NPDES PERMIT APPLICATION FORSTORM WATER DISCHARGES

ASSOCIATED WITH INDUSTRIAL ACTIVITY ATMONSANTO CHEMICAL COMPANY

ANNISTON, ALABAMA

Prepared for

ALABAMA DEPARTMENT OF ENVIRONMENTALMANAGEMENT WATER DIVISION

\15\ Con. W.L. Dickinson DriveMontgomery, Alabama 36130

Prepared by

MONSANTO CHEMICAL COMPANY300 Birmingham HighwayAnniston, Alabama 36201

andGERAGHTY & MILLER, INC.

Environmental Services14497 N. Dale Mabry Hwy.

Suite 115Tampa, Florida 33618

Plcate print or type m th« unloaded artai onlyffill-in trgff trt iptctd for t/ia tyot, /.»., 12 charicnnfinchl.

Form Approved 0MB Ho. 2040-0006 Appronl expires 7-31-68

FORM

1GENERAL &EPA

U.S. ENVIRONMENTAL PROTECTION AGENCY

GENERAL INFORMATIONContotidttfd Pfrmitt Progrwm

IK tad the "Cfnenl Inttructiont" tutor* itvlinf.)

III. rACILJl

v. MAILING ADDRES

II. POLLUTANT CHARACTERISTICS

GENERAL INSTRUCTIONS

If a preprinted label has been provided, affixit in the designated space. Review the inform-ation carefully; if any of it is incorrect, crotsthrough it and enter the correct data in theappropriate fill-in aree below. Also, if any ofthe preprinted data is absent (tfn trot to ttttleft of th« Itbtl space IHt* ttw Informationttitt dtould ippetrl. please provide it in theproper fill-In erwW below. If the let* itcomplete and correct, you need not completeItems I. Ill, V, and VI tacepr VI-B tutiichmutt o» completed ngtrttlutf. Complete sillItems if no label has been provided. Refer tothe Instructions for detailed Item descrip-tions and for the legal authorizations underwhich this data Is collected.

INSTRUCTIONS: CompletB A through J to determine whether you need to submit any permit application forms to the ERA. If you answer "yes" to anyquestions, you must submit this form and the supplemental form listed in the parenthesis following the question. Mark "X" In the box in the third columnIf the supplemental form is attached. If you answer "no" to each question, you need not submit any of these formt You may answer "no" if your activityis excluded from permit requirements; see Section C of the instructions. See also, Section D of the instructions for definitions of bold-fectd terms.

SPECIFIC QUESTIONSH A R K ' X -

**° ATTACHta

SPECIFIC QUESTIONSHARK 'X'romn

ATTACMVO

A. It thit facility a publicly owned treatment wortawhich remits in a discharge to waters of the U.S.?(FORM 2AI

Doe* or will this facility Mthtr mining or propottd)Include • oonotntrsrted animal feeding operation oraquatic animal production facility which results in adischarge to watan of the US,? (FORM 26)

C. Is this a facility which currently results in discharge*to waters of the U.S. other than those described inA or B above? (FORM 20)______ _________

D. Is thia a proposed facility lotfitr thtn thote detcrib«d~In A or B abowj which will result in a discharge towateri of the U.S.? (FORM 20)_____________

E. Does or will this facility treat, store, or dispose ofhazardous wattes? (FORM 3)

F. Do you or will you inject at this facility industrial ormunicipal affluent below the lowermost stratum con-taining, wfthln one quarter mile of the well bore,underground sources of drinking water? (FORM 4)

G. Do you or will you inject etthis facility any producedwater or other fluids which are brought to the surfacein connection with conventional oil or natural gas pro*duct ion, inject fluids ut*d for enhanced recovery ofoil or natural gas, or inject fluids for storago of liquidhydrocarbons? (FORM 4)

H. Do you or will you Inject at this facility fluids for spe-cial processes such as mining of sulfur by the Freschprocess, solution mining of minerals, in situ combus-tion of fossil fuel, or recovery of geothermal energy?(FORM 4)

"T Is this facility a proposed stationary source which isone of the 28 industrial categories listed in the in-structions and which will potentially emit 100 tonsper year of any air pollutant regulated under theClean Air Act and may affect or be located In anattainment area? (FORM 5)

J. Is this facility a proposed stationary source whicrTGTNOT one of the 28 industrial categories listed in theInstructions and which will potentially emit 260 tonsper year of any air pollutant regulated under the CleanAir Act and may affect or be located In an attainment

? (FORM 6)III. NAME OF FACILITY

MonsantoIV. FACILITY CONTACT

A. N A M E ft TITLE (lott. ftrtt. A titlt)

Jones, Robert Environmental SpecialistV. FACILITY MAILING ADDRESS

300 Birmingham Highway

_i i . i . i i i i i i i i i iAnniston

VI. FACILITY LOCATIONA. STREET, ROUTE. NO. OR OTHER SPECIFIC IDENTIFIER

3D01 Birmingham'Highway '

B. COUNTY NAME

CalhounC. CITY OH TOWN

^Annistonfr>.STATC|

T^TTfC. ZIP CODE

36201

F. COUNTY CODE___(if known)___'known

TABLE OF CONTENTS

EPA Form 2 - Application for Permit to Discharge Storm Water Associated withIndustrial Activity

FIGURES

1. Site Location Plan.

2. Production Facility Storm Water Site Plan

3. Landfill Storm Water Site Plan.

APPENDICES

A. Existing NPDES Permit No. AL0001201.

B. IV.B and IV.C Narrative Description of Pollutant Sources.

C. Nonstorm-water Discharge.

D. VI. Significant Leaks or Spills.

PROATF525\RPT\NPDESAPP.W51

FORM2F

PROATFS2S\RPTVNPDESAPP.W51

Pleas* print or typ« in the unshaded area* onlyEPA ID Number (copy from /fern I of Form f )

ALD004019048Form Approved. OMB No. 2040-O086

Approval expires 5-31-92

Form

2FNPOES

United States Environmental Protection AgencyWashington, DC 20460

Application for Permit To Discharge StormwaterDischarges Associated with Industrial Activity

Paperwork Reduction Act NoticePublic reporting burden lor this application is estimated to average 28 6 hours per application, including time for reviewing instructions.searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection ol mlormation Sendcomments regarding the burden estimate, any other aspect ol this collection o< mlormation. or suggestions lor improving ihij lotm. includingsuggestions which may increase or reduce this burden to: Chief, Information Policy Branch, PM-223. US. Environmental Protection Agency.•»01 M St.. SW. Washington. DC 20*60. or Director. Office of Information and Regulatory AHairs, Office of Management and Budget.Washington. DC 20503.

I. Outfall Location_________________________________________________Fpr each outfall, list the latitude and longitude of its location to the nearest 15 seconds and the name of the receiving water.

A. Outlall Number(list) 8. Latitude C. Longitude

0. Receiving Water(name)

DSN-001 33 39' 13" 85 51 12" Snow CreekDSN-004 33 39' 18" 85 51' 23" Snow CreekDSN-006 33 39' 16" 85 51' 27" Snow CreekDSN-007 33 39' 21" 85 51' 13" Snow CreekDSN-008 33 38' 54 85 51' 12" Snow CreekDSN-009 33 38' 57 85 51' 8" Snow CreekDSN-010 33 38' 59" 85 51' 3" Snow CreekDSN-011 33 39' 01" 85 50' 59" Snow CreekDSN-012 33 39' 02" 85 50' 57" Snow Creek

II. ImprovementsA. Are you now required by any Federal, Slate, or local authority to meet any implementation schedule for the construction, upgrading or

operation of wastewatar treatment equipment or practices or any other environmental programs which may affect the dischargesdescribed in this application? This includes, but is not limited to. permit conditions, administrative or enforcement orders, enforcementcompliance schedule letters, stipulations, court orders, and grant or loan conditions.

II. Identification of Conditions,

1 Agreements. Etc.NA

1

1-

| —————————————

(

2. Affected Outfallsnumber

NAsource of discharge

NA3. Brief Description of Project

NA

4. FinalCompliance Datea. req.NA

b. proj.NA

You may attach additional sheets describing any additional water pollution (or other environmental projects which may affect yourdischarges) you now have under way o< which you plan. Indicate whether each program is now under way or planned, and indicate youractual or planned schedules for construction.

"I. Site Drainage MaAttach a site map showing topography (or indicating the outline of drainage areas served by the outfall (s) covered in the application >ltopographic map is unavailable) depicting the facility including: each ol its intake and discharge structures: the drainage aiea ol each s;ormwater outlall: paved areas and buildings within the drainage area of each storm water outlall. each known past or present areas used foroutdoor storage or disposal of significant materials, each existing structural control measure to reduce pollutants in storm watermaterials loading and access areas, areas where pesticides, herbicides, soil conditioners and fertilizers are applied: each ol its«.isie treatment, storage or disposal units (including each area not required to have a RCRA permit which is used for accumulatingw,istt under 40 CFR 262.34): each well where fluids from the facility are injected underground: springs, and other suriace water bodies »ncnreceive storm water discharaos from the facility.

k Form 3S10-2F (11-00) Page t of 3 C o

EPA 10 Number (copy from Ham lot Form t)Continued from Page 2 ALD004019048VII. Discharge Informal!A,B,C, & 0: S«e Instructions before proceeding. Complete one set of tables for each outfall. Annotate the curtail number in the space provided.

_____Tables Vll-A. Vll-6. and VII-C are included on separate sheets numbered VII-1 and VII-2.E: Potential discharges not covered by analysis - Is any pollutant listed in Table 2F-2 a substance or a component of a substance which you

currenUy use or manufacture as an intermediate or final product or byproduct?

Yes (list all such pollutants below) n No (go to Section K)

Benzene4-Nitrdphenol

yical Toxicity TestingOo you have any knowledge or reason to believe that any biological test for acute or chronic toxicity has been made on any of your discharges oron a receiving water in relation to your discharge within the last 3 years?

n Yes (list all such pollutants below) No (go to Section IX)

IX. Contract Analysis Informal!Were any of the analyses reported in Item V performed by a contract laboratory or consulting firm?

I xl Yes (list the name, address, and telephone number of, and pollutants________analyzed bv. each such laboratory or firm below)

| j No (go to Section X)

A. Name B. Address C. Area Code & Phone No. D. Pollutants Analyzed

Environmental IndustrialResearch Associates, Inc.

161 James Drive West,Suite 100St. Rose, LA 70087

(504) 469-0333 )il and GreaseTSSTotal Kjeldahl

NitrogenNO3-NTotal PhosphorusBODS

/ certify under penalty of law that this document and all attachments were prepared under my direction orsupervision in accordance with a system designed to assure that qualified personnel properly gather and evaluatethe information submitted. Based on my inquiry of the person or persons who manage the system or those personsdirectly responsible lor gathering the information, the information submitted is, to the best of my knowledge andbelief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information,including the possibility of fine and imprisonment lor knowing violations.

A, Name & Official Title ffyp« or print)

IC. Signature

I

B. AIM Code »nd Phono No.

0. Date Signed

PA Form 3510-2F (11-90) Page 3 of 3

from <h« FrontIV. Narrative Description of Pollutant Sources

For each outfall, provide an estimate of the area (include units) of impervious surfaces (including paved areas and building rools) drainedto the outfall, and an estimate ol the totaJ surface area drained by the outfall.

OutfallJjlurrb.e.1

Area ol Impervious Surface TotaJ A/ea Drained(•provide up/ts)

Outfall Area of Impervious Surfaceunits)

Total Area Drained

DSNOO.DSNOODSNOODSNOO '

5.4 ACRES3.3 ACRES1•3 ACRES2.1 ACRES

15.5 ACRES17.0 ACRES8.8 ACRES1 -3 ACRES

DSNDSNOODSN01DSN01DSN01

0 ACRES0 ACRES0 ACRES0 ACRES0 ACRES

________

-0 ACRES10.0 ACRES11-9 ACRES13.2 ACRES17.3 ACRES

3. Piovide a narrative description of significant materials that are currently or in the past three years have been treated, stored or diioosea ma manner to allow exposure to storm water: method of treatment, storage, or disposal: past and present materials management practicesemployed, in the last three years, to minimize contact by these materials with storm water runoff; materials loading and access areas: andthe location, manner, and frequency m whirh pesticides, herbicides, soil conditioners, and fertilizers are applied. __ __

SEE APPENDIX B

C. For each outfall, provide the location and a description ol existing structural and nonstruclural control measures to reduce pollutants m1 Storm water runoff; and a description of the treatment the storm water receives, including the schedule and type of maintenance lor corv.toi

and treatment measures and the ultimate disoosal of. anv solid or fluid wastes, other than bv discharae.Outfall

Nurnber

1

I —————

Treatment

SEE APPENDIX B

List Codes fromTable 2F-1

V. Nonstocmwater Discharges_____ ___ _ _A. I certify under penalty of law that the outfall(s) covered by this application have been tested or evaluated for me presence ol

nonstcwmwater discharges, and that all nonstormwater discharges from these outfall(s) art identified in either an accompanying Form 2Cor Form 2E application for the outfall.

(Name and Official Title (type or pant) Signature Date Signed

B. Pfovdt a description of the method used, the date of any testing, and the onsite drainage points that were directly observed during a lest

SEE APPENDIX C

I. Significant Leaks or SpillsProvide ensiing information regarding m« history of significant leak* or spills of toxic or hazardous pollutants at the facility in the last tnieeyears, including the approiimate date and location of the spill or leak, and the type and amount of material released.________________

SEE APPENDIX D

'A Form 3510-2F (11-90) Page 2 of 3 Continue on t>ag« j

VII - Supplement

The production facility is drained by four outfalls (DSN-001, DSN-004, DSN-006 andDSN-007), as shown on Figure 2. Outfall DSN-001 is the only outfall that discharges storm-water associated with the Therminol® and biphenyl production areas, the boiler area andportions of the laboratory. However, a continuous flow of once-through non-contact coolingwater also discharges through DSN-001. The non-contact cooling water is currentlypermitted to discharge through DSN-001 (please refer to Appendix A).

To obtain a storm-water only sample associated with the Therminol® and biphenylproduction areas and avoid sampling the permitted non-contact cooling water discharge, thesample location was located upgradient from DSN-001. The storm-water sample wascollected on-site at an outfall that discharges storm water associated with the Therminol®and biphenyl production areas, the boiler area and portions of the laboratory. The samplelocation is shown on Figure 2.

Outfall DSN-004 is the center outfall at the production site. It is between DSN-006and DSN-007. It receives runoff from the PNP production area, areas adjacent to theTherminol® production area, portions of former parathion production area, and runoff fromthe areas drained by DSN-006 and DSN-007. A sample of the storm water dischargedthrough DSN-004 would provide a representative sample of storm-water runoff across theentire production site north and west of the biphenyl production area.

However, a sedimentation build-up at that outfall (DSN-004) made accurate flowmeasurements difficult and outfalls DSN-006 and DSN-007 were not easily accessible.Therefore, the sample location was moved approximately 130 feet southeast of DSN-004 toan outfall free of sediment build-up and easier to access. The sample location will providea representative sample of storm-water runoff from the PNP production area, areas adjacentto the Therminol® production area, and portions of former parathion production area. Thesample location is shown on Figure 2.

PROJ\TF52S\RFT\NPDESAPP.W51 Page 1 Of 2

VII - Supplement. Continued

The landfill site is drained by five outfalls. The runoff from the five areas drainingto each respective outfall is substantially identical. One of the five outfalls associated withindustrial activity at the landfill site will be sampled. The center outfall with the concretepipe is the most practical sampling point. Sampling this outfall will provide a samplerepresentative of runoff across the entire landfill.

Quantitative data will be submitted for the representative outfalls once a properstorm event is sampled. Only data of storm-water samples from the representative outfallswill be used to complete Form 2F. These data will be listed in the spaces provided in PartsA, B, and C of Section VU.

PROATF525\RFT\NPDESAPP.W51 Page 2 of 2

r1-J

EPA 10 Number (copy frofn mm 1 ot Form 1)

ALD004019048Form Approved. OM8 No. 2040-OOW

A«»w«'t«pinj«so1 jVII. Discharge Information (Continued from oaoe 3 of form 2F)

Part A • You must provide the return ot u leut one anaryti* (or ever/ poUuunt in this table. Complete one table (or each ourtail. Seeinstructions 'or additional details.

Pollutantand

CA5 Numberlit ivaiUDit)

Oil and Grease

Gi<oiogicaJ 0«ygenCiemand (BOOS)Chemical OxygenDemand (COO)Total SuspendedSoi>ds (TSS)

Maximum Va^ueetincludf Uflitt)

Grao Sample. — Taheo During

r.fit 30Minute*

1.2 mg/1

1 ppra

31 ppm

detectedTotal Kjeldahl JBQL

Nitrogen

Nitrate plus ;0.27 mg/1Nitnte Nitrogen

Flow -weightedComposite

N/A

2 ppm

29 ppm

detectecBQL

0.22 mg/1

Average VaJueaf/nctodto ufiiti)

Grao Sampte— *ehef> Ounng —

r.r»t M •Minutes

N/A

N/A

N/A

N/A

N/A

N/A

Row -weightedComposite

N/A

N/A

N/A

N/A

N/A

N/A .

Numberol

StormEvents

Sampled

1

1

1

1

1

1

Outfall DSN 001

Sources of Pollutants

car/truck traffic

normal background

normal background

normal background

use of fertilizers

use of fertilizersro1*' 0.14 mg/1 .0.15 mg/1 < N/A j N/A !i use of fertilizersPivjsohoryi ' ' ' ioH Minimum 7 .06 ManmumN/A Minimum N/A Maximum N/A

Pan 8 • List eacn poiiuiant mat is limited m an ertluent guideline which me (acuity •! tuoieci to or any pollutant i>ji«a in me laciiity t NPCESpermit tor its process *astewater M me facility is operating under an enstmg NPOES permit) Campiete one table 'or eacn ou:!anSee the instructions lor additional d*tiili and r*Quitem*nt*

Pollutantand

CAS Numberlit availaoif)

Maximum Values(includ* ufiini

Grab SampleTaken Ounng

first MMinute*

NA ' NA

iii

1

r j1

i

1

;

_______ L

Flow-weightedComposite

NA

Average Values(inctud* vflrrs;

Grab SampleTaken During

First XMinute*NA

1

i

Flow -weightedComposite

NA

NumberOl

StormEvents

SampledNA

•

Source* ot Pollutant*NA

1

•Jt Form 3S10-2F M1-9(n

Continued from the

I Pert C • U*t ••<* pottutant shown in Table* 2F-2. 2F-3. and 3F-4 that yew know or have reason to believe is present See ffw instruction* loradditional Oetail* and requirements. Complete one table tor eecft outlall.

PoOuUntand

CAS Number(if tvtiltbtt)

Benzene

Maximum Value*(TneA/de unit*)

Grab SampleTaben During

first 30Mtaute*

BQL

Flow-weightedCompositeBQL

Average Values(include unit*)

Grab SampleTaken During

First 30Minutes

N/A

Flow-weightedCompositeN/A

-

Numberof

StormEvents

Sampled1

Outfall DSN 001

Source* of Pollutant*Handled and Stored inDrainage Area

Part 0 • Provide data for the storm event(s) which resulted in the maximum values tor the flow weighted composite sample.1.

Date ofStormEvent

8 / 4 / 5

I•

2. 3. 4. *• «. . . 7. 8.Duration Total rainfafl Number of hours between Maximum floe (ate Total flow from Season FoimotAftinrm *. ,«M «i««« ~~~« beginning of storm mea«- during rain event rain event «*m«»tawa» Precipitationof Storm during storm event ^ u*,,* of previoua (gaOoHs/mlnutm or (gallons or "mp*"** {aMA

(in minutes) (in inches) measurable rain event specify units specify units) taken snowmen)

„ 144 0-7 308 . 0 .3883 CFS 447 CF summer rainfal:2

'.). Provide a description of the method of flow measurement or estimate.

Flow rate and total flow measurements were taken automatically withan ISCO flowmeter. However, samples were taken manually.

'A Form 3S10-2F (tt-90)

ERA 10 Numb*r (copy from /tern / at Form t)ALD004019048

Form Approved. OM8 No. 204O40M-wv— **uu^ 5-31 -W

VII. Discharge Information (Continued tram oaae 3 ot form 2F)Pan A • You must provide th* result* of at (*asi on* analysis for every pollutant in tMs lab»». Complete on* table lor each outtaii. See

instructions lor Additional details.

Pollutantand

CAS Number

Ol and Grease

6«oiog»caJ OiygenDemand (BOOS)Chemical OiygenDemand (COO)Total SuspendedSoi>ds (TSSI

Maximum VaJuee

Grab SampleT»kon During

First 30Minutes

3.4 mg/1

2 ppm

16 ppm

78 PP^Total KjeidahlNitrogen BQL

'1.6 ma / 1jNMfte Nitrogen ""'

Flow-weightedConnposiie

N/A

4 ppm

21 ppm

50 PPm

BQL

1.8 mg/1

Average Value*

Grab SampleTaken During

F.rst 30 *Minutes

N/A

N/A

N/A

N/A

N/A

N/A

Flow -weightedComposite

N/A

N/A

NJA

N/A

N/A

N/A

Numberof

StormEvents

Samoieo

1

1

1

1

1

1

Outfall DSN 004

Sources of Pollutants

car/train trafficnormal background

normal background

normal background

use of fertilizers

use of fertilizers

< otat t i . . - IIQ^ of fertilizers

pM Mirimum 7 m 62 -Maximum N/A MinimurrN/A Maximum N/APart B • List eacn pollutant mat >s limited m an etiluent guideline whicn in* lacihty >i subiect to or any pollutant listed in me facility s NPCE5

permit lor its process wastewater (if the facility is operating under an existing NPDES permit) Complete one table for eacn ou:?aitSee the instructions lor additional fl*taili And reaui/ements.

PollutantMaximum Value*

(include umrt)and i Grab Sample

f* \ f &> __w._ Ta«en OurinoCAS Number P -- «(it avarfaoJt) : Minutes

NA < NA

i

;

1

i

1

1

Flow-weightedComposite

NA

Average Value*finc/ude unity)

Grab SampleTaken During

first 30Minutes

NA

i

Flow-weightedComposite

NA

——————————— 1

NumberOf

StormEvents

SampledNA

Sources of PollutantsNA

. •

* Form 3510-2F Mi-«m

from tt>« FrontPart C • Ust each pollutant shown In TaWes 2F-2. 2F-3. and 2F-4 that you know or have reason to believe la present See the instructions tor

additional details and requirements. Complete one table for eeoh outfaO.

Pollutantand

CAS Number(if *v*il*b»)

ParathionMethylParathion

4-nitroph

-

Maximum Value*(Include units)

Grab SampleTaken During

firsOOMnwtee

EOT,

BQLnol BOL

flow-weightedCompositeBQTd

BQLBQL

Average Values(include units)

Orab SampleTaken During

First 30Minutes

N/AN/A

N/A

flow-weightedComposite

M-j Tt ——

N/AN/A

-

Numberof

StormEvents

Sampled1

11

Outfall DSN004

Sources of PollutantsFormer Production AreaFormer Production Area

hanrno^ in drainagearea

Part D • Provide data for the storm event(s) which resulted in the maximum values lor the Row weighted composite sample.1.

Date ofStormEvent

5 /4 /9

2. 3.Duration Total rainfallof Storm during ttorm event

(in minutes) (in inches)

144 0.7

*•

4.

Number of hour* betweenbeginning of storm meas-ured and end of previous

measurable rain event

308

5. 6. . 7. 8.Maximum floe rat* Total flow from Season Fotmolduring rain event rain event ..—,,1. _,., Precipitation

(gallons/minute or (gallons or **mp««w«« (ninfaa.specify wits specify units) taken snowmeft

1.26 CFS 8,640 CF summer rainfall

9. Provide a description of the method of Row measurement or estimate.

Flow rate and total flow measurements were taken automatically withan ISCO flowmeter. However, samples were taken manually.

'A Form 3510.5F

EPA )0 Number /copy from n»m I ol form t;ALD004019048

form Approved, OMB No. 2D4040MAp*TO¥1' «pm Wt-W

VII. Discharge Information (Continued from paae 3 of form 2F)Pan A • You must provide the rtsuits of at Itaat one anarysa for every pollutant in trus table. Comp tta on* taota for eacft oultafl. See

instructions for additional details.

Pollutantand

CAS Numberdf ivi/UDHI

O<l and Greas*

Jioiogtcal OiygenDemand (8005)Chemical QiygtnDemand (COO)Total SuspendedSOIKJS (TSS)

Maximum VjJuotttncliAfr unrtt)

Grab SampleTaken Ourmg

F.rsl XMinutes

3.2 mg/1

6 PPro

65 ppm

88 PPmI'otal KjekJanlNitrogen BQL

Nitrate plus .Nitr-ie N,irogen ' °'36 rog/1

Dow-wetgJitedComposite

N/A

7 PPm

61 ppm

32 PPm

BQL

0.28 mg/1

Average Valuesf7m:/uc'» u/iir>;

Grab SamptaTaken Ourmg

F-rsl 30 'Minutes

N/A

N/A

N/A

N/A

N/A

Flow-weightedComposite

N/A

N/A

"N/A

N/A

N/A

N/A N/A

Numberof

StormEvents

Sampled

1

1

1

1

1

1

Outfall DSN010

Sources of Pollutants

car/truck traffic

normal backgroundnormal background

normal background

use of fertilizers

use of fertilizers

To1" n -re /i • i ie /- i1 «/, «/, - use of fertilizers,Pho«ho.us °'75 m9/1 1-25 mg/1. N/A i N/A 1[pH Minmom 6 .42 ManmumN/A Minimum N/A Msnmwm N/A

Pan B • List tacn pollutant mat is limited in an tffluent guideline wfncn me f Jddty is suoieci to or any pollutant listed in me facility s NPCE5ceimit for -is process wastewater (if the facility is operating under an eustmg NPOCS peimni Complete one table for eacn ov/.?anS«r m« instructions for Jflflilionil detaili and reauirements

{PoOutant

andj CAS Number' t,f avaiiiQit)

Majiimum Values{indudt units)

Grab SampleTaken Ourmg

First XMinutes

Flow-wetghtedComposite

NA ' NA NA

i ;! i

ii

——— 1

i

1

i

Average Value*r-nc/i/tfe t/nrfj)

Grab SampleTaken Ourmg

first 30Minutes

NA

Row-weightedComposite

NA

Numberof

SlormEvent*

SampledNA

1

Sources of PollutantsNA

from thePart C • Utt eae* pollutant shown In Table* 2F-i 2F-3. and 2F-4 that you know or have r«a*on to believe i* present. See the instructions tor

additional detail* and requirement*. Complete one table for each outtafl.

PofluUntand

CAS Number(HtvtiUbtt)

BenzeneMethyl ParaParathion4-nitrooh

i

Maximum Value*fTnctofe unto)

Grab SampleTaMrt During

Fir* 30Wmite*

BQLhion RQT,BOL

no! ROT,

Ftow^eightedComposite

BQLBQL

BOL.SQL ——— .-

Average Value*(includt unto)

Grab SampleTtk*n During

First XMinute*

N/AN/AN/A

—— N/A ——— -

Flow-weightedCompositeN/A

N/AN/A

——— &WV ———

Numberof

StormEvent*

Sampled1111,

DSN 010

Sources of Pollutantstfaste Disposal in LandfiWaste Disposal in LandfiWaste Disposal in Landfi

Wflsl-p nifipnsaljiP..LfdnU J- X J. J.

' Part 0 • Provide data for the storm event(s) which resulted in the maximum values to* the flow weighted composite sample.1.

Out* ofSro/mEifent

• / 4 / 9

i 3.Duration Total rainfallof Storm during storm event

fn minutet) (in inches)

i

144 0.7

4. S ft. . 7. 8.Number of hours between Majomum fto* rat* Total (tow from Season Form ofbeginning Of «torm m*a»- during rain event rain event .-moi. w*« Precipitationu/ed and end of prevtou* (g*Jlofi*/minut» or (yallontof »«"R" » (rainfill,

measurable rain event specify unrts specify unit*) taken snowm«/r|

308 ' 0 .23 CFS 1,040 CF summer rainfall

9. Provide • description of the method of flow measurement or estimate.

Flow rate and total flow measurements were taken automatically withan ISCO flowmeter. However, samples were taken manually.

:£]-(•*<** lt»X 'V't-f^

^^^^^^^•.^^•'^,,:. >." '.;; ', '•' ; • • ' : • ; '•"'•

, -^'.VV^^'..^^-^--.'-^-'^;. -.I-.':"?.••.!•:,'•.'••. :•' 'i-,«-,i.

' ' • • f - ' - ' ' A !'''' :-1 ' ' ' "•:•'""-"•-•• ' : ' ' ' : ' - ' *?' '^•'\''f!'^---'f''':'f'' •'..'' =;r>\,;i.V:':^il-;'':-': "'•''':;;- -f •'' A- ':~t\ "'•••>± -^.'-•f^-^.'--:('*

FIGURES

PROATF32S\RPT\NPDESAPP.W51

GERAGHTY & MILLER. INC.

NOTES:1. OUTFALL OESCNATONS ARE MDCATED ON FUURES 2 AND 1

2. OUTFAU. COORDMATES ARE OVEN OH FORM *. HUE 1 OF &

SOURCE. USOS 74 M4UTE SERCS (TOPOQRAPMC) AMCSTON OUACRAMQLE 1994 PHOTO REVBED 1972. 7/55

APPBOX. SCALE

GERAGHTYMILLER, INC.

i'nvironm^rUoi

SITE LOCATION PLANNPDES STORM WATER DISCHARGE PERMTT APPUCATKDN

MONSANTO OEMCAL COMPANYANMSTON, ALABAMA

FIGURE

1

' " • • - • ^ - - ' " - ' "

APPENDIX A

EXISTING NPDES PERMIT NO. AL0001201

PROATT32S\RPT\NPDESAPP.W31

DISCHARGE

300 BIRMINGHAM HWYNNISTOItr^tABA

(CALHOUH^OUMTY)FACILITY LOCATION: -

PERMIT NUMBER:

RECEIVING WATERS:

A10001201

SNOW CREEK VIA STORM WATER DITCH

In accordance u-ith and subject lo the profi.iiont of the Federal If'ater Pollution Control Act. aioaiended. 331 '..SY.'. §§ 1251-1.178(the "FBPCA "). the Alabama Water Pollution Control Aft. o.i amended. Cndf of Alabama 197 S. §§ 22-22- / In 22-22-11 (the"A WPCA "). the Alabama Kn vironmenlal Manafement Act. 0.1 amended. Cndf of A labama 1975. §S 22-22A-I lo 22-22A-I5.and rules and rtpulalion* adopted thereunder, and subject further to the terms and conditions set forth in this permit, the Permittee ithereby authorixd lo discharge into the above-named receiviaf toalfn.

ISSUANCE DATE: September 30, 1991 .

EFFECTIVE DATE: November 1. 1991 ^ " ^ . _ ,

EXPIRATION DATE: October 31, 1996 .. ,

rum

PAKTI

PAKTm

D.

D.

P.

TwiR*MRMMH*

T«o^Mk« of Monitor*)*

Dbduuf* lU1.2.

Od*w Reporti** Mi NotMcatfoa Ii. Airhifair.dr ——••--A ••» • - -•

3.

B«M4 OB Brtiawtod OMTKteHitlci

AMDDCnBiOperational and Management 1I. PaelHtJe* Operation ndl

3. Spitl Pi«»<unlun. Control, and Management

Other RaepowtbtlHiw'• P*7 T« Mitigate Adreroe Impact

BranIV*

Dm to Comply with Permit. lUfea, aod SUOJIN1. Drty to Comply2* JUB^HO^T^Q SBDVUOOAC3. Lou or Puloic of Treatmeat PacOltloi4. CompBaocc with Sutate* and Rjilet

Pennit Trarer. Modificattoa, Snipeoiion. Rcvoeaboa. aod RcbnaawI. Daty to Reappty or Notify of IntoolZ Catania Dbcbwg*3* TrarHref of Pemil4. Permh Modifieatioa and Revocation3. Permh Termmatioa& Permit Soipenrioo7. Reqwat foi Pennit Aetioo Doe* Not Stay Any Pennh Retirement

Compliaoee with Toxk PoflBtant Suodard or Prohibition

a Ducharje of Waatewaier Oeoennod by OlhenOTHQLPERMTXCaraXTIOKi

A. Civil and Criminal Liability

Oil and Haurdou Stbetance Lub&tf

Property tod Other Rifhti

Availabifity of Repotti

BxpiratioBof Permit* For New or lacreaaed Ducharfet

CompGame With Water Qoality Standards

OrooadwoM

D.

C.

D.

E.

P.

O.

Severabifity

PART IV

Other Reqeiremcoai

PAKTI

ARGBLDfnAIIONS AND MOtVTOKING ttQUIREMHNTS

During the period beginning on the effective date of this permit and lasting through tbe expiration date of this permit, the pennittee is authorized todischarge from the following point source<s) outfall(s)), described more folly in the pennittee's application:

DSN001: Noacootact cooling water and steam condemate.

Soon discharge shall be limited and monitored by the permittee as specified below:

Effluent Characteristic _____ Discharge Limitations________ Monitoring Requirements I/Daily Mimmom Daily Maximum Monthly Average 2/ Measurement Sampk

Preqoency Type

NO LIMITATIONS OR MONITORING REQUIREMENTS APPLY.

SEE PART IV.. FOR OTHER REQUIREMENTS.

I/ Sample* collected to comply with the monitoring requirements specified above shall be collected at the following location: At the nearest accessiblelocation jost prior to discharge and after final treatment. Unless otherwise specified, composite samples shall be time composite samples collected usingautomatic sampling equipment or a minimum of eight (8) equal volume grab samples collected over equal time intervals. All composite samples shall becollected for the total period of discharge not to exceed 24 boors.Monthly average limits apply only when a parameter is monitored more than once in a month.

•*•!•PAKTi

A, PfffffAFff" • iMrTAima« Aim unMTTnBinn »BQnr»igMm*re

During the period beginning on the effective date of this permit and lasting through the expiration date of this permit, the permittee is authorized todischarge from the following point source(s) ontfall(s)), described more fully in the permittee's application:

DSN003 A 004: Storm water.

Soch discharge shall be limited and monitored by the peonittee as specified below:

Effluent Characteristic __________Discharge Limitations________ Monitoring Requirements I/Daily Minimum Daily Maximum Monthly Average 21 Measurement Sample

Frequency Type

NO LIMITATIONS OR MONITORING REQUIREMENTS APPLY.

SEE PARTTV.. FOR OTHER REQUIREMENTS.

I/ Samples collected to comply with the monitoring requirements specified above shall be collected at the following location: At the nearest accessiblelocation just price to discharge and after final treatment Unless otherwise specified, composite samples shaD be time composite samples collected usingaatomatic sampling equipment or a minimum of eight (8) equal volume grab samples collected over equal time intervals. All composite samples shall becollected for the total period of discharge not to exceed 24 boors.

2/ Monthly average limits apply only when a parameter is monitored more than once in a month.

DISCHARGE MOMETDtlNO AND RBCORD KHHWO IBQUHHMBXTS

1. Representative Sampling

Samples sod measurements taken u readied herein shaD be representative of die Tolome and natureof the monitored discharge aod shall be m accordance with the provisions of this permit

2. Test ProceduresTest procedures for the analysis of pollutants shall conform to 40 CFR Put 136 sad guidelinespublished pursuant to Section 304<h) of the FWPCA, 33 U.S.C. Section 13l4(bX If moit than onemethod for analysis of a substance is approved for use, a method having a detection limit lower thanthe permit limit shall be used. If the detection limit of all methods is hither than the permit UmH themethod baviaf the lowest detection limit shaD be used sod a report of less than detection limit shallconstitute compliance, however should EPA approve a method with a lower detection Itmh duringthe term of this permit the permittee shall use the newly approved method.

When an EPA approved test procedure for analysis of a poDutant does not exist, the Director shallapprove the piciceouie to be used.

3. Recording of Results

For each measurement or sample taken porsoant to the requirements of this permit, the permitteeshall record the following information:

a. The facility name and location, point source number, date, time and exact place of sampling;

b. The name(s) of person(s) who obtained the samples or measurements;

c. The dates and times die analyses were performed;

d. The name(s) of the persond) who performed the analyses;

e. The analytical techniques or methods used, including source of method and method number;and

L The results of all required analyses.

4. Records Retention and Production

a. The permittee shall retain records of all monitoring information, including an calibration andmaintenance records aod aD original strip chan recordings for continuous monitoringinstrumentation, copies of all reports required by the permit, and records of all data used tocomplete the above reports or the application for this permit, for a period of at least threeyean from the date of the sample measurement, report or application. This period may beextended by request of the Director at any time. If litigation or other enforcement action,under the AWPCA and/or the FWPCA, is ongoing which involves any of the above records,the records shall be kept until the litigation is resolved. Upon the written request of theDirector or his designee, the permittee shall provide the Director with a copy of any recordrequired to be retained by this paragraph. Copies of these records shall not be submittedunless requested.

b. AH records required to be kept for a period of three yean shall be kept at the permittedfacility or an alternate location approved by the Department in writing and shall be availablefor inspection.

5. Reduction, Suspension, or Termination of Monitoring and/or Reporting

a. The Director may, with respect to any point source identified in Provision I. A. of this permit,authorize the permittee to reduce, suspend or terminate the monitoring and/or reportingrequired by this permit upon the submission of a written request for such reduction,suspension or termination by the permittee, supported by sufficient data which demonstratesto the satisfaction of the Director that the discharge from such point source will continuouslymeet the discharge limitations specified in Provision L A. of this permit.

b. It remain* the responsibility of the permittee to comply with Ike monitoring and leporUngrequirements of thti permit until written authorization to reduce, napeod or terminate socbmonitoring and/or reporting is received by the permittee from the Director.

6. Monitoring Equipment and InstrumentationAH equipment and instrumentation used to determine compliance with me requirements of thispermit shall be installed, maintained, tod calibrated io accordance with the manaractnrer'sinstructions or, in tbe absence of manufacturer's instructions, io accordance with accepted practices.At a minimum, flow measurement devices shall be calibrated at least once every 12 months.

P1. Reporting of Monitoring Requirement!

ft. Monitoring results obtained during the previews [ HfA ] reporting period shaO besummarized on a Discharge Monitoring Report (DMR) Form approved by the Department.and received by the Director no later than the 28th day of the month following thismonitoring period The DMR must be kgible and bear an oririnal signature, photo andelectronic copies of the signature are not acceptable and shall not satisfy the reportingrequirements of this permit The first report is doe WA . If the permittee,using approved analytical methods as specified io Provision I. B. 2. monitors any dischargefrom a point source for a limited substance identified in Provision I. A. of this permit morefrequently than required by this permit, the results of soch monitoring shall be included in thecalculation and reporting of values on the DMR Form and tbe increased frequency shall bejtytirjfxi on the DMR Form. In the event no discharge from a point source ^rrtirV** inProvision L A of this permit and described more fully in the permittee's application occorsduring a monitoring period, the permittee shall report "No Discharge" for such period on theappropriate DMR Form.

b. Tbe permittee may certify io writing that a discharge win not occur for an extended period oftime and after such certification shall not be required to submit monitoring reports. Writtennotification of a planned resumption of discharge shall be submitted at least 30 days prior toresumption of the discharge. If an unplanned resumption of discharge occurs, writtennotification shall be submitted within 7 days of tbe resumption, hi any case, aD dischargesshall comply with an provisions of this permit

c. An reports and forms required to be submitted by this permit the AWPCA and theDepartment's Rules and regulations, shall be signed by a "responsible official" of thepennittee as defined in ADEM Administrative Code Rnk 335-6-6-.09 or a "duly authorizedrepresentative" of such official as defined in ADEM Administrative Code Rnk 335-6-6-.09and shall bear tbe following certification:

1 certify mder penalty of law that this document and anaOacJamato were pnpond mder 117 dfrtctiom or tmpcrrisiou inaccordant* wiA a system designed to assmre mat notifiedpersonnel property gamer and ewmate the information tmbmitted.Based en my mqtdrj of me person or persons who manage thesystem, or those persons direcdy responsible for garneringinformation. ate information submitted ts. to the best of myknowledge and belief, true, accurate. and complete. lam aware thatthere an significant penalties for submitting false information,auJudaig the possibility of fine and imprisonment for knowingviolations."

An reports and forms required to be submitted by this permit, the AWPCA and tbeDepartment's Rules, shafl be addressed to:

DirectorAlabama Department of Environmental Management1751 Congressman Dickinsoo DriveMontgomery, Alabama 36130Attention: Industrial Branch, Water Division

2. ^TTKwpHyffT Notificationa. If for coy reason, the permittee 'i discharge (1) does not comply with toy daily minimum or

maxiraam discharge limitation for aa efuoeot characteristic specified in Provisioo L A. oftfaii pennit which is denoted by an "(X)', (2) threateoi bomao beahb or welfare, fish oraquatic life, or water quality standards, (3) does not comply whh ao applicable toxk poOotaoteffluent otaodard or probibitioD established ooder Section 307(a) of the FWPCA, 3) U.S.CSection 1317(a), (4) contains a quantity of a haardoos substance whkh has been determinedmay be harmful to public health or welfare ooder Section 31 l(bX<) of the FWPCA, 33 U.S.CSection 1321(bX4). (5) exceeds any discharfe limitation for ao effloeot characteristic at aresult of ao unanticipated bypass or upset, or (6) is in anperattted direct or indirect dischargeof a pollutant to a water of the state (anpermitted discharges property reported to theDepartment ooder any other requirement are not required to be reported coder thu provision),the permittee soaD orally report the ocumeoce sod circumstances of soch discharfe to theDirector within 24-hoon after the permittee becomes aware of the occurrence of sochdischarge. In addition to the oral report, the permittee shall submit to the Director a writtenreport as provided to Provisioo L C 2. c. DO later than five (5) days after becomiof aware ofthe occurrence of soch discharfe.

b. If for any reason, the permittee's discharfe does not comply with soy limitation of thispermit, the permittee shall submit to the Director a written report as provided m Provisioo LC. 2. c. below, soch report shall be submitted with the next Discharfe Monitoring Reportrequired to be submitted by Providon I. C 1. of this permit after becoming aware of theoccurrence of such noocompliaoce.

c. Any written report required to be submitted to the Director by Provisioo L C. 2 a. or b. shallbe submitted using a copy of the Noncompliance Notification Form provided with this permitand shall inclodeie fc'f — =— '-•—-—

(1) A description of the discharge and cause of noncompliance;

(2) The period of noncompliaoce, including exact dates and times or, if not corrected, toeanticipated time the noncompliaoce is expected to continue; and

(3) A description of the steps taken and/or being taken to reduce or eliminate thenoncomplying discharge and to prevent its recurrence,

D. OtbHK REPORTING AND NOTIFICATION REQUIREMENTS

1. Anticipated Noocompliance

The permittee shall give the Director written advance notice of any planned changes or othercircumstances regarding a facility which may result in noDcompliance with pennit requirements.

2. Termination of DischargeThe permittee shall notify the Director, in writing, when aD discharges from any point sources)identified in Provision L A. of this pennit have permanently ceased This notification shall serve assufficient cause for instituting procedures for modification or termination of the permit

3. Updating Information

a. The permittee shall inform the Director of any change in the permittee's mailing address ortelephone number or in the permittee's designation of a facility contact or office having theauthority and responsibility to prevent and abate violations of the AWPCA, the Department'sRules and the terms and conditions of this pennit, in writing, no later than ten (10) days aftersuch change. Upon request of the Director or Us designee. the permittee shall furnish theDirector with an update of any information provided in the permit application.

b. If the permittee becomes aware (bat it failed to submit any relevant facts in a permitapplication, or submitted incorrect information in a permit application or in any report to theDirector, it shall promptly submit such facts or information with a written explanation for themistake and/or omission.

4. Doty to Provide InformationThe permittee shall furnish to the Director, within a reasonable time, any information which theDirector or hit designee may request to determine whether cause exists for modifying, suspending, orrevoking this permit, B whole or in part, or to determine compliance with this permit

5. Cooling Water and Boiler Water Additrvtfla. The permittee shall notify the Director in writini not later than sixty (60) days prior to

instituting the ose of any Uodde corrosion inhibitor or chemical additive in a cooling orboflex system, not identified in the application for this permit, from which discharge isallowed by ***** pmnit Such notification sfaafl include:

(1) name and general composition of biodde or chemical,(2) 96-hoor median tolerance limit data for organisms representative of the biota of the

waterway into which the discharge win ultimately reach,(3) Quantities to be used.(4) frequencies of use,(5) proposed discharge concentrations, and(6) BPA registration number, if applicable.

b. The use of a biocide or additive containing tributyl tin, tribntyl tin oxide, zinc, chromium orrelated compounds in a cooling or boiler system(s), from which a discharge regulated by thispermit occurs, b prohibited. The ose of any additive not identified in this permit or in theapplication for this permit prior to a determination by the Department that permitmodification to control discharge of the additive is not required or prior to issuance of apermit modification controlling discharge of me additive is prohibited.

6. New or Increased Discharges

a. If this permit was issued based on estimates of the characteristics of a process dischargereported on an EPA NPDES Application Form 2D (EPA Form 3510-2D), the permittee shallcomplete and submit an EPA NPDES Application Form 2C (EPA Form 3510-2Q no laterthan two yean after the date that discharge begins. Sampling required for completion of theForm 2C shall occur when a discharges) from the process(s) causing the new or increaseddischarge is occurring.

b. This permit shall be reopened if required to address any new information resulting from thecompletion and submhtal of the Form 2C

SCHEDULE OF COMPLIANCE

1. The permittee shall achieve compliance with the discharge limitations specified in Provision I. A. inaccordance with the following schedule:

COMPLIANCE SHALL BE ATTAINED ON THE EFFECTIVE DATE OF THIS PERMIT

No later than 14 calendar days following a date Identified in the above schedule of conpttaoce. thepermittee shall submit either a report of progress or, in the ca*e of specific action being required byidentified dates, a written notice of compliance or ooocoopliance. In the latter case, the notice shallinclude the canse of noooomphapce, any remedial actions taken, and the probability of meetinf thenext scheduled requirement.

PATT D

A. OFERATKNALANDMANAOEMEKTRBQUIKEMENTS

1. Facilities Operation t™* MaintenanceThe permittee shall at aD times properly operate and maintain an facilities and systems of treatmentand control (and related appurtenances) which are insulted or used by the permittee to achievecompliance with the conditions of the permit Proper operation and maintenance includes effectiveperformance, adequate funding, tdequate operator staffing and training, and adequate laboratory andprocess controls, including appropriate quality assurance procedures. This provision requires theoperation of backup or auxiliary facilities only when necessary to achieve compliance with theconditions of the permit

2. Best Management Practices

a. Dilution water shall not be added to achieve compliance with discharge limitations exceptwhen the Director or his designee has granted prior written authorization for dilution to meetwater quality requirements.

b. The permittee than prepare. implement, and maintain a Spill Prevention, Control andConntenneasures (SPCQ Plan in accordance with 40 CPU. Section 1 12 if required thereby.

c. The permittee shall prepare, submit for approval and implement a Best Management Practices(BMP) Plan for containment of any or all process liquids or solids, in a manner such thatthese materials do not present a significant potential for discharge, if so required by theDirector or his designee. When submitted and approved, the BMP Plan shall become a part ofthis permit and all requirements of the BMP Plan shall become requirements of this permit

3. Spill Prevention, Control, and ManagementThe permittee shall provide spill prevention, control, and/or management sufficient to prevent anyspills of pollutants from entering a water of the state or a publicly or privately owned treatmentworks. Any containment system used to implement this requirement shall be constructed of materialscompatible with the substances) contained and which shall prevent the contamination ofgroundwater and such containment system shaD be capable of retaining a volume equal to 110percent of the capacity of the largest tank for which containment is provided.

B. fTTTIHB

1 . Duty to Mitigate Adverse Impacts

The permittee shall promptly take all reasonable steps to mitigate and minimize or prevent anyadverse impact on human health or the environment resulting from ooncompliance with anydischarge limitation specified in Provision L A. of this permit, including such accelerated oradditional monitoring of the discharge and/or the receiving waterbody as necessary to determine thenature and impact of the noncomplying discharge.

2. Right of Entry and Inspection

The permittee shall allow the Director, or an authorized representative, upon the presentation ofproper identification to:

a. enter upon the permittee's premises where a regulated facility or activity is located orconducted, or where records must be kept under the conditions of the permit;

b. have scout to and copy, at reasonable times, toy record* that most be kept voder theconditions of the permit;

c. inspect at reasonable times any facilities, equipment (including monitoring and controlequipment), practices, or operations regulated or required under the permit; and

d. sample or monitor at reasonable times, for the purposes of assuring permit compliance or asotherwise authorized by the AWPCA, any substances or parameters at any location.

C BYPASS AND TJPSET

1. Bypassa. Any bypass is prohibited except as provided in b. and c. below:

b. A bypcss is not prohibited if:

(1) It does not cause any discharge limitation specified in Provision I. A. of this permit tobe exceeded; and

(2) It is necessary for essential maintenance of a treatment or control facility or system toassure efficient operation of such facility or system.

c. A bypass is not prohibited and need not meet the discharge limitations specified in ProvisionL A, of this permit if:

(1) It is unavoidable to prevent loss of life, personal injury, or severe property damage;(2) There are no feasible alternatives to the bypass, such as the ose of auxiliary treatment

facilities, retention of untreated wastes, or maintenance during normal periods ofequipment downtime (this condition is not satisfied if adequate back-up equipmentshould have been installed in the exercise of reasonable engineering Judgement toprevent a bypass which occured during normal periods of equipment downtime orpreventive maintenance); and

(3) The permittee submits a written request for authorization to bypass to the Director atleast ten (10) days prior to the anticipated bypass (if possible), the permittee is grantedsuch authorization, and the permittee complies with any conditions imposed by theDirector to minimize any adverse impact on human health or the environmentresulting from the bypass.

d The permittee has the burden of establishing that each of the conditions of Provision n. C. 1.b. or c. have been met to qualify for an exception to the general prohibition against bypassingcontained in a. and an exemption, where applicable, from the discharge limitations specifiedin Provision I. A. of this permit.

2. Upset

a. A discharge which results from an upset need not meet the discharge limitations specified inProvision 1 A. of this permit it

(1) No later than 24-bonrs after becoming aware of the occurrence of the upset, thepermittee orally reports the occurrence and circumstances of the upset to the Directoror his designee; and

(2) No later than five (5) days after becoming aware of the occurrence of the upset, thepermittee furnishes the Director with evidence, including properly signed,contemporaneous operating logs, or other relevant evidence, demonstrating that (i) anupset occurred; (ii) the permittee can identify the specific cause(s) of the upset; (iii)the permittee's facility was being properly operated at the time of the upset; and (iv)the permittee promptly took all reasonable steps to minimize any adverse impact onhuman health or the environment resulting from the upset

b. The permittee has the burden of establishing that each of the conditions of Provision n C 2.a. 01 this permit tare been met to qualify for an exemption from the discharge limitationspecified in Provision L A. of this permit

D. DinT TO COMPLY WITH PERMIT, RULES, AND STATUTES

1. Doty to Comply

a. The permittee mast comply with an conditions of this permit Any Derail noocomplianeeconstitutes a violation of the AWPCA and the FWPCA and is frotmds for enforcement action,for pexmit termination, revocation and reissuance, suspension, modification; or denial of apermit renewal application.

b. The necessity to halt or reduce production or other activities io order to maintain compliancewith the conditions of the pennit shall not be a defense for a permittee in an enforcementaction.

c. The discharge of a pollutant from a source not specifically identified in the pennit applicationfor this pennit and not specifically included in the description of an outfall hi this permit isnot authorized and shall constitute noncompUance with this permit

d. The permittee shall take aD reasonable steps, including cessation of production or otheractivities, to minimi** or prevent any violation of this pennit or to minimize or prevent anyadverse impact of any pennit violation.

2. Removed Substances

Solids, sludges, filter backwash, or any other pollutant or other waste removed in the course oftreatment or control of wastewaters shaD be disposed of in a manner that complies with all applicabkDepartment Rules.

3. Loss or Faflnre of Treatment Facilities

Upon the loss or failure of any treatment facility, including but not limited to the loss or failure ofthe primary source of power of the treatment facility, the permittee shall, where necessary tomaintain compliance with the discharge limitations specified in Provision I. A. of this pennit, or anyother terms or conditions of this permit, cease, reduce, or otherwise control production and/or audischarges until treatment is restored.

4. Compliance With Statutes and Rulesa. This permit has been issued under ADEM Administrative Code, Chapter 335-6-6. A1J

provisions of this chapter, that are applicable to this permit, are hereby made a part of thispennit A copy of this chapter may be obtained for a small charge from the Office of GeneralCounsel, Alabama Department of Environmental Management, 1751 Congressman DickinsooDove, Montgomery, AL 36130.

b. This permit does not authorize the noocomplianee with or violation of any Laws of the Stateof Alabama or the United States of America or any regulations or rules implementing suchlaws. FWPCA, 33 U.S.C. Section 1319, and Code of Alabama 1975, Section 22-22-14.

EL PERMIT TRANSFER, MODIFICATION, SUSPENSION, REVOCATION. AND REISSUANCE

1. Duty to Reapply or Notify of Intent to Cease Discharge

a. If the permittee intends to continue to discharge beyond the expiration date of this permit, thepermittee shall file a complete pennit application for reissuance of this permit at least 180days prior to its expiration. If the permittee does not intend to continue discharge beyond theexpiration of this pennit, the permittee shaD submit written notification of this intent whichshall be signed by an individual meeting the signatory requirements for a permit appUcatiooas set forth in ADEM Administrative Code Rule 335-6-6-.09.

b. Failure of the permittee to apply for reissuance at least 180 days prior to pennit expirationwin void the automatic continuation of the expiring permit provided by ADEMAdministrative Code Rule 335-6-6-.06 and should the permit not be reissued for any reasonany discharge after expiration of this permit win be an unpermined discharge.

2. Change in Discharge

ft. The permittee shall apply for a permit modification at least 180 day* to advance of anyfacility expansion, production increase, process cfaaofe. or ocber action that could result In thedischarge of additional poDutanti or increase the quantity of • discharged poUotant socfa thatexisdmTpexmit limitations would be txc*t4t4 or that could result in ao additional dischargepoint This requirement applies to pollutants that are or that are not subject to dischargelimitations in this permit No new or increased discharge may begin until the Director hasauthorized it by issuance of a permit modification or a reissued permit

to. The permittee shall notify the Director as soon as it is known or there is reason to believe:(1) That any activity has occurred or will occur which would result in the discharge on a

routine or frequent basis, of any toxic poOotant which is not limited in this permit, tfthat discharge win exceed the highest of me following notification levels:

(a) one hundred micrograms per liter,

(b) two hundred micrograms per liter for acroleln and acrylonitrOe; five hundredmicrograms per liter fox 2,4-dtnitropbenoI and for 2-methyM,6-dini-tropnenol; and one milligram per liter for antimony;

(c) five times the maximum concentration value reported for that pollutant in thepermit application; or

(2) That any activity has occurred or win occur which would result in any discharge, on aaon-routine or infrequent basis, of a toxic pollutant which is not limited in the permit,if that discharge win exceed the highest of the following notification levels:(a) five hundred micrograms per liter(b) one milligram per liter for antimony;(c) ten times the maximum concentration value reported for that pollutant in the

permit application.

3. Transfer of Permit

This permit may not be transferred or the name of the permittee changed without notice to theDirector and subsequent modification or revocation and reusuance of the permit to identify the newpermittee and to incorporate any other changes as may be required under the FWPCA or AWPCA. lathe case of a change in name, ownership or control of the permittee's premises only, a request forpermit modification in a format acceptable to the Director is required at least 30 days prior to thechange. In the case of a change in name, ownership or control of the permittee's premisesaccompanied by a change or proposed change in effluent characteristics, a complete permitapplication is required to be submitted to the Director at least 180 days prior to the change,whenever the Director is notified of a change in name, ownership or control, be may decide not tomodify the existing permit and require the submission of a new permit application.

4. Permit Modification and Revocation

a. This permit may be modified or revoked and reissued, in whole or in part, during its term forcause, including but not limited to, the following:

(1) If cause for termination under Provision D. E. S. of this permit exists, the Directormay choose to revoke and reissue this permit instead of terminating the permit;

(2) If a request to transfer this permit has been received, the Director may decide torevoke and reissue or to modify the permit; or

(3) If modification or revocation and reissuance is requested by the permittee and causeexists, the Director may grant the request

b. This permit may be modified during its term for cause, including but not limited to, thefollowing:

(1) If cause for termination under Provision II. E. 5. of this permit exists, the Directormay choose to modify tins permit instead of terminating this permit;

10

(2) There are material and substantial alterations or additions to the facility or activitygenerating wastewater which occurred after permit issuance which jasdfy theapplication of permit conditions that are different or absent in the existing permit;

(3) The Director has received new information that was not available at the rime of permitissuance and that would have justified the application of different permit conditions atthe time of issuance;

(4) A new or revised requiremenKs) of any applicable standard or limitation ispromulgated under Sections 301(bX2XQ, (D), (E), and (F), and 307(aX2) of theFWPCA;

(5) Errors in calculation of discharge limitations or typographical or clerical errors weremade;

(6) To the extent allowed by ADEM Administrative Code, Rote 335-6-6-.17, when thestandards or regulations on which the permit was based have been changed bypromulgation of amended standards or regulations or by judicial decision after thepermit was issued;

(7) To the extent allowed by ADEM Administrative Code. Rule 335-6-6-.17, permits maybe modified to change compliance schedule*;

(8) To agree with a granted variance under 3«(c), 301(g), 3<X(h), 301(1), or 3l6(a) of theFWPCA or for fundamentally different factor*;

(9) To incorporate an applicable 307(a) FWPCA toxic effluent standard or prohibition;

(10) When required by the reopener conditions hi this permit;

(11) When required under 40 CFR 403.8(e) (compliance schedule for development ofpretreatment program);

(12) Upon failure of the state to notify, as required by Section 402(bX3) of (he FWPCA.another state whose waters may be affected by a discharge permitted by this permit;

(13) When required to correct technical mistakes, such as errors hi calculation, or mistakeninterpretations of law made in determining permit conditions; or

(14) When requested by die permittee and the Director determines that the modification hascause and will not result in a violation of federal or state law, regulations or rules.

S. . This permit may be terminated during its term for cause, including but not limited to, the following:

a. Violation of any term or condition of this permit;b. The permittee's misrepresentation or failure to disclose fnOy all relevant facts in the permit

application or during the permit issuance process or the permittee's misrepresentation of anyrelevant facts at any time;

c. Materially false or inaccurate statements or information in the permit application or thepermit;

d. A change in any condition that requires either a temporary or permanent reduction orelimination of the permitted discharge;

e. The permittee's discharge threatens human life or welfare or the maintenance of water qualitystandards;

L Permanent closure of the facility generating the wastewater permitted to be discharged by thispermit or permanent cessation of wastewater discharge;

g. New or revised requirements of any applicable standard or limitation that is promulgatedunder Sections 301(bX2XQ. (D), (E). and (F), and 307(aX2) of the FWPCA that the Directordetermines cannot be complied with by the permittee; or

h. Any other cause allowed by the ADEM Administrative Code, Chapter 335-64.

11

6. This permit may be suspended durinf its term for cause, bdodinf bat not limited to, tfae reasoat fortermination listed in Provision n B. 5. of mis permit

7. The filing of a request by me permittee for modification, suspension or revocation of this permit, inwhole or m part, does not stay any permit term or condition.

F.

If any applicable effluent standard or prohibition (including any schedule of compliance specified in socbeffluent standard or prohibitioa) is established under Section 307(a) of the FWPCA, 33 U.S.C. Section13l7(a), for a toxic pollutant discharged by the permittee and such standard or prohibition is more stringentthan nay discharge limitation on the pollutant specified in ProviMoo L A. of this permit, or controls apollutant not limited in Provision L A. of this permit, this permit shaD be modified to conform to the toxtepollutant effluent standard or prohibitioa and the permittee shall be notified of such modificsiioa. If thispermit has not fr*fft modified to conform to the toxic pollutant effluent standard or prohibition before theeffective date of soch standard or prohibitioo, the permittee shall attain compliance with me requirements ofthe standard or prohibition within die time period required by the standard or prohibition and shall continueto comply with the standard or prohibitioa until this permit is modified or reissued.

a DBCBAROT OF WASTWATHR GENERATED BY OTHERS

The discharge of wastewater, generated by any process, facility, or by any other means not under theoperational control of the permittee or not identified in the application for tbis permit or notidentified specifically in the description of an outfall in this permit a not authorized by this permit

PART m

A. CIVIL AND CRIMINAL LIABILITY

1. Tampering

Any person who falsifies, tampers with, or knowingly renders inaccurate any monitoring device ormethod required to be maintained or performed under the permit shall, upon conviction, be subject topenalties as provided by the AWPCA.

2. False Statements

Any person who knowingly makes any false statement, representation, or certification in any recordor other document submitted or required to be maintained under this permit, including monitoringreports or reports of compliance or noncompliance shall, upon conviction, be subject to penalties asprovided by the AWPCA.

3. Permit Enforcement

a. Any NPDES permit issued or reissued by the Department is a permit for the purpose of theAWPCA and the FWPCA and as such any terms, conditions, or limitations of the permit areenforceable under state and federal law.

b. Any person required to have a NPDES permit pursuant to ADEM Administrative CodeChapter 335-6-6 and who discharges pollutants without said permit, who violates theconditions of said permit, who discharges pollutants in a manner not authorized by the permit,or who violates applicable orders of the Department or any applicable rule or standard of theDepartment, is subject to any one or combination of the foDowing enforcement actions underapplicable state statutes.

(1) An administrative order requiring abatement, compliance, mitigation, cessation,clean-up, and/or penalties;

(2) An action for damages;(3) An action for injunctive relief, or

(4) An action for penalties.

12

4. Relief Prom Liability

Except as provided in Provision n. C. 1. (Bypass) and Provision 0. C. 2. (Upset), nothing in thispermit shall be construed to relieve the permittee of dvil or criminal liability under the AWPCA orFWPCA for Doncompliance with any term or condition of this permit

B. CD. AM) HAZAIJDOUS SUBSTANCE LLABILTTT

Nothing in this permit shall be construed to preclude the institution of any legal action or relieve thepermittee from any responsibilities, liabilities or penalties to which the permittee U or may be subject underSection 311 of the FWPCA, 33 U.S.C Section 1321.

C FROPEtTYANDOlBERXIGBFS

This permit does not convey any property rights in either real or personal property, or any exclusiveprivikges, nor does it authorize any injury to persons or property or invasion or other private rights, or anyinfringement of federal, state, or local laws or regulations, nor does it authorize or approve the constructionof any physical structures or facilities or the undertaking of any work hi any waters of the state or of theUnited States.

D. AVAILABILITY OF REPORTS

Except for data determined to be confidential under Code of Alabama 1975, Section 22-22-9(c), all reportsprepared in accordance with the terms of this permit shall be available for public inspection at the offices ofthe Department. Effluent data shall not be considered confidential.

B. EXPDIATIC)N OF PERMTTS FOR NEW OR INCREASED DCCHAJROBS

1. If this permit was issued for a new discharger or new source, this permit shaD expire eighteenmonths after the issuance date if construction of the facility has not begun during the eighteen monthperiod.

2. If this permit was issued or modified to allow the discharge of increased quantities of pollutants toaccommodate the modification of an existing facility and if construction of this modification has notbegun during the eighteen month period after issuance of this permit or permit modification, thispermit shall be modified to reduce the quantities of pollutants allowed to be discharged to thoselevels that would have been allowed if the modification of the facility had not been planned.

3. Construction has begun when the owner or operator has:

a. begun, or caused to begin as part of a continuous on-site construction program:

(1) any placement, assembly, or installation of facilities or equipment; or(2) significant site preparation work including clearing, excavation, or removal of existing

buildings, structures, or facilities which is necessary for the placement, assembly, orinstallation of new source facilities or equipment; or

b. entered into a binding contractual obligation for the purpose of placement, assembly, orinstallation of facilities or equipment which are intended to be used in its operation within areasonable time. Options to purchase or contracts which can be terminated or modifiedwithout substantial loss, and contracts for feasibility, engineering, and design studies do notconstitute a contractual obligation under the paragraph. The entering into a kase with theState of Alabama for exploration and production of hydrocarbons shall also be consideredbeginning construction.

F. COMPLIANCE WITH WATER QUALITY STANDARDS

1. On the basis of the permittee's application, plans, or other available information, the Department hasdetermined that compliance with the terms and conditions of this permit should assure compliancewith the applicable water quality standards.

2. Compliance with permit terms and conditions notwithstanding, if the permittee's discharge^) frompoint sources identified in Provision L A. of this permit cause or contribute to a condition incontravention of state water quality standards, the Department may require abatement action to betaken by the permittee in emergency situations or modify the permit pursuant to the Department'sRules, or both.

13

3. If the Department determine*, on the basis of a notice provided ponoant to this permit or anyinvestig anon, inspection or sampling, that a modification of thu permit is necessary to assuremaintenance of water quality standards or compliance with other provisions of the AWPCA orFWPCA, the Department may require such modification and, m cases of emergency, the Directormay prohibit the discharge until the permit has been modified.

a GKOUNDWATBR

Unless specifically authorized by mis permit, the discharge of pollutants to froundwater is prohibited.Should a threat of groundwater contamination occur, the Director may require froundwater monitoring toproperly assess the degree of the problem and the Director may require that the permittee undertakemeasures to abate any such discharge and/or contamination.

H. DEHNmONS

1. Avenge monthly discharge limitation - means the highest allowable average of "daily discharges"over a calendar month, calculated as the sum of all "daily discharges" measured during a calendarmonth divided by the nmnber of "daily discharges" measured daring that month (zero discharge daysshall not be included in the number of "daily discharges" measured and a less than detectable testresult shall be treated as a concentration of zero if the most sensitive EPA approved method wasused).

2. Average weekly discharge limitation - means the highest allowable average of "daily discharges"over a calendar week, calculated as the sum of all "dairy discharges" measured during a calendarweek divided by the number of "daily discharges" measured during that week (tero discharge daysshall not be included in the number of "daily discharge*" measured and a less than detectable testresult shall be treated as a concentration of zero if the most sensitive EPA approved method wasused).

3. AWPCA - means the Alabama Water Pollution Control Act

4. Bypass - means the intentional diversion of waste streams from any portion of a treatment facility.5. Daily discharge - means the discharge of a pollutant measured during any consecutive 24 boor period

in accordance with the sample type and analytical methodology specified by the discharge permit

6. Daily maximum • means the highest value of any individual sample result obtained during a day.

7. Daily minimum - means the lowest value of any individual sample result obtained during a day.

8. Day - means any consecutive 24-hour period.

9. Department • means the Alabama Department of Environmental Management

10. Director - means the Director of the Department

11. Discharge - means "[t]he addition, introduction, leaking, spilling or emitting of any sewage,industrial waste, pollutant or other waste into waters of the state". Code of Alabama 1975, Section22-22-l(bX9).

12. Discharge monitoring report (DMR) - means the form approved by the Director to accomplishreporting requirements of an NPDES permit

13. EPA • means the United States Environmental Protection Agency.

14. FWPCA - means the Federal Water Pollution Control Act15. Permit application • means forms and additional information that is required by ADEM

Administrative Code Rule 335-6-$-.08 and applicable permit fees.

16. Point source - means "any discernible, confined and discrete conveyance, including but not limited toany pipe, channel, ditch, tunnel, conduit, well, discrete fissure, container, rolling stock, concentratedanimal feeding operation, or vessel or other floating craft,... from which pollutants are or may bedischarged." Section 502(14) of me FWPCA, 33 U.S.C. Section 1362(14).

14

17. Pollutant - induces for proposes of this permit, but is not limited to. those ponmtou q*cified inCode of AJ«hj|T" 1975, Section 22-22-l(bX3) and. those effluent characteristics specified toProvision!. A. of this permit

IS. Severe property damage • mesas substantial pbysical damage to property, damage to the treatmentfacilities which causes them to become inoperable, or substantial and permanent low of nanmlresource* which can reasonably be expected to occur in the absence of a bypass. Severe propertydamage does not mean economic loss caused by delays in production.

19. Upset - meant an exceptional incident in which there is an unintentional and temporaryooDcompliance with technology-based permit discharge limitations because of factor* beyond thereasonable control of the permittee. An upset does not indode noncompliance to the extent caused byoperational error, improperly designed treatment facilities, inadequate treatment facilities, lack ofpieventive maintenance, or careless or improper operation.

20. Waters • means "[ajn waters of any river, stream, watercourse, pond, lake, coastal, ground or surfacewater, wholly or partially within the state, natural or artificial. This does not include waters whichare entirely ctmRntA tod retained completely upon the property of a single individual, partnership orcorporation unless such waters are used in interstate commerce." Code of Alabama 1975, Section22-Z2-l(bX2). Waters "include all navigable waters" as defined in Section 502(7) of the FWPCA, 22U.S.C. Section 1362C7), which are within nV State of Alabama.

21. Week • means the period beginning at twelve midnight Saturday and ending at twelve midnight thefoDowiof Saturday.

SHVRRABniTY

The provisions of this permit are severable, and if any provision of this permit or the application of anyprovision of this permit to any circumstance is held invalid, the application of such provision to othercircumstances, and the remainder of this permit, shall not be affected thereby.

PART IV15

A. OTHER REQUIREMENTS

Permittee shall submit to the Department a certification of continuation of applicationconditions. This certification shall be submitted annually and must be received by ADEMnot later than June 30 of each year.

ALABAMA DEPARTMENT OF ENVIRONMENTAL MANAGEMENTWATER DIVISION - INDUSTRIAL BRANCHNONCOMPUANCB NOTIFICATION FORM

PERMITTEE NAME:.

PERMIT NUMBER:

FACILITY LOCATION:

DMR REPORTING PERIOD:

1. DESCRIPTION OF DISCHARGE:

NONCOMPLIANCE PARAMETER(S):

CAUSE OF NONCOMPLIANCE: (Attach additional pages if necessary)

2. PERIOD OF NONCOMPLIANCE: (Include exact date(s) and time<s) or, if Dot corrected, the anticipatedtime the ooocompli&oce is expected to continue):

3. DESCRIPTION OF STEPS TAKEN AND/OR BEING TAKEN TO REDUCE OR ELIMINATE THENONCOMPLYING DISCHARGE AND TO PREVENT ITS RECURRENCE (attach additional pages ifnecessary):

NAME AND TITLE OF REPONSffiLE OFFICIAL (type or print)

SIGNATURE OF RESPONSIBLE OFFICIAL DATE SIGNED

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APPENDIX B

IV.B AND IV.C NARRATIVE DESCRIPTION OF POLLUTANT SOURCES

PROJ\TF525\RPT\NPDESAPP.W51

GERAGHTY & MILLER. INC.

IV.B. Narrative description of signiflcant materials that are currently or in the past threeyears have been treated, stored, or disposed in a manner to allow exposure to storm water,method of treatment, storage, or disposal; past and present materials management practicesemployed, in the last three years, to minimize contact by these materials with storm waterrunoff; materials loading and access areas; and the location, manner, and frequency inwhich pesticides, herbicides, soil conditioners, and fertilizers are applied.

PRODUCTION FACILITY

The Monsanto site produces p-nitrophenol (PNP), Therminol®, and biphenyls as itsthree primary products. These products are produced on site and shipped off site in bulkquantity via rail cars or tank truck. Powdered PNP, several biphenyl derivatives, andTherminol® is shipped in drums. The raw materials used in production of the above arereceived in bulk and stored in above-ground storage tanks. The attached table summarizesthe raw materials and products handled and stored at the Monsanto facility.

An intermediate product from Thenninol® production and a by-product of biphenylproduction is mixed and used as boiler fuel. The material is a hazardous waste and storedin an above-ground storage tank, where it is transferred to a feed tank then to the boiler.

Wastewater containing PNP is treated in an on-site wastewater treatment system.This system also receives runoff contained in dikes around above-ground storage tanks andleachate from Monsanto's permitted landfill. The treatment system consists of two aerationtanks, one of which is currently used as a holding tank, a clarifier, and a dischargemonitoring station. The effluent is discharged to Anniston POTW.

Pesticides and herbicides are not used at the facility. Triple 13, a fertilizer, is appliedto grass areas.

PROJ\TF525\RFT\NPDESAPP.W51

GERAGHTY & MILLER. INC

LANDFILL

The Monsanto landfill is a RCRA-permitted disposal facility. There are twohazardous waste disposal cells and eight non-hazardous waste disposal cells. Waste disposalin the landfill ceased in December, 1991. Materials buried in the landfill include productionby-products and commercial solid waste.

A soil cover is placed over debris to minimize storm-water contact. Vegetation inthe form of trees, shrubs, bushes, and grass covers the landfill surface.

A leachate collection system is operated at the landfill. Leachate is pumped to aholding tank then to the facility wastewater treatment plant.

PROATF525\RFT\NPDESAPP.W51

GERAGHTY & MILLER. INC.

List of Materials, Handling, and Storage Methods, and Management Practices,Monsanto Chemical Company, Anniston, Alabama.

MaterialBenzene

Biphenyl

Cumene

Santowax R

Santowax C

Santowax Q

Santotar 9

Therminol®

T-59 Ends

4-Nitrophenol

4-Nitrochlorobenzene

Sulfuric Acid

Sodium Hydroxide

Diphenyl oxide

Triple 13

TypeRaw

Product

Raw

Product

Product

Product

Waste

Product

Waste

Product

Raw

Raw

Raw

Raw

Fertilizer

Storage Tank

Above Ground

Above Ground

Above Ground

Above Ground

Above Ground

Above Ground

Above Ground

Above Ground

Above Ground

Above Ground

Above Ground

Above Ground

Above Ground

Above Ground

-

Handling

Received inBulk

Shipped inBulk

Received inBulk

Shipped inDrums

Shipped inDrums

Shipped inDrums

Burned inBoiler

Shipped inDrums

Burned inBoiler

Shipped inDrums/BulkReceived in

BulkReceived in

BulkReceived in

BulkReceived in

BulkReceived in

Bags

StructuralControls

Diked

Diked

Diked

Diked

Diked

Diked

Not Diked

Diked

Diked

Diked

Diked

Diked

Diked

Diked

--

IV.C. Location and a description of existing structural and nonstructural control measuresto reduce pollutants in storm water runoff, and a description of the treatment the stormwater receives including the schedule and type of maintenance for control and treatmentmeasures and the ultimate disposal of any solid or fluid wastes other than by discharge.

PRODUCTION FACILITY

Dikes and grading are used to contain storm water in, and divert storm water around,materials handling and storage areas. Storm water contained in diked areas is transmittedto the facility wastewater treatment plant. Figure 2 shows the location of these structures.Structural controls are also listed in the List of Materials, Handling and Storage Methods,and Management Practices table.

There are vegetative buffer zones throughout the facility. These provide areas forrunoff to infiltrate into the ground, and help to slow the movement of runoff.

A chemical response plan outlines the measures for the prevention and control ofhazardous materials releases to the environment. An onsite response team is responsiblefor its implementation.

LANDFILL

The landfill is completely covered with vegetation. The surface is graded with benchterraces which reduce slope length and divert flow to minimize erosion.

PROJ\TFS2S\RFr\NPDESAPP.WSl

GERAGHTY & MILLER. INC

APPENDIX CV.B. NONSTORM-WATER DISCHARGES

PROJ\TF525\RFT\NPDESAPP.W51

GERAGHTY & MILLER. INC.

V.B. Description of the method used, the date of any testing, and the on-site drainagepoints that were directly observed during a test.

Monsanto is currently authorized under Alabama NPDES Permit No. AL0001201 todischarge storm water from four outfalls: DSN-001, DSN-004, DSN-005 and DSN-006.DSN-007 and the landfill outfalls are not permitted. Outfall DSN-005 no longer exists. Thesource was physically removed, as was associated piping, when parathion production ceased.

Mr. Douglas Hatler of Geraghty & Miller, Inc. of Tampa, Florida evaluated theexisting outfalls for dry weather flow on Wednesday, July 24, 1991. Flow was not observedat three of the four existing production facility outfalls (DSN-004, DSN-006, and DSN-007),or at the landfill outfalls. A continuous flow of water resulting from the discharge of once-through non-contact cooling water was observed at outfall DSN-001.

PROATF52S\RPT\NPDESAPP.W51

APPENDIX DVI. SIGNIFICANT LFJUCS AND SPILLS

PROJ\TF525\RFT\NPDESAPP.WS1

GERAGHTY & MILLER. INC.

1989 RELEASES

DATE01/09/8901/25/8902/05/8902/24/8902/24/8903/08/8903/18/8903/21/8904/10/8904/26/8905/15/8908/15/8909/13/8909/20/8912/28/8912/29/89

01/03/9003/04/9003/26-9004/12/9004/18/9005/03/9006/08/9006/14/9006/25/9006/29/9007/10/9007/10/9007/11/9007/17/9008/02/9008/20/9008/30/9009/05/9009/12/9010/03/9010/09/9010/14/9010/19/9010/22/9010/24/9010/31/9011/07/9011/08/9011/13/9011/30/90

AMOUNT100 GALLONS10 GALLONS1000 POUNDS<1 GALLON150 GALLONS300 GALLONS10 GALLONS30 GALLONS50 GALLONS10 GALLONS30 GALLONS10 GALLON1 GALLON100 GALLONS30 GALLONS55 GALLONS

10 GALLONS2 POUNDS6000 POUNDS2500 POUNDS100 GALLONS<0.1 POUND100 GALLONS10 GALLONS5 GALLONS300 GALLONS5 GALLONS100 GALLONS15 GALLONS2 GALLONS125 POUNDS1500 POUNDS100 GALLONS2 GALLONS500 GALLONS0.5 GALLONS30 GALLONS95 POUNDS200 POUNDS300 GALLONS6.5 POUNDS15 GALLONSDROPS2 GALLONS800 GALLONS200 GALLONS

MATERIALNAOHBIPHENYLNAOHBIPHENYLWW SLUDGEPUPNA PNPBIPHENYLSANTOWAX RALIMETPNPTHERMINOL 66THERMINOL 66BIPHENYLRAW WASTEWATERBIPHENYL

1990 RELEASES

BIPHENYLBENZENEALIMETBIPHENYLFLUX OILBENZENEPNP WASTEWATERSULFURIC ACIDSULFURIC ACIDBLENDED FUEL OILTHERMINOL 59 ENDSBLENDED FUEL OILTHERMINOL 59 ENDSTHERMINOL 66BENZENE50% NAOH SOLNRAW WASTEWATERBENZENENAOHBENZENESANTOTAR 9PNPPNPTHERMINOL 66PNPBIPHENYLBENZENEPNPCRUDE SANTOWAXSANTOTAR 9

DISPOSITIONWASTEWATER TREATMENTWASTEWATER TREATMENTWASTEWATER TREATMENTCLEANED UP/DISPOSEDCLEANED UP/DISPOSEDWASTEWATER TREATMENTWASTEWATER TREATMENTCLEANED UP/DISPOSEDCLEANED UP/DISPOSEDWASTEWATER TREATMENTWASTEWATER TREATMENTCLEANED UP/DISPOSEDCLEANED UP/DISPOSEDCLEANED UP/DISPOSEDWASTEWATER TREATMENTCLEANED UP/DISPOSED

CLEANED UP/DISPOSEDRELEASED TO THE AIRWASTEWATER TREATMENTCLEANED UP/DISPOSEDRETURNED TO PROCESSRELEASED TO THE AIRABSORBED INTO THE DIRTWASTEWATER TREATMENTWASTEWATER TREATMENTCLEANED UP/DISPOSEDCLEANED UP/DISPOSEDCLEANED UP/DISPOSEDCLEANED UP/DISPOSEDCLEANED UP/DISPOSEDRELEASED TO THE AIRWASTEWATER TREATMENTABSORBED INTO THE DIRTCLEANED UP/DISPOSEDWASTEWATER TREATMENTCLEANED UP/DISPOSEDCLEANED UP/DISPOSEDWASTEWATER TREATMENTWASTEWATER TREATMENTCLEANED UP/DISPOSEDRELEASED TO CITY SEWERCLEANED UP/DISPOSEDCLEANED UP/DISPOSEDWASTEWATER TREATMENTCLEANED UP/DISPOSEDCLEANED UP/DISPOSED

1991 RELEASES

01/01/9101/15/9101/17/9101/21/9102/08/9102/11/9102/12/9102/18/9103/07/9104/18/9104/19/9105/06/9105/08/9105/09/9105/10/9105/20/9105/20/9105/20/9105/23/9105/25/9106/18/9106/18/9106/18/9106/19/9106/19/9106/19/9106/27/9107/09/9107/15/9107/19/9107/24/9107/30/91

0.25 GALLON10 GALLONS< 1 POUND15 GALLONS4 GALLONS50 GALLONS1 GALLON12 GALLONS1000 GALLONS10 GALLONS6 POUNDS2 POUNDS1 GALLON2 POUNDS300 POUNDS5 POUNDS15 GALLONS5 GALLONS< 0.5 POUND18 GALLONS< 0.5 POUND< 0.5 POUND< 0.5 POUND< 0.5 POUND< 0.5 POUND< 0.5 POUND2 GALLONS< 0.5 POUND6 POUNDS2 POUNDS25 POUNDS< 0.5 POUND

BLENDED FUELCUMENEBIPHENYLPNCBBLENDED FUELSANTOTAR 9THERMINOL 59BIPHENYLBALANCED POLYMERBLENDED FUELBIPHENYLBENZENECUMENECUMENESANTOWAX CBENZENEBENZENEBIPHENYLCUMENESULFURZC ACIDBENZENEBIPHENYLBIPHENYLCUMENEBIPHENYLBENZENEBIPHENYLTHERMINOL 59SANTOWAX CBENZENECUMENEBIPHENYL

CLEANED UP/DISPOSEDCLEANED UP/DISPOSEDCLEANED UP/DISPOSEDCLEANED UP/DISPOSEDCLEANED UP/DISPOSEDCLEANED UP/DISPOSEDCLEANED UP/DISPOSEDCLEANED UP/DISPOSEDRELEASED TO CITY SEWERCLEANED UP/DISPOSEDCLEANED UP/DISPOSEDCLEANED UP/DISPOSEDCLEANED UP/DISPOSEDCLEANED UP/DISPOSEDRETURNED TO PROCESSCLEANED UP/DISPOSEDCLEANED UP/DISPOSEDCLEANED UP/DISPOSEDCLEANED UP/DISPOSEDWASTEWATER TREATMENTRELEASED TO THE AIRRELEASED TO THE AIRCLEANED UP/DISPOSEDCLEANED UP/DISPOSEDRELEASED TO THE AIRCLEANED UP/DISPOSEDCLEANED UP/DISPOSEDCLEANED UP/DISPOSEDCLEANED UP/DISPOSEDCLEANED UP/DISPOSEDCLEANED UP/DISPOSEDCLEANED UP/DISPOSED

U . S . E P A R E G I Q N I V

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