1) �richlorofluorosethane
exachlorobutadiene (1) ` '1;4,6-Trichlorophenol (1)
'-1,2-Dichlorobenzene (1)
v1,3-Dichlorobenzene (1)
--,4-Dichlorobenzene (1)
"i,3-Dichlorobenzidine (1)
" 1,1-Dichloroethane (1)
�1,2-Dichloroethane (1)
�i;l-Dichloroethylene (1)
(1)
NS
�!2-Chlorophenol (1)
k Chroeius, total (1)
vChrysene (1) _
Cresols
Cyanide, Total (1)
J �,4-DDD (1)
�,4-DDT (1
�ibenzo(a anthracene(1)
-41-n-butyl phthalate (1)
'Diphen 1a
klixachlorocyclopentadiene (1) N5
vNexachloroethane (1)
NS b-lndeno(1,2,3-cd)pyrene (1)
N5 L-Isobutanol
''p-Toluidine
✓Trichloropropane
;-'1,1,2-Trichloro-1,2,2-trifluoroethane
vinyl chloride (1)
,"Zinc, total (1)
(11 Priority Pollutant
Gsx tv# Ts 7`1/(1 7 - ,t e4o109r�greiJ .

N'9a'E
ies9-AtseI
j��/rJ�i gyotw-,/
ig/Dftcigjee)ev-
ffleer,wC-
Qe/n.e t'e.,T/N‘--
/2 -1D-k
c
r/y-773_ So' •
(#?) 37Z -- /'
ea3-g g-683 7
xs> z9i3
�3 - 7q

DIVISION OF ENVIRONMENTAL MANAGEMENT
September 10, 1986
MEMORANDUM
TO: R. Paul Wilms
FROM: George T. Everett
SUBJECT: Preliminary Draft NPDES Permit
Laurinburg-Maxton Airport Authority (LMAC)
NPDES No. NC0044725
As requested, the staff of the Water Quality Section has prepared a
preliminary draft version of the LMAC, NPDES permit which includes all
present indirect discharges as well as the proposed GSX facility.
This draft permit has been prepared in such a manner as to allow the
best possible assurance that the intended and classified uses of the Lumber
River would be protected. To provide this assurance, limits were derived to
protect the "C" classification at the discharge point and "WSIII" as the
Lumber River is a drinking water source for the City of Lumberton, North
Carolina. The regulatory support for this approach is included in 15 NCAC
2B.0203 which states "In cases where treated sewage, industrial wastes or
other wastes including those from nonpoint sources are directly or indi-
rectly allowed to enter into waters which are assigned a different classi-
fication than the waters into which such receiving waters flow, the
standards applicable to the waters which receive such wastes shall be
supplemented by the following: The quality of any waters receiving sewage,
industrial wastes or other wastes shall be such that no impairment of the
best usage of waters in any other class shall occur by reason of such
waste".
As you can see, the parameters for which effluent limits have been
developed and/or for which monitoring is required, is quite comprehensive.
Yet, these compounds which have been included are either known or suspected
to be in the wastewater based on information available to the Division.
That information includes:
Categorical standards for current indirect discharges;
Compounds to be received and treated by GSX;
Compounds detected by Divisional evaluations of current wastewater;
Compounds detected at a similar facility as GSX, in New York State;
Applicable water quality standards and or compounds of concern.

As stated previously, permit conditions have been designed for the
protection of class "C" waters and "WSIII" waters as provided by 15 NCAC
2B.0203. Both aquatic life and human health criteria were evaluated and the
most restrictive of the two criteria was employed to establish permit limi-
tations. Drinking water or human health criteria has been provided by DHR
as preliminary only, and criteria for each compound is still under review.
Aquatic life criteria were derived from existing water quality standards as
specified in 15 NCAC 2B.0200. In addition, for those compounds where suf-
ficient data is not available to adopt statewide numerical concentration, 15
NCAC 2B.0208 was employed to develop aquatic life protection criteria.
Applicable parts of 15 NCAC 2B.0208(a) state: "The concentration of toxic
substances in the receiving water, (either alone or in combination, when
affirmatively demonstrated to be non bioaccumulative) when not specified
elsewhere in this Section, shall not exceed the concentration specified by
the fraction of the 96-hour LC value which predicts a no effect chronic
level. If an acceptable acute/chronic ration is not available, then that
toxic substance shall not exceed 0.01 of the 96-hours LC50 or if it is
affirmatively demonstrated that a toxic substance has a Half life of less
than 96 hours or is not bioaccumulative, the maximum concentration shall not
exceed 0.05 of the 96-hour LC50".
In addition for compounds that are listed as substances requiring
special attention (NCAC 2B.0208(b)) "Appropriation limitations shall be set
based on the evaluations and/or criteria specified in paragraph (a) of this
rule.
Whereas, we have developed numerical limitations for numerous com-
pounds, it should be noted that these limitations were based on zero back-
ground levels. LMAC is currently involved in a headworks evaluation to
characterize wastewater at the facility as well as background assessment of
the Lumber River. Also, we have used draft information from GSX as to the
compounds they intend to accept and treat. These lists have changed over
time and final permit inclusions will be based on any revised list from LMAC
or GSX.
Drinking water criteria as provided in this preliminary draft permit
are still under review by DHR and several of our aquatic life criteria are
also in the additional review process.
The list of compounds either to be limited and/or monitored is quite
extensive. We are continuing our evaluation, with the assistance of labo-
ratory personnel, as to the appropriate analytical methods for quantitative
determination and a review of those compounds which cannot be analyzed by
our laboratory for compliance purposes because of equipment needs.
Whereas, GSX has proposed monitoring of their indirect discharge to
the LMAC facility, we feel it essential that we concentrate our controls at
the river discharge point in addition to any indirect discharger monitoring
because of the multiple waste sources to this POTW.

This draft is being provided for your ;review and discussion. Whereas,
the details, limits, etc. are subject to modification as we continue our
review, our over all approach is fairly clear as to how we wish to proceed
technically.
Upon your review, please advise if you wish to discuss.
cc: Steve Tedder
Mick Noland
Dennis Ramsey
Alan Klimek
Bill Kreutzberger
Ken Eagleson
John Dorney
Dale Overcash
Dave Vogt
Meg Kerr

Permit No. NC0044725
STATE OF NORTH CAROLINA
DEPARTMENT OF NATURAL RESOURCES & COMMUNITY DEVELOPMENT
DIVISION OF ENVIRONMENTAL MANAGEMENT
PERMIT
To Discharge Wastewater Under the NATIONAL
POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions 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,
Laurinburg-Maxton Airport Commission
is hereby authorized to discharge wastewater from a facility located at
Laurinburg-Maxton Airport
Wastewater Treatment Plant
on NCSR 1434
East of Laurinburg
Scotland County
to receiving waters designated as the Lumber River in the Lumber River Basin
in accordance with effluent limitations, monitoring requirements, and other conditions
set forth in Part 1, I1, and III hereof.
This permit shall become effective
This permit and the authorization to discharge shall expire at midnight on
Signed this day of
R
R. PAUL WILMS, DIRECTOR
DIVISION OF ENVIRONMENTAL MANAGEMENT
BY AUTHORITY OF THE ENVIRONMENTAL
MANAGEMENT COMMISSION
M1E11

)116
Permit No. NC0044725
SUPPLEMENT TO PERMIT COVER SHEET
Laurinburg-Maxton Airport Commission
is hereby authorized to:
1. Continue the operation of the existing 1.0 MGD wastewater treatment plant
consisting of influent pumping, comminution, grit removal, oxidation ditches,
clarifiers, chlorination, effluent pumping, sludge drying beds.
2. After receiving an Authorization to Construct from the Division of Environ-
mental Management construct additional facilities as may be needed to meet
the final effluent limitations contained in this Permit (See Part III, Condition
No. C of this Permit) , and
3. Discharge 1.0 MGD from said treatment works at the point of the existing
discharge into the Lumber River which is classified Class "C" waters in the
Lumber River Basin.

x
tab
A. (1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
RA FT
During the period beginning on the effectiveidate of the Permit and lasting until expiration,
the perml ttee is authorized to discharge from outfal 1 s) 'icerl al number(s) 001.
Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characterlitics
Monthly Avg.
Flow
BOD, 5Day, 20°C**
Total Suspended Residue**
N H as N
Fecal Coliform (geometric mean) *****
Total Residual Chlorine
Temperature
Total Nitrogen (NO2 + NO3 + TKN)
Total Phosphorus
Chloride 1451
Sodium 1451
Toxicity
Biological Monitoring
Color
Discharge Limitations
lbs/da Other -Units (Specify)
Weekly Avg. Monthly Avg. Weekly Avg.
1.0 MGD
30.0 mg /I 45.0 mg/I
30.0 mg/I 45.0 mg/I
1814
1669
* Sample location: E - Effluent, I - Influent.
1000.0 / 100 mi.
0.2 mg/I
* * *
2000.0/100 nil.
0.2 mg /1
Monitoring Requirements
Measurement
** The monthly average effluent BOD5 and Total Suspended Residue consentrations
respective influent values (85% removal)
Frequency
Continuous
Weekly
Weekly
Weekly
Weekly
Daily
Weekly
Monthly
Monthly
Weekly
Weekly
***
Annual ****
Weekly
Sample * Sample
Type Location
Recording I or E
Composite I, E
Composite I, E
Composite E
Grab E
Grab E
Grab E
Composite E
Composite E
Composite E
Composite E
*** ***
Composite E
shall not exceed 15% of the
** ,, See Part . 1 1 1 , Condition No. J.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and
shall be monitored weekly at the effluent by grabsamples.
les.
p
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Continued ...
CI sD a c►
g;

'DRAFT
Permit No. NC0044725
Biological Monitoring will be conducted as required by Part 111 Condition No. K, of the Permit. Biological
monitoring shall include assessment of invertebrate populations and fishery body burden bioaccumulation
assessments. Additional limitations may be imposed, after opportunity for hearing by the Director of
the Division of Environmental Management, provided that said limitations are required to insure that the
Lumber River is suitable for its assigned best usage.
In the event the Lumber River is reclassified from Class "C" to Class "B" waters, the following fecal
coliform effluent limitations shall apply:
Monthly Average 200.0 / 100 ml. Weekly Average 400.0/100 ml .

RC 1) .EFFLUENT L I N I TS MONITORING REQ . F 1 NRLCC0NT )
CHEMICAL
END OF PIPE
END OF PIPE
FREQ
SAMPLE
, LOC
LIMIT (µgf 1)
LIMIT (µ9/1)
TYPE
MONTHLY RUG
DRILY FIX
1
1,1, t-TR 1 CI-L
1 14492.73
21739.131 14
E
grub
1,1,2j2-TETRRCHLOROETHRNE
126.81
190.221 111
grab
E
1,1,2-TRICHLOR0-1,2,2-TRIFLUOROETHRHE
72463768.12
108695652.171
N
grab
E
1,1, 2-TR I CFLOR0ETFIFIt1E
44.281
66.41i W
grab
E
1,1-0I CHL
42028.99
63043. 48
W
grab
E
1,1-0I CHLOROETFIMLEME
44.20
66.30
1119rab
E
1, 1-01 CHL
W
grab
E
1,1-D I CHL
W
E
1, 1-D I CHLOROMETHYLENE
507.251
760.871
W
grab
E
1,1-0IPIETHYL ZIME
W
E
1,12
W
E
1,2,4-TRICHLOROBENZENE
2934.781
4402.17
1.1
grab
E
1, 2-01 BROM03-CHLOROPROPAl
14
comp
E
1, 2-D I BROM0IETliA'E
-
W
grab
E
1,2-0ICHLOROBENZENE
228260.87
342391.30
W
grab
E
1,2-01CHLOROETHANE
27.90
41.85
W
grab
E
1,2-DICHLOROETHYLENE
507246.38
760869.57
W
c, rab
E
1, 2-D I CIL
405.801
' 608.70
14
comp
E
1, 2-D I PI ENYL-HYDRAZ I I€
Ii
comp
E
1,2-01PHEYLHYDRAZINE
3.26
4.891
W
comp
1, 2-0XATH I OLf E
W
y
comp
E
1, 2: 34-0I EPDXYBIJTAIIE _
11
comp
E
1,3-0ICHLOROBENZENE
228260.87
342391. 30
W
grab
E
1,3-01CHLOROPROPENE
W
grab
E
1, 4-01 Cif.
54347.83
81521. 74
W
grab
E
1, 4-D I OXAI€
30579710.14
45869565.22
W
grab
E
1, 4-i THOQU I N0HE
• 2173. 91
3260.87
11
comp
E
1-NAPTHYLAM1NE
W
comp
E
2, 6-01 CHLOROPHEIfl.
745652. 17
1118478.26
W
comp
E
2, 4, 5-TR I CHLOR0P EN0L
127.46
191.201
. W
comp
E
2, 4, 6-TR I CHLOR PHEMOL
1159.42
1739.131
W
comp
E
2, 4-01 CHLOROPHENOL
7246.381
10869.57
W
comp
E
2, 4-011 ETHYLPFENOL
7608.70
11413.04
W
comp
E
2, 4-0I N I TROPI ENOL
2246.38
3369.571
14
comp
E
2,4-0INITROTOLUENE
8.19
12.28
W
grab
E
2, 6-D I N I TROTOLUENE
U(co.p
E
2- PICOLINE
W
comp
E
2-ACEi7LAN I NOFLUOR 11€
W
comp
E
2-CI LOIOTHYL VINYL ETHER
1275362.32
1913043.48
14
grab
E
2- THE
W
E
grab
2-CHLORrOPHENOL
4347.83
6521.74
11,comp
E
2-1EHYL-R2RIDItE
U
comp
E
2-iWTl LRM I t E
14
comp
E
2-NI TROPE
173913.04
260869.571
L1
comp
E
2-NITROPFIOPRIE
W1co
p
E
3, 3' -0I tETHDXYBENZ I D I tE
W
comp
E
3, 3' -O I I ETHYLBENZ I D I NE
WIcomp
E
3,3-0ICHLIDINE
1.52
2.28'
14comp
E
3,5-0ICHLOROFHENOL
14
comp
E
3-tETHYLCHO
-
11
comp
E
Page 1

A(1).EFFLUENT LIMITS MONITORING REQ. F1NL(CONT)
'CHE11 I CAL
EMJ OF P I PE
1 END OF P I PE ! FREQ
SAMPLE
LOC
L
LIMIT (iq/I)
LIMIT (µgf1)1
TYPE
M
MONTHLY AVM
DRILY MAX
4,6-DIMITRO-0-CRESOL
833.33
1250.001
W
comp
E
4-4' IS(2-CIL IITINE)
14comy
E
ETA
1 14
grab
E
4-NITROPIENOL
32246.381
48369.571
14comp
E
7,12-01METHYLBENZIAIRMTHRRCENE
W
comp
E
ACENAPHTHENE
Wgrcb
E
ACENRPHTHYLEHE
14
comp
E
RCETON I TR I LE
1521739. 13'
2282608. 7O1 1
coop
E
RCROLE I M
297.10
445.65 W
comp
E
AC�'I I DE
507246.38
760869.571 W
comp
E
ACRYLONITRILE
1.06
1.591 14
comp
E
ALDR I N
0.141
0.221 W
comp
E
ALPf t, BETA, DELTA, BHC
I 14
comp
E
ALUMINUM
i W
comp
E
RMITROLE
14
comp
fE
AN I L II NE
3804347.831
5706521. 741
U
�P
E
ANTHRACEHE
2.03
3.04
W
comp
E
ANTIMONY
1014.49
1521.74
Ulcomp
E,
ARSEN 1 C
3623.19
5434.78
W comp
E
ARSENIC PENTOXIDE
Wicomp
E
RRSEH I C TRIOXIDE
Wlcomp
E
ASBESTOS
Wicomp
E
AURRM I NE
,
Ulcomp
E
AZASERINE
14
comp
E
81IRIU1
67028.99_
100543.48
14
comp
E
BENZRNTHRRCEIS
0.22
0.33
ulgrab
E
BENZENE
94.20
141.30
W
grab ,
E
BENZIDINE
0.01`
0.02
W
comp
E
BENZOCA E
0.22!
0.33
14
comp
E
BENZO(B)FL
. ulgrab
E
ECIZOPYREHES
W
grab
E
BENZOTRICHLORIOE
I
1
comp
E
BEMZYL CHLORIDE
14130.43
21195.65
W'comp
E
BERYLL I UM
797. 10 1
1195.65
,
u
comp
E
B I S(2-ETHYL i•EXYL) PHTHALATE
1449.28! 2173.91
14
comp
E
I B I S(CHL XY) METHANE
u
grab i
E
BIS(CHLOROETHYDETHER
0.94
1.41
14,
comp
E
B 1 S(D I CHLORO 1 SQL) ETHER
ulgrab
E
BATE
14
comp
E
BROMODICHLOROMETHANE
W
grab
E
BF )110FOR11
105072.46
157608.70
U1grcb
E
BROMOPHENNLPHEHYL ETHERS
WI
E
BUTANO I C AC I O
W
comp
E
BUTYL. OCTANOL
u
comp
E
CM I U11
144.93
217.39
Hemp
E
CRLCIUH
Upplio
E
CRRBRMIC RCID, ETHYL ESTER
W
comp
E
CARBON D I SULFATE
280855.071
434782.61
u
comp
E
Chi DISULFIDE
289$55.07
434782.61
W
grab
E
CARBON TETRACHLORIDE
19.49
29.241 14
comp
E
Page 2

R(1).EFFLL HT LIMITS MONITORING REQ. FINRL(CONT)
C i'1 I CAL
1 END OF PIPE
END OF PIPE FREQ !SAMPLE
ILQC '
LIMIT (µg/1)
LIMIT (g%I)
1TYPE
'rEMTHLY AVG
DRILY MAX
I
CHLOAAMBUC 1 L
WI
comp I E
CHLORDANE
0.289855072461
0.43
W
comp i E
CILOR I NATED CRESOLS
W
comp = E
CH.OR I KITED NAPHTHALENE
Ulgrab
Meow
Ia
;
comp
E
E
E
CH_OSOHAPHAZ I ME
CHLOROACETALDEHYDE
i 17500.00
26250.00
CHLOROBENZEME
467391.30
W
grab
E
CH.TIiANE
W
grab
E
CILORGETHYL ETHER
869565.22
1304347.83
1.1
grob
E
CHLOROFORM
36.231
54.351
W
grab
E
CHLOROMETHAHE
1
` 14
., .,.
E
CHLOROMETHANE
41
grab
E
CI LOROMETHYL BENZENE
lit
comp
E
CHLOROMETHVL [ETHYL ETHER
li
grab
E
CHLOROEETHYL ETHER
' li
grab
E
CHLOROPHENYLPHENYL ETHER
1 i W
grab
- E
CHROt1 l UM
3623.191 5434.781 11
comp
E
CHRYSENE
0.221 " 0.331 I4
comp
E
COBALT
72463. 77
108695.651 W(comp
E
COPPER
1086.961 1630.431 liom
cp
E
CYANIDE
362.32, 543.48! I
comp
E
CYCLOPHOSPHAMIDE
W
comp
E
DOD
0.43
0.65
11comp
E
DOE
13.041
19.571
W
cosp
E
DDT
0.07246376812
0.11
141
comp
E
DI-N-BUTYL PHTHALATE
1811.59
2717.39
11icomp
E
DI-N-OCTYL PHTHALATE
N
comp
E
D I-N-PROPYLN I TROSRM I NE
Memo
E
DIBBIZO(FORMTHRRCENE
W
grab
E
DIBENZOCA, I
- IJlcoop
E
DICHLOROBENZENE
8695.65
13043. 48
11
grab
E
DICHLOROBENZIDIHE
1.52
2.28
I
grab
E
DICHLOROBROMOMETHANE
W
grab
E
D 1 CHL0R)D I FLUOROMETHRNE
Wi
E
DICHLOROPROPANE
405.80
608.70
Wgrab
E
DICHLOROPROPANOL
1a
grab
E
DICHLOROPROPENE
22282.61
33423.91
la
grab
E
D I ELDR I N
0.07
0.111 W
coop
E
DIETHYL PHTHALATE
188405.801
282608.701 W
comp
E
D I ETHYLST I BESTROL
la
comp
E
D I HYDROSRFROLE
W
comp
E
D I !'ETHYL PHTHALATE
119565.22
179347.831
Meow
E
DIMETHYLAMINOAZOBENZENE
W
grab
E
DIFIETHYLPIRMIOVLGLORIDE
Maw
E
0 I METHYLSULFATE
W
comp
E
0 ! N I TR0BENZEiE
li
comp
E
DINITROCRESOL
W
comp
E
D I PHENYLAi1 I NE
W
comp
E
DI INE
3.26
4.89
Wc
E
ENDOSlJ. FAN
3.62
-5.43
. W
omp
E
Page 3

AC 1) .EFFLUENT LIMITS MEON I TOR I NG REQ. F 1 NRL CCONT )
CHE11 I CAL
ENO OF PIPE
END OF PIPE
FREQ
SAMPLE LOC
LIMIT Cµg/I)
LIMIT (µg/l)
TYPE
!MONTHLY RUG
DAILY MAX
MORIN
0.14
0.22114,comp
E
EPICHLOROHYDRIN
256. 16
384.241 I4
comp
E
ETHAMETH I OM I DE
Weary
E
ETHYL tETHANESULFON ATE
Wlcocap
E
ETHYLBEMZENE
23550. 72
35326.09
W
grab
E,
HY
ETHYLENE DICHLORIDE
21557971. 01
32336956.52
14
comp
E
ETHYLENE OXIDE
111,7ab
E
ETHYLENE TH I Oi R
W
comp
E
EYHYLENE DIBAOMIDE
0.036231884061
0.05 WIcomp
E
FLLM)REME
0.221
0.331 W
grab
_
E
FLUOR I DE
130434.78
195652.171 W
grab
E
FLUOROANTHENE
_, 105.651
293. 48i LI
comp
E
FORMALDEHYDE
1702.90
2554.351 14,9rab
E
FORMIC ACID
5072463.771
7608695.65i W
comp
E
GLYC I
11
grab
E;
LESS, TOTAL
} 7246376.81
10869565.22 W
comp
•
E
HEPTACHLOR
0.29
0.43
W
comp
r
E
HEPTACHLOR EPDXIDE
W
comp
E,
HEXACHLOROBENZEHE
1.52
2.28
Nam
E
HEXACHLOROBUTADIENE
46.38
69.57. W
comp
E,
HEXACHLOROCYCLOHEXANE
5.80
8.701 W
comp
E
HEXRCI LORt YCLOPENTAD I ENE
25.36
38.041 W
comp
E
HEXACHLOROETHRHE
178.62
267.93
Wlgrab
E
HYDRAZINE
W
grab
E
1 t 0(1, 2, 3-DC )PiRTE
W
comp
E
I N DEHDPYRENES
W
grab
E
IRON
_
72463.77
108695.65
W
comp
E
IRON DEXTRAN
W
comp
E
ISOBUTANOL
W
comp
E
I SSE
- W
comp
E
1 COL
W
comp
E
ISOPHORONE
423913.04
635869.57
W
comp
E
KEPONE
W
comp
E
LAS I OCARR I NE
W
camp
E
LEAD
1811.59
2717.39
W
comp
E
LEAD ACETATE
W
comp
E
LEAD PHOSPHATE_
W
comp
E
LEAD SUBICETATE
11
comp
E
L I f 1E
0.72
1.09
W
comp
E
M-CFESOL
17028.99
25543.48
W.eo®p
E
M-XYLEM£
797.10
1195.651
W
E
grab
SSE
289.861
434.78
W
camp
E
MBAS
36231.88
54347.83
Hemp
E
MELPI
W
comp
E
MERCURY
1.45
2.17
W
comp
E
tETHOXYCHLOR
2.17
3.261
W
comp
E
METHYL CI LOR I DE
1016304. 35
1524456. 52
W
g ab
E,
METHYL ETHYL KETONE
108695.65
163043.481
W
grab
E
METHYL MERCURY
11
comp
E
PETHYLBROM I DE
Wl grab
E
Page 4

AC 1) . EFFLUENT LIMITS NON I TOR I N G REQ. F I NAIL{CONT )
CHEMICAL
END OF PIPE
END OF PIPE
FREQ !SAMPLE
LOC '
LIMIT (µcg/l)
LIMIT (pg/l)
ITYPE
,MONTHLY LY AUG
DAILY MAX
METHYLENE CHLORIDE
144.93
217.39
W,grcb
E
METHYLENE CIL0RONETHYL MDR IDE
W
grab
E
l'ETHYLIODIDE
W
comp
E
I-IETHYL-N' -NI TRO-N-N I T RN I iE
I�l�c
1 E
NI-N
Wicomp
E
I TIC-N-ETHYLUi A
N-N I
.
I1lcomp
E
1-N I TR0S0-11-rETYLL EA
j
Wieomp
E
N-N I TROS D I-N-BUTVLAM I NE
W[comp
E
N-NITROSODI-N-Pf PYLANINE
W
comp
E
N-N 1 TROSODIETHANOLAM I NE
W
comp
E
N-N1TROSOD1ETHYLAMINE
j
W
comp
E
N-N I TR06001 METHYl.AM I NE
0.07!
0. 11
W
comp
E
N-NIITROSOPIPERIDINE
1
W
comp
E
N-NITROSOPYRROLIDINE
Wlcamp
E
N-NITROSOSMETHYLVINYLAMINE
{{
W
comp
E
NAPTHALENE
25000.00I
37500.00
W'coop
- E
NICKEL
3623.19(
5434.781 W
comp
E
NITROBENZENE
2.32
3.48
W,
comp
E
N 1 TROSAti 1 NIES
,
W
comp
E
0-CRESOL
35869.571
53804.35
Wcomp
1
E
0-TOLUIDINE
W
comp
E
0-TOLUIDINE HYDROCHLORIDE
W
comp
E
OIL & GREASE
W
comp
E
P SOL
115.94
173.91
u,comp
E
P-CF ESOL
14492.75
21739.13
Ut
comp
E
P-TOLU I D I NE
t
WIcomp
E
P-XYLENE
57971.01
86956.52
W
grab
E
PARATHION
2.90.
4.35
W
comp
E
PENTEOROPIENIOL
152.17
228.26
W
comp
E
PIENACET I N
- Il
comp
E
PHENAMTHRENE
W
grab
E
PIES.
2463.77.
3695.65
W
comp
E
PIENOL I C COMPOUNDS
72.46
108.701
W
coap
E
PHENYLENEDIAMINE
20797.101
31195. 651
14$comp
E
ATE
2.17
3.26
W
comp
E
PHA I TH I O I C RCID D ESTERS
Wicoop
E
PHOSPHOROTHIOCIC ACID 1Sl tra
W
comp
E
PHTHALIC ANHYDRIDE
1
4 Wicomp
E
POLYCHLOR I MATED D I PHENYL ETHERS
W1grab
E
PYiENE
0.22
0.33
W
coop
I E
PYRIDINE
E 7246.381
10 69.57
W
E
grab
FESERP I NE
t
W
comp
1 E
SACCHARIN AND SILTS
W,
comp
E
SRFROLE
W
comp
E
SELEN I L11'I
'724.64._
1086.96
W
comp
E
SILVER
724.64
1086.06
W
comp
E
STREPT0Z0T0C IN
W
comp
E,
SULFATES
_
18115042.03
27173013.04
W
coop
E
SULFIDE
W
comp
E
TETOROETHYLENE
48.55f 72.83
.ugrab
E
Page?

A(1).EFFLUENT LIMITS MONITORING REQ. FINRL(CONT)
CHEM 1 CAL
E1113 OF PIPE
ENO OF PIPE
FREQ
SAMPLE JLOC ,
LIMIT (µg/I)
LIMIT 0g/I)1
TYPE
MONTHLY AUG
DAILY MAX
T ALL I UM
1014.49
1521. 74: N
comp E
TH I OCYANATE
1 I1
comp
E
TH I A
to
comp
E
TOLUENE
797.101
1195.65' I.I
! E
TOLUENE 011
1 a coal 3 E
TOLUENE-2, 4 D I AM I NE
Mirth
1 E
E
grab i E
TOXAPHENE
0.94
1.41 + W1coop
TR I CHLOROETHYLENE
188.411
282.611 ui
:FRICHLOROFLUOROMETHANE
760869.57'
1141304.35
Id1 grab 1 E
TR I CIL0R0PHENOLS
Ulcoop E
TR I CHLOH0P
W
grcb E
TR I HA..OMETHANES
14I eomp 1 E
U1 1 I UM
i 14
comp
E
URHFID I UM
t U
comp
E
VINYL CHLORIDE
1.091 1.631 11.grab
E
ZINC
3623. 191 5434.781
I1icomp
I . E
i
I 1

Part I
Permit No. NC
B. SCHEDULE OF COMPLIANCE
1. The permittee shall achieve compliance with the effluent
limitations specified for discharges in accordance with the
folllowing schedule:
4. No later than 14 calendar days following a date identified in
the above schedule of compliance, the permittee shall submit
either a report of progress or, in the case of specific actions
being required by identified dates, a written notice of
compliance or noncompliance. In the latter case, the notice
shall include the cause of noncompliance, any remedial actions
taken, and the probability of meeting the next scheduled
requirement.

Permit No. INIC1010
C. MONITORING AND REPORTING
1. Representative Sampling
Samples collected and measurements taken as required herein
shall• be characteristic of the volume and nature of the
permitted discharge. Samples collected at a frequency less
than daily shall be taken on a day and time that is
characteristic of the discharge over the entire period which
the sample represents.
2. Reporting
Monitoring results obtained during the previous month(s)
shall be summarized for each month and reported on a monthly
Discharge Monitoring Report (DMR) Form (DEM No. MR 1, 1.1,
2, 3,) or alternative forms approved by the Director, DEM,
postmarked no later than the 30th day following the
completed reporting period.
The first DMR is due on the last day of the month following
the issuance of the permit or in the case of a new facility,
on the last day of the month following the commencement of
discharge. Duplicate signed copies of these, and all other
reports required herein, shall be submitted to the following
address:
Division of Environmental Management
Water Quality Section
ATTN: Central Files
Post Office Box 27687
Raleigh, NC 27611
3. Definitions
a. Act or "the Act": The Federal Water Pollution Control
Act, also know as the Clean Water Act, as amended, 33 U.S.C.
1251, et. seq.
b. The monthly average, other than for fecal coliform
bacteria, is the arithmetic mean of all the samples
collected in one calendar month. The monthly average for
fecal coliform bacteria is the geometric mean of samples
collected in one calendar month.
c. The weekly average, other than for fecal coliform
bacteria, is the arithmetic mean of all the samples
collected during one calendar week (Sun -Sat). The weekly
average for fecal coliform bacteria is the geometric mean of
all samples collected in one calendar week (Sun -Sat)-.
M 5

Permit No. ;NIC;010
d. DEM or Division: means the Division of Environmental
Management, Department of Natural Resources and Community
Development.
e. EMC: used herein means the North Carolina Environmental
Management Commission.
f. Flow, M3/day (MGD): The flow limit expressed in this
permit is the 24 hour average flow, averaged monthly. It is
determined as the arithmetic mean of the total daily flows
recorded during the calendar month.
g. Arithmetic Mean: The arithmetic mean of any set of
values is the summation of the individual values divided by
the number of individual values.
h. Geometric Mean: The geometric mean of any set of values
is the Nth root of the product of the individual values
where N is equal to the number of individual values. The
geometric mean is equivalent to the antilog of the
arithmetic mean of the logarithms of the individual values.
For purposes of calculating the geometric mean, values of
zero (0) shall be considered to be one (1) .
i. Composite Sample: These samples consist of grab samples
collected at equal intervals and combined proportional to
flow, a sample continuously collected proportionally to
flow, or equal volumes taken at varying time intervals. If a
composite sample is obtained from grab samples, the
following requirements apply. The intervals between influent
grab samples shall be no greater than hourly. Intervals
between effluent grab samples shall be no greater than
hourly except where the detention time of the wastewater in
the facility is greater than 24 hours, in which case, the
interval between grab samples shall be no greater in number
of hours than the detention time in number of days;
provided, however, in no case may the time between effluent
grab samples be greater than six hours nor the number of
grab samples less than four during any discharge period of
24 hours or less.
j. Grab Sample: Grab samples are individual samples
collected over a period of time not exceeding 15 minutes;
the grab sample can be taken manually.
M 6

Permit No. IN;C;010' 1 1 1 1 1
4. Test Procedures
Test procedures for the analysis of pollutants shall conform
to the EMC regulations published pursuant to N.C.G.S.
143-215.63 et seq, the Water and Air Quality Reporting Act,
and to regulations published pursuant to Section 304(g), 33
USC 1314, of the Federal Water Pollution Control Act, As
Amended, and Regulation 40 CFR 136.
5. Recording Results
For each measurement or sample taken pursuant to the
requirements of this permit, the permittee shall record the
following information:
a. The exact place, date, and time of sampling;
b. The dates the analyses were performed; and
c. The person(s) who performed the analyses.
6. Additional Monitoring by Permittee
If the permittee monitors any pollutant at the location(s)
designated herein more frequently than required by this
permit, using approved analytical methods as specified
above, the results of such monitoring shall be included in
the calculation and reporting of the values is required in
the DMR. Such increased frequency shall also be indicated.
The DEM may require more frequent monitoring or the
monitoring of other pollutants not required in this permit
by written notification.
7. Records Retention
All records and information resulting from the monitoring
activities required by this Permit including all records of
analyses performed and calibration and maintenance of
instrumentation and recordings from continuous monitoring
instrumentation shall be retained for a minimum of three (3)
years. This period of retention shall be extended during the
course of any unresolved litigation or if requested by the
Division of Environmental Management or the Regional
Administrator of the Environmental Protection Agency.
M 7

Permit No. ;N;C1010
1111
till
PART II GENERAL CONDITIONS
A. MANAGEMENT REQUIREMENTS
1. Change in Discharge
All discharges authorized herein shall be consistent with
the terms and conditions of this permit. The discharge of
any pollutant identified in this permit more frequently than
or at a level in excess of that authorized shall constitute
a violation of the permit. Any anticipated facility
expansions, production increases, or process modifications
which will result in new, different, or increased discharges
of pollutants must be reported by submission of a new NPDES
application or, if such changes will not violate the
effluent limitations specified in this permit, by notice to
the DEM of such changes. Following such notice, the permit
may be modified to specify and limit any pollutants not
previously limited.
2. Noncompliance Notification
The permittee shall report by telephone to either the
central office or appropriate regional office of the
division as soon as possible but in no case more than 24
hours or on the next working day following the occurrence or
first knowledge of the occurrence of any of the following:
a. Any occurrence at the water pollution control
facility which results in the discharge of significant
amounts of wastes which are abnormal in quantity or
characteristic, such as the dumping of the contents of a
sludge digester, the known passage of a slug of
hazardous substance through the facility or any other
unusual circumstances.
b. Any process unit failure, due to known or unknown
reasons, that render the facility incapable of adequate
wastewater treatment, such as mechanical or electrical
failures of pumps, aerators, compressors, etc.
c. Any failure of a pumping station, sewer line, or
treatment facility resulting in a by-pass directly to
receiving waters without treatment of all or any portion
of the influent to such station or facility.
d. Any time that self -monitoring information indicates
that the facility has gone out of compliance with its
NPDES permit limitations.
M 8

Permit No.
LN!CIOIO
Persons reporting such occurrences by telephone shall also
file a written report in letter form within 15 days
following first knowledge of the occurrence.
3. Facilities Operation
The permittee shall at all times maintain in good working
order and operate as efficiently as possible all treatment
or control facilities or systems installed or used by the
permittee to achieve compliance with the terms and
conditions of this permit.
4. Adverse Impact
The permittee shall take all reasonable steps to minimize
any adverse impact to navigable waters resulting from
noncompliance with any effluent limitations specified in
this permit, including such"accelerated or additional
monitoring as necessary to determine the nature and impact
of the noncomplying discharge.
5. Bypassing
Any diversion from or bypass of facilities is prohibited,
except (i) where unavoidable to prevent loss of life or
severe property damage, or (ii) where excessive storm
drainage or runoff would damage any facilities necessary for
compliance with the effluent limitations and prohibitions of
this permit. All permittees who have such sewer bypasses or
overflows of this discharge shall submit, not later than six
months from the date of issuance of this permit, detailed
data or engineering estimates which identify:
a. The location of each sewer system bypass or overflow;
b. The frequency, duration and quantity of flow from
each sewer system bypass or overflow.
This requirement is waived where infiltration/inflow
analyses are scheduled to be performed as part of an
Environmental Protection Agency facilities planning project.
The permittee shall report by telephone to either the
central office or appropriate regional office of the
division as soon as possible but in no case more than 24
hours or on the next working day following the occurrence or
first knowledge of the occurrence of any diversion from or
bypass of facilities.
M 9

Permit No.
6. Removed Substances
N1C 1 1
Solids, sludges, filter backwash, or other pollutants
removed in the course of treatment or control of wastewaters
shall be disposed of in accordance with NCGS 143-215.1 and
in a' manner such as to prevent any pollutant from such
materials from entering waters of the State or navigable
waters of the United States.
7. Power Failures
The permittee is responsible for maintaining adequate
safeguards to prevent the discharge of untreated or
inadequately treated wastes during electrical power failures
either by means of alternate power sources, standby
generators or retention of inadequately treated effluent.
8. Onshore or Offshore Construction
This permit does not authorize or approve the construction
of any onshore or offshore physical structures or facilities
or the undertaking of any work in any navigable waters.
B. RESPONSIBILITIES
1. Right of Entry
The permittee shall allow the Director of the Division of
Environmental Management, the Regional Administrator, and/or
their authorized representatives, upon the presentations of
credentials:
a. To enter upon the permittee's premises where an
effluent source is located or in which any records are
required to be kept under the terms and conditions of
this permit; and
b. At reasonable times to have access to and copy any
records required to be kept under the terms and
conditions of this permit; to inspect any monitoring
equipment or monitoring method required in this permit;
and to sample any discharge of pollutants.
M 10

Permit No.
2. Transfer of Ownership or Control
NIC;010; 1
1 1 1 1
1 1 1 1
This permit is not transferable. In the event of any
change in control or ownership of facilities from which the
authorized discharge emanates or is contemplated, the
permittee shall notify the prospective owner or controller
by letter of the existence of this permit and of the need to
obtain a permit in the name of the prospective owner. A copy
of the letter shall be forwarded to the Division of
Environmental Management.
3. Availability of Reports
Except for data determined to be confidential under NCGS
143-215.3(a) (2) or Section 308 of the Federal Act, 33 USC
1318, all reports prepared in accordance with the terms
shall be available for public inspection at the offices of
the Division of Environmental Management. As required by the
Act, effluent data shall not be considered confidential.
Knowingly making any false statement on any such report may
result in the imposition of criminal penalties as provided
for in NCGS 143-215.1(b) (2) or in Section 309 of the
Federal Act.
4. Permit Modification
After notice and opportunity for a hearing pursuant to NCGS
143-215.1(b) (2) and NCGS 143-215.1(e) respectively, this
permit may be modified, suspended, or revoked in whole or in
part during its term for cause including, but not limited
to, the following:
a. Violation of any terms or conditions of this permit;
b. Obtaining this permit by misrepresentation or failure
to disclose fully all relevant facts; or
c. A change in any condition that requires either a
temporary or permanent reduction or elimination of the
authorized discharge.
M 11

Permit No. ;NIC1010
5. Toxic Pollutants
Notwithstanding Part II, B-4 above, if a toxic effluent
standard or prohibition (including any schedule of
compliance specified in such effluent standard or
prohibition) is established under Section 307(a) of the Act
for a toxic pollutant which is present in the discharge, if
such standard or prohibition is more stringent than any
limitation for such pollutant in this permit, this permit
shall be revised or modified in accordance with the toxic
effluent standard prohibition and the permittee so notified.
6. Civil and Criminal Liability
Except as provided in permit conditions on "Bypassing" (Part
II, A-5) and "Power Failures" (Part II, A-7), nothing in
this permit shall be construed to relieve the permittee from
any responsibilities, liabilities, or penalties for
noncompliance pursuant to NCGS 143-215.3, 143-215.6 or
Section 309 of the Federal Act, 33 USC 1319. Furthermore,
the permittee is responsible for consequential damages, such
as fish kills, even though the responsibility for effective
compliance may be temporarily suspended.
7. Oil and Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the
institution of any legal action or relieve the permittee
from any responsibilities, liabilities, or penalties to
which the permittee is or may be subject to under NCGS
143-215.75 et seq. or Section 311 of the Federal Act, 33 USC
1321. Furthermore, the permittee is responsible for
consequential damages, such as fish kills, even though the
responsibility for effective compliance may be temporarily
suspended.
8. Property Rights
The issuance of this permit does not convey any property
rights in either real or personal property, or any exclusive
privileges, nor does it authorize any injury to private
property or any invasion of personal rights, nor any
infringement of Federal, State or local laws or regulations.
M 12

Permit No. ;NIC1010I
9. Severability
The provisions of this permit are severable, and if any
provision of this permit to any circumstance is held
invalid, the application of such provision to other
circumstances, and the remainder of this permit shall not be
affected thereby.
10. Expiration of Permit
Permittee is not authorized to discharge after the
expiration date. In order to receive authorization to
discharge beyond the expiration date, the permittee shall
submit such information, forms, and fees as are required by
the agency authorized to issue permits no later than 180
days prior to the expiration date. Any discharge without a
permit after the expiration will subject the permittee to
enforcement procedures as provided in NCGS 143-215.6, and 33
USC 1251 et seq.
11. Industrial Pretreatment Standards
Permittee shall require any industrial dischargers into the
permitted system to meet Federal Pretreatment Standards (40
CFR, Part 403) promulgated in response to Section 307(b) of
the Act. The permittee shall provide semiannual reports to
the permitting agency regarding the pretreatment
requirements which have been imposed on each major
contributing industry and the results achieved therefrom.
Other information may be needed regarding new industrial
discharges and this will be requested from the permittee
after the permitting agency has received notice of the new
industrial discharge.
A major contributing industry is one that: (a) has a flow
of 25,000 gallons or more per average work day; (b) has a
flow greater than five percent of the flow carried by the
municipal system receiving the waste; (c) has in its waste a
toxic pollutant in toxic amounts as defined in standards
issued under Section 307 (a) of the Act; (d) has significant
impact either singly or in combination with other
contributing industries, on the treatment works or the
quality of its effluent.
Any change in the definition of a major contributing
industry as a result of promulgations in response to Section
307 of the Act shall become a part of this permit.
M 13

Permit No.
PART III OTHER REQUIREMENTS
A. Requirements for Effluent Limitations on Pollutants Attributable
to Industrial Users
1. Effluent limitations are listed in Part I of this permit.
Other pollutants attributable to inputs from major contributing
industries using the municipal system may be present in the
permittee's discharge. At such time as sufficient information
becomes available to establish limitations for such pollutants,
this permit may be revised to specify effluent limitations for
any or all of such other pollutants in accordance with best
practicable technology or water quality standards.
2. Under no circumstances shall the permittee allow introduction
of the following wastes into the waste treatment system:
a. Wastes which create a fire or explosion hazard in the
treatment works.
b. Wastes which will cause corrosive structural damage to
treatment works, and in no case discharges with pH less than
5 unless the system is specifically designed to accomodate
such discharges.
c. Solid or viscous substances in amounts which cause
obstructions to the flow in sewers or interference with the
proper operation of the treatment works.
d. Wastewaters at a flow rate and/or pollutant concentration
which will cause a loss of treatment efficiency.
e. Heat in amounts which will inhibit biological activity in
the treatment works, resulting in interference but in no
case heat in such quantities that the temperature at the
treatment works influent exceeds 40 C (104 F) unless the
works are designed to accommodate such heat.
3. With regard to the effluent requirements listed in Part I of
this permit, it may be necessary for the permittee to supplement
the requirements of the Federal Pretreatment Standards (40 CFR,
Part 403) to ensure compliance by the permittee with all
applicable effluent limitations. Such actions by the permittee
may be necessary regarding some or all of the major contributing
industries discharging to the municipal system.
M 14

Permit No.
IN1C1010
1 1 1 1
1 I I I
4. This Permit shall be modified, or alternatively, revoked and
reissued, to incorporate or modify an approved POTW Pretreatment
Program or to include a compliance schedule for the development
of a POTW Pretreatment Program as required under Section
402(b)(8) of the Clean Water Act and implementing regulations or
by the requirements of the approved State pretreatment program,
as appropriate.
B. Previous Permits
All previous State water quality permits issued to this
facility, whether for construction or operation or discharge,
are hereby revoked by issuance of this permit. The conditions,
requirements, terms, and provisions of this permit authorizing
discharge under the National Pollutant Discharge Elimination
System govern discharges from this facility.
C. Construction
No construction of wastewater treatment facilities or additions
thereto shall be begun until Final Plans and Specifications have
been submitted to the Division of Environmental Management and
written approval and Authorization to Construct has been issued.
D. Certified Operator
Pursuant to Chapter 90A of North Carolina General Statutes, the
permittee shall employ a certified wastewater treatment plant
operator in responsible charge:,of the wastewater treatment
facilities. Such operator must hold a certification of the grade
equivalent to or greater than the classification assigned to the
wastewater treatment facilities.
E. Groundwater Monitoring
The permittee shall, upon written notice from the Director of
the Division of Environmental Management, conduct groundwater
monitoring as may be required to determine the compliance of
this NPDES permitted facility with the current groundwater
standards.
M 15

Permit No. Continued
Permit No. NC0044725
F. Toxicity Reopener
This permit shall be modified, or revoked and reissued to incorporate
additional toxicity limitations and monitoring requirements in the event
toxicity testing or other studies conducted on the effluent or receiving
stream indicate that detrimental effects may be expected in the receiving
stream as a result of this discharge.
G. Limitations Reopener
This permit shall be modified, or alternatively, revoked and reissued, to comply
with any applicable effluent standard or limitation issued or approved under
Sections 301(b) (2) (C), and (D), 304(b) (2), and 307(a) (2) of the Clean Water
Act, if the effluent standard or limitation so issued or approved:
1. contains different conditions or is otherwise more stringent than any
effluent limitation in the permit, or
2. controls any pollutant not limited in the permit.
The permit as modified or reissued under this paragraph shall also contain any
other requirements in the Act then applicable.
H. This permit shall be modified, or revoked and reissued, to incorporate new
limitations in this permit in the event an industry ties.on to this treatment
works that will change the wastewater strengths to the treatment works to the
extent of having an impact on the Lumber River.
I. The disposal of any sludge or solid waste that is generated at this facility
shall comply with all applicable state and federal rules and regulations
regarding this disposal as implemented by the N.C. Department of Human Resources
and the N.C. Department of Natural Resources and Community Development.
J. Toxicity Limitations and Monitoring Requirements
1. The permittee shall conduct chronic toxicity tests on a weekly basis using
protocols defined in E.P.A. Document 600/4-85/014 entitled "Short -Term
Methods for Estimating the Chronic Toxicity of Effluents and Receiving
Waters to Freshwater Organisms". The testing shall be performed as a
Ceriodaphnia Survival and Reproduction Test. Effluent collection will
be performed as daily 24 hour composite samples. Effluent samples will be
taken immediately prior to disinfection, but after all other treatment
processes. The Chronic Value (ChV) must be greater than 1.4%. There will
be minimally five effluent concentrations and a control exposure treatment.
One effluent concentration shall equal 1.4%, which represents the instream

DRAFT
Part III Continued
Permit No. NC0044725
waste concentration (I.W.C.) during 7Q10 low flow conditions and daily
permitted discharge volume. The remaining concentrations shall be 0.4,
0.7, 3, 6 and 95%. There may not be more than 20% mortality in at least
95% effluent after 48 hours of exposure.
2. The permittee shall conduct monthly 96 hour acute static daily renewal
toxicity tests using protocols defined in E.P.A. Document 600/4-85/013
entitled "Methods of Measuring the Acute Toxicity of Effluent to Freshwater
and Marine Organisms." The testing shall be performed as a Pimephales
promelas Survival Test. Effluent collection will be performed as 24 hour
composite samples. There shall be no more than 107 mortality in at least
100% effluent after 96 hours of exposure.
Note: Failure to achieve test conditions as specified in the cited
documents, such as minimum control organism survival and appropriate
environmental controls, shall constitute an invalid test and will require
immediate retesting. Failure to submit suitable test results will
constitute a permit violation.
K. Biological Monitoring
The permittee shall prepare and submit a biological monitoring plan within 180
days following issuance of this Permit for approval by the Director, Division of
Environmental Management. Such approved monitoring is to be conducted on an
annual basis and is to be initiated within one year following issuance of this
Permit. The permittee shall submit the results of biological studies and
monitoring studies in a manner and under a schedule to be approved by the
Director of the Division of Environmental Management.
L. Permit Reopeners
This Permit shall be modified, or alternatively revoked and reissued, to
incorporate new effluent limitations and monitoring requirements into this
Permit in the event:
1. there is a change in the 7Q10 flow of the Lumber River that warrants more
stringent effluent limitations;
2. that long term BOD data demonstrates a need to modify the present CBOD/BOD
ratio of 2.0;
3. that ambient data indicates that the upstream background concentration of
any pollutant is greater than zero;
4. that constituents not included in this Permit are identified in the
Laurinburg Maxton Airport Commission effluent (from headworks or effluent
analyses);

t:•ss +tiy
Permit III Continued
Permit No. NC0044725
5. that new constituents are added to any industry's effluent discharge to the
Laurinburg-Maxton Airport Commission treatment plant;
6. the Division of Environmental Management sets a water quality standard or
a no -effect chronic level for aquatic toxicity or the Environmental
Protection Agency establishes an effluent guideline for any constituent
listed in this Permit or found in the Laurinburg-Maxton Airport Commission
effluent;
7. the Division of Environmental Management changes any existing water
quality standard or if any applicable Environmental Protection Agency
effluent guideline is changed;
8. the Department of Human Resources, Division of Health Services determines
new safe drinking water levels for chemicals not listed in this Permit;
9. the Department of Human Resources, Division of Health Services, makes any
safe drinking water levels more stringent for any chemical listed in this
Permit.

• Pretreatment Program Implementation
Under authority of sections 307(b) and (c) and 402 (b) (8) of the
Clean Water Act and implementing regulations 40 CFR Part 403; North
Carolina General Statute 143-215.3 (14) and implementing regulations
15 NCAC 2H .0900, and in accordance with the approved pretreatment
program all provisions and regulations contained and referenced in
the Pretreatment Program Submittal are an enforceable part of this
NPDES permit.
The permittee shall operate its approved pretreatment program in
accordance with section 402(b)(8) of the Clean Water Act, the
Federal Pretreatment Regulations 40 CFR Part 403, the State
Pretreatment Regulations 15 NCAC 2H .0900, and the legal
authorities, policies, procedures, and financial provisions
contained in its pretreatment program submission. Such operation
shall include but is not limited to the implementation of the
following conditions and requirements:
1. The permittee shall develop, in accordance with 40 CFR
403.5(c), specific limits to implement the prohibitions listed
in 40 CFR 403.5 (a) and (b) .
2. The permittee shall issue permits for construction,
operation and discharge to all significant industrial users in
accordance with NCGS 143-215. These permits shall contain
limitations, sampling protecals, ". reporting requirements,
appropriate standard conditions, -and compliance schedules as
necessary for the installation of control technologies to meet
applicable pretreatment standards and requirements. Prior to
the issuance of a permit to construct or as a condition of the
permit an evaluation of the treatment process proposed must be
made as to its capacity to meet the permit limitations.
3. The permittee shall carry out inspection, surveillance, and
monitoring requirements as described in its approved
pretreatment program in order to determine, independent of
information supplied by industrial users, compliance with
applicable pretreatment standards. All significant industrial
users must be sampled at least twice per year for limited
parameters.
4. The permittee shall enforce and obtain appropriate remedies,
for noncompliance with categorical pretreatment standards
promulgated pursuant to section 307(b) and (c) of the Clean
Water Act (40 CFR 405 et.seq.), prohibitive discharge standards
as set forth in 40 CFR 403.5, specific local limitations --and
pretreatment permit requirements.
5. The permittee shall require all industrial users to comply
with the applicable monitoring and reporting requirements
outlined in the approved pretreatment program, the industries
pretreatment permit and/or in 15 NCAC 2H.0908.
•
M

6. The permittee shall submit twice per year a pretreatment
report describing its pretreatment activities over the previous
six months. A report shall be submitted to the Division by
August 1 of each year describing pretreatment activities for
January 1 through June 30 of that year, and a like report shall
be submitted by February 1 of each year for activities conducted
from July 1 through December 31 of the previous year. These
reports shall contain, but not be limited to, the following
information:
a. a narrative summary of actions taken by the
permittee to ensure compliance with pretreatment -
requirements
b. a list of any substantive changes made in the
approved program
c. a compliance status summary of all significant
industrial users
d. a list of those industrial users in violation of
pretreatment requirements, the nature of the violations,
and actions taken or proposed to correct the violations
e. sampling and analytical results recorded on indirect
discharger monitoring reporting (IDMR) forms.
7. The permittee shall retain for a minimum of three years
records of monitoring activities and results, along with support
information including general records, water quality records,
and records of industrial impact on the POTW.
8. The permittee shall publish annually, pursuant to section
101(c) of the Clean Water Act and 40 CFR Part 105, a list of
industrial users that have significantly violated pretreatment
requirements during the previous twelve month period.
9. The permittee shall maintain adequate funding levels to
accomplish the objectives of its approved pretreatment program.
10. The permittee shall maintain adequate legal authority to
implement its approved pretreatment program.
11. The permittee shall update its industrial user survey at
least once every three years .
12. Modifications to the approved pretreatment program including
but not limited to local limits modifications and monitoring
program changes shall be considered permit modification and
shall be governed by 15 NCAC 2H .0114.
M

DIVISION OF ENVIRONMENTAL MANAGEMENT
September 5, 1986
MEMORANDUM
TO: George T. Everett
FROM: Steve W. Tedder
SUBJECT: Preliminary Draft NPDES Permit
Lau ri nburg-Maxto n Airport Authority
NC0044725
As requested, the staff of the Water Quality Section has prepared
a very preliminary draft version of the LMAC permit with GSX as an
indirect discharge to the LMAC, POTW.
As you can see, we have written this permit to allow the best
possible assurance that the intended and classified uses of the Lumber
River would be protected. The compounds either limited or for which
monitoring are required are based on the following:
A. Categorical Standards for indirect discharges;
B. Compounds to be received and treated by GSX;
C. Intensive Bioassay Evaluation Report (DEM);
D. Compounds found at similar facility in New York State;
E. Applicable water quality standards.
Based on the information we have, each of these compounds may be
in the LMAC wastewaters. The list of compounds to be handled by GSX
has changed several times so this list is yet to be finalized as this
is a very early draft.
In addition, as we are to protect for aquatic life and in this
case, there is a drinking water supply downstream, we have also
included drinking water criteria in our evaluations and limitations.
As we are still awaiting comments and recommendations from DHR, these
limits are also subject to change. Where water quality and drinking
water standards were applicable, we chose to use the most restrictive
criteria of the two for limitation purposes.

George Everett
September 5, 1986
- page two -
Whereas, GSX has proposed substantial monitoring of their dis-
charge, it is essential that we concentrate our controls at the river
discharge point. Potential interaction of the multiple waste sources
of this POTW should necessitate extensive limits and monitoring at
the discharge of LMAC.
This draft is for review and discussion. Whereas the details,
numbers, etc. are subject to modification as we review more thoroughly,
our overall concept is fairly clear as to how we wish to proceed
technically.
Upon your review, we will meet with appropriate water quality
staff to discuss.
SWT:mlt
cc: Ken Eagleson
Arthur Mouberry
Dale Overcash
Bill Kreutzberger
John Dorney
Dave Vogt

Permit No. NC0044725
STATE OF NORTH CAROLINA
DEPARTMENT OF NATURAL RESOURCES & COMMUNITY DEVELOPMENT
DIVISION OF ENVIRONMENTAL MANAGEMENT
PERMIT
To Discharge Wastewater Under the NATIONAL
POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions 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,
Laurinburg-Maxton Airport Commission
is hereby authorized to discharge wastewater from a facility located at
Laurinburg-Maxton Airport
Wastewater Treatment Plant
on NCSR 1434
East of Laurinburg
Scotland County
to receiving waters designated as the Lumber River in the Lumber River Basin
in accordance with effluent limitations, monitoring requirements, and other conditions
set forth in Part 1, II, and III hereof.
This permit shall become effective
This permit and the authorization to discharge shall expire at midnight on
Signed this day of
R. PAUL WILMS, DIRECTOR
DIVISION OF ENVIRONMENTAL MANAGEMENT
BY AUTHORITY OF THE ENVIRONMENTAL
MANAGEMENT COMMISSION
M1 & 11

Permit No. NC0044725
SUPPLEMENT TO PERMIT COVER SHEET
Laurinburg-Maxton Airport Commission
is hereby authorized to:
1. Continue the operation of the existing 1.0 MGD wastewater treatment plant
consisting of influent pumping, comminution, grit removal, oxidation ditches,
clarifiers, chlorination, effluent pumping, sludge drying beds.
2. After receiving an Authorization to Construct from the Division of Environ-
mental Management construct additional facilities as may be needed to meet
the final effluent limitations contained in this Permit (See Part III, Condition
No. C of this Permit) , and
3. Discharge 1.0 MGD from said treatment works at the point of the existing
discharge into the Lumber River which is classified Class "C" waters in the
Lumber River Basin.
0

Y
A. (1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL
During the period beginning on the effectiveidate of the Permit and lasting until expiration,
the pennittee is authorized to discharge from outfall(s) 'serial number(s) 001.
Such discharges shall be limited and monitored by the pennittee as specified below:
Effluent Characteristics
Discharge Limitations
lbs/day Other -Units (Specify)
Monthly -Avg. WeekTy Avg. Month ty Avg. iieeKly Avg.
Flow
BOD, 5Day, 20°C**
Total Suspended Residue**
NH, as N
Fecal Coliform (geometric mean) *****
Residual Chlorine
Temperature
Total Nitrogen (NO2 + NO3 + TKN)
Total Phosphorus
Chloride 1451
Sodium 1451
Toxicity
Biological Monitoring
**
1814
1669
* Sample location: E - Effluent, I - Influent
Monitoring Requirements
Measurement
requen y
1.0 MGD Continuous
30.0 mg/I 45.0 mg /I Weekly
30.0 mg/I 45.0 mg/I Weekly
Weekly
1 000. 0 / 100 ml . 2000. 0 / 100 ml . Weekly
RAF
The monthly average effluent BOD5 and Total Suspended Residue
respective influent values (85% removal)
Daily
Weekly
Monthly
Monthly
Weekly
Weekly
***
Annual ****
Recording
Composite
Composite
Composite
Grab
Grab
Grab
Composite
Composite
Composite
Composite
***
*
Location
consentrations shall not exceed 15% of the
*** See Part III, Condition No. K.
The pH shall not be less than 6.o standard units nor greater than 9.0 standard units and
shall be monitored weekly
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Continued ...
I or E
E
I, E
E
E
E
E
E
E
E
***
c-� w a a
A �
tr+
0 0

Permit No. NC 0044725
Biological Monitoring will be conducted as required by Part I11 Condition No. L, of the Permit. Biobgical
monitoring shall include assessment of invertebrate populations and fishery body burden bioaccumulation
assessments. Additional limitations may be imposed, after opportunity for hearing by the Director of
the Division of Environmental Management, provided that said limitations are required to insure that the
Lumber River is suitable for its assigned best usage.
In the event the Lumber River is reclassified from Class "C" to Class "B" waters, the following fecal
coliform effluent limitations shall apply:
Monthly Average 200. 0 /100 ml. Weekly Average 400. 0 /100 ml.

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Page 6

Part I
Permit No. NC
B. SCHEDULE OF COMPLIANCE
1. The permittee shall achieve compliance with the effluent
limitations specified for discharges in accordance with the
folllowing schedule:
No later than 14 calendar days following a date identified in
the above schedule of compliance, the permittee shall submit
either a report of progress or, in the case of specific actions
being required by identified dates, a written notice of
compliance or noncompliance. In the latter case, the notice
shall include the cause of noncompliance, any remedial actions
taken, and the probability of meeting the next scheduled
requirement.

Permit No. IN1C10101 1
C. MONITORING AND REPORTING
1. Representative Sampling
Samples collected and measurements taken as required herein
shall be characteristic of the volume and nature of the
permitted discharge. Samples collected at a frequency less
than daily shall be taken on a day and time that is
characteristic of the discharge over the entire period which
the sample represents.
2. Reporting
Monitoring results obtained during the previous month(s)
shall be summarized for each month and reported on a monthly
Discharge Monitoring Report (DMR) Form (DEM No. MR 1, 1.1,
2, 3,) or alternative forms approved by the Director, DEM,
postmarked no later than the 30th day following the
completed reporting period.
The first DMR is due on the last day of the month following
the issuance of the permit or in the case of a new facility,
on the last day of the month following the commencement of
discharge. Duplicate signed copies of these, and all other
reports required herein, shall be submitted to the following
address:
Division of Environmental Management
Water Quality Section
ATTN: Central Files
Post Office Box 27687
Raleigh, NC 27611
3. Definitions
a. Act or "the Act": The Federal Water Pollution Control
Act, also know as the Clean Water Act, as amended, 33 U.S.C.
1251, et. seq.
b. The monthly average, other than for fecal coliform
bacteria, is the arithmetic mean of all the samples
collected in one calendar month. The monthly average for
fecal coliform bacteria is the geometric mean of samples
collected in one calendar month.
c. The weekly average, other than for fecal coliform
bacteria, is the arithmetic mean of all the samples
collected during one calendar week (Sun -Sat). The weekly
average for fecal coliform bacteria is the geometric mean of
all samples collected in one calendar week (Sun -Sat).
M 5

Permit No.
1 1 1 1
1 1 1 1
d. DEM or Division: means the Division of Environmental
Management, Department of Natural Resources and Community
Development.
e. EMC: used herein means the North Carolina Environmental
Management Commission.
f. Flow, M3/day (MGD): The flow limit expressed in this
permit is the 24 hour average flow, averaged monthly. It is
determined as the arithmetic mean of the total daily flows
recorded during the calendar month.
g. Arithmetic Mean: The arithmetic mean of any set of
values is the summation of the individual values divided by
the number of individual values.
h. Geometric Mean: The geometric mean of any set of values
is the Nth root of the product of the individual values
where N is equal to the number of individual values. The
geometric mean is equivalent to the antilog of the
arithmetic mean of the logarithms of the individual values.
For purposes of calculating the geometric mean, values of
zero (0) shall be considered to be one (1).
i. Composite Sample: These samples consist of grab samples
collected at equal intervals and combined proportional to
flow, a sample continuously collected proportionally to
flow, or equal volumes taken at varying time intervals. If a
composite sample is obtained from grab samples, the
following requirements apply. The intervals between influent
grab samples shall be no greater than hourly. Intervals
between effluent grab samples shall be no greater than
hourly except, where the detention time of the wastewater in
the facility is greater than 24 hours, in which case, the
interval between grab samples shall be no greater in number
of hours than the detention time in number of days;
provided, however, in no case may the time between effluent
grab samples be greater than six hours nor the number of
grab samples less than four during any discharge period of
24 hours or less.
j. Grab Sample: Grab samples are individual samples
collected over a period of time not exceeding 15 minutes;
the grab sample can be taken manually.
M 6

Permit No.
4. Test Procedures
NiCi0101 11111
Test procedures for the analysis of pollutants shall conform
to the EMC regulations published pursuant to N.C.G.S.
143-215.63 et seq, the Water and Air Quality Reporting Act,
and to regulations published pursuant to Section 304(g), 33
USC 1314, of the Federal Water Pollution Control Act, As
Amended, and Regulation 40 CFR 136.
5. Recording Results
For each measurement or sample taken pursuant to the
requirements of this permit, the permittee shall record the
following information:
a. The exact place, date, and time of sampling;
b. The dates the analyses were performed; and
c. The person(s) who performed the analyses.
6. Additional Monitoring by Permittee
If the permittee monitors any pollutant at the location(s)
designated herein more frequently than required by this
permit, using approved analytical methods as specified
above, the results of such monitoring shall be included in
the calculation and reporting of the values is required in
the DMR. Such increased frequency shall also be indicated.
The DEM may require more frequent monitoring or the
monitoring of other pollutants not required in this permit
by written notification.
7. Records Retention
All records and information resulting from the monitoring
activities required by this Permit including all records of
analyses performed and calibration and maintenance of
instrumentation and recordings from continuous monitoring
instrumentation shall be retained for a minimum of three (3)
years. This period of retention shall be extended during the
course of any unresolved litigation or if requested by the
Division of Environmental Management or the Regional
Administrator of the Environmental Protection Agency.
M 7

Permit No. ;NWC=OWI I
PART II GENERAL CONDITIONS
A. MANAGEMENT REQUIREMENTS
1. Change in Discharge
All discharges authorized herein shall be consistent with
the terms and conditions of this permit. The discharge of
any pollutant identified in this permit more frequently than
or at a level in excess of that authorized shall constitute
a violation of the permit. Any anticipated facility
expansions, production increases, or process modifications
which will result in new, different, or increased discharges
of pollutants must be reported by submission of a new NPDES
application or, if such changes will not violate the
effluent limitations specified in this permit, by notice to
the DEM of such changes. Following such notice, the permit
may be modified to specify and limit any pollutants not
previously limited.
2. Noncompliance Notification
The permittee shall report by telephone to either the
central office or appropriate regional office of the
division as soon as possible but in no case more than 24
hours or on the next working day following the occurrence or
first knowledge of the occurrence of any of the following:
a. Any occurrence at the water pollution control
facility which results in the discharge of significant
amounts of wastes which are abnormal in quantity or
characteristic, such as the dumping of the contents of a
sludge digester, the known passage of a slug of
hazardous substance through the facility or any other
unusual circumstances.
b. Any process unit failure, due to known or unknown
reasons, that render the facility incapable of adequate
wastewater treatment, such as mechanical or electrical
failures of pumps, aerators, compressors, etc.
c. Any failure of a pumping station, sewer line, or
treatment facility resulting in a by-pass directly to
receiving waters without treatment of all or any portion
of the influent to such station or facility.
d. Any time that self -monitoring information indicates
that the facility has gone out of compliance with its
NPDES permit limitations.
M 8

Permit No.
NIC1�I I I I I I i
Persons reporting such occurrences by telephone shall also
file a written report in letter form within 15 days
following first knowledge of the occurrence.
3. Facilities Operation
The permittee shall at all times maintain in good working
order and operate as efficiently as possible all treatment
or control facilities or systems installed or used by the
permittee to achieve compliance with the terms and
conditions of this permit.
4. Adverse Impact
The permittee shall take all reasonable steps to minimize
any adverse impact to navigable waters resulting from
noncompliance with any effluent limitations specified in
this permit, including such accelerated or additional
monitoring as necessary to determine the nature and impact
of the noncomplying discharge.
5. Bypassing
Any diversion from or bypass of facilities is prohibited,
except (i) where unavoidable to prevent loss of life or
severe property damage, or (ii) where excessive storm
drainage or runoff would damage any facilities necessary for
compliance with the effluent limitations and prohibitions of
this permit. All permittees who have such sewer bypasses or
overflows of this discharge shall submit, not later than six
months from the date of issuance of this permit, detailed
data or engineering estimates which identify:
a. The location of each sewer system bypass or overflow;
b. The frequency, duration and quantity of flow from
each sewer system bypass or overflow.
This requirement is waived where infiltration/inflow
analyses are scheduled to be performed as part of an
Environmental Protection Agency facilities planning project.
The permittee shall report by telephone to either the
central office or appropriate regional office of the
division as soon as possible but in no case more than 24
hours or on the next working day following the occurrence or
first knowledge of the occurrence of any diversion from or
bypass of facilities.
M 9

Permit No. INIC10101 ; I I !
6. Removed Substances
Solids, sludges, filter backwash, or other pollutants
removed in the course of treatment or control of wastewaters
shall be disposed of in accordance with NCGS 143-215.1 and
in a manner such as to prevent any pollutant from such
materials from entering waters of the State or navigable
waters of the United States.
7. Power Failures
The permittee is responsible for maintaining adequate
safeguards to prevent the discharge of untreated or
inadequately treated wastes during electrical power failures
either by means of alternate power sources, standby
generators or retention of inadequately treated effluent.
8. Onshore or Offshore Construction
This permit does not authorize or approve the construction
of any onshore or offshore physical structures or facilities
or the undertaking of any work in any navigable waters.
B. RESPONSIBILITIES
1. Right of Entry
The permittee shall allow the Director of the Division of
Environmental Management, the Regional Administrator, and/or
their authorized representatives, upon the presentations of
credentials:
a. To enter upon the permittee's premises where an
effluent source is located or in which any records are
required to be kept under the terms and conditions of
this permit; and
b. At reasonable times to have access to and copy any
records required to be kept under the terms and
conditions of this permit; to inspect any monitoring
equipment or monitoring method required in this permit;
and to sample any discharge of pollutants.
M 10

Permit No. IN;C;010
2. Transfer of Ownership or Control
i
This permit is not transferable. In the event of any
changein control or ownership of facilities from which the
authorized discharge emanates or is contemplated, the
permittee shall notify the prospective owner or controller
by letter of the existence of this permit and of the need to
obtain a permit in the name of the prospective owner. A copy
of the letter shall be forwarded to the Division of
Environmental Management.
3. Availability of Reports
Except for data determined to be confidential under NCGS
143-215.3(a) (2) or Section 308 of the Federal Act, 33 USC
1318, all reports prepared in accordance with the terms
shall be available for public inspection at the offices of
the Division of Environmental Management. As required by the
Act, effluent data shall not be considered confidential.
Knowingly making any false statement on any such report may
result in the imposition of criminal penalties as provided
for in NCGS 143-215.1(b) (2) or in Section 309 of the
Federal Act.
4. Permit Modification
After notice and opportunity for a hearing pursuant to NCGS
143-215.1(b) (2) and NCGS 143-215.1(e) respectively, this
permit may be modified, suspended, or revoked in whole or in
part during its term for cause including, but not limited
to, the following:
a. Violation of any terms or conditions of this permit;
b. Obtaining this permit by misrepresentation or failure
to disclose fully all relevant facts; or
c. A change in any condition that requires either a
temporary or permanent reduction or elimination of the
authorized discharge.
M 11

Permit No.
5. Toxic Pollutants
Notwithstanding Part II, B-4 above, if a toxic effluent
standard or prohibition (including any schedule of
compliance specified in such effluent standard or
prohibition) is established under Section 307(a) of the Act
for a toxic pollutant which is present in the discharge, if
such standard or prohibition is more stringent than any
limitation for such pollutant in this permit, this permit
shall be revised or modified in accordance with the toxic
effluent standard prohibition and the permittee so notified.
6. Civil and Criminal Liability
Except as provided in permit conditions on "Bypassing" (Part
II, A-5) and "Power Failures" (Part II, A-7), nothing in
this permit shall be construed to relieve the permittee from
any responsibilities, liabilities, or penalties for
noncompliance pursuant to NCGS 143-215.3, 143-215.6 or
Section 309 of the Federal Act, 33 USC 1319. Furthermore,
the permittee is responsible for consequential damages, such
as fish kills, even though the responsibility for effective
compliance may be temporarily suspended.
7. Oil and Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the
institution of any legal action or relieve the permittee
from any responsibilities, liabilities, or penalties to
which the permittee is or may be subject to under NCGS
143-215.75 et seq. or Section 311 of the Federal Act, 33 USC
1321. Furthermore, the permittee is responsible for
consequential damages, such as fish kills, even though the
responsibility for effective compliance may be temporarily
suspended.
8. Property Rights
The issuance of this permit does not convey any property
rights in either real or personal property, or any exclusive
privileges, nor does it authorize any injury to private
property or any invasion of personal rights, nor any
infringement of Federal, State or local laws or regulations.
M 12

Permit No. 1NICI0101 1 1
9. Severability
The provisions of this permit are severable, and if any
provision of this permit to any circumstance is held
invalid, the application of such provision to other
circumstances, and the remainder of this permit shall not be
affected thereby.
10. Expiration of Permit
Permittee is not authorized to discharge after the
expiration date. In order to receive authorization to
discharge beyond the expiration date, the permittee shall
submit such information, forms, and fees as are required by
the agency authorized to issue permits no later than 180
days prior to the expiration date. Any discharge without a
permit after the expiration will subject the permittee to
enforcement procedures as provided in NCGS 143-215.6, and 33
USC 1251 et seq.
11. Industrial Pretreatment Standards
Permittee shall require any industrial dischargers into the
permitted system to meet Federal Pretreatment Standards (40
CFR, Part 403) promulgated in response to Section 307(b) of
the Act. The permittee shall provide semiannual reports to
the permitting agency regarding the pretreatment
requirements which have been imposed on each major
contributing industry and the results achieved therefrom.
Other information may be needed regarding new industrial
discharges and this will be requested from the permittee
after the permitting agency has received notice of the new
industrial discharge.
A major contributing industry is one that: (a) has a flow
of 25,000 gallons or more per average work day; (b) has a
flow greater than five percent of the flow carried by the
municipal system receiving the waste; (c) has in its waste a
toxic pollutant in toxic amounts as defined in standards
issued under Section 307 (a) of the Act; (d) has significant
impact either singly or in combination with other
contributing industries, on the treatment works or the
quality of its effluent.
Any change in the definition of a major contributing
industry as a result of promulgations in response to Section
307 of the Act shall become a part of this permit.
M 13

Permit No. INIC10101 I
PART III OTHER REQUIREMENTS
A. Requirements for Effluent Limitations on Pollutants Attributable
to Industrial Users
1. Effluent limitations are listed in Part I of this permit.
Other pollutants attributable to inputs from major contributing
industries using the municipal system may be present in the
permittee's discharge. At such time as sufficient information
becomes available to establish limitations for such pollutants,
this permit may be revised to specify effluent limitations for
any or all of such other pollutants in accordance with best
practicable technology or water quality standards.
2. Under no circumstances shall the permittee allow introduction
of the following wastes into the waste treatment system:
a. Wastes which create a fire or explosion hazard in the
treatment works.
b. Wastes which will cause corrosive structural damage to
treatment works, and in no case discharges with pH less than
5 unless the system is specifically designed to accomodate
such discharges.
c. Solid or viscous substances in amounts which cause
obstructions to the flow in sewers or interference with the
proper operation of the treatment works.
d. Wastewaters at a flow rate and/or pollutant concentration
which will cause a loss of treatment efficiency.
e. Heat in amounts which will inhibit biological activity in
the treatment works, resulting in interference but in no
case heat in such quantities that the temperature at the
treatment works influent exceeds 40 C (104 F) unless the
works are designed to accommodate such heat.
3. With regard to the effluent requirements listed in Part I of
this permit, it may be necessary for the permittee to supplement
the requirements of the Federal Pretreatment Standards (40 CFR,
Part 403) to ensure compliance by the permittee with all
applicable effluent limitations. Such actions by the permittee
may be necessary regarding some or all of the major contributing
industries discharging to the municipal system.
M 14

Permit No. ;NICI0101 ; j
4. This Permit shall be modified, or alternatively, revoked and
reissued, to incorporate or modify an approved POTW Pretreatment
Program or to include a compliance schedule for the development
of a POTW Pretreatment Program as required under Section
402(b)(8) of the Clean Water Act and implementing regulations or
by the requirements of the approved State pretreatment program,
as appropriate.
B. Previous Permits
All previous State water quality permits issued to this
facility, whether for construction or operation or discharge,
are hereby revoked by issuance of this permit. The conditions,
requirements, terms, and provisions of this permit authorizing
discharge under the National Pollutant Discharge Elimination
System govern discharges from this facility.
C. Construction
No construction of wastewater treatment facilities or additions
thereto shall be begun until Final Plans and Specifications have
been submitted to the Division of Environmental Management and
written approval and Authorization to Construct has been issued.
D. Certified Operator
Pursuant to Chapter 90A of North Carolina General Statutes, the
permittee shall employ a certified wastewater treatment plant
operator in responsible charge of the wastewater treatment
facilities. Such operator must hold a certification of the grade
equivalent to or greater than the classification assigned to the
wastewater treatment facilities.
E. Groundwater Monitoring
The permittee shall, upon written notice from the Director of
the Division of Environmental Management, conduct groundwater
monitoring as may be required to determine the compliance of
this NPDES permitted facility with the current groundwater
standards.
M 15

Part III Continued
F. Toxicity Reopener RAF
This permit shall be modified, or revoked and reissued to" Permit No. NC0044725
incorporate toxicity
limitations and monitoring requirements in the event toxicity testing or other
studies conducted on the effluent or receiving stream indicate that detrimental
effects may be expected in the receiving stream as a result of this discharge.
G. Limitations Reopener
This permit shall be modified, or alternatively, revoked and reissued, to comply
with any applicable effluent standard or limitation issued or approved under Sections
301(b) (2) (C), and (D), 304(b) (2), and 307(a) (2) of the Clean Water Act, if the
effluent standard or limitation so issued or approved:
1. contains different conditions or is otherwise more stringent than any effluent
limitation in the permit, or
2. controls any pollutant not limited in the permit.
The permit as modified or reissued under this paragraph shall also contain any other
requirements in the Act then applicable.
H. This permit shall be modified, or revoked and reissued, to incorporate new limitations
into this permit in the event an industry ties on to this treatment works that will
change the wastewater strengths to the treatment works to the extent_.of having an
impact on the Lumber River.
I. Should violations of the fecal conform requirement of the North Carolina Water Quality
Standards occur, the permittee shall undertake immediate corrective action to remedy
the violation.
J. The disposal of any sludge or solid waste that is generated at this factility shall
comply with all applicable state and federal rules and regulations regarding this
disposal as implemented by the NC Department of Human Resources and the NC
Department of Natural Resources and Community Development.
K. Toxicity Limitations and Monitoring Requirements
1. The permittee shall conduct chronic toxicity tests on a weekly basis using
protocols defined in E.P.A. Document 600 /4- 85 /014 entitled "Short -Term
Methods for Estimating the Chronic Toxicity of Effluents and Receiving Waters
to Freshwater Organisms". The testing shall be performed as a Ceriodaphnia
Survival and Reproduction Test. Effluent collection will be performed as daily
24 hour composite samples. Effluent samples will be taken immediately prior
to disinfection, but after all other treatment processes. The Chronic Value
(ChV) must be greater than 1.4%. There will be minimally five effluent
concentrations and a control exposure treatment. One effluent concentration
shall equal 1.4%, which represents the instream waste concentration (I .W. C. )
during 7Q10 low flow conditions and daily permitted discharge volume. The
remaining concentrations shall be 0.4, 0.7, 3, 6 and 95%. There may not be
more than 20% mortality in at least 95% effluent after 48 hours of exposure.

Part III Continued
Permit No. NC0044725
2. The permittee shall conduct m`c nth !6 hod- Mute stc daily renewal toxicity
tests using protocols defined in E.P.A. Document 600/4-85/013 entitled
"Methods for Measuring the Acute Toxicity of Effluent to Freshwater and
Marine Organisms." The testing shall be performed as a Pimephales promelas
Survival Test. Effluent collection will be performed as 24 hour composite samples.
Note: Failure to achieve test conditions as specified in the cited documents,
such as minimum control organism survival and appropriate environmental controls,
shall constitute an invalid test and will require immediate retesting. Failure to
submit suitable test results will consitute a permit violation.
L. Biological Monitoring
The permittee shall prepare and submit a biological monitoring plan within 180 days
following issuance of this Permit for approval by the Director, Division of Environmental
Management. Such approved monitoring is to be conducted on an annual basis and is
to be initiated within one year following issuance of this Permit. The permittee shall
submit the results of biological studies and monitoring studies in a manner and under
a schedule to be approved by the Director of the Division of Environmental Management.
M. Permit Reopeners
This Permit shall be modified, or alternatively revoked and reissued, to incorporate
new effluent limitations and monitoring requirements into this Permit in the event:
1. there is a change in the 7Q10 flow of the Lumber River that warrants more
stringent effluent limitations;
2. that long term BOD data demonstrates a need to modify the present CBOD /BOD5
ratio of 2.0:
3. that ambient data indicates that the upstream background concentration of any
pollutant is greater than zero;
4. that constituents not included in this Permit are identified in the Laurinburg-
Maxton Airport Commission effluent (from heathyet- s analysis »r ott..- ft,,44y4;t.a-1 44olpsed.
1.ac..4 wn.lcJ
5. that new constituents are added to any industry's effluent discharge to the
Laurinburg-Maxton Airport Commission treatment plant;
6. the Division of Environmental Management sets a water quality standard, a As c '
the Environmental Protection Agency establishes an effluent guideline for
any constituent listed in this Permit or found in the Laurinburg-Maxton
Airport Commission effluent;
7. the Division of Environmental Management changes any existing water quality
standard or if any applicable Environmental Protection Agency effluent
guideline is changed;
8. the Department of Human Resources, Division of Health Services determines
new safe drinking water levels for chemicals not limited in this Permit;
9. the Department of Human Resources, Division of Health Services, makes any
safe drinking water levels more stringent for any chemical listed in this Permit.
�,4ro w c

• Pretreatment Program Implementation
Under authority of sections 307(b) and (c) and 402 (b) (8) of the
Clean Water Act and implementing regulations 40 CFR Part 403; North
Carolina General Statute 143-215.3 (14) and implementing regulations
15 NCAC 2H .0900, and in accordance with the approved pretreatment
program all provisions and regulations contained and referenced in
the Pretreatment Program Submittal are an enforceable part of this
NPDES permit.
The permittee shall operate its approved pretreatment program in
accordance with section 402(b)(8) of the Clean Water Act, the
Federal Pretreatment Regulations 40 CFR Part 403, the State
Pretreatment Regulations 15 NCAC 2H .0900, and the legal
authorities, policies, procedures, and financial provisions
contained in its pretreatment program submission. Such operation
shall include but is not limited to the implementation of the
following conditions and requirements:
1. The permittee shall develop, in accordance with 40 CFR
403.5(c), specific limits to implement the prohibitions listed
in 40 CFR 403.5 (a) and (b) .
2. The permittee shall issue permits for construction,
operation and discharge to all significant industrial users in
accordance with NCGS 143-215. These permits shall contain
limitations, sampling protecals, reporting requirements,.
appropriate standard conditions, and compliance schedules as
necessary for the installation of control technologies to meet
applicable pretreatment standards and requirements. Prior to
the issuance of a permit to construct or as a condition of the
permit an evaluation of the treatment process proposed must be
made as to its capacity to meet the permit limitations.
3. The permittee shall carry out inspection, surveillance, and
monitoring requirements as described in its approved
pretreatment program in order to determine, independent of
information supplied by industrial users, compliance with
applicable pretreatment standards. All significant industrial
users must be sampled at least twice per year for limited
parameters.
4. The permittee shall enforce and obtain appropriate remedies,
for noncompliance with categorical pretreatment standards
promulgated pursuant to section 307(b) and (c) of the Clean
Water Act (40 CFR 405 et.seq.), prohibitive discharge standards
as set forth in 40 CFR 403.5, specific local limitations and
pretreatment permit requirements.
5. The permittee shall require all industrial users to comply
with the applicable monitoring and reporting requirements
outlined in the approved pretreatment program, the industries
pretreatment permit and/or in 15 NCAC 2H.0908.
M

6. The permittee shall submit twice per year a pretreatment
report describing its pretreatment activities over the previous
six months. A report shall be submitted to the Division by
August 1 of each year describing pretreatment activities for
January 1 through June 30 of that year, and a like report shall
be submitted by February 1 of each year for activities conducted
from July 1 through December 31 of the previous year. These
reports shall contain, but not be limited to, the following
information:
a. a narrative summary of actions taken by the
permittee to ensure compliance with pretreatment -
requirements
b. a list of any substantive changes made in the
approved program
c. a compliance status summary of all significant
industrial users
d. a list of those industrial users in violation of
pretreatment requirements, the nature of the violations,
and actions taken or proposed to correct the violations
e. sampling and analytical results recorded on indirect
discharger monitoring reporting (IDMR) forms.
7. The permittee shall retain for a minimum of three years
records of monitoring activities and results, along with support
information •including general records, water quality records,
and records of industrial impact on the POTW.
8. The permittee shall publish annually, pursuant to section
101(c) of the Clean Water Act and 40 CFR Part 105, a list of
industrial users that have significantly violated pretreatment
requirements during the previous twelve month period.
9. The permittee shall maintain adequate funding levels to
accomplish the objectives of its approved pretreatment program.
10. The permittee shall maintain adequate legal authority to
implement its approved pretreatment program.
11. The permittee shall update its industrial user survey at
least once every three years .
12. Modifications to the approved pretreatment program including
but not limited to local limits modifications and monitoring
program changes shall be considered permit modification and
shall be governed by 15 NCAC 2H .0114.
M

Facility Name
Type of Waste
Status
Receiving Stream
Stream Class
Subbasin
County
Regional Office
Requestor
Date of Request
Quad
/
/,i���ades
WASTELOAD ALLOCATION APPROVAL FORM
LAURINBURG-MAXTON
COMBINED
EXISTING
LUMBER RIVER
C-SWAMP
030751
ROBESON
FAYETTEVILLE
S. TEDDER
9-2-86
H 21 SE
Wasteflow
5-Day BOD
Ammonia Nitrogen
Dissolved Oxygen
TSS
Fecal Coliform
pH
AIRPORT
VJ-18-6
Request No. :
Drainage Area (sq mi) : 367.
Summer 7Q10 (cfs) : 111.
Winter 7010 (cfs) : 148.
Average Flow (cfs) : 511
RECOMMENDED EFFLUENT LIMITS
:
(mgd): 1.0
(mg/l): 30
(mg/1):
(mg/1):
(mg/1) : 30
(#/100ml): 1000
(SU): 6-9
:
:
:
COMMENTS
THESE LIMITS APPLY ONLY TO THAT PART OF THE PERMIT PERTAINING TO
OXYGEN -CONSUMING WASTE. FECAL COLIFORM LIMITS MAY CHANGE TO 200/100 ML
IF THIS SECTION OF THE LUMBER RIVER IS CHANGED TO A "B" CLASSIFICATION.
Recommended by ____ ____________ Date
Reviewed by:
Tech. Support Supervisor ___________ ___ Date
Regional Supervisor ________ ________ Date ____ _
Permits & Engineering __ _____ Date

~ ^`
`~
Discharger
Receiving Stream
MODEL RESULTS
: LAUR%NBURG-MAXTON AIRPORT
o LUMBER RIVER
The End D.O. is
The End CBOD is
The End NBOD is
7.05 mg/l.
0"70 mg/l.
Segment 1
Reach 1
Reach 2
Reach 3
Reach 4
Reach 5
Segment 2
Reach 1
Reach 2
WLA
DO Min CBOD
(mg/1) Milepoint Reach # (mg/1)
6"59
5
3.35 2
130
0
O
0
140
0
WLA
NBOD
(Mg/1)
WLA
DO Waste Flow
(mg/1) (mgd)
0.00 0.00 3.80000
0.00 0.00 0"00000
0.00 0.00 0.00000
0"00 0"00 0.00000
0.00 0.00 0.00000
0"00 0"00 1"00000
0"00 0.00 0.00000

Segment 1 Reach 4
Waste ; 0.000
Tributary 1 0.000
* Runoff 1 0.580
Segment 1 Reach 5
Waste ; 0.000
Tributary ; 0.000
* Runoff 1 0.320
Segment 2 Reach 1
Waste 1 1.550
Headwaters1111.000
Tributary s 0.000
* Runoff 1 0.320
I
0.000
0.000
2.000
0.C)0C) 1
0.000
2.000
1140.000
1 2.000
0.000
1 2.000
Segment 2 Reach 2
Waste 1 0.000
Tributary 1 0.000
* Runoff 1 0.210 1
0.000
0.000
2.000
* Runoff flaw is in cfs/mile
0.000 1
0.000 ;
0.000 1
0.000
0.000
0.000 1
0.000
0.000
7.560
0.000
0.000
7.560
0.000 j 0.000
0.000 1 7.560
0.000 1 0.000
0.000 1 7.560
0.000 1
0.000
0.000 1
0.000
0.000
7.560

*** MODEL SUMMARY DATA ***
Discharger : LAUR I NBURG--MAXTON AIRPORT Subbas i n : 030751
Receiving Stream : LUMBER RIVER Stream Class: C-SWAMP
Summer 7010 : 111. Winter 7010 : 148.
Design Temperature: 25.
:LEN6THI SLOPE: VELOCITY I DEPTH: K1 1 K1 1 K2 I K2 I KN 1 KN I KNR 1 KNR
1 mile ft/mil fps 1 ft !design: 220.:design: 8204 :design: 8200 :design: 8204
Segment 1 I 2.23 2.20 0.691 13.30 10.47 10.37 1 1.49 1 1.34 0.00 1 0.00 1 0.00 1 0.00
Reach 1 1
Segment 1 1 1.02 2.20 0.779 13.12 10.47 : 0.37 1 1.68 I 1.51 0.00 1 0.00 1 0.00 1 0.00
Reach 2 1
Segment 1 I 2.77 3.60 0.779 1 3.14 10.48 10.38 12.75 1 2.47 0.00 1 0.00 1 0.00 1 0.00
Reach 3 1 1 1 1 !•I 1 I I I
Segment 1 1 1.40 1.10 0.779 1 3.15 1 0.47 1 0.37 1 0.84 1 0.75 0.00 10.00 : 0.00 1 0.00
Reach 4 I 1 1
Segment 1 I 0.38 1.10 0.121 1 8.02 10.44 1 0.35 : 0.45 1 0.12 0.00 10.00 1 0.00 1 0.00
Reach 5 I ! : 1 1
Segment 2 I 2.73 1.10 0.121 17.89 1 0.44 10.35 1 0.45 I 0.12 0.00 1 0.00 1 0.00 : 0.00
Reach 1 I
Segment 2 I 4.81 1.001 0.116 1 8.09 10.44 1 0.35 1 0.45 : 0.10 0.00 1 0.00 1 0.00 1 0.00
Reach 2 I
1 Flaw I CBOD I NBOD 1 D.O.
I cfs 1 mg/1 1 mg/1 1 mg/1
Segment 1 Reach 1
Waste 1 5.580 1130.000 1 0.000 : 0.000
Headwaters 1 107 . ��00 1 2.000 : 0.000 1 7.560
Tributary : 0.000 : 0.000 1 0.000 1 0.000
* Runoff 1 0.450 : 2.000 1 0.000 1 7.560
Segment 1 Reach 2
Waste 1 0.000 1 0.000 1 0.000 : 0.000
Tributary 1 0.000 1 0.000 1 0.000 : 0.000
* Runoff : 0.580 I 2.000 : 0.000 1 7.560
Segment 1 Reach 3
Waste 1 0.000 1 0.000 1 0.000 1 0.000
Tributary 1 0,000 1 0.0cx0 : 0.0000 1 0.0000

•
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Lcut, l i •v) bvrg -
) foh aloft Wj A V DV
Ko
S Lew l c -6 &_� )
_coxaoVitt_
3_ P. Ste4ev_S nlitc
140ke. C0,4-
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190 tt cw okr
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I�t 11
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S►. 1t S3
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Facility:
NPDES Permit #:
1.) The permittee shall conduct chronic toxicity tests on a weekly
basis using protocols defined in E.P.A. Document 600/4-85/014
entitled "Short -Term Methods for Estimating the Chronic Toxicity
of Effluents and Receiving Waters to Freshwater Organisms". The
testing shall be performed as a Ceriodaphnia Survival and Repro-
duction Test. Effluent collection will be performed as daily
24 hour composite samples. Effluent samples will be taken immed-
iately prior to disinfection, but after all other treatment processes.
The Chronic Value (ChV) must be greater than 1.4%. There will be
minimally five effluent concentrations and a control exposure treat-
ment. One effluent concentration shall equal 1.4%, which represents
the instream waste concentration (I.W.C.) during 7Q10 low flow con-
ditions and daily permitted discharge volume. The remaining concen-
trations shall be 0.4, 0.7, 3, 6 and 95%. There may not be more than
20% mortality in at least 95% effluent after 48 hours of exposure.
2.) The permittee shall conduct monthly 96 hour acute static daily
renewal toxicity tests using protocols defined in E.P.A. Document
600/4-85/013 entitled "Methods for Measuring the Acute Toxicity of
Effluents to Freshwater and Marine Organisms". The testing shall
be performed as a Pimephales promelas Survival Test. Effluent
collection will be performed as 24 hour composite samples.
Note: Failure to achieve test conditions as specified in the cited
documents, such as minimum control organism survival and appropriate
environmental controls, shall constitute an invalid test and will
require immediate retesting. Failure to submit suitable test results
will constitute a permit violation.

OSX C4EMICALS
7Q10 (CFS)
1 111
1
s
DICE VOL (MGM
- 1
WC(S)
.. 1.38
1
%HQ1
� � 1
I CRL
IgASS IFRV =FRV/3
'DRINKING
.. OR CV IMO OF PIPE ;EOP
LIMIT
(µQ/ I) 1(jzg/ I) WATER CRITERIA 149/ 1) ILIMIT (Ptg/ I)
INSTANTANEOUS
1 PER DIIR !WEEKLY AVG
MAX (µg/1)
E CE HT ENE
1(µg/I)
1 1 1
/
POLWNXLETi1 AROMATIC!
1
1
ACROLEIN
1
5501 1 39988.3f
ACETON I TR ILE •
_
I 1
- --- --- •-----�
210001 1 15268261
HCRYLilfflDE
1 =
70001 `• 308942'
ACRYL.ON I TRILE1
ALDRIN
=
i
0.0146 1 1.06150761
AROI
- 31 1.00
_
0.03 0.0021 0.1454121 ' 72.706
1242
DIELDRIN
ALUMINUM
1 2.51 0.831
0.0011 0.0021 0.072706 � 60.5
tETfil. 1 ;_
1 =.
i8l1011I A
_
.._ ....
1 1
ANILINE
1 Ti1RRCENE
- 1 1 1
525001 1 3817065
1POLYtwLEAR AROMATIC ! 1
.» . .._...
,... .__
_ _._
'
ANTIMONY
METAL •i---•
141 1017.8841
ARSENIC
ASBESTOS
1
4401 46.67
501 sot 3635.310663.54666667
BARIUM
1 1
1 1
BENZENE
:METAL 1 . 185001 6166.67r
925
67253.051448353.0666667
BE1Q
1VOLAT 1 LE
% 3100= 1 33.33
1.3=.. 124
94.5178175129.53333333
IOINE
1.51 109.059
r8£hQYL CHLOR I OE
1izOPE
•
:----- `•
1
B1FRYL.BEL IYL ETEAROMATIC!1
1POLYNUCLERR - 1 }
I _
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BORATE
1 1 '•
799.7661
CADMIUN
LCfLCUU1METAL
1 1.51 0.501
101 2
14S.412= 36.353
C'RR80N
'• 1 1
_
1
DISULFIDE
C>tif18Of1OISUFATE
a .'
1
I
40001
290824
CARBON
•1 . 1
40001
TETFIRC♦LOR I OE
CHLOROACETILOEHY(E
VOLATILE 730'• 243.331
0.2691 36.5
19.557914117691.79333333
CHLORDANE
1 I :
241.31 1 17538.499!
!'EST I C I DE 1 2.41 0.801
1 0.0041 0.290824' 58.1648
CHLORIDE
0-CRESOL
:
2500001181765001
!
• 9.91 3.301
20001 4951 35989.471 239.9298
1 4.71 1.571
20001 2351 17085.911113.9060666667
M..
M-XYLENE
1
20001 2001
14541.21
0.221 0.071
1 111
799.76615.3317733
xYLErE
P-CILORO-M-CF
€ 1 161 5.331
1
;
ai
1 8001 58164.8i 387. 7b.S3
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1 1
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TP
f
0• i= 7.27061
24 •,
;PESTICIDE
101 727.061
DOE
.PESTICIDE _
1 1001 7270.6!
'DOT
(PESTICIDE
1 0.181 13.087081
_
1.1.
DOT
!PESTICIDE 0.371
0.103 0.0011 0.072706. 26. 65880666667
Page 1

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Page 2
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A. (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Final)
•
During the period beginning on the effective date of this Permit and lasting until the completion =.of *xp
to 1. MGD . the permittee is authorized to discharge from outfall serial number 001. Such
discharge shall be limited and monitored by the permittee as specified below:
Effluent Characteristics
kq(day
Monthly vq.
Flow, M3/day (MGD)
BOD (5 day @20 C)
Total Suspended Solids
Fecal Col i form Bacteria
(Geometric Clean)
Settleable Matter
Dissolved Oxygen
Chemical Oxygen Demand
Total Residue
Ammonia Nitrogen as ti
*Cobalt
*Chloride
*Sodium
57(125)
57(125)
1.6(3.6)
659(1451)
659(1451)
Discharge Limitations
(lbs/day) diriir Units Specify).
Weekly A9 v . Monthly Avg. Weekly Avg.
" 85(187)
85(187)
1892(0.5)
30 mg/1 45 rig/1
30 mg/1 45 mg/1
tc ., C> 0�
1.6(3. ") i ck?)1 ,�
824 181 y, ��
759(1669 �5,1 , -;``p�`"
Monitoring Requirements
Measurement Sample Sample
Frequency ,Type Locd o
Daily Continuous I or E
Monthly Composite I ,E,t;,D
Quarterly Composite I,E
Monthly Grab U,D
Daily Grab E
Daily Grab U,0
Monthly Composite E,U,D
Quarterly Composite I,E
Quarterly Composite I,E
Weekly Composite I,E,U,
Monthly Composite I,E,U,
Monthly Composite I,E,U,
The pH shall not be less than 6 standard units nor greater than 9 standard units and shall
grab sample taken from the I,E,U,D.
There shall be no discharge of floating solids or visible foam in other than trace amounts. The temperature in the
effluent shall be such as not to cause a temperature in the receiving stream of2.8°C (5.04°F) above the natural
water temperature and in no case shall the natural water temperature exceed 32°C
C (89.6°F) and shall be monitored
daily by grab sample taken from the E,U, and D.
*This parameter, limited as a daily average and a daily maximum respectively, is to be monitored due to the fact
that Carolmet discharges process wastewater into the Laurinburg-Maxton Airport Commission Wastewater Treatment Plant:
**Daily means every day on which a discharge occurs, except Saturdays, Sundays, and legal holidays. Daily stream
sampling frequency may be reduced at each sampling station to one (1) time per week except during the months of
June, July, August, and September, when the frequency must be no less than three (3) times per week at each
sampling station.
***All Stream sampling is to be by grab sample.
T _ T..s1 ..wry . C Cff l s,ant . II _ Itnatream: and D = Downstream
be monitored monthly by

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Co/7
State of North Carolina
Department of Natural Resources and Community Development
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor R. Paul Wilms
S. Thomas Rhodes, Secretary September 2, 1986 Director
MEMO TO: John Freeman, D.V.M.
FROM: George Everett, Chief
Water Quality Section
SUBJECT:
PECEIVED
SEP 04 19S6
H: ER Ql!:\L iTY SECTIO+4
OPERA-P NS G "!•'il
Numerical Criteria for Human Health Protection
(Drinking Water) for Laurinburg-Maxton Airport
Commission (LMAC) Wastewater Treatment Plant
We are preparing a draft NPDES permit for LMAC presuming
that GSX will be contributing waste to their system. In order to
incorporate drinking water protection for Lumberton into the
permit, we need numerical drinking water criteria for chemicals
to be treated by GSX and other chemicals likely to be found in
their effluent. We understand that these.numbers are still being
developed and modified but presently need numbers for a "draft"
permit. There will be an opportunity for you to modify these
numbers in the future. Also, we will include a reopener in the
permit to reflect additional data as they become available.
Specifically, we need to know whether the "Promulgated or Derived
MCL at Lumberton Intake (ug/1)" from the GSX report entitled
"Development of Discharge Concentrations Based on Aquatic
Toxicity and Human Health Criteria - 8/21/86" can be used for
this purpose subject to future modification.
Other available numerical criteria could also be cited for
our use in the draft permit. We plan to use the more restrictive
numbers (human health or aquatic life based) in developing permit
limits for LMAC if GSX is in place. Any guidance you can provide
by September 4, 1986, would be helpful.
GE:JD/jhs
cc:
Page Benton
Steve Tedder
Dennis Ramsey
Alan Klimek .
Ted Taylor
SEP 8 1986
PERMITS & ENGI ..0 R
Pollution Prevention Pays
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

State of North Carolina
Department of Natural Resources and Community Development
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor
S. Thomas Rhodes, Secretary
June 6, 1986
Mr. Steve Floyd, President
Laurinburg/Scotland County Area
Chamber of Commerce
P.O. Box 1025
Laurinburg, NC 28352
R. Paul Wilms
Director
Dear Mr. Floyd:
The Division of Environmental Management received a copy of Mr.
Nelson V. Mossholder's May 7, 1986 letter to you about the proposed GSX
discharge to the Laurinburg Maxton Sewage Treatment Plant. We feel that
several points in the letter are unclear and perhaps misleading. I am
writing today to clarify the State's perspective on GSX and the assimi-
lative capacity of the_Lumber River.
The State of North Carolina has been delegated authority by the
Environmental Protection Agency for issuing NPDES permits to all dis-
chargers of waste to the surface waters of the state. NPDES permits
contain effluent limitations calculated to protect the water quality
standards of the receiving stream under low flow design conditions.
The design flow specified in our regulations.is the average 7 day low
flow that has a probability of reoccurring once every 10 years (the
7Q10). Assimilative capacity is allocated on a first come, first
served basis.
Effluent limits for Laurinburg Maxton (LMAC) with GSX as an indirect
discharger will allocate all of the available assimilative capacity for
specified toxic substances in the Lumber River unless DEM is requested
to do otherwise. For example, the water quality standard for lead in
the Lumber River is 25 ug/1. Effluent limitations for LMAC (with GSX)
will be calculated to produce a stream concentration of exactly 25 ug/1
during 7Q10 conditions and permitted flow. Background lead concentrations
Pollution Prevention Pays
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

Mr. Steve Floyd
June 6, 1986
- page two -
will be factored into the analysis. If a new discharger was to request
permission to discharge lead to the river after the LMAC permit was
issued, DEM would have to first reduce the allowable loading from LMAC.
The necessary permit renegotiating could be time consuming and difficult.
If LMAC was out of compliance with the assigned limit, new development
would be delayed until they could demonstrate that they could reduce
their discharge.
Mr. Mossholder describes several conservative assumptions made in
GSX's calculations of discharge concentrations. If his analysis is
correct, GSX could accept limits more restrictive than those required
to protect water quality. However, DEM cannot take any of his arguments
into consideration in our permit analysis, and thereby "reserve" some of
the river's assimilative capacity for toxicants, unless we are formally
requested to do so by LMAC.
I hope this letter clarifies the Division's procedures for allocating
assimilative capacity. If you have any questions, please do not hesitate
to contact George Everett, the Water Quality Section Chief, at 919-733-5083.
Sincerely,
R. Paul Wilms
cc: George Everett
LMAC
DHR

GSx
M 63 -
cen
gat i"1-1
Rzecruad40
pck4AAT
•
•
//o
- - : - ..... GS: Cheenkal Services, Inc.
P.O. Box 210799
121 Executive Center Drive
Conger.. Building, Suite 100
Columbia, SC 29221
[phone]
MAY 1 `i 1986
WATER QUALITY
SECTION
te
Mr. Steve Floyd, President
Laurinburg/Scotland County Area
Chamber of Commerce
P.O. Box 1025
Laurinburg, NC 28352
Dear Mr. Floyd:
May 7, 1986
V. Mossholder, PH. D.
Director,
R EC I 'V D
MAY 12 1888
I. a f:twa ngarvitl
cum Na
I am responding to your requests for contacts in
other communities where GSX has . facilites and for an
explanation of why the treated water discharge from our
proposed Laurinburg Facility would not "use up" the
available capacity of the Lumber River and thus reduce
future economic development.
The contacts at other GSX Facilities are:
REIDSVILLE, NC
LAUREL,
*Charles King - Reidsville Fire Department
[phone]
*Gloria Pegram - 1st National Bank of Reidsville
[phone]
*Doug Law-=. antainOr Division
(919) 342-7 10
MD
*Robert Malone -.Laurel Chamber of Commerce
[phone]
GREENBRIER, TENNESSEE
*Fred Schott - Chief, Robertson County Fire
Department. [phone]
*Martha Wilkinson - Robertson County Planning &
Zoning Commission [phone]
*Charlie Ralph - Robertson County Chamber
of Commerce [phone]
The Chamber and others have expressed concern that
the GSX discharge will result in the concentrations of many
constituants being elevated to the maximum levels the river
can safely receive and thereby will restrict economic growth
by preventing any additional loadings by other industries.

Page 2.
2.
The GSX Permit Application for the discharge of
pretreated wastewater clearly shows that this is not the
case. The methods GSX used to arrive at some suggested
limits for possible components of its discharge were very
conservative and provide for protection of the river while
not restricting other industrial discharges. Appendix D-5
of the application to discharge pretreated wastewater
presents the methods and rationale used to arrive at the
suggested pretreatment limits. Some key, highly
conservative assumptions were explained in that appendix
which substantiate the statement that GSX's dischrage will
not elevate any constituants to the maximum level the river
can receive.
The first highly conservative assumption was that
every batch discharge of treated water would contain the
maximum allowable level of every permitted constituant. As
the permit application explains, waste shipments received
from many kinds of industries will be treated individually
in batches. Therefore, the treated wastewater, also
discharged in batches, could not contain all the permitted
constituants in every batch simply because of the variable
sources and characteristics of the wastes received for.
treatment. Some batches of water could contain the maximum
allowable concentrations of some constituants, but over time
the Laurinburg Maxton Sewage Treatment Plant (LMAC) and the
Lumber River will actually be receiving a safe, average
level of constituants that will be substantially lower than
the maximum levels. Nevertheless, GSX has conservatively
used the maximum levels instead of the more 'realistic
average levels for its computations of loadings to the LMAC
and the Lumber River.
AM
The second_�i Conservative assumption was that
the LMAC would provide absolutely no treatment of any of the
constituants and that the GSX waste water would only be
diluted by the other POTW wastewaters. EPA surveys of
Publically Owned Treatment Works (POTW's) have demonstrated
that an average removal of over 75 percent of heavy metals
can be expected by POTWs using the activated sludge process
used _by LMAC. In a&ition, 75 percent of the volatile
organic compounts (VOC) that may remain in GSX wastewater
can also be expecterd to be removed by the LMAC plant. GSX
calculations have been highly conservative by not taking any
credit for the continued treatment that will be afforded by
the LMAC POTW treatment system.
A third "safety factor" assumption was that
constituants reaching the Lumber River would not be reduced
in concentration during the approximately 7 days required
for the water to reach Lumberton. That is, no allowance was
provided for any decrease or removal of any constituant
after it reached the river. This approach ignores the
natural reduction of constituant concentrations that will
occur from the following phenomena:

Page 3..
- 1l
1./A1
ke sof
tus
tisk
a) biodegradation by microorganisms
b) volatilization
c) chemical oxidation - reduction reactions
sedimentation
uptake by the stream biota
chemical specialization
complexation and binding to
inorganic particulates
they and natural
clean Mechanisms within the
riverine environment
Furthermore, suggested limits on GSX discharges are
based on concentrations in the river at low flow conditions
(7Q10), rather than on the average flow which is about six
(6) times greater.
Finally, it should be noted that a number of the
suggested constituant limits are based on criteria more
stringent that N.C. water quality standards or drinking
water standards. For example, metals such as chromium and
lead have suggested limits at GSX that are based on
categorical pretreatment standard guidelines and toxic'
threshold concea., for'; POTWs, respectively...
Therefore, many of 'he suggested -limits for GSX discharges
are based on criteria more stringent than riverine
standards, which means they are to be discharged at levels
below those required for protecting the river environment.
•
In summary, —the -ipuggested GSX discharge limits do
not come close to approaching the„capacity of the river to
accept these constituants. If the extremely conservative
GSX assumptions were replaced by more realistic, but still
conservative, estimates, it can be shown that the river has
the capacity to receive over 5 times the levels GSX has
suggested for its limits. For example, if the average
discharge contained as much as 70% of the maximum specified
limits, and the LMAC POTW removed only 60% of those
constituants, and the Lumber River provided further removals
of. only 30% of the remaining levels, then the river loading
would be less than 20% of that allowedin the highly
conservative GSX calculations. That is, under these
realistic estimates, GSX would utilize less than 20% of the
rivers capacity. These calculations did not even allow for
the fact that many constituants (eg., heavy metals) meet
criteria even more stringent than water quality or drinking
water standards. Therefore, even these "realistic
estimates" are still very conservative.

Page 4.
If you have additional questions, I will be happy
to address them.
NVM/hhk
cc: W. Meyer
NCDHR
P. Wilms
NCDNRCA
Sincerely,
kpdet,li,-t) i • fr)A4-4.12,61
Nelson V. Mossholder, PH.D.
Director
Technical Services

1
March 13, 1986
•
To: George Everett
Through: Alan Klimek
Bill Kreutzberger b4144
From: John Dorney Gip
Subject: Preliminary analysis of GSX Pretreatment Application
I have listed the major shortcomings that I have found for
the GSX Pretreatment Application as they pertain to water
quality. I think that GSX [and DEM] would have to address these
points before we could tell LMAC that GSX's facility would be
acceptable from a water quality standpoint. A more detailed memo
follows this summary.
1. Acute toxicity - Based on the NY plants, GSX's effluent
will probably be acutely toxic to Daphnia. Both DEM and GSX have
agreed that no acutely toxic effluent would be released to LMAC
because LMAC is already marginally toxic. To demonstrate that
they could comply with this provision, GSX or DEM would have to
arrange for effluent sampling from the New York plants.
2. Water Quality Standards - Based on the NY data, we will
need to develop 24 additional water quality standards. I have
begun this work.
3. Pretreatment Limits - GSX has suggested pretreatment
limits based on the most restrictive of pretreatment categorical
limits, toxic threshold levels, water quality standards and
drinking water standards. GSX's calculations for the later two
are wrong and need to be corrected. Meg Kerr and I tried to
duplicate their results unsuccessfully. Also, these limits
assume zero as background in the LMAC effluent and Lumber River.
After reviewing STORET and LMAC data, it appears that DEM and
LMAC will need to collect substantial amounts of toxicant data
(low level metals and organics) in order to decide what are
proper background levels. Organic sampling (especially
pesticides) should be done for several seasons. The final
problem with GSX's pretreatment limits is that for three
chemicals (Pb, Ni and heptachlor), NY effluent concentrations are
regularly higher and GSX would be expected to regularly exceed
these limits. GSX would be expected to occassionally exceed
limits for four other compounds (As, Cd, Zn and endosulfan) even
assuming zero background in the Lumber River or at LMAC.
4. Chemical monitoring - GSX identified 12 pass -through
compounds, 11 which could bioaccumulate, 17 which could
accumulate in sludge and 19 carcinogens. I have identified 77
pass-throughs, 117 bioaccumulators, and 44 sludge accumulators.
Based on these findings, frequent chemical monitoring (at least
initially) is essential to protect water Quality. GSX's

2
monitoring proposal is too infrequent.
• 5. Plant design - GSX will probably
plant to include a) activated carbon use
filters to protect the carbon units, c)
filter as backup, and d) more holding
order to have enough capacity to allow
testing.
b) Other issues -
need to redesign their
on every batch, b) sand
an additional carbon
tanks (at least two) in
for 48 hour Daphnia
A) Does DEM (at least initially) want to review the
bioassay and chemical data from GSX or rely on LMAC to do so?
B) GSX says that they will not accept PCB's or
multi -chlorinated benzene compounds but does not say how they
will test for these in incoming wastes.
C) A detailed flow model of the Lumber River is
essential to protect Lumberton's drinking water source.
D) The stormwater management plan seems inadequate -
due to lack of storage capacity.
In summary, GSX's proposal falls short of assuring protection
of LMAC, aquatic life in the Lumber River and Lumberton's
drinking water source. The most difficult issues for GSX to meet
will be acute toxicity; the chemical monitoring necessary to
ensure protection of LMAC, the' Lumber River and Lumberton;
pretreatment limits; and plant design. Most of these problems
relate to the location of GSX (into a marginally toxic POTW and
above a drinking water source). It is likely that a hazardous
waste treatment facility could be acceptably located in North
Carolina if these locational problems were avoided.

DETAILED COMMENTS ON GSX PRETREATMENT PERMIT APPLICATION.
I. Acute Toxicity
• DEM has stated and GSX has agreed that their effluent to the
LMAC plant will not be acutely toxic (LC50 > 90'/. effluent). This
was done to prevent any worsening of the already toxic LMAC
plant. If GSX's effluent were acutely toxic, it would make the
LMAC effluent more toxic.
The SCA plant in NY discharges directly into the Niagara
River after a treatment process similar to GSX except that the
SCA plant holds its treated effluent in large lagoons for up to a
year before discharge. Their NPDES permit requires bioassay
testing. Their effluent is not acutely toxic to fathead minnows
or rainbow trout. However, it is consistently acutely toxic to
Daphnia, Magna (LC50 of 51 to 70% effluent). NY state officials
and SCA personnel think that is caused by dissolved salts (ave.
9.8 mg/1 total dissolved salts) rather than by toxicants.
However, DEM's experience is that Daphnia, are quite tolerant of
salt in these levels. A more likely cause of toxicity is the
high nickel levels (ave. 1.43 mg/1) and additive effects of low
levels of organic compounds and other metals. In any case, it
appears that the GSX effluent will be acutely toxic to Daphnia,
and will, therefore, increase toxicity problems at the LMAC. One
would expect that GSX's effluent would be more acutely toxic than
SCA because GSX will not hold its effluent in ponds for months.
No bioassays have been run at the indirect dischargers (CECOS and
Frontier) in New York which are more similar (in design) to GSX.
GSX and/or DEM should arrange to have two or more effluent
samples taken from the indirect dischargers in NY to be tested
for acute toxicity to Daphnia. If they are toxic, GSX should
explain in detail how they will remove this toxicity in order to
meet the acute toxicity limit they have agreed upon.
In general, GSX seems to place too much reliance on Microtox
as an eventual test. We should reemphasize that Microtox may
work but that we consider that adequate bioassay testing will
require Daphnia and fathead minnows. GSX's available holding
tanks and plant design should reflect this position. Their
process for DEM and LMAC acceptance of the Microtox test is
unclear (pg. 5-5). Before we agree on a process to decide
whether Microtox is acceptable, we will need a clarification of
their plan. They do not state what will happen if Microtox does
not prove to be acceptable. We need them to state that, in this
case, Daphnia and minnow testing will be done on each batch.
Finally, in their discharge management plan (pg 5-1), GSX states
that "LMAC will be able to approve" rather than saying that LMAC
(and/or) DEM will have to approve discharge. This distinction
should be made very clear to GSX and LMAC.
II. Water Quality Standards
Based on data on toxicants from similar facilities in New
York state, DEM will need to develop water quality standards for

24 additional compounds which are often present in effluents from
the New York plants. Those chemicals are aluminum; barium;
chloroform; methylene chloride; 1,2-dichloroethane;
trichloroethylene; 1,1,2,2-tetrachloroethane; carbon
tetrachloride; tetrachloroethylene; 1,1-dichloroethane; vinyl
chloride; isophorone; 2-chlorophenol; 2-nitrophenol;
pentachlorophenol; trichlorophenol; phenol; hexachlorobutadiene;
1,2,4-trichlorobenzene; diethyl bexyl phthalate; di-n-butyl
phthalate; DDE; and DDD. This is a lengthy process. As an
option, it would be possible (under our regulations) to take 0.05
or 0.01 of the lowest acute data (96 hr LC50) to use as a
standard. For some chemicals with little data, acute toxicity
testing may be required. It would be most prudent to develop
comprehensive standards for these compounds which would take
about three months. I have begun this process.
III. Suggested Pretreatment Limits
GSX has suggested pretreatment limits based on the most
stringent of four values - 1) categorical pretreatment standards
(the most stringent applicable), 2) toxic threshold
concentration (to prevent POTW upset), 3) drinking water
standards and 4) freshwater quality standards. This seems to be
a reasonable process to select pretreatment limits.
However, there are three major problems with the values
determined by GSX. First, the calculations for the water quality
and drinking water standards are not correct. Meg Kerr and I
have been unable to determine how they calculated their limits.
GSX determined a limit of 17.6 mg/1 for arsenic based on water
quality standards. The correct value is 5.2 mg/1. Similarly, the
North Carolina drinking water standard (DHS) for silver
corresponds to a pretreatment limit of 5.2 mg/1 while GSX
calculated a limit of 9.2 mg/1. GSX should explain these
differences and modify their calculations appropriately.
A more important problem with the values is that they assume
a background level of zero in the LMAC effluent on the Lumber
River for these toxicants. This is probably unrealistic in any
water body like the Lumber River which receives industrial and
municipal discharges as well as urban land agricultural runoff.
STORET data were pulled for stations upstream, at and downstream
of Maxton to determine the available data for background levels.
In general, sufficient data exist for metals to determine
background levels (see Table 1 and following discussion) but data
on organic compounds is lacking. Before pretreatment limits can
be established for organic compounds, data on their presence or
absence need to be collected. Similarly, data on toxicants from
LMAC plant are few (see Table 2 and following discussion).
Additional data on metals and organics need to be collected
before pretreatment limits can be accurately determined.
In the past 3 years, DEM has taken seven effluent samples
from LMAC and analyzed for toxicants (Table 2). Average metal
levels (assuming 1/2 detection level when less than detection)

5
are: Al = 542 ug/1 (n = 6), Cd = 10 ug/1 (n = 6, all less than
detection), Co = 2360 ug/1 (n = 5), Cr = 25 ug/1 (n = 6, all less
.than detection), Cu = 80 ug/1 (n = 6), Fe = 800 ug/1 (n = 7), Hg
= 0.35 (n = 4), Ni = 58.3 (n = 6, 5 less than detection), Pb = 50
(n = 6, all less than detection) and Zn = 273 ug/1 (n = 7). One
sample (taken on April 4, 1985) has been analyzed for acid
extractables and base/neutral compounds. None were identified.
It appears that DEM needs data on levels of arsenic, barium,
beryllium, cyanide, selenium and silver as well as complete GC/MS
scans for all fractions from the LMAC effluent in order to see if
GSX's proposed pretreatment limits are appropriate. At least
three samples should be taken to understand the varibility. Low
level analyses for metals (especially for nickel, cadmium,
chromium and lead) should be done on these samples.
Three samples have been analyzed for base/neutrals and acid
extractables in the Lumber River near Maxton (Table 1).
Di-n-octyl (740 ug/1) and ethyl butyl phthalates (12 ug/1) were
the only compounds identified. Metal levels were all less than
detection but in some cases, detection limits were much higher
than our water quality standards. It appears that DEM needs data
on levels of barium, beryllium, selenium, silver, and cyanide as
well as complete GC/MS scans for all fractions in order to decide
what pretreatment limits are appropriate for GSX. These samples
should be taken to reflect seasonal variability. Spring sampling
for pesticides would be most appropriate. Since levels of many
pesticides vary seasonally, sampling throughout the year may be
necessary for organic compounds. In addition, routine laboratory
detection limits for several metals are too high to determine
whether water quality standards are being exceeded or how close
river levels are to the standards. For these metals (Cd, Cr, Cu,
Ni, Pb, and Zn), DEM will need low level metal monitoring data
for several samples in order to determine the background level to
accurately set pretreatment standards for GSX.
The final major problem with GSX's proposed pretreatment
limits is that (even assuming that they may be too high because
background levels were not considered) in some cases, GSX will
probably not be able to meet these limits based on operational
experience from similar New York facilities. Three chemicals
(lead, nickel and heptachlor) have average levels in the CECOS
effluent (indirect discharger to Niagara Falls POTW with design
similar to GSX) which are higher than GSX's proposed pretreatment
limits. For these chemicals, exceedances of pretreatment limits
would probably occur regularly. Four other compounds (arsenic,
cadmium, endosulfan and zinc) have maximum levels in the CECOS
effluent which exceed GSX's proposed limits. For these
compounds, pretreatment limits would probably be exceeded
ocassionally by GSX. These findings with regard to probable GSX
exceedance of pretreatment limits are conservative since
background levels of organics and metals have not been
considered. When these backgrounds are taken into account, there
may be additional chemicals which would probably exceed
pretreatment limits. In addition (as discussed previously), it
appears that DEM will need to calculate water quality guidance

6
for 24 additional compounds found in effluents from the New York
plants. In some cases, these may also present problems regarding
43SX's pretreatment limits. If LMAC requests that DEM not
allocate the entire Lumber River's capacity to them and/or if
LMAC wants to reserve a portion of their capacity for additional
industries, GSX's suggested pretreatment limits would be lowered
as well. This may pose additional problems regarding levels of
toxicants in the CECOS, N.Y. plant.

7
Table 1
• Toxicants in Lumber River
Near Maxton (1981 to 1985) (#02133624)
Water Quality Drinking Water
Metals Maximum Minimum Standard Standard
Al 600 ug/1 400 ug/1 none none
As 12 < 10 50 ug/1 50 ug/1
Cd < 50 < 20 2.0 ug/1 10 ug/1
Co <100 < 20 1.0 mg/1 none
Cr < 50 < 50 50 ug/1 50 ug/1'
Cu <100 < 40 15 ug/1 50 ug/1
Fe 1100 200 1.0 mg/1 1.0 mg/1
Hg < .5 < .2 0.2 ug/1 2.0 ug/1
Ni <100 <100 50 ug/1 none
Pb <100 <100 25 ug/1 50 ug/1
Zn 60 < 20 50 ug/1 50 ug/1
Organics 3 Samples
di-n-octyl phthalate: 740 ug/1
ethyl butyl phthalate: 12
Need (several (N = 3) samples
Metals:
As, Ba, Be, Cn, Se, Ag
Organics: All fractions including TBTO

8
alb
.
•
Table 2
Toxicants in LMAC Effluent
Metals 9/25/85 7/24/85 6/28/85 4/4/85 6/28/85 11/4/83 9/19/E
ug/1
Al 1400 400 300 <100 300 - 800
Cd < 20 <20 - < 20 < 20 < 20 < 20
Co 700 - - 300 8400 1100 1300
Cr < 50 <50 - < 50 < 50 < 50 < 50
Cu 90 60 - 40 40 90 160
Fe 2200 700 500 300 500 900 500
Hg 0.6 0.2 - <0.2 - 0.5
Mn 50 - - < 50 - -
Ni <100 <100 - <100 <100 <100 <100
Pb <100 <100 - <100 <100 <100 <100
Zn 410 280 200 150 200 430 240
Phenols - <5ug/1
Organics
- - - 1 unidentified - - -
peak at 15 ug/1
-pesticides not run
- purgeables not run
- herbicides not run

9
IV. Chemical Monitoring
•
GSX has proposed to monitor metals from each batch of
effluent and also monitor organic priority pollutants from a
weekly composite sample. In selecting this schedule, GSX
identified compounds which 1) pass -through activated sludge
plants (12 chemicals), 2) bioaccumulate in aquatic organisms
(11 chemicals), 3) accumulate in sludge (17 chemicals) or 4)
are carinogenic (pretreatment standards for 19 chemicals).
After extensive literature surveys, DEM staff have identified 77
pass -through chemicals, 117 bioaccumulative compounds, and 44
chemicals which accumulate in sludge. DHS staff are examining
the issue of carcinogenic chemicals and their appropriate
monitoring.
From these findings, it is clear that many chemicals have
properties which would present problems such as bioaccumulation
in the river, accumulate in the LMAC sludge (making disposal
difficult), or pass -through the LMAC plant and be potential human
carinogens in the Lumberton drinking water. The New York
indirect discharger (CECOS) monitors volatile organics and metals
in each batch and organic priority pollutants weekly. They find
volatiles and organic pollutants (in low levels) in every batch.
No drinking water issue is present in their situation except
across Lake Ontario with the city of Toronto. In order to
control these chemicals, GSX should conduct metals and organic
priority pollutant scans on each batch of effluent. In addition,
complete GC/MS scans should be done biweekly (at least
initially). This procedure may require additional laboratory
equipment and personnel for GSX. However, it will probably not
require additional storage capacity beyond the additional storage
needed to conduct 48-hr bioassays. The 48 hours which are needed
for the bioassays should be sufficient time for organic priority
pollutant analyses by GSX. Once sufficient data have been
generated by GSX for chemistry and bioassays, the frequency and
type of monitoring could be modified if data warrant such a
change. However, initially at least, an extensive chemical
monitoring program is essential to protect LMAC's plant from
upset, protect water quality and aquatic life in the Lumber River
and protect Lumberton's drinking water source.
A. Pass -Through Compounds
GSX identified 12 compounds (4 metals, 1 pesticide and 7
organic priority pollutants) as chemicals which could
pass -through activated sludge WWTP's. The percent removal of a
compound which would identify it as a pass -through was not
specified. In order to examine their list, the literature was
searched for compounds with less than or equal to 50% removal
(comparing influent to effluent) in activated sludge WWTP's
(similar to LMAC's). An additional 65 compounds were identified
as pass -through chemicals for a total of 77 compounds. These are
4 metals (As, Cd, Cr, and Ni), 2 acid extractables, 16

10
base/neutrals, 23 pesticides, 19 volatiles and 9 other chemical
compounds (non -EPA priority pollutants). These results support
more frequent chemical monitoring until sufficient data are
gathered to ensure that these compounds have been removed in
sufficient quantities by the GSX pretreatment facility.
B. Bioaccumulative Compounds
GSX proposes to monitor possible bioaccumulative compounds
from their effluent. To select these compounds, they propose the
following selection criteria.
BCF x persistance > 14,000
Measured BCF in fish > 1,000
Measured or calculated log P > 4.35
BCF = bioaccumulation factor
log P = log octanol:water partition coefficent which is a
measure of a chemical's fat solubility.
The first two criteria are based on EPA recommendations
which appear to be appropriate. The final criteria is based on
the log P which is predicted to result in a BCF > 1000. The
final criteria should be lowered slightly based on an analysis of
the literature concerning the relationship of log P and BCF. The
log P values which predicts a BCF of 1000 are listed below for
several publications. The geometric mean of these is a log P of
4.29. In general, GSX has proposed reasonable criteria to use
to determine potential bioaccumulative compounds.
Log P Organism Citation
for BCF >
1000
4.25 fish Veith, et al. 1984
4.81 fish Kenaga, et al. 1980
5.28 trout Kenaga, et al. 1980
4.06 trout Oliver and Niimi 1984
3.87 trout Oliver and Niimi 1984
3.79 trout Oliver and Niimi 1984
3.71 trout Oliver and Niimi 1985
4.71 fish Davies and Dobbs 1984
Using their criteria, GSX identified 11 chemicals (2 metals,
6 pesticides and 3 organic priority pollutants) as
bioaccumulative. DEM staff have identified an additional 105
bioaccumulative chemicals. This list should not be considered
exhaustive. Clearly, a large number of compounds are potentially
bioaccumulative. Groups with many bioaccumulative compounds are
1) hydroxynapthoquiones, 2) dimethylquinoliniums, 3) benzoic
acids, 4) promazines, and 5) styrenes.
Obviously, routine monitoring for these compounds would be
an impossible task. However, these findings clearly demonstrate
the need for periodic priority pollutant scans as well as

11
complete GC/MS scans. These priority pollutant scans should be
done on each batch until DEM, LMAC and GSX have sufficient
•perational data to reduce their frequency. Complete GC/MS
scans should be done bimonthly from composite samples. The
frequency of these analyses could be reduced once enough data is
collected (estimated time of 4 to 6 months). This information
will also allow us to evaluate the usefulness of bioassays (esp.
Microtox) for this type of effluent. Based on these
considerations plus the drinking water source downstream, GSX's
chemical monitoring proposal (metals on every batch, pesticides
when they are being processed, and priority organic pollutants
weekly) is inadequate.
C. Sludge -Accumulating Pollutants
GSX identified 17 chemicals which tend to accumulate in
sludge (7 metals, 2 pesticides, 7 priority organic pollutants).
This behavior could make the LMAC sludge difficult to dispose.
Based on a limited literature search, an additional 27 organic
compounds and one metal (molybdenum) have been identified as
possible sludge accumulators. This evidence again reinforces
the need for extensive chemical monitoring of the GSX effluent,
at least during initial operation of the plant.
D. Carcinogens
GSX identified possible or probable human carcinogens from
their effluent and determined suggested pretreatment limits for
19 chemicals. Dr. Ted Taylor (DHS) is examining this list in
detail and may have comments regarding its completeness.
V. GSX Pretreatment Plant Design
Several items appear to be inadequate in GSX's design of
their pretreatment plant. First, GSX's design allows them to
avoid using their activated carbon unit and, indeed, they plan
to use it only when necessary. Existing facilities in the U.S.
which treat similar wastes routinely use activated carbon on
every batch of effluent. Sand filters and gravity settler
thickners are used to remove some solids in order to extend the
useful life of the carbon. Given the wide variety of toxicants
(especially organics) which will be treated by GSX, it is clear
that activated carbon should be used to routinely treat all
effluent from their facility. This would require (at a minimum)
the addition of sand filters and probably another carbon column
as a backup unit (both in Phase I).
Second, similar plants in Norfolk, Virginia and Niagara
Falls, New York have had operational problems in the winter
(caused by low temperatures) and have either enclosed their plant
(VA) or will be installing heating units for their biological
system (NY). In New York this is being done to control high
levels of volatile organic chemicals in their effluent in the
winter. This issue should be addressed by GSX.

12
Finally, it appears the GSX's holding capacity for their
final effluent is not sufficient.- GSX plans to release 125,000
•
gpd after testing and approval with 4 holding tanks of 125,000
gallons each. They will be doing 48 hr Daphnia and fathead
minnow tests. Therefore, two tanks will always be full (being
tested), one will be filling and one emptying if the batches pass
the tests. In any case, time will be needed for setting up the
Daphnia (and chemical tests), writing up the data, analyzing them
at GSX, and then analyzing them at LMAC (and DEM?) before
discharge. This process will take about 2 days. Therefore at a
minimum, GSX will need two additional 125,000 gallon holding
tanks. GSX hopes to avoid this by using Microtox as a bioassay
test (15 minute test) to get approval for release. However, it
is far from certain that this will be acceptable and, in any
case, substantial data will have to be gathered on Microtox's
efficiency before it can be used in place of Daphnia tests. In
addition, building additional tanks will be easier while the rest
of the plant is constructed. Therefore, DEM should require GSX
to build at least six 125,000 gallon holding tanks (four are
proposed). Even six tanks may be too few when capacity to store
stormwater runoff is considered.
VI. Additional Issues
Several other items are important relative to DEM's approval
of GSX's pretreatment application.
A. Review of data before discharge - GSX plans to get
LMAC's approval of the treated effluent before release primarily
using bioassay testing. Should DEM (either in Raleigh and/or
Fayetteville) also review the data to approve release to the
LMAC? In New York, indirect dischargers get approval from the
municipality before release and the State regional office reviews
chemical data (often several months after release). In the case
of GSX with Lumberton's drinking water source downstream to
protect, should DEM (or DHS) assume that the LMAC staff will
adequately review GSX's results and ensure water quality in the
river and the drinking water intake? If DEM (and/or DHS) does
review GSX's data before discharge, it will add to the review
time before GSX can release. This will probably require a total
of additional holding capacity at GSX's facility (up to six
additional holding tanks would probably be sufficent).
B. GSX says it will not take PCB wastes or wastes with more
than two chlorine atoms on a benzene ring. However, the
pretreatment application does not specify how this will be
accomplished. In order to make this assurance, each delivery
would have to have a GC/MS scan for pesticides before the batch
is accepted. This seems unlikely due to time and financial
constraints although the SCA plant in New York does screen each
shipment (drum, truck or tank car) for PCB's. In any case, it
appears that some PCB's and chlorinated benzene compounds will be
accepted and treated, and may appear in GSX's effluent.

C. A point that we made to GSX at an early meeting was that
a detailed flow model of the Lumber River is needed from LMAC to
4.umberton's drinking water intake in order to protect the
drinking water supply. The model will be useful in the case of a
spill or large release of toxicants as well as in predicting
Lumberton's concentrations of toxicants which will be released
routinely in low levels. GSX should be responsible for
developing and calibrating the model.
D. The stormwater management plan during Phase I seems
inadequate. GSX states that a large holding tank will be used
(250,000 gallon) in the case of the 100 yr storm (475,000
gallons). This should be carefully examined by DEM. Also, the
issue should be considered whether their management of the 100
year storm is enough to negate the need for a stormwater permit.
cc. Dennis Ramsey
Steve Tedder
Bill Mills
Mick Nolan
Ken Eagleson
Doug Finan

DIVISION OF ENVIRONMENTAL MANAGEMENT
February 21, 1986
MEMO TO: George Everett
FROM: John Dorneib
THROUGH; Bill Kreutzber er WQ `J'G
Alan Klimek
RE: Hazardous Waste Treatment Facilities in New York:
A report on Site Visits
From February 5 to 8, I traveled to Albany and Buffalo, New
York to visit state officials and staff of two hazardous waste
treatment facilities (SCA and CECOS) .in and near Niagara Falls,
New York. Some of these findings are relevant to the
GSX-proposed facility near Laurinburg.
To provide background, the CECOS facility has a design very
similar to what GSX has proposed. CECOS discharges in batch
(about 250,000 to 400,000 gpd) to the Niagara Falls POTW after
chemical/physical treatment, biological treatment (sequential
batch reactors) and activated carbon. Batches are chemically
tested tefore discharge (about every other day) to the Niagara
Falls POTW (an activated carbon plant) which eventually
discharges to the Niagara River (ave flow appx. 60.000 cfs) . In
contrast, the SCA facility stores its treated wastewater (after
using a treatment process similar to CECOS) in large facultative
ponds (to 60 MG) where it is stored for up to a year before
chemical and bioassay testing and direct discharge to the Niagara
River with a diffuser at a 1 MGD maximum rate. CECOS tests for
volatile chemicals on each batch (with a permit limit of 1 mg/1
for each volatile chemical) and also conducts organic priority
pollutant scans (with a permit limit 0.1 mg/1 total) every two
weeks. Metals are done on each batch. Another indirect
discharger (Frontier) is located in Niagara Falls but state
officials say that Frontier and CECOS are similar but that fewer
data are available from Frontier because their indirect discharge
permit is older and has fewer monitoring requirements. New York
state officials say that they plan to modify Frontier's permit to
reflect CECOS' requirements.
I. Volatile Organic Chemicals
SCA has few (if any) volatiles in their effluent since the
treated wastewater is held for about a year. CECOS has
relatively high levels of volatiles, especially in the winter
when their biological plant is less effective. They are
installing heating units to compensate. Table 1 lists the 18
volatiles that have been found in the last year from CECOS and
IV. Bioassay
Only SCA conducts bioassays of their effluent. Acute tests

George Everett
February 21, 1986
Page 2
seasonal trends for total volatiles. The highest levels (to 2.6
mg/1 for methylene chloride and 2.47 mg/1 for chloroform) are
found in the winter. CECOS has limits of 1 mg/1 for each
chemical which they exceeded eight times last year. Chloroform
(average 109 ug/1, 59% of samples), methylene chloride (180 ug/1,
76%), 1,1,2,2 - tetrachloroethane (15 ug/1, 40%), 1,2
-dichloroethane (10 ug/1, 37%) and trichloroethylene (5 ug/1,
32%) are the most common volatile compounds. The waste treatment
process does a good job of eliminating volatile organic chemicals
except in the winter. I would expect that the levels of total
volatiles that CECOS achieves in the spring, summer and fall
(average 101 ug/1 total volatile organics) would be achievable by
GSX (see Figure 1). Summer levels from CECOS are often less than
detection (1 ug/1) for all volatiles. The winter levels from
CECOS would probably not be encountered by GSX because our
winters are much less severe than Buffalo's. However, some
increase in the winter would be expected especially if GSX's
wastewater treatment plant is not heated or enclosed.
II. Non -Volatile Organic Chemicals
Complete synthetic organic chemicals scans have not been run
at either facility. EPA priority pollutants are essentially
never found at the SCA plant except for low levels of halogenated
organics (2 ug/1, 0.8 ug/1 and 0.23 ug/1 in 1985, 1984 and 1983).
Phthalates, benzidine, hexamelthylbenzenes, benziothiazole, and
PCB's were not detectedin batches from those years.
The CECOS facility has detected 22 non-volatile, priority
pollutants in the past year (Table 2). Most coon ones are
isphorone (average of 29 ug/1, in 79% of samples) , phenol (12
ug/1, 25%), and heptachlor (0.4 ug/1, 21%). In addition, (b-BHC
has been found in 46% of samples (average 3.1 ug/1) but these
mostly appear to be another chemical since they were not
confirmed by GC/MS. With the exception of isophorone (an
industrial solvent), the treatment process appears to do a good
job removing non-volative organic, priority pollutants. No
seasonal trends were evident.
III. Metals
Levels of metals for the SCA effluent (with a 1 year
retention time) are generally lower than CECOS. Nickel levels are
rather high from both plants - SCA averages 1.43 mg/1 while CECOS
averages 2.47 mg/1 (Table 3). Otherwise, metal levels are usually
less than 1 mg/1. The SCA plant reports aluminum levels. Total
aluminum averaged 0.97 mg/1 of which 24'% was in the ionic form.
IV. Bioassay
Only SCA conducts bioassays of their effluent. Acute tests

George Everett
February 21, 1986
Page 3
are done on each batch using rainbow trout, fathead minnows and
Daphnia. Treated effluents have never been toxic to the fish -
indeed, no deaths have occurred at any dose. However, toxicity
to Daphnia is common (48 hr LC50's of 51% and 67% in 1984 and 70%
in 1985 - [more data are coming]). State personnel and the plant
operators think that the cause is salt levels in the effluent
which are somewhat high (ave. 9.8 mg/1 total dissolved salts).
Ken Eagleson does not think that these salt levels (by
themselves) would cause Daphnia mortality. However, paphnia
lnagna is very sensitive to nickel (48 hr LC50 from 510 to 4.9
mg/1 - depending on hardness) and this may be another cause of
toxicity. Based on these data, it appears that GSX's effluent
will likely be toxic to Daphnia. Since CECOS and Frontier are
similar in design to the proposed GSX facility, it might be
advisable to arrange with the CECOS and New York State officials
to sample CECOS's (and/or Frontier's) finished effluent, ship it
(on ice) to us' for toxicity testing to confirm this finding.
Alternatively, we might ask GSX to do the testing to indicate if
their effluent will be acutely (and/or chronically) toxic.
V. Bioaccumulative Compounds
The SCA plant is required to maintain colonies of rainbow
trout and fathead minnows- in their discharge to test for
bioaccumulative compounds. As a control, they use fish
maintained in the Niagara River. Other than ethyl hexyl
phthalate in 1984, there is no evidence that effluent -exposed
fish have higher levels of chlorinated pesticides, phthalate
esters or PCB's than do those in the Niagara River. However,
effluent - exposed fish do have levels of heptachlor (to 80 ppt
[trillion]), DDE (to 40 ppt), DDD (to 15 ppt), DDT (to 18 ppt)
which are above detection. This indicates that some organic
compounds may be bioaccumulating but without "clean water
controls" the evidence is inconclusive especially in relation to
the Lumber River situation.
VI. Carbon Treatment
Both state personnel and plant operators agreed that use of
activated carbon on all wastewater from these plants was
essential to protect water quality. -
Vil. In -Lab Testing Facilities
Both plants have a fair amount of laboratory equipment. The
SCA plant screens each shipment to the plant for PCB's using - GC
analyses on -site. If levels are too high (> 50 ppm), the
shipment is refused. The SCA lab has 4 GC's, an auto analyzer
(for metals) and an ion chromatograph. The CECOS lab has an auto
analyzer, and a GC (for volatiles) . They contract out the
priority pollutant analyses and many of the volatile analyses.

George Everett
February 21, 1986
Page 4
IX. State Review of Data
Larry Nadler, Engineer in the Albany Office, suggested that a
crucial element in the GSX decision may be how long it would take
DEM and/or LMAC to collect and review the bioassay and chemical
data before a discharge is allowed. Realistically, it
takes the State of New York about 2 weeks to completely review
the chemical data (which includes mailing time and review by
other agencies). CECOS is allowed to discharge based on fairly
simple measures such as TOC, TSS, pH, phenol and some metals. If
permit limits are complex, a longer review time would be required
which would necessitate more retention time per batch. SCA must
have their bioassay and chemical datqa completely analyzed and
approved by the State before discharge.
X. Water Quality Guidance
Based on these data, it appears that it would be advisable to
develop water quality guidance for the 23 chemicals listed
below. In some cases, aquatic toxicity data may be lacking. In
these cases, DEM should consider contracting for acute or chronic
toxicity testing or doing the testing ourselves. I would expect
that, given the dilution in the Lumber River, the volatiles will
not present water quality problems from the viewpoint of aquatic
toxicity. This should be confirmed with water quality standard
calculations. However, these chemicals may be of concern
relative to the effluent's acute or chronic toxicity or drinking
water quality downstream in Lumberton.
Metals:
Aluminum (in progress)
Barium
Volatile Organic Chemicals
Chloroform
Methylene Chloride
1,2-dichloroethane
trichloroethylene
1,2-dichloroethylene
1,1,2,2-tetrachloroethane
Carbon tetrachloride
Tetrachloroethylene
1,1-dichloroethane
Vinyl Chloride
Non - Volatile Organic Chemicals
Isophorone
2-chlorophenol
2-nitro phenol
Pentachlorophenol
Trichlorophenol
Hexachlorobutadiene
1,2,4-trichlorobenzene

George Everett
February 21, 1986
Page 5
diethyl hexyl phthalate
di-n-butyl phthalate
DDE
DDD
SUMMARY: IMPLICATIONS OF THESE FINDINGS FOR GSX
1. GSX would be expected to release volatile organic
chemicals (especially chloroform, methylene chloride,
tetrachloroethane and trichloroethane) in the 100 ug/1 range
(total volatiles) especially in the winter, fall and spring. The
high levels (to 6 mg/1 total volatiles) seen in the CECOS data
will probably not be found by GSX since our climate is more
moderate than Buffalo, NY.
2. GSX (if they use activated carbon routinely) would be
expected to have few non-volatile priority pollutant organic
chemicals with the exception of isophorone. Isophorone (an
industrial solvent) would probably be present in nearly every
batch (average at CECOS of 29 ug/1, maximum 130 ug/1).
3. GSX would be expected to have low levels of metals in
their effluent except for nickel (1 to .3 mg/1 range) .
4. GSX's effluent would be expected to be nontoxic (acutely)
to rainbow trout_ and fathead minnows. However, the effluent will
likely be acutely toxic to paphnia waasa (LCcri at SCA of about 50
to 70% effluent). Whether this is cased by toxicants
(especially nickel) or the relatively high salt content is
unclear. It would be prudent if DEM (and/or the GSX personnel)
could arrange to have effluent samples from the indirect
dischargers shipped for bioassay testing to confirm this finding.
If the effluents are toxic, it is likely that GSX would not be
able to meet the stipulation (to which we and they have agreed)
that the effluent not be acutely toxic.
5. Low levels of chlorinated organics and phthalate esters
may pass through the GSX plant and be bioaccumulated. However,
data from New York are inconclusive (for our situation) because
their control fish are exposed to the Niagara River which would
be expected to have more organics than does the Lumber River.
6. Activated carbon treatment is essential for every batch
of effluent to ensure acceptable water quality.
7. Based on chemicals found for the New York facilities,-23
additional water quality guidance (mostly for organic compounds)
should be developed. In some cases, it may be necessary to have
DEM or an outside contractor conduct bioassays for chemicals with
few data.

George Everett
February 21, 1986
Page 6
cc. Page Benton
Dennis Ramsey
Steve Tedder
Bill Mills
Mick Nolan
Doug Finan
Ken Eagleson
JD/kls
everett.mem

Table 1
CrCl7S: Dec. 1984 to Nov. 1905
Vo1atil�� nrganic Chemicals
Chemical
Chloroform
Methylene Chloride
1,2 - dichloroethane
Trichloroethylene
1,1,1 - Trichloroethane
1,1,2 - Trichloroethane
Trans 1,2-dichlorethylene
1,1,2-tetachloroethane
1,2 - dichloropropane
Benzene
Chloromethane
Carbon Tetrachloride
Tetrachloroethylene
1,1 - clichloro methylene
1,1 - dichlororlethane
Brou o clichlc•t c :s (: pane
1,2 - dichloroethylene
Vinyl chloride
1, 1- dichloroethylene
Total Volatiles annual
Winter
spring
summer
fall
Number
Present
73
93
45
39
21
62
19
49
2
15
2
17
10
5
8
2
7
1
Ma MO
Samples
Total Percent blie
Samples Presence
123 5 9.3 % 309.2 iig/1
123 75.6 179.7
123 36.6 9.8
123 33.7 5.3
123 17.1 15.2
123 50.5 17.9
123 1.6 0.1
123 39.0 15.3
123 1.6 0.1
123 12.2 1.2
123 1.6 0.2
123 13.8 10.2
123 8.1 1.3
123 4.1 0.4
123 6.5 0.5
123 1.6 0.1
123 5.7 1.0
123 3.3 0.5
123 0.0 0.1
Notes
* If less than detection, then sample equals zero.
--- 347.0 ug/1
1195.0
141 .0
--- 31.0
146.0
Concentrations
Max..,
2 470
2610
140
66
5 2.0
890
7
210
7
19
15
310
37
14
15
11
31
70
9.3
5551
6230
792
286
1077
ug/1 1.9 ug/1
5.0
3.0
1.9
5.2
3.5
6.0
7.0
6.0
5.2
13.0
6.7
4.5
3.4
5."
3.4
32.0
9.3
ug/1 0.001 ug/1
0.000
0.000
0.000
0.000

,
Chemical
Table 2
CECOS: Dec. 1984 to Nov. 1985
Priority Pollutant Organic Chemicals - ug/1
,samples
Present
Samples
Presence
flYg*
Total
Max.
Acid extractables:
Phenol 6 24 25.0% 12.1 ug/1 171 ug/1 5.3 ug/1 '
Pentachlorophenol 3 24 12.5 4.3 84 9.6
2 - Chlorophenol 1 24 4.2 0.3 87 87
2 - Nitrophenol 2 24 8.3 10.8 160 100
2,4,6-trichlorophenol 3 24 12.5 1.5 18 3.4
Base/neutrals: I
Ethyl hexyl phthalate 1 24 4.2 0.3 6.3 6.3
Di-n-butyl phthalate 1 24 4.2 0.3 7.4 7.4
Isophorone 19 24 79.2 29.4 130 8.6
Hexachlorobutodiene 2 24 8.3 0.1 2.6 0.94
1,2,4-trichlorobenzene 2 24 8.3 0.2 2.3 2.0
Pesticides:
Heptachlor 5 24 20.8 0.38 4.3 0.2
Heptachlor epoxide 2 24 8.3 0.02 0.21 0.2
a - BMC 3 24 12.5 0.04 0.6 0.1
b - BMC@ 11 24 45.8 3.10 @ 10.0 0.045
g - BMC 3 24 12.5 0.03 0.63 0.03
d - BHC 3 24 12.5 0.07 1.5 0.11
Endrin 1 24 4.2 0.01 0.16 0.16
Hexachlorocylohexanes 1 24 4.2 0.02 0.39 0.39
Endosulfan 1 24 4.2 0.08 2.0 2.0
4,4,-DDD 1 24 4.2 0.02 0.47 0.47
4,4,-DDE 3 24 12.5 0.02 0.24 0.16
4,4,-DDT 1 24 4.2 0.01 0.13 0.13
Totals
Halogenated -- - 4.23 ug/1 I0.0 0
Non -halogenated - -- - 65.0 ug/1 201.3 0 -
notes:
*: If less than detection - then sample equals zero
@: of the 11 B - BMC samples, 7 were not confirmed by GC/MS
Table 3
CECOS: Dec. 1984 to Nov. 1985
Metals and Other Parameters
Monthly Monthly plonthiv
Chemical Coverage* Maximum Minimum
Arsenic 0.08 mg/1 0.27 mg/1 < 0.005 mg/1 ,
Barium 0.76 1.80 < 0.1
Cadmium 0.08 0.61 < 0.005
Chronium 0.30 - 1.75 0.01
Copper 0.17 0.27 0.01
Lead 0.42 0.75 0.15
Mercury <.0002 <.0002 < .0002
Nickel 2.47 5.38 1.22
Zinc 0.68 1.35 0.23
SOC 432 lb/day 800 lb/day 238 lbs/day
TSS 62.9 124 6.6
Notes:
* If less than detection, sample equals zero.

DIVISION OF ENVIRONMENTAL MANAGEMENT
February 14, 1986
MEMORANDUM
TO: Arthur Mouberry
FROM: Steve Zoufaly
THRU: Meg Kerr g
SUBJECT: Laurinburg-Maxton Airport
A Level B modeling analysis was performed on the existing Laurinburg-
Maxton Airport discharge to the Lumber River. The resulting limits were
computed to be 63 mg/1 BODult for summer at 1.0 MGD. The BODuit dis-
aggregation therefore was BOD5 15 mg/1 and NH3-N 12 mg/1, however the
Fayetteville regional engineer, Tommy Stevens, reviewed the facility's
self monitoring data and felt a different BODuit disaggregation was required.
Still using the formula BODuit - 1.0 (BOD5) + 4.0 (NH3-N), limits of BOD5
27 mg/1 and NH3-N 9 mg/1 for the summer were recalculated. The latter
limits are the ones seen on the NPDES Waste Load Allocation form.
If you have any questions regarding the change, please ask.
SZ/gh

MEMORANDUM
TO:
FROM:
THROUGH:
DIVISION OF ENVIRONMENTAL MANAGEMENT
January 16, 1986
George Everett
John Dorney
Alan Klimek U
Bill. Kreutzberger?i
JAN1? 1986
PERMITS 4 ENGINEERING
REGARDING: Norfolk, Virginia site visit and planned visits to
New York hazardous waste treatment plants
On January 6, six staff members (Rick Hiers, Arthur Mouberry,
Mick Nolan, Matt Mathews, myself and Bill Reid [DHS]) went to the
Naval Yard in Norfolk, Virginia to tour their activated carbon
WWTP and talk to officials of the Hampton Roads Sanitary District
which receives waste from the Navy. The Naval facility is
essentially a large metal plating operation but in addition
receives and treats large amounts of organic chemicals (esp.
phenols, methylene chloride and trichlorethane) used in paint
stripping operations. They discharge about 120,000 gpd. The
Navy has used carbon at their facility since about '1978 at the
insistance of the Sanitary District. After chemical treatment of
the wastes (pH adjustment, H 0 , chlorination), the wastewater
enters a gravity settler th1c1ener (to remove solids), sand
filters (for more solids removal) and finally enters the carbon
beds. From the Navy's data, activated carbon has reduced phenol
levels from an average of 8.5 mg/1 to 0.1 mg/1 (98% reduction).
Before they installed the sand filters and thickener, the Navy
had to replace the carbon fairly often. Since then, they replace
the carbon less than 4 times a year. They have used Microtox to
a limited extent but find that it is not too useful.Recently,
they have enclosed the -plant to reduce operational problems in
adverse weather especially in the winter.
Guy Adylett (Chief, Industrial Waste Division of the Sanitary
District) said that (in GSX's case) he thought that GSX should
use activated carbon on each batch with sand filtration to
protect the carbon beds. The Navy has a total toxic organics
limit (as a metal plater) of 2.13 mg/1. The Naval wastewater is
usually about 0.1 mg/1 (data being sent). Complete GC/MS scans
are done twice a year.
The three plants near Niagara Falls, NY are more similar to
the proposed GSX plant. I have copies of the NPDES permit for
the SCA facility and the CECOS facility (indirect discharger) in
New York. If you or anyone else would like complete copies,

Page 2
George Everett
January 16, 1986
please let me know. The SCA permit is very complex and
comprehensive. The company has numerical limits for 23 metals,
11 other pollutants and 8 organics (PCB's, phenol, benzidine,
toluene, phthalates, benzisothiazole, hexamethylbenzene, and
total halogenated hydrocarbons). In addition, there are
monitoring requirements for 6 metals, and 5 other pollutants
(such as bromide and iodide). Each batch must be tested for all
limited parameters. In addition, each batch is subject to acute
flow -through testing with fathead minnow, rainbow trout and
Daphnia. Complete GC/MS scans are also done on each batch. State
and local review groups have 30 days to review the data before
discharge. During discharge, rainbow trout are used as
biomonitors for mortality, sublethal effects and bioaccumulative
substances.
The CECOS facility discharges to the Niagara Falls POTW. Both
facilities routinely use activated carbon. The CECOS
pretreatment discharge permit has limits for 8 metals, two
organics (trichloroethane and chloroform at 34 ug/1 each) and
souble organic carbon (1.32 mg/1). They also discharge in a
batch basis after testing and agreement with the city. Complete
GC/MS scans are done every two weeks. TOC, phenols, conventional
pollutants and volatiles are analyzed from each batch. The
extensive data show some volatiles after carbon treatment with a
few acid extractables or base -neutrals infrequently.
Due to the massive amounts of data from the SCA and CECOS
facilities, state and local officials are reluctant to copy and
send their numbers but are very willing to allow us to see them
and copy what we need. Therefore, I tentatively plan to visit
Albany and Niagara Falls (Buffalo) from February 5 to 8 to view
state government documents and talk to state officials and then
fly to Buffalo for site visits at the plants and visits with
local officials to see their data.
Meg Kerr and the Technical Support Unit have rechecked their
earlier estimate of flow time from the Laurinburg-Maxton POTW to
the City of Lumberton drinking water intake on the Lumber River.
The correct distance from Laurinburg to Lumberton is 34.6 river
miles. The river meanders tremendously through a swamp forest.
Using an empirically derived travel time of 0.3 fps, the travel
time to Lumberton at 7Q10 was estimated to be 7.0 days.
JRD/kls
cc:
Steve Tedder
Dennis Ramsey
Bill Mills
Doug Finan
Arthur Mouberry
Mick Nolan

CHROME
P?�EFJOL
INFLUENT
CYAN l OE
INFLUEN
<602
<N202
<NaOH
CHRQM E REDUCTION
PHeNoL PRETREATMENT
---(C(2
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CYANIDE
OXIDATION
OLYkIER
u
1.1E U TR A L I ZATI 014
figure 2 .
Upgraded. Process Flow
v
SETTLER
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H
60,E
.N D
FILTER
FILTER PREBE
SLU DGE
CONOITIONINC
CARBON ADSORPTION
(PERMANENT)
EFFLUEN1
TO HRSD
CAKE To SECURE LANDFILL

State of North Carolina
Department of Natural Resources and Community Development
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor R. Paul Wilms
S. Thomas Rhodes, Secretary January 13, 1986 Director
Nelson V. Mossholder
Director of Technical Services
GSX Corporation
Chemical Services Group
P.O. Box 210799
100 Executive Center Drive
Santee Building, Suite 128
Columbia, South Carolina 29221
Dear Dr. Mossholder:
RE: GSX Comments Relating to
Preliminary Draft LMAC Permit
We would like to thank you for your review and comments, dated December
4, 1986, concerning the subject draft permit. Your response has been eval-
uated by the staff and the following addresses those comments.
Comment: Your review correspondence indicated that the lowest LC50 for
chlorine that has been found was 0.23 mg/1 and that our stan-
dard was more conservative than necessary. It was also com-
mented that the North Carolina regulations promulgate no
standard other than 2.0 mg/1 for trout waters. Additionally
you questioned the chloride and sodium limitations.
Response: The figure that you have quoted for the lowest LC5 value for
chlorine is off by an order of magnitude. Ward aria DeGrave,
1978 have reported an LCS0 value of 17 micrograms per liter.
This Division is also currently developing a statewide chlo-
rine implementation strategy that may modify any restrictions
indicated in the draft LMAC permit. Our regulations allow us
to limit any toxic constituent based upon predicted receiving
stream impacts.
Your comments relating to a trout water chlorine stan-
dard of 2.0 mg/1 are in error. The N.C. chlorine standard
for trout water is 2.0 micrograms per liter.
Pollution Prevention Pay.
P.O Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Emnlourr

The sodium and chloride limitations included in the
draft permit are based upon previous LMAC permit limitations
which are based on effluent guidelines for one of the indi-
rect discharges to the LMAC system.
Comment: Your comments indicated that there were several constituents
listed that GSX will not be accepting and that a few of the
constituents listed are unstable in water. Also you noted
typographical errors, duplicative entries, etc.
Response: Your comments have been noted and any final draft developed
will take those comments into account.
Comment: Your review of the permit limitations in the draft permit
indicated that they are overly conservative and you indicated
that a dilution factor of 176 allows more assimilative capa-
city than we have allocated.
Response: Your comments indicate that the ratio of 135 cfs (7Q10) and
1.0 MGD (Permit Flow) is 176 times. After proper conversion,
the correct ratio is approximately 88 times, not 176. In
addition, the most recent flow information indicates that the
7Q10 is 111 cfs rather than 135 cfs. It is the intent for
allocation to allow maximum discharge concentrations as
defined by our water quality regulations and based on mass
balance equations.
Comment: It was noted that for some chemicals that the end of pipe
limits indicated in the draft would not assure protection of
human health or the environment.
Response: Your comments are noted and final determinations will be made
in conjunction with the Department of Human Resources to
assist in human health numerical limitations.
Comment: You have suggested that the reopeners be modified to include
language that required demonstration of adverse effects or
impacts to the Lumber River.
Response: The reopeners should not be usable only upon demonstration of
aquatic or human health impacts. We are regulating impacts
at predicted flow levels ;(7Q10). If flows are high there
may not be an immediate effect even though the permit is
being violated. Any human health or aquatic impacts will not
be allowed to be expressed prior to DEM's response of reope-
ning a permit.
Comment: You have indicated that the Ceriodaphnia test concentrations
are too low and that a higher level substituted for the lower
concentration may be more useful for monitoring than those we
established.

Response: Your argument has merit. If we knew that the ChV measure-
ments were going to be significantly higher than the IWC's,
then this makes sense. If, however, a toxic problem does
arise, we will want to know by how much LMAC is failing to
meet the permit limit. In this case the lower concentrations
would be more useful. Perhaps these test concentrations may
be modified after future testing with a requirement that
lower concentrations be used if a problem arises.
Comment: The inclusion of a single exposure treatment of 95% seems
superfluous when weekly chronic tests are being conducted
simultaneously.
Response: Depending on the acute to chronic ratio of a substance, it
is possible that there may be an acute response in a concen-
tration over 90% with no reproductive impairment in Ceriod-
aphnia. Our water quality regulations indicate that a toxic
substance is to be allocated at a level one hundred times
lower than the LC50 value.
Since the IWC is greater than one percent, the LCSQ
value must exceed 100%. In this instance the LC50 would
theoretically have to be greater than 137%. Since this is
not possible, North Carolina uses a criteria of no signifi-
cant mortality in 90% effluent (for Daphnia tests only). To
allow 50% mortality in 90% effluent would be contradictory of
our Water Quality Regulations.
We agree that there was an inconsistency between the
allowable mortality in Ceriodaphnia versus the Fathead Min-
now. The permit should be altered to require no more than
10% mortality in 90% effluent for Ceriodaphnia and no more
than 10% mortality in the Fathead Minnow tests. A specifi-
cation of 20% mortality in the draft permit should have been
10% to be consistent with our protocols.
Again, we appreciate your comments and if there are questions, please
contact George Everett or Steve Tedder at [phone].
Sincerely,
.27"".1*)
L.P. Benton, Jr.
Deputy Director
cc: R. Paul Wilms
George T. Everett
Steve W. Tedder
Dennis Ramsey

/2 4 c
GOMBS & ASSOCIATES, INC.
POST OFFICE BOX 32185 • CHARLOTTE, NORTII
ORIGINAL TO: RAMSEY/MILLS
COPY TO: Permits
December 20, 1985
Department of Environmental Management
Attention: Dr. George Everett
P.O. Box 27687
Raleigh, North Carolina 27611-7687
Re: GSX Toxic Waste Facility
Dear Dr. Everett:
CAROLINA
28232 - 2185
'(704) 370 - 0450
.-err; ,�=: C -: r Y• ./" ��yj f_.Y �.'#q
;SEC 231925
WATER 'QUALITY
S
DEC 27 .1985.
PERMITS & ENGIJJeF,Rf OE
Thank you; very much for allowing me to visit during the meeting this
past Tuesday morning on the GSX facility.
I would appreciate your efforts to keep me posted on these meetings so:
that I may, participate. I'm quite familiar with these treatment '
schemes, and I'm very interested in.seeing these systems as fail safe as
possible.
I would like to make the following request that clarification be made or'
changes as necessary for the following items:
From the flow data :::en, it would appear that. the storm water at.
worst case and the ign flow of .the. plant will exceed the pumping'
capacity of the ps fromthe,equalization basin into the -mix
tank. Should.thesumps be made slightly larger in capacity or a
third pump:added fohe worst case condition? Other pumps within';
the facility. may be. 4.004 the same category. r! x
I am sure.the Laurinburg-Maxton treatment facility is interested'in`
:having as few suspended solids as possible sent to them from the
pretreatment„ -facility. Experience has shown that chemical,
addition, such::as a polymer, can reduce pinpoint floc. I would
uggeatHthat so4e type. of inline.mixer or.floculator type clarifier
eF ' ativestigated Sol that the :addition of floculating chemicals
within the feed well could remove as much of the pinpoint floc :As
possible.

be addressed
December 20, 1985
Dr. Everett
page -2-
3. During the meeting it was noted that there may be the potential for
surges from the pretreatment facility to the Laurinburg-Maxton
facility during high storm water flows. I gathered from the
presentation that the operator of the pretreatment facility would
have to communicate with the operator at the Laurinburg-Maxton
facility in order to alarm the Laurinburg-Maxton operator of the
hydraulic surge. I would suggest that some type of simple
flowmeter be installed in the line from the pretreatment facility
to Laurinburg-Maxton in order to enhance this communication between
the operators.s vr400.�"_
. Ground water monitoring should
application.
5. If South Carolina, Virginia, or any other states have toxic waste
facility guide lines for permitting, I would appreciate GSX
cooperation in obtaining some of these guidelines.
6. How are toxic waste which enter the pretreatment facility which are
not biodegradable handled and what.is their ultimate consequence
should they pass through the activated carbon filters?
In lieu of hauling the toxic sludge waste into South Carolina, has
GSX investigated burning the waste on site?
good point :was made with regards to low flows through the
effluent -holding tanks. Oxygen depletion may occur and I would.
(appreeiatn;,GSX addressing this problem with aeration and mixing..
the
permit
I am hopeful that.the questions which were asked in the letter by Mr.
Johnny Hester and' Mr. Raymond Deese:. can be resolved to their
satisfaction. Once again, I appreciate your efforts to keep me involved
on this project. I would like to request that once the application for
the permit of the GSX facility is submitted, I be allowed to review its
contents. 'Your cooperation is appreciated.

North Carolina Department of Human Resources
Division of Health Services
P.O. Box 2091 • Raleigh, North Carolina 27602-2091
James G. Martin, Governor
Phillip J. Kirk, Jr., Secretary
December 16, 1985
Mr. Dennis E. Harrington, Director
Scotland County Health Department
P. 0. Box 69
Laurinburg, N. C. 28352
Dear Mr. Harrington:
Ronald H. Levine, M.D., M.P.H.
State Health Director
919/733-2870
DEC 17 198!
PERMITS & ENGINEERING
Reference is made. to your December 6, 1985 letter expressing your concerns
regarding the potential contamination of water supply intakes by wastes from
the proposed GSX Hazardous Waste Treatment Facility.
We share your concerns for assuring that raw water quality is not jeopardized
by upstream discharges.
We are not familiar with the "rule of thumb" included in your letter. The
Environmental Management Commission classifies all of the state's surface waters.
A -II classifications are usually initiated by a request from a governmental
body (city, county, etc.) which proposes tousethe water as a source of drinking
water supply. The classified segment usually extends from some local landmark
such. as a bridge or county line to a point just downstream from the proposed
intake.. For water supply reservoirs, the entire watershed is usually classified
as A -II.
Once a stream segment is classified as A -II, the Division of Environmental
Management must request the Division of Health Services review of any applications
to permit discharges into it. DivisionofEnvironmental Management will not
issue.a NPDES into A -II waters over Division of Health Services' objection.
Although the Laurinburg-Maxton Waste Treatment Plant discharges to Class C
water, due to the nature of the proposed GSX facility and the proximity to A -II
waters, the DEM and the DHS have been working together to review the proposals
on wastewater treatment and disposal for the proposed GSX facility. This review
is not yet complete. However, you can be assured that protection of the downstream
.water intakes is of primary concern.
If you have any further questions regarding this matter, please let us know.
Sincerely,
.C/44P4v
7
James F. Stamey, Chief
Environmental Health Section
cc: Ronald H. Levine, M.D., M.P.H.
rthur Moubefry.
C. E. Rundgren An
Eat OPpornmity � Affirmative Action Employer
Bill Meyer

SCOTLAND COUNTY HEALTH DEPARTMENT
1405 WEST BOULEVARD
POST OFFICE BOX 69
LAURINBURG, NORTH CAROLINA 28352
Dennis E. Harrington, M.P.H.
Health Director
December 6, 1985
Dr. Ronald Levine, State Health Director
Division of Health Services
P.O. Box 2091
Raleigh, North Carolina, 27602
Dear Dr. Levine:
DEC
ortnr-
Phone [phone]
7.4
QEc 10 fa:
In reviewing the permit application locally for the GSX Hazardous Waste Treatment
Facility in Scotland County, the importance of the POTW (Laurinburg-Maxton Waste
Water Treatment Plant) has become increasingly clear as it relates to accepting
the waste water from the proposed industry (GSX) and inturn discharging its
effluent to the Lumber River. The area of the river of the POTW'S discharge is
within 1500 feet' of a Robeson County surface intake and approximately 14 miles
from the intake of Lumberton Municipal Water System. In discussions concerning
this area of the river as it relates to water classifications based on its
proximity to the above mentioned intakes, a "rule of thumb" has surfaced as follows:
ENL "the area upstream froman intake of a public water supply for
r�,,,_:3 = five (5) to ten (10) miles should be considered an"A-II" water
zone of the river. This river designation would require any
discharge permit issued to be reviewed by Division of Environmental
Management and the Division. of Health Services and be issued
jointly."
I ful if you would address this issue for us in order to
clarify and define such a designation and outline what steps will be taken to
assure safe water quality at these critical intakes. This will enable all .
concerned to work under a unified understanding and not a "rule of thumb"
known by some and not by others. r ,
Your consideration and response to this matter will be greatly appreciated.
cerely,
De is E. Harrington
Health Director
cc: Scotland -County Boards of Health
and County Commissioners •
Scotland County Permit Review.Committee

►
DIVISION OF ENVIRONMENTAL MANAGEMENT
October 16, 1985
MEMORANDUM
TO: Bill Mills
FROM: Arthur Mouberry
SUBJECT: GSX
RCRA Permit Application
Scotland County
I have reviewed the portion of the GSX permit application that
pertains to items that may require a NPDES permit. The following
items are noted for your review.
1. The facility proposes to discharge their process wastewater
into the Laurinburg-Manton Airport Wastewater Treatment
Plant for final treatment before discharging into the Lumber
River. Given the nature of this facility, it is recommended
that the applicant pursue a separate NPDES permit for this
facility.
2. The applicant proposes to contain the maximum one hour
rainfall with a 10 year recurrence interval (144,000
gallons) that falls within the tertiary containment area.
This water will be pumped to the tertiary containment tank
for treatment. The applicant should be advised that all
rainfall on the container and railcar handling facility, the
bulk waste handling and chemical pretreatment plant, and the
wastewater treatment plant should be collected and routed
through the waste treatment facility. We request that the
applicant provide additional justification as to why the 10
year one hour rainfall event was choosen. Any other
rainfall on the site is proposed to be discharged without
treatment. The applicant needs to be made aware that this
facility will fall under the new federal regulations
covering stormwater runoff. A NPDES permit application will
need to be filed by December 31, 1987.
3. As this facility is located approximately 24 miles upstream
of an A -II water body, the Division of Health Services will
be asked to provide comments on the proposed discharge from
this facility.

Memorandum to: Bill Mills
Page Two
October 16, 1985
4. The applicant proposes to do an extensive series of
pretreatment operations on the waste prior to discharging to
the waste treatment facility. After reviewing the data
provided, I do not feel that a non -discharge permit for a
recycle system would be required. The disposal of the
sludge generated from the pretreatment facility and the
waste treatment facility does fall under this Department's
jurisdiction. However, the applicant does not propose to
dispose of this sludge locally. The plan is to ship the
sludge out of state to an approved facility. It is my
recommendation that the Department request the Division of
Health Services to assume the responsibility of permitting
the disposal of sludge under its RCRA manifest system.
If you have any questions concerning these comments, please
contact me.
cc: Dennis Ramsey

Monitoring Recommendations
GSX Hazardous Waste Treatment
Facility
I. Indirect Discharge GSX
A.) Continuous Biomonitoring (FishRespiration)
B.) Mutagen Testing (Ames/Prival)
To be performed on each batch treatment process prior to
discharge.
C.) Teratogen Testing (Hydra Assay.)
To be performed on each batch treatment process prior to
discharge.
D.) Chemical Monitoring
Levels of all chemicals known to be in waste batch determined,
and compared to known toxicity levels.
II. Direct Discharge - Laurinburg/Maxton Airport
A.) Pass/Fail Chronic Testing
To be performed monthly on NPDES discharge point, above
chlorination.
If this test is failed, a full range acute and chronic test
must be performed immediately.
B.) Chemical Monitoring
Low Level Metals
Priority Pollutants
Organics Scans
Conventional Pollutants
C.) Biological Survey
1.) Benthic Macroinvertebrate Surveys to be performed
quarterly at a minimum of two stations below the
discharge and one above.
2.) Yearly Fisheries Survey to identify population structures
and evaluate health (conditions) of resident species
(three stations).
To include growth (scale) measurements and year class
analyses.

Test Component Advantaggs
1.) Continuous Biomonitor
(Fish Respiration)
2.) Mutagen Testing
(Ames/Prival)
3.) Hydra Assay
4.) Chemical Monitoring
5.) Pass/Fail Chronic
Testing
Provides "Real Time" biological evalu
ations.
Allows diversion of waste stream if
toxicants are detected.
Provides some human health protection.
Indirectly monitors carcinogens.
Provides moderate detection Of
Teratogens
Provides specific concentrations of
chemicals present.
Allows monitoring of toxicant levels'
which are predicted to have no
effect on the receiving stream.
Disadvantages
A pass/fail criteria would have to be
established.
A single species may not react to the
variety of chemicals which may be
present.
Frequency of False Negatives and False
Positives unknown.
Requires 48 hours Test Duration.
_.t
Requires seven days to perform.
Not thoroughly tested for use in complex
effluents.
Must specify parameters to be identified.
Biological effects of most compounds not
well defined.
' Additive Toxicities not identified.
Requires seven days to complete test.
6.) Biological Stream Survey Extremely Sensitive to toxicant impacts. Detects Impacts after they have occurred.
1

DIVERSION
Hydra
Assay (Teratogens)
Biological Survey
1
ti
Continuous Biomonitoring
(Fish Respiration)
Mutagen Testing
(Ames/Prilval)
r J
Chemical• Monitoring
DIRECT
Pretreatment
Requirements
• Laurinburg/Maxton Airport
Monthy:.Pass/Fai 1 CironicTestXng
Chemical Monitoring
Biological Survey
Biological Survey
_ � v
Lumber River
Lumberton

Monitoring Costs Estimates (GUESS)
1.) Continuous Biomonitoring
2.) Mutagen
$600 .per test
25stests per year
3.) Teratogen Testing
$800 per test
25.tests per year
4.) Chemical Monitoring
5.) Chronic Testing
$250 per test
12 tests per year
Start Up Cost Yearly Costs
$ 20,000 $ 8,000
15,000
'20,000
3,000
6.) Biological Survey
. Benthic Survey 5,000
Fisheries Survey - 3,500
$20,000
$54,500
(Non -Chemistry)

Chapter I —Environmental Protection Agency § 261.20
6 261.11 Criteria for listing hazardous
waste.
(a) The Administrator shall list a
(vii) The plausible types of improper
management to which the waste could
be subjected.
(vim The auantitles of the waste
Recoils" 4-6 Gsx's CA
tial 64‘
w al foie k a.�. � �►10 a l ( otf4,o1/44,4
ti cLLOvTL1I4 ades (etcepl Jr gse Ae104,
uent in the waste.
(iii) The potential of the constituent
or any toxic degradation product of
the constituent to migrate from the
waste into the environment under the
types of improper management consid-
ered in paragraph (a)(3)(vii) of this
section.
(iv) The persistence of the constitu-
ent or any toxic degradation product
of the constituent.
(v) The potential for the constituent
or any toxic degradation product of
the constituent to degrade into non -
harmful constituents and the rate of
degradation.
(vi) The degree to which the constit-
uent or any degradation product of
the constituent bioaccumulates in eco-
systems.
7>. Hills
Subpart C—Characteristics of
Hazardous Waste
f 261.20 General.
(a) A solid waste, as defined in
§ 261.2, which is not excluded from
regulation as a hazardous waste under
§ 261.4(b), is a hazardous waste if it ex-
hibits any of the characteristics identi-
fied in this Subpart.
(Commend f 262.11 of this chapter sets
forth the generator's responsibility to deter-
mine whether his waste exhibits one or
more of the characteristics identified in this
Subpart]
(b) A hazardous waste which is iden-
tified by a characteristic in this sub-
part, but is not listed as a hazardous
1
353

§ 261.21
waste in Subpart D, is assigned the
EPA Hazardous Waste Number set
forth in the respective characteristic
in this Subpart. This number must be
used in complying with the notifica-
tion requirements of Section 3010 of
the Act and certain recordkeeping and
reporting requirements under Parts
262 through 265 and Part 270 of this
chapter.
(c) For purposes of this Subpart, the
Administrator will consider a sample
obtained using any of the applicable
sampling methods specified in Appen-
dix I to be a representative sample
within the meaning of Part 260 of this
chapter.
[Comment: Since the Appendix I sampling
methods are not being formally adopted by
the Administrator, a person who desires to
employ an alternative sampling method is
not required to demonstrate the equivalency
of his method under the procedures set
forth in tt 260.20 and 260.21.]
[45 FR 33119. May 19, 1980. as amended at
48 FR 14294, Apr. 1, 1983]
f 261.21 Characte
of ignitability.
(a) A solid waste a -he-cKarac-
teristic of ignitability if a representa-
tive sample of the waste has any of
the following properties:
(1) It is a liquid, other than an aque-
ous solution containing less than 24
percent alcohol by volume and has
• flash point less than 60°C (140'F), as
determined by a Pensky-Martens
Closed Cup Tester, using the test
method specified in ASTM Standard
D-93-79 or D-93-80 (incorporated by
reference, see f 260.11), or a Setaflash
Closed Cup Tester, using the test
method specified in ASTM Standard
D-3278-78 (incorporated by reference,
see § 260.11), or as determined by an
equivalent test method approved by
the Administrator under procedures
set forth in f § 260.20 and 260.21.
(2) It is not a liquid and is capable,
under standard temperature and pres-
sure, of causing fire through friction,
absorption of moisture or spontaneous
chemical changes and. when ignited,
burns so vigorously and persistently
that is creates a hazard.
(3) It is an ignitable compressed gas
as defined in 49 CFR 173.300 and as
determined by the test methods de-
scribed in that regulation or equiva-
Title 40—Protection of Environment
lent test methods approved by the Ad-
ministrator under f i 260.20 and 260.21.
(4) It is an oxidizer as defined in 49
CFR 173.151.
(b) A solid waste that exhibits the
characteristic of ignitability, but is not
listed as a hazy ous waste in Subpart
D, has Hazardous Waste
Numbe
[45 FR 331 ,-May-19, 1980, as amended at
46 FR 35247, July 7, 1981]
0 261.22 Characteris c corrosi
(a) A solid waste exhibits the charac-
teristic of corrosivity if a representa-
tive sample of the waste has either of
the following properties:
(1) It is aqueous and has a pH less
than or equal to 2 or greater than or
equal to 12.5. as determined by a pH
meter using. either an EPA test
method or an equivalent test method
approved by the Administrator under
the procedures set forth in § § 260.20
and 260.21. The EPA test method for
pH is specified as Method 5.2 in "Test
Methods for the Evaluation of. Solid
Waste, Physical/Chemical Methods"
(incorporated by reference, see
§ 260.11).
(2) It is a liquid and corrodes steel
(SAE 1020) at a rate greater than 6.35
mm (0.250 inch) per year at a test tem-
perature of 55°C (130°F) as determined
by the test method specified in NACE
(National Association of Corrosion En-
gineers) Standard TM-01-69 as stand-
ardized in "Test Methods for the Eval-
uation of Solid Waste, Physical/
Chemical Methods" (incorporated by
reference, see § 260.11) or an equiva-
lent test method approved by the Ad-
ministrator under the procedures set
forth in § § 260.20 and 260.21.
(b) A solid waste that exhibits the
characteristic of corrosivity, but is 'not
listed as a hazardous waste in Subpart
D. has t H : = dous Waste
Numbe
[45 FR 33 ' , 1980, as amended at
46 FR 35247, July 7, 1981]
6 261.23 Characterlsti
(a) A solid waste exh • - e charac-
teristic of reactivity if a representative
sample of the waste has any of the fol-
lowing properties:
354

Chapter I —Environmental Protection Agency
(1) It is normally unstable and read-
ily undergoes violent change without
detonating.
(2) It reacts violently with water.
(3) It forms potentially explosive
mixtures with water.
(4) When mixed with water, it gener-
ates toxic gases, vapors or fumes in a
quantity sufficient to present a dange
to human health or the environme
(5) It is a cyanide or sulfide be
waste which, when exposed to pH
ditions between 2 and 12.5, can gen r-
ate toxic gases, vapors or fumes in a
quantity sufficient to present a . _ r
to human health or the environme t.
(6) It is capable of detonation or
plosive reaction if it is subjected to a
strong initiating source or if hea d
under confinement.
(7) It is readily capable of deto
tion or explosive decomposition or
action at standard temperature an
pressure.
(8) It is a forbidden explosive as d
fined in 49 CFR 173.51, or a Class
explosive as defined in 49 CFR 173.53
or a Class B explosive as defined in 49
CFR 173.88.
(b) A solid waste that exhibits the
characteristic of reactivity, but is not
JD listed :. :. us waste in Subpart
D. Hazardous Waste
N
f 261.2
(a) A solid waste
teristic of EP toxicity if, using the test
methods described in Appendix II or
equivalent methods approved . by the
Administrator under the procedures
set forth in If 260.20 and 260.21, the
extract from a representative sample
of the waste contains any of the con-
taminants listed in Table I at a con-
centration equal to or greater than the
respective value given in that Table.
Where the waste contains less than 0.5
percent filterable . solids, the waste
itself, after filtering, is .considered to
be the. extract:Sor the .purposes of this
section. -- . . .. ..... .. .
(b) A solid waste that exhibits the
characteristic of EP toxicity, but is not
listed as a hazardous waste in Subpart
D. has the EPA Hazardous Waste
Number specified in Table I which cor-
responds to the toxic contaminant
causing it to be hazardous.
§ 261.30
TABLE 1—MAXIMUM CONCENTRATION OF CON-
TAMINANTS FOR CHARACTERISTIC OF EP
Toxicrry
EPA
hazardous te
Contaminant
0004 Arsenic
D005 Barium
Cadmium
D007 . Chromium »».....»««
D008 Lead
0010 »»..».»_..
O 011 .. Silver ....... ».......»»»»..... ««.»......
«.».
Endrin (1.2,3.4.10.10-hexach-
Ioro-1,7-epoxy-
1.4.4a.5.6.7.8,8a-octahydro-
1.4.endo. undo-5.8-crimeth-
ono-naphthslene.
O 013 - Lindens (1.2.3.4.5.8•hexa- ch or
_ ocyaohexane. gamma isomer.
D014 w«« Methoxych or (1.1.1 Trichloro-
(p-rnethoxy-
) 0015 Toxephene (C,.H,.•Ct,. Technical
chlorinated csmphene. 87-89
percent chlorine).
0016....-»« 2.4.0. (2.
tic add).
0017 ........»... 2.4.5-TP Sikes (2.4.5-Trichlo•
>r- add)
Maxinxum
concentra-
tion
(p��
5.0
100.0
1.0
5.0
5.0
02
1.0
5.0
0.02
0.4
10.0
0.5
10.0
1.0
Subpart D—Lists of Hazardous
Wastes
f 261.30 General.
(a) A solid waste is a hazardous
waste if it is listed in this subpart,
unless it has been excluded from this
list under f f 260.20 and 260.22.
(b) The Administrator will indicate
his basis for listing the classes or types
of wastes listed in this Subpart by em-
ploying one or more of the following
Hazard Codes:
IQrrltablewaste ...........»«....»»«....« ..... »..............»......»...
Corrosive Waste
Reactivewaste..»».........»»...«.»«.»»»....»»......»»...«»....
EPToxic Waste ....».«»...»»«».».««....».»..........«»..».»....
AcuteHazvdous Waste.».»..««....»....»«»»».........«.»»..
ToxicWssta«.....»....................»..»«».....»»«»..««»...»«««
(n
(C)
(R)
(H)
Appendix VII identifies the constitu-
ent which caused the Administrator to
list the waste as an EP Toxic Waste
(E) or Toxic Waste (T) in f f 261.31
and 261.32.
(c) Each hazardous waste listed in
this subpart is assigned an EPA Haz-
355

§ 261.31
ardous Waste Number which precedes
the name of the waste. This number
must be used in complying with the
notification requirements of Section
3010 of the Act and certain record -
keeping and reporting requirements
under Parts 262 through 265 and Part
270 of this chapter.
Title 40—Protection of Environment
(d) The following hazardous wastes
listed in f 261.31 or 1261.32 are subject
to the exclusion limits for acutely haz-
ardous wastes established in § 261.5:
(Reserved]
[45 FR 33119, May 19. 1980, as amended at
45 FR 74892. Nov. 12, 1980; 48 FR 14294,
Apr. 1. 1983]
6 261.31 Hazardous wastes from non-specific sources.
Industry and A hersrdous
wule No.
Hazardous Mate
Hazard
code
irenericRxn_
fat
Foos
F004
F005
Foos
Foos
F009..
FO10»........
F011
F012..
The following spent halogenated solvents used in degreasing teVachloroethylene.
trianloroethylene. methylene Maids. 1.1.1-tridnlorosthane. carbon tetrachloride.
and chlorinated fluorocarbons; and sledges from the recovery of these solvents an
degreasing operations.
The following sperd i-alo-mated solverdsi tstractaoroetnyien e. methylene chloride.
tricfhlorostlhy4ene. 1.1.1-trichlorosthane. chlorpbenzermi. 1.1.2-trk'lhlono.1.2.2-trills°
°ethane, ortiodchiorobenzene. and . and the still bottoms
from the recovery of these solvents.
The following spent non -halogenated solvents: nylene. acetone. ethyl acetate. ethyl
benzene. ethyl ether. methyl isobutyl ketone, n•butyl alcohol, cyclothehcsnone. and
methanol and the slid bottoms from the recovery of these solvents.
The following spent non -halogenated solvents: cresols and cresytic acid. and
nitrobenzene; and the still bottoms from the recovery of these solvents.
The following spent non -halogenated solvents: toluene. methyl ethyl ketone. carbon
disulfide. boobutanol, and pyridine; and the still bottoms from the recovery of these
solvent&
Wastewater treatment sldges from electroplating operations except from the
following processes: (1) sulfuric add anodizing of aluminum; (2) tin plating on
carbon stool; (3) zinc plating (segregated basis) on carbon steel; (4) aluminum or
zinc -al um mum plating on carbon steed (5) clearing/stripping associated with tin
zinc and aluminum plating on carbon steel; and (6) chemical etching and miffing of
Wastewater treatment sludges from the chemical conversion coating of aluminum
Spent cyanide plating bath sokrtions from electroplating operations (accept for
precious metals electroplating spent cyanide plating bath solutions).
Plating bath sledges from the bottom of plating baths from electroplating operations
where cyanides are used in the process (except for precious metals electroplating
plating bath sludges).
Spent stripping and cleaning bath solutions from electroplating operations where
cyanides are used in the process (except for precious metals electroplating spent
stripping and dewing bath solutions).
Ouencfhingg bath sludge from oil baths from metal heat treating operations where
cyanides are used in the process (except for precious metals heat -treating
quenching bath sludges).
Spent cyanide solutions from salt bath pot leaning from metal heat treating
operations (except for precious metals heat treating spent cyanide solutions from
salt bath pot cleaning).
Ouendhing wastewater treatment sludges from metal heat treating operations where
cyanides are used in the process (except for precious metals heat treating
auendhkg wastewater treatment sludges).
. irrehetilr it -inn *vireo !o, gartherucru.ess:km, heavy V[.A, thin U. w J" m
m
m
Jv-"
futoriL-a
[46 FR 4617, Jan. 16. 1981, as amended at 46 FR 27477, May 20, 1981; 49 FR 5312, Feb. 10,
1984]
EFFECTIVE DATE No At 49 FR 5312, Feb. 10, 1984, the waste stream identified by EPA
hazardous waste no. F024 was added to the table in t 261.31. effective August 10, 1984.
356

Chapter I —Environmental Protection Agency
§ 261.32 Hazardous wastes from specific sources.
§ 261.32
Indusby and EPA hazardous
waste No.
Hazardous waste
Wood preservation: K001
Inorganic ems:
K002
K003
K004
K005..N....N.NNN.NN....NN.....N.
K008...N.N.N.....N.N.N...N..N.....
Organic chemicals:
K009
K010 NNN.
K011NN.......NNNNN..NN.»NN.N.
K013
K014
K015
K018
K017
K018
K019
K020 NN..N.NNNN...N.N....NN.N..
K021
K022
K023
K024
K029
K095
u6
v1(03o NNNNN.
083
IS1o3 -- _ -
1�k(104 . ._
rfcoss
A05
Inorganic chemicals:
(4(071
4073
4 IAA
K031
K032
K033 --
K// -- 034
a1�C097 NN.
.N.NN..N.N.N...NNN.
K035 .NN.NN.N.NNNNNN.N.NNN..
K038N.NNN.....N.N..N....N.........
K037N.N.N.N..NNN.1I..NNN.....N.
K038 N.
Bottom sediment sludge from the treatment of wastewaters from wood preserving
processes that use creosote and/or pentachlorophenol.
Wastewater treatment sledge from the production of chrome yellow and orange
Wastewater treatment sludge from the production of molybdate orange pigments
Wastewater treatment sludge from the production of zinc yellow pigments.. ..... NN...N...N
Wastewater treatment sludge from the production of chrome green pigments
Wastewater treatment sludge from the production of chrome oxide green pests
(anhydrous and hydrated).
Wastewater treatment sludge from the production of iron blue pigments ...NNN.N...N..N
Oven residue from the production of chrome oxide green pis.
Distillation bottoms from the production of acetaldehyde from ethylene -------
Distillation side cuts from the production of acetaldehyde from ethylenheNNNNN.NNN.N..NN
Bottom stream from the wastewater stripper in the production of a aylonlaile..N..NNNNN.
Bottom stream from the acetonlbile column in the production of aaylonitrile.N.. N
Bottoms from the aoetunitrile purification column in the production of aaylonitrils NNNN
Shell bottom from the ctistillation of benzyl chloride..NNN.N....NNNNNN.NNN.NN.NN
Heavy ends or mitigation residues from the prodtction of carbon tetrachloride
Heavy ends (still bottoms) from the purification _sol mn in the production of
epichlorohydrkh. — .
Heavy ends from the fractionation column in ethyl chloride production-.NN_......NN..
Heavy ends from the distillation of ethylene dichloride in ethylene dichloride
production.
Heavy ends from the distillation of vinyl chloride in vinyl chloride monomer
ate. •
Aqueous spent antimony catalyst waste from fluoromethanes production NNN
Distillation bottom tarn from the production of phenol/acetone from cumene.N..N..N.»N.
Distillation tight ends from the production of phthaiic anhydride from naphthalene.__
Distillation bottoms from the production of phthelic anhydride from naphtlhelene
Distillation tight ends from the production of phthalic anhydride from onto-xylene.NNNN
Distillation bottoms from the production of phthafic anhydride from ortho-xytene N.NN.NN
Disti ietion bottoms from the production of nitrobenzene by the nitration of benzene.....
Stripping still tails from the production of meaty ethyl pyridines NNNNN.N.
Centrifuge and distitiation residues from toluene diisocyanate production...N.N...N.NN...NN
Spent catalyst from the hydrochlorkhator reactor in the production of 1,1,1-trichIor
oethane.
Waste from the product steam skipper in the production of 1,1,1-tdchioroethane. ..
Distillation bottoms from the production of 1,1,1-trichloroet haneNN.N....NNNNNN.N..NNNNN..
Heavy ends from the heavy ends column from the production of 1,1,1-trichloroeth-
ane.
Column bottoms or hesvy ends from the combined production of tricloroethyisne
and perchloroethylene.
Distillation bottoms from wane production NN. N..N...NN.
Process residues from amine extraction from the production of aniline
Combined wastewater streams generated from nitrobenzene/aniline production .
Distillation or fractionation column bottoms from the production of c lorobenzerhaNN.N
Separ t.d aqueous stream from the reactor product washlng step in the production
of ctlorobenzenes.
NNNNNN.
Brine puridc at$on muds from the mercury cell process in chlorine production, where
separately prspurtfied brkre is not used.
Chlorinated hydrocarbon waste from the purification step of the diaphragm oil
process using graphite anodes in dilation production.
Byproduct salts generated in the production of MSMA and cacodytc acid --
Wastewater treatment fudge from the production of chlordane
Wastewater and scrub water from the chlorination of cyclopentadiene In the
production of chlordane.
Fitter solids from the titration of hexachlorocyclopentediene In the production of
chlordane.
Vacuum stripper discharge from the chlordane chlorinator in the production of
chlordane.
Wastewater treatment sludges generated in the production of creosote ... ....N...N.NN.NNN
Still bottoms from toluene reclamation distillation In the production of disulfoton
Wastewater treatment sludges from the production of disutfotonNN...N.N
Wastewater from the washing and stripping of phorate production..N..N.N..N.N.NNNNN...NN
m
m
m
m
m
m
m
m
m
m
(R. T)
(R. T)
m
m
m
m
m
m
m
m
m
m
m
m
m
m
m
(R, T)
m
m
m
m
m
m
m
m
m
m
m
m
m
m
m
m
m
m
m
357

§ 261.33
Title 40—Protection of Environment
Industry and EPA hazardous
waste No.
Hazardous waste
Hazard
code
,A039 Filter cake from the filtration of diethylphosphorodithioic acid in the production of (T)
phorate.
-K040 wastewater treatment sludge from the production of phorate (T)
„K041 wastewater treatment sludge from the production of toxaphene ............ co
11(098 Untreated process wastewater from the production of toxaphene m
,,K042 Heavy ends or distillation residues from the distillation of tetrachlorobenzene in the (T)
production of 2.4.5-T.
A043 2.6-Dichlorophenol waste from the production of 2.4-D
K(099 Untreated wastewater from the production of 2.4-0
Explosives:
m
m
048...................................... Diseohred air notation (DAF) float from the petroleum refining industry............................. m
1�(( 49 "..... ............... Slop oil emulsion solids from the petroleum refiningbdustrY.............................................. co..... �':....»....................- Heat bonds from the petoeleumm retuning Y.--...�..��.... (T)
l 051».»................................. API separator skate from 9* petroleum refining industry
14062........
Secondary lead:
✓k069 ........................ Emission control dust/sludge from secondary lead smelting............................-...... (1)
•iu100waste leaching solution from acid leading of emission control dust/sludge from (T)
secondary lead smelting. •
m
1*052 ------- Tank bottoms (leaded) from the petroleum refining kidusby ... m
Iry and sleet •
061 Emission control dust/sludge from the prvnsiy production of steel in electric (T)
furnaces.
Spent pidde liquor from steel finishing operations -
(C.T)
�ninwy phsnmsoeuticals:M.•
jj((o64 ...................... wastewater treatment sludges generated during the production of veterinary pharma- m
ceuticals from arsenic or oCganoarsenic compounds.
0(1o1 ............................... Distillation tar residues from the distillation of -aniline-based compounds in the (T)
production of veterinary phwmaceuticais from arsenic or organ -arsenic corn-
.)
✓ (102............................»....... Residue from the use of activated carbon for decolorization in the production of (T)
veterinary phwmeceuticals from arsenic or organ arsenic compounds.
Yrnk formulation: K006 Solvent washes and sludges, caustic washes and sludges. or water washes and m
sludges from dealing tubs and equipment used in the formulation of ink from
pigments. driers, soaps, and stebiimea containing chromium end lead
,:onegO
-. Ammonia still line sludge from coifing operatiorus...................»...»..»....... .... m
Decanter tank tar sledge from coking operations..... (T)
[46 FR 4618, Jan. 16, 1981, as amended at 46 FR 27476-27477, May 20, 1981]
§ 261.33 Discarded commercial chemical
products, off -specification species, con-
tainer residues, and spill residues
thereof.
The following materials or items are
hazardous wastes if and when they are
discarded or intended to be discarded:
(a) Any. commercial chemical prod-
uct, or manufacturing chemical inter-
mediate having the generic name
listed in paragraph (e) or (f) of this
section.
(b) Any off -specification commercial
chemical product or manufacturing
chemical intermediate which, if it met
specifications, would have the generic
name listed in paragraph (e) or (f) of
this section.
(c) Any container or inner liner re-
moved from a container that has been
used to hold any commercial chemical
product or manufacturing chemical in-
termediate having the generic names
listed in paragraph (e) of this section,
or any container or inner liner re-
moved from a container that has been
used to hold any off -specification
chemical product and manufacturing
chemical intermediate which, if it met
specifications, would have the generic
name listed in paragraph (e) of this
section, unless the container is empty
as defined in § 261.7(b)(3) of this chap-
ter.
[Comment IInless the residue is being bene-
ficially used or reused, or legitimately recy-
358

Chapter 1—Environmental Protection Agency § 261.33
cled , or reclaimed; or being accumulated.
stored. transported or treated prior to such
use. re -use, recycling or reclamation, EPA
considers the residue to be intended for dis-
card, and thus a hazardous waste. An exam-
ple of a legitimate re -use of the residue
would be where the residue remains in the
container and the container is used to hold
the same commerical chemical product or
manufacturing chemical product or manu-
facturing chemical intermediate it previous-
ly held. An example of the discard of the
residue would be where the drum is sent to
a drum reconditioner who reconditions the
drum but discards the residue.]
(d) Any residue or contaminated soil,
water or other debris resulting from
the cleanup of a spill into or on any
land or water of any commercial
chemical product or manufacturing
chemical intermediate having the ge-
neric name listed in paragraph (e) or
(f) of this section, or any residue or
contaminated soil, water or other
debris resulting from the cleanup of a
spill, into or on any . land or water, of
any off -specification chemical product
and manufacturing chemical interme-
diate which, if it met specifications,
would have the generic name listed in •
paragraph (e) or (f) of this section.
[Gbmment• The phrase "commercial chemi- sPo12...».......»..
cal product or manufacturing chemical in----
termediate having the generic name listed 011••~~••~~••�
in . ." refers to a chemical substanceµ'
which is manufactured or formulated for54
commercial or manufacturing use which vPo13...»..»»»».
consists of the commercially pure grade of
the chemical, any technical grades of the vP077 .».»»
chemical that are produced or marketed, 40P028 ....»..
and all formulations in which the chemical 144:142•..•µ
is the sole active ingredient. It does not
refer to a material. such as a manufacturing.»»..».»
process waste. that contains any of the sub- 0o15......»
stances listed in paragraphs (e) or (f).
Where a manufacturing process waste is �p17»
deemed to be a hazardous waste because it
contains a substance listed in paragraphs (e) t102L ...._
or (f), such waste will be listed in either VP123».»..».»»»
t t 261.31 or 261.32 or will be identified as a `'t'1O3~~~••~••••~
hazardous waste by the characteristics set 4,022
~�.~•.~•».
forth in Subpart C of this part.]"'"'•""""'
(e) The commercial chemical prod-•~•~~~~~••
ucts, manufacturing chemical interme- 4..""»»•":
diates or off specification commercial .....»
chemical products or manufacturing 4-12027
chemical intermediates referred to in ...
paragraphs (a) through (d) of this sec-
tion, are identified as acute hazardous wastes (H) (H) and are subject to be the
(Comment For the convenience of the regu-
lated community the primary hazardous
properties of these materials have been indi-
cated by the letters T (Toxicity), and R (Re-
activity). Absence of a letter indicates that
the compound only is listed for acute toxici-
ty.]
These wastes and their correspond-
ing EPA Hazardous Waste Numbers
are:
Hazardous
waste No.
Substance
4-Poo2
small quantity exclusion defined in 44037~..».~....~,
1 261.5(e).
Acetaldehyde, chioro-
Acetamide, N-(aminothioxomethyf).
Acetarnide. 2-tluoro.
Acetic add, [arosodium salt
Acetimldic add. Nd(methylcsr-
bamoyf oxylthlo-, methyl ester
and salts. when presard at concentradons
''greater than 0.3%
1-Acetyf-2'-thiourea
Aaolein
Aidicarb
Alddn
Aayl alcohol
Aluminum phosphide
4-aAminopyrtdine
Ammonium vanadate
Arsenic add
Arsenic Oil) dodde
Arsenic (V) oxide
Arsenic pentoxide
Arsenic trioxide
Arsine. diethyl-
Aziridine
Barium cyanide
Benzenamine, 4-chloro-
Benzenamine. 4-nitro-
Benzene. (chloromethyl)-
1.2-f3enzenediol, 4-(1.hydnoxy-2.mettM-
amino)ethy 1-
Benzenethiol
eenzyl chloride
Beryllium dust
ether
Bromascetone
Brucine
Caldunni cyanide
Camphene. octachlo
Caibainiiiiidaseienoic
Carbon bisultide
Carbon disulfide
Chlorine taldehyde
p-Chloroeniiine 1
3-Chlonopropionitnile
Copper cyanides
c cyanide salts), not else-
where specified
Cyarogen chloride
Dichlorophenylarsine
Dielddn
Diethytarsine
359

§261.33
Hazardous
waste No.
Substance
4,P039 O,O.Oiethyl S•[2 (ethytthio)ethyl] phosphoro-
dith oate
✓{�Wtw».....»»Diethyi-p-nitrophenyl phosphate
t,P040 0.0-Diethyl O-pyrazinyl phosphorothioste
Diisopropyl tluoroptosphate
✓p044........w.wOimethoate
t,P045w.ww...w.»3,3.Oimethy1-1-(methylthio)-2-butanone. O-
((methylamino)csrbonyl] oxime
1413071 O,O.Dimethyl O-p•nitrrophenyl phosphoro-
thioate
1.P082 Dimethylnitrosamine
1P046.N.w......Nalpha, alpha-Dimethylphenethylamine
4,6 D n tro-o-cr sol and salts
4.
41048.» 2,4-Dina rophenol
400020».»w.» - Oiroseb
4085 Diphosphoramide, octamethyi-
41039.-- Oisultoton
0049 2,4-01t iobiuret
4.41100 Oithiopyrophosphoric add, tetraethyl ester
Endosuthn
Endothall
ww.».wMN
'P051w»_.. Endrin
li 042.wN»•N - Epinephrine
Et anamine, 1,1 •2-phenyl-
t42084»N......N»N Ethenamine, N-methyl-N-rritroso-
4.)/01N. Ethyl cyanide
' 54 Ethylenkmine
s P097 Famplwr
t,.P057........».»». Fluomaoetamide
t,P058»»».w»»... Fluoroaosdc add, sodium salt
..
4.P059ww.w.....N» Heptachlor
1,2.3,4,10,10-Hexadrloro-6,7-epoxy
1.4,4s,5,8,7 ,endo-
1.4:5.
vcr037 1,2,3,4,10,104Isxachlor0-6,7-opoxy
1.4,4a.5.6.7 ,eoo-
1.4:5,
1130601,2.3„4.10,10•Hexadrloro-1.4,40.8.8a-
hsxdydro-1.4 5,8-.ndo. endoddmeth- an-
thalen
14004 . 1.2,3 4 0,10-Heocachloro-1.4.4a.5.8.8a-
hsxshydro-1.4 5,8-endo,exo-
dimethanonaphthslene
$060......».»»». e000-
dimethanonaphthidene
t YVi..wN.wwNN. Hexasttyl tatraphosphate
*P116
010611 Hydradns. MOM*
Hydrocyanic add
14007 w». 3(2H)4soxszolone, 5-(si inomsthyt)-
G*092............»» Mercury. (aoetato-O)ph -
N.w.Nw
rir "P016..»w».»»». Methane. oxybis(chioro-
'P112..»»»..»..» Methane. (R)
ut51111 Methanethloi. trichloro-
"5059.»»»..»..... 4.7-Mslhano-1 H4indene. 1,4,5.0.7.8.8-hsp-
tachloro-3 .4.7.7a-tetrahydro-
POeB..... w Mettorfyl
.•..N.•........ 2-M t ytazirtdkre
'»»»...N.»w Methyl hydrazine
v11089 2•Msthyllactonttrile
.12071 Methyl parathion
72.NN..w
.Pb74w._....wNickel cyanide
Title 40—Protection of Environment
Hazardous
waste No.
Substance
4'P074 Nickel(Il) cyanide
+-P075 Nicotine and setts
4'076-Nilrl�eside
M077
p-Nitroaniline
lvru rs.,.vya.. vwr+cw+.r
PW7Bretir - v+cidO
41e84.mrsimmr-Nitrealyearine-fR)
' -'P082 N-Nitrosodimethytamine
'P084 N-Nittosomethylvirtylamine
t•P050 5-Norbomene-2,3.dimethanot, 1,4.5,8,7,7-hex-
adrloro. cyclic sulfite
1-P085 Octamethylpyrophosphommide
"P087...w.......wOsmium oxide
�P087.wN.....»Osmium tetroxide
,,P088 7-Oxabicydb[22.1 ]heptane-2,3-dicarboxylic
add
‘P089..w.w»...wParathion
.43034.....NwPhenol.2-cydohexyl-4.8-dinitr+o-
vP048....N.w.....» Phenol.2,4dinitro-
t.P047Nww,,...»Phenol. 2,4•dirritro•8-methyl-
aP020....N...»Phenol. 2,4-dnitro-8.(1 •methylpropyl}
P000....w.Mo
b
Pfiar�A. �,4.O�b �ibt, , �zrrra�arm ..11(R)
LP038w Phenyl didrloroarsine
NN.ww.
�1092NMw».NNwM Phenylmerauric acetate
t.P093.......NN-Phenytthiourea
t�P094.w........N.N Phonate
P090 Pheephine
s•P041.w.....wwN.. Phosphate acid. diethyl p nitrophenyi ester
Phosphorodithioic add. O,O.dimethyl S-(2-
(methylamino)-2-oxoethy ]ester
1-P043 PhosphoroMioric add bis(1-ine hylettM)-
ester
Phosphorothioic add. 0.0-diethyl S-
(ethytthb)methyl ester
Phoep honothiod add. O.0.diethyl O-(p-ntro-
estsn
VP040.. w. Ptosphorothioic add. O.O-diethyl 0- pyrazlnyl
eater
t•P097NNN.ww».» Phosphorot ioic acid. O,O-dknethyl O•[p•((d-
metf yla minc).sulionytphenyaester
Piunrbane, tetraethyl -
Potassium cyanide
4.12099 Potassium sinter cyanide
r.P070 Propanat. 2-methyl-2•(methytthio)'. O-
((methylamino)carbonyOmd me
''P101._N.» Pr+opsner k*,
4.P027.. Props nitrile.3-chloro'
Propanenitrile, 2-hydnoxy 2-m tl *
1,21.1
2-Propanone. 1•bronw.
'-P102........N....» Propangyl alcohol
✓P003.N.w....N2-Propenal
t�P005.»».w2•Propen-1 -0I
1.2-Propylsnmtns
VP102..............N 2•Propyn-l-ot
4•Pyridinamin e
-1.•P075.»w»»»ww. Pyridine. (8)(1-mettry1-2-pyrrolidinyt)-.
salts
'P089N»»» ..
t. 3111wNw.wN»...
i-P104.N.ww.w»w.
�P105....N..N......
v P108
1 P107
leP108
0018
i-P108
vP115
j.P109
Pyrophoephoric add. tetraethyl ester
Selenounaa
Sliver cyanide
cyanideSodium aside
Sodium
Strontium sulfide
8trycixn•10-one. and setts
Strychnidin-10 one. 2.3-dimetlaxy-
StryichNne and salts 1
Sulfuric add, thattium(I) salt
Tetraethyldithlopyrophosphate
360

Chapter I —Environmental Proton
Hazardous
waste No.
Substance
413014N.N»..»»».
K116.643026.
`P072. _
16.1°P093.N»NN».»»
`13123....».........
4P119....NN.N.....
VP120..»»..»»»»
✓P001
+43121
rP122......».»»».
Tetraethyl Ned
Totraethylpyrophosphate
T (R)
Tetrapasphoric add, hexaethyl ester
Theft oxide
ThaNiu m(t[q oxide
Thallium(I) selen•1
Thallium(i) sulfate
Thiofanox
Thloimkkxlicarbonic drrnide
Thiophenol
Thiosemicarbezkie
Thiourea, (2yI)-
Thiourea.1.rrspl slaM-
Toxsp ens
Trichloromethenethiol
Vansdic add. ammonium salt
Vsnsdl<un pentohdde
Vanadum(V) odds
Warfarin,, when present at concentrations
greater than 0.3%
Zinc cyanide
Zinc phosphide. when present at concentra-
tions greater than 10%
(f) The commercial chemical prod-
ucts, manufacturing chemical interme-
diates, or off -specification commercial
chemical products referred to in para-
graphs (a) through (d) of this section,
are identified as toxic wastes (T)
' unless otherwise designated and are
subject to the small quantity exclusion
defined in § 261.5 (a) and (f).
(Comment For the convenience of the regu-
lited community. the primary hazardous
properties of these materials have been indi-
cated by the letters T (Toxicity). R (Reac-
tivity), I (Ignitability) and C (Corrosivity).
Absence of a letter indicates that the com-
pound is only listed for toxicity.]
These wastes and their correspond-
ing EPA Hazardous Waste Numbers
are:
en
Hazardous
Waste No.
Substance
261.33
rU011
✓U012
r.11014 .........N
h'U015
rU010
641037....»..NNN.
''0190 »»»..N.N..
4-U028
l�U102
6.U107 ......
�t1070 .N.N.NNN»
.-0071...N..N»N»
r1072 N.
A1223 ...»..N.N.N
41239 ....N.......N
r i201
✓U127
4'U188...N»».N».
vt1105...».N.....»
.h110B..N..N.NNN
641203 ...NNN.NN.
•.1.1141...N .
�C1090.....N..N.N.
•► UtB9 ....N..NN.N
4- U183 ....
'- U185
▪ U020 .....N...NN
00207 N.N.
rU023 .»...N.......
Acetyl chloride (C.R.T)
Aaylamide
Acrylic add (I)
Acrylonitrils
Atanine. 3-(p`bis(2-chIcroethyt)am no]
per-. L.
Arnitnole
Aniline (I,T)
Arramhre
Azaserine
Asirino(2'.3'.3,4)py olo(1,2-s)lndole-4.7.dlone.
e{smino-8-[((aminocarbonyi) oxy)methya-
1.1a,2r3
methyl-.
Benz [ j ] aceanthrylens. 1.2-dihydro-3-methyl-
8snz(c]aaidine
3.4.Benzaaidine
Benz& chloride
Benz[a]antihracene
1,2-Benzanthracene
1.2-Benz anttracens. 7.12-dimethyl-
Bertasnanine (I.T)
Benmenamine, 4,4'.carboNmldoylbis(N.N.di-
mettwl- .
Benaenismhre. 4 chloro-2-methyl-
Benzenamine, N.N'
Benzenamine. 4,4'- methylenebis(2-chtoro-
Benzenamine. 2-methyl-, hydrochloride
Benzenamine, 2-methyl-6-nitro
Benzene (bT)
Benzeneacetic add, 4-chloro-alpha (4-chbro-
pheryl}dpha4ydroxy. ethyl ester
Benzene.1-bromo-4-phenoxy-
Benzene, chloro-
1.2 add anhydride
1.2 add. [bie(2.ethyb
heuyl eaten 1.2-Benzenedicarboxylic
add. dlbutyt ester
1.2 add. diethyl ester
1.2-Benzenedicarboxylic add, dimethyl ester
1.2 add di-n.octyl ester
Benzene. 1,2-dichloro-
Benzene, 1.3-dichlono-
Benzene, 1,4•dichloro-
Benzene. (didhtoromethhyl)-
Benzene. 1.3dieocyanatometthyl• (R.T)
Benzene, dmethyl-(I.T)
1.3.8enzenediol
Benzen% hexacthloro-
Benzene. hexahydro- p)
Benzene, hydroxy-
Benzene. methyl -
Benzene. 1-methhy1-1-2.4-dWtro-
Benzene. 1-methy1-2.8-dintro•
Benzene, 1.2
Benzene. 1.2
Benzene,1.2
Benzene, (1-mettylethyl)- m
Benzene. nitro- (I.T)
Benzene, pentachloro-
Benzene, pentachloro-nitro-
Benzenesulfonic add chloride (C,R)
Benzenesultonyl chloride (C.R)
Benzene. 1.2,4.6-tetrachloro-
Benzene. (trichlorormethyq.(C.R,T)
VU021
"U202
W120
600022
"1022
041107
Benzidine
1.2 , 1,1-dioxide
Benzo(j,k]nuorene
BenzoCelpyrene
3,4-Benzopyrene
p-Benzogtrinone
•
361

§ 261.33
Hazardous
Waste No.
Substance
0023
01050
Ooes
r 021
s-d073
"(J091
✓U095
v)024
vt1027
a'0244
�U028
00248
W225
W030
W128
V1172
✓U035
1U031
1.0169
8enzotrichloride (C,R,T)
1,2.8enzph.nanthr.ne
2,7-Biotdran• (1,T)
(1,1'.8ipheny f)-4,4'-diamine
(1,1'$iphenyl)-4,4'-diamine, 3,3' dichbro-
(1,1'-Biphenyl) 4,4' dlamine, 3,3'-dimethoxy
(1,1'-Bipheny ).4,4'-diamine, 3,3'-dimethyl-
Bis(2-chloroethoxy) methane
134(2-chlorotsopropyl) ether
Bia(dimethytthiocarbamoyl) disulfide
Bls(2-ethylhexyl) phthalate
Bromine cyanide
Bromotorm
4-Bromophenyi phenyl ether
1,3-Butadiene, 1,1,2,3,4,E
1-Butenamine, N-butyl-N-nitroso-
Butanoic acid, 4-(B13(2-chloroethyl)amino]
benzene-
1-Butanoi (1)
2-8utanone (1,T)
•
143053 _ 2-Butenal ~ _
/.11074 2-Butene, 1,4diicNoro- (1.T)
n-Butyl alchohol (I)
441138 Cacodylic acid
4.14032 ... Calcium chromate
Carbamic add, ethyl ester
4-U178Carbarnic add, methylnitroso-, ethyl ester
W 178 Carbamlde. Noso-
L.U177» ....»Carbamide, N-methyl-N-nitroso-
01219........_Carbamide, thio-
1.U097 ...._ ._Carbamoyl chloride, dimethyl-
4..U216....»Carbonic add, dithagium(I) salt
✓U156.. »..»Carbonochioridic add. methyl ester (1.1)
r4:1211....._.... Carbon tetrachloride
.... ». ....
✓U034
`t1035 _.........._.
.4.1036 ...........»..
1'0037
' .i039
441041
✓t1042
vt1048
..ati4a
,.H049
14:1032
4.0050
+.b051
.,H052
r'U052
W053
a1d055
✓U248
1.0197 .........»
ld'J056
1)1057 .........»
W 130.......»..»
'-U058
v U240
v U059
v U060
✓U061
yU142
VU062
c'0133
yt'1221
Chloral
CNorambucii
Chlordane, technical
Chiorriaphazine
Chionobenzene
4-Chloro-m esol
1-chioro-2,3-epoxypropane
2-c hioroethyt vinyl ether
Chloroform
Chloromethyt methyl ether
beta-Chioronaphthaiene
o-CNorophenol
4-Moro-o-toklldine, hydrochloride
Chromic add, calcium salt
Chrysene
Creosote
Cresols
Crssylic add
Crotonakiehyde
Cumene (1)
Cyanopen bromide
1,
Cydohaxane (1)
Cydohexanone (I)
1.3 tadl.ne, 12 3,4,5,5-h.xa- chloro-
CYdo-Fbsphemide
2,44-0, salts and esters
Daunomycin
DOD
DOT
Decachlorooctahydro-1,3,4-metheno-2H.
cyclobuta[c,d3-penta$en-2-one
Diallate
Diamine (R,T)
Diaminotoiuene
Title 40—Protection of Environment
Hazardous
Waste No.
Substance
s41083
.k1083
10084
.Jd084
�(1088
K1089
U062
Vd070
t41071
'0072
'-0073
vr1074
t..t1076
01192...._
U081
W078
,41079 .......
00025 ».......
v0082
kAJ240
'/U083
"U084
vt7085
v(1108
-00086 .._
v(1089 ...._..,
148
141090
vb093 _.
2094
095 »_.....»
Dibenz [ a , h ] a n thracen.
12:5,6-0ibenzanthracene
1,2:7,8-Dibenzopyrene
Dibenz(a,l]pyrene
12-Dibromo-3-chloropropane
Dibutyl phthalate
S-(2,3-Dichloroaly1) dli op opyithiocarbamate
o-0ichlorobenzene
m-Dichlorobenzene
p-Dichlorobenzene
3,3'-Dichlorobenzldine
1,4-Dichloro-2-but.ne (1,T)
Dichlorodifluoromethane
3,6-Dic hloro-N-(1,1-dimethyl-2-propyny()
benzamide
Dichloro diphenyl dichioroethane
Dic lord diphenyl trichioroethane
1,1-Dichloroethylene
12-Dichloroethylene
Dichloroethyl ether
2,4-Dichlorophenol
2.f3-DichloroPhen01
2, add, salts
eaters
1,2-Dichioropropane
1,3-Dichloropropene
1,2:3,4-Diepoxybutane (1,T)
1.4-Diethyfene dioxide
N,N-Oiethy hydrazine
0,0-01ethyl to
Diethyl phthalate
Diethylstilbestrol
1,2-Dihydro-3,6-pyradizined one
Dihydrosafroie
3,3'-Dimethoxyybenzidine
Dimethytamine (I)
Dimethyteurinoetzobenzene
7,12-Dimethytbenz [ a ] a n Urcacene
3,3'-Dimethytbenzidine
and
v(1117
1.4.425
'4184
rd`208
td209
M218
247
V0227
0043
Dimet ylcarbamoyf chloride
1,1-Dimethylhydrazine
1.2-Dimethylhydrazine
2,4-Dimethylphenot
Dirnethyl phthalate
Dimethyt sulfate
2,4-Dinitrotoiuene
2,6-Dlnitrotoluene
Di-n-octyl phthalate
1,4-Dioxane
1.2- Diphenythydrazine
Dipropylamir►e (I)
Di-N-propylnitrosamine
Ethanol (I)
Ethanamine, NCI-N-n(troso-
Ethane, 12-duxomo-
Ethane, 1,1-dichioro-
Ethane, 12-dicNoro-
1,2-E add
Ethane, 1,1,12,2,2-hsxacNoro-
Ethane, 1,1'-[n»thyienebis(oxy)3bls(2-chloro-
Ethan.nitrtle (1, T)
Ethane,1.1'-oxybts- (I)
Ethane. 1,1'-oxybis(2-thloro-
Ethane, pentac Moro -
Ethane, 1,1,12-tetrachloro-
Ethane, 1,1,22-tetrachloro-
Ethanethioarnide
Ethane, 1,1.1,-trichloro-22-bis(p-met oxy-
phenYl).
Ethane, 1,1,2-trichloro-
Ethane, chloro-
362

Chapter I —Environmental Protection Ag.ncy § 261.33
Hazerdorr
Waste No.
&tataeros
600042
613210 »»»»
141004
•t1608
611,12
1 113 N.».
• 1238»..
64:1138...»». —
t+tl'114
1.0087
t410n -
4'0117
✓0078
000118
•47119
613139
'U120N
441122 —
r11123 »»».
41/124»....
✓1J125
.411213 »»......
800124 ....
..U208
1128
▪ Win »»N.
k U127
"U128 ..•••••
.U129
..V130 »»»,».».»
w1OE) ••••••.
✓U134
4,14134 N.»..
4
j.U142NN....»•••••
It045
..1048
Ethane. 2-chloro thoxy-
Ethrne. 1.lddloro-
Ethane. trw-1,2-ddloro-
Ethane. 1.1.2.2-tetra chkrro-
Ethtanol, 2.2'-(1111usuM4rw)bis-
Ethanone. 1-pheryl-
Ettwroyl chloride (CAT)
Ethyl Ethyl acetate (I) a
Ethyl arbsmste (en)
Ethyl 4.4%dchiorobenzilate
Et ylan.ais(dith carbernic acid)
Etylene dbroelde
Ethylene dichloride
Ethiene oxide an
Ethylene thiourea
Ethyl ether (q
Et yrdene dichloride
EdrAmethecrylale
Ethyl melhanesullonale
Ferric *Wren
Fkroranthene
Fo n sklehyde
Formic add (C.T)
Furan (t)
2 m
2.5-Furandione
Furan. o-(1)
Ftrfural (1)
Fultran (I)
D-Gsluoopyrano.e, 2
.ourekb)-
Glycidytakiehyde
nttro-
Hexachkwobenzene
Hexachkxotrutadiene
Hexachlorocydohexene (gamma isomer)
Hexechlorowdopentacreene
Hexachioroethene
Hexadiorophene
Hexadloropropene
Hydrazine (R.T)
Hydrazine.
Hydrazine. 1.1 denetf yl-
Hydrazine.1.2drmetlyl-
1 Ndazine.1.2M-
Hydro1uoric add (C.T)
Hydrogen Woride (C.T)
Hydroxydmethyleraine oxide
2
ktdono(1.2.3-ccUpyrene
kon dextran
lsobutyl alcohol (LT)
bossfrole
Kamm)
Lasiocarpine
Lead acetate
Lead phosphate
Lead subacetste
Undone
Metric arlydtide
Metric hydrazide
Malononitrie
Melphalan
Mercury
Methacrylonttriio
Methanantirte. N-methyl- (l)
Methane. chloro- (1.1)
Methane. c loromethoxt►-
Hazaroaus
Waste No.
Substance
I-0088
SA/080
4-11075
" G138
1,1J119
w211
1ii1121
0(J153
•1J225
✓ J154.»».»N.....
.1U155...,..».»..»
0U247
41154
1011188 »,».»N».,.
✓U045 N»
1,41158
0.°11157 WON.*
✓1J132 »»»N».N»
rt1122.....—..-
841159 »»..
Methane. dibromo-
Methane. dic loro-
Methane. dichlorodiMroro-
Methane. lodo-
Methanesulhonic add. ethyl ester
Methane. tetrachloro-
Methane. trichlorotluoro-
Methanethiol (l.T)
Methane. tribrnmo-
Methane. trichloro-
Methtene, trichlorofkroro-
Methanoic add (C.T)
4.7-Methano ndan. 1.2.4.5.8.7.8.8-octa-
chloro-3a.4.7.7a-tetrshydro-
Methanol (1)
Methepyrilene
Meffroxychdot
Methyl alcohol 0)
1-Methybufadien. (1)
Methyl chloride (LT)
Methyl dlorocarbonate (LT)
Iiethyrd lorotorm
4.4'-Methylenebis(2-chloroaniline)
2x-Methylenebls(3.4.8-trich lorophenol)
Methylene bromide
Methylene chloride
Methylene oxide
Methyl ethyl ketone (1.7)
4.0138 »»»N,»..,:
ret1161 N»
✓ J162NN»
✓ 1163_
101/161....N»NN.,.
t.t1184 .......»..»»
,,J01o.....N»....»
W185
60168 »»N---
.•t1236 N N»
' 0168..».
W168,
t.t1167 N.
40189 ,»NN».»N.
11172.N»N»..»»
1d1114...»..».N...
178
177
Jd178
"O179
44f180
,,Jd181
L.t7193
.411115
Methyl iodide
Methyl isobutyl ketone 0)
Methyl -Methyl-N� Vitro saltine
4-Methyl.2 pentanone (l)
Methytthlouadl
Mitornycin C
5.12-Naphthacenedione. (8Sds)-8-ecety1-10-
[(3-arnino-2.3.8-trideoxy-alpha-L-hyxo-
hexopy anosyt)oxylj-7.8.9.10•tetrahydro-
8.8.11-trihydroxy-1-methoxy-
Naphthalene
Naphthalene. 2.chloro-
1.
2.7-Naphthaienedisufonic add, 3.3'-[(3.3'-dr
methyl-(1.1'-biphenyl)-4.4'diy1)]-b s
(azo)bis(5-amino•4-hydroxy)-.tetrasodium
salt
1.4.Naphthaquinone
1-NaphthylsmU e
2-Naphthytsmins
alpha-Naphthylamine
beta-Naphthytamtne
2-Nephthylamine. N.N'-bb(2-chloromethyt)-
N trobenzene (1.7)
p-NItrophenol
2-Nlitropropsne (t)
N-Nitroso-N-ethykrea
N-Nitroso-N-methylurea
N-Nitroso-N-methyl rethane
N Nitrosopiperidine
N-Ni rosopyrroiidine
1.2 Oxathiolane. 2.2-dioxide
2H-1.3.2-Oxazephosphorine, 2-[bis(2-c lorol-
ethy9arnino tetrahydro-. oxide 2-
Oxkane (1.7)
363

• •
§ 261.33
Haunaous
Waste No.
Substance
141041
u1d182
IJ183
1.0184
441165
dd242
100188
i.'0187
4.4.1188 ».
41081
✓(J1O1....
•1170 N....N.....w
VU242._N.w
✓i1212...w.»N»
00231 .......
v0137.N».w.....w
'0145 --
41087 ww.N.NN.w
K1007 N..NN.N.».
0084 _NNN.
401,1243...w».NwN.
stow •N.NNN.NN
,M008...N..... —
0t1113 NNw...
vU182.......N.N.N
i'0233.Nw.....: .
AKh 94 ...w..N».».
vU198 NNw....
,t1155
1,1179 .......»»»
▪ U191.N......NwN
KJ184
80
v0200
• 201 N.......
N
"U202
d204
205
MT233
1C1089
iR3206
°sirens. 24ch loromethyl)-
Paraldehyde
Pentschlorobenzene
Pentachlomethane
Pentachloronitrobenzene
Pentachlorophenol
1.3•Pentadiene (I)
Phenaostin
Phenol
Phenol, 2-chloro-
Phenol. 44;hloro-3 meth yl-
Phenol. 2.4-dichloro-
Phenol, 2.84lichrloro-
Phenol, 2.4.dirnsthyl-
Phenol, 4-nitro-
Phenol. pentadMoro-
Phenol. 2.3.4.8-tetradrloro-
Phenol, 2,4.5-triclrioro-
Pherol. 2.4,8 trichioro-
1.10-(1,2.pherylene)pyrene
Phosphoric add. Dead se
Phosphorodithioic add, 0.0-diethyl-. S-methY-
fester
Phosphorous sulfide (R)
Phthalic anhydride
Prorrornicie
1-Propanamine (I,T)
1-Propanamine, N-pr'opyl- (I)
Propene,1,241ibromo.3 o-
Propanedinitriie
Propane, 2-nitro- (1)
Propane, 2xoxybis(2-chIoro-
1,3-Propane sultan°
1-Propanol, 2.3-dibromo-. phosphate (3:1)
1-Prropanol. 2-methyl- (1.T)
2-Propenamide
Propene,1.3-dichi_ra
1-Propene, 1.1.2.3.3.3-lucachloro-
2-Propenenitrile
2-Propeneniblie, 2-methyl- (1,T)
2-Propenoic add m
2-Properwic add. ethyl ester (1)
2-Propenoic acid, 2-methyl-. ethyl ester
2-Propenoic acid, 2-methyl-, methyl ester (LT)
Propionic acid, 242,4,5-tridNorophenoxy)
n-Propylamlne (I.T)
Propylene dichloride
PYritrthe
Pyridine. 2-E (24dimethylamirw)-2-thenyla-
rNnol-
Pyridne, 2-methyl-
4(1 H)•Pyrimidlnono, 2-
thioxo-
tetratrydno-N-nitnoso-
Reserpine
Resorcinol
Saccharin and salts
Safrole
Selenious acid
Selenium dioxide
Selenium disuttide (R.T)
!.-Sarin, diazoacetate (ester)
SlIvex
4.4'-Stlbenediol. alpha.stpha'-dlethyl-
Streptozotodn
Title 44—Protection of Environment
Hazardous
Waste No.
substance
rt1205
" 232
40207
K1208
`0209
' 6210
10212
' 1213
' 1214
4215
K1218
" [1217
v(1218
1I1153
'0219 »....w.....N
80244
841220
80221
GIU223
1U011 .►..
80228 N..N.......;.
i.U227
W228
14228 .........N
K1121.........N
U230
141231
VG232
''G182 ...N.....N...
60235
41236
r0237
#6237 N.
•'0248
K1239
#1,200
Sulfur selenide (R,T)
2,4,5-T
1,2,4.5-Tetrachiorobonzene
1.1,1,2-Tetradhloroethane
1.1.2.2-Tetrachloroethsne
TetradtibroethyNne
2,3,4,8-Tetrachlorophenol
Tetrahydrofuren (I)
Thattium(I) acetate
Thallium(I) carbonate
Th Nium(1) chloride
Thalum(I) nitrate
Thioacetamide
Thiomethanol (LT)
Thiourea
Th iram
Toluene
Toluenediamine
Toluene dilsocyenate (R.T)
O-Toluidine hydrochloride
1 H-1,2,4-Trlazol-3-smins
1.1.1 Trichloroethane
1;1,2Trichloroethane
Trichbroethone
Trictrloroethylene
Trichlorornonofiuorometharie
2.4.5-Tricf rtorophenol
2.4.8-Trfchlorophenol
2.4.5-Tridilorophenoxyacetic acid
1.3.5-Trioxane.2.4.5-tri<nalhyi- -
Trls(2.3.dibromopropyl) phosphate
Trypan blue
Uracil, 5(bis(2-chlorOmethy1)amino3-
Uracil mustard
Vinyl chloride
Warfarin. when present at concentrations of
0.3% or lass
Xylene (1)
Yohimban-18oarboxylic add. 11.17-dlmethmethyl ester
-
12011.01. 2111:0 Lie Se
[45 FR 78529, 78541, Nov. 25, 1980, as •
amended at 46 FR 27477, May 20, 1981; 49
FR 19923, May 10,19843
Em crzvE DATE Nara: At 49 FR 19923.
May 10, 1984, 261.33 was amended by re-
vising three entries in the table in para-
graph (e), and adding three entries to the
table in paragraph (f) identified by hazard-
ous waste numbers U248, (3-(alpha-Aceton-
ylbenzy1)-4•hydroxycoumarin and salts,
when present at concentrations of 0.3% or
less, and Warfarin, when present at concen-
trations of 0.3% or less), and U249, (Zinc
phosphide, when present at concentrations
of 10% or less), effective November 12. 1984.
For the convenience of the user, the super-
seded entries from the table in paragraph
(e) are set out below.
103
189
Sulfuric add, dimethy l ester
Sulfur phosphide (R)
364

ti
Biological treatment of hazardous waste in
sequencing batch reactors
Philip A. Herzbrun, Robert L. Irvine, Kenneth C. Malinowski
The sequencing batch reactor (SBR) is one of several inno-
vative and alternative biological waste treatment systems that
have been evaluated by the U. S. Environmental Protection
Agency (U. S. EPA)' and the Office of Technology Assessment.'
Irvine and Busch described SBR operation in 1979.3 Since that
time, a U. S. EPA demonstration study has shown that the SBR
is an excellent alternative to conventional activated sludge treat-
ment for municipal wastewater.' Recently, results from bench -
scale studies indicated that the SBR can provide substantial sav-
ings in energy and costs by removing organic compounds found
in hazardous waste biologically, rather than with activated car-
bon.s•6 Based on these findings, the New York State Energy Re-
search and Development Authority (NYSERDA) and CECOS
International agreed to co -fund a full-scale SBR study that would
demonstrate similar cost and energy savings for biological treat-
ment of hazardous wastes at CECOS. Preliminary findings from
early bench -scale studies, which were used to design the SBR
for the CECOS facility, were discussed by Herzbrun et al.' This
paper presents additional results from the CECOS bench -scale
study and summarizes performance for the first month of full-
scale operation.
BACKGROUND -
While a reasonably complete description of the treatment fa-
cility at CECOS was presented by Herzbrun et al.,7 an overview
of the CECOS operation is summarized below for convenience.
CECOS International operates a 14.9 km2 site in Niagara Falls,
New York —one of only two fully permitted treatment, storage,
and disposal facilities in New York. CECOS currently manages
several operations, including a secure chemical management fa-
cility, a secure sludge management facility, a sanitary landfill, a
fuels blending program, and a multi -faceted wastewater treat-
ment facility.
The treatment plant typically receives 9 500 to 11 300 m3 of
wastewater each month. Approximately 50% of this is leachate
pumped from both active and inactive landfills on the CECOS
site; approximately 30% is pumped as part of a remedial
groundwater program from an unrelated facility bordering the
CECOS site; and the remaining 20% is received in bulk or drums
from various industries in a 640-km radius. The treatment plant
uses a two-phase operation: -Phase 1 is dedicated to oxidation-
reduction reactions, acid neutralization, heavy metals precipi-
- tation, and dewatering; Phase 2 is dedicated to pH adjustment,
biological degradation, carbon adsorption, and batch discharge.
Effluent limitations for the total plant are summarized in
Table 1.
The primary purpose of Phase 2 operation is to remove organic
carbon by adsorption on activated carbon: -Because of the. high
costs associated with . the regeneration of activated carbon,
CECOS decided to study alternative methods of organic carbon •
removal; biological removal in the SBR was selected as the most
cost-efficient alternative. • - .:
A plant design that uses SBR rather than carbon
adsorption for organics removal relied heavily on
thorough bench -scale testing of the concept.'
The SBR is a periodically .operated, fill -and -draw reactor.1.3-4
Each reactor in a SBR system has five discrete. periods in each
cycle: fill, react, settle, draw, and idle. Reactions imitated during
• fill (the time during which raw wastewater enters the tank) are ' •-•
completed during react. After react, the mixed liquor suspended
solids (MLSS) are allowed to separate by sedimentation during
settle in a defined time period; the treated effluent is withdrawn
during draw. The time period between the end of draw and the
beginning of new fill is termed idle. Because of the large storage
tanks available at the CECOS site, all of the bench -scale studies
to be described were conducted in a single -tank SBR system.
In the first phase of bench -scale testing four 10-L SBRs were
operated at different hydraulic detention times for 8 weeks. All
four reactors were operated at room temperature with reactor
temperatures from 24 to26°C. Table 2 shows the operating
strategies used for each of these reactors. Feed was obtained
from the pH adjustment tank. Results from these studies,' in-- -•
dicated that total organic carbon (TOC) and phenol effluent •
• limitations of 1000 g/m3 and 2.4 g/m3 (based on an expected
average flow rate of 300 m3/d) would be satisfied easily, provided =
• the SBR detention time was maintained between 2.5 and 10
days. (Note that the 1.25-day detention time reactor yielded poor _
These initial studies were the basis fora rather extensive bench -
scale study that continued through the construction periods and
first month in which the full-scale SBR was operated. Three of
these studies —a cold weather simulation, a phenol augmentation
experiment, and an energy conservation strategy —will be de-
scribed.
BENCH -SCALE STUDIES The following results were obtained from SBRs that were op-
erated and monitored for 1 year. Each reactor was a 10-L poly
carbonate container, drilled and ported to allow gravity discharge
• December 1985
1163-

Herzbrun et al.
Table 1—Effluent limitations.
Total organic carbon •
Total halogenated organics
Volatile halogenated priority pollutants
Chemical oxygen demand
Phenol
Total suspended solids
Organic phosphorus
pH
1000 g/m3
0.1 g/m3
1.0 g/m3 each
1040 kg/d
0.8 kg/d
990 kg/d
1.6 kg/d
5.5-9.0
of preset volumes through automatic solenoids. Air was supplied
by an air compressor and controlled through automatic sole-
noids. Additional mixing was provided by magnetic stirrers. Feed
was supplied to the reactors through peristaltic pumps and ad-
justed for appropriate volumes depending on the particular
treatment strategy used. All pumping, aeration, agitation, and
discharge functions were sequenced automatically with labora-
tory timers. Both 5-day and 9-day detention time systems were
studied in detail because expected flow variations to any full-
scale SBR would likely cause the detention time to vary within
these limits. •
Cold weather simulation. To determine the viability of full-
scale SBR operation during extended winter periods, a bench -
scale reactor was modified to operate below room temperature.
An insulated cooling jacket was constructed to circulate refrig-
erated anti -freeze. This reactor, designated Reactor 5, operated
for 8 months, while a control reactor, designated Reactor 6,
operated concurrently at room temperature. Both reactors re-
ceived identical feed. Monthly average reactor temperatures and
detention times are shown in Table 3. The operating strategies
used for the 5-day and 9-day detention time periods are defined
in Table 2 as Strategy B and Strategy A, respectively (except the
maximum liquid volume was 9 L instead of 10 L). The influent
and effluent total organic carbon (TOC) concentrations from
both reactors are shown in Figure 1.
These results as illustrated in Figure 1 show clearly that the
TOC degradation in Reactor 6, operating between 21 and 25°C,
was superior to that obtained from Reactor 5. The disparity in
degradation was most obvious from March to May 1984, when
Reactor 5 operated between 5 and 6°C. It should be noted that
in no case did the average TOC exceed the 1000 g/m3 discharge
limit. Phenol limits, except as noted during special studies, were
also met throughout the cold weather temperature simulations.
Table 2—Reactor operating strategies.
Strategy
A B C
Detention. time, days - -
Maxiriium reactor liquid volurne, L
Feed volume/cycle, L
Cycles per day
Total volume fed per day, L
Time for
Fill, hours
React, hours
Settle, hours
Draw/idle, hours
Total cycle time, hours
10 5 2.5
10 . 10 .10
1 2 -. 2
1 2
1.25
10
4
2
2 4 • 8
10 10 5
<10 10 5
2 -
: 2 _ 1 -
2 1 ,.
12
5
5
1
1
12
Table 3—Average monthly temperatures and detention
times.
Month
October 1983
November 1983
December 1983
January 1984
February 1984
March 1984
April 1984
May 1984
- Temperature (°C)
Detention time - -
(days) - Reactor 5 Reactor 6
5
9
9
9
9
9
5 -
• 5
17 25
11 25
10 24
9 25
9 23
6 .• .- 21
5'- -24
6 ' '23
While not reflected in this data, the rate of temperature de-
crease affected organic removal appreciably. In particular, as the
temperature approached 12 to 15°C the degradation rate reduced
noticeably, necessitating that the system be held at a slightly
elevated temperature until the organism distribution adjusted
to the new temperature. After such acclimation (this sometimes
required up to 2 weeks), active degradation proceeded until the
next temperature plateau was reached.
Phenol augmentation experiments. A 9=week phenol augmen-
tation study was conducted between January and March 1984.
During this time, influent streams to Reactor 5 (the cold tem-
perature reactor) and Reactor 6 (the room temperature control)
were spiked daily with increasing amounts of phenol. The results
of this work are shown in Figure 2.
Influent phenol remained at raw wastewater'concentrations
for Weeks 1 through 3. After that time, increasing amounts were
added to each reactor until 570 g/m3 phenol was reached at
Week 9. Reactor 5, which operated from 5 to 9°C during the
first 8 weeks, had two major phenol breakthroughs; thesfirst was
during Week 4 when the phenol averaged at 55 g/m3, and the
second occurred in Week 8 when the effluent averaged 63 g/m3.
During this period, Reactor 6 operated with identical influent
volumes and composition. For comparison purposes, the op-
erating temperature was between 23 and 25°C; no effluent sam-
ples exceeded 0.4 g/m3 phenol. During Week 9 the effluent phe-
MONTHLY AVERAGES OF INFLUENT TOC VS. EFFLUENT TOC
1800
1600
1400
1200
E 1000
°, ..
0 800
600
400
200
0
♦ loam/4
• Effluent Ream eS
• Mont Reactor e6
Oet.'83 Nov'83 Dm.'83 Jan.'84 Feb.'84 Mac184 Apr.'84 May'84
Month l
Figure I —Monthly averages of influent and effluent TOC.
Journal W_PCF,_Yolume 5_7.,Number 12..

n-
4.
)1)
Its
ns
re
at
he
as
he
13.
nt
1-
n-
Le-
Process Design
WEEKLY AVERAGES OF INFLUENT PHENOL VS. EFFLUENT
PHENOL: REACTOR#5
600 —
500 —
400—
tA
✓ 300—
a.
200-
100-
0
• Phenol Added
No Additional
Spiked With
Additional Phenol
1 2 3 4 5
Week Number
Figure 2—Weekly averages of influent and effluent phenol, Reactor 5.
nol from the cold temperature system declined rapidly to 1.3
g/m3 when Reactor 5 was warmed to 26°C.
Energy conservation strategy. Energy can be conserved in the
SBR quite simply by allowing portions of the fill period to pro-
ceed without aeration but with mixing, or without aeration or
mixing. Either action would reduce the rate of degradation of
the organics during fill, and shift the distribution of organisms
present (and, of course, the reactions taking place) in the mixed
liquor. A reduction in reaction rate at this time could be tolerated,
provided the system detention time was sufficiently large to allow
the required reactions to go to completion during the remaining
portions of the cycle. Previous studies by Herzbrun et al.7 had
showed marked reduction in TOC removal at a 1.25-day deten-
tion time. Consequently, any energy saving policy implemented
during periods in which the proposed full-scale SBR would op-
erate at the shorter detention times (for example, 5 days) might
result in reduced removals of both TOC and phenol. With these
factors in mind, Reactor 9 operated for 2 weeks with the first 2
hours of fill unaerated but stirred, followed by 2 additional weeks
in which the first 4 hours of fill period operation was unaerated
and stirred. Finally, the reactor operated for 9 weeks with the
Table 4—Performance data.
Detention time, days
Influent TOC, g/m3
Effluent TOC, g/m3
TOC degraded
Effluent phenol, Wm
MLSS, g/m3 -
MLVSS, g/m3
Effluent SS, g/m3
SVI, mL/g
Reactor 6 -
5
1620
340
79%
0.4
-3760
3240
150
50
Reactor 9
5.5
1620
400
75%
0.4
3620
3020 -
160
60
.3 Influent
(Weekly Average Effluent
Phenol For Reactor a6
5. 0.4 g/m')
Effluent
first 6 hours of fill unaerated and stirred for the first 51 days and
unaerated and unstirred for the last 12 days.
A comparison of Reactor 9 and control Reactor 6, both of
which operated between 23 and 25°C and received identical
influent composition and nearly identical detention times, is
shown in Table 4. Results for TOC, .phenol, MLSS, mixed liquor
volatile suspended solids (MLVSS), effluent suspended solids
(SS), and sludge volume index"(SVI) are expressed as the average
of weekly averages.
Performance in Reactor 9 was almost identical to the control
with respect to TOC degradation, phenol degradation, SVI, and
effluent suspended solids. Although TOC degradation was slightly
better in the control, it must be noted that the 6 hours of anoxic
feed represents an approximate 30% overall energy savings. One
potential problem with anoxic feed is an elevated odor that could
make anoxic conditions in the full-scale impractical.
PHENOL VS. TIME: REACTOR #9
10 12 14
Time (hours)
• Figure 3—Phenol versus time, Reactor 9.
•
JI
December .1985 :
- i165

Herzbrun et al.
Table 5—Spiked oxygen uptake studies: anoxic and
control reactors.
Phenol
added
SBR (mg)
Change in
phenol
(g/m3)
Unit
Oxygen oxygen
uptake uptake
(g/m3 • h) (g/kg • h)
Reactor 6
Reactor 6
Reactor 6
Reactor 9
Reactor 9
Reactor 9
0
49
4.6
0
49
4.9
360
360
0 12.8
11.1
36 24.0
0 24.0
49.2
36 136.0
3.8
3.3
7.1
7.5
15.4
42.5
Phenol degradation was also studied during the anoxic feed
period. Figure 3 plots phenol concentration versus time for the
6-hour, unaerated, stirred fill period in Reactor 9. The phenol
build-up in this reactor during the 6-hour unaerated period was
very close to calculated theoretical levels (if no biodegradation
was assumed). Before aeration, less than 1% of the phenol had
been degraded. Two hours after the aeration began, at the 8-
hour mark, 28% of the available phenol had been degraded. By
the end of the treatment cycle, well over 99% of the phenol had
been degraded and the effluent concentration had decreased to
0.4 g/m3. By comparison, the phenol concentration in the con-
tinuously aerated control reactor receiving identical feed was
0.4 g/m3 at the 8-hour mark.
TOC removal data show similar results. Before aeration in
Reactor 9, approximately 20% of the TOC added was degraded;
80% of the degradable TOC was used 2 hours after aeration
began. Control Reactor 6 maintained a virtually constant TOC
concentration before feed, 8 hours into the feed period, and
after the treatment cycle.
Oxygen uptake rate data were obtained for Reactors 6 and 9
to determine how the different operating strategies affect the
ability of the organisms to degrade phenol. At the end of the
react period, 135 mL of mixed liquor was removed from each
reactor, spiked with different amounts of a phenol solution, and
Phase 1 Water
Phase 2 Water
Leachate
L-5
1.140m3
L-6 L-7
1,140m3 1,140m3
HCI
Storage
Tank
L-8
170m3
sealed from the -atmosphere with a dissolved oxygen probe
(Table 5).
Unit oxygen uptake rates confirmed that the anoxic Reactor
9, in which the bacterial population was acclimated, hada high
tolerance, to high phenol concentrations before aeration, was
much more adapted to using phenol as a food source. Thus, the
control Reactor 6 experienced either a minor increase or slight
decrease in unit oxygen uptake when phenol was added.
FULL-SCALE DEMONSTRATION FACILITY -
Results from the bench -scale studies were used to design a
full-scale demonstration facility. Construction began in Decem-
ber 1983. The existing treatment facility was modified for Phase -
2 operation (Figure 4). On June 6, 1984, the full-scale SBR,
roughly a 1900-m3 reactor, was put on-line. The SBR was situated
in the Phase 2 operation between the storage, equalization, and .-
neutralization basins (Tanks L-5, L-6, *L-7, and L-8) and the
activated carbon columns. Major changes to Phase 2 operation
included: construction of an insulated, covered SBR, rerouting
of wastewater from Tank L-6 to Tank L-8 for pH adjustment
with hydrochloric acid; storage of this water in Tank L-7 for
final treatment in the SBR; and use of Tank L-12 for any ad-
ditional necessary sedimentation and for use as a feed tank to
the activated carbon system.
Preliminary results from the full-scale system are presented
in Table 6. Because the first week primarily involved start-up
and stabilization, the only results for Weeks 2 through 5 are
reported in this table. All data are reported as the average of
weekly averages. The data for phenol, TOC, effluent suspended
solids (SS), and sludge volume index (SVI) all indicate acceptable
treatment as anticipated from the bench -scale reactors. In ad-
dition, TOC degradation decreased from 86% in Week 2 to 72%
in Week 5. Such results were expected; because lab reactors typ-
ically required 4 to 8 weeks for treatment to stabilize fully.
Flow through the SBR averaged 220 m3/d, giving an 8- to 9-
day detention time, and representing approximately 90% of the
wastewater processed at the Niagara Falls site. As anticipated,
there was significantly less reliance on activated carbon to remove
contaminants of concern during this period.
L-12
1,440m3
Sand
Filters Carbon Adsorber
NFWTP
Discharge
L-11
- 1.140m3
Figure 4—Phase 2 wastewater treatment system modified to include the SBR.
1166 _ _ Journal WPCF, Volume 57, Number 12.

the
for
igh
'as
.he
iht
a
m-
ase
IR,
ted
nd
the
:on
ing
!nt
for
to
Process Design
Table 6—Full-scale performance data.
Influent TOC, g/m3
Effluent TOC, g/m3
TOC degraded
Influent Phenol, g/m3
Effluent Phenol, g/m3
Phenol degraded
MLSS, g/m3
MLVSS, g/m3
Effluent SS, g/m3
SV1, mL/g
1100
260
76%
39.6
0.4
99.0%
1100
930
80
60
CONCLUSIONS
- . the use of carbon for polishing purposes, 'a significant cost and
energy savings is anticipated. .
• Nine bench -scale SBR reactors have been operated during
the past year. Detention times of 1.25 to 10 days were investi-
gated, with acceptable results for all anticipated full-scale flows.
• One of these SBRs operated for 8 months at temperatures
as low as 3°C to simulate winter operations. Results for this
reactor were not as favorable as an identical control reactor op-
erated simultaneously between 21 and 25°C, but discharge lim-
itations for TOC and phenol removal were maintained provided
the rate of temperature decrease was controlled.
• One reactor was operated with up to 6 hours of stirred, and
unstirred, unaerated feed with very favorable results. Such en-
ergy -saving operational strategies for use in the full-scale reactor
are under consideration.
• Construction of a 1900 m3 SBR was completed in May
1984, and operation began 1 month later. TOC degradation
averaged 76% and phenol degradation averaged 99.0% during
the first month of operation. All other data indicated proper
performance.
• The role of organic contaminant removal has shifted from
adsorption on activated carbon to degradation in the SBR. With
- - •
ACKNOWLEDGMENTS
- Credits. This study was supported in part by the New York
State Energy Research and Development Authority, Contract
number 601-CON-IC-84. The process equipment and tanks were
. supplied and installed by Jet -Technology inc., Industrial Airport,
Kansas. The full-scale process design and pilot and full-scale
studies were supervised. by SBR Technologies, Inc., Mishawaka,
- Indiana.
- Authors. Philip A. Herzbrun is a laboratory manager with
• CECOS International; Robert L. Irvine is a professor of civil
. engineering at the University of Notre Dame; and Kenneth C.
Malinowslci is vice-president of research development with
CECOS International. Correspondence should be addressed to
Dr. Irvine, Dept. of Civ. Eng., Univ. of Notre Dame„ Notre
Dame, IN 46556.
- -
REFERENCES
• - 1. Irvine, R. L., "Project Sun -unary. Technology Assessment of Se-
quencing Batch Reactors." EPA/600/S2-85/007, U. S. EPA, (1985).
2. U. S. Congress, Office of Technology Assessment, "Superfund Strat-
egy." OTA-ITE-252, Washington, D. C., 211 (April 1985). •
3. Irvine, R. L., and Busch, A. W., "Sequencing batch reactors —an
overview." J. Water Pollut. Control Fed., 51, 235 (1979). •
4. Irvine, R. L., et aL, "Municipal application of sequencing batch
treatment at Culver, Indiana." J. Water Pollut. Control Fed., 55, • •
484 (1983).
5. Irvine, R. L., et aL, "Enhanced Biological Treatment of Leachates
• -from Industrial Landfills." Hazardous Waste, 1, 123 (1984).
6. Sojka, S. A., et aL, "Impact of Genetic Engineering in Pollution
Control: Enhanced Biological Destruction'of Environmental Xe- .
nobiotics." In "Biotechnology Applied to Environmental Problems."
D. L. Wise (Ed.), CRC Press, Inc. (in press). • •
7. Herzbrun, P. A., et aL, "Treatment of Hazardous Wastes in a Se-
quencing Batch Reactor." In "Biotechnology Applied to Environ-
mental Problems." D. L. Wise (Ed.), CRC Press, Inc. (in press).

MEMORANDUM
TO: Bill Mills
Water Quality Section
FROM:
SUBJECT:
DIVISION OF ENVIRONMENTAL MANAGEMENT
September 30, 1985
M. J. Noland, Regional Supervisor
Fayetteville Regional Office
Proposed Hazardous Waste Treatment Facility
GSX Corporation
Laurinburg-Maxton Airport Commission
U. S. Hwy 74, Scotland County
144,Q
RECEIVED
LJT
0 1 1985
iry SECTION
GSX Corporation is proposing to build a hazardous waste treatment facility
in the Laurinburg-Maxton Airport Commission industrial park in Scotland County.
This facility would treat hazardous waste by various physical and chemical
means on a batch basis to remove and concentrate the hazardous constitutents.
The concentrated hazardous constitutents are to be disposed of or utilized
offsite. No land application, land filling or incineration is to take place
on -site. Water remaining after the concentrate has been removed is to be
treated biologically in an anaerobic reactor and settled. Settled water is
to be collected on a batch basis and tested prior to discharge to Laurinburg-
Maxton Airport Commission Wastewater Treatment Plant for further treatment.
This facility then discharges into the Lumber River at a point which is
approximately 26.2 river miles upstream of the City of Lumberton's drinking
water intake near the I-95 bridge in Lumberton. Time of travel at 30Q2 conditions
from the discharge to I-95 in Lumberton is estimated to be approximately 53
hours. In addition to accepting hazardous wastes from industries, leachate
from the hazardous waste landfill in Pinewood, South Carolina is to be trans-
ported and treated at the proposed facility.
Given the nature and location of this proposed operation it will be
necessary to impose strict monitoring requirements on both the indirect dis-
charger (GSX) and the direct discharger (L-M Airport Commission). The L-M
Airport Commission NPDES Permit will need to be reissued containing effluent
limitations for all potential chemicals which may be present in the discharge.
GSX will have to provide a list of all potential chemicals which might be
present as well as toxicity information on each chemical so that stream standards
can be set utilizing 1/100 of the 96 Hour LC 50. Additionally, continuous
chronic and acute toxicity biological monitoring is needed to ensure that no
adverse impact occurs in the stream.

Bill Mills
Water Quality Section
September 30, 1985
Page 2
The Laurinburg-Maxton Airport Commissions pretreat program will have to
be revised to include this facility and establish pretreatment standards.
This proposed facility raises a tremendous number of technical and non-
technical questions as to what level of treatment and monitoring will ensure
protection of stream standards and downstream water uses. As more information
becomes available, additional areas of coverage in the NPDES process may become
necessary.
If there is any need for additional information or clarification, please
advise.
14,
MJN/cbm

HAMPTON ROADS SANITATION DISTRICT
INDUSTRIAL WASTE CONTROL PROGRAM
PUBLIC INFORMATION SHEET
The Hampton Roads Sanitation District is a political subdivision of the
Commonwealth of Virginia charged with responsibility for water pollution abate-
ment within its jurisdiction. The District's boundaries currently encompass
approximately 1,700 square miles of Southeastern Virginia known as Tidewater.
The District is unique in that it serves an area surrounding Hampton Roads,
which is the largest natural harbor in the world.
Tidewater is a very heavily militarized area. More than half of all
industrial waste generated within the District comes from large military in-
stallations which are themselves similar in size to small cities. Other sources
of industrial waste include light and heavy manufacturing, food processing and
associated service industries. Waste generated by these industrial and com-
mercial sources is treated at the District's nine treatment plants. These
plants treat, in aggregate, approximately 130 million gallons per day.
HRSD's Industrial Waste Division is responsible for regulating industrial
and commercial discharges through application of the District's Industrial
Wastewater Discharge Regulations. These regulations include general and
specific effluent limitations and a discharge permit program. Adequate author-
ity to enforce the Industrial Wastewater Discharge Regulations of the Hampton
Roads Sanitation District and all applicable State and Federal regulations,
including final EPA "pretreatment limitations", is provided in Appendix "A" of
the HRSD Industrial Wastewater Discharge Regulations. Compliance is effected
through the use of an extensive monitoring program in conjunction with indus-
trial self -monitoring. The District conducts work -week wastewater monitoring

•
surveys at least annually, utilizing high-speed automatic samplers interfaced
with flow monitoring equipment. In addition, all industries known to dis-
charge toxic pollutants are grab sampled and spot checked monthly at un-
announced times. These same industries are required to perform varying degrees
of self monitoring using methods acceptable to the District.
Approximately 300 industrial dischargers have been issued discharge
permits which outline applicable effluent limitations, monitoring requirements,
metering requirements, and appropriate compliance schedules. These industries
have invested millions of dollars to achieve compliance.
Although EPA final pretreatment limitations for industrial subcategories
were not available during development of the Industrial Wastewater Discharge
Regulations, existing industrial waste problems necessitated the enforcement of
District limitations. During the development of specific pollutant limitations,
several factors were taken into consideration. Of primary consideration was
protection of District treatment structures and processes. The proposed limits
(particularly heavy metals) were carefully reviewed for their effect on the
quality of sludges generated by the District taking into account ultimate dis-
posal. Although incineration is now the principal method of sludge disposal
used by the District, land application is planned to replace incineration in
the future. In addition, effects of the proposed District limits were examined
for various processes, including activated sludge and anaerobic digestion.
Finally, effects of incompatible pollutant discharges to receiving waters from
District treatment facilities were also studied to assure that State and Federal
water quality standards were satisfied.

-3-
The assessment of compatibility with EPA pretreatment limitations pre-
sented considerable difficulty. Local standards much less stringent than EPA
limits may result in construction of inadequate pretreatment facilities and
wasted capital investments. Conversely, local standards much more stringent
than EPA limits, which are not based on specific treatment objectives (e.g.,
land disposal of sludge), inay result in "treatment for treatment's sake",
wasted energy and duplication of treatment. It was the District's intent to
develop and enforce local standards compatible with EPA"final" limits. There-
fore, we have proceeded on the basis that pretreatment systems designed and
built to meet District limits could be the "guts" for whatever system may be
necessary to meet EPA limits, for example, addition of polishing filters to
an existing chemical precipitation system for heavy metals removal.
The District's Industrial Waste Division currently implements a sur-
charge program generating approximately $3 million in revenue annually. The
surcharge is an additional charge to industrial and commercial users which
have high -strength wastes (BOD and/or TSS concentrations greater than 250
mg/1). The surcharge serves a two -fold purpose: 1) High -strength users are
required to pay their fair share of treatment costs rather than being supple-
mented by residential customers generating normal domestic wastes; and 2)
industries are given a financial incentive to "clean up their act". Many
dischargers have substantially reduced or eliminated the surcharge by insti-
tuting simple housekeeping practices, thus saving themselves money and provid-
ing additional treatment capacity at the POTW.
An important part of industrial waste control at the POTW is the ability
to locate and hold liable sources of unusual discharges which cause treatment
difficulties. The District has such capabilities in the form of an "Industrial
Waste Alert System". All treatment facilities are manned 24 hrs./day, 365

days/year. An emergency reporting procedure is in place where a treatment
plant operator can report any change in influent pH, odor, color, or general
appearance(oil, etc.). In addition, any process failure, such as loss of
chlorine residual or treatment effectiveness, is also reported. Members of the
Industrial Waste Division respond immediately to locate and terminate the source
of the unusual discharge. Enforcement mechanisms for passing along liability
for damages to sources of upsets and for termination of service are provided
for in the District's Industrial Wastewater Discharge Regulations, Part V,
Violations and Enforcement. This activity has resulted in the collection of
considerable sums in damages from industrial sources of unusual wastes. Addi-
tionally, the overall quality of District discharges has been improved.
Effective industrial waste control is essential to successful POTW oper-
ation. This control is best administered at the local level, if the control
program is designed around the needs of the POTW it serves. The District has
in place as rigorous an industrial waste control program as can be found in the
wastewater treatment industry. Such a program is necessary in providing the
best and most cost effective wastewater treatment services to all of its
customers.

Biological treatment of hazardous waste in
sequencing batch reactors
Philip A. Herzbrun, Robert L. Irvine, Kenneth C. Malinowski
The sequencing batch reactor (SBR) is one of several inno-
vative and alternative biological waste treatment systems that
have been evaluated by the U. S. Environmental Protection
Agency (U. S. EPA)' and the Office of Technology Assessment?
Irvine and Busch described SBR operation in 1979.3 Since that
time, a U. S. EPA demonstration study has shown that the SBR
is an excellent alternative to conventional activated sludge treat-
ment for municipal wastewater.` Recently, results from bench -
scale studies indicated that the SBR can provide substantial sav-
ings in energy and costs by removing organic compounds found
in hazardous waste biologically, rather than with activated car-
• bon s•6 Based on these findings, the New York State Energy Re-
search and Development Authority (NYSERDA) and CECOS
International agreed to co -fund a full-scale SBR study that would
demonstrate similar cost and energy savings for biological treat-
ment of hazardous wastes at CECOS. Preliminary findings from
early bench -scale studies, which were used to design the SBR
for the CECOS facility, were discussed by Herzbrun et al.' This
paper presents additional results from the CECOS bench -scale
study and summarizes performance for the first month of full-
scale operation.
BACKGROUND
While a reasonably complete description of the treatment fa-
cility at CECOS was presented by Herzbrun et al..' an overview
of the CECOS operation is summarized below for convenience.
CECOS International operates a 14.9 km2 site in Niagara Falls,
New York —one of only two fully permitted treatment, storage,
and disposal facilities in New York. CECOS currently manages
several operations, including a secure chemical management fa-
cility, a secure sludge management facility, a sanitary landfill, a
fuels blending program, and a multi -faceted wastewater treat-
ment facility.
The treatment plant typically receives 9 500 to 11 300 m3 of
wastewater each month. Approximately 50% of this is leachate
pumped from both active and inactive landfills on the CECOS
site; approximately 30% is pumped as part of a remedial
groundwater program from an unrelated facility bordering the
CECOS site; and the remaining 20% is received in bulk or drums
from various industries in a 640-km radius. The treatment plant
uses a two-phase operation: Phase 1 is dedicated to oxidation-
reduction reactions, acid neutralization, heavy metals precipi-
tation, and dewatering; Phase 2 is dedicated to pH adiustment,
biological degradation, carbon adsorption, and batch discharge.
Effluent limitations for the total plant are summarized in
Table 1.
The primary purpose of Phase 2 operation is to remove organic
carbon by adsorption on activated carbon. Because of the high
costs associated with the regeneration of activated carbon,
CECOS decided to study alternative methods of organic carbon
removal; biological removal in the SBR was selected as the most
cost-efficient alternative.
A plant design that uses SBR rather than carbon
adsorption for organics removal relied heavily on
thorough bench -scale testing of the concept.
The SBR is a periodically operated, fill -and -draw reactor.'•'
Each reactor in a SBR system has five discrete periods in each
cycle: fill, react, settle, draw, and idle. Reactions imitated during
fill (the time during which raw wastewater enters the tank) are
completed during react. After react, the mixed liquor suspended
solids (MLSS) are allowed to separate by sedimentation during
settle in a defined time period; the treated effluent is withdrawn
—during draw. The time period between the end of draw and the
beginning of new fill is termed idle. Because of the large storage
tanks available at the CECOS site, all of the bench -scale studies
to be described were conducted in a single -tank SBR system.
In the first phase of bench -scale testing four 10-L SBRs were
operated at different hydraulic detention times for 8 weeks. All
four reactors were operated at room temperature with reactor
temperatures from 24 to 26°C. Table 2 shows the operating
strategies used for each of these reactors. Feed was obtained
from the pH adjustment tank. Results from these studies,' in-
dicated that total organic carbon (TOC) and phenol effluent
limitations of 1000 g/m3 and 2.4 g/m3 (based on an expected
average flow rate of 300 m3/d) would be satisfied easily, provided
the SBR detention time was maintained between 2.5 and 10
days. (Note that the 1.25-day detention time reactor yielded poor
results.) .
These initial studies were the basis for a rather extensive bench -
scale study that continued through the construction periods and
first month in which the full-scale SBR was operated. Three of
these studies --a cold weather simulation, a phenol augmentation
experiment, and an energy conservation strategy —will be de-
scribed. ,,:...�. .
BENCH -SCALE STUDIES
The following results were obtained from SBRs that were op-
erated and monitored for 1 year. Each reactor was a 10-L poly -
carbonate container, drilled and ported to allow gravity discharge
-1163 •

• Herzbrun et al.
Table 1—Effluent limitations.
Total organic carbon
Total halogenated organics
Volatile halogenated priority pollutants
Chemical oxygen demand
Phenol
Total suspended solids
Organic phosphorus
pH
1000 g/m3
0.1 g/m3
1.0 g/m3 each
1040 kg/d
0.8 kg/d
990 kg/d
1.6 kg/d
5.5-9.0
of preset volumes through automatic solenoids. Air was supplied
by an air compressor and controlled through automatic sole-
noids. Additional mixing was provided by magnetic stirrers. Feed
was supplied to the reactors through peristaltic pumps and ad-
justed for appropriate volumes depending on the particular
treatment strategy used. All pumping, aeration, agitation, and
discharge functions were sequenced automatically with labora-
tory timers. Both 5-day and 9-day detention time systems were
studied in detail because expected flow variations to any full-
scale SBR would likely cause the detention time to vary within
these limits.
Cold weather simulation. To determine the viability of full-
scale SBR operation during extended winter periods, a bench -
scale reactor was modified to operate below room temperature.
An insulated cooling jacket was constructed to circulate refrig-
erated anti -freeze. This reactor, designated Reactor 5, operated
for 8 months, while a control reactor, designated Reactor 6,
operated concurrently at room temperature. Both reactors re-
ceived identical feed. Monthly average reactor temperatures and
detention times are shown in Table 3. The operating strategies
used for the 5-day and 9-day detention time periods are defined
in Table 2 as Strategy B and Strategy A, respectively (except the
maximum liquid volume was 9 L instead of 10 L). The influent
and effluent total organic carbon (TOC) concentrations from
both reactors are shown in Figure 1.
These results as illustrated in Figure 1 show clearly that the
TOC degradation in Reactor 6, operating between 21 and 25°C,
was superior to that obtained from Reactor 5. The disparity in
degradation was most obvious from March to May 1984, when
Reactor 5 operated between 5 and 6°C. It should be noted that
in no case did the average TOC exceed the 1000 g/m3 discharge
limit. Phenol limits. except as noted during special studies, were
also met throughout the cold weather temperature simulations.
Table 2—Reactor operating strategies.
Strategy
A B C D
Detention time, days
Maximum reactor liquid volume. L
Feed volume/cycle, L
Cycles per day
Total volume fed per day, L
Time for
Fill, hours
React, hours
Settle. hours
Draw/idle, hours
aa1 cycle time, hours
10 5 2.5 125
10 10 10 10
1 2 2 4
1 1 2 2
1 2 4 ;._ 8
10
10
2
2
24
10
10
2
2 .
24
5
5
1
1
12
5
5
1
1
12
Table 3—Average monthly temperatures and detention
times.
Month
Temperature (°C) •
Detention time
(days) Reactor 5 Reactor 6
October 1983
November 1983
December 1983
January 1984
February 1984
March 1984
April 1984
May 1984
5
9
9
9
9
9
5
5
17
11
10
9
9
6
5
6
25
25
24
25
23
21
24
23
While not reflected in this data, the rate of temperature de-
crease affected organic removal appreciably. In particular, as the
temperature approached 12 to 15°C the degradation rate reduced
noticeably, necessitating that the system be held at a slightly
elevated temperature until the organism distribution adjusted
to the new temperature. After such acclimation (this sometimes
required up to 2 weeks), active degradation proceeded until the
next temperature plateau was reached.
Phenol augmentation experiments. A 9-week phenol augmen-
tation study was conducted between .January and March 1984.
During this time, influent streams to Reactor 5 (the cold tem-
perature reactor) and Reactor 6 (the room temperature control)
were spiked daily with increasing amounts of phenol. The results
of this work are shown in Figure 2.
Influent phenol remained at raw wastewater concentrations
for Weeks 1 through 3. After that time, increasing amounts were
added to each reactor until 570 g/m3 phenol was reached at
Week 9. Reactor 5, which operated from 5 to 9°C during the
first 8 weeks, had two major phenol breakthroughs; the first was
during Week 4 when the phenol averaged at 55 g/m3, and the
second occurred in Week 8 when the effluent averaged 63 g/m3.
During this period, Reactor 6 operated with identical influent
volumes and composition. For comparison purposes, the op-
erating temperature was between 23 and 25°C; no effluent sam-
ples exceeded 0.4 g/m3 phenol. During Week 9 the effluent phe-
MONTHLY AVERAGES OF INFLUENT TOC VS. EFFLUENT TOC
1800—
1800— 1
1400—
/
1200
1000—
p
p 800-
1-
600 —
400 i
200-
0
Oct.'83
Nov. '83
• taw..�aw .orIS
• a..a...s
�.---•—�
1 T I t 1•
Dec.113 Jsr.'94 Feh.'64 Mar.'84 Apr.'84 May'34
Month
Figure 1—Monthly averages of influent and effluent TOC.
i 164 Journal WPCF, Volume 57, Number

•
i
4
WEEKLY AVERAGES OF INFLUENT PHENOL VS. EFFLUENT
PHENOL REACTOR #5
600—
500—
Aft
no-
el
E �—
a.
200-
No Ad46ortal
Phenol Added
air
spiked with
Additional Phenol
i
„dr'
(weekly Average Mood
Phenol for Reactor e6
Effluent
2 3 4 5
Week Number
Figure 2—Weekly averages of influent and effluent phenol, Reactor 5.
nol from the cold temperature system declined rapidly to 1.3
g/m3 when Reactor 5 was warmed to 26°C.
Energy conservation strategy. Energy can be conserved in the
SBR quite simply by allowing portions of the fill period to pro-
ceed without aeration but with mixing, or without aeration or
mixing. Either action would reduce the rate of degradation of
the organics during fill, and shift the distribution of organisms
present (and. of course, the reactions taking place) in the mixed
liquor. A reduction in reaction rate at this time could be tolerated,
provided the system detention time was sufficiently large to allow
the required reactions to go to completion during the remaining
portions of the cycle. Previous studies by Herzbrun et al.' had
showed marked reduction in TOC removal at a 1.25-day deten-
tion time. Consequently, any energy saving policy implemented
during periods in which the proposed full-scale SBR would cp-
erate at the shorter detention times (for example, 5 days) might
result in reduced removals of both TOC and phenol. With these
factors in mind, Reactor 9 operated for 2 weeks with the first 2
hours of fill unaerated but stirred, followed by 2 additional weeks
in which the first 4 hours of fill period operation was unaerated
and stirred. Finally, the reactor operated for 9 weeks with the
Table 4—Performance data.
Reactor 6 Reactor 9
Detention time, days
influent TOC, g/m3
Effluent TOC, g/m3
TOC degraded
Effluent phenol. g/m3
MLSS, g/m3
MLVSS. fj/rn3
Effluent SS, g/m3
SVI, mL/ g
5
1620
340
79%
0.4
3760
3240
150 .
50
5.5
1620
400
75%
0.4
3620
30^0
160
60
.9
Process Design
first 6 hours of fill unaerated and stirred for the first 51 days and
unaerated and unstirred for the last 12 days.
A comparison of Reactor 9 and control Reactor 6, both of
which operated between 23 and 25°C and received identical
influent composition and nearly identical detention times, is
shown in Table 4. Results for TOC, phenol, MLSS, mixed liquor
volatile suspended solids (MLVSS), effluent suspended solids
(SS), and sludge volume index (SVI) are expressed as the average
of weekly averages.
Performance in Reactor 9 was almost identical to the control
with respect to TOC degradation, phenol degradation, SVI, and
effluent suspended solids. Although TOC degradation was slightly
better in the control, it must be noted that the 6 hours of anoxic
feed represents an approximate 30% overall energy savings. One
potential problem with anoxic feed is an elevated odor that could
make anoxic conditions in the full-scale impractical.
70
a]
so—
E 40—
or
230-
20
10
PHENOL VS. TIME: REACTOR #9
■
0
• ,ll.aietall �
O
0
0 2 4 6 8 10 12 14 16 18 23 22 24
Time (ems)
Figure 3—Phenol versus time, Reactor 9.
December 1985
-1165

Herzbrun et al.
Table 5—Spiked oxygen uptake studies: anoxic and
control reactors.
Phenol
added
SBR (mg)
Change in
phenol
(g/m3)
Unit
Oxygen oxygen
uptake uptake
(g/m3 • h) (g/kg • h)
Reactor 6 0 0
Reactor 6 49 360
Reactor 6 4.6 36
Reactor 9 0 0
Reactor 9 49 360
Reactor 9 4.9 36
12.8
11.1
24.0
24.0
49.2
136.0
3.8
3.3
7.1
7.5
15.4
42.5
Phenol degradation was also studied during the anoxic feed
period. Figure 3 plots phenol concentration versus time for the
6-hour, unaerated, stirred fill period in Reactor 9. The phenol
build-up in this reactor during the 6-hour unaerated period was
very close to calculated theoretical levels (if no biodegradation
was assumed). Before aeration. less than I% of the phenol had
been degraded. Two hours after the aeration began. at the 8-
hour mark, 28% of the available phenol had been degraded. By
the end of the treatment cycle, well over 99% of the phenol had
been degraded and the effluent concentration had decreased to
0.4 g/m3. By comparison, the phenol concentration in the con-
tinuously aerated control reactor receiving identical feed was
0.4 g/m3 at the 8-hour mark.
TOC removal data show similar results. Before aeration in
Reactor 9, approximately 20% of the TOC added was degraded:
80% of the degradable TOC was used 2 hours after aeration
began. Control Reactor 6 maintained a virtually constant TOC
concentration before feed. 8 hours into the feed period, and
after the treatment cycle.
Oxygen uptake rate data were obtained for Reactors 6 and 9
to determine how the different operating strategies affect the
ability of the organisms to degrade phenol. At the end of the
react period. 135 mL of mixed liquor was removed from each
reactor, spiked with different amounts of a phenol solution, and
Phase 1 Water
Phase 2 Water
Leachate
L•S L-6 L-7
1,140m3 1,140m3 1,140m3
HC1
Storsge
Tank
sealed from the atmosphere with a dissolved oxygen probe
(Table 5).
Unit oxygen uptake rates confirmed that the anoxic Reactor
9, in which the bacterial population was acclimated, had a high
tolerance, to high phenol concentrations before aeration, was
much more adapted to using phenol as a food source. Thus, the
control Reactor 6 experienced either a minor increase or slight
decrease in unit oxygen uptake when phenol was added.
FULL-SCALE DEMONSTRATION FACILITY
Results from the bench -scale studies were used to design a
full-scale demonstration facility. Construction began in Decem-
ber 1983. The existing treatment facility was modified for Phase
2 operation (Figure 4). On June 6, 1984, the full-scale SBR,
roughly a 1900-m3 reactor, was put on-line. The SBR was situated
in the Phase 2 operation between the storage, equalization, and
neutralization basins (Tanks L-5, L-6, L-7, and L-8) and the
activated carbon columns. Major changes to Phase 2 operation
included: construction of an insulated, covered SBR, rerouting
of wastewater from Tank L-6 to Tank L-8 for pH adjustment
with hydrochloric acid: storage of this water in Tank L-7 for
final treatment in the SBR: and use of Tank L-12 for any ad-
ditional necessary sedimentation and for use as a feed tank to
the activated carbon system.
Preliminary results from the full-scale system are presented
in Table 6. Because the first week primarily involved start-up
and stabilization, the only results for Weeks 2 through 5 are
reported in this table. All data are reported as the average of
weekly averages. The data for phenol, TOC, effluent suspended
solids (SS), and sludge volume index (SVI) all indicate acceptable
treatment as anticipated from the bench -scale reactors. In ad-
dition, TOC degradation decreased from 86% in Week 2 to 72%
in Week 5. Such results were expected, because lab reactors typ-
ically required 4 to 8 weeks for treatment to stabilize fully.
Flow through the SBR averaged 220 m3/d, giving an 8- to 9-
day detention time, and representing approximately 90% of the
wastewater processed at the Niagara Falls site. As anticipated,
there was significantly Tess reliance on activated carbon to remove
contaminants of concern during this period.
L-12
1,440m3
Sand
Filters Carbon Adsorbers
L•8
170m3 LJJ
NFWTP
Discharge
L•11
1.140m
Figure 4—Phase 2 Nastewater treatmert system modified to include the SBR.
1 166 Journal WPCF, Volume 57, Number 12

Process Design
s
+sss. e.
the -.:.a
for
igh
.as
.he
;ht
�a
m-
ase
IR,
ted
.nd
the
on
ing
ant
for
ad -
to
ted
up
are
of
led
ble
id-
2%
JP-
9-
we
•
•
4
Table 6—Full-scale performance data.
Influent TOC, g/m3
Effluent TOC, g/m3
TOC degraded
Influent Phenol, g/m3
Effluent Phenol, g/m3
Phenol degraded
MLSS, g/m3
MLVSS. g/m3
Effluent SS, g/m3
SVI, mL/9
1100
260
76%
39.6
0.4
99.0%
1100
930
80
60
CONCLUSIONS
• Nine bench -scale SBR reactors have been operated during
the past year. Detention times of 1.25 to 10 days were investi-
gated, with acceptable results for all anticipated full-scale flows.
• One of these SBRs operated for 8 months at temperatures
as low as 3°C to simulate winter operations. Results for this
reactor were not as favorable as an identical control reactor op-
erated simultaneously between 21 and 25°C, but discharge lim-
itations for TOC and phenol removal were maintained provided
the rate of temperature decrease was controlled.
• One reactor was operated with up to 6 hours of stirred, and
unstirred, unaerated feed with very favorable results. Such en-
ergy -saving operational strategies for use in the full-scale reactor
are under consideration.
• Construction of a 1900 m3 SBR was completed in May
1984, and operation began 1 month later. TOC degradation
averaged 76% and phenol degradation averaged 99.0% during
the first month of operation. All other data indicated proper
performance.
• The role of organic contaminant removal has shifted from
adsorption on activated carbon to degradation in the SBR. With
the use of carbon for polishing purposes, a significant cost and
energy savings is anticipated.
ACKNOWLEDGMENTS
Credits. This study was supported in part by the New York
State Energy Research and Development Authority, Contract
number 601-CON-IC-84. The process equipment and tanks were
supplied and installed by Jet -Technology Inc., Industrial Airport,
Kansas. The full-scale process design and pilot and full-scale
studies were supervised by SBR Technologies, Inc., Mishawaka,
Indiana.
Authors. Philip A. Herzbrun is a laboratory manager with
CECOS International; Robert L. Irvine is a professor of civil
engineering at the University of Notre Dame; and Kenneth C.
Malinowski is vice-president of research development with
CECOS International. Correspondence should be addressed to
Dr. Irvine, Dept. of Civ. Eng., Univ. of Notre Dame, Notre
Dame, IN 46556.
REFERENCES
1, Irvine. R. L., "Project Summary. Technology Assessment of Se-
quencing Batch Reactors." EPA/600/52-85/007, U. S. EPA, (1985).
2. U. S. Congress, Office of Technology Assessment, "Superfund Strat-
egy." OTA-ITE-252, Washington, D. C., 211 (April 1985). •
3. Irvine, R. L., and Busch, A. W.. "Sequencing batch reactors —an
overview." J. Water Pollut. Control Fed.. 51, 235 (1979).
4. Irvine. R. L, et at, "Municipal application of sequencing batch
treatment at Culver, Indiana." J. Water Pollut. Control Fed., 55,
484 (1983).
5. Irvine, R. L. et al.. "Enhanced Biological Treatment of Leachates
from Industrial Landfills." Hazardous Waste. 1, 123 (1984). .-
6. Sojka, S. A., et al.. "Impact of Genetic Engineering in Pollution
Control: Enhanced Biological Destruction' of Environmental Xe-
• nobiotics." In "Biotechnology Applied to Environmental Problems."
D. L. Wise (Ed.), CRC Press, Inc. (in press). .
7. Herzbrun, P. A., et at, "Treatment of Hazardous Wastes in a Se-
quencing Batch Reactor." In "Biotechnology Applied to Environ-
mental Problems." D. L. Wise (Ed.), CRC Press, Inc. (in press).
12 .
December 1985
1167