20070812 Ver 2_Review of Alcoas NPDES historical files_20090225

Re: alcoa notes
Subject: Re: alcoa notes
From: Mike Templeton <[e-mail]>
Date: Thu, 26 Feb 2009 09:13:18 -0500
To: Coleen Sullins <Coleen. Sul lins@ncmail. net>
CC: John Dorney <[e-mail]>, Michael Parker <Michael. Parker@ncmail. net>
Coleen -
Mike Parker went through the Alcoa correspondence files at MRO and found only one mention of
PCBs, none of PAHs. An application for renewal about three cycles back showed only NDs for PCBs.
So according to our records, none of Alcoa's permit applications - going back to the early '80s, which
might include the original NPDES app - has indicated the presence of PCBs in its NPDES discharges.
It appears that any PCB sources at the Badin Works were already contained by then or had been
removed, possibly to one of the nearby landfills/ disposal sites.
- Mike T
Mike Templeton wrote:
John - I did some digging into the Alcoa files for Coleen. She asked me to send you my notes
(below). - Mike T
Review of NPDES's historical files going back to 1980.
• PCBs, PAHs. Modeling's wasteload allocations (WLAs) and permit apps going back to
1985 consistently report NDs for PCBs and PAHs in Alcoa's discharges. I found no record
of PCBs being detected in the discharges and very little detection of PAHs.
The 1986 WLA recommends a limit for benzo(a)pyrene for the lagoon discharge, based on
effluent guidelines. I found no DMR data for it and no other mention of it in the files.
Toxicity (as indicator of PCBs, PAHs). Alcoa has had quarterly toxicity limits at five
outfalls since at least 1989. From 1996 to Nov 2006, it passed approx. 80 of 85 tests. It
failed one test at Outfall 002 (chlorine in feed water), four at 005 (diesel spill by others,
cooling tower release, two of unknown cause), and one at 012.
• Process waters as potential sources. By the 2008 permit issuance, Alcoa had eliminated all
process WW other than cooling waters and utility blowdowns. A 1985 flow schematic
shows the facility had few process discharges even then. Wastestreams in 1985 included a
lagoon discharge (Outfall 003), boiler blowdown, evaporative losses, and stormwater.
Sanitary wastes went (and still go) to the Stanly County WWTP.
Alcoa eliminated the lagoon in the mid 90s. In a 1992 pre-closure study, they reported "no
organic, pesticide, herbicide, `129 list', or PCB contamination" of the bottom sludge and
similar results for the filtrate. The sludge also passed a TCLP test and so was to be sent to a
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Re: alcoa notes
municipal landfill as a non-hazardous waste.
I didn't review the latest NPDES application (1998) for more recent data - it has gone to Central
Files, possibly State Archives (am checking on it). Mike Parker will look into the MRO files and
see if he has any record of us dealing with PCBs, PAHs on or around the site.
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