NC0025135_Wasteload Allocation_19930616

NPDES DOCUMENT SCANNING COVER SHEET
NC0025135
Huffman Finishing WWTP
NPDES Permit:
Document Type:
Permit Issuance
,�
Wasteload Allocation2`'�
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Compliance
Speculative Limits
Instream Assessment
(67b)
Environmental Assessment (EA)
Permit
History
Document Date:
June 16, 1993
'hiss document ig printed on reuse paper - ignore nay
content on the reverse 'side

DIVISION OF ENVIRONMENTAL MANAGEMENT
June 16, 19.9"
MEMORANDUM
TO: Randy Kepler
THRU: Ruth Swanek'
Carla Sanderso
FROM: Jacquelyn M. Nowell/4
SUBJECT: Comments on Chromium Limit for Huffman Finishing Company
NPDES Permit No. NC0025135
Caldwell County
The Instream Assessment Unit has reviewed the letter from Lee Huffman of the
subject facility. The limit for total chromium of 1.3 lbs/day (when Huffman discharges
directly into Lake Hickory) is based on EPA effluent guidelines using 40 CFR 410.52 for
the industrial discharger. We do not recommend deletion or removal of guideline based
limits from NPDES permits unless the North Carolina water quality standard for the same
parameter is more stringent . The EPA guideline for chromium is lower than a North
Carolina water quality limit, therefore, it is included in the permit.
Huffman indicates that self monitoring data shows that the effluent is "consistently"
under the limit, in that case, compliance with the limit should not be a concern. If Huffman
Finishing would like a reduction in the monitoring frequency for chromium, they can
submit a written request to the Division after they have collected twelve months of data.
If there are any additional questions concerning this matter, please contact me.
cc: Forrest Westall
Central Files

eamylawy, 9i40, q I
INFANTS', CHILDREN'S, MISSES' AND MEN'S
HOSIERY
April 29, 1993
Mr. Steve Teddar, Chief
Water Quality Section
N.C. Division of Environmental Management
P.O. Box 29535
Raleigh, North Carolina 27626-0535
RE: NPDES Permit No. NC 0025135
Huffman Finishing Company
Caldwell County
Dear Mr. Teddar:
MAY 4 1993
WATER QUALITY
SECTION
We have received and reviewed the most recent "draft" NPDES permit for our
proposal effluent discharge. In general, the draft permit addressed most of the comments
we made regarding the original "draft"; however, there appears to be one minor
discrepancy in the current "draft."
Please look at the first and third set of effluent limits. On page 1 of both conditions,
there is a monthly average requirement for chromium of 1.3 lbs/day. On the second page
of both conditions, there is a requirement to only monitor for chromium. We request the
latter requirement for "monitoring -only" be maintained and the former requirement (1.3
lbs/day) be deleted. Our self monitoring reports indicate we have consistently been well
under the 1.3 lbs/day limit and the "monitoring -only" seems appropriate for our set of
circumstances.
If you or your staff have any questions, please contact me.
Sincerely,
Huffman Finishing Commpany, Inc.
VQ.s; 1 (
Lee T. Huffman
CC: Arthur L. Kennedy,
The Wooten Company
Sam Moore
Burlington Research, Inc.
P.O. Box 170 • Granite Falls, North Carolina 28630 Telephone: [phone] • Fax: [phone]

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State of North Carolina
Department of Environment, Health, and Natural Resources
512 North Salisbury Street • Raleigh, North Carolina 27604
James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary
DIVISION OF ENVIRONMENTAL MANAGEMENT
WATER QUALITY SECTION
MEMORANDUM
TO:
THROUGH:
FROM:
March 8, 1993
Randy Kepler
Permits and Engineerin
Forrest R. Westall
Water Quality Regi
Paul White, P. E. ,4/;
Environmental Engineer
SUBJECT: Huffman Finishing Company
Proposed Phenols Limit
NPDES Permit Number NC0025135
Caldwell County
upervisor
l
As we discussed over the telephone, the Division of Environmental
Health, Water Supply Branch has requested that the phenols limit be
based on the capability of the treatment plant rather than allowable
loading. The proposed phenols limit for discharge to Lake Hickory is
104 ug/l. This is also the proposed interim limit for their current
/ discharge location. Their existing phenols limit is 1.2 ug/l, which
6Aaad uk) has proven difficult to meet on a continuous basis.
4o C.RS h,ik111mv.,
terse.. Based on conversations with Lee Huffman of Huffman Finishing, the
discharge from the wastewater treatment facility should be able to
meet a phenols limit of 20 ug/l. This will avoid intermittent
violations due to the limit being so close to the detection limit, yet
will be only about one -fifth of the allowable loading. Therefore, it
is recommended that the proposed phenols limit for the interim current
location and for the proposed discharge to Lake Hickory be set at 20
ug/l.
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] Fax # [phone]
An Equal Opportunity Affirmative Action Employer

Randy Kepler
Memorandum
March 8, 1993
Page Two
In addition, the dates in the schedule should be revised to
reflect the anticipated permit issue date. Please note that items 1 -
3 pertaining to the cost analysis, plume study, and toxicity
evaluation have been completed. Enclosed is a copy of the marked up
schedule submitted July 13, 1992 in a memo to Coleen Sullins. This
mark up includes completion dates for these items.
If you have any questions, please call.
Enclosure

{
dates.
The following schedule should be included in the permit:
Submit Cost Analysis of Alternative Wastewater Treatment
Proposals by. . . . . . August 5, 1991
:: C: •t..e 4-ti j&t s1, j
. Submit Dispersion Plume Study by August 31, 1991
4-1.1g4,4t / 1 11)
Submit Toxicity Identification and Evaluation Study along
with recommendations and supportin information by. . . . .
I .r�t.� I • , , 1992
Ake Fekna,r1 V , 1 °!al z
4. Submit plans and specifications within 120 days of permit
issuance a_-state-Ga r ren..e--w ---No . every—rs
]pater. Target date : . . . . . . . . . . . . . J e ,
/ha r ch 1 1g93
5. Initiate construction within 270 days of permit issuance -ems
conettr renec
Target date: . . . . . . . . . . . .
?u tY 9(4• )‘.,,,. ...E_5 t. 3
6. Complete construction, providing additional treatment or
eliminating existing discharge point within 400 days of
permit issuance arstat.e concurrence- with--- a----3-above;
whIehever ib later. Target date: . . . . . .
ace- , /q y 3
7. Comply with effluent limitations within 490 days of permit
issuance er ctat-ec--oncuxr. enc:e----with----No -3--arbeve% Target
date -
The specified number of days will take precedence over the target
It is recommended that the permit be renewed with the above
modifications. If there are any questions, you may contact Forrest
Westall or Paul White.
• - P w
Signature of Report Preparer
ter Regional Supervisor
Date

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09/11/91 ver 3.1 T OXICS REVIEW
Facility: HUFFMAN FINISHING
NPDES Permit No.: NC0025135
Status (E, P, or M) : E
Permitted Flow: 0.3 mgd
Actual Average Flow: 0.1 mgd
Subbasin: '030832
Receiving Stream: UT CATAWBA RIVER I PRETREATMENT DATA I----EFLLUENT DATA ----
Stream Classification: WS-III I ACTUAL PERMITTEDI
7Q10: 0.1 cfs I Ind. + Ind. + 1 FREQUENCY
IWC: 83.78 % I Domestic PERMITTED Domestic I OBSERVED of Chronic
Stn'd / Bkg 1 Removal Domestic Act.Ind. Total Industrial Total 1 Eflluent Criteria
Pollutant AL Conc. 1 Eff. Load Load Load Load Load 1 Conc. Violations
(ug/l) (ug/1) 1 % (#/d) ($/d) (#/d) (#/d) (#/d) 1 (ug/1) (#vio/#sam)
Cadmium S 2.0 1 0%
Chromium S 50.0 1 0%
Copper AL 7.0 1 0%
Nickel S 25.0 1 0%
Lead S 25.0 1 0%
Zinc AL 50.0 1 0%
Cyanide S 5.0 1 0%
Mercury S 0.012 1 0%
Silver AL 0.06 1 0%
Selenium S 5.00 1 0%
Arsenic S 50.00 I 0%
Phenols S 1.0 I 0%
NH3-N C 1 0%
T.R.Chlor.AL 17.0 I 0%
Pollutant
18.0
13.0 1 I
45.0 1 N
94.0 1 P
2.0 1 U
406.0 1 T
10.0
0.0 1 S
4.0 1 E
0.0 1 C
41.0 1 T
0.0 1 I
I 0
I N
ALLOWABLE PRDCT'D PRDCT'D PRDCT'D MONITOR/LIMIT I--ADTN'L RECMMDTN'S--
Effluent Effluent Effluent Instream I Recomm'd
Conc. using using Conc. Based on Based on Based on 1 FREQUENCY INSTREAM
Allowable CHRONIC ACTUAL PERMIT using ACTUAL PERMITTED OBSERVED 1 Eff. Mon. Monitor.
Load Criteria Influent Influent OBSERVED Influent Influent Effluent 1 based on Recomm'd ?
(#/d) (ug/1) (ug/1) (ug/1) (ug/1) Loading Loading Data 1 OBSERVED (YES/NO)
Cadmium S 1 0.00
Chromium S I 0.07 59.677
Copper AL 1 0.01 8.355
Nickel S 1 0.03 29.839
Lead S 1 0.03 29.839
Zinc AL 1 0.07 59.677
Cyanide S 1 0.01 5.968
Mercury S 1 0.00 0.014
Silver AL 1 0.00 0.072
Selenium S 1 0.01 5.968
Arsenic S 1 0.07 59.677
Phenols S 1 0.00 1.194
NH3-N C 1 0.000
T.R.Chlor.AL 1 20.290
2.387 0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000 15.08 Limit 1 NCAC YES 1 A
0.000 10.89 Limit 1 NCAC NO 1 N
0.000 37.70 1 Weekly YES 1 A
0.000 78.76 Limit 1 NCAC YES 1 L
0.000 1.68 Monitor I NCAC NO 1 Y
0.000 340.16 Monitor 1 Weekly YES 1 S
0.000 8.38 Limit 1 NCAC YES 1 I
0.000 0.00 1 NCAC NO I S
0.000 3.35 Monitor 1 Weekly YES
0.000 0.00 1 NCAC NO 1 R
0.000 34.35 1 NCAC YES 1 E
0.000 0.00 1 NCAC NO I S
0.00 1 1 U
0.00 I 1 L
I I T
I I s
Monitor
Limit

DIVISION OF ENVIRONMENTAL MANAGEMENT
March 4, 1993
MEMORANDUM
TO: Randy Kepler
THRU: J. Trevor Clements
Ruth Swanek'
Carla Sanderson
FROM: Jacquelyn M. Nowell ��\
SUBJECT: Addition of Phenols Limit to Interim Limits
Huffman Finishing Company
NPDES Permit No. NC0025135
Caldwell County
Please include a phenols limit of 104 ug/l in the interim limits for Huff-
man Finishing. A limit for phenols was previously included upon relocation to
Lake Hickory but was inadvertently omitted in the comments on the draft permit.
Other recommendations addressed in the February 24th memo remain the same.
cc: Forrest Westall

DIVISION OF ENVIRONMENTAL MANAGEMENT
February 24, 1993
MEMORANDUM
TO: Randy Kepler
THRU: J. Trevor Clement
Ruth Swanek 2C5
Carla Sanderson
FROM: Jacquelyn M. Nowel
SUBJECT: Comments on Draft Permit for Huffman Finishing Company, Inc. from
1) Division of Environmental Health and 2) Huffman Finishing
NPDES Permit No. NC0025135
Caldwell County
The subject document has been reviewed by the Technical Support Branch and
we submit the following comments and recommendations.
Regarding the Division of Environmental Health's request that effluent limi-
tations be assigned based on Huffman's Finishing treatment capability rather
than allowable loading, current DEM procedure requires that limits are developed
per N.C. Regulation 15A NCAC 2B .0206. The more stringent standards to protect
the water supply classification of Lake Hickory were applied to the limits for
metals and other toxicants from Huffman's discharge. In addition, the minimum
instantaneous release (40 cfs) of Lake Rhodhiss Dam was used in the calculation
of limits rather than the higher minimum daily flow (225 cfs) for the protec-
tion of the water intakes. The limits recommended by Technical Support will
adequately protect the water supply intakes downstream of Huffman Finishing's
outfall.
During our reevaluation of the data for permitted limits, two revisions are
now recommended whether Huffman relocates the outfall directly to Lake Hickory
or continues to discharge into the UT Lake Hickory. The revisions are:
1. Effluent limitations for selenium and mercury should be deleted from the
permit.
2. Effluent monitoring for cyanide and fluoride instead of limits.
Because of Huffman's pending relocation, Technical Support recommends the
following limitations and monitoring requirements until relocation and direct
discharge into Lake Hickory. A schedule for relocation must be included in the
revised NPDES permit. The staff report (July 30, 1991) from the Asheville
Regional Office contained a detailed schedule for construction and compliance
which should be updated with new target dates. We recommend that Paul White of
the ARO be contacted to help with the revision of this schedule.

The following interim limits are recommended pending relocation:
Mo. Avg. Da. Max
GODS (lbs/da) 68.5 135.8
COD (lbs/da) 790 1581.8
TSS (lbs/da) 290 578.7
Sulfides (lbs/da) 2.6 5.3
Chromium (lbs/da) 1.3 2.6
Fecal Coliform (/100m1) 200 400
pH (SU) 6-9 6-9
In addition, we recommend twelve months of monthly monitoring for the
following parameters: cadmium, arsenic, nickel, chloride, fluoride, cyanide,
phenols, barium, antimony, copper, zinc, lead, silver, total phosphorus, total
nitrogen, residual chlorine, and ammonia. Attached is a letter from Aquatic
Toxicology with their recommendation that a multiple concentration chronic
Ceriodaphnia test be performed on a quarterly basis when no toxicity limit is in
effect. Technical Support concurs with this recommendation.
These interim limits and monitoring requirements are essentially those
recommended for "Discharge Condition No. 3: discharge the treated wastewater
directly to the Catawba River (Lake Hickory), with our discharge pipe within
feet of our current stream mouth", with the exception of the acute toxicity
test. They are recommended based on the assumption that Huffman will be relo-
cating the discharge.
In the event that Huffman does not relocate its discharge, then revised lim-
its recommended for "Discharge Condition No. 2: Continue to operate the upgraded
and expanded plant with discharge at the current location" will be applicable.
The two revisions will be those previously mentioned, the deletion of limits for
selenium and mercury, and effluent monitoring only for cyanide and fluoride.
If there are any additional questions concerning these recommendations,
please contact me.
cc: Steve Tedder
Forrest Westall

Division of Environmental Management
October 30, 1992
MEMORANDUM
To: Jackie Nowell
Through: Larry Ausley
From: Matt Matthews rftfJ
Subject: Draft Permit Comments
Huffman Finishing Company
NPDES No. NC0025135
Caldwell County
Data Assessment and Certification Group personnel have reviewed and evaluated the subject draft permit
comments submitted by the facility in regards to whole effluent toxicity and chloride limits. Toxicity
Reduction Evaluation activities indicate that total dissolved solids are the major contributor to observed
effluent toxicity. Review of selfmonitoring data indicates that the facility cannot currently meet its chronic
toxicity limit of 84%. Joni Barnhardt of Burlington Research, Inc. has indicated in phone conversations
with our office that the facility effluent causes 100% mortality within 48 hours in a 90% effluent
concentration about 50% of the time.
The facility has proposed relocation of its discharge pipe to the Catawba River which would give the
facility an IWC of 0.96% and an acute Daphnid toxicity limit of LC50>90%. However, the relocation of
the pipe is not guaranteed at this point. Additionally, as indicated above, it appears that the facility will not
be able to consistently meet the acute limit assigned should the relocation occur. The facility will have to
make some further efforts in terms of toxicity reduction regardless of the outcome of the pipe relocation
proposal.
As in our memo of August 30, 1991, this office recommends that a multiple concentration chronic
Ceriodaphnia test be performed on a quarterly basis during the time, if any, in which no toxicity limit is in
effect. Should the pipe relocation attempt be unsuccessful, a chronic limit of 84% should be assigned based
on the existing discharge point's 7Q10 of 0.075 and the permitted flow of 0.25 MGD. Should the
discharge point be relocated to the proposed site on Lake Hickory, an acute limit of >90% would be
appropriate based on an IWC of 0.96%. The IWC is calculated from the permitted flow of 0.075 MGD and
the 7Q10 of 40 cfs which is based on the minimum instantaneous release from the Catawba River -Lake
Rhodhiss dam. Any variance from these ultimate limits should be presented by facility representatives to
Water Quality Section Chief Steve Tedder. The same procedure should be followed in regards to any change
in the facility's chloride limit.
If any further information or clarification is required, please contact me or Larry Ausley at [phone].
cc: Forrest Westall
Kent Wiggins
Trevor Clements
Attachments

MEMO
TO:
/12
6,1c Atii..)
cvdD°1
RECEIVED
OCT 2 2 1992
ENVIRONMENTAL SCIENCES gRpryGWom;
DATE:
A1/41/f Z
SUBJECT:
/J44/ /Z6 Arb-444-74
North CaroUna'bepartmeflt of Environment,
Health, and Natural Resources e
Printed on Recycled Paper

i
1-1
September 15, 1992
INFANTS'. CHILDREN'S. MISSES' AND MEN'S
HOSIERY
GRANITE FALLS. N. C. 28630
Mr. Paul White, P.E.
Regional Engineer
N.C. Division of Environmental Management
Asheville Regional Office
Interchange Building
59 Woodfin Place
Asheville, North Carolina 28801
Re: NPDES Permit No. NC 0025135
Huffman Finishing Company
Caldwell County
r,)
Dear Mr. White:
We appreciate receiving a copy of the "draft" NPDES permit for our proposed wastewater discharge to
the Catawba River (Lake Hickory). We have reviewed the permit provisions and would like to take this
opportunity to offer comments and request several revisions to the permit before it goes to "public
notice." We have assembled wastewater data from various sources in support of our request that several
provisions of the permit be revised prior to issuance. The wastewater data are identified as follows:
Appendix "A":
Appendix "B":
Appendix "C":
Appendix "D" :
Effluent results from our monthly self -monitoring reports for BOD,
COD, NH3-N, Total Suspended Residue and Phenol. Results are
presented in a graph format and reflect the improved effluent quality
following completion of our wastewater treatment improvements project
in the summer of 1990, and the THE and waste minimization completed
in May 1991.
"Annual Pollutant Analysis" for Huffman Finishing Company's WWTP.
Graph depicting Chronic Toxicity results for the current wastewater
discharge.
Monthly self -monitoring results of wastewater treatment plant effluent.
As we understand the draft permit, there are three (3) separate discharge conditions and each discharge
condition has its own set of effluent limitations:
Discharge Condition No. 1: Huffman Finishing Company continues to operate the recently
upgraded and expanded plant until the existing discharge is relocated to the Catawba River.
Discharge Condition No. 2: Continue to operate our recently upgraded and expanded plant with
discharge at the current location.

Mr. Paul White, P.E.
September 15, 1992
Page 2
Discharge Condition No. 3: Discharge the treated wastewater directly to the Catawba River, with
our discharge pipe within feet of our current stream mouth.
Our comments and/or requests for relief generally follow the sequence of effluent limitations cited for
each "discharge condition."
A. Discharge Condition No. 1 (DC-1):
1. Attached (under Appendix "A" and "D") are self -monitoring results for sulfides and
ammonia nitrogen. Because the sulfide discharge is consistently less than 10% of the
discharge limitation and because the effluent ammonia nitrogen concentration is
consistently less than 1.0 mg/1, we request the monitoring frequency be reduced from
weekly to monthly.
2. Attached (as Appendix "B") is a copy of Huffman Finishing Company WWTP's "Annual
Pollutant Analysis." On page 12 of 13, the results indicate the concentrations of
cadmium, chromium, and nickel are either below the detectable limit or significantly
below the effluent limitation. Since the test results represent only a single sample, we
propose to monitor these parameters on a weekly basis for 2 months. If the results
continue to be significantly below rameters beeuentdeleted,00r, we as arequest the minitnum, reduceting
he
requirements for all three (3) pa
monitoring frequency to no greater than quarterly.
3. It is our understanding the Chronic Toxicity testing requirement as written (Part B1,
Condition D) may not reflect the original intent of the NCDEM staff. As written,
Huffman Finishing Company cannot meet the Chronic Toxicity requirement at the 84%
concentration. For this very reason, we are proposing to relocate our discharge to the
Catawba River.
Attached hereto (as Appendix "C") is a graph depicting our Chronic Toxicity test results
over the past year. As indicated thereon, we cannot consistently pass the Chronic
Toxicity test at a concentration greater than 20%.
We are currently only "monitoring" for Chronic Toxicity. We request we be allowed to
continue to "monitor only" during the interim period until the effluent can be relocated.
If it is mandatory that a Pass/Fail limit be established, we request the testing requirement
be based on a concentration of 5 20% effluent.
4. Weekly monitoring is required and daily limits are established for Cyanide, Mercury,
Selenium, Fluoride, Barium, and Antimony. The results cited in the Annual Pollutant
Analysis (Appendix "B") are either below detectable limits or significantly below thew
discharge limitation. Since the test results represent only a single sample, we propose
to monitor these parameters on a weekly basis for 2 months. If the results continue to
be significantly below the effluent limitations, we request the monitoring requirement for
all six (6) parameters be deleted or, as a minimum, reduce the monitoring frequency to
no greater than quarterly.

Mr. Paul White, P.E.
September 15, 1992
Page 3
5 Our Annual Pollutant Analysis and our monthly self -monitoring reports indicate we
cannot consistently meet the arsenic discharge limitations. We request the arsenic limit
be increased to no less than 100 µgfl.
6. Based on our 1992 performance data (monthly monitoring reports), the phenol limits
should be met under either of the discharge conditions.
We have determined through our Toxicity Identification Evaluations (TIE) studies that
chloride is the primary contributor in our inability to meet the chronic Toxicity Testing
requirements. As noted elsewhere herein, it is for this very reason Huffman Finishing
Company wishes to relocate the discharge from the zero flow stream that is tributary to
the Catawba River and discharge directly to the river.
It is not our intent to diminish our current level of treatment by relocating the discharge.
It is simply not economically feasible to reduce the chloride concentration tfo the Treatment
cited in the permit. (See report in Appendix "E" entitled "Analy
Alternatives, Huffman Finishing Company," July 1991.) However, as a measure of our
commitment to continue to produce a high quality effluent and since thecity ty test
will ultimately govern the discharge to the Catawba River, we propose
that the
chide
limitation be installed as an action level to be enforced after significant non-compliance
of an Acute Toxicity Limit of LC50 90%. This limit is the same as will be imposed
when the discharge is relocated.
B. Discharge Condition No. 2 (DC-2):
The discharge limitations for Discharge Condition No.2 are the same as those cited for Discharge relief
No. 1. Accordingly, the same rationale outlined under Discharge �odDisochargelseeking Condition No.
in monitoring requirements and discharge limitationsapplicable
2.
ty effluent and
It is Huffman Finishing Company's intent to
discharge m improvements to our waspewater treatment
rotect the water
quality in the Catawba River. Our expend P Appendix "A"—areplant in 1989 and 1990 and the results of that investment —as illustrated in
testimony to our commitment.
s not
It is also our desire to relocate the discharge to the foCar toz cwba Rlver because it at our currentldischarge locationy
feasible for us to meet the in -stream 7Q10 standardtoxicity
However, we can meet the standards described for the discharge to the Catawba River.
ischarge.
refore,
We understand there is no assurance we will bepermitted ue to operate le the and discharge at ourecurrent
we must seek adequate relief to insure we can P
location. Since we can and will continue to meet the ultimate at tests required �,of intsas a discharge
of
Catawba River, we must not be put out of business
a lack of salt removal technology and the stream classification of the ditch to which we discharge.

Mr. Paul White, P.E.
September 15, 1992
Page 4
C. Discharge Condition No. 3 (DC-3):
1. Within Appendixes "A" and "B" and through our monthly self -monitoring results, there
is evidence to indicate the discharge values for sulfides, chromium, and phenols are well
under the proposed permit limits. We recognize the presence of these pollutants;
however, due to the results we have been achieving, we request the monitoring frequency
be reduced from weekly to monthly.
2. With regard to Cadmium, Nickel, Cyanide, Arsenic, Barium, Antimony, Lead, and
Silver, we suspect these elements are either (a) non-existent in our waste stream,
(b) below detectable limits, or (c) exist at such insignificant concentrations as to adversely
impact water quality in the stream. We do not propose to eliminate monitoring;
however, based on the results of various wastewater analyses cited herein, we do request
the monitoring frequency be reduced to no greater than quarterly.
OK item 1 of the page entitled "Supplement to Permit Cover Sheet," the description
As final comment, underP g
Hof the 0.110 MGD wastewater treatment plant should be deleted since the improvements to upgrade and
expand the plant to a capacity of 0.250 MGD have been completed.
Again we thank you for the opportunity to provide these comments regarding our proposed NPDE
permit. If you or the DEM staff have any questions regarding any of the information presented
or n
clarification on those items for which we seek relief, please contact either me, Sam Moore at Burlington
Research (919 584-5564), or Buck Kennedy at The Wooten Company (919 828-0531). To further aid
in clarification of our actions since our WWTP upgrade in 1990-91, we are supplying a summary of our
efforts in support documents which are enclosed under Appendix "F" and Appendix G .
We look forward to securing the new permit and completing the discharge relocation.
Sincerely,
HUFFMAN FINISHING COMPANY
A(2- I 934"---
Lee T. Huffman
Attachments
c: Forrest Westall, NCDEM, Asheville
Steve Tedder, NCDEM, Raleigh
Don Safrit, NCDEM, Raleigh
Rick Rowe, NCDEH, Raleigh
Sam Moore, Burlington Research
Buck Kennedy, The Wooten Company

State of North Carolina
Department of Environment, Health, and Natural Resources
Asheville Regional Office
James G. Martin, Governor Ann B. Orr
William W. Cobey, Jr., Secretary Regional Manager
DIVISION OF ENVIRONMENTAL MANAGEMENT
WATER QUALITY SECTION
October 16, 1992
MEMORANDUM
TO: Randy Kepler
Permits and Engineering
THROUGH: Forrest R. Westa
Water Quality Rego `'Super\Ti sor
FROM: Paul White, P. E.(,�
Environmental Engi eer
SUBJECT:
Huffman Finishing Company
Comments on Huffman Response to Draft Permit
NPDES Permit No. NC0025135
Caldwell County
I have reviewed the response by Huffman Finishing Company to their
draft permit and am including my comment on each point. These
comments follow the same format as used in the letter from Lee Huffman
on September 15, 1992.
A. DISCHARGE CONDITION NO. 1 - Interim operation at current location.
1. Huffman request for reduced monitoring of sulfides and
ammonia nitrogen.
The sulfide monitoring requirement was requested to be
reduced from weekly to monthly due to the sulfide levels
being consistently less than 10% of the limit (2.6 lbs/day
monthly average, 5.3 lbs/day daily max.). For January, June,
July, and August of 1992 the monthly average sulfide level
was 0.38 lbs/day, 0.99 lbs/day, 0.90 lbs/day, and 0.99
lbs/day, respectively. Daily maximum levels of 1.07 lbs/day,
1.17 lbs/day, 3.1 lbs/day, 1.91 lbs/day, 1.24 lbs/day, and
1.34 lbs/day have occurred since July 1991. Therefore, it is
recommended that the sulfide monitoring frequency remain at
weekly.
Interchange Building, 59 Woodfin Place, Asheville, NC. 28801 • Telephone [phone]
An Equal Opportunity Affirmative Action Employer
:

Randy Kepler
Memorandum
October 16, 1992
Page Two
The ammonia nitrogen monitoring requirement was requested to
be reduced from weekly to monthly due to the levels being
consistently less than 1.0 mg/l. The monthly average ammonia
nitrogen levels have been consistently less than 1.0 mg/1,
with a maximum daily value of 1.55 mg/1 within the period
from September 1991 through August 1992. Therefore, we
concur that the ammonia nitrogen monitoring frequency may be
reduced to monthly.
2. Monitoring requirements for cadmium, chromium, and nickel
were requested to be reduced to quarterly if not eliminated,
if monitoring on a weekly basis for 2 months does not
indicate significant levels of these metals. This was based
on results of the Annual Pollutant Analysis for December
1991. Total chromium is listed in the EPA effluent
guidelines for this category of industry. There is currently
an effluent limitation of 57 ug/1 daily maximum for chromium,
which was exceeded in August 1991. Although chromium values
have been very low since November 1991, it is recommended
that the chromium limit remain at 60.0 ug/1 as drafted.
Cadmium was detected in the Annual Pollutant Analysis at 0.5
ug/l, the quantitation limit for a graphite furnace. Nickel
was below the detection limit in the analysis. A decreased
monitoring frequency could be considered at a later time
based on additional monitoring under the proposed monitoring
requirements.
3. It was requested that toxicity be monitored only, or if it is
necessary to establish a limit, that it be based on a maximum
of 20% effluent. It was intended that interim requirements
for chronic toxicity be for monitoring only, with no
pass/fail limit. The first effluent limits page, which
relates to the period beginning on the effective date of the
permit and lasting until 90 days after completion of
additional treatment or relocation of the existing discharge
point, should reflect a monitoring only toxicity requirement
with no limits. For clarity Fart III, Condition D, which
refers to the chronic toxicity requirement, should also
reflect a "monitoring only" requirement for this interim
period. Suggested wording would be: "Beginning 90 days
after the completion of additional treatment or relocation of
the existing discharge point, the effluent discharge shall at
no time exhibit chronic toxicity using test procedures
outlined in:".
There is still some question as to whether the facility will
be able to meet an acute toxicity limit of LC50 >/= 90%.

Randy Kepler
Memorandum
October 16, 1992
Page Three
4. Weekly monitoring of cyanide, mercury, selenium, fluoride,
barium, and antimony was requested to be deleted or reduced
to quarterly if monitoring for two months does not indicate
significant levels of these parameters. Decreased monitoring
of these parameters could be considered at a later date if
monitoring according to the proposed schedule in the draft
permit indicates insignificant levels of these parameters.
5. The arsenic limit was requested to be increased to at least
Z�q2 100 ug/1 due to the inability to meet the proposed limit of
`D� 60 ug/l, based on the Annual Pollutant Analysis and monthly
l ,tee self -monitoring reports. The only current information we
1"�`. have on arsenic is the Annual Pollutant Analysis. Arsenic is
cP5-4"�J w��t not currently reported since it is not limited nor is
�. �`,�3 monitoring required. It is noted that the arsenic limit only
pD''""
0 Lapplies to the current discharge point on the unnamed
2 �,tributary and not to the proposed discharge to the Catawba
River. We will be in contact with Huffman Finishing
concerning the need for including relief from the arsenic
limit in the permit schedule along with toxicity.
6. Mr. Huffman indicates that he should be able to meet proposed
phenols limits under either of the discharge conditions.
7. This comment concerns the chloride limit in the draft permit,
specifically, a request to make it an action limit
enforceable only after significant toxicity is indicated by
non-compliance with an acute toxicity limit of LC50 >/= 90%.
The Toxicity Identification Evaluation studies indicated that
chloride is a major contributor to toxicity. Analyses of the
cost of alternatives involving 1-?-patment to reduce toxicity
were based on chloride removal.. Since the purpose of the
permit schedule is to provide relief from enforcement of
toxicity limits while an alternative to discharging is
arranged, chloride should not br limited at 298.0 mg/1 in the
interim effluent limitations. 11 is recommended that only
monitoring be required for chloride in the interim effluent
limitations.
B. DISCHARGE CONDITION NO. 2 - Discharge at the current location (U.T.
Catawba River) 90 days after completion of additional treatment.
(Although extensive toxicity studies have been done and a Toxicity
Identification and Evaluation study has been submitted, more toxicity
work can be done, and this discharge scenario needs to remain in the
permit as an option in case some easily removable but heretofore masked
toxicant is found.)

Randy Kepler
Memorandum
October 16, 1992
Page Four
The same request made in Discharge Condition No. 1 was made for
Discharge Condition No. 2. The following paragraphs refer to the
requests made under the previous discharge condition:
Comments 1, 2, and 4. This involved requests for reduction of
monitoring requirements and elimination of effluent limitations
for ammonia nitrogen, sulfides, cadmium, chromium, nickel,
cyanide, mercury, selenium, fluoride, barium, and antimony. If
any changes are made to these requirements in the future, the
appropriate effluent limitations page(s) should be modified.
3. Concerning relief from the toxicity limitation, this
discharge condition would only come into play if it were more
feasible to eliminate the toxicity through treatment than to
relocate the discharge. In other words, the toxicity limit
required for this discharge condition would only be applied
if it were demonstrated that the limit could be met through
treatment. Therefore, the part of the comment concerning
toxicity is unwarranted.
5. Any schedule subsequently devised for meeting arsenic limits
should be reflected in all appropriate effluent limitations
pages.
6. It was indicated that phenol limits could be met.
7. As previously discussed, this discharge condition would only
come into play if it were demonstrated that toxicity limits
could be met through treatment. since chloride is considered
to be the primary toxicant, this would involve chloride
removal. Therefore, this discharge condition would only come
into play if it were demonstrated that chlorides could be
economically and sufficiently reduced to eliminate toxicity.
Studies to date have not indicated this to be the case. In
addition, Administrative Code Section T15A:02B .0211 (b) (4),
Fresh Surface Water Classifications and Standard, Action
Levels for Toxic Substances indicates that listed substances
will be limited if they are a significant contributor to
toxicity. Therefore, the chlor.idP effluent limitation should
remain as is unless it is demonstrated that chlorides can be
reduced to the point at which they are no longer a
significant contributor to toxicity.
C. DISCHARGE CONDITION NO.3 - Discharge to the Catawba River.
1. It was requested that the monitoring frequency of sulfides,
chromium, and phenols be reduced from weekly to monthly,
based on levels well under the proposed discharge limit for
discharge to the Catawba River.

Randy Kepler
Memorandum
October 16, 1992
Page Five
The proposed discharge limit for sulfides remains at 2.6
lbs/day as a monthly average and 5.3 lbs/day as a daily
maximum. The August discharge monitoring report listed an
average sulfide level of 0.99 l.bs/day with a daily maximum
value of 1.34 lbs/day. This is not considered to be
sufficiently under the effluent limitation to warrant
lessening of the monitoring frequency. Therefore, it is
recommended that the sulfide monitoring frequency remain at
weekly as is proposed in the draft permit.
The proposed chromium effluent limitation for discharge to
the Catawba River is 1.3 lbs/day as a monthly average. This
limit is a "best practicable technology" (BPT) limit and is
well above the level needed to protect water quality. This
corresponds to 624 ug/1 at a flow of .250 mgd. The highest
single day since August 1991 was 43 ug/l. The average
monthly chromium level for the past 12 months is 2.0 ug/l.
Therefore we would not have a problem with a reduction of the
monitoring frequency for chromium from weekly to monthly.
The proposed phenols effluent limitation for discharge to the
Catawba River is a daily maximum of 104.0 ug/l, set to
protect water quality. Although phenols reduction has been
successful in lowering the level of phenols in the effluent
to under the current effluent limitation of 1.2 ug/1, it is
recommended that the monitoring frequency remain at weekly.
This is recommended due to the potential for taste and odor
problems associated with chlorinated phenols in water
supplies. Monthly monitoring would be too infrequent to
assure the avoidance of taste And odor problems should
phenols again become problems in products used in the process
at Huffman Finishing.
2. It was requested that the monitoring frequency be reduced
from monthly to quarterly for radmium, nickel, cyanide,
arsenic, barium, antimony, lead, and silver. Insufficient
data is available at this time to warrant a reduction in
monitoring frequency. A request for a reduction in
monitoring could be considered at a later time, based on data
collection under the proposed monitoring frequency as
required under the draft permit.
As indicated on the last page of the letter from Lee Huffman, the
supplement to the cover sheet should be revised to eliminate reference
to the 0.110 mgd capacity plant, since the improvements have been to
expand the capacity to .250 mgd. Suggested modifications were included
in my memo to Coleen Sullins on July 13, 1992.

Randy Kepler
Memorandum
October 16, 1992
Page Six
The request for an increase in the arsenic limit at the current
discharge location remains to be addressed. As mentioned earlier, we
have been in touch with Huffman Finishing regarding documentation of
arsenic levels in the effluent. It may he that the draft permit will
need to be modified prior to going to public notice to reflect a
schedule of compliance with the arsenic limit. I will let you know as
soon as possible if any modifications are recommended.
The proposed permit schedule should again be revised to reflect
the anticipated date of permit issuance.
If you have any questions, please give me a call.

DIVISION OF ENVIRONMENTAL MANAGEMENT
Permits and Engineering/ NPDES Unit
7
October Is, 1992
Memorandum
TO: Jackie Nowell
TSB
FROM: Randy Kepler a&
SUBJECT: Huffman Finishing Company
NC0025135
Caldwell County
1
RECEWE���
OCT 0 7 1992
TECHNICAL SUPPORT BRANCH
We have received comments from the Division of Environmental Health
and from Huffman Finishing Co. concerning the above mentioned permit. A
copy of the letters are attached. DEH concurs provided limitations are
modified to reflect treatment and not max. loading rate. We need to assure
DEH that the limits that were assigned were so to protect the downstream
water supplies. If you could explain in a memo how the limits originated so
DEH can see we have the permit drafted to protect the water quality. Also
Huffman has made several comments to the draft permit. Would you also
please comment on these.
Thank You
c&
6 bc-- b00-1-j �b � Lunn
vva_72,

0
INFANTS'. CHILDREN'S. MISSES' AND MEN'S
HOSIERY
GRANITE FALLS. N. C. 28630
September 15, 1992
Mr. Paul White, P.E.
Regional Engineer
N.C. Division of Environmental Management
Asheville Regional Office
Interchange Building
59 Woodfin Place
Asheville, North Carolina 28801
Re: NPDES Permit No. NC 0025135
Huffman Finishing Company
Caldwell County
Dear Mr. White:
ram)
We appreciate receiving a copy of the "draft" NPDES permit for our proposed wastewater discharge to
the Catawba River (Lake Hickory). We have reviewed the permit provisions and would like to take this
opportunity to offer comments and request several revisions to the permit before it goes to "public
notice." We have assembled wastewater data from various sources in support of our request that several
provisions of the permit be revised prior to issuance. The wastewater data are identified as follows:
Appendix "A": Effluent results from our monthly self -monitoring reports for BOD,
COD, NH3-N, Total Suspended Residue and Phenol. Results are
presented in a graph format and reflect the improved effluent quality
following completion of our wastewater treatment improvements project
in the summer of 1990, and the THE and waste minimization completed
in May 1991.
Appendix "B": "Annual Pollutant Analysis" for Huffman Finishing Company's WWTP.
Appendix "C": Graph depicting Chronic Toxicity results for the current wastewater
discharge.
Appendix "D": Monthly self -monitoring results of wastewater treatment plant effluent.
As we understand the draft permit, there are three (3) separate discharge conditions and each discharge
condition has its own set of effluent limitations:
Discharge Condition No. 1: Huffman Finishing Company continues to operate the recently
upgraded and expanded plant until the existing discharge is relocated to the Catawba River.
Discharge Condition No. 2: Continue to operate our recently upgraded and expanded plant with
discharge at the current location.
w

• Mr. Paul White, P.E.
September 15, 1992
Page 2
• • • Discharge Condition No. 3: Discharge the treated wastewater directly to the Catawba River, with
our discharge pipe within feet of our current stream mouth.
Our comments and/or requests for relief generally follow the sequence of effluent limitations cited for
each "discharge condition."
A. Discharge Condition No. 1 (DC-1):
1. Attached (under Appendix "A" and "D") are self -monitoring results for sulfides and
ammonia nitrogen. Because the sulfide discharge is consistently less than 10% of the
discharge limitation and because the effluent ammonia nitrogen concentration is
consistently less than 1.0 mg/1, we request the monitoring frequency be reduced from
weekly to monthly.
2. Attached (as Appendix "B") is a copy of Huffman Finishing Company WWTP's "Annual
Pollutant Analysis." On page 12 of 13, the results indicate the concentrations of
cadmium, chromium, and nickel are either below the detectable limit or significantly
below the effluent limitation. Since the test results represent only a single sample, we
propose to monitor these parameters on a weekly basis for 2 months. If the results
continue to be significantly below the effluent limitations, we request the monitoring
requirements for all three (3) parameters be deleted, or as a minimum, reduce the
monitoring frequency to no greater than quarterly.
3. It is our understanding the Chronic Toxicity testing requirement as written (Part III,
Condition D) may not reflect the original intent of the NCDEM staff. As written,
Huffman Finishing Company cannot meet the Chronic Toxicity requirement at the 84%
concentration. For this very reason, we are proposing to relocate our discharge to the
Catawba River.
Attached hereto (as Appendix "C") is a graph depicting our Chronic Toxicity test results
over the past year. As indicated thereon, we cannot consistently pass the Chronic
Toxicity test at a concentration greater than 20%.
We are currently only "monitoring" for Chronic Toxicity. We request we be allowed to
continue to "monitor only" during the interim period until the effluent can be relocated.
If it is mandatory that a Pass/Fail limit be established, we request the testing requirement
be based on a concentration of 5 20% effluent.
4. Weekly monitoring is required and daily limits are established for Cyanide, Mercury,
Selenium, Fluoride, Barium, and Antimony. The results cited in the Annual Pollutant
Analysis (Appendix "B") are either below detectable limits or significantly below the
discharge limitation. Since the test results represent only a single sample, we propose
to monitor these parameters on a weekly basis for 2 months. If the results continue to
be significantly below the effluent limitations, we request the monitoring requirement for
all six (6) parameters be deleted or, as a minimum, reduce the monitoring frequency to
no greater than quarterly.

• Mr. Paul White, P.E.
• September 15, 1992
Page 3
5. Our Annual Pollutant Analysis and our monthly self -monitoring reports indicate we
cannot consistently meet the arsenic discharge limitations. We request the arsenic limit
be increased to no less than 100 µg/l.
6. Based on our 1992 performance data (monthly monitoring reports), the phenol limits
should be met under either of the discharge conditions.
7. We have determined through our Toxicity Identification Evaluations (TIE) studies that
chloride is the primary contributor in our inability to meet the chronic Toxicity Testing
requirements. As noted elsewhere herein, it is for this very reason Huffman Finishing
Company wishes to relocate the discharge from the zero flow stream that is tributary to
the Catawba River and discharge directly to the river.
It is not our intent to diminish our current level of treatment by relocating the discharge.
It is simply not economically feasible to reduce the chloride concentration to the value
cited in the permit. (See report in Appendix "E" entitled "Analysis of Treatment
Alternatives, Huffman Finishing Company," July 1991.) However, as a measure of our
commitment to continue to produce a high quality effluent and since the acute toxicity test
will ultimately govern the discharge to the Catawba River, we propose that the chloride
limitation be installed as an action level to be enforced after significant non-compliance
of an Acute Toxicity Limit of LC50 Z 90 % . This limit is the same as will be imposed
when the discharge is relocated.
B. Discharge Condition No. 2 (DC-2):
The discharge limitations for Discharge Condition No.2 are the same as those cited for Discharge
No. 1. Accordingly, the same rationale outlined under Discharge Condition No. 1 seeking relief
in monitoring requirements and discharge limitations is applicable to Discharge Condition No.
2.
It is Huffman Finishing Company's intent to discharge a quality effluent and protect the water
quality in the Catawba River. Our expenditures for improvements to our wastewater treatment
plant in 1989 and 1990 and the results of that investment —as illustrated in Appendix "A" —are
testimony to our commitment. : 11.
1,
N
It is also our desire to relocate the discharge to the Catawba River because it is not economically
feasible for us to meet the in -stream 7Q10 standard for toxicity at our current discharge location.
However, we can meet the standards described for the discharge to the Catawba River.
We understand there is no assurance we will be permitted to relocate the discharge. Therefore,
we must seek adequate relief to insure we can continue to operate and discharge at our current
location. Since we can and will continue to meet the ultimate tests required of a discharge to the
Catawba River, we must not be put out of business at our current discharge point as a result of
a lack of salt removal technology and the stream classification of the ditch to which we discharge.

Mr. Paul White, P.E.
September 15, 1992
Page 4
C. Discharge Condition No. 3 (DC-3):
1. Within Appendixes "A" and "B" and through our monthly self -monitoring results, there
is evidence to indicate the discharge values for sulfides, chromium, and phenols are well
under the proposed permit limits. We recognize the presence of these pollutants;
however, due to the results we have been achieving, we request the monitoring frequency
be reduced from weekly to monthly.
2. With regard to Cadmium, Nickel, Cyanide, Arsenic, Barium, Antimony, Lead, and
Silver, we suspect these elementsare either (a) non-existent in our waste stream,
(b) below detectable limits, or (c) exist at such insignificant concentrations as to adversely
impact water quality in the stream. We do not propose to eliminate monitoring;
however, based on the results of various wastewater analyses cited herein, we do request
the monitoring frequency be reduced to no greater than quarterly.
As final comment, under item 1 of the page entitled "Supplement to Permit Cover Sheet," the descri tion
since the improvements t the 0.110. MGD wastewater treatment plant should be deletedP
expand the plant to a capacity of 0.250 MGD have been completed.o upgrade and
Again we thank you for the opportunity to provide these comments regarding our proposed NPDES
permit. If you or the DEM staff have any questions regarding any of the information presented or need
clarification on those items for which we seek relief, please contact either me, Sam Moore at Burlington
Research (919 584-5564), or Buck Kennedy at The Wooten Company (919 828-0531). To further aid
in clarification of our actions since our WWTP upgrade in 1990-91, we are supplyinga summaryof our
efforts in support documents which are enclosed under Appendix "F" and Appendix "G".
We look forward to securing the new permit and completing the discharge relocation.
Sincerely,
HUFFMAN FINISHING COMPANY
Lee T. Huffman
Attachments
c: Forrest Westall, NCDEM, Asheville
Steve Tedder, NCDEM, Raleigh
Don Safrit, NCDEM, Raleigh
Rick Rowe, NCDEH, Raleigh
Sam Moore, Burlington Research
Buck Kennedy, The Wooten Company

State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Environmental Health
P.O. Box 27687 • Raleigh, North Carolina 27611-7687
James G. Martin, Govemor Richard K. Rowe
William W. Cobey, Jr., Secretary Director
TO:
August 4, 1992
Ms. Colleen Sullins
NPDES Permits Group Leader
Discharge Permits Unit
Division of Environmental Management
FROM: Rick Rowe, Director kkiac,ts
Division of Environmental Health
SUBJECT: Draft National Pollutant Discharge
Elimination System Permit
Huffman Finishing Company
Permit No. NC 0025135
Caldwell County
Reference is made to the above mentioned Draft National Pollutant Discharge
Elimination System Permit. We have reviewed this permit application very carefully
due to the proximity of the proposed discharge to the Town of Longview and City of
Hickory water supply intakes. We feel that special consideration is warranted due
to the complex hydraulics of Lake Hickory during various flow conditions and the
uncertain impacts this may have on the two downstream intakes.
We concur with the issuance of this permit provided the effluent limitations,
particularly phenols, are modified to reflect the wastewater plant's treatment
capability rather than the maximum allowable loading rate for Lake Hickory, as
proposed. This should significantly reduce the amount of contaminants which might
be allowed in the lake, while establishing effluent limitations which can be
achieved by Huffman Finishing. Our concurrence is also contingent upon proper
operation and maintenance of the facility and compliance with the toxicity limit.
If we can be of further assistance, please contact us.
WCK/cb
An Equal Opportunity Affirmative Action Employer

North Carolina Division of Environmental Management
Water Quality Section / Intensive Survey Group
March 12, 1992
MEMORANDUM
To: Ruth Swanek
Through: Jay Sauber,Kellt
From: Howard Bryant ibn.3
Subject: Long-term BOD Analysis forHuffman Finishing
County: Caldwell
NPDES #NC0025135
Receiving Stream: UT to Catawba River
Sub -basin: 030832
PAY BOD. NH3-N TKN-N NOX-N TAN
0 0.19 3.0 15.00 18.0
5 3.36 0.21 3.8 16.00 20.0
10 6.08 0.12 3.6 15.00 19.0
15 7.86 0.09 4.3 17.00 21.0
20 9.18 0.06 3.9 15.00 19.0
25 10.30 0.02 5.1 15.00 20.0
30 11.16 0.11 4.4 15.00 19.0
35 12.01
40 12.62
50 14.03
60 15.26 0.08 3.9 15.00 19.0
70 16.63
80 17.69
90 18.75
100 19.62
110 20.40
120 21.14
130 21.78 0.02 4.0 17.00 21.0
Date Collected: October 9, 1991
0725-0730
cc: Central Files
Regional Water Quality Supervisor
Collected by: White
pH: 8.2
Test evaluation: excellent
Seeded: seeded

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