NC0001643_Technical Review of Discharger's Comments_19890130

DIVISION OF ENVIRONMENTAL MANAGEMENT .
January 30, 1989
MEMORANDUM
TO: Arthur Mouberry
FROM: Juan C. Mangles ''"
THROUGH: David Vogt t
Trevor Cleme s
Steve Tedder
SUBJECT: Technical review of discharger's comments
regarding the stream monitoring requirements
recommended in the draft permit for
renewal of NPDES 11 NC001643
Fieldcrest Cannon, Inc.
Rockingham County
Per your request, Technical Services has reviewed the comments of
Fieldcrest Cannon (in their letter to you dated 1-13-89) regarding the
stream monitoring requirements as recommended by the Technical Support Unit
via wasteload allocation 114759.
The following comments are provided:
All major facilities are required to perform instream monitoring, as
per Divisional procedure. This requirement is especially useful in this
particular case since existing water quality in the section of the Dan River
where the subject facility discharges is relatively unknown. There are sev-
eral discharges in this segment of the receiving stream. Therefore, there
is a need to establish a database to determine possible water quality
impacts. Other discharges in this area may be required to implement self-
monitoring programs as their permits come up for renewal.
It is recommended that the upstream station be maintained at 100 ft.
above the outfall, or at a site located between Miller Brewery and Fieldcrest
Cannon outfalls. However, if access to the recommended sites presents a
problem, the upstream site can be located at Hwy 17. The downstream samp-
ling station should be at Hwy 700. Stream monitoring at the Smith River
(prior to confluence with the Dan River) and at Hwy 87 would provide informa-
tion but should not be required in the permit. These two monitoring sites
may be required for other facilities when their permits are due for renewal.

We concur with Fieldcrest's proposal to perform instream monitoring for
the following parameters: color, conductivity, dissolved oxygen and temper-
ature. However, they should include BODS. The monitoring frequencies
should be weekly during the summer (Apr-Oct) and monthly during the winter
(Nov-Mar). Grab samples are acceptable for SODS.
Please contact Trevor or myself if you need further clarification of
Technical Support's position on these issues.
Attachment
JCM/gh
cc: Steve Mauney
Fieldcrest Cannon WLA File
Central Files

fr/" FIELDCREST CANNON, INC.
Tr/
1J" Eden, North Carolin4a 27288
Corporate Engineering
( 919 ) 627-3195
/b/A/4fr
January 13 , 1989
Mr. Arthur Mouberry $:
Permits & Engineering
NC Dept. of Natural Resources
P.O. Box 27687
Raleigh, NC 27611-7687
Dear Mr. Mouberry:
Re: Fieldcrest Cannon, Inc.
Rockingham County
NPDES Permit NC0001643
A review has been made of the "draft" permit for our New Street
wastewater treatment plant. We are in agreement with the
conditions contained in the permit except for the following:
Upstream and downstream monitoring requirements;
Priority pollutant analysis requirements.
Our comments relative to these two ( 2) issues are as noted
below.
STREAM MONITORING REQUIREMENTS:
The regulatory purpose for stream monitoring is to assess
discharges that have an impact on the stream water quality.
This discharge does not have an impact, nor has it exhibited an
impact, on the water quality of the Dan River. Mr. Steve Tedder
of the Water Quality Section indicated that the primary reason
for including the stream monitoring in this permit was to estab-
lish a water quality database. He further indicated that this
was necessary to determine what impact the Smith River has on
the Dan River. It is well documented that the primary impact on
Dan River water quality in the Eden area is the Martinsville, VA
WWTP discharge to the Smith River. It does not seem appropriate
to require Fieldcrest Cannon to monitor for water quality
impacts attributable to other sources. In fact, the sampling
locations listed in the permit would not in our opinion provide
meaningful data relative to the concerns of the Division' s Water
Quality Section. REcEp
C V u
JAN 20i989
TECHNICAL sta. lCES 3iz
ANCH.

Mr. Arthur Mouberry Page -2-
January 13 , 1989
At this point in time our greatest concern is the water quality
of the Smith River prior to confluence with the Dan. This is
because the Fieldcrest Central Filter Plant raw water source is
located on the Smith River. It would seem that sampling
locations on the Smith and Dan Rivers prior to their confluence,
together with an adequate downsteam sampling location would
provide valuable and meaningful water quality data. For the
reasons noted previously, Fieldcrest is agreeable to the
following:
1 . Stream monitoring on the Smith prior to confluence with
the Dan; the Dan at the Hwy 87 bridge; and the Dan at
the Hwy 700 bridge.
2 . Monitoring for the parameters of color, conductivity,
temperature, and dissolved oxygen at these locations;
In the future when new or modified permits are issued to other
Eden discharges, Fieldcrest is agreeable to a coordinated stream
montioring program for the Dan River.
PRIORITY POLLUTANT ANALYSIS:
The priority pollutant analysis for this permit renewal showed
all orangics (purgeables, acid extractables, base neutrals,
pesticides & PCB' s, and herbicides) to be below the
quantification limit (BQL) . This would be expected since the
wastewater generated is predominately from low water use textile'
manufacturing operations, as noted in the permit application.
It is our opinion that for this particular permit it is not
appropriate nor justified to require an annual pollutant
analysis for these organics.
It also follows that it is not appropriate nor justified to
require quantification of the largest 10 GC/MS peaks in each
organic chemical analytic fraction ( "10 significant peaks rule" )
when the complete priority pollutant analysis for the organics
was below the quantification limit (BQL) . In this instance to
require this additional analysis borders on nothing more than a
"fishing expedition" , that will add increased cost to the
operation while providing no real regulatory benefit.
As the permit relates to prioity pollutant analyses, Fieldcrest
is agreeable to the following:
1 . Monitor for the priority pollutant categories of organic
chemical analytic fractions every three ( 3 ) years.
2 . Monitor under the "10 significant peaks rule" only for
the categories of organic chemical analytic fractions
quantified to be above the BQL.

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Mr. Arthur Mouberry Page -3-
January 13, 1989
3 . Monitor for the priority pollutant category of metals
and other chemicals on an annual basis.
We appreciate the opportunity to review this permit, and trust
that favorable consideration will be given to the specific
comments presented. If any additional information or further
clarification is needed, please let me know.
Very truly yours,
ote, '
Evander H. Rowell, P.E.
Director - Environmental
Engineering
EHR: er
pc: Messrs. S. M. Ellington
M. W. Jeffries
Steve W. Tedder, NC DEM, Raleigh
Ms. B. S. Remeta
•

A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Final
NPDES No. NC000N
During the period beginning on the effective date of the permit and lasting until expirata�
l Permittee is authorized to discharge from outfall(s) serial number(s) 001. Such discharges
limited and monitored by the Permittee as specified below: shall
Effluent Characteristics
Discharge Limitations Monitoring Requirements
Lbs/day Other Units (Specify) Measurement
1
Daily Avg. DailyMax. Sample *Sample
Daily Avg. Daily Max. Frequency Type
Location
Flow
1' BOD, 5-day, 20 degree C 0.500 MGD Continuous Recording I or E
•i g 191. 8 216. 9
illi Dissolved Oxygen (minimum) 2/month Composite E, U, D
Total Suspended Solids 129. 7 259.4 Weekly Grab E, U, D
Temperature 2/month Composite E
iH Conductivity Weekly Grab E, U, D
� Total Chromium Weekl -
I' 0 38 0. 76 2/month Composite E
Iii! SlufiTotal e Grab U, D
:II Phenol 0. 19 0.38 2/month Grab E
:�i COD 382.0 764.0 2/month Grab E
Acute Toxicity ** 2/month Composite E
Priority Pollutants *** Quarterly Composite E
Annually
Total Nitrogen (NO2 + NO3 + Tom) E
• ; Total PHosphorus
Quarterly Composite E
j Quarterly Composite E
11
1
1! * Sample locations: E - Effluent, I - Influent, U - Upstream 100 feet above discharge, D - Down
Highway 700 8 stream at N.C.
i
** Acute Toxicity (Fathead Minnow 24 hour) No Significant Mortality at 90%; February, May, August, and November;
See Part III, Condition G.
*** See Part III, Condition H. •
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored
weekly at the effluent, upstream, and downstream.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
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