NC0005762_Correspondence_19900912

i`90
Christopher N. Zfitffbw "
Assistant Secretary and
Assistant G¢neral Counsel
L
Nco5762
. F "11?)-Lirr
1
West Point Pepperell
September 12, 1990
Mr. M.J. Noland, P.E.
Regional Supervisor
State of North Carolina
Department of Natural Resources
and Community Development
Fayetteville Regional Office
Wachovia Building
Suite 714
Fayetteville, N.C. 28301-5043
4-11-1 SEP 14 1990 lOggaTIET
ENV. MANAGEMENT
FAYETTEVILLE REG. OFFICE
Re: J.P. Stevens & Co., Inc. Wagram Facility
Dear Mr. Noland:
On behalf of WestPoint Pepperell I wish to express ap-
preciation to you for meeting with Jim Walters and myself on Septem-
ber 5, 1990, in order to discuss various developments affecting the
Wagram facility of J.P. Stevens & Co., Inc. As discussed in our
meeting, personnel from WestPoint Pepperell, the parent company of
J.P. Stevens, have been involved in reviewing the operations of the
wastewater treatment plant at the Wagram facility and through the
fine efforts of the Stevens personnel and management at Wagram
changes have been implemented which have resulted in improvements to
those operations. We are continuing to make progress in this regard
and are also reviewing other areas of environmental interest at
Wagram as well. We are hopeful that these efforts will provide ad-
ditional improvements in the near future. We anticipate that we can
complete our review of the draft permit and the recommendations
provided by Hydroscience, Inc. within the next sixty (60) days, at
which time we would like to schedule another meeting with you to
discuss our findings and proposals. If we are able to accomplish
this task sooner we will let you know, but in any event we will stay
in contact with you as we proceed. In the meantime if you have any
questions or comments relating to the Wagram facility you should
feel free to contact Mr. Jim Walters. Jim can be reached in Lumber-
ton at [phone] or at the Wagram facility at [phone].
Thank you for your cooperation.
Very my yours,
��. tA &411
Christop er N. Zodrow
dt
cc: Mr. Bill Crumbley
Mr. Jim Walters
POST OFFICE BOX 71, WEST POINT, GEORGIA 31833 • AREA 404 645-4112

COPY '. U:
TREE• .
DON SAFRi1'
State of North Carolina
Department of Environment, Health, and Natural Resources
Asheville Regional Office
James G. Martin, Governor
William W. Cobey, Jr., Sepretary
DIVISION OF ENVIRONMENTAL MANAGEMENT
WATER QUALITY SECTION
MEMORANDUM
TO:
FROM:
SUBJECT:
August 7, 1990
George T. Everett, Director
Division of Environmental Management
Roy M. Davis, Regional. Supervisor
Division of Environmental Management
Public Meeting
Application for Permit Renewal
J. P. Stevens Company, Inc.
NPDES Permit Number NC0005762
Scotland County
Ann B. Orr
Regional Manager
)j0'
RECEIVED
AUG 141990
TECHN;CAS. SUPPORT 8Rr P4!°H
Pursuant to instructions, I held the subject public meieting on July 17,
1990 in the Scotland County Courthouse in Laurinburg,JN. C. Seventeen
(17) people registered at the door; of these five (5) presented
statements.
J. P. Stevens presently discharges 3.6 MGD of treated process and
domestic wastewater plus other miscellaneous discharges, to the Lumber
River and a tributary, from its terry cloth and carpet dyeing plants.
Discharge 001 is from the wastewater treatment plant and takes place to
the Lumber River along with discharge 003 which is the water plant
discharge. Discharge 002 and 004 are both cooling water discharges to
Big Shoe Heel Creek. The Lumber River at the point of discharge is
C-Swamp-HQW. The classification of the Lumber River further downstream
is WS-III-Swamp-HQW. In this downstream segment Robeson County makes
occasional use of the River as a source of raw water for a public water
supply, relying primarily on wells, whereas the City of Lumberton makes
almost exclusive use of the River as a source of raw water relying
infrequently on wells as a back-up. Both public water treatment plants
are evidently able to satisfactorily treat: water drawn from the Lumber
River except for those occasions occurring a few times each year when
Interchange Building it) Wrnxltin I'lacc. A,heville. NC 2x801 • Telephone-(4-25I.r208

Ge'oi:CJe T _ Everett
Memorandum
August 7, 1Y90
Page Two
J. P. Stevens discharges predominately treated red dye wastewater
during low stream flow conditions. On those occasions the treated
water at both locations can be visibly red in color. Both water
plants, with advance notice, can, using activated charcoal, deal
successfully with the color but obviously at some increased treatment
cost.
The permit in question is designed to insure that raw water drawn into
the two publicly owned water plants is treatable using conventional
methods. A later generation draft than the one we went to public
notice with contains three sets of interim limits for the main
wastewater discharge and a time schedule guiding J. P. Stevens through
an acute toxicity, fecal coliform and color reduction program and
requires compliance with the final limits on April 1, 1993. The final
limit in terms of color is a restatement of the Administrative Code
with the practical goal being discharge of treated wastewater that does
not change the color of the receiving stream.
It is anticipated that the Company will have in its treatment future
the construction of a flow equalization basin, polymer feed units,
flocculation chamber, and effluent diffuser.
Richard Regan, speaking for the local environmental community requested
denial of the permit. Spokesman for the Town of Lumberton and Robeson
County concerned themselves primarily with the issue of the discharge
of color by J. P. Stevens and its impact upon the treatability of water
drawn from the Lumber River.
The current draft permit places limits on Sulfide and Chromium both of
which appear in the effluent guide lines published for this particular
industrial category. Effluent monitoring data spanning the past year
and a half indicate these pollutants to be present at less than
detection limits if at all. The Company has requested a reduction of
the frequency of self -monitoring for these pollutants.
The draft permit presently under consideration differs from the draft
sent to public notice in that three sets of interim limits for the
process/domestic wastewater discharge, designated discharge 001, are
included and color language exceeding the Water Quality Standards is
deleted.
The draft permit limits flow to 4.5 MGD which represents an increase of
0.9 MGD. As no increase in the discharge of pollutants is proposed the
intent of the High Quality Regulations is honored.
Recommendations.
l)
Given the modifications which have been made, I recommend we
go back to public notice with this permit in its final form.
Absence entirely new comments, I recommend against another
public hearing.

Georie T. Everett -
Memorandum
August 7, 1990
Page Three
2
3
Given that the Town of Lumberton and Robeson County
occasionally encounter problems treating raw water to remove
color and that on at least one instance Lumberton produced
pink treated water, I recommend that the J. P. Stevens NPDES
Permit be amended to include the following language. "There
shall be no significant statistical difference between
upstream and downstream color based on a quantifiable
measurement system to be developed from color monitoring data
collected pursuant to Part III, Condition D." on the final
limits page for discharge 001. This in addition to color
related language appearing elsewhere in the permit.
Given that self -monitoring does not indicate the presence of
Sulfide and Chromium in the effluent it is recommended that
limits and testing requirements for these two pollutants be
deleted from the permit. We could use the results of chronic
and acute toxicity testing to inform us if testing for these
pollutants needs to be reinstated.
4) It is suggested that the following condition be added to
address the City of Lumberton's concern about being notified
when J. P. Stevens personnel observe a river condition that
could possibly create a problem with treatment at the water
plant:
The Division of Environmental Management, Fayetteville
Regional Office; City of Lumberton Water Plant and
Robeson County Water Plant shall be notified immediately
whenever J. P. Stevens personnel observe an in -stream
color level which could adversely affect normal water
treatment operations.
Mick Noland has spend endless hours in dealing with the matter of J. P.
Stevens influence on the color of the Lumber River and its impacts upon
downstream water plants. He and I are more than willing to sit with
you, should you require further discussion.
RMD:ls
xc: Steve Tedder
Mick Noland/Tommy Stevens

DIVISION OF ENVIRONMENTAL MANAGEMENT
July 20, 1990
To: Dale Overcash
From: Carla Sanderson(
Through: Trevor Clements
Subject: J.P. Stevens & Co.
Modification for NPDES Permit No. NC0005762
Scotland County
I am writing on response to the letter sent from Mr. Lunney, dated July 13,
1990, concerning the monitoring frequencies for sulfide, chromium, and nickel.
Data collected from January 1989 through May 1990 reported levels of sulfide as
high as 3.35 #/day (14% of the monthly permit limit - 24 #/day) and chromium as
high 1.4 #/day (12% of the monthly permit limit - 12 #/day). Due to the low
levels of sulfide and chromium reported in the effluent, Technical Support would
like to recommend reducing the monitoring frequencies from 2/month to 1/month.
Data was also collected for nickel from November, 1989 through January, 1990.
All the data reported were at levels less than detection. Technical Support
would like to recommend the monitoring frequency for nickel be reduced from
2/month to 1/month. In addition, the limit may be dropped with a year of data
showing no significant values.
If you have any questions concerning this matter, please let me know.
cc: Mick Noland
Central Files

07/01/90
W.J.L.
J.P. STEVENS STATEMENT
TO BE READ INTO THE RECORD
AT THE PUBLIC MEETING IN LAURINBURG, NC, JULY 17, 1990
J. P. Stevens has operated in the present location since the late
1960's. The Company serves as employer to some 2000 residents and
currently generates a payroll of something in the excess of
$50,000,000/annum.
In addition to being the largest employer in the County, the Company
has a vested interest in the welfare of its employees, their families and
the community. That includes a commitment to protecting the environment
in which they live and work.
The Company has always operated within the parameters of their
Discharge Permit, with only a few minor exceptions, over these many
years. The present high quality water status of the Lumber River here in
Scotland County demonstrates that commitment.
The office of the Department of Environmental Management intends to
include new and more stringent water quality limitations in the Company's
new Discharge Permit. Simply put, there are more of us now than ever
before using the same natural resources and the agency has deemed this
necessary to preserve water quality.
The new conditions require certain modifications to be made to the
Company's Waste Treatment Facility. The Company is committed to
accepting the responsibilities required by these new conditions. The new
conditions will require the addition of an equalization basin to control
flow and safely satisfy the Fecal Coliform limitation. The plan also
calls for the installation of a outfall diffuser to comply with a new
acute toxicity requirement should testing demonstrate such a feature to
be necessary. A floculation chamber will be constructed to allow the
controlled supply of a polymer or carbon feed system to minimize color.
It is the Company's intent to submit final drawings and specifications to
the D.E.M. for these improvements and go forward in a responsible
manner. The Company accepts the new requirements and is supportive of
the regulations. It also encourages the citizens of the community to
accept their responsibility and be supportive as well.
FINAL NOTE:
Preliminary layouts of what is envisioned to be required in order to
achieve the new requirements are available for your review.

STEVENSHOMEFASHIONS
J.P. Stevens & Co., Inc.
P.O. Box 388
Wagram, NC 28396
919 369-2231
July 13, 1990
Mr. M. J. Noland
NC Dept. of Environmental Management
Wachovia Bldg., Suite 714
Fayetteville, NC 28301-5043
Terry, Bath & Kitchen
PrrhIw rc Division
JUL 3.8
Lc 7//3
WATER QU.,,LITY
SECTION
RE: TESTING REQUIREMENTS FOR SULFIDES, CHROMIUM AND NICKEL
Dear Mr. Noland:
During our meeting of June 13, 1990, it was agreed that the Owner would
summarize and submit historical test data for the above. It is the
writer's understanding that to obtain relief from this testing a modifi-
cation would be required to the existing regulation. Your offices gave
a commitment to review the issue.
Reports from May, 1989, through May, 1990, were reported in #'s/Day.
The values were derived by using the reported concentration of <.10
and <.04 for sulfide and chromium respectfully. These concentrations
are the detection limits of the equipment at our independent testing
facility and were the same for every single sample tested during 1989
and 1990. More correctly, these amounts should have been reported
as "less than" values which, in every case, would be less than 10% of
the permit limitation. The years of 1988 and 1987 are a repeat of the
same statement.
A data sheet is also attached for nickel which is in the proposed draft
as a new item. A similar mechanism for relief from this testing is
requested when the data sufficiently demonstrates that nickel does not
exist. A time frame of one year's testing is suggested.
Sincerely,
J. P. $TVENS A CO., INC.
JJ i
W. J. Lunney
Div. Dir. of Engineering
Cc: Messrs./Steve Tedder, DEM, Raleigh, NC
Tommy Stevens, DEM, Fayetteville, NC
Ed Barnhart, Hydroscience, Inc., St Helena Island, SC
Gary Church, JPS, Wagram, NC
WJL/mb
Attachment

DATE
PERMIT LIMIT MO. AVG.
PERMIT LIMIT DAILY MAX.
#/DAY #/DAY
SULFIDE CHROMIUM
24.0 #/DAY
49.0 #/DAY
12.0 #/DAY
?4.0 #/DAY
May, 1990 3.27 1.3_
April, 1990 2.92 1.17
March, 1990 3.08 1.23
February, 1990 1.67 1.07
January, 1990 3.00 1.20
December, 1989 1.80 .72
November, 1989 3.00 1.23
October, 1989 2.67 1.10
September, 1989 2.46 .99
August, 1989 2.56 1.02
July, 1989 2.40 .96
June, 1989 2.90 1.17
May, 1989 3.40 1.4C,
April, 1989 3.23 1.29
March, 1989 2.52
February, i9_= 3.35
January, 2:

DATE m 1
January 26, 1990
January 5, 1990
December 29, 1989
December 22, 1989
December 19, 1989
December 15, 1989
November 30, 1989
November 21, 1989
November 8, 1989
November 1, 1989
<.05
<.05
<.05
<.05
<.05
<.05
<.05
<.05
<.05
<.05
PROPOSED PERMIT LIMIT .25
PLEASE NOTE THAT .05 IS THE DETECTION
LIMIT OF THE LABORATORY EQUIPMENT.

G' �V15
(p f 5/qo
S4-e ‘tetAs kes--nvAse,
-Oo 16 oes-t I Lo 3D.±/i3 c\rnoN Av-e) oAcvrasc,
3 (, 3 /D Lpa-P
ikAu d ova So;vv I oo,di w�. vue a5 u} l - U3cts
Z c� 1 d. u o4 �Ilou) awia, ltn(r-eci 0()
\Oac) ►4A/4 s s evu doe -lb ewb vu,a c.w
(j
vvAov- - i -} cw d-( cam U avu da-TA Cis
IN, W-+ 600 J cs Z/a o -r-o a I (ow bcg
00,6 (3.i' s v\_0()(emu.. r 4 c 3ou /ici
L0`, \Px. `i vwe a s.P d (006.)
�_.) CO b e5 - ✓ 0 \ -5 en }}-1}40
4 a1 c15 /Oa (17t,�Q A+tc .)
-} ear v� � CAv'e. I12 - /Dcu,,, Co"e-v,.y4v,e)
3 4- D3(4 4 Low v\Akkij
JLJ vvut-b, co\s) ev cti \(,)a,co-c
_5, Act./ 01 04)60 -I-1 (A)Ct_cD TY-OR)
( OCCO 1 4s @ 106-1 a
skiy\kx - vk,A.A.)4 4-t: Turec)re--()
CASs re i Kts vwfvut V�i car L
-6 So i-Ci. G /- t,� Q ° (�,,,,,u, „-
rt���4 i,
vr;\FTA'ov►,�

BUJ r- a col lu-4 ,'
1 r� L vwt CLA g I c1-1 /( e
e),,w3-0.xtuvv_• ;6‘, T1/(0 y\xu-tAJ boulit
lU ;tzar) iu6uc to .c;---/
(09 , .;t ,k
la-)�
du)-
l(T
4Z3ke co-0
-��✓,µ mks ' 6 , v Luck, 6
LG
C.s4. �'Lkr
\AA 4- to R +o W:aLM
)s a-t/ ea
-e4 - v A
S .
t v‘4.4;(A 0.11&- 4fj
rja \mile la°)0 -5 t4
v

/644
0,6 LALAA_c)
vLs- COO cht,O --ev
Une(ii 50C ��,011'4vs1,

STEVENSHOMEFASHIONS
J.P. Stevens & Co., Inc.
P.O. Box 388
Wagram, NC 28396
919 369 2231
May 10, 1990
N. C. Environmental Management Commission
P. O. Box 27687
Raleigh, North Carolina 27611-7687
Subject: Public Comment Period
Ending May 31, 1990
Relative to J.P. Stevens
N.P.D.E.S. Permit # 0005762
Dear Sir:
dir$ Diu-47-4
ab
Terry, Bath & Kitchen
Products Division.
!4�
775,1S1,
%...4
MAY 25 1990
This correspondence is in response to the Commission's
request for comment as solicited in the "Laurinburg Exchange"
dated April 30, 1990.
Attached is a summary of comments dated 5/15/90 on items in
the Draft Permit which are unacceptable to the Owner. The
comments are the same as submitted on February 2, 1990. As
of the date of this writing, the Owner has not received a
response to the submission.
Sincer-ly
W• �
W. . Lunney
Div. Dir. of rgineering
WJL.jn
Attachment
MAY 2 9 1990
TECHNICAL SUPPORT BRANCH

05-15-90
W.J.L.
Summary of Proposed Position
On Draft Version of Wagram
N.P.D.E.S. Permit
B.O.D A monthly avg. of 1632 #/Day and daily maximum 3263
#/Day is requested.
The permit limitations of 1306 #/Day and 2611 are
the same as they were at a flow of 3.6 MGD. The
avg. flow in this permit is 4.5 MGD.
What is requested is a prorated amount resulting
from the ratio of 3.6 : 4.5.
a. COD
3 Sulfide
T.S.S.
5 Chromium
A monthly avg. of 21397 #/Day and daily maximum
42795 #/Day is requested.
The draft permit limitations of 17118 and 34256 are
the same as they were at a flow of 3.6 MGD. The
avg. flow in this permit is 4.5 MGD.
What is requested is a prorated amount resulting
from the ratio of 3.6 : 4.5.
Long standing historical data demonstrates
that Sulfide occurs in amounts equal to
approximately 10% of the discharge limitation.
Based on this data, semi-annual testing is
reasonable in lieu of the monthly currently being
done. (Certainly not the bi-weekly being
suggested.)
A monthly avg. of 3197 #/Day and maximum 6393 #/Day
is requested.
The draft permit limitations of 2558 and 5115 are
the same as they were at a flow of 3.6 MGD. The
avg. flow in this permit is 4.5 MGD.
What is requested is a prorated amount resulting
from the ratio of 3.6 : 4.5.
Long standing? historical data demonstrates
that Sulfide , occurs in amounts equal to
approximately 10% of the discharge limitation.
Based on this data, semi-annual testing is
reasonable in lieu of the monthly currently being
done. (Certainly not the bi-weekly being
suggested.)

ti Phenols.
Ni. The .25 Mg/L is acceptable. Limited testing
U indicates this element to be below .05 Mg/L in
every test.
It is reasonable to add language that would allow
the deletion of this requirement after monthly
testing over a 12 month period demonstrates this
element to be some fraction of the suggested limit.
(say 20%).
A daily max. of .02 Mg/L is in the
proposed draft with NO daily average. Since the
daily avg. has been deleted, it is suggested to
accept this limitaion with monthly testing. A
trigger mechanism is also suggested that would
require an immediate retest to confirm
non-compliance before a non -compliant status could
be reached based on a single test.
f Fecal Coliform It appears that the current Engr. study will result
in the addition of an equalization basin thereby
rendering this limitation to mute point status. It
is suggested that current monitoring including
frequency be continued exactly the same as it has
in recent years.
Long Term B.O.D. A max. time limit of 50 Days duration is
requested for all BOD testing.
It appears there is little to be gained by
continuing the test beyond this time frame.
Chronic Toxicity Based on the 7Q10 flows and a discharge of 4.5 MGD
the effluent concentration should be 6.5% in lieu
of 12%.
Acute Toxicity
If it exists, criteria for establishing a
non -compliant status is unclear in the present
wording.
A provision could exist that would require
verification of test results (via a repeat test)
prior to the permittee being deemed to be in a
non -compliant status.
The requirement of establishing the LC50 at 90% is
deemed to be virtually impossible.
It is requested to drop this requirement entirely
or set the concentration at some attainable
percentage of 40%.
Alternately, we would be willing to accept
language that would require the owner to develop
and submit for approval a plan for the installation
of a outfall diffuser to eliminate acute toxicity.
This would eliminate the need for testing or the
monitoring of any action level percentage.
This concept carries with it the inherent benefit
it contributes to addressing the color issue.

Color All color language in Part III Condition G
could be replaced with a requirement that the owner
submit an approvable color control program by some
reasonable date.
Additional
Monitoring
Requirements
the Proposed
Draft
New Effluent Monitoring Requirements are Monitoring
included for Copper, Zinc, Total Nitrogen, Total
in Phosphorus, Dissolved Oxygen, temperature and
conductivity. This could be acceptable if the
Total Nitrogen and Total Phosphorus was done
quarterly in lieu of monthly.
Considering the extent and radical increase in
testing expense that this draft permit suggests, it
is reasonable to retain the Priority Pollutant
Analysis Monitoring Requirement exactly where it is
now. Namely at the time of renewal.
Completed...