NC0088081_NPDES Draft Permit_20050720

Michael F. Easley`
Govemor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
July 20, 2005
. Mr. Jaime Kalanta
22 Hedgefield Court
Orange, Connecticut 06477
RECEIVED
JUL 21 2005
DENR - FAYET IEVILLE REGIONAL OFFICE
Subject: NPDES Draft Permit
Permit No. NC0088081
Cookson GW Remediation Site
Anson County
Dear Mr. Kalanta:
Please find enclosed the DRAFT permit for the subject groundwater remediation system for
your review and comment. The permit includes monitoring for various pollutants of concern
that were detected in the groundwater during the site assessment. Limits were implemented for
pollutants detected above the water quality standards. The limits were implemented without
the benefit of dilution because the discharge is to a zero flow stream. At the time of permit
renewal the Division will evaluate the collected effluent data and determine if there is
reasonable potential to exceed any water quality standard or criteria for all the monitored
parameters. Once this evaluation is completed the monitoring requirements in the permit can
be modified to reduce monitoring or implement limits.
Please provide any comments you have regarding the draft permit to this office by
August 26, 2005. At this time, the Division is also publishing a notice in the newspapers of
general circulation in Anson County, inviting public comment on the draft permit. Following
the 30-day comment period, we will review all pertinent comments received and take
appropriate action on the permit renewal.
If you have any questions concerning the draft permit or the other requirements for your
facility, please call me at [phone], extension 553.
Sincerely,
Teresa Rodriguez
NPDES Unit
Cc: NPDES Files
Fayetteville Regional Office
Philip L. Rahn, P.G. - Waters Edge Environmental, LLC
4901 Waters Edge Drive, Suite 201
Raleigh, North Carolina 27606
One
NorthCarolina
,Naturally
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internet: h2o.enr.state.nc.us 512 N. Salisbury St. Raleigh, NC 27604 FAX [phone]
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper

Permit No. NC0088081
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYS 1hM
In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended, the
Cookson D.O.G.
is hereby authorized to discharge wastewater from a facility located at the
Former Cookson Facility
10056 US Highway 52
Ansonville
Anson County
to receiving waters designated as UT to Buffalo Creek in the Yadkin Pee -Dee River Basin in
accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts
I, II, III and IV hereof.
This permit shall become effective
This permit and authorization to discharge shall expire at midnight on January 31, 2009.
Signed this day
DRAFT
Alan W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission
Page 1

Permit No. NC0088081
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked. As of this permit issuance, any previously issued permit bearing this number is no longer
effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the
permit conditions, requirements, terms, and provisions included herein.
Cookson D.O.G.
is hereby authorized to:
1. After obtaining an Authorization to construct.from the Division, construct and operate a
groundwater remediation system located at 10056 US Highway 52, Ansonville, Anson County,
and consisting of:
•. Egnali7ation tank
• Air Stripper
•. Granular Activated Carbon units
2. Discharge from said treatment works, through outfall 001, into an unnamed tributary to
Buffalo Creek, a Class C water in the Yadkin Pee -Dee River Basin, at the location specified on
theattached map.
Page 2

Cookson D.O.G.
State Grid/Quad: G18SW/Ansonville Latitude: 35° 07' 04" N
Longitude: 80° 06' 12" W
Receiving Stream: UT to Buffalo Creek Drainage Basin: Yadkin —Pee Dee River
Stream Class: C Sub -Basin: 03-07-10
North
NPDES Permit No. NC008808 1
Anson County

Permit No. NC0088081
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Beginning on the effective date of this permit and lasting permit expiration, the Permittee is.
authorized to discharge wastewater from a groundwater remediation system from Outfall 001. Such
discharges shall be limited and monitored by the Permittee as specified below:
VM 5
PARAMEIFR
EFFLUENT LIMITATIONS
�
r MONITORING REQUIREMENTS
Monthly
Average,
Weekly
;x Avera e .
;° Dady
Maximum'
Measurement
.. ;Frequency
Sample Type°
Sample
Location„
Flow (MGD) 1
0.10
Continuous
Recording
Effluent
Toluene
11 µg/L
2/Month
Grab
Effluent
1,1 Dichloroethene
6900 µg/L
2/Month
Grab
Effluent
Trichloroethene
92.4 µg/L
2/Month
Grab
Effluent
1,1,1 Trichloroethane
2460 µg/L
2/Month
Grab
Effluent
1,2-Dichloroethane
99 µg/L
2/Month
Grab
Effluent
1,1,2,2-Tetrachloroethane
10.8 µg/L
2/Month
Grab
Effluent
Naphthalene
78 µg/L
2/Month
Grab
Effluent
Methylene Chloride
Monthly
Grab
Effluent
Acute Toxicity 2
Quarterly
Grab
Effluent
Footnotes:
1. All volumes of wastewater leaving the facility shall be monitored. Flow may be measured using a flow
totalizing device. If the discharge is not continuous, flow may be monitored weekly by an instantaneous
flow estimate. If no discharge occurs during a given month, the permittee shall indicate "No Discharge" on
the monthly Discharge Monitoring Report (DMR) to the Division.
2. Acute Toxicity (Fathead Minnow). Monitoring, Quarterly during months of January, April, July, and
October, See Supplement to Effluent Limitations and Monitoring Requirements Page - Special Conditions
A (2).
THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR VISIBLE FOAM IN OTHER THAN TRACE AMOUNTS.
Page 4

Permit No. NC0088081
A. (2.) ACUTE TOXICITY PASS/FAIL PERMIT LIMIT (QRTRLY)
The permittee shall conduct acute toxicity tests on a quarterly basis using protocols defined in the
North Carolina Procedure Document entitled "Pass/Fail Methodology For Determining Acute
Toxicity In A Single Effluent Concentration" (Revised -July, 1992 or subsequent versions). The
monitoring shall be performed as a Fathead Minnow (Pimephales promelas) 24 hour static test.
The effluent concentration at which there may be at no time significant acute mortality is 90%
(defined as treatment two in the procedure document). Effluent samples for self -monitoring
purposes must be obtained during representative effluent discharge below all waste treatment. The
tests will be performed during the months of January, April, July, and October.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the month in which it was performed, using the parameter
code TGE6C. Additionally, DWQ Form AT-2 (original) is to be sent to the following address:
Attention: North Carolina Division of Water Quality
Environmental Sciences Section
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section no
later than 30 days after the end of the reporting period for which the report is made.
Test data shall be complete and accurate and include all supporting chemical/physical
measurements performed in association with the toxicity tests, as well as all dose/response data.
Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is
employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring
is required, the pennittee will complete the information located at the top of the aquatic toxicity
(AT) test form indicating the facility name, permit number, pipe number, county, and the
month/year of the report with the notation of "No Flow" in the comment area of the form. The
report shall be submitted to the Environmental Sciences Section at the address cited above.
Should any single quarterly monitoring indicate a failure to meet specified limits, then monthly
monitoring will begin immediately until such time that a single test is passed. Upon passing, this
monthly test requirement will revert to quarterly in the months specified above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, then
monthly monitoring will begin immediately until such time that a single test is passed. Upon
passing, this monthly test requirement will revert to quarterly in the months specified above.
Should any test data from either these monitoring requirements or tests performed by the North
Carolina Division of Water Quality indicate potential impacts to the receiving stream, this permit
may be re -opened and modified to include alternate monitoring requirements or limits.
Page 5

Permit No. NC0088081
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum
control organism survival and appropriate environmental controls; shall constitute an invalid test
and will require immediate follow-up testing to be completed no later than the last day of the
month following the month of the initial monitoring.
Page 6

DENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NC0088081
Facility Information
>Applicant/Faclity Name
Cookson D.O.G. / Former Cookson Facility GW Remediation site
:Applicant Address -
22 Hedgefield Court, Orange CN 06477
?Facility Address '
;;t`
10056 US Highway 52, Ansonville, NC 28007
Permitted Flow (MED)
s
0.10
Typeof Waste '
Treated Groundwater
Facility: Classification:
Class
Permit Status.°
New
'County: f-
`
Anson
Miscellaneous
Receiving Stream„ ;
UT to Buffalo Creek
Regional -Office _;
FRO
Stream Classifcation
C
State Grid/ USES Quad
G18SW / Ansonville
,303(d)`Listed?
No
Permit Writer
Teresa Rodriguez
si Ban/Subbasin,
Yadkin 03-07-10
Date „' _
7/6/05
Drainage Area (mil)•
*�
'° '� f.#'M
Lat. - 35° 07' 04" N Long° 80° 06' 12". W
ummer 7Q10 (cfs) -
0
Wintar=7Q10 (cfs)
0Q2_(cf0)
0
Average Flow(cfs) _,;�
I, (%); `
;�'°
100 •
Summary: The former Cookson Fibers, Inc. usedto manufacture polyester and nylon fibers. The
site is now owned and operated by Premier Fabrics. Soil and groundwater assessment activities at
the site detected fuel oil constituents and volatile organic compounds in the groundwater. A
Comprehensive Site Assessment and a Corrective Action Plan have been submitted to the Aquifer
Protection Section. An Engineering Alternatives Analysis was submitted along with an NPDES
permit application for a discharge of 0.10 MGD of treated groundwater.
Alternative Analysis:
An Engineering Alternatives Analysis was prepared for the Cookson facility by Waters Edge
Environmental, LLC. The following alternatives were evaluated:
1. Conection to the Town of Ansonville — The town could only accommodate 10,000 gpd of
effluent flow.
2. Reuse — The existing facility (Premier Fabrics) will be able to reuse only 10,000 gpd.
3. Land Application — Infiltration gallery at the site ($32,039)
4. Direct discharge to an UT to Buffalo Creek ($10,237)
The most economical alternative is the direct discharge.
Proposed treatment: The proposed treatment system will consist of 17 groundwater recovery
wells, an equalization tank, a 75 gpm shallow 4-tray air stripper, and two 1,000 pounds granulated
activated carbon units. The estimated discharge is 50 to 70 gpm.
Existing stream conditions: The unnamed tributary to Buffalo Creek is a zero flow stream.
Buffalo Creek is not rated in the Yadkin River Basin Plan.
Fact Sheet
NPDES NC0088081
Page 1

Permitting strategy:
Pollutants of Concern - Analyses of the groundwater at the site detected. VOCs and fuel
components. Attachment A presents the maximum detected concentration for each pollutant
compared to the state standard or criteria. Pollutants detected above the water quality
standards were given limits. The limits are implemented without dilution since the discharge is a
zero flow stream.
Parameter
Monitoring/Limit
Toluene
Daily maximum limit 11 pg/L
1,1 Dichloroethene
Daily maximum limit 6900 pg/L
Trichloroethene
Daily maximum limit 92.4 pg/L
1,1,1 Trichloroethane .
Daily maximum limit 2460 pg/L
1,2-Dichloroethane
Daily maximum limit 99. pg/L
1,1,2,2-Tetrachloroethane
Daily maximum limit 10.8 pg/L
Naphthalene
Daily maximum limit 78 pg/L
Methylene Chloride
Monthly monitoring
Flow — The flow will be limited to 0.10 MGD based on thecapacity of the groundwater treatment
system.
➢. Quarterly Aquatic Toxicity - Toxicity testing is required for all discharges of complex
wastewaters .
PROPOSED. SCHEDULE FOR PERMIT ISSUANCE
Draft Permit to. Public Notice:
Permit Scheduled to Issue:
NPDES DIVISION CONTACT
July 20, 2005
September 12, 2005.
If you have questions regarding any of the aboveinformationor on the attached permit, please
contact Teresa Rodriguez at [phone] ext. 553.
NAME: (/fry`- G- DATE: 1//0S.
Fact Sheet
NPDES NC0088081
Page 2

REGIONAL OFFICE COMMENTS
NAME: DATE:
SUPERVISOR DATE:
Fact Sheet
NPDES NC0088081
Page 3

a
Data Comparison
Maximum Detected vs. Water Quality Standards and Criteria
Cookson Facility
NPDES Permit NC0088081
I`All analytes reported in ug/I: nn1ess liotei
fBt
Vr 0
s� o
fPf� �Jf 04,max
Q 2r
fir '
ofaP t lLJ
fe�fN �"�;d!!t
TABLE 2 Analytes
s s
dC4f•
%
C
c�
fjj
!
`4�
fr�
T
d 4 s .*+'f.4".
�
n' r k
Aad' 54
'°�
VOL-97IlE;ORGANCSm <
• ...
,
o.
F`
,T; z
ba ...,max; n
Benzene
5.93
1.19
71.40
NC standard
C
n-Butylbenzene
5.22
x
C
sec-Butylbenzene
ND
x
C
tert-Butlybenzene
ND
X
C
cis-1,2 Dichloroethene
43.00
x
C
1,1-Dichloroethane
1200.00
x
19500.00
RAIS
C
1,1-Dichloroethene (DCE)
140000.00
6900.00
340.00
19000.00
ECOTOX, NRWQC
L
Isopropyl Benzene
13.00
x
C
n-Propylbenzene
5.22
x
C
p-lsopropyltoluene
10.00
x
C
MTBE
18.00
X
C
Naphthalene
197.00
78.00
ECOTOX
L
Tetrachloroethene (PCE)
2500.00
0.69
NRWQC
C
Trichloroethene (TCE)
1400.00
92.40
NC standard
L
1,1,1-Trichloroethane (TCA)
160000.00
2460.00
•ECOTOX.
L
1,2,4-Trymethylbenzene
2.80
x
C
1,3,5-Trimethylbenzene
ND
x
C
1,2-Dichloroethane
420
0.38
99
EPA
L
1,1,2,2-Tetrachloroethane
25
10.80
NC standard
L
Toluene
500
11
NC standard
L
Ethylbenzene
61
520
620.00
5,700
ECOTOX, NRWQC
C
Total Xylenes
470
780.00
NC, EPA
C
Chloroform
79
902
5.70
470
ECOTOX
C
Methylene chloride
3,400
11,000
4.70
1,600
EPA, ECOTOX
M
Vinyl chloride
29
0.25
525.00
EPA, NC
• C
C = cut - no monitoring required
M = monitor only - no permit limit
L = add permit limit
NRWQC-National recommended water quality criteria
ECOTOX - USEPA ECO TOXicology database
RAIS - Risk Assessment information system

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