NC0004405_staff comments_19931124

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
Nann B. Guthrie, Regional Manager
Asheville Regional Office
AvICA
E)EHNR
DIVISION OF ENVIRONMENTAL MANAGEMENT
WATER QUALITY SECTION
November 24, 1993
Mr. Arthur Toompas
Cone Mills Corporation
1201 Maple Street
Greensboro, North Carolina 27405
Subject: Draft NPDES Permit
CONE MILLS, CLIFFSIDE PLANT
NPDES Permit No. NC0004405
Rutherford County
Dear Mr. Toompas:
This letter is provided in response to our telephone conversation
of this date concerning the proposed renewal permit for the Cliffside
Plant's wastewater discharge. Comments regarding each item discussed
are listed below.
Mercury - The limitation (0.28 ug/1 as a daily maximum) is proposed
in the draft permit due to results reported by the Cliffside Plant
in an annual pollutant analysis. The proposed limit would be
required to insure compliance with the surface water standard of
0.012 ug/1 for mercury. Based upon information that mercury is not
used in the Cliffside Plant, I would suggest monthly monitoring for
mercury at the effluent with no numerical discharge limitation.
After a period of six months to one year and depending upon data
generated, this agency would then carefully consider Cone Mills
Corporation's request to remove the "monitoring only" requirement
for mercury from the permit. If Cone Mills Corporation would be
amenable to "monitoring only" with a frequency of monthly for
mercury, please submit a letter requesting such to Ms. Coleen
Sullins, Permits and Engineering Unit, PO Box 29535, Raleigh, NC
27626-0535. The letter must be submitted on or before December 15,
1993.
Interchange Building. 59 Woodfin Place, Asheville, N.C. 28801 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

Arthur Toompas
November 24, 1993
Page 2
Phenols - The proposed daily maximum concentration -limit of 23 ug/1
at a flow of 1.75 MGD is equivalent to the former daily maximum
mass -limitation of 0.35 lbs/day. The phenols limitation would more
accurately be stated as a concentration -limit of 23 ug/1 since
phenols should be collected as a grab sample and not as a composite
sample, as incorrectly stated in the draft permit. (Sulfides
should also be collected as a grab and not as a composite sample.
By copy of this letter I am advising the permits section of the
typographical errors concerning grab versus composite for both
phenols and sulfides.)
Chlorine - The concerns about installation of dechiorination could
be addressed through inclusion of a construction schedule in the
permit. In the letter to Ms. Sullins discussed in the "mercury"
section above, please request inclusion of a schedule date in the
renewal permit.
Your attention to these matters is appreciated. Please contact me
at telephone [phone] if there are questions concerning the proposed
wastewater discharge permit.
Sincerely,
7
James R. Reid
Environmental Engineer
Enclosure
xc: Mike Gibert

Slopes
Facility: Cone Mills Corp.
Stream: Second Broad River
Dist
4.90
3.87
3.15
0.05
4.73
0.33
1.74
800
780
760
740
720
700
680
660
640
620
600
0.00
Cum. Dist.
0.00
4.90
8.77
11.92
11.97 ,
l�
16.70 yr
17.03
18.77 ---
\I
Elevation Slope
800
780
760
740;
720
689
669 Iv
649
4.08
5.17
6.35
400.00
6.55 7
60.61
11.49
■
i
5.00 10.00 15.00
Graph for Plotting Slopes
20.00