NC0002305_correspondence_20030814

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GUILFORD MILLS. I N C. • G R E E N S B O R O, NC
P.O. Box 26969 • Greensboro, NC 27419-6969 • [phone]
August 14, 2003
VIA UPS GROUND -NEXT DAY LETTER
Mr. Alan W. Klimek, P.E., Director
North Carolina Division of Water Quality
512 North Salisbury Street
Raleigh, NC 27604
[phone], ext. 203
Subject: Request for Informal Settlement of Dispute
NPDES Permit NC0002305 Issued July 25, 2003
Guilford Mills, Inc. — Guilford East Plant
Kenansville, Duplin County
Dear Mr. Klimek:
DV OF WATER QUALITY
DIRECTORS OFFICE
This letter is to request an informal settlement conference with the Division of Water
Quality (DWQ) to resolve disputed issues regarding subject NPDES permit, according to
the procedures in Chapter 150B, Section 22, of the North Carolina General Statutes.
We request that an informal conference be held before the September 1, 2003 effective
date of the permit.
Background Information:
Subject permit is a renewal of a permit that expired on January 31, 2002. An application
for renewal was submitted as required and has been under review by DWQ since July
2001.
A Waste Load Allocation (WLA) Study was begun by Guilford Mills, Inc. (Guilford) in
2002, on the section of the Lower Cape Fear River affected by our discharge.
Preliminary findings of this Study indicate that the assimilative capacity of the receiving
stream is greater than permitted. Completion of this Study is pending suitable river flow
conditions.
Special Order by Consent (SOC) Number EMC SOC WQ01-011, was signed by the
director of the Environmental Management Commission on May 3, 2002. Guilford has
met the terms and conditions of this SOC, which expired on June 1, 2003. During the
term of the SOC, Guilford identified the need to construct addional upgrades to it's
wastwater treatment plant. On March 7, 2003, Guilford requested an Autorization to
Construct. On June 17, 2003, ATC Number 002305A02 was approved, and Guilford has
begun construction of these facilites which will cost approximately $1,000,000. On April
11, 2003, Guilford requested an amendment to the original SOC, requesting a new
expiration date of June 1, 2004. This amendment was requested for permit relief during
the construction period. The amendment has not been approved as of this writing.
H:\documents\Word\NC Plants\Guilford East\kr DWQ NPDES Permit 150B-22 Procedure 14AUG03.doc

Mr. Alan W. klimek
August 14, 2003
Page 2
Upon receipt of the draft NPDES permit, Guilford submitted a comment letter to DWQ,
dated May 19, 2003, that contained a request to delay issuance of the final NPDES
permit letter. This letter contained justification for our request. We are again requesting
that the renewal permit not be issued until the WLA study can be completed and results
reviewed by DWQ.
Disputed Issues:
1. Guilford respectfully requests that the renewal permit not be issued until the
WLA study can be completed and results reviewed by DWQ.
2. Guilford requests that the amendment to the SOC be issued as requested.
References (copies attached):
1. Request for amendment of SOC, dated On April 11, 2003.
2. Comment letter regarding draft NPDES permit, dated May 19, 2003.
Please note that a sludge thickener, an approved component of our WVVTP, is not listed
on the Supplement to Permit Cover Sheet. This was pointed out in our May 19th letter.
Please call me at 336-316-4319 if you have any questions or if you need any additional
information concerning this request.
Paul R. Bruesch, P.E.
Corporate Environmental Manager
Cc: David A. Goodrich —Division of Water Quality
Pat Durrett —Division of WaterQuality, Wilmington Regional Office
Brent Tumer, Huck Booz—Guilford East
Gilbert O'Neal, — ITT
George House — Brooks, Pierce, McLendon, Humphrey & Leonard
H:trlocuments\Word\NC Plants\Guilford EastUtr DWQ NPDES Permit 150E-22 Procedure 14AUG03.doc