NC0002305_Report_19970623

NPDES DOCUMENT $CANNINO 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
, e Q�i
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
June 23, 1997
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Guilford Mills Kenansvilie Toxicity Study
Prepared for
Guilford Mills Incorporated
June 23, 1997
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By
Grey Engineering, Inc.
Mocksville, NC

Guilford Mills Kenansville Toxicity Study
Prepared for
Guilford Mills Incorporated
June 23, 1997
-51
By
Grey Engineering, Inc.
Mocksville, NC

Guilford Mills Kenansville Toxicity Study
Table of Contents
Section Page
1.0 Background 1
2.0 Approach 1
3.0 Conclusions 2
4.0 Toxicity Dilution at the Point of Discharge 2
4.1 Outfall Relocation to The Main Channel 2
4.1.1 Swamp Transects 2
4.1.2 Biologist's Report by David M. DuMond 3
4.1.3 Permitting 9
4.1.4 Preliminary Outfall Design 10
4.1.5 Other Design Considerations 10
4.1.6 Constructability 11
4.1.7 Sequencing and Coordination 12
4.2 Pumping the Discharge to Other Points 13
4.3 No Action 14
5.0 Toxicity Reduction 15
5.1 Removing Toxics in the Treatment Process 15
5.2 Avoiding Toxics in the Production Process 16
6.0 Cogentrix Cooperation in the Outfall Project 17
Exhibit 1 - Toxicity Test History 18
Figure 1- Site Plan and Profile
Figure 2 - Ecosystems
Figure 3 - Enlarged Site Plan, Cogentrix
Figure 4 - Proposed Wastewater Outfall Plan and Profile
Appendix:
Copy of SOC
Letter From Jimmy Summers to Mike Williams Conceming Toxicity Progress
Toxicity Test Results from samples on 6/4/97 and 6/11/97 (Filtration Tests)
Toxicity Test Results from Samples on 3/11/96.(Coagulation Test)

Ma
1.0 Background
The Guilford Mills Kenansville Wastewater Treatment Facility (also known as Guilford East) is located
�► near the Northeast Cape Fear River at its confluence with the Goshen Swamp near Kenansville in Duplin
County, NC. See Figure 1 for a vicinity map.
The wastewater treatment facility was originally constructed in 1972 and permitted at a flow rate of 0.5
''R' mgd. The facility was upgraded over the years to 0.96 mgd and 1.25 mgd. The plant has now been
upgraded to operate at 1.5 mgd. The facility currently operates under permit number NC0002305.
A complex swamp system exists at the point of wastewater discharge. Figure 2 shows site related
ecosystems and the existing discharge location. Original NPDES permit limitations were developed
assuming that the full flow capacity of the Northeast Cape Fear River was available for dilution and
flushing. After a field investigation, State regulatory personnel recognized that the discharge did not
access the main body of the river and felt, therefore, that the permitted toxicity dilution requirements
should be changed from an In stream Wastewater Concentration (IWC) of 23% to 90%. The older limit
required the waste to be non -toxic (chronic value) after addition of 77% dilution water. The newer limit
requires the waste to be non -toxic after the addition of only 10% dilution water.
Exhibit 1 is a chronic toxicity test history compiled by Jimmy Summers, Guilford Mills Corporate
Environmental Manager. Exhibit 1 shows that the plant often failed to meet limits of 19% and began
rum
meeting more stringent limits of 23% only after most NPE surfactants were eliminated from the
production process. Given the history depicted in Exhibit 1, it is doubtful that the facility can comply with
high IWC toxicity restrictions.
Guilford entered into a Special Order By Consent (SOC) with the Environmental Management
Commission on November 11, 1996. A copy of the SOC is provided in Appendix A. Under the SOC
Pori (EMC WQ NO. 96-14), Guilford is allowed to operate without toxicity limits while it fulfills the various
requirements of the Order. The SOC generally requires that Guilford maintain vigilance in protection of
the environment while examining its options and proposing solutions which, when agreed to, will be
implemented in accordance with the SOC schedule. The production and submission of this report is
required by the SOC.
fifft
2.0 Approach
1
Three separate areas are addressed:
,,7, 1. Toxicity Dilution at the Point of Discharge: It is clear that Guilford cannot meet high concentration
limits for effluent toxicity. Three approaches for dealing with this issue are: 1) Relocating the
discharge to the main channel of the Northeast Cape Fear river through the Goshen swamp on
Plant property; 2) Pumping the discharge to other locations in the drainage system; and 3)
Continuing to discharge at the current outfall location, thus allowing the Goshen Swamp to
pre-process the wastewater prior to its eventual discharge in the main body. See Section 4.
2. Toxicity Reduction: Effluent toxicity may be reduced through enhanced wastewater treatament or
�► by eliminating toxics from the production process.There is some evidence to suggest that a
portion of the toxic compounds are held in a suspension of sub -micron dissolved particles which
may be agglomerated and settled through the use of a cationic polymer. Extracting toxics at the
treatment facility is normally difficult and expensive compared to the elimination of toxicants from
the production process. Smooth communication and reliable control between environmental and
production efforts can save large amounts of money. See Section 5.
3. Participation of Cogentrix in the Outfall Project: State officials have suggested that the Cogentrix
corporation join in the outfall relocation project. Section 6.0
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'�' Mocksville, NC Page 1

n 3.0 Conclusions
Guilford Mills Should:
1. Relocate the effluent outfall to the main body of the Northeast Cape Fear River as shown on
Figure 4. The estimated project cost of this relocation is $541,000. Section 4.1.5.
2. Offer Cogentrix the opportunity to share in the use of the new outfall and in its project expense.
1.4 Section 6.0.
3. Petition the State to set the lnstream Wastewater Concentration (IWC) for chronic toxicity to
27%. Request that flow be limited to 1.5 mgd and that mass effluent limits be retumed to the
levels set forth in Attachment A of the SOC as shown in the Appendix. See Section 4.0.
4. Further test the relationship between coagulation and toxicity reduction. Section 5.1.
5. Continue to avoid use of NPE surfactants if possible. Section 5.2.
6. Comply in a timely manner with other elements of the toxicity SOC. Copied to Appendix.
It should be noted that the wastewater treatment plant is capable of operating at 1.5 mgd and is currently
operating at only about 0.5 mgd. In order to protect its ability to prosper, Guilford should insure that it can
"scale up" operations to full capacity without violating wastewater treatment limitations.
4.0 Toxicity Dilution at the Point of Discharge
It is clear that Guilford cannot meet high concentration limits for effluent toxicity. Three approaches for
dealing with this issue are:
1. Relocating the discharge to the main channel of the Northeast Cape Fear river through the
Goshen swamp on Plant property. This is the recommended option and is discussed in Section
4.1;
2. Pumping the discharge to other locations in the drainage system. This is discussed in Section
4.2; and
3. Continuing to discharge at the current outfall location, thus allowing the Goshen Swamp to
pre-process the wastewater prior to its eventual discharge in the main body. This is discussed in
Section 4.3.
When Guilford's permitted waste flow increased from about 1 mgd to 1.25 mgd, the dilution toxicity limit
was changed from 19% to 23%. Since Guilford now proposes to increase permitted flow from 1.25 to 1.5
mgd, it is proposed that the dilution level be changed from 23% to 27%.
4.1 Outfall Relocation to the Main Channel of the Northeast Cape Fear River
This section discusses issues related to extending the outfall through the swamp system on the Plant
property and discharging into the main channel of the Northeast Cape Fear river.
4.1.1 Swamp Transects to Locate the Main Channel
MEI
General Discussion
rim The Goshen Swamp in the vicinity of the Plant is a very braided and dense system. There is Tittle
information available about the actual location of significant flow bearing channels. Two field transects
were accomplished. The reconnaissance team for the first transect ("A") included a consulting field
biologist, a registered engineer and surveyor (the author) and an engineering technician responsible for
(.' mapping. That transect was initiated with a Topcon GTS 303 total station, however, hurricane damage
had felled so many trees that proceeding with a conventional survey was not practical. Therefore,
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transect "A" was completed as a compass traverse with distance estimates. The initial field work on
transect "A" was begun on April 2 and completed on April 4, 1997. On June 18, 1997, transect "B" was
completed using a light weight surveying transit with stadia distance measurement to confirm transect "A"
and to check for alternate routes.
Figure 1 shows site topography and transect "A" profile.
4.1.2 Biologist's Report By David M. DuMond
Methods employed for this investigation were relatively simple. Access to most areas was limited by the
nature of the terrain and was covered on foot through water varying in depth from several inches to
several feet. Notes were taken in the field where necessary. The transect established to traverse the
swamp forest and intercept the main channel of the Northeast Cape Fear River was laid out using hand
compass and estimates of distances traversed. To be sure that the main channel was indeed
intercepted, swamp forest east of the suspected main channel was traversed far enough that open farm
land was visible. Movement through the swamp forest was severely hampered by the prevalence of
windfalls caused by hurricanes of the previous season.
No systematic surveys or collections of biological or ecological entities were made during the course of
this investigation. No specific searches for threatened, endangered or otherwise rare organisms were
made. Most observations were undertaken casually without rigorous intent at this time. Plant
communities have been defined on the accompanying map in order to reveal the general character of the
landscape surrounding the project area.
Hydrologic Characteristics of the Project area
From a regional geographic perspective, the Guilford Mill site is positioned in a rural, farmland setting. It
lays closely adjacent to the drainage of the Northeast Cape Fear River and about 1800 feet from the
main river swamp. Goshen Swamp is a major tributary of the Northeast Cape Fear at this point and joins
it roughly one mile northeast of the mill site. The Northeast rises near Mt. Olive adjacent to the drainage
of Thoroughfare Swamp, tributary of the Neuse River, and forms the southern common boundary
between Duplin and Wayne counties. It flows generally south toward Wallace and then on to Wilmington
where it joins the Cape Fear River. Goshen Swamp extends west past Mt. Olive almost to Newton Grove
in Sampson County. From the intersection of Goshen and the Northeast Cape Fear River, the Northeast
rises an additional 22 miles to the northwest, while Goshen Swamp rises almost 33 miles to the
northwest.
The active channels of the Northeast Cape Fear River and Goshen Swamp are heavily braided. Water
moving through these two stream systems follows a highly anastomosed system of channels that direct
the flow in ways dependent upon the prevailing hydrologic conditions in the basins. Well above the
project area both the Goshen Swamp stream and the Northeast Cape Fear River stream are each
contained in a single channel. Below the project area just north of the Sarecta Bridge the Northeast Cape
Fear again becomes confined to a single channel. The swamp forest corridor through the project area is
approximately 4000 feet wide along the eastem part of the project area. From the end of the access road
at the outfall the main channel of the Northeast Cape Fear River is roughly 1360 feet due east (Figure 2).
A very low, intermittent, natural levee parallels portions of the main channel of the river in this area.
The braided channels are a reflection of highly changeable hydrologic conditions along the flood plains of
the two streams. They represent channels that were once in use during an earlier period of stream
history or that are currently subject to channel cutting. The lack of relief in the river valley bottoms
promotes the formation of oxbows, cutoffs and a meandering drainage pattern. Partially as a reason for
and partially as a result of the braiding, a wide corridor of swamp forest has formed along the active flood
plain of both the Goshen Swamp and the Northeast Cape Fear River. In the winter and early spring
when evapo-transpiration rates are reduced throughout forested systems, water normally spreads across
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tocl
the flood plain and flows through the shallower braided channels or across the entire floor of the swamp
forest as a sheet several inches to several feet in depth. Aquatic wildlife forms respond accordingly and
use these intermittently flooded areas for foraging and reproduction. These areas perform the well
documented ecological function of flood peak flow reduction (Mitsch and Gosselink 1993).
As indicated above, water levels in the swamp forest vary considerably through the year depending on
precipitation and runoff regimes in the respective watersheds. Summers are generally the periods of
lowest flow through these systems. These are also periods when plants are removing moisture from the
soil and when evaporation rates from the soil surface are the highest due to higher temperatures. In spite
of these factors, summertime deluges can temporarily raise the water levels in the swamp. The most
obvious ecological function or value aside from flood flow reduction during such periods is sediment
retention.
Spring of this year was somewhat wetter than usual, based on general observation. The customary short
dry season of springs in this area was not realized this year. Winter water normally issuing from the
watersheds of these two streams were combined with the slight excess that came with the rains of
March. Water level fell noticeably each day during the field work between April 2 and April 4. When the
field work was begun on April 2, the water in the swamp forest was roughly 1.5 feet deeper than when
observed later on April 20. In many areas at the upper edge of the swamp forest where flowing water
had been observed in early April, only isolated puddles and soft sediments were present on April 20.
Because of the continuous effluent from Guilford Mills water regularly flows through the outfall plume area
of the swamp (Figure 2).
Habitat Reconnaissance
Habitats within the general vicinity of the project area consist of an assortment of human habitations,
fields, woodlands, and swamp forests associated with the drainages of both Goshen Swamp and the
Northeast Cape Fear River (Figure 2). Woodlands and wetlands on the Guilford Mills property are most
pertinent with respect to the present study.
A road maintained as access to the swamp traverses the distance from the rear of the plant site,
' paralleling the buried discharge pipe, to the edge of the swamp forest at the outfall. The road passes a
field on the south, but is bordered on that side mostly by young hardwood forest and some wetland
forest. Along the north side of the road, a branch of the swamp forest, an old oxbow, extends north and
roughly parallels the curvature of the road. Enclosed within the loop of the oxbow are a pine plantation
and a stand of upland, mixed pine -hardwood forest. To the north where swamp forest has been cut for
timber in recent years, shrub -scrub wetlands have resulted.
Hardwood forest has grown where fields once provided pasturage for livestock all the way to the edge of
the wetland. Moister versions of this forest type are codominated by sweetgum (Liquidambar styraciflua),
red maple (Acer rubrum) and water oak (Quercus nigra). White oak (Quercus alba), American beech
(Fagus grandifolia), mockemut hickory (Carya tomentosa) and southern red oak (Quercus falcate) are
more common in the dryer examples. Loblolly pine (Pinus taeda) is scattered through these woodlands.
f=+ Several understory species in both the subcanopy and shrub layers are important. Subcanopy strata
contain two characteristic woody, small tree species, flowering dogwood (Comus florida) and hornbeam
(Carpinus caroliniana) in dryer and moister areas, respectively. A third species, sourwood (Oxydendrum
arboreum) is scattered through the drier portions of the woodland. Common shrubs are pepper bush
(Clethra alnifolia), horse sugar (Symplocos tinctoria), wax myrtle (Myrica cerifera), and sparkleberry
(Vaccinium arboreum).
0.4 Upland mixed pine -hardwood and pine plantation are encircled within the old oxbow north of the access
road. The mixed pine -hardwood forest contains many of the same species as the hardwood forest
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discussed above, but generally has a greater number of loblolly pine stems in the canopy. Another stand
of pine plantation occurs next to the old field. The pine plantation is an area of planted loftily pine.
Naturally occurring pine forest grows closer to the plant site, and represents an• area that more recently
supported cultivated farm land.
The most expansive habitat or plant community type in the project area is swamp forest. There are many
minor variations of this habitat type depending on substrate and hydrologic characteristics. These natural
variations were not noted in detail during the course of this investigation. Visual evidence of human
activity within most of this forest system is minimal. Natural disturbances are associated with hurricane
windfall damage during the latter part of the previous growing season.
Swamp forest normally consists of only one well developed stratum, the canopy. Lower strata have not
had the opportunity to develop because of frequent flooding. Shrub and herbaceous species are limited
to the bases of canopy trees or logs and forest debris that remain for a time above flooded soil. Wasting
of soil from the uptumed roots of windfalls will eventually create additional mounds of material that will
rise above swamp forest soils and provide substrate for the growth of both wetland and upland shrub and
herb species.
Normally the canopy of the swamp forest is closed except following the event of an occasional fallen tree.
Now it has been extensively opened by hurricane damage. Additional light on the floor of the swamp
forest will for a number of years promote growth of shrubs and herbs as well as young individuals of
,u, canopy tree species.
Canopy species of the area that are considered more strictly swamp forest species are bald cypress
r`' (Taxodiuum distichum), red maple, swamp black gum (Nyssa biflora) and green ash (Fraxinus
pennsylvania). Other species of trees are more characteristically associated with the somewhat less
frequently flooded soils of flood plains. These are overcup oak (Quercus lyrata), willow oak (Quercus
piR phellos), swamp chestnut oak (Quercus michauxii), American elm (Ulmus americana) and sweetgum.
The typical subcanopy species, hornbeam, is also usually found in somewhat drier flood plain soils.
Woody vines using tree trunks for support and limited soil deposits at tree bases for substrate are poison
ivy (Toxicodendron radicans), rattan (Berchemia scandens), green briar (Smilax rotundifolia) and climbing
hydrangea (Decumaria barbara). Herbaceous species noted were butterweed (Senecio glabellus) and
violet (Viola sororia).
Rare, Threatened and Endangered Species
Rare plant species listed for Duplin County (Table 1.) are generally found in habitats other than those
known to occur within the project area. Most animal species are also specific to other habitats
Exceptions may be the American alligator and two of the three invertebrate species. Because of the
general lack of open areas along flowing streams, alligators are likely to be very infrequent in most of the
f;u' project area. Freshwater mussel shells were noted in the swamp forest during the course of the field
work, but were not collected for identification.
A species of aquatic snail, Viviparus intertextus (Say), not previously recorded in North Carolina, was
collected in the swamp forest approximately 100 to 200 yards east of the outfall pipe, while water levels
were still high. This find constitutes a considerable northern range extension for this species which .was
6.4 previously not known north of southeastern South Carolina. Specimens obtained during the field work
were identified by Arthur Bogan, malacologist with the North Carolina Museum of Natural History. This
species is not currently listed as threatened or endangered federally or in North Carolina.
Viviparus intertextus is a bottom -feeding species that here seems to associate with areas of clean
blackwater in shallowly flooded flats and channels in the spring. It seemed to occur in temporarily flooded
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areas where two species of aquatic moss Tontines filiformis and Fissidens fontanus) were growing
attached to stumps, tree bases and cypress knees. An additional species of aquatic snail, Planorbe!!a
trivolvis, was also collected in the same habitats. The latter is not considered rare in this area.
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Carl
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Table 1. Rare, threatened and endangered plant and animal species recognized as occurring in Duplin
County, North Carolina by the Division of Parks and Recreation, Natural Heritage Program
Common Name
Scientific Name
Vertebrates
American Alligator
E.Diamondback Rattlesnake
Four -Toed Salamander
Southern Hognose Snake
Red -Cockaded Woodpecker
Invertebrates
Pod Lance
Croatan Crayfish
Eastem Creekshell
Vascular Plants
Scale -Leaf Gerardia
Branched Gerardia
Venus Flytrap
Threadleaf Sundew
Lewis's Heartleaf
Pale Mannagrass
Spike Triodia
Carolina Clover
Alligator mississippiensis
Crotalus adamanteus
Hemidactylium scutatum
Heterodon simus
Picoides borealis
Elliptio folliculata
Procambarus plumimanus
Villosa delumbis
Agalinis aphylla
Agalinis virgata
Dionaea muscipula
Drosera fliformis
Hexastylis lewisii
Torreyochloa pallida
Tridens strictus
Trifolium carolinianum
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0111
Observations of Waste Water Plume
Waste water from Guilford Mills is currently sent by gravity through two 10 inch diameter pipes from the
plant site to the edge of the swamp forest complex, where it is released adjacent to the upper wetland
margin. No natural channel occurs at the point of the outfall. At times of high water in the swamp the
`.' effluent is diluted and swept to the south. Without the benefit of flowing water in the wetland forest the
waste water moves slightly to the north of the outfall and then flows in a southerly direction, becoming
somewhat more apparent over a wider and wider area of the swamp forest floor as it continues south. A
1=+ shallow channel that only intermittently carries swamp water is intercepted by the waste water roughly
100 ft southeast of the outfall, but this channel soon disappears down -flow and the waste water fans out.
The entire course of the waste water flow has not yet been investigated. It may eventually reach an ill
defined secondary channel that carries it to the primary channel.
Present interpretations are that an abundance of suspended materials have been deposited in the
wetland forest along a sediment plume that extends south from the outfall. This deposited material
follows the western edge of the swamp. Eastward the plume widens away from the upland into the
swamp for several hundred feet. A rough representation of this observed area of deposition has been
sketched on the accompanying map (Figure 2).
Geri
The suspected area of deposited solids is generally characterized by the strong odor of hydrogen sulfide,
a gray surface color and extreme softness. Anaerobiosis is indicated. The odor and the softness of the
sediments are not found elsewhere in natural swamp forest sediments of the area. Additional casual
observations seem to indicate that normal swamp forest invertebrate species including aquatic snails,
crayfish and clams are scarce or absent from this area, but that mosquito fish (Gambusia affinis) are
present in some of the surface waters.
There is some indication that the swamp forest within the plume is slowly deteriorating. There appears to
be a somewhat greater incidence of tree death that has resulted in what are now standing, rotting stems,
and a slight thinning of the canopy. Only a vague image of this condition can be gained from viewing
recent (pre -hurricane) aerial photography, but there are some visible differences in canopy sizes and
shapes of trees now growing in the plume area.
Summary and Conclusions
Guilford Mills, Inc. north of Kenansville, in Duplin County, North Carolina has since the early
1970's disposed of their waste water in swamp forest along the Northeast Cape Fear River just south of
its intersection with Goshen Swamp. This practice appears to have resulted in a buildup of a plume of
very fine sediment that has modified the swamp forest along the eastem edge of the wetland. The
'.' buildup may be responsible for apparent changes (tree death, gray surface color of sediments, sulfide
odor, reduction of animal diversity) within the plume area.
Swamp forest habitats northward and eastward of the outfall, as well as other habitat types in the
area do not seem to have been affected by the development of the deposits of fine sediment. This
seems further evidenced by the finding of two species of snails, one new to the state, that are generally
characteristic of unpolluted waters.
Literature Cited
ain Mitsch, W. J. and J. G. Gossalink. 1993. Wetlands. Man Nostrand Reinhold. New York. 722p.
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4.1.3 Permitting
r,
404 Wetlands
The swamp area shown in Figure 2 is 404 wetlands as indicated in the biologist's report. Construction of
the proposed outfall should be covered by US Corps of Engineers Nationwide Permit Number 7. This
1.1 permit requires that impacts to the wetlands be minimized during construction. Therefore, the
construction corridor will be held to a width of 30' or less. The corridor will be cleared of standing or fallen
timber and debris but will not be stumped. Since the outran will be elevated and supported on pilings, the
integrity of the existing cypress root system will be protected during construction.
FEMA
Duplin County rules do not require permitting for an industrial sewer outfall project. However, to minimize
hydraulic impacts, it is proposed that the outfall be constructed above the high water mark appearing on
trees in the swamp system.
+'1 NCDEM-Permits and Engineering
got
1l
Construction Plan Approval and Permission to Construct will be obtained from NCDEM.
NCDEM-Land Quality
Since the project is largely elevated, less than one acre of actual ground disturbance is anticipated.
Erosion and Sediment Control permits should not be required. However, the project must be designed
and constructed to minimize any sediment impacts regardless of permit status.
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4.1.4 Preliminary Outfall Design
100 Year Flood Elevation
As shown on the profile in Figures 1 and 4, the 100 year flood elevation is at elevation 62 ft msl. This
information was provided by the Duplin County Planner, Mr. Mike Aldridge. He indicates that, while the
area has not been given a final delineation on the FEMA flood maps, he has a file correspondence stating
that Mr. Ken Old of the Corps of Engineers determined 62 ftmsl to be the base flood elevation for
property in the vicinity of the site.
Preliminary Hydraulics
Preliminary hydraulic information is summarized below. Under emergency conditions the proposed
effluent chamber may surcharge slightly, however, the new sampling manhole located at the chlorine
building should not surcharge.
Preliminary Hydraulic Information
See Figure 4
Ground elevation at effluent chamber 70.5 ftmsl
Invert of old manhole below new chlorine bldg. 65.5 ftmsl
Invert of new mahhole at chlorine bldg 67.6 ftmsl
100 year flood elevation 62.0 ftmsl
High water mark on trees in the swamp 58.7 ftmsl
Guilford Mills permitted flow capacity 1.5 mgd
Cogentrix flow allowance 0.3 mgd
Diffuser headloss allowance at 2.0 mgd 24"
Length of pipe pressurized 3,600 If
Hazen Williams "C" 120
Allowable emergency hydraulic head in flood 5.5 ft
Available flow given 12" ductile iron outfall 0.79 mgd
Available flow given 18" ductile iron outfall 2.28 mgd
The Cogentrix flow allowance was arrived at by scanning the NPDES monthly reporting forms for the
period of record. The highest flow rate noted in the scan was approximately 0.30 mgd.
As indicated in the table above, a 12" diameter outfall is to small to function under gravity flow in flood.
Provision of an 18" outfall will insure proper function in flood situations and provide capacity for future flow
increases.
4.1.5 Other Design Considerations
Environmental damage to the existing swamp system is minimized if the outfall is elevated. Flood impacts
both to the outfall itself and to the environmental system are minimized if the line is constructed above the
local high water marks shown on trees in the swamp. It is advisable to provide a slope of at least 0.1% to
the outfall so that it can drain with acceptable velocity when the water level in the swamp is low. These
constraints require the outfall be elevated along the existing dirt service road for approximately 1,750 feet.
The outfall will be elevated above the swamp system for approximately 1,430 feet.
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Discharge Options
The pipeline route crosses a significant sub -channel prior to reaching the main channel of the river. In
order to achieve maximum dilution, it may be necessary to diffuse wastewater into both channels.
Guidance from State Water Quality officials will be sought in this regard.
4.1.5 Construction Cost Estimate
Cost estimates for gravity outfall are summarized in the table below. See Figure 4.
Item Title
Description Cost Comment
8
1 Effluent Chamber
6' diameter concrete
chamber 6' deep
5,000 Provide penetration for
Cogentrix as needed
2 Buried Outfall
130 If of 18" DI
6,000 May use PVC
3 Outfall Over Road 1,750 If of 18" DI on 220
piers
131,250 Piers @ 8200.00 ea.
Pipe @ $50.00/If
4 Outfall Over Swamp 1,430 If of 18" DI on 80
timber pile bents
232,500 Bents @ 82,000 ea.
Pipe © 550.00/If
5 Main Channel Diffuser DI valve, drop and
diffuser
8,000 20 ft long diffuser and bank
restoration
6 Maintenance Walkway 3 ft wide wood walkway 52,000
7 Sub -Channel Diffuser DI valve, drop and
Diffuser
8,000 as above
8 Clearing
1,430 If of Swamp, 30 ft
wide.
15,000
Move debris off route and
leave it to degrade. Do not
obstruct flow. Do not disturb
stumps.
9 Contingency 80,000
10 Design 40,000
11 Permitting 15,000
Total Estimated Cost 592,750
4.1.6 Constructabili y
Mr. Jerry Smith, Vice President, T. A. Loving Company, General Contractors, Goldsboro, NC., visited the
site and provided comment on constructability of the project. Mr. Smith is in charge of the Utilities
Construction Division for the company. That division employs approximately 300 persons and performed
approximately $34,000,000 in contract work in 1996. Loving was recommended to review the preliminary
project concept by other eastern North Carolina contractors who use the Utilities Division for specialty
sub -contract work on large projects. Mr. Smith visited the site on June 18, 1997. He stated that
equipment on mats should be able to work in the swamp during dry season conditions and he provided
some of the cost estimating information used above.
Construction methods which might permit use of the existing gravity outfalls and allow for trenching the
proposed extension to the main channel were discussed on -site with Mr. Smith and Mr. DuMond. The
environmental impacts of uprooting large stumps to create a trench for the new pipe section were thought
to be excessive.
Grey Engineering, Inc. Guilford Mills Kenansville Toxicity
Mocksville, NC Page 11

4.1.7 Seauencing and Coordination
Project design will depend upon obtaining accurate detailed survey information for the proposed route.
These surveys can only be accomplished after some clearing of the route. Regulatory, design and
construction administration elements of the project should agree on the outfall route prior to detail design
surveys. After that, sufficient low impact clearing should take place so that the design surveys may be
completed. As soon as detailed design surveys are completed, they should be forwarded to State Water
Quality officials for a determination on the number of diffusers required and final toxicity dilution limits.
The entire project should be coordinated with State and Federal (wetlands) review officials so that review
and approval schedules will permit construction to proceed in the driest time of the year.
Grey Engineering, Inc. Guilford Mills Kenansville Toxicity
Mocksville, NC Page 12

4.2 Pumping the Discharge to Other Points in the Drainage System
The possibility of pumping the wastewater discharge to other points in the Northeast Cape Fear drainage
system has been proposed. This option would require that the effluent be diffused into two channels of
the Goshen Swamp and into the main channel of the Northeast Cape Fear. Discharging to these points
would be accomplished by installing a wastewater forcemain in Highway 11, crossing two bridges and
constructing three diffuser systems. Assuming that one half of the wastewater could be diffused into the
Goshen and the rest taken into the Northeast Cape Fear, then approximately 6,600 feet of 12" diameter
force main and 9,600 feet of 10" forcemain would be required to discharge at the three locations.
The 16,200 feet of forcemain would be served by a pumping station with duplex 80 hp pumps producing
approximately 125 feet of system head and consuming approximately 60 kw of input power. The
following table provides a preliminary cost estimate for this option.
Estimated cost of Pumping Wastewater along NC Hwy 11 to Goshen and Northeast Cape Fear
Item Title
Description Cost Comment
1 Pump Station Duplex 80 hp Flygt 200,000 10ft wide rectangular station 9 ft
submersible station
deep with pumps and controls
2 12" forcemain
6,600 If of 12" PVC
198,000 $3011f
3 10 " forcemain
9,600 If of 10" PVC
278,400 $29/If
5 Channel Diffusers 3 diffuser and valve
assemblies
30,000 20 ft long diffuser and bank
restoration
6 Bridge Crossings
Additional cost of
crossing bridges with
ductile iron pipe on
supports.
50,000 Assumes that NCDOT will allow
pipe to be hung frm bridges.
NCDOT has rejected such
requests in recent years.
7 Erosion Control 16,200 If of impact and 80,000
restoration
8 Contingency 160,000
9 Design 80,000
10 Permitting
15,000 Wetlands permits in three
swamp sections at diffusers.
NCDOT permits will be
negotiated.
Total Estimated Cost 1,091,400
Environmental Consequences of this option.
Diffusing the Guilford wastewater into the swamps along NC 11 will deteriorate some rather pristine
systems and endanger areas not currently affected by wastewater discharge. This option appears to
have negative environmental impact.
Other Considerations
A variety of additional considerations are associated with this option. Issues such as additional easement
acquisition for diffuser placement and permission from NCDOT to use right of way and bridges for
pipeline routing remain in question.
Grey Engineering, Inc. Guilford Mills Kenansville Toxicity
Mocksville, NC Page 13

4.3 No Action
The plant has been discharging at its current location for 25 years. While the swamp system shows some
sign of stress, water quality in the Northeast Cape Fear has remained relatively high. The State should
consider that one important function of swamp systems is protection of the receiving stream from a
variety of overland pollutants. The environmental benefits of continuing to discharge at the edge of the
swamp should be considered by the State. It is very likely that diffusing the discharge into the swamp
system short of the main body of the river would be the best solution for the total environment. However,
the State's rules governing toxicity dilution would need to be examined to permit Guilford to operate at
attainable permit limits
Grey Engineering, Inc. Guilford Mills Kenansville Toxicity
Mocksville, NC Page 14

1-49
5.0 Toxicity Reduction
Toxicity should be controlled by removing toxicants in the treatment process and avoiding them in the
production process .
5.1 Removing Toxics in the Treatment Process
In the course of wastewater treatment plant evaluation and design for the new chlorination facility it was
observed that effluent suspended solids seemed high and that total solids seemed to be
fall disproportionately high when compared to suspended solids. A toxicity study was therefore performed on
final effluent as a control and treated clarifier influent. The clarifier influent was coagulated with cationic
polymer (MEC 998013), allowed to settle and decanted. Test results are copied in Appendix A. It was
determined that the coagulation resulted in a 25% decrease in TSS (80 mgl to 60 mg!) and a 65% (17 to
28) decrease in chronic toxicity. As a result of these findings, the plant was equipped with additional
clarifier baffles to enhance settling and the ability to add polymer prior to clarification was provided. The
fact that a cationic polymer was effective in TSS and Toxicity reduction pointed to the possibility that
anionic micro particles are mediating the toxicity effect.
To gain further insight, toxicity tests were performed on filtered and unfiltered clarifier effluent samples.
Sample filtration was accomplished using the Gelman 1 micron A/E glass fiber filter typical of TSS tests.
There was only slight difference in toxicity between the filtered and unfiltered samples. It is likely that
toxicity is mediated by sub -micron particles which can be agglomerated and removed from solution. The
Following table shows chronic toxicity versus TSS for a variety of tests.
rml
TSS and Chronic Toxicity (CV)
Sample Date TSS (mg/I) CV
March 11,1996 Effluent 80 17
March 11, 1996 Coagulated 60 28
June 11, 1997 32 65
June 4,1997 21 92
Since there seems to be fairly strong correlation between TSS and toxicity and no difference in toxicity
between filtered and unfiltered samples. Toxicity is probably at least partially mediated by sub -micron
particles which can be coagulated using a cationic polymer. This is quite plausible since extended
aeration plants operated at low F/M ratios tend to produce an ash like, anionic, micro floc. The presence
of surfactants would tend to hold that floc in suspension. It is likely therefore, that one direction for toxicity
control at the wastewater treatment plant is to provide for a more thorough agglomeration of sub -micron
particles either through a process of enhanced bio-flocculation (probably by operating the plant at higher
F/M ratios) or by the use of coagulants.
It should be noted that there are a variety of factors affecting particle agglomeration and removal
including: bio-floc characteristics; hindered settling regimes in the clarifiers; particle charge management
through selection of proper coagulants; mixing; dispersion; particle contact mechanics; and the presence
of inhibitory agents.
It is recommended that further study be done on correlations between sub -micron particle removal and
toxicity reduction. It is obvious that TSS reduction alone does not reduce toxicity. Filtered samples have
no TSS under the standard test. Particles that might have gotten through the filter need to be coagulated
and removed.
ram+
Grey Engineering, Inc. Guilford Mills Kenansville Toxicity
Mocksville, NC Page 15

5.2 Avoiding Toxics in the Production Process
The Toxicity Reduction Evaluations (TRE's) performed in February and May, 1994 suggested that
surfactants, cationic metals and amonia were likely sources of toxicity with surfactants making the most
significant contribution.
When Guilford reduced the use of nonyl-phenol-ethoxylate (NPE) surfactants in early 1995, effluent
toxicity improved. NPE was contained in a chemical used to clean out dye machines between batches.
The replacement chemical did not perform well and left a residue in the machines which deteriorated
product quality. As the quality of the finished product declined, customer satisfaction and economic
viability were threatened. In order to protect its market, use of the better cleaning agent was resumed in
August, 1996. A search had been under way to find a better substitute and, after extensive testing,
another substitute for NPE surfactant was placed into service in March, 1997. Effluent toxicity has again
been reduced.
Successful production and finishing of fabrics is a dynamic and competitive endeavor. Market forces and
consumer preferences change frequently. New dye colors are demanded by customers and quality
control must be precise. It is typically difficult for production process control to anticipate wastewater
treatment issues in chemical selection.
In some instances the wastewater treatment process must be enhanced to remove a pollutant critical to
successful production. In other instances product substitution can avoid costly wastewater treatment
procedures. The company will always balance the cost of removing a pollutant from its wastewater
against the benefit of putting it in there to begin with. If enhanced coagulation will remove the offending
agent then it may be best to coagulate. Reliable communication between wastewater treatment and
production insures that the State or Federal govemment will remain outside the communication loop.
Grey Engineering, Inc. Guilford Mills Kenansville Toxicity
Page 16
Mocksville, NC

ral
6.0 Cogentrix Cooperation in the Outfall Project
Cogentrix discharges wastewater at the edge of Goshen Swamp in much the same manner as Guilford
Mills. State Water Quality officials have suggested that Cogentrix and Guilford cooperate on outfall
construction and share in the use of the facility.
Figure 3 shows the relationship of Cogentrix to the proposed effluent chamber. The Cogentrix site was
visited and wastewater records were reviewed. Records indicate that the facility had processed asmuch
r°,, as 0.31 mgd of wastewater in the past depending upon rainfall events. Water Quality officials have stated
that a permit can be prepared which protects Guilford from variances in Cogentrix wastewater by
establishing sampling points upstream of the effluent chamber so that neither Guilford nor Cogentrix
make the other liable for "end of pipe" situations.
Guilford may wish to lease hydraulic capacity to Cogentrix in an amount not to exceed 0.4 mgd. Lease
provisions could include payment of an initial capital cost and protection from liability. Guilford should
Fogl review a draft of the State's proposed sampling and liability agreement prior to final lease execution.
Cogentrix should provide Guilford with daily flow records to verify that the capacity reservation is not
exceeded.
rig
Cogentrix would further need to construct a pumping station and 1,500 If of 6" PVC force main at an
estimated project cost of approximately $150,000.
r.,
Grey Engineering, Inc. Guilford Mills Kenansville Toxicity
Mocksville, NC
Page 17

T1
Mel
Exhibit 1
Guilford East Chronic Toxlclty Test History
Month
Pass/Fail _goer Information
in Oct 1990 Pass 19%
July 1991 Pass- 19%
January 1992 Fail 19%
rwl February 1992 Fail 19%
March 1992 Fail 19%
April 1992 Fall 19%
May 1992 Fail 19%
pr' June 1992 Pass 19%
August 1992 Pass 19%
October 1992 Pass 19%
r"+ January 1993 Pass 19% (DEM split failed)
April 1993 Fail 18%
May 1993 Pass 19%
July 1993 Fail 19%
� ' September 1993 Pass 19%
October 1993 • Fail 19%
November 1993 Fail 19%
MI December 1993 Pass 19%
January 1994 Fail 19% 1 god IC25.=3896,IC5�>50%
February 1994 Pass
�, April 1994 Pass 19%
May 1994 THE 19% IC25=25%,IC50 =42%
July 1994 Pass 19%
October 1994 Pass 19%
F January 1995 Fail 19%
February 1995 Fail 19%
March 1995 Pass 19%
min July 1995 Pass 19% Chronic value = 44%
October 1995 Pass 19%
January 1996 Pass 23%
March 1996 Full Range Uncoag-17%,Coagul-28%
':' April 1996 Pass 23%
July 1996 Pass 23%
November 1996 Pass 23%
January 1997 Full Range Chronic Value - 16.3%
February 1997 Full Range Chronic Value - 32.53%
n
rin
Grey Engineering, Inc. Guilford Mills Kenansville Toxicity
ow, Mocksville, NC Page 18

Appendix
Copy of SOC
Letter From Jimmy Summers to Mike Williams Concerning Toxicity Progress
Toxicity Test Results from samples on 6/4/97 and 6/11/97 (Filtration Tests)
Toxicity Test Results from Samples on 3/11/96 (Coagulation Test)

DEC 19 '96 02:25PM GUILFORD CORP ENGR P.3/10
, NORTH CAROL) •
ENVIRONMENTAL MANAGEMENT COM WISSION
COUNTY OF DUF%T
IN .nECE 1VIATTER OF ) •
NORTH CAROL1N ) SPECIAL ORDER BY CONSENT
NPDES PERMIT ) E1VYC WQ NO. 96-14
NO. NC0002305 )
HEIR BY GUILFORD MILLS )
INCORPORATED)
w
Pursuant to provisions of North Carolina General Statutes (G.S.) 143-215.2 and 143-215.67, this
ron Special Order by Consent is entered into by Guilford Mills; Inc., hereinafter referred to as Guilford
Mills, and the North Carolina Environineotal Management Commission, an agency of the State of
North Carolina created by G.S. 143B-282, and hereinafter referred to as the Commission:
r.,
fon
1. Guilford Mills and the Commission hereby stipulate the following:
a. That Guilford Mills bolds North Carolina NPDBS Permit No. NC0002305, for
operation of an existing wastewater treatment works and for making an outlet
therefrom for treated wastewater to the Northeast Cape Fear River, Class "C-Swamp"
waters of this State in the Cape Fear River Basin, but will be unable to consistently
comply with the final effluent limitations anticipated in the renewal of Permit No.
NC0002305 to be issued effective July 31, 1996. Compliance may require preparation
of plans and specifications for construction and operation of additional treatment
works, and/or relocation of the outfall pipe 001.
b. That noncompliance with final effluent limitations will constitute a cause and
contribution to pollution of the waters of this State named above, and Guilford Mill'
is within the jurisdiction of the Commission as set forth in G.S. Chapter 143, Article
21.
c. Since this Special Order is by Consent, neither party will file a petition for a
contested case or for judicial review concerning its terms.
d. Thar no extension of this order will be granted beyond the expiration date of
January 31, 1999.
2. tuilford Mills desiring to comply with the permit identified in paragraph la. above, hereby
agrees to do the following:

DEC 19 '96 02s25PM GUILFORD CORP ENGR
P.4/10
a.
b.
Comply with all terms and conditions of the permit except those effluent limitations
identified in paragraph la. above. See Attachments A, B, and C for all monitoring
requirements and effluent 'limitations. The peimittee may also be required to monitor
for other parameters as deemed necessary by the Director in future permits or
administrative betters.
Undertake the following activities in accordance with the indicated time schedule:
1) Continue implementation of the Toxicity Reduction Evaluation and submit derailed
quarterly IRE progress reports in triplicate to the Wilmington Regional Office no
later than the 30th day of each March, June, September and December for the
duration of the SOC. Quarterly TRE progress reports will contain TRE activities
undertaken during the quarter, and activities proposed for the upcoming quarter. The
TRE should consider but is not limited to effluent characterization and identification
of -suspected toxicants, evaluation of point source contributions of toxicity,
engineering evaluation of the WWTP, activated sludge treatabiiity/refractory studies,
evaluation of chemical usage and product substitution, and WWTP/Production
changes which may affect toxicity.
2) Conduct a study of the Northeast Cape Fear River system in the vicinity of
Guilford Mills, Inc. and study alternatives to meet new NPDES permit limitations.
The study will model the flow regime of the River/swamp system adjacent to the
plant, include a surveyed transact of the River/swamp. system from the area of the
present outfall area, and will suggest alternatives for meeting new permit limits. The
study will be completed and three (3) copies of the report of the findings will be
submitted to DEM on or before June 30. 199Z.
3) Meet with DEM to determine course of action based on study, and select
alternative for meeting new permit limits on or before July 31. 1997.
4) Submit application for modified NPDES Permit, if needed on or before August 31.
1997. ei2.-A1-4 :50A---Hq7
ritk °tart t,cr
5) Submit application for authorization to construct fo i selected alternative on or
before September 30. 1997.
Gan t)e-
4:6 DIC6) Receive approval for authorization to construct November 30. 1997.
7) Begin construction of necessary improvements to achieve compliance on or before
December 15. 1997.
8) Complete construction of necessary improvements to achieve compliance on or
before September 30. 1998.
eonslr.l' a4Nr'ni otir
i,.S�sWt—I`I`l$
Oe-ekriA'

DEC 19 '96 02:26PM GUILFORD CORP ENGR P.5/10
9) Comply with final effluent limitations contained to NPDES Permit NC0002305 on
or before Comber 30. 1991.
c. During the time in which this Special Order.by Consent is effective, comply with the
interim. effluent limitations contained in Attachments A, 13, and C. The following
reflects. only the requirements that have been modified from previous NPDES
requirements:
Parameter
Toxicity
Parameter
Fecal Coliforni Weekly Composite effluent
Permit Limitatiin
No observable inhibition of
reproduction or significant
mortality at an effluent
concentration of 23 %
Permit Monitoring Requirements
Conductivity 3/Week Composite @ 1X, and D
Annual Pollutant None as Required by previous
Analysis permit.
SOC Limitarioct
M •
Full range chronic toxicity
monitoring at serial dilutions of
60%, 46%, 23 %, 1 1.5 %, and
6.5 %
SOC Requirements
Weekly Grab effluent
3/Week Grab @ 'U, and D
Annual sampling
@ effluent (See attachment C)
d. No later than fourteen (1.4) calendar days after antedate identlfiied for accomplishment
of any activity listed in _2b. absave bmix to the, hector of DEM written✓ oofice of
compliance or noncompliance_ therewith. In the casea _oacompliance the notice
shall include a statement of the rea9nfs) for noncompliance. remedial action(s) taken,
and a statement identitving the extent to which _subsequent dates or times for
accomplishment of listed activities may be affected, .
3. Guilford Mills agrees that unless excused under paragraph 4, Guilford NEW will pay the
Director of DEM, by check payable to the North Carolina Department of Environment,
l ealth and Natural Resources, stipulated penalties according to the following schedule for
failure to meet the deadlines set out in paragraphs 2b. and 2d., or failure to comply with the
effluent limitations/monitoring requirements contained in Attachments A, B, and C.

'. DEC 19 '96 02:26PM GUILFORD CORP ENGR P.6/10
Pri
rwl
Failure to meet a schedule date 5100/day for the first 7 days; $500/day
thereafter
Failure to maintain compliance with S1,000 per violation
any modified limit contained in the
soC.
Failure to achieve compliance with 510,000 per month
effluent Limits at final compliance
deadline of October 30, 1998 and beyond.
Failure to monitor chronic toxicity $5,000 per omitted value
in accordance with the schedule
'contained in attachments A and/or B.
4. Guilford Mills and the Commission agree that the stipulated penalties are not due if the
company satisfies DEM that noncompliance was caused solely by:
a. An act of God;
b: An act of war;
c. An intentional act or omission of a third party but this defense shall not be available if
the act or omission is that of an employee or agent of the defendant or if the act or
omission occurs in connection with a contractual relationship with the puttee;
d. An extraordinary event beyond the permit' control. Contractor delays or failure to
obtain funding will not be considered as events beyond the permittees control; or
e. Any combination of the above causes.
•
Failure within thirty (30) days of receipt of written demand to pay the penalties, or challenge
them by a contested case petition pursuant to G.S. 150E-23, will be grounds for a collection
action, which the Attorney General is hereby authorized to initiate. The only issue in such an
action will be whether the thirty (30) days has elapsed.

. DEC 19 '96 02:27PM GUILFORD CORP ENGR
P.7/10
5. This Special Order by Consent and any terms, conditions and interim effluent limitations
contained herein; hereby supersede any and all previous Special Orders, Enforcement
Compliance Schedule Letters, terms, conditions, and limitations contained therein issued in
connection with NPDES Permit No..NC0002305. •
6. Noncompliant with the terms of this Special Order by •Consent is subject to enforcement
action in addition to the above stipulated penalties, including injunctive relief pursuant to
G.S. 143 215.6C.
'M' with all schedule dates, terms, and conditions of this document.
fort
fal
Pq
OR1
45,
mR
PM
M9
mm
7. The permittee, upon signature of the Special Order by Consent, will be expected to comply
8. This Special Order by Consent shall expire on January 31.j9g9.
For Guilford Mills, Inc.:
'ch, Chief Operating Officer
rd Mills, Incorporated
Date Glrrlq,6
For the North Carolina Environment Management Commission:
9(7 Chair of the Commission
Date /0"//‘

l 1 1 1 1 3 3. 1 1 3 3 1 1 1 1 1 1 1
•
EMC WQ No. 96-14
ATTACHMENT Aka
Guilford Mills, Inc.- NPDES Permit i+(C0002305
Ali). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - interim
During the period beginning on the effective dale of this Special Order aid lasting until Ocsalier 30. V98. Permitted is autleocizad to dladiarge from outfall serial number
001. Such discharges shall be limited and monitored by the petrmittee es specified below:
.
Effluent Cherarlerjsti, Discharge f.imitelions Monitoring Reauiremenlg
Units as Spocllied Measurement Sample **Sample
Monthly Average Addy Mar Frame/ley Tune Lotellen 55
Flow 1.25 MGD Cosdinuoue ReeorcIg 1 or E
BOD, 5 day, 20 degrees C (lbalday) 83.4 Ibs/day. 125.1 lbs/day 3/Week Composite B
DOD, S Day, 20 dngFeee C (ngll) 12.0 mall 3/Week Composite B
COD 3000.0 lbelday 6000.0 U lday Weekly Composite B
Total Suspended Solids 1035.0 lbalday 2071.0 Ms/day 3/Week Composite E
Sulfide 10 lba/day 20.0 lbsfday Weekly Grab E'
Phenols 5.0 lbalday 10.0 tbs/day Wcckly Grab . B
Fecal Cofiform (Geometric Mean) 2001100 sal 400/100 m! Weekly Drab E
Total Chromium 217.0 uall Weekly Composite B.
Total Resided Chlorine *** 28.0 ugh Weekly Grab E
Dissolved Oxygen's* Week Grab L,U,D
Tempt: um 3/Week Grab E,U,D
Chloride 2/Month Composite B •
Copper 2lMoutb . Composite E
Oil and 0rcase 2/Month Composite E
Zino Mandl Grab E
Total Phosphorous Monthly Composite: E
Total Nitrogen (NO2+NO3+TKN) Monthly Composite E
amnia Toxicity * (Auacltment 0) Quarterly Composite E
Conductivity 3/Week Grab • U,D
Annual Pollutant Analysis (APAM) (Attachment C) Annually E
* Toxicity monitoring shall be conducted es required in Attachment B.
Sample London: I - Influent, B - Efiluce!, U - Upstream at nearest scnessile point, D - Immediately downstream at the Sancta Bridge.
** The deify average effluent dissolved oxygen concentration 'hall not be loss than 6.0 mg/1.
*** , Total residual chlorine should only be limited if added to die wastanreem.
Tha pH shall not be lean than 6.0 standard units nor greater than 9.0 standard snits and shall be by grab sample three times per week at the affluent.
Thera shall be ao discharge of floating solids -or visible foam in other than tram amounts.
The permitlea may also be required to monitor for other parameters as deemed necessary by the permit or Administrative iett4m.

DEC 19 '96 02:27PM GUILFORD CORP ENGR P.9/10
ATTACHMENTB
CONIC TOXICITY MONITORING (QUARTERLY)
• - Guilford 1]]s, Inc.
NPDES Permit NC0002305
EMC SOC WQ 96-14
. Ouplin County .
The Permittee shall conduct chronic toxicity tests using test procedures outlined in:
The ?Torth Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure (September, 1994) or
subsequent versions.
The effluent concentration defined as the Xnstreara Waste Concentration (lsWC) shall be 2
Recommended effluent serial dilutions for the full range test are 60%, 46%, 23 %, 11.5%, and 6.5 %
(these concentrations may be modified upon prior approval from the Environmental Sciences Branch
provided that phase XZ methodology is adhered to). The chronic value for the analysis- will be
determined using the geometric mean of the highest concentration having no statistically detectable
impairment of reproduction or survival and the lowest concentration that does have a statistically
detectable impahmeut of reproduction or survival. The presence of 48 ' hour acute toxicity will be
determined using Fishers Exact Test at 48 hours from test initiation. Collection methods, exposure
regimes, and further statistical methods are described by the document referenced above.
•
The permit holder shall perform at a minimum, quarterly monitoring using these procedures to
establish compliance with the Order condition. Full range toxicity monitoring is to be conducted during
the months of January., April, July, and October. Effluent sampling for this testing shall be performed
at the NPDES permitted final effluent discharge below all treatment processes.
All toxicity testing results required as part of this Order condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the months in which tests were performed, using the
appropriate parameter code T 3B for the chronic value and TGA3B for the 48 hour Acute Toxicity
measure (Pass/Fail). Additionally, TEEM Form AT-3 (original) is to be sent to the following address:
Attention:
Environmental Sciences Branca
North Carolina Division of
Environmental Management
4401 Reedy Creek Road
Raleigh, NC 27607
Test data shall be complete and accurate and include all supporting chemical/physical measurements
pe.oroaed in association with the toxicity tests, as well as all dose/response data. Total. residual
chlorine of the effluent toxicity sample must be measured and reported if cb.lorine is employed for
disinfection of the waste stream.
Should any test data from this monitoring requirement or tests performed by the North Carolina
Division of Environmental Management indicate potential impacts to the receiving stream, this Special
Order by Consent may be re -opened and modified to include alternate monitoring requirements or
limits
Nara Failure to achieve test conditions as wed in the cited document, such as minimum control
organism survival and appropriate eavironznental controls, shall constitute an invalid test and will
require immediate retesting (within thiity (30) days of initial monitoring event). Failure to submit
suitable test results will constitute noncompliance with monitoring requirements.

r DEC 19 '96 02:28PM GUILFORD CORP ENGR
.•
P.10/10
ATTACEMENT C
ANNUAL POLLUJTANT ANALYSIS MONITORING (APAM)
Guilford Mills, Inc.
EMC SOC WQ 96-14
NPDES Permit NC0002305
Duplin County
TL• : Permittee shall conduct a test for pollutants annually at the effluent from the treatment plant. The
,.4 discharge shall be evaluated as follows:
(1) A pollutant analysis of the effluent must be completed annually using EPA approved methods for
the following analytic fractious (a) purgeables (Le., volatile organic compounds); (b) acid extractables;
(c) base/neutral extractables; (d) organochlorine pesticides and PCB's; (e) herbicides; and (f) metals
and other inorganics. The Annual Pollutant Analysis Monitoring (APAM) Requirement Reporting Form
A and accompanying memo, to be provided to all discharges affected by this monitoring requirement,
describes the sampling and analysis requirements and lists chemicals to be included in the pollutant
analysis. This monitoring requirement is to be referred to as the "Annual Pollutant Analysis Monitoring
Requirement" (APAM) .
ti
(2) Other significant levels of organic chemicals must be identified and approximately quantified. For
the purpose of implementing this requirement, the largest 10 GC/MS peaks in the purgeable
ram► base/neutral extractable, and acid extractable fractions (or fewer than 10 if less than 10 unidentified
peaks occur) for chemicals other than those specified on the APA requirement Reporting Form A
should be identified and approximately quantified as stated in the APAM Reporting Form A
in....cuctions. This part (item 2) of the APAM requirement is to be referred to as the "10 significant
peaks rule".
ANNUAL POLLUTANT ANALYSIS MONITORING SHOULD BE CONDUCTED ]N
CON I NCTION WITH EFFLUENT TOXICITY MONITORING

fmt
GUILFORD
F
A
B
R
1
C
GUILFORD M I L L S, I.N•G.. .• G R E E N S S O R O, NC
.P.O. Box 26969 • Greensboro; NC 27419-6969 • [phone]
March 3, 1997
Mr. Michael F. Williams
Environmental Specialist
Division of Water Quality
Wilmington Regional Office
127 Cardinal Drive Extension
Wilmington, NC
28405-3845
Subject: Toxicity Reduction Evaluation (TRE) Letter Response
Guilford Mills, Inc. - Guilford East Plant, Kenansville
NPDES Permit No. NC0002305
Duplin County
Dear Mr. Williams:
We are in receipt of your letter dated February 14, 1997, concerning the TRE
Progress Reports at the Guilford East Plant. This letter contains our response to
the issues raised in your letter.
Enclosed, please find the results of chronic toxicity tests that were performed on
samples of clarifier influent and final effluent. The clarifier influent was
rz9 flocculated with a polymer and allowed to settle. The supernatant from this
sample was tested. These tests were run to test the hypothesis that a certain
portion of the toxicity in the effluent is partitioned to the sludge. The hypothesis
is based on information available that shows that surfactants like nonyl-phenol
ethoxylates (NPEs) and alkyl -phenol ethoxylates (APEs) are toxic and tend to
partition to organic phases. Guilford Mills undertook a clarifier renovation
project (addition of baffles under the weirs) in order to reduce that amount of
sludge particles which escape the clarifiers. It is believed that the baffles will
reduce suspended solids, BOD, and effluent toxicity.
Guilford Mills performed a TRE study in 1994 which showed that surfactants
were the likely cause of effluent toxicity at the Guilford East Plant. After the

Csol
Mr. Williams
Page 2
study, the company identified nonyl-phenol ethoxylates (NPEs, .a class of APEs)
as the likely cause of the toxicity. The company made an effort to identify NPEs
and APEs in chemicals being used at the plant, and to reduce the amounts of
these surfactants being sent to the WWTP for treatment. One chemical in
particular was targeted for reformulation as a result of this process, since it.
accounted for a large amount of the NPE going to the WWTP. This change
resulted in decreased toxicity in the effluent. Copies of the study reports were
previously sent to DWQ. Please find enclosed several e-mail letters and some
articles related to NPE and APE toxicity. This information forms the basis for
our belief that these surfactants are toxic when partially degraded in treatment
plants.
`' Guilford Mills will investigate the cause and effects of copper in the effluent as
part of the current TRE. It is likely that a majority of the copper in the
,., wastewater is organically bound, since most of it comes from use in dyestuffs.
The textile trade association ATMI has performed studies that have shown that
organically bound copper is not toxic even at very high concentrations. The
TRE study performed in 1994 did not directly point to metals as being a cause of
toxicity in the Guilford East effluent.
Please call me at [phone] if you have any questions or need any
additional information.
Sincerely,
Jimmy Summers
Corporate Environmental and Energy Manager
cc: Brent Turner, Dean Lee, Bernie Flynn
John Grey - Grey Engineering, Inc.

Water Tochnolosv
9103421522 P-01
OBI
Pal
fogl
rill
caa
1-49
WATER TECHNOLOGY AND CONTROLS, INC.
Water Treatment Chemistries & Environmental Laboratory
Date: 6/17/97
# pages 4
To: John Grey, Jr.
President, Grey Engineering, Inc.
fax [phone]
From: Michael Shelton
Subject: Results from wet chemistry and toxicity analyses of
Guilford Mills East effluent. jw'pL*. cle4 t.: (o/047 m5
All analyses of effluent from the Guilford Mills East
facility in Kenansville, NC have been completed. The results
are summarized as follows:
Parameter Resul.
Total Suspended Solids 21 mg/1
Total Phenols 0.014 mg/1
Chronic Toxicity:
Untreated NOECz= 92%
LOEC2 >92%
Filtered
NOEC.. 92%
I,OEC= >92%
ti
= NOEC- No Observed Effect Concentration
2 LOW- Lowest Observed Effect Concentration
The wet chemistry report form as well as the chronic toxicity
reproduction bench sheets for both the untreated and filtered
sample tests are included with this cover Sage.
Please contact the Water Technology and Controls, Inc.
laboratory at [phone] if you have any questions or need
any additional information. Water Technology and Controls,,
Inc. works hard to provide the best environmental testing
services available. We thank you for your patronage.
Offices: 106-A South Walnut Circle • P.O, Box 8808 • Greensboro, N.C. 27419 • [phone]
Laboratory: 642 Tamco Road • Reidsville, N.C. 27320 • [phone]

Water TechnoIogle 9103421522
P. 02
CLIENT t
(k,t104.LEc,s-1-•
SAMPLE DATE!
`-' SAMPLE: �„ )eA. ,39-; 1 y1I SAMPLE RGVD: rO Mt"
SAMPLE ID# ; 4169.")Cral3
PARAMETERS
r=t
TSS,
COMMENTS
Y • •YM• •••••••rrr•••r• �.
• • ••r• • • •••
RESULTS ANALYSIS ANALYST
Dote '
a� tvjjam. 6-6-qi 5e&A
t. �I' l� •• is `� •C
_r rw•••Ad _.
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•w •_

•
Water Tech no 1 oa a
9103421522 P.03
WATER TECHNOLOGy AND CONTROLS, INC.
Water Treatment Chemistries &.Erw7rvnmenfal Laboratory
CariodApi+nia Chronic Toxicity Test
Aeproduatioa Dada Sheet
Client 6kA /rd►r KW! E 4*
# H fYe4
Dilution Water LaL 1244.ds y tL
Organism Age at Start_ 9 Lot
fan
tam
Replicates
Effluent Dav# i 2 4 ,� 7
3
Control 5 tp
7
To tad. ' .. .Z -
3
5 tea'
7
Total
ly 5
7
Total
3
1.3 5
7
Total
Starting. Date 6/6/41 7 Time /Kii
Ending bate C//2-/'i7 Time Or 3 0
Ana lye t /
9
WO 5
.2CZ)
2- 12, I2. 12-
m ye
Wr:1:2sTW-
W 9R W.14W fa/l/k
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116 75 3E X . 2.6 . /.. . . wr,qTotal 2, 2;- 23. 2 7 , � '
3 6..,"4/4k
5
Total
To al, TRIM Eggi bya,
Srd Day 0 44
1 L•'S' Dayy 2
el
Z II_ Day 3'"
Day 4
Day 5
Day 6
Transfer by!.
Day 2
Day 5 rye
Terminated
vi 7--
21-17
NoEe =9zz.
toec =?9z2
•
211
zt
Offices: 106-A South Walnut Circle • P.O. Box 8808 • Greensboro, N.C. 27419 • [phone]
Laboratory 642 Talmo Road • Reidsville, N.C. 27320 • [phone]

•
Water Teahnolo,y
9103422522
P. 04
n
FIR
Carl
WATER TECHNOLOGY AND CONTROLS, INC.
Wafer Treatment aemaew: rnvawnmenta,Labona,ozy
nexiodaphnia Chronic Toxicity
.Reproduction Data Sheet
client i, d 1; llf Gd
RPDBIL4L.7_11:7 ?Are.'
Dilution Water L, Ldovv
Organism Age at Start !C, Lr
pff uemt Pay*
r. 3
Control 5
7
Total
rin
Mal
3
5
7
Total
2
3 O
5 i72: 1 V
Total
Kip
, 27 , g
Replicates
Test
starting. Date4,/Sig 7 Time
Ending Date 6/j2, 7 Tf m4.CY43
Analyst
$ 10
!1 11
13,E z-
3
5
7
Total
3
5
7
Total
3
5
7
Total
0.
`•'.lo o z Jp alb
0
tl
gzin
g g
S to
AJoEc la
Lo6c_ • )c2%
Offices: 106-A South Walnut Circle • P.O. Box 8808 • Cieensboro, N.C. 27419 • [phone]
Laboratory: 642 Tamco Road • Reidsville, N.C. 27320 • [phone]
To\ 1
ow
/0ce g4)owl Day
cytz2, Day 0
Day2
3
Day 4
Day 5
Day 6
.t Fed by:,
Z3.7
JAC
Taus f 1.11XL
Day 2
6l10 Sty 1� Day5
2rz .&Z Zea,. 4, Terminatea
1
of �A

0
Water Technolo,.
9103421522 P.01
WATER TECHNOLOGY AND CONTROLS, INC.
Date: 6/17/97
#i pages': 1
Water Treatment Chemistries & Envlronmentai Laboratory
To: John Grey, Jr.
President, Grey Engineering, Inc.
(a' fax [phone]
From: Michael Shelton 11(
faEl
facl
Subject: Revised fax of requested data
1) The nominal pore size of the Gelman A/E glass fiber
filters used for TSS is 1.0.m
2) Settleable solids was performed on the remaining 700 ml of
unfiltered Guilford East effluent. The results were
calculated to be 1.4 m1/1.
3) b33 has not been performed on the sample that was taken
6/11/97. Results aref available at this moment.
471
Offices: 106-A. South Walnut Circle • P.C. Box 8808. • Greensboro, N.C. 27419 • [phone]
Laboratory: 642 Tamco Road • Reidsville, N.C. 27320 • [phone]

•
Water Technolo,5r
9103421522
P. 01
WATER TECHNOLOGY AND CONTROLS, INC.
Water Treatment Chemistries & Environments! Laboratory
r' Date: 6/20/97
timl
n
# pages: 4
To: John Grey, Jr.
President, Grey Engineering, Inc.
fax [phone]
From: Michael Shelton
Sub3ect: Results from wet chemistry and toxicity analyses of
Guilford Mills East effluent, 6/11/97 sample
All analyses of effluent from the Guilford Mills East
facility in Kenansville, NC sampled on 6/11/97 have been
completed. The results are summarized as follows:
Parameter Results
Total Suspended Solids 32 mg/1
Total Phenols 0.012 mg/1
Chronic Toxicity:
Untreated NOEC1= 46%
LOEC2= 92%
rnR Filtered NOECok 46%
LOEC= 92%
2- NOEC- No Observed Effect Concentration
LOEC- Lowest Observed Effect Concentration
The wet Chemistry report form as well as untreatedand filtered
ethachronic
reproduction bench sheets for both
sample tests are included with this cover page.
Please contact the Water Technology and Controls, Inc.
rA, laboratory at [phone] if you have any questions or need
any additional information.
Offices: 106-A South Walnut Circle • P.O. Box 8808 • Greensboro, N.C. 27419 • [phone]
Laboratory: 642 Tamco Road • Reidsville, N.C. 27320 • [phone]

Nazar TQchnology 9103421522
P.02
Rol
Fc►
fill
1=1
rag
1.9
3
5
7
Total
mq
mn
M9
WATER TECHNOLOGY AND CONTROLS, INC.
w Treatment Chemistries a Environmental Laboratory
Ceriodaphnia Chronic Toxicity Test
Reproduction Data Sheet
Client Cy k.e L4.- 2 &a8 ', (Q1q'T7)
# r-c,t4,2.4
Dilution Water L •ectgvvilL.
Organism% Age at Start 19 tpi
Sf luent gawk i 2V
CassiLsail
l2
3
5
7
3
5
7
Total
3
5
y
Total
3
5
7
Total
8
Replicates
.1 5 5� 7/
Starting Date 6//4t57 Time /5/30
Ending Date 41/9/57 Time /0,
Analyst • ryk - _--
7rer
opt. oily
Zd.. ?eZ
io S/ti � M-cf a'Itl
2
tfvE0.02.'7 2'4. a.a ,.
3 Warii
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Day 5
Terminated
bys
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/71 6cle4.4)
--231 m .1
Sin tlfcr.'-
Offices: 106-A South Walnut Circle • P.O. Box 8806 • Greensboro, N.C. 27419.• [phone]
Laboratory: 642 Tamco Road • Reidsville, N.C. 27320 • (910) 3424748

Water T.chnolosv
9103421522
P. 03
r2a
fag
Mrt
WATER TECHNOLOGY AND CONTROLS, INC.
Water Theatment Chemistries & Environments! Laboratory
gAtiodaphnia, Chronic Toxicity Test
RReproduction Data Sheet
Client , ' 44" •
NPECSIr
Dilution water- t .
Starting Dater -47 Tilnafiso
Balding Date , /,i 57 Tiie lc:33d
Analyst
Organism; Age at Start I'3 L
Replicates ,r-
7 8V ''f 10� TNI.3,
,- (MUM
377 C.1/.?.3
22 - 7-2— 242..
Effluent plat
3
Control 5
7
Total
a 3 4'�
5
511
2s-
3 -
4if sig s�.
r7►
a6ri114E
Total 2:. �M.?�
NJI
� . 3 z-
_ .-
3
5
7
Total
. 7
Tota].
3
5
7
Total
g.2/3
5
7
Total
CS
�i 12_•.17_s..
OR 1
2
Me
Z
P-Q-1 e'S
3 2ity
tb6e y6%
to 6c. 9r20
7 73-5
Test!kY.J.
Day 0
Day 1
Day 2
Day 3
Day 4
Day 5
Day 6
Txa nefer by
Day 2
Day 5 0 _
Term fnat.sosd
�clga0
,-•/.7, ihilmatil rib*
(.1c64)
• rt
Offices:106-A South Walnut Circle • P.O. -Box 8808 • Greensboro, N.C. 27419 • [phone]
Laboratory: 642 Tarnco Road • Reidsville, N.C. 27320 • [phone]

Water Technolovtir
9103421522 P.04
I
=,
CLIENTs
(5v% GAL. &s1)--
' ' SAMPLE: 1,tk L>et k 5(4
D°r? '1A
ma
PARAMETERS
SAMPLE ID.:
SAMPLE DATE:
SAMPLE RCVD s
(4,11 t(1-7
WI
MI
fwl
MI
COMMENTS
oot_
MM•MI•• ••••M•w•
RESULTS
.•...•....•••.••.may
ANALYSIS
Date •
ANALYST
p.o/a t77
3A.
L
4-1147
X 47.76
4- 1S-c?-1 6p 6/11__
w IP)
1°C‘aSS
tM M• vM•Mi"•••
1
•••«.m•rw•••
••• MOM ••• w�
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1
1
•
•

'LOY. do3
Cal
For:
A.,
ran
r=,
PRI
1.
REF:
Vann Laboratories
P.O. Box 668
Wallace, N.C. 28466
WASTEWATER ANALYSIS REPORT ••
Grey Engineering, Inc.
Atten: Mr. John Grey
Guilford —East
•
Phone: [phone]
Date Samples Collected:
March 11, 1996
1
S
UNJT
Iient
ClarifierPARAMETER
Influent
Does not meet holding time,
PH - forreference only.
•
BODS
mg/L
12. 1
9.6
•
COD
mg/L
•
Fecal Coliform
/100
Total Kjeldahl Nitrogen
mg/L
Total Residue
mg/L
Total Suspended Residue
mg/L
80
60
Detergents MBAS
mg/L
Oil & Grease
mg/L
Total Phosphorous
mg/L
Sulfides
mg/L
Phenols
ug/L
Total Chromium
ug/L
ug/L
Total Copper
Total Magnesium
mg/L
Total Zinc
ug/L
Ammonia Nitrogen
mg/L
Chronic Value•
%
17
28
* 20 ppm of ploymer MEC998013 added to samphot
then sample decanted before analysis oats. March ,1996996

,"MAR ZE ' 9E OS: 04PM SURLING 7C.N RESEARCH
CH
! ARCH
10111111
foci
Cal
fan
•
• Aquatic Bioassay Testing • Aquatic Toxicity Reduction Evaluations
Chemical Product Environmental Assessments a NPDES Testing
Reporting & Data Handling Services
P.3
1302 Belmont Street • Burlington, NC 27215-6935 • [phone] • Fax [phone]
BIOASSAY .REPORT
•
Ceriodaphnia dubia Survival and Reproduction. Test
CUSTOMER:
FACILITY:
NPDES PERMIT #:
SAMPLES:
Collected:
Received:
TEST DATE:
WORK ORDER 0:
REPORT DATE:
REPORT TO:
VANN LABORATORIES
Guilford East
WWTP Final Effluent
3/11-12/96
3/13/96
3/ 13-19/96
6C264-001
3/25/96
Mr. Wayne Vann
RESTLT (%) `70 ..;
STJ RV VAL
24-Hour LC50
48-Hour LC50
96-dour LC50
144-Hour LC50
144-Hour Mortality at Current 23% IWC
REPRODUCTIOisi
Chronic Value (ChV )
No Observed Effect Concentration (NOEC)
Lowest Observed. Effect Concentration (LOEC)
(Survival LOEC)
Inhibition Concentrations: IC25
IC50
> 60
54
35
22
50
17
12
23
(Not Calculable)
(41.5 - 70.5)
(27.5 - 43.8)
(15.8 - 31.5)
15 (7.50 - 24.0)
25 (20.2 - 28.4)
* Protocol: North Carolina Phase IL Chronic Whole Effluent Toxicity Test Procedure, July 1991. Revised 12/95

MEI
MAR ZS '96 @3 : 04PM BURLING T ON RESEARCH
q _ NGTON
E SLAr�
o -A uatic Toxicity Recuc len E•ialuatians
Aquatic� 'Bioassay Testing 4
iemic:c Product Snvironmental Data Handling 9 SeiviceMPOES Testing• •
Reporting �.
P.4
1302 SeLmor;t Street r St:. iititcn, NC •27216-c938 o (910) 5 7 0~4661 a Fr:C [phone]
CUSTOMER:
FACILITY:
NEVES PER1Va #:
f�1 5A iPLES
Collected:
Receives:
TEST DATE:
WORK ORDER . :
REPORT DATE:
'PO&T TO:
SURVIVAL.
BIOASSAY laITORT
erioda hP. c dubia Survival and Reproduction Test .
24 Hoer LC50
�., 48-Hour LC50
96-Hour LC50
144-Hoer_ LC50 ,�
144-Hour �riortality at 'C'�=-'nt 23 % C
VANN LABORATORIES
Cunard ttit
Clarifier 1i+w+ rt
y/Z 1 - 2196
3/13 36
3/13-19/96
6C264-002
i
3/25/55
T
Mr.tiWayne ., ajim
REPRODUCTION
Chronic Value (QiY)
No Observed Effect Concentration (NOEC)
Lowest Observed Effect Concentration (LOEC)
Inhibition. ibition. Concentrations: IC25
IC50 .
•
r;a� . L ortn mina
> 60
r
L
60
51
20
;✓;trout no it uet oxicitY
28
23
33
(Not Calculable)
(Not Calculable)
(;dot Reliable)
(32.4 - 81.4)
11 (7.41 - 35.3)
43 (37.2 - 48.7)
est ' ocraurc, ulY 1 u 1-•1