NC0002305_Correspondence_19950508

NPDES DOCUHENT SCANNING COVER SHEET
NPDES Permit:
NC0002305
Guilford Mills WWTP
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Owner Name Change
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
May 8, 1995
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GUILFORD
May 8, 1995
Mr. A. Preston Howard, Jr., P.E.
Director, Division of Environmental
Management
P. O. Box 29535
Raleigh, NC
27626-0535
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Subject: DEM Concerns Regarding VWI TP Outfall —
Guilford Mills, Guilford East Site
NPDES No. NC0002305, Duplin County
MAY 0 1995
Dear Mr. Howard:.f`' .,
In September 1994, the Division of Environmental Management (DEIVI tisued r'r
an NPDES permit for the Guilford East Site in Duplin County which allows the facility to
expand beyond current capacity. As part of the transmittal letter for the final permit
(attached), DEM expressed concern regarding the location of the outfall for the facility.
The outfall does not extend into the main channel of the Northeast Cape Fear River but
to the edge of a swamp that borders and flows into the river. This outfall has always
been located in this general area. The letter indicated that this outfall location could
effect future permit limitations for specific chemical parameters as well as the required
instream waste concentration (IWC) for the whole -effluent toxicity (WET) limit. The
permit expires on July 31, 1996 to be consistent with DEM's basinwide planning and
permitting process.
Plans and specifications were submitted to DEM in late November 1994 to allow
expansion of waste treatment facilities. The authorization to construct (ATC) was just
issued on April 21, 1995 and was received by the plant the week of May 1, 1995.
Guilford Mills is extremely concerned about potential changes to the permit
requirements when the NPDES permit expires next year.
The design of our planned improvements is based upon the current NPDES
permit. Potential changes to permit limits because of the outfall discharge location are
a major concern since they may require us to immediately initiate another construction
project, or, more importantly, will change our approach to the expansion we are ready
to begin. Our consultant, CH2M HILL, has discussed this concern with a number of
DEM staff and there has been a general recognition that the timing of the permit
renewal and the ATC is unfortunate.
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CORPORATE HEADQUARTERS
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Mr. Howard
Page 2
We recognize that the present outfall location may affect the future IWC for
WET testing and that a toxicity reduction effort or extension of the outfall may be
necessary to comply with these requirements. We have been evaluating means to
eliminate periodic toxicity at our present WET limits and are continuing these efforts.
However, we are concerned that the outfall configuration could affect DEM's
determination of limits for BOD5 and COD in the near future. We do not think this is
reasonable because of the status of our planned improvements. Guilford Mills needs
guidance from DEM on this issue so that we can adequately plan for the near future.
Guilford Mills is requesting specific feedback from DEM regarding future permit
limits for the present outfall location. This should be possible because of the recent
efforts to complete the draft Cape Fear River Basinwide Water Quality Management
Plan. We recognize that DEM may require low flow estimates for the swamp area
where the outfall is located. At present, we would assume that this swamp provides a
small amount of dilution under low flow conditions.
Please call me at [phone] if you have any questions regarding this
request. Thank you for your help in this matter.
Sincerely,
Jimmy Summers
Corporate Environmental and Energy Manager
Cc: Larry Rising, Keith Westbrook, Dave Goodrich - DEM, Dave Adkins - DEM
Bill Kreutzberger - CH2M HILL
Attachments

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
Mr. Jimmy Summers
Guilford Mills, Inc.
P.O. Box 498
Kenansville, North Carolina 28349
Dear Mr. Summers:
AT54741
11:30E1-11\IFI
September 26, 1994
Subject: NPDES Permit Issuance
NC0002305
Guilford East Division
Duplin County
In accordance with your application for discharge permit received on June 9, 1993, we are forwarding
herewith the subject state - NPDES permit. This permit is issued pursuant to the requirements of North
Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the
US Environmental Protection agency dated December 6, 1983.
Based on your letter dated February 11, 1994, the following comments are offered:
a) Fecal Coliform
The Division agrees to phase in the fecal coliform limit as you requested. For the first year after
the effective date of the permit, Guilford Mills will only be required to monitor for fecal coliform.
Guilford Mills will be required to meet the fecal limit beginning one year after the effective date.
b) Total Residual Chlorine
You also requested that the limit for total residual chlorine (TRC) be raised to 74 µg/1. The TRC
limit of 28 µg/1 is not based on a saltwater standard, but given to dischargers to freshwater systems to
protect biota in the receiving stream from a discharge of total residual chlorine which may cause acute
toxicity. The limit is applied to all discharges without considering dilution, so the limit will remain at 28
µgn•
c) Biochemical Oxygen Demand
The Division will agree to a mass limit for biochemical oxygen demand as requested, but the
permittee should understand that a daily maximum concentration limit will be kept in the permit and that
concentration limits may be reinstated upon renewal, depending on the results of the Cape Fear River
basinwide management plan.
d) Total Suspended Solids
You also requested that the limit for total suspended solids be increased above currently -permitted
levels. During the site visit in 1993, excessive deposits of solids were observed in the swamp in the
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
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ige -2-
Guilford Mills
NC0002305
September 26, 1994
vicinity of the outfall. Since the Division has documented the buildup of solids in the receiving stream, no
increase in the mass of total suspended solids will be granted.
e) Dissolved Oxygen
Finally, you requested that the dissolved oxygen minimum concentration remain at 5.0 mg/l.
Raising the dissolved oxygen concentration is an attempt to provide some additional protection for the
receiving stream near the point of discharge. The treatment facility has equipment to provide post aeration,
but does not have to operate this system to meet the 5 mg/l. Meeting the 6.0 mg/1 minimum should not
cause an operational problem and will be an added safeguard to the water quality of the receiving stream.
Please be advised that the Division has concerns with this discharge as it was discovered that the outfall
does not extend into the main channel of the Northeast Cape Fear River, but to the fringe of the swamp.
i This could affect future allocations of limits for chemical specific parameters, and the limit given for the
1 whole -effluent toxicity test. The Division has also begun to require certain permittees to monitor for
settleable solids. Given the abundance of solids documented in the receiving stream, it is likely that this
monitoring will be placed in this permit in the future. For your information and planning purposes, be
advised that a settleable solids average of less than or equal to 5 ml/1 is considered to be acceptable in most
L cases. ----
If any parts, measurement frequencies or sampling requirements contained in this permit are unacceptable
to you, you have the right to an adjudicatory hearing upon written request within thirty (30) days
following receipt of this letter. This request must be in the form of a written petition, conforming to
Chapter 150B of the North Carolina General Statutes, and filed with the Office of Administrative
Hearings, Post Office Drawer 27447, Raleigh, North Carolina 27611 -7447. Unless such demand is
made, this decision shall be final and binding.
Please take notice this permit is not transferable. Part II, B.2. addresses the requirements to be followed
in case of change in ownership or control of this discharge.
This permit does not affect the legal requirements to obtain other permits which may be required by the
Division of Environmental Management or permits required by the Division of Land Resources, Coastal
Area Management Act or any other Federal or Local governmental permit that may be required.
If you have any questions concerning this permit, please contact Mr. David Goodrich, NPDES
Supervisor, at telephone number 919/733-5083, ext. 517.
Sincerely,
yr-ZA. Preston Howard, Jr., P. E.
cc: Mr. Jim Patrick, EPA
Wilmington Regional Office
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