NC0005762_speculative limits_20081114

Michael F. Easley, Govemor
State of North Carolina
William G. Ross, Jr., Secretary
Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
November 14, 2008
Mr. Eddie Lanier
Director, Environmental Department
WestPoint Home, Inc.
P.O. Box 71
WestPoint, Georgia 31833
Subject: Speculative Effluent Limits
WestPoint Stevens/ Wagram WWTP
NPDES Permit #NC0005762
Scotland County
Dear Mr. Lanier:
This letter is in response to your request for speculative effluent limits for a regional wastewater
treatment facility located at the current Wagram WWTP. Currently, this facility is permitted for flows up
to 7 MGD and the proposed facility would have the same permitted capacity.
Receiving Stream. This facility discharges to the Lumber River, a class WS-IV B; Sw; HQW stream in the
Lumber River Basin. This stream classification does not preclude a discharge of domestic wastewater,
however NCAC 02B .0224(b) does prescribe specific limits for facilities discharging to streams designated
as High Quality Waters (HQW). In addition to the speculative limits given below, DWQ is required to
evaluate limits for toxicants (including whole effluent toxicity) at one half the normal standard.
Speculative Limits. Based on available information, speculative effluent limits for the proposed discharge
of 7 MGD to the Lumber River are presented in below. A complete evaluation of these limits and
monitoring frequencies in addition to monitoring requirements for metals and other toxicants will be
addressed upon receipt of a formal NPDES permit modification request.
Effluent Characteristic
Effluent Limitations
Monthly Average
Weekly Average
Daily Maximum
Flow
7.0 MGD
BOD5, Summer
5.0 mg/L
7.5 mg/L
GODS, Winter
10.0 mg/L
15.0 mg/L
TSS
20 mg/L
30 mg/L
NH3 as N, Summer
2.0 mg/L
6.0 mg/L
NH3 as N, Winter
4.0 mg/L
12.0 mg/L
Dissolved Oxy&en
Minimum 6.0 mg/L
pH
Between 6.0 and 9.0 s.u.
Fecal coliform
200/100 ml
400/100 ml
Total residual chlorine
28 pg/L
Engineering Alternatives Analysis (EAA). Please note that the Division cannot guarantee that an NPDES
permit will be issued with these speculative limits. Final decisions can only be made after the Division
receives and evaluates a formal permit application for the City's proposed discharge. In accordance with
the North Carolina General Statutes, the practicable wastewater treatment and disposal alternative with
the least adverse impact on the environment is required to be implemented. Therefore, a detailed
engineering alternatives analysis (EAA) must be prepared. The EAA must justify requested flows, and
provide an analysis of potential wastewater treatment alternatives. Alternatives to a surface water
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
512 N. Salisbury Street, Raleigh, North Carolina 27604 On the Internet at http://h2o.enr.state.nc.us/
An Equal opportunity/Affirmative Action Employer
NOr Carolina
Naturally

Mr. Eddie Lanier
Speculative Effluent Limits
Wagram WWTP NC0005762
discharge, such as spray/drip irrigation, wastewater reuse, or inflow/infiltration reduction, are
considered to be environmentally preferable. A copy of the EAA requirements is attached to this letter.
Your permit application will be returned as incomplete if all EAA requirements are not adequately
addressed.
Environmental Assessment (EA). Based on the final funding sources and/or ownership of this proposed
regional facility, it may fall under State Environmental Policy Act (SEPA) requirements. A SEPA EA
document must be prepared for all projects that 1) need a permit; 2) use public money or affect public
lands; and 3) might have a potential to significantly impact the environment. Please contact Hannah
Stallings with the DWQ Planning Branch at [phone] to determine whether this project requires the
submittal of an EA or similar environmental document.
Publicly Owned Treatment Works (POTW) Requirements. If the Regional WWTP will be a POTW, the
NPDES permit would include Pretreatment Program conditions as required by 40 CFR 403 and 15A
NCAC 02H .0900. It is likely the current textile operation would meet the criteria for a Significant
Industrial User (SIU). The Interlocal Agreements (ILAs) between the partners specifying ownership and
operational responsibility setups will also need to specify which organizations will have which
Pretreatment Program responsibilities and how the entities will work together to address industrial
wastewater discharge needs. Please contact Dana Folley of the the Pretreatment, Emergency Response,
and Collection Systems Unit (PERCS) at 919-807-6311 to discuss these issues.
Should you have any questions about these speculative limits or NPDES permitting requirements, please
feel free to contact Toya Fields at [phone].
Sincerely,
1�
Gil Vinzani
Supervisor, Eastern NPDES Program
Attachment: EAA Guidance Document
cc: (without Attachment)
Shankar R. Mistry, Ph. D., P.E., 120 North Boylan Avenue, Raleigh, NC 27603-1423
Fayetteville Regional Office, Surface Water Protection
Central Files
NPDES Permit File
Hannah Stallings, Planning Branch
Dana Folley, PERCS
2

Mr. Eddie Lanier
Speculative Effluent Limits
Wagram WWTP NC0005762
discharge, such as spray/drip irrigation, wastewater reuse, or inflow/infiltration reduction, are
considered to be environmentally preferable. A copy of the EAA requirements is attached to this letter.
Your permit application will be returned as incomplete if all EAA requirements are not adequately
addressed.
Environmental Assessment (EA). Based on the final funding sources and/or ownership of this proposed
regional facility, it may fall under State Environmental Policy Act (SEPA) requirements. A SEPA EA
document must be prepared for all projects that 1) need a permit; 2) use public money or affect public
lands; and 3) might have a potential to significantly impact the environment. Please contact Hannah
Stallings with the DWQ Planning Branch at [phone] to determine whether this project requires the
submittal of an EA or similar environmental document.
Publicly Owned Treatment Works (POTW) Requirements. If the Regional WWTP will be a POTW, the
NPDES permit would include Pretreatment Program conditions as required by 40 CFR 403 and 15A
NCAC 02H .0900. It is likely the current textile operation would meet the criteria for a Significant
Industrial User (SIU). The Interlocal Agreements (ILAs) between the partners specifying ownership and
operational responsibility setups will also need to specify which organizations will have which
Pretreatment Program responsibilities and how the entities will work together to address industrial
wastewater discharge needs. Please contact Dana Folley of the the Pretreatment, Emergency Response,
and Collection Systems Unit (PERCS) at 919-807-6311 to discuss these issues.
Should you have any questions about these speculative limits or NPDES permitting requirements, please
feel free to contact Toya Fields at [phone].
Sincerely,
a
Gil Vinzani
Supervisor, Eastern NPDES Program
Attachment: EAA Guidance Document
cc: (without Attachment)
Shankar R. Mistry, Ph. D., P.E., 120 North Boylan Avenue, Raleigh, NC 27603-1423
Fayetteville Regional Office, Surface Water Protection
Central Files
NPDES Permit File
Hannah Stallings, Planning Branch
Dana Folley, PERCS
2

Re: Scotland County Regional WWTP
Subject: Re: Scotland County Regional WWTP
From: Dana Folley <[e-mail]>
Date: Fri, 14 Nov 2008 13:24:28 -0500
To: Toya Fields <[e-mail]>
CC: Paul Rawls <[e-mail]>, Belinda Henson <[e-mail]>, Danny
Smith <[e-mail]>, [e-mail], Gil Vinzani
<G i l . V inzani @ncmai 1. net>
Toya, as we just discussed, as this is proposed to be POTW, Deborah and I request you insert the
following paragraph into your response. Also, please cc: me on the letter, including the attachments.
Thanks! - Dana
Publicly Owned Treatment Works (POTW) Requirements. If the Regional WWTP will be a POTW, the
NPDES permit would include Pretreatment Program conditions as required by 40 CFR 403 and 15A
NCAC 02H .0900. It is likely the current textile operation would meet the criteria for a Significant
Industrial User (SIU). The Interlocal Agreements (ILAs) between the partners specifying ownership and
operational responsibility setups will also need to specify which organizations will have which
Pretreatment Program responsibilities and how the entities will work together to address industrial
wastewater discharge needs. Please contact Dana Folley of the the Pretreatment, Emergency Response,
and Collection Systems Unit (PERCS) at 919-807-6311 to discuss these issues.
Paul Rawls wrote:
I have cc'd Belinda as this is in her region, wasn't sure why Danny was cc'd.
Thanks
Toya Fields wrote:
Hello All,
I just wanted to send an FYI that I've reviewed a request for speculative effluent limits for a
proposed regional facility in Scotland County. It would be a 7 MGD facility at the site of the
current WestPoint Stevens/Wagram WWTP (discharging to the Lumber River). A feasibility
study is currently being conducted, funded by the NC Clean Water Management Trust Fund.
A "consortium of local entities" is conducting the study to look into regionalization:
- Scotland County
- Hoke County
- Robeson County
- Laurinburg
- Raeford
- Maxton
1 of 2 1 1 / 17/2008 2:00 PM

Re: Scotland County Regional WWTP
--Red Springs
- Laurinburg Maxton Airbase and Industrial Park
Since this list includes so many entities, I wanted to send an FYI to a large audience. I really
don't know many other details besides what I've described, but if you have any questions, feel
free to let me know.
Thanks,
Toya
denr.dwq.psb mailing list
denr.dwq.psbAlists.ncmail.net
denr.dwq.percs mailing list
denr.dwq.peres(a Iists.ncmail.net
2 of 2 11 / 17/2008 2:00 PM

WESTPOINT
HOME
September 12, 2008 i1 is ^
!
Mr. Gil Vinzani, P.E. SEP 1 8 2008 1 L''
Supervisor, Eastern NPDES Program
NC Division of Water Quality "~`--1-
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Subject: Request for Speculative Effluent Limits
WestPoint Home, Inc./Wagram WWTP
NPDES Permit No. NC 0005762
Wagram, Scotland County
Dear Mr. Vinzani:
WestPoint Home operates at our Wagram facility a 7.0 mgd wastewater treatment plant (WWTP)
which discharges its effluent into Lumber River in accordance with the NPDES Permit No
NC0005762. The WWTP is currently permitted for treatment and discharge of industrial
wastewater flows.
A consortium of local entities consisting of the Counties of Scotland, Hoke and Robeson, the
Cities of Laurinburg and Raeford, the Towns of Maxton and Red Springs, and the Laurinburg-
Maxton Airbase and Industrial Park is conducting a feasibility study for the use of WestPoint
Home/Wagram WWTP to serve as a regional facility. The Study is funded by the NC Clean
Water Management Trust Fund. The WWTP will continue to serve the existing industrial
operations for their wastewater treatment and disposal needs.
In order to properly evaluate the wastewater treatment system improvements need for the
WestPoint Home/Wagram WWTP to serve as a regional facility, it is hereby requested that you
provide Speculative Effluent Limits for the currently -permitted 7.0 mgd plant.
Should you have any questions concerning this matter, please call me at 706-645-4515 or
Shankar Mistry at 919-828-0531.
Eddie Lanier
Director, Environmental Department
WestPoint Home, Inc.
Environmental Dept., 3300 23rd Drive, Valley, AL 36854, Phone: [phone], Fax [phone]

RE: Scotland Co. WPH WWTP Study: Speculative Limits Request
Subject: RE: Scotland Co. WPH WWTP Study: Speculative Limits Request
From: Lanier Eddie <[e-mail]>
Date: Fri, 12 Sep 2008 15:07:09 -0400
To: "Gil Vinzani" @ncmail.net>, "Chris Thomson" <[e-mail]>
CC: "James B. Perry" <[e-mail]>, <[e-mail]>,
"Charlie Davis" <[e-mail]>. "Dan Boone" <[e-mail]>
Mr. Vinzani, here is a signed copy of the revised letter. Please let me know if you have any questions.
Eddie Lanier
Director - Environmental Department
3300 23rd Drive
Valley. AL 36854
706-645-4515
706-645-4539 (fax)
Original Message
From: Chris Thomson [mailto:cthomson©thewootencompany.com]
Sent: Wednesday, September 10, 2008 4:35 PM
To: Lanier Eddie
Cc: 'Gil Vinzani'; 'James B. Perry'; [e-mail]; 'Charlie Davis'; 'Dan Boone'
Subject: Scotland Co. WPH WWTP Study: Speculative Limits Request
Mr. Lanier:
The Wooten Company is working to finalize a study of the WestPoint Home Wastewater Treatment Plant
(WWTP) for potential conversion to a municipal WWTP for use by a consortium of local governments in
and around the facility in Wagram, NC. As part of the study, we have been working with the North Carolina
Division of Water Quality (DWQ) on permitting the facility for municipal use. We have spoken with DWQ
regarding permitting and obtaining "speculative limits" for the plant; speculative limits are preliminary limits
on the plant's discharge that DWQ might impose if the facility is converted for municipal use. They provide
valuable information to us on what will be allowed in the plant's discharge so we can consider the types of
treatment units required.
DWQ has requested that the Permittee, in this case WestPoint Home, formally request the speculative
limits from the state. We have composed a letter on your behalf to send to Mr. Gil Vinzani of DWQ
requesting such limits. Please review the attached letter, and if you have no comments, copy the letter to
company letterhead, sign, and mail the letter to Mr. Vinzani so that he can have it for his file and issue the
speculative limits.
If you have any questions, please do not hesitate to contact us. I have copied Mr. Vinzani on this email. I
have also copied Mr. Jim Perry, Executive Director of the Lumber River Council of Governments, on this
email. Jim's organization has been instrumental in the backing of this study and is familiar with your staff in
Wagram.
Chris
Christopher A. Thomson, MA, MS
The Wooten Company
120 North Boylan Avenue
1 of 2 9/12/2008 4:25 PM

Scotland Co; WPH WWTP Study: Speculative Limits Request
Subject: Scotland Co. WPH WWTP Study: Speculative Limits Request
From: "Chris Thomson" <[e-mail]>
Date: Wed, 10 Sep 2008 16:35:15 -0400
To: <Lanier.eddie@ wphome.com>
CC: "'Gil Vinzani"' <[e-mail]>. "'James B. Perry"' <[e-mail]>.
<[e-mail]>, "'Charlie Davis"' <[e-mail]>, "'Dan
Boone" <[e-mail]>
Mr. Lanier:
The Wooten Company is working to finalize a study of the WestPoint Home Wastewater Treatment Plant
(WWTP) for potential conversion to a municipal WWTP for use by a consortium of local governments in and
around the facility in Wagram, NC. As part of the study, we have been working with the North Carolina Division of
Water Quality (DWQ) on permitting the facility for municipal use. We have spoken with DWQ regarding permitting
and obtaining "speculative limits" for the plant; speculative limits are preliminary limits on the plant's discharge that
DWQ might impose if the facility is converted for municipal use. They provide valuable information to us on what
will be allowed in the plant's discharge so we can consider the types of treatment units required.
DWQ has requested that the Permittee, in this case WestPoint Home, formally request the speculative limits from
the state. We have composed a letter on your behalf to send to Mr. Gil Vinzani of DWQ requesting such limits.
Please review the attached letter, and if you have no comments, copy the letter to company letterhead, sign, and
mail the letter to Mr. Vinzani so that he can have it for his file and issue the speculative limits.
If you have any questions, please do not hesitate to contact us. I have copied Mr. Vinzani on this email. I have
also copied Mr. Jim Perry, Executive Director of the Lumber River Council of Governments, on this email. Jim's
organization has been instrumental in the backing of this study and is familiar with your staff in Wagram.
Chris
Christopher A. Thomson, MA, MS
The Wooten Company
120 North Boylan Avenue
Raleigh, NC 27603-1423
Phone: [phone]
Fax: [phone]
Content -Type: application/msword
Speculative Effluent Limits requestSept.9 2008.doc
Content -Encoding: base64
1 of 1 9/11/2008 9:06 AM

September 9, 2008
Mr. Gil Vinzani, P.E.
Supervisor, Eastern NPDES Program
NC Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Subject: Request for Speculative Effluent Limits
WestPoint Stevens/Wagram WWTP
NPDES Permit No. NC 0005762
Wagram, Scotland County
SEP 1 1 2008
DENR - WATER DUALITY
PC NT SOtJRCF EP:,`:CH
ArY
Dear Mr. Vinzani:
WestPoint Stevens operates a 7.0 mgd Wagram Wastewater Treatment Plant which
discharges its effluent into Lumber River in accordance with the NPDES Permit No
NC0005762. The WWTP is currently permitted for treatment and discharge of industrial
and commercial wastewater flows.
A consortium of local entities consisting of the Counties of Scotland, Hoke and Robeson,
the Cities of Laurinburg and Raeford, the Towns of Maxton and Red Springs, and the
Laurinburg-Maxton Airbase and Industrial Park is conducting a feasibility study for the
use of WestPoint Stevens/Wagram WWTP to serve as a regional facility. The Study is
funded by the NC Clean Water Management Trust Fund. The WWTP will continue to
serve the existing industrial and commercial and residential establishments for their
wastewater treatment and disposal needs.
In order to properly evaluate the wastewater treatment system improvements need for the
WestPoint Stevens/Wagram WWTP to serve as a regional facility, it is hereby requested
to provide Speculative Effluent Limits for the currently permitted 7.0 mgd plant.
Should you have any questions concerning this matter, please call me at 706-645-4515 or
Shankar Mistry at 919-828-0531.
Sincerely,
Eddie Lanier
Director, Environmental Department
WestPoint Home, Inc
PO Box 71
WestPoint, Georgia 31833

THE
WOOTEN
COMPANY
ENGINEERING
PLANNING
ARCHITECTURE
120 North Boylan Avenue
Raleigh NC 27603-1423
919.828.0531
fax [phone]
June 9, 2008
Mr. Gil Vinzani, P.E.
Supervisor, Eastern NPDES Program
NC Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Subject: Request for Speculative Effluent Limits
WestPoint Sieveiis/Wagram WWTP
NPDES Permit No. NC 0005762
Wagram, Scotland County
JUN 10 2008 i
Dear Mr. Vinzani:
WestPoint Stevens operates a 7.0 mgd Wagram Wastewater Treatment
Plant which discharges its effluent into Lumber River in accordance with
the NPDES Permit No NC0005762. The WWTP is currently permitted for
treatment and discharge of industrial and commercial wastewater flows. At
present we are in process of preparing an Engineering Report for use of the
existing WWTP for treatment and discharge of wastewaters generated from
communities in the Scotland County and surrounding Counties that are in
close proximity of the WWTP. The WWTP will continue to serve the
existing industrial and commercial establishments for their wastewater
treatment and disposal needs.
Considering addition of wastewater flows from the communities in
Scotland County and surrounding Counties and for us to properly evaluate
the wastewater treatment plant improvements need we will appreciate your
assistance in providing Speculative Effluent Limits for the currently
permitted 7.0 mgd plant.
Should you have any questions concerning this matter, please call me at
919-828-0531.
Sincerely,
a-+Lc_..v
K. R. N,,,- j
Shankar R. Mistry, Ph. D., P.E.

Permit NC0005762
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of this permit and lasting until expiration,
the permittee is authorized to discharge industrial and domestic wastewater from outfall
001. Such discharges shall be limited and monitored by the Permittee as specified below:
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Weekly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample Location'
Flow
7.0 MGD
Continuous
Recording
E
BOO, 5-day, 20° C
1306 Ibs/day
2611 Ibs/day
Daily
Composite
E
COD
14,890
Ibs/day
29,780
Ibs/day
Daily
Composite
E
Total Suspended Solids
2558 Ibs/day
5115 Ibs/day
Daily
Composite
E
Sulfides
24 Ibs/day
49 Ibs/day
Quarterly
Grab
E
Total Chromium
12 Ibs/day
24 Ibs/day
Quarterly
Composite
E
Total Phenols
0.75 lbslday
20,pg/I
Weekly
Grab
E
Fecal Coliform (geometric mean)
200/100 ml
400/100 ml
Weekly
Grab
E
Total Residual Chlorin&
28 pg/I
Weekly
Grab
E
Total Copper
Monthly
Composite
E
Total Zinc
Monthly
Composite
E
Temperature
Daily
Grab
E
Temperature
3/Week
Grab
U & D
Conductivity
Daily
Grab
E
Conductivity
3/Week
Grab
U & D
Dissolved Oxygen3
Daily
Grab
E
Dissolved Oxygen
3/Week
Grab
U & D
Chronic Toxicity
Quarterly
Composite
E
Total Nitrogen (NO2+NO3+TKN)
Monthly
Composite
E
Total Phosphorus
Monthly
Composite
E
NH3-N
Monthly
Composite
E
Colors
Daily
Grab
E
Colors
3/Week
Grab
U & D
pH6
6.0-9.0
Daily
Grab
E
Footnotes:
1. Sample locations: E-Effluent, U-Upstream at NCSR 1403, D-Downstream at (1) NCSR
1310 and (2) NC Highway 71. Stream samples shall be grab samples and shall be
collected 3/Week during June -September and 1 /Week during the remaining months of
the year.
2. Total residual chlorine monitoring is required only if chlorine is used as a disinfectant
or elsewhere in the process.
3. The daily average dissolved oxygen concentration shall not fall below 5.0 mg/L.
4. Chronic Toxicity (Ceriodaphnia dubia) P/F at 9%: February, May, August, and November
(see Special condition A.3.). Toxicity monitoring shall coincide with quarterly metals
monitoring.
5. Refer to Special Condition A.4. regarding color monitoring.
6. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Outfall 004
Lat: 34° 49' 50"
Lon:79° 22' 30"
Outfall 002
Lat: 34° 50' 00"
Lon:79° 22' 32"
Outfall 001
Lat: 34° 49' 50"
Lon:79° 21' 08"
USGS Quad Name: Wakulla, H21SE
Receiving Stream: Lumber River (001)/Big Shoe Heel Cr. (002 & 004)
Stream Class: WS-IV, B-Sw, HQW (001)/C-$w (002 &004)
Subbasin: Lumber— 03-07-51 (001) / 03-07-55 (002 & 004)
QKE
BESON
Facility
Location411
%
SCALE 1:24,000