NC0000108_WASTELOAD ALLOCATION_19950915

NPDES DOCUWKNT SCANNIN& COVER SHEET
NPDES Permit:
NC0000108
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Monitoring Report
Instream Assessment (67B)
Environmental Assessment (EA)
Permit
History
Document Date:
September 15, 1995
Thim doanment I" printed on reume paper - ignore any
ooaMtent on the :-eYe Me Aide
•
0
0

Page 1
Note for Jackie Nowell
From: Carla Sanderson
Date: Fri, Sep 15, 1995 10:47 AM
Subject: RE: COATS AMERICAN
To: Jackie Nowell; Jay Lucas
OK, I will assume this is the final word Thanks!
From: Jay Lucas on Fri, Sep 15, 1995 10:45 AM
Subject: RE: COATS AMERICAN
To: Carla Sanderson; Jackie Nowell
I agree. I think we should at least give them the limit of 0.1 mg/l. Because they were
discharging the chlorinated water illegally and didn't get caught until recently, I think we can
treat it as a new discharge.
From: Carla Sanderson on Fri, Sep
Subject: FW: COATS AMERIC_AI
To: Jackie Nowell; Jay Lucas
F1�3 1
Actually - I would not mind seeing a limit on chlorine at 0.1 mg/l as asked by the facility.
We cannot justify giving one based on our chlorine SOP, but since they may be willing to
accept one, the 0.1 mg/l would be better than monitoring (they have values in the 300s ug/1).
Jay - what do you think? If we go by SOP - we cannot really support applying a limit at this
time.
Hope we are not confusing you!
From: Jackie Nowell on Fri, Sep 15, 1995 10:15 AM
Subject: FW: COATS AMERICAN
To: Jay Lucas
Cc: Carla Sanderson; Dave Goodrich
Per this last message on 6/26, it was our recommendation that chlorine monitoring only be
placed in the renewed permit for Coats American's outfalls 001 and 002. Per the facility's
request for a C1 limit of 0.1 mg/1 in the September 6th letter, we recommend that they be
notified that Cl monitoring (with no numerical limit) will be sufficient.
From: Jackie Nowell on Mon, Jun 26, 1995 10:41 AM
Subject: RE: COATS AMERICAN
To: Jay Lucas
I've talked with Carla and she says that adding chlorine monitoring to the permit for 001 and
002, should be sufficient and letting them know that a chlorine limit may be added in the
future. Since this is an existing facility and chlorine has been added all along, just because
we're now finding out about it, -we may not be able to place a limit on them.
So if you would just add chlorine monitoring and the frequency, that should take care of
Coats American. I will' ask Marcia to delete the WLAs you requested (#8311, #8312, # 8313
on 6/16/95)
From: Jay Lucas on Mon, Jun 26, 1995 8:08 AM
Subject: RE: COATS AMERICAN

Page 2
To: Jackie Nowell `
If you think we don't need a WLA, that's fine. I can use the streamline package to develop
the permit and add a chlorine limit to outfalls 001 and 002.
From: Jackie Nowell on Fri, Jun 23, 1995 1:28 PM
Subject: COATS AMERICAN
To: Jay Lucas
Cc: Carla Sanderson; Dave Goodrich
I HAVE REVIEWED THESE WLAS, UNLESS THERE IS SOME NEW ADDITIVE TO
WETTING THESE STOOLS, IS A WLA NECESSARY? JUDGING BY THE
SCHEMATIC, ONLY CHLORINE IS DESIGNATED AS AN ADDTIZVE, IF A
CHLORINE LM41T IS ADDED TO PIPE 001 AND 002, IT WOULD BE @ 28 µg/1 AND
WE MAY NOT NEED A WLA FOR THAT ADDITION. PLEASE LET ME KNOW IF
YOU THINK MORE IS NEEDED.

4i9._�
Coats
North America
Engineering
SUBJECT: DATE:
SCHEMATIC OF WASTE WATER FLOW
SYLVAN PLANT — TRANSYLVANIA COUNTY
ROSMAN, NORTH CAROLINA
POTABLE WATER
CHLORINATION
FOR DISINFECTION
PROCESS/COOLING WATER
CHLORINATION
AS BIOCIDE
CQTTMPROVE.TWON THREAD�I_S-WETTED_=TO
IIS�TING.B.Y,..RLINNIN
LT,HROUGHt:TROUGHS.OF..RROEESS
WATER CONTINUOUS�MAKE-UP/
OVERr2ow 1S MAII,�fTA�NBD*TO
PREVEhR-AL•`GAE GROWTH.
PACKAGE
TREATMENT
PLANT (AERATION)
NON -CONTACT
COOLING WATER
-AIR COMPRESSOR
AFTERCOOLER
• AIR DRYER
CONDENSER
COOLING
TOWER
WET'
twis ISIG-7
BLOWDOWN
OUTFALL 003
OUTFALL 002
_„
OUTFALL 001

MEMORANDUM
North Carolina Division of Environmental Management
Water Quality Section, Permits and Engineering Unit
TO: Forrest Westall, ARO
CCarla Sanderson, IAU
FROM: Jay Lucav -&-
SUBJECT: Coats American, NC0000108
DATE: Sept. 14, 1995
Please let me know your comments on this letter by Sept. 29 and call me if you
have any questions.
cc: Project File

MOORE & VAN ALLEN
A PROFESSIONAL Lim= LIABILr[7 ComPANY
ATTORNEYS AT LAW
PETER J. MCCRATH JR. NATTONSBANK CORPORATE CENTER TELEPHONE [phone]
DIRECT DIAL 704.331-1081 100 NORTH TRYON STREET FLOOR 47 FACSIMILE 704.331-1159
CHARLOTTE, NORTH CAROLINA 28202.4003
September 6, 1995
VIA FACSIMILE 9191733-0719
AND U. S. MAIL
Mr. Jay B, Lucas, P. E. '
Environmental Engineer ,
North Carolina Department of
Environment, Health and Natural Resources
Division of Environmental Management
Post Office Box 29535
Raleigh, North Carolina 27636 ,
RE: NPDES Draft Permit No. NC0000108/Coats American, Inc./Sylvan Plant
WWTP/Transylvania County
Dear Mr. Lucas:
This firm represents Coats American, Inc., holder of the NPDES Permit which you propose to
renew by issuance of a new permit in the form of the referenced draft permit. The terms,
conditions and limitations of the draft permit are, in general, acceptable to Coats American, Inc.
Coats American, Inc. though makes the following specific objections and comments with respect
to the draft permit.
1. The name of the permittee should be Coats American, Inc., not Coats North
American as currently listed in the draft permit.
2. Coats American, Inc. objects to the total residual chlorine limit in the draft permit
effective May 1, 1996, for outfalls 001 and 002. Coats American, Inc. does not
object in principle to the imposition of a total residual chlorine limit on those
outfalls. Coats American, Inc., however, adds chlorine to wastewater at the
subject facility to control algae growth in the wastewater treatment system. If
chlorine concentrations fall below .10 mgll, algae growth becomes a problem
which interferes with the operation of the wastewater treatment system.
Coats American, Inc. believes that the draft'permit's toxicity testing requirements
are adequate to address any toxicity concerns relating to chlorine. If the Division
CHAR 2\f:\ROCS\PJM\LETTER\140114_1

Mr. Jay B. Lucas
September 6, 1995
Page 2
of Environmental Management is concerned over chlorine concentrations for other
reasons, Coats American, Inc. would like to discuss the Division's concerns to
determine whether alternate limits or operational procedures are appropriate to
address those concerns, while allowing the facility to control algae growth and
operate its wastewater treatment system effectively. Coats American, Inc.
therefore proposes a residual chlorine limit effective May 1, 1996, of .10 mg/l.
Coats American, Inc. does not intend these comments to be controversial, but to only assure the
permit is properly protective of water quality in North Carolina. We look forward to discussing
these comments with you. Please feel free to contact me at your convenience. We will be
happy to meet with you to discuss our concerns.
Yours truly,
MOORE & VAN ALLEN, PLLC
Peter J. Mc6ra , Jr. �--
PJM/fww
cc: W. Rex Stuckey
A. Mark Adcock
CHAR_2\F:\DOCS\PJM\LETTER\140114_1

t
SOC PRIORITY PROJECT: Yes No XX
IF,YES, SOC NUMBER
TO: PERMITS AND ENGINEERING UNIT
WATER QUALITY SECTION
ATTENTION: Jay Lucas
DATE: July 10, 1995
NPDES STAFF REPORT AND RECOMMENDATION
COUNTY Transylvania
PERMIT NUMBER NCO000108
PART I - GENERAL INFORMATION
1. Facility and Address: Coats North American
Mailing: W. R. Stuckey
POB 670
Toccoa, Georgia 30577
2. Date of Investigation: March 2, 1995
3. Report Prepared By: Kerry Becker
4. Persons Contacted and Telephone Number: Eddie Briscoe
704-862-4215
5. Directions to Site: Coats America is located on old U.s. Hwy
64 approximately 3 mile east of Rosman, NC.
6. Discharge Point s), List for all discharge points:
Latitude: 350 10, 001, Longitude: 820 48' 3011
Attach a USGS map extract and indicate treatment facility site and
discharge point on map,
U.S.G.S. Quad No. 185»NE U.S.G.S. Quad Name Rosman, NC
7. Site size and expansion area consistent with application?
x_ Yes No If No, explain:
Page 1

8. Topography (relationship to flood plain included): Flat, located
within the flood plain.
9. Location of nearest dwelling: >500 ft.
10. Receiving stream or affected surface waters: Galloway Creek
a.. Classification:�C
b. River Basin and Subbasin No.: 04-03-01
C. Describe receiving stream features and pertinent downstream
uses: Aquatic and wildlife habitat and propagation
PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
1. a. Volume of wastewater to be permitted
Pipe 001 (Non -contact cooling water) >0.050 MGD
Pipe 002 (Wet Twisting Operation) 0.010 - 0.050 MGD
Pipe 003 (Domestic plant) 0.015 MGD (Ultimate Design
Capacity)
b. What is the current permitted capacity of the Wastewater
Treatment facility?
Pipe 001: No limit
Pipe 002: No limit
Pipe 003: 0.015 MGD
C. Actual treatment capacity of the current facility (current
design capacity
Pipe 001: N/A
Pipe 002: N/A
Pipe 003: 0.015 MGD
d. Date(s) and construction activities allowed by previous
Authorizations to Construct issued in the previous two years:
None within the past two years.
e. Please provide a description of existing or substantially
constructed wastewater treatment facilities: Pipe 003: The
existing facility consists of an extended aeration package
plant followed by effluent chlorination.
f. Please provide a description of proposed wastewater treatment
facilities: None proposed.
g. Possible toxic impacts to surface waters: Pipe 002 effluent
bioassay has shown some toxicity; cause is unknown.
Page 2

2. Residuals handling and utilization/disposal scheme:The residuals
will be pumped and hauled by a commercial septage hauler to the
City of Brevard's sludge handling facilities.
3. Treatment plant classification.(attach completed rating sheet):
Class II
4. SIC Codes (s) : 2284'
5. Wastewater Code
Primary 02 Secondary 14, 55
Main Treatment Unit Code:pipe 003 060-7
PART III - OTHER PERTINENT INFORMATION
1. Is this facility being constructed with Construction Grant Funds
or are any public monies involved. (municipals only)?
2. Special monitoring or limitations (including toxicity) requests:
Include toxicity monitoring requirement
3. Important SOC, JOC, or Compliance Schedule dates: (Please
indicate) N/A
Date
Submission of Plans and Specifications
Begin Construction
Complete Construction
4. Alternative Analysis Evaluation: Has the facility evaluated all
of the non -discharge options available. Please provide regional
perspective for each option evaluated. Spray irrigation could be a
possibility.
Spray Irrigation:
Connection to Regional Sewer System:
Subsurface:
Other disposal options:
5. Other Special Items: None
Page 3

PART IV - EVALUATION AND RECOMMENDATIONS
The permit should be renewed noting pipe 002 as wet twisting instead of noncontact
cooling water. Acute toxicity tests have shown this effluent to be extremely toxic
at times. Toxicity monitoring should be added to the permit (fa,"?,JiA,V0;L),
Signatufib of Report Preparer
r-
Writer Quality Regional Supervisor
741
Date
Page 4

A (} EFFLUENTT THAT ATTONS AND MONITORING REQUIREMENTS SUMVLCR (A n 1 1 - Octo
b r 3I) Perini€ Na NC0-V)OM8
e
a , p
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from
outfall(s) serial number 003. Such discharges shall be Iimited and monitored by the permittee as specified below:
Effluent Characterlstics
Flow
BOD, 5 day, 20°C
Total Suspended Residue
NH3 asN
Fecal Coliform (geometric mean)
Total Residual Chlorine
Tomperature
Discharge Limitations
ManitorIng
Re ulrements
Measurement
Sample
"Sample
Monthly Ava, Weekly Avg,
Daily Max
FtgAuengy
I-Y-"
LOCation
0.01 5 MGD
Weekly
Instantaneous
I or E
30.0 mg/l
45.0 mg/l
2/Month
Grab
E
30.0 mg/l
45.0 mg/I
2/Month
Grab
E
21.0 mg/I
2/Month
Grab
E
200.01100 ml
400.0 /100 ml
2/Month
Grab
E
Daily
Grab
E
Weekly
Grab
E
* Sample locations: f:; - Effluent, i - influent
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored 2/month at the effluent by grab
sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
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