NC0006190_CORRESPONDENCE_19911231

NPDES DOCUWENT SCANNlNS CdVIZR SHEET
NPDES Permit:
NC0006190
Document Type:
Permit Issuance '
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Correspondence
Speculative Limits
Instream Assessment (67b)
Environmental Assessment (EA)
Permit
History
Document Date:
December 31, 1991
Tlixia documerYt is printed on reuse paper -- ignore any
coaterit on the reverse side

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State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Govemor
William W. Cobey, Jr., secretary
December 31, 1991
Mr. Larry Horton, P.E.
Applied Water Technology, Inc.
P.O. Box 36008
Raleigh, N.C. 27606
George T. Everett, Ph.D.
Director
Subject: Duck Head Apparel's NPDES Discharge Relocation to Clark Creek
NPDES Permit No. NC0006190
Catawba County
Dear Mr. Horton:
We have received your letter of November 20th and this is to confirm that your
understanding of our November 19th letter is correct. Any modifications of efflu-
ent limits for the Town of Maiden or Duck Head Apparel will not be influenced
based on which discharge is upstream of the other.
Please contact me if there any additional questions concerning this matter.
Sincerely,
/En'v
el M. Now1 ronmental Modeler
Technical Support Branch
v�
CC,. Trevor Clements
MA__F7ileJ
Pollution Pnwendon Pays
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
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APPLIED WATER TECHNOLOGY
P.O. Box 36008
RALEIGH, N.C. 27606
[phone] f
Mr. J. Trevor Clements
Assistant Chief
Technical Support Branch
Water Quality Section ;
N. C. Division of Environmental Management
Post Office Box 27687
Raleigh, North Carolina 27611-7687
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AWT
November 20, 1991
7i(A
"i BRAND
Re: Duck Head Apparel's NPDES Discharge Relocation to Clark Creek
NPDES Permit No. NC0006190
Catawba County
Dear Mr. Clements:
AWT is writing to thank you and your staff for the November 14, 1991 letter concerning
the referenced discharge relocation and to confirm our understanding of that letter.
It is our understanding that neither the present nor the future effluent discharge limits of the
town or Duck Head Apparel Co., Inc. (DHA) would be affected by which discharge is
upstream of the other. It is also our understanding that although the discharge limits may
change for the town and DHA upon permit renewal, the changes in the discharge limits for
neither the town nor DHA will be affected by which discharge is upstream of the other.
If our understanding of the November 14 letter, as discussed above, is incorrect, please
notify AWT as soon as possible.
Si erely,
A , Incorporat 1
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arty L Horton, P. E.
cc: Allen McRee, Duck Head Apparel
Jerry Jackson, Duck Head Apparel
Mark Beaumont, Duck Head Apparel
Charles Blackwell, AWT

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State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G Marlin, Govemor
1Mlliam W. Coney, Jr., Secretary
November 14, 1991
Mr. Larry Horton, P.E.
Applied Water Technology, Inc.
5214 Western Blvd.
P.U. Box 36008
Raleigh, N.C. 27606
George T. Everett, Ph.D.
Director
Subject: Duck Head Apparel's NPDES Discharge Relocation to Clark Creek
NPDES Permit No. NC0006190
Catawba County
Dear Mr. Horton:
Thank you for scheduling the time to come and discuss the concerns of Duck
Head Apparel and the Town of Maiden. My staff indicated to me that the meeting was
beneficial and answered questions for both parties.
The primary issue was the effect of relocating Duck Head's discharge directly
to Clark Creek and how it would impact existing effluent limitations for Maiden.
The Town of Maiden is concerned that if Duck Head is located above its outfall
rather than below it, Maiden's effluent limits will be affected. As explained
to you and Mr. Blackwell, the Level B model that was used to develop the effluent
limits for Duck Head, accounted for all of the dischargers in the Clark Creek
Basin. Our model results indicated that there is interaction between the Newton -
Clark Creek WWTP, the Town of Maiden, and the relocated Duck Head Apparel dis-
charge. It is standard operating procedure within the Division of Environmental
Management when developing wasteload allocations, that if a new, expanding, or
relocating discharge interacts with an existing discharge, no more stringent limi-
tations will be placed on the existing discharge for oxygen -consuming waste. The
new discharge will only be allowed to discharge the waste that the receiving
stream can assimilate above that already allowed by the existing discharges.
There are scenarios where the application of more stringent limits to the
Town of Maiden may occur upon permit renewal. First, as mandated by the EPA, all
facilities will be reviewed to determine whether existing ammonia limits protect
against instream ammonia toxicity. Many existing, secondary dischargers that
have been reviewed by the Division within the past two years have received an
ammonia limit upon renewal. Other toxic substances may also be limited based on
updated effluent analyses and pretreatment headworks information. Second, after
completion of the basin management plan in 1995, existing and proposed discharg-
ers within a basin may have stricter limits for the long-term protection of water
quality. Third, if the facility requests an expansion of wasteflow prior to or
Polludon Preventlon Pays
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
An Equal Opportunity Aflimtiative Action Employer

Mr. Horton
November 15, 1991
- Page 2 -
upon permit renewal, more stringent limits may apply. These actions would be
taken whether Duck Head Apparel discharges above Maiden's outfall or below it.
2 hope that the questions that you have concerning this relocation have been
answered. Please feel to contact Ruth Swanek or Jackie Nowell if any additional
information is needed.
Sin rely
q,.
Trevor Clements
st. Chief, Technical Support Branch
JTC/JMN
cc: Don Safrit
Rex Gleason

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FAX
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APPLIED WATER TECHNOI.O(=Y
Air • Wastewater • Solid & Hazardous Waste
Pollution Control Systems + Chemical & Hazard Communications
Permuting • Planning • Pnvesligations
LARRY kORTON, P,E.
PRQfECT MANAGER
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F.O. BOX 3&)Oe
RALEIGH, N-C. 27&M
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FAXXI9197 831.2736
AWT
APPLIED WATER TECHNOLOGY, INC.
Air • Wastewater 9 Solid & Hazardous Waste
Pollution Control Systems • Chemical & Hazard Communications
P+erntining • Planning • Pnveuigatiom
3214 WESTERN BLVD.
CHARLES D. BLACKWELL P.O. BOX 3600i
ENVIRONMENTAL CONSULTANT RALEIGH. N. C. 276M

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TOWN OF MAIDEN
NORTH CAROLINA
28650
P.O. BOX 125 (764)-428-8578
September 20, 1991 OFFICE OF
TOWN MANAGER
Mr. Larry Horton, P.E.
Applied Water Technology
PO Box 36008
Raleigh, N. C. 27606
Dear Mr. Horton:
As per our telephone conversation September 19, 1991 please find enclosed
letters addressed to me from Mr. Larry Taylor, Wastewater Treatment Plant
Superintendent and Mr, Dennis Fox, Fox & Ritter, Inc. You will also find copies
of the Town's sewer easements requested.
Relating to items #1, 2, 3, 4 1 believe that the Council would approve the
following requirements:
5 (1) That Duck Head accept responsibility for maintaining and clearing
of both the Duck Head and Town easements.
(2) That the Town would have the rights of inspection on both ease-
ments before, during and after construction.
0j, (3) That Duck Head conform to N.C. Statutes as they relate to
material and construction laws.
0�(4) That Duck Head video tape the easement�aft-t-_r construction to assure
no damage to the Town's outfall line has occurred.
(5) That Duck Head consider having their outfall discharge below the
Town's discharge.
As we discussed on the phone, these requirements are my own. The Town Council
will have final word on what will be required to allow Duck Head's request, when
formally asked.
I hope this information is sufficient but if it is not, please do not hesitate
to contact me.
MES/db
Enclosures
Sincerely,
&�_
e<�`,�.. Marshall E. Shepherd
Town Manager
50
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FOX & RITTER, INC.
1612 E. OZARK AVE.
GASTONIA, N. C. 28054
September 17, 1991
Mr. Marshall Shepherd, Town Manager
Town of Maiden
P. O. Box 125
Maiden, N. C. 28650
Dear Mr. Shepherd:
Civil Engineers
Surveyors
665-6661 (704)
This is to reply to a letter.from Mr. Larry Horton of Applied
Water Technology to you regarding easements for a possible sewer
line from DucK Head Apparel, Inc. to Clark's Creek. Furthermore,
the sewer line would contain the treated waste (or plant
effluent) from the Duck Head.Apparel Plant at S. Main St. to
Clark's Creek.
Mr. Horton advises the initial plan is to parallel (as close as
possible) the existing Town of Maiden Sewer outfalls along Shady
Branch. Enclosed are the two (2) copies each of the applicable
recorded plats for the Town of Maiden Rights -of -way for the sewer
lines. One copy is for your reference and files and one copy is
to be forwarded to him (assuming you want to send them at his
request). Mr. Horton was correct in that the Town of Maiden does
have a 20 feet Permanent R/W - 10 feet each way from the
Centerline of the sewer.
Engineering wise, I see no objection to allowing Duck Head to
parallel the existing Town of Maiden Sewer Line - 10 feet away.
However, it will have to be a special engineered project in that
at some places, the Town of Maiden Sewer Line is shallow such
that heavy equipment should not be allowed on top of the line.
Other places will require crossing over and/or under the Town of
Maiden Lines. In some places, physical constraints- creeks,
power line rights -of -way, etc.) will not allow them to follow the
existing Town of Maiden Outfall lines. This is especially true
between S. D. Ave, and the Woonsocket Mills Properties (R/W Map
No. THREE), Sht. 3 of 11. In this area we have a 1211 water line
running parallel to the Outfall.
With regard to Item 2 of Mr. Horton's letter, perhaps the Town of
Maiden should require a TV inspection of the Town of Maiden
outfall lines after construction where they have used the Town of
��. Maiden easement for construction purposes. This is the only way
I know to prove that no damage has occurred to the existing Town

Page Two
llw Mr. Marshall Shepherd
September 17, 1991
of Maiden Sewer Lines.
It is hoped the above will help you in evaulating Mr. Horton's
letter. Please advise if you have any questions on the above
or any other questions.
Sincerely,
FOX ITTER,&- _::,- IN
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Dennis L. Fox, P. E.

TOWN. OF MAIDEN
NORTH CAROLINA
28650
P.O. BOX 125 (704) 428•8178
September 16, 1991
TO: Marshall E. Shepherd, Town Manager
FROM: Larry C. Taylor. Wastewater Plant Superintendent
RE: Duckhead Proposed Outfall Discharge Location
After studving the proposed Duckhead outfall discharge
location and conversation with the North Carolina division
of Environmental Management and other State agencies I have
learned that this location would not at this time have any
effect on Maiden's sewer outfall discharge. After much
study and after hearing this the Town probably would not
object to their plans, however I feel as many times true
with state requlation's that there could be a change
sometime in the future. So I recommend that even though it
would have no effect at present we should request DucE::head
to locate their sewer outfall discharge below the present
town discharge location.
Sincerel y ,
,<�c.,-7ror
Larry C. Tay
Wastewater Plant Superintendent
LCT/ J se

DIVISION OF ENVIRONMENTAL MANAGEMENT
September 13, 1991
MEMORANDUM
TO: Dale Overcash
FROM: Jacquelyn M. Nowell dd�
THRU: Ruth Swanek R(,5
Carla Sanderson
SUBJECT: Revision of Downstream Monitoring Site
Delta Mills, Inc.
NPDES Permit No. NC0006190
Catawba County
The Technical Support Branch has been contacted by Keith Haynes of the MRO
concerning the downstream monitoring site designated in the draft permit for the
subject facility. The location of 300 feet downstream of outfall will be very
near the discharge outfall for the Town of Maiden. After a review'of the model
results and stream profile, we recommend a revision of the downstream sampling
site. The downstream monitoring site for Delta Mills should now be Clark Creek
at State Road 1274.
If there are any questions concerning this revision, please contact me.
cc: Rex Gleason
Central Files
Wi;Ark-tlej

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DUCK HEAD
APPAREL. COMPANY; INC.
D�naFs"
220 Fast rlthen,; Street. Winder, Geor;;ia 20680 • 404-867-3111 • FAX [phone]
July 19, 1991
Mr. Dale Overcash
NC Division of Environmental Management
Water Quality Section
Post Office Box 27687
Raleigh, N.C. 27611-7687
RE: NPDES PERMIT MODIFICATION REQUEST
DUCK HEAD APPAREL CDMPANY, INC.
MAIDEN, NORTH CAROLINA
NPDES PERMIT NO. MC0006190
Dear Mr. Overcash:
Duck Head Apparel Company, Inc., requests that an NPDES permit modification be is-
sued for our Malden, N.C. wastewater treatment plant (WWTP). The permit modifi-
cation request consists of relocating the_e.tfjuent�discharge,iq�;,Clark s=Creek_.as
shown in Figure 1. The effluent hydraulic limit
mit reques,tedato remain :at»,1.0:--
M`GlD� It is requested that the NPDES perY expiration date be changed to July 31,
1995 to coincide with DEM's basin issuance strategy for Clark's Creek.
The WWTP is currently meeting NPDES permit effluent limits for all parameters
except toxicity. Based on the current WWTP performance, we believe that there will
be no difficulty in meeting the effluent requirements at Clark's Creek.
Your assistance and cooperation in resolving this matter is greatly appreciated.
The NPDES permit modification approval is part of our compliance with the proposed
schedule in the request fora Special Order by Consent which was submitted to
NCDEM previously. Please advise us if there is anything we can do to facilitate
approval of this NPDES Permit Modification request. If there are questions, or if
additional information is needed, please do not hesitate to contact Mr. Allen
McRee at our Maiden facility, or AWT at [phone]. We would appreciate
AWT being copies on any correspondence from DEM pertaining to this matter.
jSjin�cerel y,
Mark W. Beaumont
Vice President - Manufacturing
MWB : c gm
cc: Charles Blackwell, AWT
Richard Bridgeman, NCDEM
George Everette, NCDEM
Keith Haynes, NCDEM
McRee, Duck Head
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1 rrri {.Clarence_ Turner, Duck Head
w5'�4NJerry �Jack'son; Duck Head