NC0005762_Facility Update_20070216

WE STPOINT
HOME
February 16, 2007
Mr. Gil Vanzani
North Carolina Department of Environment & Natural Resources
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Re: WestPoint Home, Inc.
NPDES Permit NC0005762
Scotland County
Dear Mr. Vanzani:
This letter is a follow-up to our telephone conversation last week regarding our facility in
Scotland County, near Wagram. This facility has for many years been a very large, vertically -
integrated textile manufacturing plant, producing terry products. The operations included all
facets of production from spinning/weaving to dyeing/finishing, fabrication, and distribution.
This facility also included a small carpet dyeing operation that was not acquired when we bought
a portion of J. P. Stevens. That portion of the plant now belongs to Gulistan Carpets. All of the
wastewater from the complex is treated on site in our wastewater treatment plant (WWTP) and
discharged under the permit referenced above.
As we discussed, WestPoint Home (WPH) is closing all of its manufacturing operations at the
facility and will retain only the distribution center, which discharges no process wastewater. The
Gulistan Carpet Plant is remaining in operation, as well as the steam plant that services the entire
facility. These two discharges, which previously comprised only about 10-20% of the flow, will
now make up basically all of the process wastewater to be treated. The current permit allows a
discharge of up to seven million gallons per day (MGD) but that has now dropped to less than
one MGD.
In order to see how the DENR might want to handle this drastic change in operation, we met on
January 31st with several DENR representatives from the Fayetteville Regional Office, including
Belinda Henson in the Water Quality Section. We indicated at that meeting that we had retained
a well-known textile wastewater treatment consultant, Edwin Barnhart, to recommend the best
course of action to ensure continued compliance with our permit. We further indicated that he
would be preparing a report to summarize his recommendations. At that meeting, Ms. Henson
suggested that I give you a call to discuss the DENR preferred course of action.
I understood from our conversation that you might be willing to leave the current permit as it is
until it becomes clearer what the ultimate plan for the site might be. You also requested that I
forward you a copy of Mr. Barnhart's report once it was received.
Environmental Dept., 3300 23rd Drive, Valley, AL 36854, Phone: [phone], Fax [phone]

Page 2
Attached are copies of two documents that I received from Mr. Barnhart following his visit. The
first is entitled Wagram Process Modifications 2007. This report discusses the changes that have
occurred in manufacturing and then makes recommendations on how to modify the WWTP
operation so as to ensure that permit compliance is maintained. The report covers each treatment
step and also points out four areas that need to be closely monitored. Because the incoming
COD/BOD is reduced so drastically, the basic proposal is to convert the activated sludge process
to an aerated lagoon system, using the large equalization basin as the aerated lagoon. This should
provide the necessary treatment without the necessity for expensive modifications that might
affect the ultimate use of the WWTP by a future purchaser. The second document, Process
Conversion Procedure, is a step-by-step description of how to manage this conversion.
It is uncertain how long WPH will remain in the wastewater treatment business in that we and
DENR have learned that there is interest by several local government entities in possibly
acquiring this WWTP for use as a regional treatment facility. Over the coming days, we will be
exploring this and other possibilities to maximize the value of this asset. We intend to keep
DENR informed throughout this process.
Once you have had the opportunity to review this information, please let me know how we need
to proceed and whether changes in the permit are necessary. If you have any questions, please
give me a call at 706-645-4515.
Sincerely,
Eddie Lanier
Director — Environmental Department
Attachments
C: Ms. Belinda Henson DENR - Fayetteville Regional Office
Mr. Don Register DENR - Fayetteville Regional Office

EDWIN L. BAR OE HA \r y. J1 (
922 Stone Crab Cove
Fripp Island, SC 29920
Phone [phone]
E-mail [e-mail]
Mr. Eddie Lanier
Eng'g & Environmental Dept.
WestPoint Home, Inc.
3300 23rd Drive
Valley, AL 36854
Mr. Yancy Helton
Engineering Dept
WestPoint Home
P.O. Box 388
Wagram, NC 28396
February 7, 2007
Wagram Process Modifications, 2007
The Wastewater treatment system operated by WestPoint Home at Wagram, North
Carolina, is designed to treat a combined waste from Textile and Carpet manufacturing as
well as the domestic sewage from the manufacturing site. The Textile manufacturing
operations at the site are being discontinued. The Carpet manufacturing will continue and
this waste flow, along with a small amount of domestic sewage, will be the sole loading
to the wastewater treatment system. The existing treatment system will have to be
modified to accommodate the change in loading and waste type.
Loading from the Carpet Mill
The manufacturing activities at the Carpet Mill vary significantly from season to season
and with varying market conditions. The plant produces nylon carpet that is tufted and
backed elsewhere. The lower production period is in the fall and winter months while
higher production is usually in the spring and summer period. During low production, the
facility usually runs one continuous production line, 16 hours a day, for four or five days
each week. In times of higher production, the mill will run two continuous production
lines and possibly some small Becks (batch -type dyeing equipment) for 16 hours/day -
five days a week. The waste flow during the periods of low production is about 1.5
million gallons/week and during high production is about 3.0 million gallons/week. The
plant uses mostly acid dyes. The COD of the waste is about 1000 mg/1 to 1200 mg/1. The
BOD of the waste is low, generally less than 200 mg/l.

The flow of domestic sewage comes from a work force of 250 people and is expected to
average less than 10,000 gallons/day for a five-day week. The BOD loading will be about
50 pounds/day.
Process Modifications
Carpet wastes are typically treated in aerated lagoons or low -rate activated sludge
systems. The detention time required in an aerated lagoon is usually 7 to 10 days while
activated sludge systems usually operate at a F/M of less than 0.2.
The existing plant is very large relative to the amount of waste to be processed. The
amount of COD available is insufficient to maintain a viable culture in an activated
sludge system. The equalization pond has a volume of 10 million gallons and is more
than sufficient to serve as an aerated lagoon, providing a detention time varying from 20
to 40 days, depending on production. The waste flow can proceed from the aerated lagoon
to the existing mixer/flocculator where chemicals to aid in settling can be added if
necessary. The waste will then flow to a single clarifier for final settling. There is an
effluent contact basin available if needed.
pH Levels
The aerated lagoon should operate at a pH greater than 6.5. If the pH drops below that
level, caustic should be added to balance the system. Although the carpet mill uses acid
dyes, much of the acidity will disperse as the waste is treated.
Aeration Requirements
The COD of the waste entering the lagoon will vary from 2000 pounds/day to 4000
pounds/day. The oxygen requirements for complete treatment will be somewhat less than
the COD applied. Floating mechanical aerators will be used to provide the needed
oxygen. Two 50 HP units will provide in excess of 4800 pounds of oxygen /day. These
units can replace two of the mixers that are presently in the pond. The aerated lagoon will
then have two 50 HP aerators and two 40 HP mixers. This is sufficient to provide the
needed oxygen and prevent short-circuiting.
Mixer/Flocculator
The treated wastewater from the aerated lagoon will be pumped at a constant rate to the
mixer/flocculator unit. If necessary, chemicals will be added to aid settling or provide
disinfection. No modification of this unit operation is necessary.
Clarifiers
A single clarifier will be needed. One clarifier will provide a detention time in excess of

20 hours with an overflow rate of 65 gallons/day/ft2. The amount of solids accumulating
in the clarifier will be monitored and solids removed to the existing aerobic digester as
needed.
Other Process Considerations
There are several process concerns that may require consideration.
1. Fecal Carry -through - There is domestic sewage in the system. Under the prior
conditions, the detention time in the equalization tank, while subjected to a high
pH, provided a sufficient kill to meet the permit standard. This may not be true in
the future. The long detention time may be adequate but that is not certain. If fecal
organisms survive the aerated lagoon, it will be necessary to provide disinfection.
A chlorine -based chemical can be added at the mixer and will be effective through
the flocculator. This should provide the necessary control. The remaining chlorine
should be oxidized in the clarifier but if it is not, a final reduction could be
accomplished in the final contact basin.
1. Color - Color is not likely to be a problem. A modern carpet mill loses little dye.
Any dye that does enter the system should be oxidized in the aerated lagoon. If
excessive color does pass through the aerated lagoon, it can be removed
chemically at the mixer/flocculator.
1. Toxicity/Phenol - Toxicity and phenol were associated with early "Stain blocker"-
type chemicals. In a modern mill, discharge of these chemicals is eliminated to a
very high degree. Should this type of problem develop, control at the source is the
appropriate action.
1. Algal growth - The aerobic lagoon has a long detention time and a large surface
area. It is possible that excessive algal growth may develop. Algae can be
removed at the mixer/flocculator unit if needed.
Respectfully submitted
Edwin L. Barnhart DEE PE [ret]

ED'VV'IN J. ]3ARNIIii 1!\
922 Stone Crab Cove
Fripp Island, SC 29920
Phone [phone]
E-mail [e-mail]
Wagram Wastewater Treatment System
Process Conversion Procedure
February 2007�/
Prepared by: Edwin Barnhart . / z�/0
To: Eddie Lanier/ Yancy Helton
Introduction
This document will outline a procedure to convert the existing WWTP, designed to treat
the entire Wagram complex , to a facility to treat only the Carpet manufacturing facility
and a limited amount of domestic sewage. A discussion of the process development can
be found in a report entitled " Wagram Process Modification 2007"
The wastewater flow from the Carpet Mill is expected to average about 0.5 MGD, five
days a week. The waste strength is anticipated to be 1150 mg/1 of COD. The flow of
domestic sewage, is expected to be 0.01 MGD during the work week.
It is important to note that any changes will occur very slowly. The detention time of the
flow in the equalization pond will be about one month. This means that any changes in
the liquid quality will be slow to occur. Doing a lot of sampling and measurement will
not add significantly to process management.
The proposed process is to convert the equalization pond to an aerated lagoon. After
treatment in the lagoon, the treated waste will be pumped at a steady flow rate to the
mixer/flocculator and on to final settling in the clarifier. The need to add chemicals to aid
settling or for disinfection will be determined from operating experience.
Procedure
Install two 50 HP aerators in the equalization basin. These units may replace two of the
existing mixers. Install a pump at the exit end of the pond to pump to the pond effluent to
the mixer/flocculator. This pump should be able to pump over the range of 0.3 MGD to
0.7 MGD. Start the aerators. Check the pH in the pond. The pH should be kept above
6.5. In the beginning, the pH may still be high but it should lower quickly to the desired
level. The desired pH range is between 6.5 and 7.0. A somewhat higher pH is also fine.
Note that although the Carpet waste is acidic, many of the compounds will degrade
during treatment allowing the pH to rise. If the pH is too low, adjust it with caustic - a

little at a time. For example, if 200 gallons of caustic is needed, add it at a rate of 10
gallons/hour. Continue to flow through the existing plant (aeration basin) for about two
weeks.
After two weeks, check the COD exiting the equalization pond. If there are a lot of solids
present, check the settled waste. If the COD is under the permit limit, discontinue
running through the main aeration basin and begin pumping directly to the
mixer/flocculator, and then discharge through the clarifier.
Thereafter begin regular testing. Measure the dissolved oxygen at the exit end of the
lagoon. There should be at least 1 mg/1 of oxygen present. Observe the suspended solids
to see if they are settling out in the clarifier. A quantative measure of solids can be
developed by settling the effluent in an Imhoff cone and recording the volume of solids
after one hour.
Check the depth of solids in the clarifier. Do not let the sludge blanket build up too much
or it will produce gas and overflow. The COD/BOD of the discharge should be tested as
required by the permit. Some sampling of the composite influent from the Carpet mill
should be collected at least one day each week. The pH should be checked twice a week
until there is some data on plant performance. The frequency of testing can then be
modified, based on the rate of change of the parameter of concern.
Should chemical addition be needed to aid solids settling or disinfection, the procedures
for this activity will be developed when the waste samples are available.

March 9, 2007
WE STPOINT
HOME
DEN @F=9.
PAR 14 2007
Mr. Gil Vinzani
North Carolina Department of Environment & Natural Resources
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Re: WestPoint Home, Inc. — Wagram Complex
NPDES Permit NC0005762
Scotland County
Dear Mr. Vinzani:
0
Last month, I sent you a letter (dated 2/16/07) that discussed the recent changes in our operation
near Wagram. Since our dyeing and finishing plant closed a few months ago, the loading and
flow has greatly diminished and our existing activated sludge treatment plant will need some
process modifications to ensure that we can continue to meet our existing permit. Before this
letter was drafted, we had also talked via telephone, and you requested that I send a copy of our
consultant's recommendations so that DENR could more easily determine what course of action
might be best. Given the fact that a sale of the treatment plant to a third party might be
considered, we requested process modifications rather than structural changes. This would
consist of converting the existing equalization basin to an aerated lagoon and taking the aeration
basin out of the treatment process. This makes sense because the current food:microorganisms
(F:M) ratio is not sufficient to maintain a viable biomass population in a basin that large.
In our telephone conversation yesterday, you indicated that the situation had been discussed
within your office and that some type of permit modification would be required. You gave us the
option of requesting a minor modification with basically the same monitoring requirements, or a
major modification that might greatly reduce the testing requirements at the expense of a much
longer time being required for approval.
We are electing to request a minor modification with basically the same sampling requirements.
If we see that this change causes some difficulties or is overly burdensome, we reserve the right
to later request a major modification to save costs. This approach will allow us to proceed with
the changes right away and let the possible major modification wait until later.
Environmental Dept., 3300 23`d Drive, Valley, AL 36854, Phone: [phone], Fax [phone]

Page 2
If you have any questions or need additional information, please give me a call at 645-4515.
Sincerely,
Eddie Lanier
Director — Environmental Department
Attachments
C: �1Vds: EelindaIensonI�IVRY na3�etteville RegonalOffice
Mr. Don Register 115ENR - Fayetteville Regional Office