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HomeMy WebLinkAboutNC0005762_Fecal Coliform POA_200310294•110,1-7 off?. WESTPOINT STEVENS October 29, 2003 Ms. Belinda S. Henson North Carolina Department of Environment & Natural Resources Fayetteville Region — Department of Environmental Quality 225 Green Street — Suite 714 Fayetteville, NC 28301 Re: Fecal Coliform Plan of Action WestPoint Stevens Wastewater Treatment Plant Wagram, Scotland County NPDES Permit NC0005762 Dear Ms. Henson: LOUT S 2003 `%' Please find attached two copies of Plan of Action — Fecal Coliform Compliance Improvement, which outlines actions taken to date and future work that is designed to address periodic fecal coliform compliance issues at our Wagram Complex. This document is submitted according to your request dated August 27, 2003. If you have any questions or need additional information, please give me a call at 706-645-4515. Sincerely, Eddie Lanier, ' . Director — Environmental Department attachment POST OFFICE BOX 71, 507 W. 10TH STREET, WEST POINT, GEORGIA 31833 • AREA 706 645-4000 Plan of Action Fecal Coliform Compliance Improvement WestPoint Stevens - Wagram Complex Wagram, Scotland County, North Carolina NPDES Permit No. NC0005762 Prepared by: WestPoint Stevens Environmental Department 3300 23rd Drive Valley, Alabama 36854 October 30, 2003 _ [[gT )3 !I 2003 Plan of Action Fecal Coliform Compliance Improvement WestPoint Stevens - Wagram Complex Wagram, Scotland County, North Carolina NPDES Permit No. NC0005762 Prepared by: WestPoint Stevens Environmental Department 3300 231d Drive Valley, Alabama 36854 October 30, 2003 Prepared by: Eddie Lanier, P.E. Director — Environmental Department WestPoint Stevens Inc. t Date Table of Contents Page No. I. Introduction 1 II. Background 2 III. Conclusions 6 IV. Recommendations 7 Tables 1. History of Fecal Coliform Exceedances 8 Appendices A. Fecal Coliform Study performed by Arcadis December 30, 1999 L Introduction The WestPoint Stevens (WPS) Wagram Complex is located in Wagram, North Carolina. The Complex includes a terry yarn and weaving plant (Scotland Plant), and a dyeing and finishing plant (Bob Stevens Plant) that produces finished towels from woven fabric received from several plants in the Southeast. It also houses a carpet dyeing and finishing operation that is owned by Gulistan Carpets. These operations had formerly been a part of J. P. Stevens. The process water used at all three plants is withdrawn from the Lumber River and treated in a water filter plant owned by WPS. All of the wastewater produced by these facilities is discharged to a wastewater treatment plant (WWTP) that is owned by WPS and operated by Bob Stevens Plant personnel. This plant is permitted to discharge up to 7.0 million gallons per day of treated wastewater to the Lumber River under NPDES Permit No. NC0005762. One of the parameters monitored by this permit is fecal coliform bacteria (coliform). Over the past few years, the WWTP has periodically exceeded the permitted limit for coliform of 400 colonies/100 ml (daily maximum) and/or 200 colonies/100 ml (monthly geometric mean). Despite several actions to address the situation, the WWTP continues to experience occasional permit exceedances for coliform. The North Carolina Department of Environment and Natural Resources (NCDENR) has requested a Plan of Action (Plan) that addresses the causes of the noncompliance and outlines the actions that will be taken to prevent the recurrence of future violations. The Plan is also required to have a timeframe for the implementation of the proposed actions. The following is intended to fulfill these requirements. r- II. Background The Bob Stevens Plant began operation in 1965 as a Springs Mills (now Springs Industries) plant. The WWTP was constructed in the late 60's or early 70's after the passage of the Clean Water Act. The facility was purchased by J. P. Stevens in 1974 and later by WestPoint Pepperell (WPP) in 1988. WestPoint Pepperell's name was changed to WestPoint Stevens in 1993. As stated above, the WWTP receives wastewater from three different manufacturing operations. 1. Bob Stevens Plant, which is the largest contributor, discharges wastewater from towel bleaching, dyeing, and finishing operations. 2. Gulistan Carpets owns a carpet dyeing operation located inside the Bob Stevens facility and also discharges to the WWTP. 3. WPS Scotland Plant is a yarn -making, yarn -dying and weaving facility that discharges only a small percentage of the total flow. It has two wet manufacturing process, slashing (which is a low -water -use operation) and yarn dyeing. A central boiler room supplies steam to all three plants and discharges boiler blowdown to the WWTP. All three facilities discharge sanitary wastewater to the WWTP. This sanitary flow is collected in a separate sewer system within each plant and does not join the process sewer system until it gets outside the building. In addition, there are several detached buildings (filter plant, boiler room, wastewater lab, guard houses, etc.) that have rest rooms and which also discharge into the main outfall to the WWTP. The percentage of sanitary flow in the total flow to the WWTP is very small (<1 %). The WWTP was upgraded in 1991 with the addition of an equalization basin, mixer- flocculator, sludge thickener, and sludge digester. It was upgraded again in 1993 to handle an increased rate of production in manufacturing. This upgrade included an enlargement of both the equalization basin and the aeration basin, the replacement of the aeration equipment and the addition of mixers in the aeration basin, and the installation of a third clarifier. At the time the 1993 addition was made, coliform compliance was discussed, and the consultant believed that the combination of the high pH of the incoming wastewater with the longer retention time in the equalization basin would effectively kill any coliform bacteria contained in the water. The compliance history of the WWTP for coliform prior to the purchase by WPP-(now WPS) is not known. In 1991, the year that the WWTP was first upgraded by WPS, the WWTP effluent exceeded the fecal coliform limit a total of ten times, five daily maximum exceedances and five monthly average exceedances. In 1992, after the upgrade, there was only one monthly average violation for the entire year (325 versus a limit of 200 colonies/100 m1). In 1993 there were five exceedances (four daily maximums and one monthly average). After the completion of the 1993 upgrade, the WWTP had no exceedances of the fecal coliform limit during the entire year of 1994. 2 For the next few years the plants experienced occasional elevated fecal coliform levels, usually on one day during a month. These were typically separated by extended periods of compliance, and could usually be attributed to a particular situation. As each apparent cause was addressed, compliance would follow for a while and then another exceedance would occur. Most of the elevated results during the period of 1995-2000 occurred during the spring (March -June). See Table No. 1 fora summary of all coliform testing results from 1991 to the present. In 1998, WPS was approached by Scotland County, who was installing a collection system to expand their wastewater collection capability in that area. The contact was made to determine whether the WPS might be interested in routing their sanitary sewage to the County system. An investigation was made to identify any possible grant money that might be available to assist in this connection. When it was discovered that grant money was not available, WPS received estimates of the costs to pipe the sanitary sewage to the new County sewer line. Because of the size of the facility and the location where the connection to the complex's sanitary sewer system would need to be made, it was judged that this alternative was not economically feasible. i— In 1999, WPS retained ARCADIS Geraghty & Miller (ARCADIS) to perform a coliform study to identify the sources of coliform and to make recommendations on the best way to address the occasional permit exceedances. A copy of this report is attached in Appendix A. It identified several potential sources of coliforms for the WWTP: 1. Sanitary waste from the manufacturing facility, 2. Filter backwash from the water filter plant (coliform levels in the raw river water were as high as 2500), and 3. Water removed from the sludge in the thickener and returned to the aeration basin. ARCADIS further identified several actions that could be taken, and recommended that a preliminary design and cost study be undertaken for the following, so that the most feasible actions could be taken: 1. Isolating the sanitary wastewater from the plant discharge and directing it to the County sewer system, 2. Disinfecting the raw river water at the intake, 3. Installing a grinder pump on the sanitary discharge to improve the disinfection of the solids by the high -pH wastewater in the equalization basin, 4. Operating the equalization basin at a high level to increase the contact time with the high -pH process wastewater, 5. Installing a filter plant backwash water clarifier to thicken the solids from the filter plant (allowing the solids to be directed to the WWTP sludge digester rather than to the equalization basin), 6. Evaluating the possibility of subdividing the equalization basin to prevent the potential short-circuiting of coliform from the influent pipe to the exit end of the basin, and 7. Modifying the mixing equipment in the equalization basin to reduce solids buildup and to increase solids contact with the high -ph process wastewater. Since Option No. 1 had previously been evaluated and gauged not economically feasible (it was also noted to that Option No. 1 alone could not guarantee compliance given the coliform levels in the river water and filter plant sludge), and Option No. 4 would have compromised the purpose of the equalization basin, WPS elected to pursue Option No. 5: removing the filter plant solids from the equalization basin. It was hoped that by removing this source of solids, then the need for No. 7 (improving equalization basin mixing) would be unnecessary. The action was accomplished by routing the filter backwash to a holding tank and then to an existing sludge thickener (which had been idle following the installation of a gravity belt thickener) to remove excess water before sending the solids on to the WWTP digester. The water removed was sent to the equalization basin for contact with the elevated pH. In order to remove another potential source of excess coliforms, the permeate from the sludge gravity belt thickener was also rerouted from the aeration basin to the equalization basin to provide additional contact with the higher pH to kill any residual coliform. An additional expected benefit to removing the filter plant solids from the equalization basin was the control of organic acid production in the anaerobic sludge deposits that they had been producing. These acids tend to moderate the pH (which hinders coliform treatment) and also stimulate the growth of certain strains of filamentous bacteria that inhibit settling in the clarifiers. Loss of solids also raises the potential of elevated coliform levels in the effluent, based on the coliform population found in the digester solids. Option No. 2 is partially addressed by adding bleach at the water filter plant and maintaining a chlorine residual in the process water. Some estimates of the costs associated with Option No. 3 were prepared but were not pursued at that time because of concern that this approach would not address the problem of coliform in the filter plant sludge. It was felt that by removing the filter plant sludge from the equalization basin, one source of coliform would be removed and the remaining coliform would receive improved treatment for the reasons outlined above. Design work for Option No. 5 was done and the filter plant sludge dewatering system was placed in operation in late 2002. In conjunction with this work, a new bar screen was also installed on the influent line with the hope that this would assist in breaking up fecal material before it reached the equalization basin. However, the WWTP has continued to have occasional elevated coliform levels in the effluent, and the occurrence has gradually become more frequent during the past three years. Even -so, most elevated results have been typically followed by several readings that are compliant. The wastewater consultant for the plant believes that the occasional high coliform results are caused by small particles of fecal matter that are able to make it through the treatment system intact. The sanitary sewage flows by gravity to the WWTP and is lifted up to the equalization basin by a screw pump, which does little to break up fecal particles. The surviving particles provide the coliform bacteria a refuge from the high -pH water in the equalization basin and the disinfection that would normally be provided. It is likely that the presence of one of these particles in the effluent composite sample produces the occasional high coliform results. It also appears that the opportunity for this situation is increased when the WWTP experiences settling problems. For the past two or three years, the WWTP has battled a persistent filamentous bacteria problem that has resulted in periodic episodes of poor settling. This correlates with the increased number of fecal exceedances. WPS has tried many different ways to address the situation, including chlorination of the return sludge, the addition of polymer at the clarifiers, and dredging the equalization basin (twice). Each time there is some initial improvement but the filamentous bacteria eventually return. Since the request for this Plan was received from the NCDENR, WPS has discussed the situation with their wastewater treatment consultant who has recommended that the Food to Microorganisms Ratio (F:M) in the system be reduced. He believes that the type filament that is persistent at the WWTP is one that thrives in a high F:M system and that the adjustment will reduce the population of that filament while also improving the performance of the WWTP. The mixed liquor suspended solids level had gradually been reduced over the past couple of years to allow the WWTP to handle the settling problem. Following his recommendation, WPS has taken steps to reduce the F:M and has seen an apparent reduction in the filamentous population. At this point the full effect of the change cannot yet be determined because one of the three clarifiers drives failed last week and the WWTP has been running on only two clarifiers. Once the third clarifier is back in normal operation, it is hoped that settling will improve and any surviving fecal particles will be retained in the sludge. I III. Conclusions As mentioned above, it is believed that the occasional lapses in coliform treatment efficiency are the result of small particles of fecal matter that make their way through the WWTP intact, and which are occasionally collected in the composite sample. This phenomenon appears to be more likely to occur during periods of poor settling. The actions already taken by WPS related to the adjustment of the F:M Ratio are expected to reduce the frequency of coliform exceedances. Additional action may be required to guarantee that future coliform exceedances do not occur. 1 IV. Recommendations In order to further reduce the chance of coliform exceedances, WPS is proposing to assess four potential courses of additional action. These include the following: 1. Install a chlorination/dechlorination system on the effluent from the WWTP. 2. Install a solids grinder on the sanitary wastewater stream before it reaches the point where it is co -mingled with the process wastewater. This would require similar equipment at any location where a remote restroom facility connects to the combined flow, or the rerouting of each of these sites to a septic tank. Alternatively, a larger unit could be installed on the combined flow after it passes through the bar screen. 3. Reroute the sanitary flow to the Laurinburg-Maxton sewer system. Although this alternative has previously been deemed not economically feasible, there may be other sources of money now available to assist in the project. 4. Install baffles in the equalization basin to maximize contact time and to minimize the chance of short-circuiting. Following this assessment, WPS will prepare a summary report that outlines the findings and identifies the recommended course of action. This report will be submitted to NCDENR for approval before any work is begun. The report will include the estimated cost and the expected time required to implement each alternative. WPS proposes to provide that report within 90 days of the approval by NCDENR of this Plan. Fi I� I-i ,_J Table No. 1 History of Fecal Coliform Exceedances Date Monthly Maximum (Colonies/100m1) Limit is 400 Monthly Average Geometric Mean (Colonies/100m1) Limit is 200 Jan-93 234 142 Feb-93 397 20 Mar-93 230 127 Apr-93 688 185 May-93 TMTC 52 Jun-93 310 15 Jul-93 114 77 Aug-93 643 409 Sep-93 754 123 Oct-93 104 18 Nov-93 113 62 Dec-93 84 42 Jan-94 123 121 Feb-94 31 25 Mar-94 200 89 Apr-94 250 67 May-94 44 22 Jun-94 26 25 Jul-94 250 157 Aug-94 128 92 Sep-94 3 1 Oct-94 68 12 Nov-94 7 4 Dec-94 32 18 Jan-95 40 15 Feb-95 3 2 Mar-95 .. 900 157 Apr-95 5000 98 May-95 108 70 Jun-95 11 9 Jul-95 60 24 Aug-95 23 5 Sep-95 73 31 Oct-95 6- 5 Nov-95 16 6 Dec-95 7 6 Jan-96 5 3 Feb-96 8 3 Mar-96 2 1 Apr-96 3 1 Date Monthly Maximum (Colonies/100m1) Limit is 400 Monthly Average Geometric Mean (Colonies/100m1) Limit is 200 May-96 16 4 Jun-96 5400 1125 Jul-96 98 63 Aug-96 60 49 Sep-96 104 27 Oct-96 8 3 Nov-96 2 1 Dec-96 33 13 Jan-97 5 2 Feb-97 20 5 Mar-97 54 40 Apr-97 2200 78 May-97 2500 46 Jun-97 580 144 Jul-97 50 12 Aug-97 2 2 Sep-97 13 5 Oct-97 3 2 Nov-97 8 5 Dec-97 2 2 Jan-98 98 57 Feb-98 210 61 Mar-98 230 48 Apr-98 2000 127 May-98 3 3 Jun-98 56 24 Jul-98 300 24 Aug-98 240 168 Sep-98 310 198 Oct-98 25 5 Nov-98 270 255 Dec-98 98 91 Jan-99 430 185 Feb-99 55 43 Mar-99 50 20 Apr-99 27 16 May-99 56 13 Jun-99 84 44 Jul-99 270 66 Aug-99 41 35 Sep-99 90 89 Oct-99 15 7 Nov-99 31 10 Dec-99 72 12 Jan-00 220 21 Feb-00 21 6 Mar-00 2100 20 9 Date Monthly Maximum (Colonies/100m1) Limit is 400 Monthly Average Geometric Mean (Colonies/100m1) Limit is 200 Apr-00 2 2 May-00 1100 99 Jun-00 13 5 Jul-00 11 5 Aug-00 4 3 Sep-00 25 17 Oct-00 3 2.4 Nov-00 50 16 Dec-00 90 38 Jan-01 560 167 Feb-01 106 11 Mar-01 3800 152 Apr-01 154 68 May-01 88 2 Jun-01 15 7 Jul-01 1100 62 Aug-01 240 31 Sep-01 1000 139 Oct-01 100 20 Nov-01 600 179 Dec-01 100 56 Jan-02 260 56 Feb-02 154 21 Mar-02 28249 631 Apr-02 49100 562 May-02 118 59 Jun-02 290 92 Jul-02 62 48 Aug-02 24 5 Sep-02 240 93 Oct-02 2000 49 Nov-02 410 10 Dec-02 5100 49 Jan-03 310 150 Feb-03 86 26 Mar-03 380 18 Apr-03 2300 260 May-03 5900 267 Jun-03 400 33 Jul-03 240 45 Aug-03 56 14 10 Appendix A i i II w: . ARCADIS GERAGHTY & MILLER Fecal Coliform Study December 30, 1999 PRE P A R E D FOR WestPoint Stevens, Wagram NC Fecal Coliform Study December 30, 1999 PREPARED FOR WestPoint Stevens, Wagram NC r Prepared by: Senior Project Engineer Water and Waste Management Feca/ Col/form Study Prepared for. WestPoint Stevens Bath Products Division PO Box 388 Wagram, NC 28396 Prepared by: ARCADIS Geraghty & Miller, Inc. 420 Park Avenue Greenville South Carolina 29601 Tel 864 242 1717 Fax 864 235 9062 Our Ref.: G5023210.0000 Date: December 30, 1999 This document is intended only for the use of the individual or entity for which it was Reviewed b►:, prepared and may contain information that is privileged,confidential, and exempt from disclosure under applicable law. Any dissemination, distribution, or copying of IWW Department Manager 7 thisIdocument is strictly prohibited. Water and Waste Management Table of Contents I. EXECUTIVE SUMMARY 1 II. BACKGROUND 2 III. SUMMARY OF FECAL COLIFORM SAMPLING RESULTS 5 IV. OPERATIONAL ISSUES 7 V. CONCLUSIONS AND RECOMMENDATIONS 8 TABLES 1 FECAL COLIFORM RESULTS 5 FIGURES 1. FACILITY SITE SAMPLING LOCATION PLAN 3 2. WWTP FLOW SCHEMATIC 4 APPENDICES A. Project Progress Reports and Meeting Minutes B. Laboratory Analyses for Fecal Coliform GS023210.0002/Rpt.docrev1 12/30/99 z�• ri WestPoint Stevens Bath Products Division Fecal Coliform Study I. EXECUTIVE SUMMARY The WestPoint Stevens textile manufacturing facilities located in Wagram, NC, have a wastewater treatment plant (WWTP) that discharges to the Lumber River. The treatment facility operates without a conventional wastewater disinfection process to control fecal coliform. The facility meets fecal coliform permit levels the majority of the time, however, over the years has had occasional excursions. WestPoint Stevens has determined to take an active role in investigating viable alternatives to conventional disinfection by source control, operational or physical plant modifications to reduce fecal coliform organisms in the WWTP discharge. This proactive response is designed to eliminate the occasional fecal coliform excursion. ARCADIS Geraghty & Miller (AG&M) has been contracted to assist in this effort by examining the river water, wastewater and areas within the plant and treatment systems. As described in this report, AG&M found fecal coliform levels in various locations: the Lumber River intake water, the water plant backwash, the combined process and sanitary wastewater and parts of the wastewater treatment plant. Based upon the evaluation presented in this report, it is our opinion that there is the potential to isolate or treat these fecal coliform sources for better control and to provide additional attenuation in the wastewater treatment plant. ARCADIS Geraghty & Miller recommends that WestPoint Stevens proceed with a preliminary design and cost study to evaluate the implementation of the following actions: • Isolate the sanitary sewer collection from the process wastewater system and treat the sanitary wastewater separately with disinfection or pump it to a local municipality. • Disinfect the river water at the river intake structure. • Pretreat the sanitary sewer wastewater by using grinder pumps to improve contact/disinfection of the solids with the high pH process wastewater. • Isolate the water plant filter backwash water and associated solids from the wastewater equalization basin • . Reduce the solids accumulation in the wastewater equalization basin by improving the basin mixing. • Reduce wastewater equalization basin short-circuiting by installing curtains WestPoint Stevens should achieve additional fecal coliform reduction as the fecal coliform sources are treated or eliminated and plant modifications are made. In the event that these modifications are found to be insufficient to consistently meet the NPDES wastewater discharge limits, a positive means of disinfection such as the addition of chlorine, hypochlorite or ozone to the discharge effluent will be required: GS023210.00021pptdo evl 1213099 WestPoint Stevens Bath Products Division Fecal Coliform Study II. BACKGROUND WestPoint Stevens operates a textile manufacturing and wastewater treatment facility located in Wagram, NC. WPS has two facilities on this site, the Scotland and Bob Stevens plants. Gullistan owns and operates a carpet facility also located on the site. The Scotland plant produces -bath goods thread and woven fabric from cotton. The Bob Stevens plant bleaches, dyes, and finishes the fabric into bath goods. The two WPS plants and the carpet mill produce a combined waste stream of approximately 3.0 MGD. This flow is comprised of both process and sanitary wastewater. The site layout is shown on Figure 1. These plants require a significant volume of water for the production of these textile goods. The WPS facility operates a water treatment facility to supply water from the Lumber River for the production processes. The water plant uses coagulation, flocculation, filtration and chlorination to remove particulate, color and bacterial contamination. Treatment plant solids are accumulated and wasted to the WWTP equalization basin for disposal. The textile plants use the treated river water in various process and utility operations. The wastewater is collected in a gravity system along with the sanitary wastewater from all three manufacturing facilities and piped to the wastewater treatment plant (WWTP). The WWTP facility is permitted for a flow of 4.5 MGD and operates under NPDES Permit NC0005762 The discharge permit has a fecal coliform limit of 200 fecal coliform / 100 ml average and 400 / 100 ml maximum. Figure 2 is a schematic of the WWTP. ARCADIS Geraghty & Miller investigated the sources of fecal coliform and, as sampling results became available, the initial sampling regime was modified to further identify and confirm sources. AG&M completed a series of four sampling events. The sampling events included periodic project updates and discussions between WPS and ARCADIS that are included in Appendix A. GS023210.0002/Rpt-0oval 2 12/3099 NOTE: Numbers represent sampling locations as shown in Table 1 WestPoint Stevens, Wagram NC Site and Sampling Location Plan Taken from Hydroscience Preliminary Engineering Report January 25, 1991 Figure 1 G5023210.000LRpFdot 3 11j :u .'lj�. " Ih III ,III. Ill11%1_ _ .. =_IIIi11=111 _4u�llj-• 'L' I,.1 /7.70:0001 7:001•, M1r In w... F fl 1t.0.N (I:1;1 MN 000 3001J 11.I[:MN 0M1317] 6004 10gM10,11I11 MN 000 .1157'M 7Mem 7N [1.3w 1101.0• Iw 0-0 .tI to,, B■1,,.. 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Shut ; I- "ri�'"�i1r -. x I ii iI i iI IR i Arun: -r1-5--u- ., OM--1 r1 .IlSO] Mt" 033J 1V71ni10 Ott. 1113475 11.0 010I010 ' — 1t010011 R 101 Sans 15001 mml1 110MM' MIN • 001711103 10101 00110.011 MVI 111110./ OM■1r1,N.n I]JCYJ O.IV 000iti sot 'Groton 4'I72: UNvy�� __IC) Ci i6CP 1+4 --"" r19 r77 L..1 1.16.11 '+4? ►}I I.i.n L11A • -/ ..___.1 [....1 I MMl I I I 10.05 r/1 10Ma17S !Moat L. 1 10+4 ►+4 I venom I I L 11d L .i '11IVM 0NIIS01I•141 L d 0 Z V1Nt lip -mid 0 a i WestPoint Stevens Bath Products Division Fecal Coliform Study III SUMMARY OF THE FECAL COLIFORM SAMPLING RESULTS Wastewater samples were taken to determine the fecal coliform present at various locations in and around the facility. Grab samples were collected from locations at the river inlet, water plant clearwell basin, filter backwash trough, manufacturing plant process area, WWTP equalization basin, aeration basin, thickener filtrate, digester and the WWTP effluent. These locations are numbered on Table 1 and shown on Figure 1 and Figure 2. Samples were delivered to PACE Laboratories in Charlotte, NC for analysis. All samples were delivered within the required holding time. The results of these analyses are shown in Table 1 and the lab reports are included in Appendix B. Table 1 Fecal Coliform Results # Sample Location Fecal Coliform Results (# FC/100mL) 8/18/99 9/2/99 9/30/99 10/26/99 1 River Intake 140 ND 2500, 620 - 2 Water Filter Backwash 180 ND - - 3 Raw Waste Influent 400 ND - - 4 Digester Solids 140,000 7,000 - - 5 EQ Basin —Discharge 1,000 ND - - 6 Sludge Thickener — Filtrate 300 ND - - 7 Final Effluent ND ND - - 8 Aeration Basin ND ND - - 9 EQ Basin — Solids ND ND ND x 3 *ND x 6 10 Dye Range - - NDx2 11 Water Plant Filter Basin - - ND x 2 ND x4 * pH readings of the equalization basin solids, 7.3, 8.6, 11.9, 9.9, 11.0, 7.9 Fecal Coliform NPDES Permit Limits are 200 FC/100 ml average; 400 FC/100 ml max. ND = None Detected G502321O.OoO ppt-0ocayt 12/3W99 5 WestPoint Stevens Bath Products Division Fecal Coliform Study The results in Table 1 show that some of the samples had fecal coliform results in excess of the permit limits. The river intake water, filter plant backwash, raw waste influent, thickener filtrate, digester and equalization basin discharge were the locations identified with fecal coliform levels exceeding permit levels. These are discussed below. River Water and Filter Backwash (#1,2): The river water samples had fecal coliform results well above the effluent limits placed upon the WPS discharge. It is assumed that these fecal coliform are from warm-blooded animal discharges upstream of the intake. These fecal coliform in the river water appear to be the source of fecal coliform found in the filter plant backwash. The backwash water and solids are discharged into the wastewater equalization basin and are a source of fecal coliform found in the WWTP. Influent Wastewater (#3): The WWTP influent is a mix of sanitary and process wastewater. The influent was found to contain fecal coliform. The combined influent wastewater along with the filter backwash water is screened, pumped and stored in the 3.0-MG equalization basin. Sludge Thickener and Digester (#4,6): Fecal coliform were detected in the sludge thickener filtrate and WWTP digester solids. Normally, when the sludge is transferred to the digester from the aeration basin, the fecal coliform are in the waste MLSS. As the sludge moves through the thickener, some of the coliform are lost to the thickener filtrate. Aeration Basin and Effluent (#5,6,7,8): The aeration basin and effluent samples did not detect fecal coliform. This is somewhat inconsistent with the equalization and thickener/digester results since the equalization basin wastewater enters the aeration basin and the MLSS is wasted to the digester via the thickener. This may be due to the natural attenuation of the fecal coliform organisms that occur with water temperatures less than 98 degrees F. during the cooling and detention in the aeration basin. Filter Plant and EQ Basin Solids (9,11): The water plant filter basin solids had ND results when the river intake had positive readings. This would seem to indicate that the chlorine in the water plant is providing disinfection or the fecal coliform naturally attenuate in the basin solids. The last sample of solids collected was also a ND and this sample was taken when the chlorination system was out of service. G50I3210.0002/Rpt-dpQey1 iv3099 6 WestPoint Stevens Bath Products Division Fecal Coliform Study IV OPERATIONAL ISSUES In addition to sampling for fecal coliform, AG&M has addressed operational issues that could affect fecal coliform levels. There were two sources identified, the first was the fecal coliform found in water plant backwash solids. To confirm this as a source, AG&M collected several extra sets of solids samples from the bottom of the filter backwash basin. Based on the sample data from the six basin solids samples, fecal coliform were not found. The second concern was contamination of the equalization basin solids from the fecal coliform in the manufacturing facility effluent. As mentioned previously, the WWTP influent is mixed sanitary and process waste and is typically at pH 11 to 12 due to caustic used in the manufacturing finishing and bleaching processes. This high pH is important and has a significant effect in reducing the fecal coliform bacteria in the wastewater. However, when the WWTP influent is pumped to the equalization basin some of the fecal material may settle as solids to the bottom of the equalization basin and survive the high pH. The equalization basin has limited mixing capabilities that allow a significant build up of solids in the basin. These solids degrade forming organic acids that lower the pH in the solids. The equalization basin solids sampled October 26 indicate that the pH varies from 7.3 to 11.9 but the samples taken did not contain fecal coliform. Fecal coliform do not survive in a high pH environment but they do survive in warm neutral pH conditions. Although the samples of the equalization basin solids did not indicate the presence of fecal coliform, it appears that the solid accumulation may negatively affect the attenuation of fecal coliform provided by the high pH in the plant influent. In addition to the solids buildup in the equalization basin, there is concern that there is short-circuiting between the influent pipe location and the equalization basin pump suctions due to the absence of basin baffles. The basin is also occasionally operated at low levels that reduces the detention time significantly. GS023210.0 02/Rpt.doaev1 12/3099 7 WestPoint Stevens Bath Products Division Fecal Coliform Study V. CONCLUSIONS AND RECOMMENDATIONS River Water as a Fecal Coliform Source The samples collected confirm that the river is contaminated with fecal coliform. This may year. samples should be periodically taken of the backwash water until results indicate consistent Lv/ 1}4 ,gitG 7-13 Gd be seasonal, the result of high summer river water temperatures, and this source should be 0 A/L 7 f} Pdb verified by monthly fecal coliform sampling during rest of the Additional disinfection of the river water. The location of the disinfection may need to be relocated to the river water intake pump discharge. This will improve mixing and contact time UnAiiP resulting in disinfection that is more consistent. Sanitary Wastewater as a Fecal Coliform Source The fecal coliform data collected from the influent wastewater confirmed the presence of fecal coliform. The sample of process wastewater (#10) indicated no fecal coliform. There are several options for controlling or treating the sanitary waste as a source. The first option is to treat and/or disinfect the sanitary waste separately prior to combining with the process waste. This method has been tried at other facilities with limited success and complete control or segregation is difficult. This WWTP receives sanitary waste from the manufacturing plants plus sanitary waste at the water and wastewater plants. The success of this option would depend on the ability to identify and segregate all sanitary sources and that they would remain segregated. It would also depend on adequate disinfection before combining with the process wastewater for discharge. The second option is to segregate the sanitary waste and pump it to a local municipality (POTW) for treatment. This has some of the same disadvantages as the first because it is difficult to eliminate all cross connections. This option has the advantage of not needing separate treatment and disinfection but the loss of nutrients to the process waste treatment system may require supplemental nutrient addition The third option is to identify the sources of sanitary waste connections to the process sewer and install sanitary sewage grinder pumps in each source to macerate the sewage solids into a slurry. This pretreatment would increase the exposure of the solids to the process waste resulting in better attenuation of the fecal coliform bacteria hi SooPe&� it) Lim rArs Wdua ,tom c CiOtP pus -Mt ' 5-6 ni JAI CoviimAn GS023210.0002A1p1.dooevt 12/3099 8 WestPoint Stevens Bath Products Division Fecal Coliform Study Equalization Basin as a Treatment Process The equalization basin provides the detention of wastewater containing fecal coliform in the presence of high pH that is known to be an effective disinfectant. The level of disinfection will depend on the time, temperature and pH in the basin. The effectiveness is improved by increasing detention and having good mixing to contact the fecal coliform 45 S d1P72511 bacteria with the high pH. The settled solids from the wastewater and filter plant along with inadequate mixing contribute to the inconsistent fecal coliform removal. Recommendations ARCADIS Geraghty & Miller recommends that WestPoint Stevens address the fecal coliform sources, increase the effectiveness of the equalization basin disinfection and reduce solids accumulation in the equalization basin by considering the following: — • Disinfect the river intake water prior to entering the water treatment facility, possibly at the discharge of the river pumps to maximize the contact time and mixing. • Install a filter plant backwash water clarifier for water plant solids thickening. The solids would be wasted directly to the WWTP sludge digester or a sludge disposal truck. Water would be returned to the filter plant intake. — • Install sanitary sewage grinder pumps on all sources of sanitary wastewater to reduce fecal coliform containing solids to a slurry. • Operate the equalization basin at a high water level to increase the detention time of influent with the high pH of the process waste. • Evaluate the possibility of dividing the equalization basin into multiple sections to prevent short-circuiting of fecal coliform from the influent pipe area to the aeration basin. • Evaluate/modify/replace mixing equipment to reduce solids buildup and increase solid contact with the wastewater cao-7-Li 23e:3/6A/2/„Ap-71_, Based on the results of this fecal coliform study and the above recommendations, ARCADIS Geraghty & Miller proposes that WestPoint Stevens proceed with a preliminary design and cost/benefit study for the recommended corrective actions for fecal coliform compliance. WPS would then evaluate the cost and benefit analysis to select the options that are appropriate to proceed with. The design study would then be developed into a Preliminary Engineering Report (PER) for submittal to NCDENR . GS023210.0002/Rpttlovevl 12/3099 9 Appendix A ARCAD1S GERAGHTY&MILLER Yancy D. Helton Division Director of Engineering Bath products Division Westpoint Stevens Inc. 19320 Airbase Rd. Wagram, NC 28396 910-369-4111 Subject Meeting Minutes and Summary of Activity 8/12/99 ARCADIS Geraghty & Miller Project No. GS023210.0000 Dear Yancy, Thanks again for taking the time to meet with Dave Holland and me on August 18th. To keep you apprised of the results of our sampling activities we will send regular updates. Included in this letter are both sampling program, meeting minutes and a summary of the fecal coliform results from samples taken during our visit. Meeting Minutes: Attending: Dave Holland, Scott Bolo, Yancy Helton, Wesley Adams, and Herman Benton ARCADIS briefly explained the sampling locations and procedures and discussed the various forms of coliform bacteria. Westpoint Stevens (WPS) asked several questions about conditions contributing to fecal coliform levels. Temperature was suspect as discharge water has a relatively high water temperature. Several areas for coliform proliferation were identified as suspect. For example, ARCADIS noted that the EQ basin was at a low level and as such would have a reduced detention time. ARCADIS recommends raising the water level to increase detention time. ARCADIS was asked to consider operational changes and options (other than chlorination) that would reduce the fecal coliforms. Sampling Program: Samples were collected from sites located around the plant as identified in Table 1 (attached). The results varied from non -detect in the effluent to 140,000 per 100 mL in the digester solids. ARCADIS Geraghty & Miller is the worldwide name of Piedmont Olsen Hensley ARCADIS Geraghty & Miller. Inc 420 Park Avenue Greenville South Carolina 29601 Tel 884 242 1717 Fax 884 235 9062 WATER AND WASTE MANAGEMENT Date: 24 August 1999 Contact Scott Bolo Extension: 241-5112 ARCADIS GERAGHTY&MILLER Table 1. Results of Fecal Colifi SAMPLE LOCATION SAMPLE RESULTS (CoVl00ml) RIVER INTAKE 140 WATER FILTER BACKWASH (w/Cl) 180 RAW WASTE INFLUENT 400 DIGESTER SOLIDS 140000 EQ BASIN DISCHARGE 1000 SLUDGE THICKENER FILTRATE 300 EFFLUENT SAMPLE Non -Detect AERATION BASIN MLSS Non -Detect EQ BASIN SOLIDS (edge of liner) Non -Detect Page: 2/3 ARCADIS GERAGHTY&MILLER Yancy D. Helton Division Director of Engineering Bath Products Division WestPoint Stevens Inc. 19320 Airbase Rd. Wagram, NC 28396 910-369-4111 Subject Summary of Sampling Activity 9/2/99 ARCADIS Geraghty & Miller Project No. GS023210.0000 Dear Yancy, On Thursday, September 2nd ARCADIS Geraghty & Miller collected a second set of samples from various locations on your site. Collecting a second set of samples/data points, should confirm the presence of fecal coliforms in the system. Since fecal coliforms from the sanitary waste andriver water are in the system then the potential for fecal coliforms in the effluent is present. The following activities may help to minimize the proliferation of fecal coliforms: 1. Continue to maintain a high equal;ization basin water level and hence longer retention. 2. Keep the pH of the incoming wastestream as high as possible. 3. Minimize in plant process water discharge temperatures - fecal coliforms like warm water. 4. Continue chlorination of incoming river water, prior to the filtration plant. Nonetheless, there will always be the potential for violations when the system is treating both sanitary and process wastewater. As the follow-up to a request by WestPoint Stevens, ARCADIS Geraghty & Miller have evaluated opportunities for upgrade of the facility. At this time, it appears that segregating the sanitary waste from the process waste would prove beneficial and should be investigated as an option. We recommend moving some of the sampling upstream. This will allow us to evaluate the fecal coliform content in the process wastestreams. If sampling confirms that no fecal coliforms are present in the process wastestream then we could investigate segregating the sanitary waste and disinfecting it with either Chlorine, Ozone or UV light. This strategy of testing upstream will ensure that fecal colifonns are not entering the WWTP through the process wastestream. ARCADIS Geraghty & Miner is the worldwide name of Piedmont Olsen Hensley ARCADIS Geraghty & Miller, Inc 420 Park Avenue Greenville South Carolina 29601 Tel 864 242 1717 Fax 884 235 9082 WATER AND WASTE MANAGEMENT Date: 3 September 1999 Contact Scott Bolo Extension: 241-5112 ARCADIS GERAGHTY&MILLER Hence, the likelyhood of success of segregation can be confirmed prior to investigation of the segregation effort and capital investment. The source of the fecal coliforms can be eliminated and compliance can be assured for the WestPoint Stevens Wagram Facility. In an effort to optimize the sampling regime and complete an inital review of the requirements for segregation, ARCADIS Geraghty & Miller would like to review the facility drawings. These drawings will be used to find process outfalls. These locations will then be sampled following Westpoint Stevens approval. We will call in a few days with results of the second sampling event and discuss these additionalsampling options. If you have any questions please do not hesitate to call Dave Holland or myself. Best Regards, Scott T. Bolo M.E. Project Engineer ARCADIS Geraghty & Miller Report Completed by: Scott Bolo Copies: Dave Holland ARCADIS GERAGHTY&MILLER Yancy D. Helton Division Director of Engineering Bath Products Division WestPoint Stevens Inc. 19320 Airbase Rd. Wagram, NC 28396 Subject: Fecal Coliform Project Summary of Activity Sept, 8, 1999 ARCADIS Geraghty & Miller Project No. G5023210.0000 ARCADIS Geraghty & Miller, Inc. 420,Park Avenue Greenville South Carolina 29601 Tel 864 242 1717 Fax 864 235 9062 WATER AND WASTE MANAGEMENT i Dear Yancy, Date: September 23, 1999 ft As mentioned in our letter of August 1999, to keep you apprised of the results of our sampling activities we will send regular updates. Included in this letter you will find a summary of both of the sampling events. Sampling Summary A second set of fecal coliform samples were collected on 9/2/99 from the same sites located around the water and wastewater plant. The September results are as shown in the following table . Results of Fecal SAMPLE LOCATION SAMPLE 8/10/99 (FC/100m1) SAMPLE 9/2/99 (FC/100m1) RIVER INTAKE 140 ND WATER FILTER BACKWASH (w/Cl) 180 ND RAW WASTE INFLUENT 400 ND DIGESTER SOLIDS 140,000 7,000 EQ BASIN DISCHARGE 1,000 ND SLUDGE THICKENER FILTRATE 300 ND EFFLUENT SAMPLE ND ND AERATION BASIN MLSS ND ND EQ BASIN SOLIDS (edge of liner) ND ND This second set of samples contained significantly less fecal coliform when compared to the first set of samples. The cooler weather and the higher equalization basin level and longer equalization time may have resulted in these decreases in fecal coliform levels. The time and temperature both have an effect on the increase or decrease of fecal coliform contamination in the water. ARCADIS Geraghty & Miller recommends that the water level in the equalization basin be maintained as ARCADIS Geraghty & Miller is the worldwide name of Piedmont Olsen Hensley Contact: Scott Bolo Extension: 241-5112 ARCADIS GERAGHTY&MILLER high as possible to maximize the detention times. This is a factor that can be controlled without the expenditure of additional capital. I would like to schedule another sampling event and meeting with you the week of September 27th. At this meeting I would like to discuss the opportunity for sampling upstream in the process and plant wastewater collection system. If you have drawings of the collection system and locations of the process discharges available for this meeting, it would help in identifying possible sampling locations. I will call you early next week and try to firm up a date and time for this meeting to take place. If you have any questions or comments please feel free to contact me at your convenience. Regards, Scott T. Bolo, ME Project Engineer c: Wesley Adams Dave Holland Page: 2/2 RE ARCAD1S GERAGHTY&MILLER Yancy D. Helton Division Director of Engineering Bath Products Division WestPoint Stevens Inc. 19320 Airbase Rd. Wagram, NC 28396 910-369-4111 Subject Meeting Minutes and Summary of Activity 9/30/99 ARCADIS Geraghty & Miller Project No. GS023210.0000 Dear Yancy, Thanks again for taking the time to meet with me on Thursday, September 30. Included in this letter are meeting minutes. Meeting Minutes: Attending: Scott Bolo, Yancy Helton, and Herman Benton ARCADIS Geraghty & Miller reviewed the plant drawings with WestPoint Stevens (WPS) staff. Sanitary waste lines were confirmed to tie into the process wastewater. It appears as if the sanitary lines can be segregated from the process lines without a major effort. However, the accuracy of the as -built drawings is uncertain. WPS indicated a walk through on the plant would be necessary to identify all of the sanitary lines that tie into process wastewater piping. WPS voiced concerns over the level of fecal coliforms in the river water. Recent articles in the local newspaper have documented high levels of fecal coliform in the river water. WPS uses this water as process water for the plant. As the water enters the water plant sludge builds up in the receiving basin. If fecal coliforms are present in the river in high levels this sludge could be another source of fecal coliform bacteria. Based on servations of WPS staff, fecal levels appear to increase in the river water when thereobare high levels of precipitation. Given several recent rain events of significance, WPS and ARCADIS Geraghty & Miller agreed that filter basin solids and equalization basin solids should be checked again for presence of fecal coliforms. WestPoint Stevens (WPS) asked several questions about conditions contributing to coliform analytical positives and the statistical variability of biological tests. WPS is concerned with the accuracy of the fecal coliform test. ARCADIS Geraghty & Miller is the worldwide name of Piedmont Olsen Hensley ARCADIS Geraghty 8 Miller. Inc 420 Park Avenue Greenville South Carolina 29601 Tel 884 242 1717 Fax 884 235 9062 WATER AND WASTE MANAGEMENT Date: 1 October Contact Scott Bolo Extension: 241-5112 1 1 • ARCADIS GERAGHTY&MILLER ARCADIS Geraghty & Miller and WPS agreed that multiple samples would be taken from the same locations in an effort to evaluate the variability of both the test and fecal coliforms in adjacent but discrete locations. If fecal coliforms are not found in the river water or water plant then the coliforms are almost certainly from the WPS plant. Dye Range/ Bleaching Line wastewater was sampled In the event that segregation were chosen as the preferred management method. If coliforms are found to be present in the process line wastewater then it wouldn't make sense to segregate it. Table 1. Testing on 9/30/9 SAMPLE LOCATION SAMPLE TAKEN RIVER INTAKE 2 DYE RANGE / BLEACHING 2 WATER PLANT FILTER BASIN SOLIDS 3 EQ BASIN SOLIDS 3 We will forward the lab results and when they are reported. If you have any questions or comments please feel free to give me a call. Sincerely, Scott T. Bolo, ME Project Engineer ARCADIS Geraghty & Miller 864/242-1717 sbolo@gmgw.com cc: Dave Holland, Herman Benton ARCADIS GERAGHTY&MILLER Yancy D. Helton Division Director of Engineering Bath Products Division WestPoint Stevens Inc. 19320 Airbase Rd. Wagram, NC 28396 Subject Fecal Coliform Project Analytical Summary ARCADIS Geraghty & Miller Project No. GS023210.0000 Dear Yancy, As mentioned in our letter of August 1999, to keep you apprised of the results of our sampling activities we will send regular updates. Included in this letter you will find a summary of all three of the sampling events. Sampling Summary A third set of fecal coliform samples were collected on 9/30/99 from sites located in and around the water and wastewater plants and production areas. The results from these three sampling events are as shown in the following table. Results of Fecal Coliform Testing at WPS Wa ram NC ARCADIS Geraghty & Miller, Inc. 420 Park Avenue Greenville South Carolina 29601 Tel 864 242 1717 Fax 864 235 9062 WATER AND WASTE MANAGEMENT Date: October 2, 1999 Contact Scott Bolo Extension: 241-5112 g SAMPLE LOCATION SAMPLE 8/10/99 (FC/100m1) SAMPLE 9/2/99 (FC/100m1) SAMPLE* 9/30/99 (FC/100m1) RIVER INTAKE 140 ND 2500, 620 WATER FILTER BACKWASH (w/C1) 180 .ND - RAW WASTE INFLUENT 400 ND DIGESTER SOLIDS 140,000 7,000 EQ BASIN DISCHARGE SLUDGE 1,000 ND THICKENER FILTRATE 300 ND EFFLUENT SAMPLE ND ND - AERATION BASIN MLSS ND ND EQ BASIN SOLIDS (edge of liner) ND ND ND, ND, ND DYE RANGE - - ND, ND WATER PLANT BASIN *Du licate 1 - - ND, ND p samp es were collected from each location. Therefore, each location has multiple data. ARCADIS Geraghty & Miller is the worldwide name or Piedmont Olsen Hensley ARCADIS GERAGHTY&MILLER As we suspected the river water did contain high levels of fecal coliform. However, fecal coliforms were not detected in the water plant basin. This would seem to indicate that the chlorination being used at the water plant can be effective in removing fecal coliform from the water. However, this was not the case with the August sampling event. Additional confirmation tests should be taken during the next sampling event. It may be that the carbon in the filter bed offset the chlorine activity for a brief period of time. Fecal coliforms were not detected in the equalization basin solids either. As mentioned in the notes from the second sampling event, the cooler weather, higher equalization basin level and longer equalization time may be causing these decreases in fecal coliform levels. I would like to schedule another sampling event and meeting with you the week of October 18th. I would like to discuss additional sampling in the process and plant wastewater collection system. We should also discuss the findings of the plant walk through to identify cross connects between sanitary and process wastewater (including the Scotland Plant). I will call you early next week and firm up a date and time for this meeting. If you have any questions or comments please feel free to contact me at your convenience. Regards, Scott T. Bolo, ME Project Engineer ARCADIS Geraghty & Miller sbolo@gmgw.com cc: Wesley Adams Herman Benton Dave Holland LZIL ARCADIS GERAGHTY&MILLER Yancy D. Helton Division Director of Engineering Bath Products Division WestPoint Stevens Inc. 19320 Airbase Rd. Wagram, NC 28396 910-369-4111 _ Subject Meeting Minutes and Summary of Activity 10/30/99 ARCADIS Geraghty & Miller Project No. GS023210.0000 Dear Yancy, Thanks again for taking the time to meet with me on Tuesday, October 30. Included in this letter are meeting minutes and a DRAFT outline of the report detailing findings etc. Meeting Minutes: Attending: Scott Bolo, Yancy Helton, Wesley Adams, Herman Benton and George Brown ARCADIS Geraghty & Miller (AG&M) reviewed both historical findings and the findings from the three sampling events completed to date. WPS indicated that a disinfection system does not appear to meet their goals/needs. Instead WPS indicated that the following items were a priority for the fmal report. The following list are items that were identified as most important:. _.,,,_ 1) Handling of filter plant sludge - Action: propose a method for segregation; 2) Better mixing in the equalization basin - Action: propose methods; 3) Improved aeration in aeration basin- Action: propose methods; 4) Installation of grinder pumps on sanitary lines - Action: evaluate options. Please note these items are a change from the original scope and would require additional information to complete. We will need facility drawings of the water plant, equalization basin, aeration basin, and sanitary collection system. We will also need operating schedules, volumes and wastewater characteristics for the water plant in order to properly size equipment for a preliminary estimate of probable cost. At your request, we will prepare an estimate of time and expense to complete this additional work. ARCADIS Geraghty & Miller. Inc. 420 Park Avenue Greenville South Carolina 29801 Tel 864 2421717 Fax 884 235 9062 WATER AND WASTE MANAGEMENT Date: November 2, 1999 Contact Scott Bolo Extension: 241-5112 ARCADIS Geraghty & Miller Is the worldwide name of Piedmont Olsen Hensley ARCADIS GERAGHTY& MILLER WPS and AG&M agreed that based on the available data the equalization basin and filter backwash and water plant basin solids are a source of fecal coliforms. A portion of the solids come from the water plant. As these solids settle in the equalization basin they promote anaerobic degradation of the organic material in the solids. This anaerobic activity lowers pH in the equalization basin in some locations (see included data) thereby: reducing the effect of high pH plant effluent. WPS and AG&M agreed that the equalization basin and water plant would be sampled again. The location and quantity of samples are listed in Table 1. The water plant chlorine feed was temporarily out of order. Table 1. Testing on 10/26/99 at SAMPLE LOCATION SAMPLE TAKEN pH of Samples WATER PLANT FILTER BASIN SOLIDS 4 (spaced evenly) _ EQ BASIN SOLIDS 6 (spaced evenly in dead -zones) 7.3, 8.6, 11.9, 9.9, 11.0, 7.9 Equalization Basin Sampling 1 2 ID 3 4 6 5 Numbers = Sample Points Page: 2/3 ARCADIS GERAGHTY&MILLER If you have any questions or comments please feel free to give me a call. Sincerely, • Scott T. Bolo, ME Project Engineer ARCADIS Geraghty & Miller 864/242-1717 sbolo@gmgw.com cc: Dave Holland, Wesley Adams, Herman Benton Page: 3/3 Appendix B