Monsanto Agricultural Company Concerns About Jordan Lake Releases

State of North Carolina
Department of Natural Resources and Community Development
Division of Water Resources
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin Governor John N. Morris
S. Thomas Rhodes, Secretary Director

February 13, 1987

Mr. P. M. Pruett
Monsanto Agricultural Company
P. O. Box 2307
Fayetteville, North Carolina 28302

Dear Mr. Pruett:

Thank you for your letter of January 27 expressing the concern of the
Monsanto Company about releases of water from Jordan Lake to augment flows
and improve water quality in the Cape Fear River below the dam.

Jordan Lake provides an enormous benefit for wastewater dischargers
downstream. The project is designed to maintain a flow of 600 cubic feet
per second at Lillington under all but the most extreme drought conditions.
This compares to a historic low flow of about 11 cfs. As authorized by
Congress, about two-thirds of the conservation pool of Jordan Lake is set
aside to store water for downstream flow augmentation. A separate element
of the conservation pool is set aside for water supply use. For this reason,
use of the lake for water supply will not diminish the amount of water reserved
for downstream flow augmentation.

The Division of Environmental Management is currently studying the flow
augmentation capacity of Jordan Lake to determine under what recurrence interval
of extreme drought conditions the 600 cfs target could not be met at Lillington,
and to develop a more efficient plan for managing the flow augmentation storage
pool to maintain the best possible downstream water quality.

I am providing a copy of your letter to Mr. Trevor Clements of the Division
of Environmental Management so that he will have your statement available to him
in his review of water quality in the Cape Fear River.

Thank you for your interest in the management of North Carolina's natural
resources.

Sincerely yours,

John N. Morris

cc: Mr. Trevor Clements

P.O. Box 27687, Raleigh, North Carolina 276I1-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

Monsanto
MONSANTO AGRICULTURAL COMPANY
A UNIT OF MONSANTO COMPANY DIVISION OF WATER RESOURCES
P.O BOX 2307
FAYETTEVILLE, NORTH CAROLINA 28302
PHONE [phone]

January 27, 1987

John Morris
Director Water Resources
P. O. Box 27687
Raleigh, N. C. 27611

Dear Mr. Morris:

This is in response to a request by the North Carolina Water Quality Committee
to write you and convey Monsanto's concerns about the water allocation project
for the Jordan Lake.

The major concern Monsanto has is that the Jordan Lake 100 MGD water project
would lower the 7Q10 of the Cape Fear River. This was brought to our atten-
tion by an employee of DEM, who was doing the modeling for our plant's NPDES
permit. We were informed that our NPDES permit limits could be dropped to 5
ppm B0D5 and 2 ppm NH3N. These numbers would force us to totally redesign our
waste treatment facility. Additionally, we were informed that even before the
drought in the summer of 1986, the 600 CFS limit was not being met and that
the removal of 100 MGD would make the meeting of that limit even harder.

Since voicing Monsanto's concern at the Water Quality Committee meeting, we
have been informed by Kimberly Brewer that the 100 MGD water project will have
no effect on the 7Q10 of the Cape Fear Rvier. We were also informed by Trevor
Clements that although there was some problems with meeting the 600 CFS limit
before that, he thinks that problem has been resolved.

However, it appears to us that if all of the concerns about the 7Q10 of the
Cape Fear River have been resolved that the state would be issuing 5 year
permits instead of the planned 2 year permit.

To summarize Monsanto's feeling on the 100 MGD Jordan Lake Water project is
simply that if its not going to ever affect us, we don't have any concerns.
If the project changes the 7Q10, our NPDES permit, or causes us to have to
spend additional money on our waste treatment facility, we would have a number
of concerns, as would many other facilities in the Cape Fear Valley Region.
If you would like additional information please let me know.

Yours truly,

P. M. Pruett
Environmental/IN Supv.

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