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NC0006190_Permit Issuance_20090615
NPDES DOCUMENT SCANNING COVER SHEET NPDES Permit: NC0006190 Maiden Plant WWTP Document Type: i Permit Issuance Wasteload Allocation Authorization to Construct (AtC) Permit Modification Complete File - Historical Engineering Alternatives (EAA) Correspondence Owner Name Change Instream Assessment (67b) Speculative Limits Environmental Assessment (EA) Document Date: June 15, 2009 This document is printed on reuses paper - ignore any content on the reirerse side ern NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Dee Freeman Governor Director Secretary June 15, 2009 Mr. Steve Slaughter, Plant Manager Delta Apparel, Inc. P.O. Box 37 Maiden, North Carolina 28650 Subject: NPDES Permit NC0006190 Modification Delta Apparel — Maiden Plant Catawba County Dear Mr. Slaughter: Division personnel have reviewed and approved your application for modification of the subject permit. Accordingly, we are forwarding the attached NPDES discharge permit. This permit is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S. Environmental Protection Agency dated October 17, 2007 (or as subsequently amended.) This permit modification allows for an increase in permitted flow from 1.0 MGD to 1.1 MGD, to accommodate increased production. Please note the following changes from the draft permit modification sent to you on April 22, 2009. • As requested, the Monthly Average Flow limitation was reduced from 1.2 MGD to 1.1 MGD under Section A. (1.). As a result the following corrections had to be made to account for the new IWC of 12%. o The water quality based Chromium limit was changed to 402 ug/L. o Note 3 under Section A.(1.) has been .changed to Chronic Toxicity at 12%. o In the first sentence of Section A.(2.), The Chronic Toxicity Permit Limit, was changed to: The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to Ceriodaphnia dubia at an effluent concentration of 12%. o The effluent concentrations cited in Section A.(2.) pertaining to the North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure have been revised to 48%, 24%, 12%, 6%, and 3%. 1617 Mail Service Center, Raleigh, North Carolina 27699.1617 Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 Phone: 919-807-6300 FAX: 919-807-64921 Customer Service: 1-877-623-6748 Internet. www.ncwaterquality.org An Equal 0pportunity l Affirmative Action Employer NOrthCarolina A7atiiraIIij o In the first paragraph of Section A (3). TOXICITY IDENTIFICATION EVALUATION (TIE), 13% was changed to 12%. If any parts, measurement frequencies or sampling requirements contained in this permit are unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty (30) days following receipt of this letter. This request must be in the form of a written petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed with the office of Administrative Hearings, 6714 Mail Service Center, Raleigh, North Carolina 27699-6714. Unless such a demand is made, this permit shall be final and binding. Please take notice that this permit is not transferable. The Division may require modification revocation and reissuance of the permit. This permit does not affect the legal requirements to obtain other permits which may be required by the Division of Water Quality or permits required by the Division of Land Resources, Coastal Area Management Act, or any other Federal or Local governmental permits may be required. Clark Creek is listed as an impaired stream on North Carolina's 303 (d) list. Currently, the stream does not meet all water quality standards. If the limitations in the current permits for facilities discharging to Clark Creek do not result in improved water quality, removal of discharges to Clark Creek may be necessary for the health of the stream. Although the Division believes multiple sources of wastewater cause degradation to Clark Creek, we will continue to monitor compliance at your facility. If noncompliance with your permit's effluent limits is shown to be a direct cause of stream degradation, the Division will recommend removal of your facility' s discharge. Part III of your permit requires you to "continually evaluate all wastewater disposal alternatives and pursue the most environmentally sound alternative of the reasonably cost effective alternatives" to surface water discharge. Such an evaluation may help you find an alternative to surface water discharge that is more appropriate for your facility. If you have questions concerning this permit, please contact Julie Grzyb by e-mail (julie.grzyb@ncmail.net) or phone at (919) 807-6389. Si erely, oleen H. Sullins / Enclosure: NPDES Permit NC0006190 cc: Central Files NPDES Files Mooresville Regional Office / Surface Water Protection Section (ecopy) Aquatic Toxicology Unit EPA Region IV David Merryman, Catawba Riverkeeper, 421 Minuet Lane Suite #205, Charlotte, NC 28217 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Location: 512 N: Salisbury St. Raleigh, North Carolina 27604 Phone: 919.807-63001 FAX: 919-807.64921 Customer Service: 1-877-623-6748 Internet www.ncwaterquality.org An Equal opportunity \ Affirmative Action Employer NorthCarolina . haturalll y:r Permit No. NC0006190 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY PERMIT TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, Delta Apparel, Inc. is hereby authorized to discharge wastewater from a facility located at the Maiden Plant 100 West Pine Street Maiden, North Carolina Catawba County to receiving waters designated as Clark Creek in the Catawba River Basin in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III, and IV hereof. The permit shall become effective July 1, 2009. This permit and the authorization to discharge shall expire at midnight on May 31, 2011. Signed this day June 15, 2009. 4 C . een H. Sullins, Director tef A ‘Division of Water Quality By Authority of the Environmental Management Commission Permit No. NC0006190 SUPPLEMENT TO PERMIT COVER SHEET • All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked. As of this permit issuance, any previously issued permit bearing this number is no longer effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the permit conditions, requirements, terms, and provisions included herein. Delta Apparel, Inc. is hereby authorized to: 1. Continue to operate an existing wastewater treatment facility located at Delta Apparel, Inc., 100 West Pine Street, Maiden, Catawba County, and consisting of the following treatment components: • heat exchanger • manual bar screen dual aeration basins with mechanical aerators (1.25 Million gallons each) • dual secondary clarifiers • post aeration (84,000 gallons) • parshall flume with recording flow meter • aerated sludge storage lagoon 2. Discharge treated process wastewater from said treatment works (via Outfall 001) into Clark Creek, a Class C water in the Catawba River Basin, at the location specified on the attached map. ,..J� _- rir � t ( Latitude: 35°34'38" USGS Quad #: Longitude: 81°13'14" E14SW N SCALE 1:24,000 (1" = 2000') `�Itr j r /yy%` 1, i=- � % J -- - 7-v; 2 —�_, -rQ ii q /4--. j • • R 1 667 N s/1 rf../, ,1?uc \I. •wtv' . East CV_ Delta Apparel, Inc. NC0006190 Receiving Stream: Clark Creek Stream Classification: C River Basin: Catawba Sub -Basin #: 03-08-35 County: Catawba fit Permit No. NC0006190 A. (1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Beginning on the effective date of this permit and lasting until permit expiration, the Permittee is authorized to discharge treated process wastewater from Outfall 001. Such discharges shall be limited and monitored by the Permittee as specified below: EFFLUENT CHARAC FPSTICS , ,. ,,, ,� , �f j Y y/J'- i �y w . y ; L r 4 3y' { . MONITORINGREQUIREMENTS f.. EFFLUENT LIMITATIONS Monthly Avera•geDa ., _• Y. Ma :ximy f �-4- ,2 .._C ` } ' •• * - `, * Mea.surement f ; .' �_ j r, en is Sample Type•' -; 's (A • - !- .i�f'�. Sample Loranon' , r ;~ �r -^ • •_ f. Y-p. � M1 7 7 L ... Flow • 1.1 MGD Continuous • Recording Influent or Effluent BOD, 5-day, 20°C 162 pounds/day 325 pounds/day 31Week Composite Effluent COD 2900 pounds/day 6271 pounds/day Weekly Composite Effluent Total Suspended Solids 785 pounds/day 1853 pounds/day 31Week Composite Effluent NH3 as N 3.0 mg/L 15.0 mg/L 3iWeek Composite Effluent Sulfide 8.0 pounds/day 16.0 pounds/day Weekly Grab Effluent Phenols 4.0 pounds/day 8.0 pounds/day Weekly Grab Effluent Total Chromium 402 Argil Weekly Composite Effluent pH 6.0 < pH < 9.0 3/Week Grab Effluent Dissolved 0xygen2 3/Week Grab Effluent Temperature 3/Week Grab Effluent Conductivity 3/Week Grab Effluent Total Copper Weekly Composite Effluent Total Zinc 2/Month Composite Effluent Chloride Quarterly Composite Effluent Sulfates Quarterly Composite Effluent Total Nitrogen (NO2+NO3+TKN) Monthly Composite Effluent Total Phosphorus Monthly Composite Effluent Chronic Toxicity3 Quarterly Composite Effluent Color4 549 ADMI Weekly Composite Influent and Effluent Color (April - October) Weekly Grab Upstream & Downstream Total Copper (April - October) Monthly Grab Upstream & Downstream Dissolved Oxygen 3/Week5 Grab Upstream & Downstream Temperature 3/Week5 Grab Upstream & Downstream Conductivity 31Week5 Grab . Upstream & Downstream Notes: 1. Sample locations: Upstream = at NCSR 2007. Downstream = at NCSR 1274. 2. The daily effluent dissolved oxygen concentration shall not be less than 5.0 mg/L. 3. Chronic Toxicity (Ceriodaphnia) at 12%; March, June, September, December; refer to Special Condition A (2) and A (3) . 4. Refer to Special Condition A (4) for a complete explanation ofeffluent color limits and color requirements. 5. Instream samples shall be collected 3/Week (June -September) and 1/Week (October -May). There shall be no discharge of floating solids or visible foam in other than trace amounts. Permit No. NC0006190 SUPPLEMENT TO EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS SPECIAL CONDITIONS A (2). CHRONIC TOXICITY PERMIT LIMIT (QRTRLY) The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to Ceriodaphnia dubia at an effluent concentration of 12%. The permit holder shall perform at a minimum, puarteriu monitoring using test procedures outlined in "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions using the following effluent concentrations: 48%, 24%, 12%, 6%, and 3%. The tests will be performed during the months of March, June, September, and December. Effluent sampling for this testing shall be performed at the NPDES permitted final effluent discharge below all treatment processes. If the test procedure performed as the first test of any single quarter results in a failure or ChV below the permit limit, then multiple -concentration testing shall be performed at a minimum, in each of the two following months as described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The chronic value for multiple concentration tests will be determined using the geometric mean of the highest concentration having no detectable impairment of reproduction or survival and the lowest concentration that does have a detectable impairment of reproduction or survival. The definition of "detectable impairment," collection methods, exposure regimes, and further statistical methods are specified in the "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised - February 1998) or subsequent versions. All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Monitoring Form (MR-1) for the months in which tests were performed. If reporting pass/fail results using the parameter code TGP3B, DWQ Form AT-1 (original) is sent to the below address. If reporting Chronic Value results using the parameter code THP3B, DWQ Form AT-3 (original) is to be sent to the following address: Attention: NC DENR / DWQ / Environmental Sciences Section 1621 Mail Service Center Raleigh, North Carolina 27699-1621 Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section no later than 30 days after the end of the reporting period for which the report is made. Test data shall be complete, accurate, include all supporting chemical/physical measurements and all concentration/response data, and be certified by laboratory supervisor and ORC or approved designate signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream. Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility name, permit number, pipe number, county, and the month/year of the report with the notation of "No Flow" in the comment area of the form. The report shall be submitted to the Environmental Sciences Section at the address cited above. Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be required during the following month. Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water Quality indicate potential impacts to the receiving stream, this permit may be re- opened and modified to include alternate monitoring requirements or limits. If the Permittee monitors any pollutant more frequently then required by this permit, the results of such monitoring shall be included in the calculation & reporting of the data submitted on the DMR & all AT Forms submitted. • Permit No. N00006190 NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism survival, minimum control organism reproduction, and appropriate environmental controls, shall constitute an invalid test and will require immediate follow-up testing to be completed no later than the last day of the month following the month of the initial monitoring. A (3). TOXICITY IDENTIFICATION EVALUATION (TIE) Should any whole effluent toxicity test produce a chronic value less than 12%, the permittee will undertake toxicity identification evaluations (TIEs) using the procedures described in Toxicity Identification Evaluation: Characterization of Chronically Toxic Effluents, Phase I, EPA/600/6-91/005F, May 1992 or similar methods. A final report will be generated and submitted to the address below no later than 60 days following the initial test producing a chronic value less than 12%. The primary objective of the TIE activity will be to confirm or rule out polymer as the source of toxicity. The report detailing findings of the TIE is to be sent to the following address: Attention: Environmental Sciences Section North Carolina Division of Water Quality 1621 Mail Service Center Raleigh, North Carolina 27699-1621 A (4). COLOR PERMITTING REQUIREMENTS Color Monitoring. The perrnittee will conduct color monitoring of instream stations (upstream, downstream) on a weekly basis during each summer season (April -October). The permittee will record whether a color plume was observed around the outfall pipe during the weekly instream sampling events, and include that information on the monthly discharge monitoring report. Influent and effluent samples will be collected weekly for color on a year-round basis. Color samples will be analyzed for ADMI color at natural pH. Effluent/influent samples will consist of 24-hour composites, while instream samples will be collected as grab samples. Samples will be analyzed by a state certified laboratory. The influent monitoring station will need to be located prior to polymer addition. Color Reopener. If data show that water quality standards for color are being violated by the discharge permitted by the terms of this permit, then the Director may reopen this permit for the purpose of imposing additional requirements pursuant to 15A NCAC 2H.0114. Alternatively, if future conditions change and color is no longer a component of the influent wastestream, then the permittee may request a permit modification to remove color permit requirements. NCDENR / DWQ FACT SHEET FOR NPDES PERMIT DEVELOPMENT Delta Apparel, Inc. NPDES No. NC0006190 (Final) Facility Information Facility Name: Delta Apparel's Maiden Plant, 100 West Pine St., Maiden, NC 28650 Permitted Flow, MGD: 1.1 (original request 1.2) County: Catawba Facility Class: III Regional Office: Mooresville Facility Status: Existing USGS Topo Quad: E14SW (Maiden NC) Permit Status: Major Modification Permit writer: Julie Grzyb Stream Characteristics Receiving Stream: Clark Creek Subbasin: 030835 Drainage Area (mi2): 66.00 Stream Index No.: l 1-129-5-(0.3) Summer 7Q10 (cfs) 12 Stream Class: C Winter 7Q10 (cfs): 25.5 303(d) Listed: YES 30Q2 (cfs): 34 305(b) Status: Average Flow (cfs): 78.00 Use Support: Impaired IWC (%): 13 % at 1.2 MGD Modification revision: Requested on 6/1/09 Permitted Flow, MGD 1.1 MGD IWC (%): 12 % at 1.1 MGD FACILITY SUMMARY This is a major permit modification request for Delta Apparel, Inc., a major industrial textile facility which knits, dyes, and manufactures cotton t-shirts. The permittee is requesting an increase in flow from 1.0 MGD to 1.2 MGD based on a production rate of 800,000 lbs/cloth/week. The facility discharges 100% process wastewater, while all domestic wastewater is treated at the Town of Maiden WWTP. Sludge is land applied under permit WQ0006984. This facility was originally permitted in the 1970's and operated as Duckhead Apparel. A 1992 ATC authorized relocation of its discharge point from Shady Branch to Clark Creek. Based on planned production increases the permit was modified in January 1998 to allow expansion from 1.0 to 1.5 MGD after receiving an ATC. The permit was modified in 2000 to change the name from Delta Mills Inc to Delta Apparel Inc. A permit renewal was issued in 2002 and the Effluent Limitations and Monitoring Page for 1.5 MGD was removed maintaining the permitted flow at 1.0 MGD since the facility was able to expand production without the need for additional flow due to water conservation and reuse. The 2002 permit was contested by Delta Apparel primarily due to concerns associated with the effluent color limitations. After reaching a settlement agreement with DWQ on 8/27/2004, Delta Apparel implemented a color reducing technology and achieved significant color reductions during 2004-2005. A second color reducing technology was stipulated in the 2005 permit modification and permitted flow was maintained at 1.0 MGD. The permit was last renewed in 2006 with Effluent Guideline Limitations for BOD5, COD, TSS, Sulfide and Phenols frozen at the January 1998 permit levels which were based on the 1995-97 production rates of 104, 5101bs/day or less. NPDES PERMIT FACT SHEET (final) Delta Apparel, Inc. • Page 2 NPDES No. NC0006190 Since about June 2008 production has increased and Delta Apparel is requesting a flow modification so additional business can be accepted. The production expansion is for a daily maximum production rate of 114,300 lbs/day which will ultimately increase the average amount of wastewater generated at the facility by approximately 200,000 gallons per day. During the last two years the average monthly flow has been 1.18 MGD and the facility has complied with all permit (imitations except for flow. In accordance with 15A NCAC 2H.0105(c)(2), the facility evaluated five different disposal alternatives for the additional flow. Discharging to the Town of Maiden's WWTP was deemed unacceptable since the POTW has limited capacity and Delta would need to treat the wastewater prior to discharge. Land application was evaluated but found to be cost prohibitive. The only applicable options were surface water discharge, wastewater reuse, or a combination of surface water discharge and reuse. The most cost effective choice was for Delta to continue discharging to surface water. The latter two of these potential alternatives would require significant upgrades to the on -site system in order for the effluent quality to be acceptable for reuse in the manufacturing operations. The wastewater treatment plant at Delta consists of two 1.25 million gallon aeration basins which currently receive 0.5 MGD each having 60 hours retention. At 1.2 MGD the basins would have 50 hours of retention. Polymer for color removal is added to the flow leaving the basins which enters into dual clarifiers to settle solids. A flocculation agent is added to the center -well of each 80,000 gallon clarifier. After clarification the wastestream flows through a chlorine contact tank which is no longer in use and then into an 84,000 gallon post aeration basin. Solids that settle and thicken are wasted to a sludge storage lagoon which has a capacity of 1.8 MGD. Treated wastewaters from the clarifiers discharge to a parshall flume with an ISCO flow recorder and a refrigerated composite sampler. The effluent is discharged through a 7,500-foot gravity line to Clark Creek, approximately 100-ft above the Town of Maiden's discharge point, and several miles below the Town of Newton's discharge. Clark Creek flows into South Fork Catawba River, then into Lake Wylie. Most of Clark Creek is considered impaired. The subject stream segment is Class C, Impaired, and listed in the 2006 303(d) list as biologically impaired due to unknown causes. Delta Apparel is not proposing any modifications to its wastewater treatment system due to the increase in flow and production. The plant was originally designed to handle 1.5 MGD and increased flows during the past two years have not resulted in any permit violations other than the monthly average flow. Based on Discharge Monitoring Reports from September and December 2007, Mr. Slaughter of Applied Water Technology, Inc. provides the following chart on the percent of a pollutant removed in excess of current permit limitations with the existing treatment facility. Note that September and December experienced flows similar to the 1.2 MGD flow proposed in this modification request. Discharge Parameter Permit Limit Actual Value % Below Permit Limit Flow 1.0 MGD 1.17 MGD - BOD5 162 lbs 10.4 lbs 94 TSS 785 lbs 132.9 lbs 83 COD 2900 lbs 1173.6 lbs 60 Color, ADMI 549 su 154 su 72 Chronic Toxicit >11% 15.6%* 42 Page 2 Version: June 10, 2009 NPDES PERMIT FACT SHEET (final) Delta Apparel, Inc. Page 3 NPDES No. NC0006190 In addition, Mr. Slaughter has clarified that in order to maintain color removal rates, polymer dosing tests are performed once per month by the supplier's representative (Hychem, Inc. of Tampa, FL). Color removal is evaluated based on a 10 — minute retention time. At 1.2 MGD the clarifier retention time is estimated at 3.4 hours, therefore; maintaining the necessary retention times for color removal at the higher flow is not expected to be a problem. INSTREAM MONITORING AND COMPLIANCE SUMMARY The facility is required to conduct self -monitoring of the South Fork Catawba River at one location upstream of the discharge and one location downstream of the discharge. The instream self -monitoring includes: temperature, conductivity, dissolved oxygen, total copper and color. An analysis of DO, temperature and conductivity for the past two years showed compliance except for one period during June 2008 when temperatures were high and the DO Water Quality standard of 5.0 mg/L was violated (Table 1; attached). A DO level below 5 mg/L has not been detected downstream since the June 2008 occurrences. The Level B DO model analysis conducted in 1997 predicted an increase to 300 lbs/day BOD5 would not impact the DO downstream of the outfall. For the years 2007 and 2008, Delta Apparel's effluent levels for BOD5 have been well below the permit limit of 162 lbs/day (monthly avg.) with the calculated mean of the 24 monthly averages at 16.7 lbs/day. The mean concentration of the 24 monthly averages for NH3-N was 0.25 mg/L which is also well below the facility's permit limit of 3 mg/L, and effluent D.O. has averaged 7.7 mg/L. See attached Table 2 for details. It is recommended that existing BOD, NH3-N, and DO limits be maintained in this permit modification. Additionally, it is recommended that this segment of Clark Creek and all its dischargers be re-evaluated prior to the next permit renewal scheduled for the Catawba River Basin in 2011. Discharge Monitoring Reports have been reviewed for the period January 2007 through December 2008. The facility has been in compliance with all permit requirements except for its monthly average flow limitation. The Mooresville Regional staff performed an inspection of the Delta Mills — Maiden Plant on 2/26/09. The staff report stated that Delta Mills facilities are well operated and maintained, and there is no history of chronic noncompliance aside from the monthly average flow being exceeded. The staff had no objection to the permit renewal provided the existing treatment facilities are hydraulically capable of handling the increased flows. REASONABLE POTENTIAL ANALYSIS Reasonable potential analyses were conducted for Chromium, Copper, Zinc and Chloride (Table 3; attached). Based on reasonable potential analysis of chromium data, there is no reasonable potential to exceed the in -stream chromium water quality standard. However, since the WQ-based limit is more stringent than the corresponding effluent guideline limit, the WQ-based chromium limit of 373 ug/L is used in the modified permit along with a weekly monitoring frequency. This limit is below the current limit of 437 ug(L since the IWC was changed from 11 to 13 percent. Copper, Zinc and Chloride, all exhibit some reasonable potential to violate Action Level standards. If the increased flow results in violations of the toxicity tests, the actual impact of these action level parameters will need to be investigated and possible limitations determined. Page 3 Version: June 10, 2009 NPDES PERMIT FACT SHEET (final) Delta Apparel, Inc. Page 4 NPDES No. NC0006190 Federal Effluent Guideline Limits (EGLs). The facility is a textile knit fabric dye and bleaching operation which is subject to 40 CFR 410 Subpart E - Knit Fabric Finishing Subcategory, as a simple manufacturing operation. Although 40 CFR 410 allows for an increase in EGLs based on the requested increase in production, the Division has elected to freeze the EGL limits at the January 1998 permit levels due to the impaired stream status and the ability of the permittee to already meet these more stringent limits. The production -based limits in this permit and the 2006, 2005, and 2002 permits were based on the production volume of 104,510 lbs/day or less from previous permits (See Table 4; Textile Effluent Limits Spreadsheet). There are no Federal EGLs for color. Water Quality -Based Effluent Limits. The receiving stream segment is subject to water quality standards applicable to Class C freshwater streams. The previous permits included water -quality based effluent limits for ammonia, dissolved oxygen, and chromium. The limits for ammonia and dissolved oxygen have been retained in the draft modification and the WQ-based limit for chromium has been changed to 373 ug/L. COLOR The mean of the 24 monthly averages for color samples collected from Jan. 2007 to Dec. 2008 was 228 ADMI units (American Dye Manufacturers Institute). The monthly average permit color limit is 549 ADMI units (See Table 5) and is recommended to remain in the modified permit. TOXICITY TESTING The permittee has been consistently passing its WET tests with a chronic value of 15.6%. With the increase in flow the new IWC was calculated at 13%. Current Requirement: Quarterly Chronic Toxicity @ 11.0% MAR, JUN, SEP, DEC Recommended Requirement: Quarterly Chronic Toxicity @ 13.0% MAR, JUN, SEP, DEC. PROPOSED CHANGES • Change the effluent limitation on Flow to a Monthly Average of 1.2 MGD. • Due to the new IWC% reduce the water quality based Chromium limit to 373ug/L. • Chronic Toxicity Permit Limit set at an effluent concentration of 13 % based on new IWC. • Phase II Chronic Whole Effluent Toxicity Test concentrations changed to : 52%, 26%. 13%, 6.5% and 3.25% based on new IWC. Effluent Limitations and Monitoring Requirements for all the other parameters remain the same. Proposed Schedule for Permit Issuance Draft Permit to Public Notice: Permit Scheduled to Issue: State Contact 04/22/09 (est.) 06/15/09 (est.) If you have any questions on any of the above information or on the attached permit, please contact Julie Grzyb at (919) 807-6389. Page 4 Version: June 10, 2009 NPDES PERMIT FACT SHEET (final) Delta Apparel, Inc. Page 5 NPDES No. NC0006190 Addendum to Fact Sheet In a letter received from Steve Slaughter, Plant Manager, on June 1, 2009 Delta Apparel requested that the monthly average flow limit be reduced from 1.2 MGD to 1.1 MGD in the final permit. The original modification request was to increase the permitted flow from 1.0 MGD to 1.2 MGD. The facility is concerned that at a flow of 1.2 MGD the chronic toxicity limit of 13 % may be difficult to meet. With a flow of 1.1 MGD the chronic toxicity limit will be 12 % and Mr. Slaughter believes this reduction will provide a greater certainty of compliance with the whole effluent testing limitation. Since this change in the permit results in less of a pollutant load to the receiving stream and a greater certainty of compliance the draft permit will be made final with the following minor changes. • Change the effluent limitation on Flow to a Monthly Average of 1.1 MGD. • Due to the reducedflow low of 1.1 MGD the JWC% is 12% and the water quality based Chromium limit changes to 402 ug/L (see revision to RPA Table 3, 6/8/2009) • Change the Chronic Toxicity Permit Limit to an effluent concentration of 12% based on the revised IWC. • Phase II Chronic Whole Effluent Toxicity Test concentrations change to : 48%, 24%. I2%, 6% and 3% based on revised IWC. The Permittee will be made aware that noncompliance with any permit limit, flow or toxicity limitations could result in a schedule of compliance via either a permit modification or a SOC. Page 5 Version: June 10, 2009 NC0006190 Delta Apparel TABLE 1 NC0006190 Date 1-4-07 1/11/2007 1/18/2007 1/25/2007 2/8/2007 1/15/2007 1/22/2007 2/8/2007 2/15/2007 2/22/2007 3/1/2007 3/8/2009 3/15/2007 3/22/2007 3/29/2007 4/5/2007 4/11/2007 4/19/2007 4/26/2007 5/3/2007 5/10/2007 5/17/1997 5/24/2007 5/31/2007 6/5/2007 6/6/2007 6/7/2007 6/12/2007 6/13/2007 6/14/2007 6/19/2007 6/20/2007 6/21/2007 6/26/2007 6/27/2007 6/28/2007 7/3/2007 7/4/2007 7/5/2007 7/10/2007 7/11/2007 7/12/2007 7/17/2007 7/18/2007 7/19/2007 7/24/2007 7/25/2007 7/26/2007 7/31/2007 8/1/2007 Delta Apparel Upstream Temp. D.O. Conductivity (°C) (mg/L) (umhos/cm) 8.1 9.9 150 3.6 11.3 150 6.1 10.6 .170 4.9 10.6 160 5.2 10.7 160 3.6 11.1 120 9.2 9.6 150 5.2 10.7 160 3.6 11.1 120 9.2 9.6 150 - 7.9-.1•0.1 310 9.2 9.6 170 12.5 8.8 130 11.8 9 160 17 7.8 170 11.3 8.8 180 10.9 9 140 8.4 13.2 180 16.5 8.4 200 18.4 8 210 16.7 8.5 230 16.3 7.8 160 16.6 7.7 210 19.7 7.1 230 18.4 7.2 160 18.8 7.1 210 19.2 7.2 200 19.4 7.1 130 18 7.4 550 18 7.4 170 21.3 7 200 21.6 6.8 120 18.8 7.3 210 21.1 7 240 21.4 6.9 250 22.3 6.2 120 19.1 7.4 180 19.5 7.3 220 20 7.3 190 21.6 6.9 170 22.3 6.5 92 21.4 6.8 180 21.7 7 250 22.8 6.6 100 22.4 6.8 170 19.6 7.2 120 20.1 7 120 20.6 7.2 180 21.2 7.1 160 21.6 7 230 Downstream Temp. D.O. Conductivity (°C) (mg/L) (umhos/cm) 8.2 9.8 40 11 6 10.5 4.7 10.5 5.1 10.6 3.4 10.9 9.7 9.3 5.1 10.6 3.4 10.9 9.7 9.3 8.5 9.7 9.7 9.3 13.3 8.3 12.4 8.7 17.3 7.7 12.5 8.4 11 9 8.1 13.5 17.3 8 19.1 7.4 17.3 8 17 7.2 17.4 7.4 20.5 6.6 19.3 6.8 19.7 7 20.1 6.8 19.7 7.2 18.9 7 18.9 7 21.9 6.8 22 6.5 19.9 6.9 21.9 6.3 22.5 6.5 22.7 6.1 19.9 7 20.1 6.8 20.8 6.8 22.3 5.9 22.7 6.3 22 6.6 22.4 6.4 23.1 6.5 23 6.6 19.9 7.1 20.3 6.6 20.9 7 21.9 6.8 22.7 6.7 240 280 340 320 300 250 •300 300 250 300 150 240 190 200 300 340 390 390 350 320 410 330 480 590 570 680 580 320 <10 420 590 370 720 700 670 560 680 790 860 700 260 630 850 340 620 360 320 550 660 800 Page 1 NC0006190 Delta Apparel Date 8/2/2007 8/7/2007 8/8/2007 8/9/2007 8/14/2007 8/15/2007 8/16/2007 8/21/2007 8/22/2007 8/23/2007 8/28/2007 8/29/2007 8/30/2007 9/4/2007 9/5/2007 9/6/2007 9/11/2007 9/12/2007 9/13/2007 9/18/2007 9/19/2007 9/20/2007 9/25/2007 9/26/2007 9/27/2007 10/4/2007 10/11/2007 10/18/2007 10/25/2007 11/1/2007 11/8/2007 11/15/2007 11 /21 /2007 11/29/2007 12/6/2007 12/13/2007 12/20/2007 12/27/2007 1/3/2008 1/10/2008 1/17/2008 1/24/2008 1 /31 /2008 2/7/2014 2/14/2008 2/21/2008 2/28/2008 3/6/2008 3/13/2008 3/20/2008 3/27/2008 Temp. (°C) 22.6 24 24.2 24.5 22.9 21.9 23 23.7 23.2 23.6 22.3 22.8 23.1 21 20.1 20.8 22.4 21.9 21.4 16.1 15.6 18.8 20.3 19.2 18 20.1 16 18.1 18.3 11.3 5 13.5 9 4.8 4.3 10.7 2.9 6.9 0 10.2 4.5 6.1 3.2 9 4.4 5.2 2.3 8.6 7.4 11.6 10.1 Upstream D.O. Conductivity (mg/L) (umhos/cm) 6.9 230 7.2 246 7.2 267 7.1 274 7.1 143 7.3 296 7.1 318 6.9 251 6.7 362 6.6 141 7.2 207 7.3 252 7.1 213 7.4 285 7.7 288 7.6 292 7.3 270 7.2 274 7.4 286 8.6 237 8.8 226 8.1 252 7.7 305 8 302 8.1 315 7.5 311 8.2 326 7.9 536 8 117 9.7 265 11.4 264 9.2 243 10.2 262 11.7 259 11.9 267 10 187 12.2 249 11.2 134 16.2 11.9 14 13.1 12 11 13 10.2 12.5 11.3 10.5 9.3 9.8 172 232 262 220 252 222 142 189 171 137 190 144 186 Downstream Temp. D.O. Conductivity (°C) (mg/L) (umhos/cm) 22.2 6.6. 24.4 6.5 24.5 6.5 24.7 6.5 .22.7 6.2 22 6 23.3 5.6 23.9 5.8 23.5 5:8 24 6.3 22.8 6.7 23.1 6.5 23.4 6.7 21.1 7.1 20.2 6.7 21.1 6.9 22.4 6.4 22.2 6.1 21.6 6.3 16.5 8.5 16.2 8.7 19 7.9 7.8 7 19.3 7.7 18.5 7.7 20.7 6.9 16.1 7.5 18.3 7.3 18 8 11.5 9.3 5.7 10.9 13.6 9 9.9 9.5 5.8 11.2 5 11.5 11.6 9 3.3 12 7 10.9 0.2 10.4 5.2 6.2 3.8 9.7 4.5 7.1 4.1 8.7 7.8 11.5 10.3 15.3 11.7 13.6 12.7 9.6 10.3 11.6 10.1 12 10 9.9 9.2 9.6 • 880 899 1050 802 918 806 991 1170 931 482 896 1020 639 960 1010 1140 1130 1180 1010 701 815 807 1170 1170 1160 1370 1060 1260 305 819 762 410 789 856 912 636 790 160 617 800 733 752 851 504 404 618 570 395 498 254 173 Page 2 NC0006190 Delta Apparel Upstream Downstream Temp. D.O. Conductivity Temp. D.O. Conductivity Date (°C) (mg/L) .(umhos/cm) (°C) (mg/L) (umhos/cm) • 4/3/2008 13.1 9.2 193 13.4 8.9' 589 4/10/2008 12.1 9.4 134 13 8.6 336 4/17/2008 9.5 10.2 167 10.6 9 453 4/24/2008 13.6 8.5 187 14.4 7.9 477 5/1/2008 12 9 175 12.4 8.8 459 5/8/2008 17.8 8.1 215 18.4 7.2 568 5/15/2008 16.2 8 227 16.7 7.1 614 5/22/2008 14 8.6 250 15.4 7.4. 553 5/29/2008 16.1 7.8 135 16.7 7-.3 311 6/3/2008 19.7 7.1 337 20.4 5.5 528 6/4/2008 21.1 6.8 261 21.8 4.3 468 6/5/2008 21.4 6.7 319 22.5 4.8 483 6/10/2008 22.4 6.4 349 23 4.1 816 6/11/2008 22 6.6 298 23 4.9 689 6/12/2008 21.8 6.5 325 22.6 4.8 633 6/17/2008 22 6.5 708 22.2 4.7 279 6/18/2008 18.7 7 349 19.3 5 685 6/19/2008 19.2 7 350 19.5 5.4 662 6/24/2008 19.8 6.9 231 20.8 5.7 434 6/25/2008 20.1 6.9 266 20.8 5.4 523 6/26/2008 20.3 6.7 283 21.2 5 625 6/30/2008 21.8 6.7 193 22.3 6 388 7/ 1 /2008 18.8 7.2 237 19.5 6 520 7/2/2008 18.2 7 226 19 6.2 571 7/8/2008 21.4 6.8 244 22.2 6 345 7/9/2008 21.4 6.6 127 22 6.1 210 7/10/2008 21.7 6.6 150 22.3 6.3 187 7/15/2008 21 7 243 22 6.3 419 7/16/2008 20.4 7.1 174 21.5 6.2 543 7/17/2008 20.3 7.3 240 21.5 6.2 552 7/22/2008 22.3 6.6 449 23.3 5.1 988 7/23/2008 21.7 6.3 257 22.8 6 424 7/24/2008 21.4 6.6 258 21.7 6.2 453 7/29/2008 22.5 6.5 189 23.4 5.9 768 7/30/2008 22.8 6.4 209 23.7 5.6 644 7/31/2008 23.2 6.4 113 24.1 5.9 410 8/5/2008 22.6 6.5 254 23.5 5.8 811 8/6/2008 23.9 6.4 159 23.9 6.2 706 8/7/2008 23.3 6.4 494 23.6 5.8 1040 8/12/2008 19.8 6.8 427 19.7 6.2 1420 8/13/2008 20.3 6.3 263 20.4 6.1 380 8/14/2008 19.4 7.1 199 19.9 6.7 440 8/19/2008 20 6.9 10 20.5 6.5 165 8/20/2008 20.4 6.8 209 21.3 6.3 556 8/21/2008 20.9 6.9 250 21.7 6.4 619 8/26/2008 21 6.6 196 21.5 6.4 448 8/27/2008 21.6 6.2 49 21.9 5.7 54 8/28/2008 20.5 6.3 97 21.1 5 84 9/2/2008 20.4 7.1 182 21.1 6.8 414 9/3/2008 19.4 7.3 248 20.1 6.8 351 9/4/2008 19.2 7.4 170 19.8 7 383 Page 3 NC0006190 Delta Apparel Temp. Date (°C) 9/9/2008 21.6 ' 6.8 9/10/2008 21.4 6.8 9/11/2008 19.9 7.1 9/16/2008 20.1 7.1 9/17/2008 18.3 7.5 9/18/2008 17.4 7.7 9/23/2008 16.6 7.5 9/24/2008 15.6 7.9 9/25/2008 15.6 7.8 9/30/2008 18.5 7.4 10/1/2008 18.1 7.2 10/2/2008 14.6 7.9 10/9/2008 16.6 7.5 10/15/2008 15 7.8 10/16/2008 15 7.6 10/23/2008 9.2 9.1 10/30/2008 7.5 9.5 11/6/2008 12.6 7.6 11/13/2008 11.7 8.1 11/20/2008 4.5 10.6 11/26/2008 4.1 10.5 12/4/2008 4 11.1 12/11/2008 12 8.4 12/18/2008 11.1 9 12/24/2008 6.5 10.6 12/31/2008 8 9.7 Upstream • D.O. Conductivity (mg/L) (umhoslcm) 226 212 94 183 125 158 222 212 261 491 168 215 150 234 258 245 227 235 243 231 275 130 144 186 233 Downstream Temp. D.O. Conductivity (°C) (mg/L) (umhos/cm) 22.3 6.5 22.3 6.6 20.2 7.8 20.7 6.7 18.6 7.3 18 7.5 17.2 7.6 16.3 7.8 16.4 7.7 18.8 7.2 18.8 7.1 15.1 7.7 16.6 7.3 15 7.6 15.5 7.6 9.7 9.1 7.5 9.2 12.4 7.9 11 7.9 4 10.6 3.8 10.6 4 10.8 11.7 8.5 10.6 9 5.7 10.6 8.1 9.8 441 454 160 445 269 345 501 513 591 194 492 503 297 582 686 639 576 562 582 617 549 188 355 223 172 Page 4 tS fit, � ue �� a110 and 2008 Monthly'Aver.0ge,and Mi d, 1:.�`,TcriF •?fir':`: -. VS 4Month Mirn�`level:.' Pa 07 69.7 37.2 1.7 0.29 7.8 8.6 0 _" ;` 38.2 20 0.94 0.18 7.8 8.6 'March'- 37.5 12.3 1.3 0.23 7.4 7.9on 26.1 12.6 1.4 0.2 7.2 7.9 'Mayo 18.2 13.5 1.3 0.3 6.9 7.7 145 16 0.53 0.14 6.7 7 20.5 17.5 0.54 0.08 6.8 6.9 84.7 22 3 0.82 6.8 7.3 >Se28.5 17 0.82 0.27 7.1 7.4 37.5 16.3 1.1 0.2 7.5 8 107.1 15.8 0.41 0.12 8 8.4 De " 36.7 9.4 0.82 0.14 6.2 8.8 F an' 08 :a 79.8 29.6 10 1.83 7.4 9.6 57.2 18.1 0.46 0.17 5.8 8.2 arch 66 9.1 0.18 0.1 5.4 8 42.3 11.2 0.35 0.1 7 7.8 ell 19.6 16.9 0.33 0.1 6.8 7.2 Junea' 17.8 13.8 0.1 0.1 6.5 6.8 18.3 15 0.1 0.16 6.3 6.7 20.4 16.6 0.1 0.1 6.2 6.6 Se `' 62.6 16.8 0,13 0.1 6.3 6.7 t:-�;; G 27.9 16.2 0.1 0.1 6.5 7.2 30.1 15.4 0.1 0.14 7.2 7.7 32.4 14 0.17 0.1 7.1 8.5 :,$-mo avg ' ° , "mo avg ;'" Imo avg 5 McOtt j r`46 8375 16 7625 " 1 082 7. ,, 0:25291„� 6 8625tr,729, 67il BOD5 NH3-N D.O. ,.jmi timits_:-;_;- :162 lb/day mo. avg. 3.0 mg/L mo. avg. > 5.0m g/L REASONABLE POTENTIAL ANALYSIS Delta Apparel NC0006190 Time Period Ow (MGD) 7Q10S (cfs) 7Q10W (cfs) 3002 (cfs) 0 1.2 12 25.5 34 Avg. Stream Flow, QA (cfs) 78 RecWving Stream Clark Creek TABLE 3 • WWTP Class IV IWC (%) (a) 7Q10S 13.42 Q 7Q10W 6.7982 © 3002 5.1868 Q QA 2.3291 Stream Class C Outfall 001 Qw=1.2MGD PARAMETER TYPE (1) STANDARDS& CRITERIA (2) PQL Units REASONABLE POTENTIAL RESULTS RECOMMENDED ACTION NC WQS/ Y FAY1 Chronic Acute n 0 Del Mast Prod 61v AlfoanbIe Div Chromium NC 50 1.022 uglL 105 5 9.6 Acute: 1.022 _ _ _ _ _ _ _ __ Chronic: 373 No reasonable potential for_ a standard violation _ _ _ _ Chronic limit is more stringent then EGr L. ,New IWC% reduces Chromium limit to 373 ug/L. Copper NC 7 AL 7.3 uglL 105 105 180.9 Acute: 7 _ _ _ _ _ Chronic:- 52 Reasonable potential toexceedstandards.— ___ __- — — _ — No limit as this is an action level parameter. `Maintain monitoring. Chloride NC #tom# AL 250000 ?3O1 a es•o ug/L 9 9 Note: n<12 Limited data 3472000.0 set Acute: 250.000 _ _ _ _ _ _ Chronic: 1.713.871 _Reason_able potential to_ exceed_ standards._ _ _ _ _ _ No limit as this is an action level parameter. Maintain monitoring. Zinc NC 50 AL 67 . ug/L 49 49 256.0 Acute: 67 _ _ _ _ _ _ _ _ Chronic: 373 _Reason_able potential to_ exceed_ standards._ _ _ _ _ _ _ _ w No limit as this Is an action level parameter. Maintain monitoring. 'Legend: C = Carcinogenic NC = Non -carcinogenic A = Aesthetic •• Freshwater Discharge Table 2.xls, rpa 4/17/2009 e 4 5 Chromium Copper Date 1 2007 Month 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Month 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 2008 Month 55 56 Data BDL=1/2DL Results < 5 2.5 Std Dev. < 5 2.5 Mean < 5 2.5 C.V. < 5 2.5 n < 5 2.5 2 < 5 2.5 Mutt Factor 2 < 5 2.5 Max. Value 2 < 5 2.5 Max. Pred ( 2 < 5 2.5 3 < 5 2.5 3 < 5 2.5 3 < 5 2.5 3 < 5 2.5 4 < 5 2.5 4 < 5 2.5 4 < 5 2.5 4 < 5 2.5 5 < 5 2.5 s < 5 2.5 s < 5 2.5 s < 5 2.5 5 5 5.1 6 < 5 2.5 6 < 5 2.5 6 < 5 2.5 6 < 5 2.5 7 < 5 2.5 7 < 5 2.5 7 < 5 2.5 7 < 5 2.5 8 < 5 2.5 8 < 5 2.5 8 < 5 2.5 8 < 5 2.5 8 < 5 2.5 s < 5 2.5 s < 5 2.5 < 5 2.5 s < 5 2.5 10 < 5 2.5 10 < 5 2.5 io 8 7.8 10 < 5 2.5 10 < 5 2.5 11 8 7.9 „< 5 2.5 „ < 5 2.5 „ < 5 2.5 12 < 5 2.5 12 < 5 2.5 12 < 5 2.5 12;..' . 12 < 5 2.5 1 < 5 2.5 1 < 5 2.5 1 < 5 2.5 0.8983 2.6724 0.3362 105 1.2200 7.9 ug/L 9.6 ug/L 9 � 25 10 � . 33 11 321 12 3 : s 24 13 3:. : 33 14 4 ` 26 15 4 21 16 4 J 15 17 4-``". 14 18 5 21 19 5 22 20 5 19 21 5 21 22 5.._',:: 25 23 6 24 24 6 24 25 6 .. 24 26 6 31 27 7 36 28 7 31 29 7 22 30 7 36 31 8 -35 32 8 40.6 33 8 33.7 34 8 • 46.6 35 8 39 36 9 47 37 9 39.9 38 9 ::;'::";' 56.5 39 9 :'' ,-.: 40.6 40 10 ,`_ 42.4 41 10 ' . iw; 30.2 42 10 31.5 43 10 64.3 44 10„?''' 47.9 45 11 '•`:'•;'r- 53.1 46 11 42.3 47 1146.8 48 11 'x• 46 49 12 .. 47.7 50 12 t"'< 43.9 51 12 37.9 52 53 12;1 .;�4 50.3 54 2008 n 6r tt ) 50.5 55 11- 81.4 56 1"Y; 115 Date Data 1 2007 month'` 2 1 3 1 :4 4 1 5 1 6 2 7 2`t" 8 2 2''>=Y: BDL=1/2DL Results 43 43:0 Std Dev. 25.7934 36 36.0 Mean 50.6057 43 43.0 C.V. 0.5097 34 34.0 n 105 18 18.0 20 20.0 Mult Factor 1.3400 22 22.0 Max. Value 135.0 ug/L 22 22.0 Max. Pred 180.9 ug/L 25.0 33.0 21.0 24.0 33.0 26.0 21.0 15.0 14.0 21.0 22.0 19.0 21.0 25.0 24.0 24.0 24.0 31.0 36.0 31.0 22.0 36.0 35.0 40.6 33.7 46.6 39.0 47.0 39.9 56.5 40.6 42.4 30.2 31.5 64.3 47.9 53.1 42.3 46.8 46.0 47.7 43.9 37.9 50.3 50.5 81.4 115.0 57 1 < 5 2.5 58 1 < 5 2.5 59 2 < 5 2.5 60 2 < 5 2.5 61 2 < 5 2.5 62 2 < 5 2.5 63 3 < 5 2.5 64 3 < 5 2.5 65 3 < 5 2.5 66 3 < 5 2.5 67 4 < 5 2.5 68 4 < 5 2.5 69 4 < 5 2.5 70 4 < 5 2.5 71 4 < 5 2.5 72 5 < 5 2.5 73 5 < 5 2.5 74 5 < 5 2.5 75 5 < 5 2.5 76 6 < 5 2.5 77 6 < 5 2.5 78 6 < 5 2.5 79 6 < 5 2.5 80 7 < 5 2.5 81 7 < 5 2.5 82 7 < 5 2.5 83 7 < 5 2.5 84 7 < 5 2.5 85 8 < 5 2.5 86 a < 5 2.5 87 8 < 5 2.5 88 8 < 5 2.5 89 9 < 5 2.5 90 9 < 5 2.5 91 9 < 5 2.5 92 9 < 5 2.5 93 10 7 7.3 94 10 < 5 2.5 95 io < 5 2.5 96 10 < 5 2.5 97 10 < 5 2.5 98 11 < 5 2.5 99 11 < 5 2.5 ## 11 < 5 2.5 ## 11< 5 2.5 ## 12< 5 2.5 12< 5 2.5 ## 12 < 5 2.5 12 < 5 2.5 ## 12 < 5 2.5 57 117 117.0 58 1 44 129 129.0 59 2 ,}.=;- + 75.9 75.9 60 2 58.6 58.6 61 2 4' 70.6 70.6 62 2' a 121 121.0 63 3 � , 135 135.0 64 3 81.8 81.8 65 3 79.4 79.4 66 3 62.4 62.4 67 471.8 71.8 68 4 .AA 55.5 55.5 69 4 - 53.3 53.3 70 4 62.4 62.4 71 4=` ?� 69 69.0 72 5 < 75.7 75.7 73 5 ,,;;y; 67 67.0 74 5 f: 53 53.0 75 5;_'i34.9 34.9 76 6 . t 43.4 43.4 77 6 3 48 48.0 78 6 50.9 50.9 79 6;;';:r!.;;: 43 43.0 80 7 43 43.0 81 7 r`r-; 47.5 47.5 82 7 /�,. 78 78.0 83 7 <;, • 106 106.0 84 7 `' 108 108.0 85 8 ' ' 85.1 85.1 86 8 1Lr: 81 81.0 87 8 57.8 57.8 88 8'"` '" 51 51.0 89 9 ''_ 70 70.0 90 9 ,, 61 61.0 91 9 65.6 65.6 92 9x:':< 66 66.0 93 10 81 81.0 94 10 is=: 64.2 64.2 95 10 t,;. .:'., _- 51 51.0 96 10 ; :'„:: 80.9 80.9 97 10 7 45 45.0 98 11 '"''` 42.4 42.4 99 11 48 48.0 100 11 y :x= -1: 41.9 41.9 101 11 ; 46 46.0 102 12 '; 55.9 55.9 103 12 60 60.0 104 12 60.6 60.6 105 12 50 50.0 106 12. 12 12.0 Chloride 15 Zinc Date Data Mar-2007 1400000 Jun.2007 1400000 Oct. 2007 1400000 Dec. 2007 1810000 Mar. 2008 2240000 Jun.2008 1130000 Sept. 2008 1800000 1550000 Dec. 2008 1,980,000 BDL=1/2DL Results 1400000.0 Std Dev. 348357.2560 1400000.0 Mean 1634444.4444 1400000.0 C.V. 0.2131 1810000.0 n 9 2240000.0 1130000.0 Mult Factor 1800000.0 Max. Value 1550000.0 Max. Pred 1980000.0 1.5500 2240000.0 ug/L 3472000.0 ug/L Date Data 1 Month • 1 2 2007 1 3 2 4 2 5 3 6 3 7 4 8 4 9 5 10 5 11 6 12 6 13 7 14 7 15 8 16 8 17 9 18 9 19 10 20 10 21 11 22 11 23 12 24 12 25 Month 1 26 2008 1 27 2 28 2 29 3 30 3 31 4 32 4 33 5 34 5 35 6 36 6 37 7 38 7 39 7 40 8 41 8 42 9 BDL=1/2DL Results 72 72.0 Std Dev. 64 64.0 Mean 62 62.0 C.V. 61 61.0 n 85 85.0 72 72.0 Mult Factor 57 57.0 Max. Value 50 50.0 Max. Pred 70 70.0 84 84.0 100 100.0 76 76.0 • 140 140.0 68 68.0 105 105.0 97 97.0 64 64.0 83.3 83.3 92.2 92.2 66 66.0 80.1 80.1 125 125.0 90.2 90.2 91.2 91.2 144 144.0 179 179.0 154 154.0 118 118.0 176 176.0 130 130.0 118 118.0 109 109.0 69.2 69.2 66.3 66.3 52.6 52.6 63.6 63.6 46 46.0 59 59.0 91.8 91.8 71.3 71.3 64.9 64.9 60 60.0 32.0186 85.9714 0.3724 49 1.4300 179.0 ug/L 256.0 ug/L 43 9 53.8 53.8 44 10 59 59.0 45 10 85.5 85.5 46 11 67.4 67.4 47 11 65.7 65.7 48 12 88 88.0 49 12 65.5 65.5 TABLE 4 TEXTILE EFFLUENT LIMITS SPREADSHEET PERMIT NO: NC0006190 PERMITTEE: Delta Apparel, Inc. COUNTY: Catawba County PERMITTED FLOW: PRODUCTION DATA: Ibs/day 1 MGD DAILY MAX. 104510 MONTHLY AVG. 104510 FROM 40CFR 410 SUBPART E (all limits in Ibs/1000 Ibs) paggityllateTat BOD5 COD TSS Sulfide Phenol Total Chromium pH DAIL s ;a: .. "° ONT1ILLY AVE AGEr? 5 2.5 60 30 21.8 10.9 0.2 0.1 0.1 0.05 0.1 0.05 must be between 6 and 9 at all times LIMITS POI�IIFANT� r.: BOD5 COD TSS Sulfide Phenol Total Chromium pH DAiLYVM v ,��-MONTHLY AVERAGE *>�;. 522.6 261.3 6270.6 2278.3 20.9 10.5 10.5 must be between 6 and 9 at all times 3135.3 1139.2 10.5 5.2 5.2 BASED ON 40CFR410 SUBPART E KNIT Fabric FINISHING SUBCATEGORY according to EPA recommendation REASONABLE POTENTIAL ANALYSIS Delta Apparel NC0006190 Time Period 0 Ow (MGD) 1.1 7Q10S (cfs) 12 7Q10W (cfs) 25.5 30Q2 (cfs) 34 Avg. Stream Flow, QA (cfs) 78 Reeving Stream Clark Creek Revised TABLE 3 6/8/2009 WWTP Class IV 1WC (%) @ 7Q10S 12.441 7Q10W 6.2672 @ 30Q2 4.7752 ® QA 2.1391 Stream Class C Outfall 001 Qw =1.1 MGD PARAMETER TYPE (1) STANDARDS & CRITERIA (2) , POL Units REASONABLE POTENTIAL RESULTS RECOMMENDED ACTION NC WQS/ $4 FAv/ Chronic Acute n # Det. Max prod cw AllowableCw Chromium NC 50 1,022 ug/L 105 5 9.6 Acute: 1,022 _ __ Chronic__ _ _ _ No reasonable_ potential fora standard violation _ _ _ _ _ _ _402 Chronic limit is more stringent then EGL. New IWC% reduces Chromium limit to 402 ug/L. Copper NC 7 AL 7.3 ug/L 105 105 180.9 Acute: 7 _ _ _ _ _ Chronic_ 56 _Reasonable potential to exceed standards. _ _ _ _ _ _ _ _ No limit as this is an action level parameter. Maintain monitoring. Chloride NC ####### AL 250000 ug/L 9 9 Note: n<12 Limited data 3472000.0 set Acute: 250,000 ^_ _ _ Chronic_ 1,8 8-,768 _limitReasonable potential to exceed standards. _ _ _ _ _ _ _ _ No as this is an'action level parameter. Maintain monitoring. Zinc NC 50 AL 67 ug/L 49 49 256.0 Acute: 67 _ _ _ _ _ Chronic_ _ _ _ 402 _Reasonable potential to exceed standards. _ _ _ _ _ _ _ _ No limit as this Is an action level parameter. Maintain monitoring. • Legend: C Carcinogenic NC = Non -carcinogenic A = Aesthetic Freshwater Discharge Table 3 rpa.xis, rpa 6/8/2009 Table 5. Delta Mills Effluent Color • ram. ;K M.° x 444'4 Jan. 07 E >ee 4 M . ° ° !'„ '.. monthly -"a; 162 4 Lei' ° ADNI. Feb. 07 98 Mar. 07 100 Apr. 07 143 May. 07 129 Jun. 07 188 July.07 219 Aug. 07 196 Sept. 07. 218 Oct. 07 158 Nov. 07 154 Dec.07 179 . Jan. 08 301 Feb. 08 269 Mar. 08 237 Apr. 08 315 May. 08 349 Jun. 08 279 July.08 354 Aug. 08 245 Sept. 08 327 Oct. 08 294 Nov. 08 235 Dec. 08 319 Mean 228 Hickory Daily Record Advertising Affidavit NC DENR/DWQ BUDGET OFFICE 1617 MAIL SERVICE CENTER RALEIGH, NC 27699 Account Number RECEIVEID North Carolina Community Newspapers PO Box 968 Hickory, NC 28603 APR 2 7 200c April 23, 2009 DENR - WATER QUALITY POINT SOURCE BRANCH Date Date Category Description Ad Number Ad Size 04/23/2009 Legal Notices PUBLIC NOTICE North Carolina Environmental Management Commission/NPOES Unit 1617 Mail Service Center Raleigh, NC 27699.1617 Notice of Intent to Issue a NPDES Wastewater Permit The North Carolina Environmental Management Commission proposes to issue a NPDES wastewa- ter discharge permit to the person(s) listed below. Written comments regarding the proposed permit will be accepted until 30 days after the publish date of this notice. The Director of the NC Division of Water Quality (DWQ) may hold a public hearing should there be a significant degree of public in- terest. Please mall comments and/or information requests to DWQ at the above address. Interested persons may visit the DWQ at 512 N. Salisbury Street. Raleigh, NC to review information on file. Additional Information on NPDES permits and this notice may be found on our website: www.ncwa- terquality.org, or by calling (919) 807.6304. Delta Apparel, Inc. requested modification of per- mit NC0006190 for the Maiden Plant in Catawba County; this permitted discharge is treated proc- ess wastewater to Clark Creek, Catawba River Ba- sin. PUBLISH: Apra 23, 2009 Public NOTICE North Carolina Environment 0001378615 Media General Operations, Inc. Publisher of Hickory Daily Record Catawba County 2 x 31 L Before the undersigned, a Notary Public of Catawba County, North Carolina, duly commissioned, qualified, and authorized by law to administer oaths, in said County and State; that he/she is authorized to make this affidavit and sworn statement; that the notice or other legal advertisement, a copy of which is attached hereto, was published in the Hickory Daily Record on the following dates: 04/23/2009 and that the said newspaper in which such notice, or legal advertisement was published, was a newspaper meeting, all the requirements and qualifications of Section 1-597 of the General Statutes of North Carolina. Ncwspaperreference: 0001378615 Sworn to and subscribed before me, this i24.414.a.(C N6tmy P4�blic My Commission expirAsLaw.2 �o 1 n! t THIS IS NOT A BILL. PLEASE PAY FROM INVOICE. THANK YOU DEL TA APPAREL, INCORPORATED NCDENR NPDES - West ATTN: Ms. Julie Grzyb 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Subject: Delta Apparel, Inc. Draft NPDES Permit No. NC0006190 Dear Ms. Grzyb: Delta Apparel, Inc. requests that the monthly average flow limit in our draft NPDES permit be reduced from 1.2 MGD to 1.1 MGD prior issuance of the final permit. We understand that this reduction will also reduce our chronic toxicity limit from 13% to 12% as a consequence of the flow limit reduction. Our purpose in requesting this reduction is to provide a greater certainty that our effluent's chronic toxicity will remain compliant. Please let us know if any other information is required to accomplish the above changes to our draft NPDES Permit. We appreciate your cooperation and understanding on this matter. Sincerely, Steve Slaughter Plant Manager RECEIVED ,11 "j - 1 DENR - WATER QUALITY POINT SOURCE BRANCH 100 W. Pine Street • P.O. Box 37 • Maiden, N.C. 28650 • (828) 428-9921 • FAX (828) 428-8307 Change your shirt.. rv`a.rJ&c a Qtr� e.:. -7-1Ads mo% (351 .01 11 5-4 Om EPA has no comments on this draft permit. Page 1 of 1 https://mail.nc.gov/owa/?ae=Item&a=Preview&t=IPM.Note&id=RgAA.AADL%2f mPMH... 5/5/2009 RE: Delta Apparel draft permit Page 1 of 1 RE: Delta Apparel draft permit Grzyb, Julie Sent: Tuesday, May 05, 2009 12:10 PM To: Parker, Michael [michael.parker@ncdenr.gov] Mike, Thanks for your comments. The toxicity test is likely to be the problem given the new IWC of 13% and their current WET test results consistently having a chronic value of 15.6%. I have discussed this with the consultant and noted it to the plant director as well. I will put you comment in the final cover letter with the permit when issued if Tom thinks it is appropriate. Julie From: Parker, Michael [michael.parker@ncdenr.gov] Sent: Tuesday, May 05, 2009 8:51 AM To: Julie Grzyb Subject: RE: Delta Apparel draft permit All in all I believe Delta will be able to consistently comply with the effluent limitations contained in the new permit, however, they also need to be aware that should consistent noncompliance result upon their move up to 1.2 MGD, a compliance schedule, either in the permit or an SOC may need to be considered. Mike Original Message From: Julie Grzyb [mailto:Julie.Grzyb@ncmail.net] Sent: Friday, April 17, 2009 6:22 PM To: Michael Parker Subject: Delta Apparel draft permit Mike, Attached is Delta Apparels DRAFT permit per their modification request. Please review and let me know what you think. I am trying to get this public noticed on Wed., so it has to be turned in by 5 on Tues. If you have a chance to look at it by than it would be great but if you need more time please let me know. Also, the last item attached is their consultant's response to some additional questions. Thought you might find it interesting. Julie Grzyb Environmental Engineer NPDES West/ DWQ N.C. Dept. of Environment and Natural Resources 1617 Mail Service Center, Raleigh, NC 27699-1617 (919) 807-6389; fax (919) 807-6495 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. https://mail.nc.gov/owa/?ae=Item&t=IPM.Note&id=RgAAAADL%2 miPMHLaQqW1cuaw... 5/5/2009 Wednesday, January 14, 2009 11:09 AM BB HOBBS Q m Q CD COMPANY P.O. Box 437 Darlington, SC 29540 Phone: (843) 395-2120 Fax: (843)393-3595 Email: irrigate@bbhobbs.com Attn: Sarah Menser Subject: Approval Design Letter This letter is written confirmation that S&EC has successfully designed Advantex Treatment System in accordance with State requirements and Orenco, Inc. manufacturer of the Advantex Treatment System. This letter is in reference to the below site and project. Address: AL-AAWAR PROPERTY Louisburg Road Wake County, NC This letter is issued by BB Hobbs Co., Advantex Dealer for North Carolina, South Carolina and Georgia. Todd Harrell BB Hobbs Co. 1340 Harry Byrd Hwy. Darlington, SC 29532 843-395-2120 Office 843-307-2090 Ce11 1340 Harry Byrd Highway — Darlington, SC 29532 Unfiled Notes Page 1 Catawba River Basin Subbasin 03-08-34 Assessment Waterbody and Description Unit (AU) Class Subbasin impaired Year Use Listed Category and Reason for Listing Potential Source(s) Miles or Acres Sugar Creek 11-137a C 03-08-34 6 0.3 FW Miles From source to below WWTP, SR 1156, Mecklenburg Sugar Creek AL 1998 6 Impaired biological integrity 11-137b C 03-08-34 6 Municipal Point Sources Urban Runoff/Storm Sewers Urban Runoff/Storm Sewers 10.9 FW Miles From SR 1156 Mecklenburg to Hwy 51 Sugar Creek 11-137c C AL 1998 6 Impaired biological integrity O 1998 4a Standard violation: Turbidity O 1998 4a Standard violation: Fecal Coliform 03-08-34 6 Urban Runoff/Storm Sewers 2.5 FW Miles From Hwy 51 NC/SC border Catawba River Basin AL 2000 6 Impaired biological integrity O 2000 4a Standard violation: Turbidity O 2000 4a Standard violation: Fecal Coliform Urban Runoff/Storm Sewers Subbasin 03-08-35 Clark Creek 11-129-5-(9.5) WS-IV 03-08-35 6 1.8 FW Miles From a point 0.9 mile upstream of Walker Creek to South Fork Catawba R. O 1998 4a Standard violation: Fecal Coliform Industrial Point Sources AL 2006 6 Impaired biological integrity Urban Runoff/Storm Sewers Industrial Point Sources Clark Creek (Shooks Lake) 11-129-5-(0.3)b C 03-08-35 6 16.6 FW Miles From Miller Branch to 0.9 mile upstream of Walker Creek Henry Fork AL 1998 6 Impaired biological integrity 11-129-1-(12.5)a C 03-08-35 6 Intentional Channelization Urban Runoff/Storm Sewers Industrial Point Sources Agriculture Industrial Point Sources 10.3 FW Milos From Laurel Creek to State Route 1124 AL 2006 6 Impaired biological integrity North Carolina 303(d) List- 2006 Tuesday, June 19, 2007 Catawba Basin 03-08-35 Page 35 of 125 DEL TA APPAREL, INCORPORATED 4/14/09 Mrs. Grzyb, Enclosed is the hard copy of the corrected page 2 of 4 for the requested increase of effluent permit for Delta Apparel Dyeing and Finishing plant in Maiden N.C. if you have any questions please contact me by email or by the below numbers. Kind regards, Steve L. Slaughter Plant Manager Delta Apparel, Inc. Office (828) 428-9921 ext.239 Ce11 (704) 780-2235 RECEIVED APR 1 7 2009 DENR - WATER QUALITY POINT SOURCE BRANCH 100 W. Pine Street • P.O. Box 37 • Maiden, N.C. 28650 • (828) 428-9921 • FAX (828) 428-8307 Change your shirt. CONTINUED FROM THE FRONT C. Except for storm runoff, leaks, or spills, are any of the discharges described in ❑ YES (compkte the following table) Items II -A or B intermittent or seasonal? II!) , ter C� NO (go to Section 1. OUTFALL NUMBER (list) 2. OPERATION(s) CONTRIBUTING FLOW ((br) 3 FREQUENCY 4 FLOW a DAYS PER WEEK (spcofy a tag') b. MONTHS PER YEAR (epeclJyawr gel a FLOW RATE (m mxnI) 8 TOTAL VOLUME (.pmchr Karr iuun) C. DURATION (in'!"I'"I 1, LONG TERM AVERAGE 2. MAXIMUM DAILY 1. LONG TERM AVERAGE 2. MAXIMUM DAILY III. PRODUCTION guideline (imitation promulgated by EPA under Section YES (complete Item !ll-B) 304 of the ❑ Clean Water NO (go to Section Act apply to your !F) facility? A. Does an effluent 1511 B. Are the limitations in the applicable effluent guideline expressed in terms of production (or other measure of operalion)? YES (complete Item I!!-(.) ❑ NO (go to Section IV) CI C. If you answered 'yes' to Item III-B. list the quantity which represents an actual measurement of your level of production, expressed in the terms and units used in the applicable effluent guideline, and indicate the affected outfalls. 1. AVERAGE DAILY PRODUCTION 2. AFFECTED OUTFALLS (b.ctouttit!!numbers) a QUANTITY PER DAY b. UNITS OF MEASURE c. OPERATION, PRODUCT, MATERIAL, ETC. (sPecil,) ACTUAL 2008 PRODUCTION: 82.25 PLANNED PRODUCTION: 114.3 IV. IMPROVEMENTS A. Are you now required treatment equipment or permit conditions. administrative ❑ YES (complete 1,000 pounds cloth 1,000 pounds cloth by any Federal, State or local practices or any other environmental or enforcement orders, the.lollowmg table) Dyeing and Bleaching Dyeing and Bleaching authority to meet any implementation schedule for the construction, programs which may affect the discharges described in this application? enforcement compiiance schedule letters, stipulations, court orders. and FA NO (go to hem f('-H) 001 001 upgrading or operations of wastewater This includes, but is not limited to. grant or loan conditions. 1. IDENTIFICATION OF CONDITION. AGREEMENT, ETC. 2. AFFECTED OUTFALLS 3. BRIEF DESCRIPTION OF PROJECT 4. FINAL COMPLIANCE DATE a. NO b. SOURCE OF DISCHARGE a REQUIRED b. PROJECTED B. OPTIONAL: You may attach additional sheets describing any additional water pollution control programs (or other environmental projects which may affect your discharges) you now have underway or which you plan. Indicate whether each program is now underway or planned, and indicate yolg actual or planned schedules for construction. ❑ MARK "X' IF DESCRIPTION OF ADDITIONAL CONTROL PROGRAMS IS ATTACHED EPA Form 3510-2C (8-90) PAGE 2of4 CONTINUE ON PAGE 3 RE: Delta Apparel permit modification request Subject: RE: Delta Apparel permit modification request From: "Moore, Cindy" <cindy.a.moore@ncdenr.gov> Date: Mon, 13 Apr 2009 09:34:49 -0400 To: "julie.grzyb@ncmail.net" <julie.grzyb@ncmail.net>, James Mckay <James.McKay@ncmail.net>, Charles Weaver <Charles.Weaver@ncmail.net>, Gil Vinzani <Gi1.Vinzani@ncmail.net>, Tom Belnick <Tom.Belnick@ncmail.net>, "ron.berry@ncmail.net" <ron.berry@ncmail.net>, "sergei.chernikov@ncmail.net" <sergei.chernikov@ncmail.net>, "bob.guerra@ncmail.net" <bob.guerra@ncmail.net>, "jackie.nowell@ncmail.net" <jackie.nowell@ncmail.net>, "bob.sledge@ncmail.net" <bob.sledge@ncmail.net>, "maureen.scardina@ncmail.net" <maureen.scardina@ncmail.net>, "karen.rust@ncmail.net" <karen.rust@ncmail.net>, "vanessa.manuel@ncmail.net" <vanessa.manuel@ncmail.net>, "joe.corporon@ncmail.net" <joe.corporon@ncmail.net>, "ron.berry@ncmail.net" <ron.berry@ncmail.net> CC: "Meadows, Susan" <susan.meadows@ncdenr.gov> We have had a couple of questions about tox info for permits. I have included a couple of references. Attached is a memo (August 2, 1999) that explains our tox strategy for DWQ. This memo explains our policy for rounding the IWC % to a whole number. If the IWC was 13.4, then the Effluent concentration that is listed in the NPDES permit should be 13%. We then could recommend the following concentrations if they are asked to perform a Phase II test: 3.25%,6.5%,13%, 26% & 52% . In determining effluent dilutions, here is our Phase II document that explains how to determine %. http://h2o.enr.state.nc.us/esb/ATUwww/NC%2ODWQ%20Procedures/P-IIMethod 2-98.pdf At least two of the effluent test treatments must be of a lesser effluent concentration than the IWC, with one being one-half the concentration of the IWC. No concentration should be greater than two times that of the next lower concentration or less than one half of the next higher concentration. The following are possible test concentrations for a facility with an IWC of 45%: 22.5%t 35.0%t 45.0%t 70.0% 90.0% tlndicates required concentrations for this example, i.e. IWC and two lower concentrations If you have any further questions, please let me know. Cindy Original Message From: Meadows, Susan Sent: Wednesday, April 08, 2009 2:02 PM To: Moore, Cindy Subject: FW: Delta Apparel permit modification request Original Message From: Julie Grzyb [mailto:Julie.Grzyb@ncmail.net] Sent: Wednesday, April 08, 2009 1:59 PM To: Susan.Meadows@ncmail.net; Tom Belnick Subject: Delta Apparel permit modification request 1 of 2 4/13/2009 9:59 AM RE: Delta Apparel permit modification request Susan, I am the new engineer in the NPDES West group. I am working on a major permit modification for Delta Apparel - Maiden Plant (NC0006190) in Catawba County who is proposing to increase flow from 1.0 MGD to 1.2 MGD. Currently their IWC is 11 % with the increase it will be 13.4 % discharging to Clark Creek. The facility's current Chronic Toxicity Permit Limit requires the Phase II test procedure at the following effluent concentrations: 44%, 22%, 11%, 5.5% and 2.75%. Given the change in the IWC could you please evaluate this discharge and propose new effluent concentrations to put in the permit modification. I was given your name by Charles Weaver, if you do not handle this could you please pass this on to the appropriate person. Some general information: Most of Clark Creek is considered impaired. The subject stream segment is C Class, impaired in the 2006 303(d) list as biologically impaired due to unknown causes. Sub basin is 030835 and Clark Creek has a summer 7Q10 of 12 cfs. Delta has been passing their WET tests at a chronic value of 15.6% during the last several years. Existing permit limitations are expected to remain the same in the modified permit. If you have any questions or would like to discuss this facility in more detail, please call me at 919-807-6389 or email me back. Thanks, Julie Julie Grzyb Environmental Engineer NPDES West/ DWQ N.C. Dept. of Environment and Natural Resources 1617 Mail Service Center, Raleigh, NC 27699-1617 (919) 807-6389; fax (919) 807-6495 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. Content -Description: NC WET Strategy-8-99.pdf NC WET Strategy-8-99.pdf Content -Type: application/pdf Content -Encoding: base64 2 of 2 4/13/2009 9:59 AM Phonels Sulfides monthly avg. lb/day daily max. lb/day monthly avg. lb/day daily max. lb/day Jan. 07 <0.06 0.29 <0.31 <0.43 Feb. 07 <0.06 <0.08 <0.32 <0.39 Mar. 07 <0.07 0.14 <0.34 <0.38 Apr. 07 <0.08 <0.09 <0.39 <0.46 May. 07 <0.07 <0.09 <0.35 0.66 Jun. 07 <0.10 0.18 <0.42 <0.49 JuI.07 <0.09 0.38 <0.45 <0.49 Aug. 07 <0.09 0.33 <0.44 <0.50 Sept. 07 <0.09 <0.10 <0.43 <0.49 Oct. 07 <0.08 <0.10 <0.41 <0.51 Nov. 07 0.11 <0.95 <0.39 <0.51 Dec. 07 <0.07 <0.1 <0.36 <0.48 Jan. 08 0.09 0.1 <0.45 <0.48 Feb. 08 0.09 <0.10 <0.43 <0.50 Mar. 08 <0.01 <0.10 <0.03 <0.51 Apr. 08 <0.09 <0.09 <0.44 <0.45 May. 08 <0.09 <0.09 <0.45 <0.47 Jun. 08 0.07 <0.09 <0.34 <0.44 JuI.08 <0.08 0.13 <0.79 <0.91 Aug. 08 <0.08 0.1 <0.83 <1.02 Sept. 08 <0.08 <0.10 <0.85 <0.98 Oct. 08 <0.09 <0.10 <0.94 <1.00 Nov. 08 <0.08 0.13 <0.77 <0.91 Dec. 08 0.02 0.1 <0.03 <0.83 Possible Max 0.11 0.95 0.94 1.02 Limits 4.0Ib/d 8.0Ib/d 8.0Ib/d 16.0Ib/d IWC Calculations Facility: DELTA APPAREL NC0006190 Prepared By: Julie Grzyb Enter Design Flow (MGD): 1.2 Enter s7Q10 (cfs): 12 Enter w7Q10 (cfs): 25.5 Total Residual Chlorine (TRC) Daily Maximum Limit (ug/l) s7Q10 (CFS) DESIGN FLOW (MGD) DESIGN FLOW (CFS) STREAM STD (UG/L) Upstream Bkgd (ug/I) IWC (%) Allowable Conc. (ug/I) Fecal Coliform Monthly Average Limit: (If DF >331; Monitor) (If DF<331; Limit) Dilution Factor (DF) 12 1.2 1.86 17.0 0 13.42 127 Ammonia (Summer) Monthly Average Limit (mg NH3-N/I) s7Q10 (CFS) DESIGN FLOW (MGD) DESIGN FLOW (CFS) STREAM STD (MG/L) Upstream Bkgd (mg/I) IWC (%) Allowable Conc. (mg/I) Ammonia (Winter) Monthly Average Limit (mg NH3-N/I) w7Q10 (CFS) 200/100m1 DESIGN FLOW (MGD) DESIGN FLOW (CFS) STREAM STD (MG/L) 7.45 Upstream Bkgd (mg/l) IWC (%) Allowable Conc. (mg/l) Total Residual Chlorine 1. Cap Daily Max limit at 28 ug/I to protect for acute toxicity Ammonia (as NH3-N) 1. If Allowable Conc > 35 mg/I, Monitor Only 2. Monthly Avg limit x 3 = Weekly Avg limit (Municipals); capped at 35 mg/I 3. Monthly Avg limit x 5 = Daily Max limit (Non-Munis); capped at 35 mg/I 4. BAT for Minor Domestics: 2 mg/I (summer) and 4 mg/I (winter) 5. BAT for Major Municipals: 1 mg/I (year-round) 12 1.2 1.86 1.0 0.22 13.42 6.0 25.5 1.2 1.86 1.8 0.22 6.80 23.5 Fecal Coliform 1. Monthly Avg limit x 2 = 400/100 ml = Weekly Avg limit (Municipals) = Daily Max limit (Non -Muni) NPDES Server/Current Versions/WLA; TB 1/16/2009 April 9, 2009 Dear Mr. Steve Slaughter, To complete my review on Delta's permit modification request a few items need to be addressed. 1) Mr. Slaughter please correct and resubmit page 2 of 4 answering Yes to questions A. and B. under the section, III. Production, since this facility is subject to 40 CFR 410 Subpart E, Knit Fabric Finishing. 2) Per my discussion with Mr. Blackwell, I am using the number 800,000 lbs/cloth/week to determine a maximum daily production rate of 114,300 lbs/day. The Effluent guidelines use daily maximum and 30 day average rates to determine limitations. Planned production rates expected from this modified flow should be discussed in these terms. These numbers can be addressed under section, III. Production, C. a. along with the other revisions. 3) Discuss the facility's wastewater treatment plant and its ability to maintain the same treatment level and meet current permit limits given the increased flow in more detail. The table on page 9 under section D. is helpful in indicating that the treatment system has handled the higher flow for at least one month, however; it is important to illustrate that the system can hydraulically handle 1.2 MGD on a consistent basis. Illustrate that the System can Handle 1.2 MGD Hydraulic Flow on a Consistent Basis As previously mentioned on page 9 of our initial submittal, the system has successfully treated an average monthly flow of 1.17 MG.D in November 2007, producing an average effluent quality for the month significantly below the permit's discharge limits for a 1.0 MGD flow. This monthly flow average was within 2.5 percent of the proposed flow limit of 1.2 MGD, and is therefore considered indicative of the system's performance at a 1.2 MGD flow level. During this month, there were twelve days with flows exceeding 1.2 MGD, including a daily flow of 1.3 MGD and five consecutive days with daily flows all above 1.2 MG. There was also an additional ten days during this month when the flow was between 1.17 and 1.2 MGD. Not mentioned in the application is the fact that this month (November 2007) was preceded by six consecutive months each with average monthly flows above 1.0 MGD, with the last four months prior averaging 1.13 MGD. Subsequent to November 2007, average monthly flows were again above 1 MGD for eight out of the next twelve months. During the month of September 2008, the plant experienced a ten-day period with daily flows averaging 1.21 MG. Since monthly average flows under the requested permit limit of 1.2 MGD will place an upper limit on the system's flow average, the above flows should closely approximate the flows expected and system performance under the limit requested. That is, approaching but not exceeding 1.2 MGD as a monthly flow average, as is the case described above. Aeration basin retention times for the currently permitted flow and for the proposed flow are shown below, and were calculated based on the flows shown and an overall basin (2 basins) volume of 2.42 MG. Plant Flow Limit 1.0 MGD 1.2 MGD Difference Retention Time (Days) 2.42 Days 2.02 Days - 0.4 Days Retention Time (Hrs) 58.1 Hours 48.5 Hours - 9.6 Hours Information about the clarifiers for these two flow rates is presented below, and is based upon the information contained in the previously submitted Wastewater Treatment Plant Schematic. Parameter 1.0 MGD Flow 1.2 MGD Flow Change Surface Loading Rate, gpd/sq. ft. 441 529 + 88 Retention Time, Hrs. 4.1 3.4 - 0.7 Weir Overflow Rate, gpd/lf 4,188 5,025 + 837 4) Can the necessary detention times for color removal be maintained? Can Necessary Detention Times for Color Removal be Maintained? Color removal is accomplished by polymer feeds into the outlet of the aeration basins as the flow leaves the basins going to the clarifiers. Currently, polymer (HyperFloc CP627) is fed at the rate of 88 gallons per basin per day, and is based on a total flow of 1.0 MGD. Polymer dosing tests are performed once per month by the polymer supplier's representative (Hychem, Inc. of Tampa, Florida). Color removal is evaluated based on a 10-minute retention time. Based on the above clarifier retention time (3.4 hours at 1.2 MGD), maintaining the necessary retention times for color removal at the higher flow limit is not expected to be a problem. 5) Will removal rates for other parameters decrease because of the increased flow? Will Removal Rates for Other Parameters Decrease because of Increased Flow? Since plant influent parameters are not monitored, it would be difficult to evaluate the effect of the increased flow on plant removal rates without that information. However, given the performance of the plant as described on page 9 of the submittal, slight decreases should not adversely impact compliance at the higher flow rate. A table of the information from page 9 of the submittal is presented below. Discharge Parameter Flow Permit Limit 1.0 MGD Actual Value 1.17 MGD % Below Permit Limit - BOD5 162 lbs 10.4 lbs 94 TSS 785 lbs 132.9 lbs 83 COD 29001bs 1173.6lbs 60 Color, ADMI 549 su 154 su 72 Chronic Toxicity >11% 15.6%* 42 * Based on values from September and December 2007 6) Will COD and chlorides increase? Will COD and Chlorides Increase? Based on a flow rate of 1.0 MGD, the total mass discharged would be expected to increase as the flow approaches 1.2 MGD. Concentrations of these parameters should remain relatively constant. However, plant performance near the 1.2 MGD limit still is 60 percent below the 1.0 MGD limit for COD. Extrapolation of the effluent chloride data for the months of June and September 2008 based on flow rate indicates that effluent chlorides at a flow of 1.2 MGD might be expected to be approximately 1,845 mg/l. This concentration is still within the currently expected range for this parameter. The September and June data are shown below. Month June 2008 September 2008 Extrapolation to 1.2 MGD Flow, MGD 0.96 1.143 1.2 Effluent Chloride Concentration, mg/1 1,130 1,675 1,845 Records indicate the original treatment system would eventually be designed to handle 1.5 MGD. This flow increase was never needed and the system has since been modified to handle color removal not just provide biological treatment as identified in your letter attached to June 2008's Discharge Monitoring Report. Given these changes what is the actual design capacity of this system (if known)? What is the actual design capacity of the system (if known)? The system is designed for 1.5 MGD 7) Delta Apparel should be aware that downstream D.O. sampling during the month of June 2008 showed State Water Quality Standards were violated on six occasions. When Catawba Basin permits come up for renewal in 2011 this segment of Clarks Creek may have to be re-evaluated in more detail. The next DWQ Public Notice period starts on April 22, 2009. If you are able to respond early next week I will try to issue the Draft Permit by that time. US EPA will review this draft Permit during the public notice period as well. Please call me at 919-807-6389 or email: julie.grzyb@ncmail.net if you have any questions. Julie Grzyb Environmental Engineer, NPDES West DWQ, Surface Water Protection CONTINUED FROM THE FRONT C. Except for storm ❑ runoff. leaks. or spills. arc any of the discharges described In Items II -A or B intermittent or seasonal? YES (umrpterc rhufai rm•rng rohle) El NO (go to Section I11) . 1. OUTFALL NUMBER (tiro 2. OPERATION(s) CONTRIBUTING FLOW ] 3 FREQUENCY 4 FLOW a. DAYS PER WEEK Iwo)" mvrb):) b. MONTHS PER YEAR (srxcrljrncrrrta) a FLOW RATE fur mW B TOTAL VOLUME (.gxriJy M ith wit.) C. DURATION 1"i1il-.) it. AVERAGE 2. MAXIMUM DAILY 1. LONG TERM AVERAGE 2. maximum DAILY I11. PRODUCTION A. Does an effluent tY l guideline (imitation promulgated by EPA under Section YES (camp/err /km III-B) 304 of the ❑ Clean Water NO (go to &cuorr Act apply to your IV) fadfity? B. Are the limitations in the applicable effluent guideline expressed in terms of production (or other measure of operation)? YES (complete Item 111.0 ❑ NO (go to Seettrm IV) Q C. It you answered -yes' to Item III-B. list the quantity which represents an actual measurement of your level of production. expressed in the terms and units used in the applicable effluent guideline, and indicate the affected outfalls. 1. AVERAGE DAILY PRODUCTION 2. AFFECTED OUTFALLS (list autjullnbmhers) a. QUANTITY PER DAY b. UNITS OF MEASURE c. OPERATION, PRODUCT. MATERIAL. ETC. (Nk rify) ACTUAL 2008 PRODUCTION: 62.25 PLANNED PRODUCTiOH! 114.3 IV. IMPROVEMENTS A. Are you now required treatment equipment or permit conditions. administrative ❑ YES (crimp/etc 1,000 pounds cloth 1,000 pounds cloth by any Federal. State or local practices or any other environmental or enforcement orders, theJollon•mg ruble) Dyeing and Bleaching Dyeing and Bleaching authority to meet any implementation schedule for the construction. programs which may alert the discharges described in this application? enforcement compliance schedule letters. stipulations. court orders. and Pil NO (go to Item 11/41) 001 001 upgrading or operations of wastewater This Includes, but Is not limited to. grant or loan conditions. f. IDENTIFICATION OF CONDITION. , AGREEMENT. ETC. 2. AFFECTED OUTFALLS 3. BRIEF DESCRIPTION OF PROJECT 4. FINAL COMPLIANCE DATE a. NO b. SOURCE OF DISCHARGE a REQUIRED b. PROJECTED B. OPTIONAL: You may attach additional sheets describing any additional water pollution control programs (or other environmental protects which may affect your discharges) you now have underway or which you plan. Indicate whether each program is now underway or planned, and indicate your actual or planned schedules for construction. ❑ MARK °X' IF DESCRIPTION OF ADDITIONAL CONTROL PROGRAMS IS ATTACHED/ EPA Form 3510-2C (8-90) PAGE2of4 Plh 'do CONTINUE ON PAGE 3 CONTINUED FROM THE FRONT ' ` `Le L ,4 4. C. Except for storm runoff. leaks, or spills. are any of the discharges described in Items MA or B intermittent or seasonal? YES (L uny-A a the lollowolg table) IZI NO (go to Section /11) , • 3. FREQUENCY 4 FLOW a DAYS PER a TOTAL VOLUME 2. OPERATION(s) WEEK b. MONTHS a. FLOW RATE (mmi:,l) tirveiyn, ho+nh) I.OUTFALt CONTRIBUTING FLOW (specie• PER YEAR q, LONG TERM 2. MAXIMUM 1. LONG TERM 2. MAXIMUM C. DURATION NUMBER (is,) (lot) mvnlle) (rprcifj'mrn ) AVERAGE DAILY AVERAGE DAILY fin "dap) III. PRODUCTION A. Does an effluent guideline limitation promulgated by EPA under Section 304 of the Clean Water Act apply to your facility? YES (eomple!s t!:rn 111-8) ❑ NO (go to Section IV) B. Are the limitations in the applicable effluent guideline expressed in terms of production (or other measure or operation)? ✓ YES (urnrpht!c item 111-1.) ❑ NO (pa to Section 111 C. If you answered 'yes" to Item III-B, list the quantity which represents an actual measurement of your level of production. expressed ,n the terms and units used in the applicable eftluenl guideline, and indicate the affected outfalls. 1. AVERAGE DAILY PRODUCTION 2 AFFECTED OUTFACES a QUANTITY PER DAY b. UNITS OF MEASURE C. OPERATION, PRODUCT, MATERIAL ETC. lspcciy) (kg mrja!!numbers) ACTUAL 200E PRODUCTXOH: 82.25 1.000 pounds croon Dyeing and Bleaching 001 PLANNED PRODUCT.r)N: 114.3 1.000 pounds cloth Dyeing and Bleaching 001 IV. IMPROVEMENTS A. Are you now required by any Federal. State or local authority to meet any implementation schedule for the construction, upgrading or operations of wastewater treatment equipment or practices or any other environmental programs which may affect the discharges described in this applcation? This includes. but is not limited to. permit conditions. administrative or enforcement orders, enforcement compliance schedule letters. stipulations, court orders, and grant or loan conditions. III YES (complete ti t: followrtig (able) FA NO (go to !trot IRA) 1. IDENTIFICATION OF CONDITION, 2. AFFECTED OUTFALLS 4. FINAL COMPLIANCE DATE AGREEMENT. ETC. 3. BRIEF DESCRIPTION OF PROJECT a. NO b SOURCE OF DISCHARGE a REQUIRED b. PROJECTED B. OPTIONAL: You may attach add( ional sheets describing any additional water pollution control programs (or other environmental projects which may affect your discharges) you now have underway or which you plan. Indicate whether each program is now underway or planned. and indicate your actual or planned schedules for construction. II MARK "X" IF DESCRIPTION OF ADDITIONAL CONTROL PROGRAMS IS ATTACHED EPA Form 351 D-2C (8-90) PAGE 2of4 21114 two CONTINUE ON PAGE 3 To: Western NPDES Unit Surface Water Protection Section Attention: Julie Grzyb SOC PRIORITY PROJECT: No Date: April 2, 2009 NPDES STAFF REPORT AND RECOMMENDATIONS County: Catawba NPDES Permit No.: NC0006190 / 6 /o PART I - GENERAL INFORMATION I. Facility and address: Delta Mills, Inc.- Maiden Plant Post Office Box 37 408 South Main Avenue Maiden, N.C. 28650 2. Date of investigation: N/A 3. Report prepared by: Michael L. Parker, Environmental Engineer II 4. Person contacted and telephone number: No one. 5. Directions to site: From the jct. of Hwy. 321 (Main Street) and SR 2003 (South Main Avenue) in the Town of Maiden, travel south on SR 2003 z 0.2 mile and turn right (west) onto West Pine Street. Travel 0.1 mile and the Delta Mills Plant will be on the left (south) side of West Pine Street. 6. Discharge point(s), list for all discharge points: - Latitude: 35° 34' 38" Longitude: 81° 14' 13" Attach a USGS Map Extract and indicate treatment plant site and discharge point on map. USGS Quad No.: E 14 SW 10. Receiving stream or affected surface waters: Clark Creek a. Classification: C b. River basin and subbasin no.: Catawba 030835 c. Describe receiving stream features and pertinent downstream uses: Excellent flow observed in the receiving stream at the time of the site inspection. The receiving stream receives effluent from other WWTPs both above and below the Delta Mills discharge point. The Town of Maiden's WWTP discharge is located immediately below Delta Mills discharge point 100± feet). • PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS 1. a. Volume of wastewater: 1.5 MGD (Design capacity according to Delta Mills) b. What is the current permitted capacity: 1.0 MGD, 1.2 MGD (proposed) c. Description of existing or substantially constructed WWT facilities: The existing WWT facilities consist of a heat exchanger followed by a bar screen, dual aeration basins (1,250,000 gallon capacity each), dual secondary clarifiers, disinfection, post aeration, sludge dewatering facilities, a parshall flume with a recording flow meter, and an aerated sludge storage lagoon. Delta Mills adds lime and extracellular polymeric substance (EPS) to the aeration basins to enhance color removal. A flocculent is added to the clarifiers to improve solids settling. d. Description of proposed WWT facilities: There are no proposed WWT facilities at this time. 2. Compliance background: Delta has recently been assessed civil penalties for effluent violations for flow (see Part IV below). PART III - OTHER PERTINENT INFORMATION 1. Special monitoring or limitations (including toxicity) requests: None at this time. PART IV - EVALUATION AND RECOMMENDATIONS Delta Mills (DM) has requested a modification to the subject permit to increase the permitted flow from 1.0 MGD to 1.2 MGD. The primary reason for this flow increase is to provide for additional water use expected as a result of a proposed increase in cloth production from 600K pounds per week up to 1.0 million pounds of cloth per week. This increase in production will allow DM to be cost competitive and allow them to accept additional business. The main issue that will need to be resolved is whether the existing WWT facilities are capable of handling and treating an additional 0.200 MGD of flow. In a DMR review, it appears that DM has reached or exceeded their monthly average permitted capacity on several occasions in the past two years; however, overall effluent quality does not appear to have been compromised. In a letter dated June 18, 2007, DM's Plant Manager indicated that a number of steps have been taken to reduce overall wastewater flows, including a re -programming of existing dye machines to shorten rinse cycles and the replacement of dye machine flow meters, which we found to be inaccurate and did not function properly during low flow events. These steps should aid DM in reducing current flows, however, anticipated increases in production may off -set any improvements seen in this area — hence the need to increase the permitted flow. In the letter mentioned in the paragraph above, DM indicates that the existing WWT facilities are capable of treating flows up to 1.5 MGD. If that is the case, a review of the MRO files failed to determine why the existing permitted flow limit was set at 1.0 MGD. It may have just been an arbitrary number chosen during DM's early production days or it may coincide with a (negative) change in effluent limitations should the permitted flow limit exceed 1.0 MGD. In the June 18th letter, DM characterizes the flow exceedances as "temporary", but it appears with the planned increase in production that monthly average effluent flows above 1.0 MGD will become the norm. Page Three It would appear from a review of DMR data and the capacities of the existing treatment components that DM may have the capability of treating up to 1.2 MGD of wastewater without having to add additional treatment units. DM has certainly shown the capability to comply with their effluent limitations (with the exception of flow) using existing treatment technology. Typically, DM's facilities are well operated and maintained, and there is no history of chronic noncompliance at this facility aside from the recent monthly average flow exceedances. Such being the case, if DM can establish that the existing treatment facilities are hydraulically capable of handling wastewater flows up to 1.2 MGD, this Office would have no objection to granting the requested increase in permitted flow. Signature of Report Preparer P ate / Oh? Water Quality Regional Supervisor h:ldsrldsr091deltami 1. doc Date APPAREL, INCORPORATED 17_REc pv ./;!,„ NCDENR NPDES — West ATTN: Mr. Sergei Chernikov 1617 Mail Service Center Raleigh, North Carolina 27699-1617 DENR - WATER RI Subject: NPDES Permit ModificationPA is t o OU R - NPDES Permit No. NC0006190 — Catawba County Dear Mr. Chernikov: 3-13- Enclosed is an application in triplicate requesting that our wastewater treatment plant's monthly average permitted flow limit be increased from 1.0 MGD to 1.2 MGD. This increase will allow Delta Apparel -Maiden to increase production to meet current and projected product demands from our customers. Although we continue to work on ways to produce more with Tess water, this limited increase is necessary to respond to our customer demand. Our submittal includes the following documents and information: ➢ A check for $1,030.00 payable to NCDENR for the NPDES permit application fee. ➢ Three (3) documents which each include the following: • EPA General Form 1 and attached topographic map • EPA Form 2C and attachments ■ Engineering Alternatives Analysis and supporting information As previously indicated to you by our environmental consultant, Applied Water Technology, Inc., submission of a Local Government Review Form is not included with this submittal because it is not applicable to our situation. Namely, we are not a "non -municipal domestic wastewater treatment facility", and the proposed alternative (surface water discharge) does not affect or alter the current zoning status of our treatment facility. If there are any questions about this submission and request, please contact either Jackie Harvell of Delta Apparel -Maiden at 828-428-9921, extension 235, or our environmental consultant contact, Charle Blackwell of Applied Water Technology, Inc., at 919-L'.SE or 6� l- t,�(S/ We appreciate the continuing cooperation of the NPDES — West Permit Unit and look forward to working with you concerning this matter. Please make every effort to process our application as soon as possible. Thank you. Yours truly, Steve Slaughter Plant Manager s'- eve , S 1 a ti� G., � -(46LP P eb.S. .. c c ►� 100 W. Pine Street • P.O. Box 37 • Maiden, N.C. 28650 • (828) 428-9921 • FAX (828) 428-8307 Change your shirt. CtrJ_\ iSCHARGE f$001 N35 34' 36' W81 14' 25 y ' 3•D TopoQuads Copyright ®1999 DeLorme Yarmouth, ME 09096 Source Data: USCS I 000 ft Scale:1: 25,000 Detail: 13-0 Datum: WGS84 WATER FLOW SCHEMATIC DELTA APPAREL, INC. <> MAIDEN, NC Water Intake from Town of Maiden 392.96 MG Delta Apparel, Inc. 30.11 MG V Boilers 0.78 MG Blowdown 355.88 MG 29.33 MG Steam Dyeing & Finishing 3.17 MG 3.80 MG Restrooms Maiden Sewer 7.24 MG Cooling Towers 2.86 MG To Atmosphere • 377.97 MG Heat Exchanger Steam & Dryer Evaporation to Atmosphere 0.31 MG 379.06 MG • Delta Apparel, Inc. Wastewater Treatment Plant NPDES No. NC0006190 Blowdown 2.85 MG Water in Land Application of 2.95% Solids Sludge 376.21 MG • Discharge from Outfall No. 001 to Clark Creek Water Volumes Shown Are Based On CY2008 Totals For 347 Days of Operation Out of 366 Days MG = Million Gallons 1.19 rari r+4 mro r=t 11111 WASTEWATER TREATMENT PLANT SCHEMATIC DELTA APPAREL, INC. <> MAIDEN, NC Bar Screen Aeration Basin #2 Vol. =1,250,000 gallons (3) 50 H.P. Floating Aerators 180' L x 90' W x 12' D 0.5 MGD Polymer Feed Points Aeration Basin #1 Vol. = 1,250,000 gallons (3) 50 H.P. Floating Aerators 180' L x 90' W x 12' D 0.5 MGD Sludge Retum b AA Flocculent 38 Ft. Dia. 10 Ft. Sidewater Depth Waste Sludge 4 Sludge Retum Flocculent Sludge P.S. Chlorine Contact & 2.0 MGD Flow Meter Sludge Storage Lagoon Surface Area = 49,170 Sq. Ft. 1.8 MG Holding Capacity (5) 7.5 HP Surface Aerators (2) 5 HP Surface Aerators 117 1.5 MGD Effluent Row Measurement Device Reaeration Basin (2)10 H.P. Floating Aerators i d o'°3a,k‘ eI^s Clark Creek Discharge No. 001 (7,500 Ft. From Effluent & Flow Measurement & Sampler) DELTA APPAREL, INC. CATAWBA COUNTY MAIDEN, NC NPDES PERMIT NO. NC0006190 PRESENT WWTP OPERATING STATUS DELTA APPAREL, INC. Wastewater from the dye and bleaching process goes to the heat reclaimer equipment for heat recovery from the hot (120°F) wastewater. Lint is filtered at this point before being discharged to the WWTP. Wastewater enters the WWTP through a bar screen, then goes into dual aeration basins. Each aeration basin is 180 feet long by 90 feet wide by 12 feet deep, and contains 1,250,000 gallons with 60 hours retention at 1 MGD of total plant flow. Polymer for color removal is added to the flow leaving the aeration basins. From aeration, the flow goes into dual clarifiers to settle solids, where a flocculation agent is added to the center -well of each clarifier. Each clarifier is 38 feet in diameter and 10 feet deep with a capacity of 80,000 gallons. From the clarifiers the flow goes through the old chlorine contact chamber and a float and cable flow recorder. From here, the flow goes into the post aeration basin that is 50 feet long and 25 feet wide and 9 feet deep with a capacity of 84,000 gallons. The flow then goes to the parshall flume with an ISCO flow recorder and refrigerated composite sampler. From here, the flow travels 7,500 feet through a 14-inch gravity line (Outfall No. 001) discharging to Clark Creek. DELTA APPAREL, INC. CATAWBA COUNTY MAIDEN, NC NPDES PERMIT NO. NC0006190 r+� 12114 rmi Owl SLUDGE MANAGEMENT PLAN NARRATIVE DELTA APPAREL, INC. Solids that settle and thicken in the clarifiers are wasted at a rate of 50,000 gallons-100,000 gallons per week. The waste rate can vary with the mixed liquor total solids, flow, and sludge depth in the clarifiers. Sludge is wasted into the sludge storage lagoon, which has a capacity of approximately 1,800,000 gallons. During wasting and storage, the sludge is aerated with seven (7) surface aerators. Decant is pumped back into the aeration basins. When the lagoon nears capacity, a professional contractor hauls the solids to various sections on 240 acres of pasture for land application. Land application of these biosolids is carried out within the regulations of Permit No. WQ0006984. DELTA APPAREL, INC. CATAWBA COUNTY MAIDEN, NC NPDES PERMIT NO. NC0006190 CM MI MI MI MI MI FM Alternatives Analysis Delta Apparel, Inc. NPDES Permit No. NC0006190 March 2009 For: n Delta Apparel, Inc. 100 West Pine Street c, Maiden, North Carolina 28650 Catawba County (704) 428-9921 rm FM, ...., By: WI Applied Water Technology, Inc. 311 South Academy Street Cary, North Carolina 27511 (919) 466-9246 n MI r� Pal MI IM IM MI Delta Apparel, Inc. March 2009 Page 2 TABLE OF CONTENTS PAGE NO. SUMMARY 3 BACKGROUND INFORMATION 3 PROJECT DESCRIPTION 4 EVALUATION OF DISPOSAL ALTERNATIVES 5 A. Connection to a Sewer Collection System 5 1. Existing Sewerage System 5 2. Planned Sewerage System 6 B. Land Based Disposal 6 1. On -Site Land Based Disposal 6 2. Off -Site Land Based Disposal 7 C. Wastewater Reuse 7 D. Surface Water Discharge 9 E. Disposal Combinations 10 Surface Water Discharge and Wastewater Reuse Combination 10 F. Economic Feasibility of Alternatives 11 Attachments mo • Wastewater Treatment Plant Schematic • Aerial View of Site and Adjacent Property Use • Land Availability for Land Based Disposal Alternative Letter • Land Area Required for 0.2 MGD Flow • Land Area required for 1.2 MGD Flow • Estimation of WWTP Effluent Characteristics at 1.2 MGD r, • Delta Apparel WWTP Characteristics [See EPA Form 2C Item V] • Derivation of Present Value Factor for Economic Feasibility Analysis • Quote from Calgon Carbon Corporation c► • Quote from Koch Membrane Systems Map Pocket • Catawba County Tax Map • To -Scale Facility Site Map TM r, n l SUMMARY Delta Apparel, Inc. March 2009 Page 3 �, Delta Apparel, Inc. would like to increase their monthly wastewater flow limit to provide for increased production at their Maiden Plant as soon as possible to continue to be competitive and to meet consumer demand. The current permitted flow of this facility is ,.--, 1.0 MGD. This increase will result in an increase in wastewater generated of 0.2 MGD as a monthly average. r, Since May 2007, the wastewater treatment plant (WWTP) has experienced numerous days when the flow exceeded 1.0 MGD, and where the monthly flow average has approached 1.2 MGD. Review of the monthly flow data since May 2007 indicates that a monthly flow limit of 1.2 MGD should allow the facility to meet its consumer demand production and remain within its NPDES permitted flow limits. In part, the overall flow increase has been and will be offset by ongoing water reduction and minimization r measures within the manufacturing operations. Although flows have exceeded 1.0 MGD since May 2007, the WWTP still maintained its compliance with all other NPDES permit limits during this period, and expects this to continue with the 1.2 MGD permit limit. MI To comply with both state and federal requirements for requesting a NPDES permit modification due to an increase in flow, an alternatives analysis has been completed. .1 This alternatives analysis is an evaluation of the available disposal alternatives, their relative costs, and applicability to determine the most cost effective alternative. The results of this analysis indicate that the most cost effective alternative available to Delta is to continue surface water discharge of their wastewater. , MI The only additional costs associated with continuing to discharge to surface waters result from an increase in flow -variable operating costs at the existing on -site wastewater treatment plant to handle the additional flow. The other applicable disposal alternatives require additional treatment of the wastewater. Costs provided in this analysis represent preliminary budgetary costs on a relative basis, and are not necessarily representative of actual construction costs. Costs were provided by vendors based on telephone conversations about the systems or equipment being evaluated for the purposes of a general cost comparison designed to verify a technology's ,.., initial viability in this analysis. Costs for treatment of Delta Apparel's existing WWTP flow are based on Delta's expenditure records for 2008. BACKGROUND INFORMATION Delta Apparel, Inc. (NPDES Permit NC0006190) is a manufacturer of cotton and F, synthetic fabrics using circular knitting machines. The manufacturing process includes bleaching, dyeing, and finishing these fabrics using a variety of chemicals and dyes. r1 1. pal Delta Apparel, Inc. March 2009 Page 4 There are two separate wastewater streams generated at this facility, sanitary and manufacturing wastewater. The sanitary wastewater is discharged to the Town of Maiden's sewer system and treated by their domestic wastewater treatment plant. The manufacturing wastewater includes wastewater from the boilers, cooling tower, and the dyehouse that is discharged to Delta's on -site wastewater treatment plant. This on -site wastewater treatment plant has been used by Delta for the past forty-two (42) years to treat the industrial wastewater generated at this facility. The performance of this treatment plant has been very good thus far. The treatment plant has consistently discharged an effluent which meets its NPDES discharge permit limits, even during the times that the treatment plant has been operating at or above its permitted capacity of 1.0 MGD. As indicated on the attached wastewater treatment plant schematic, the plant consists of a bar screen, two aeration basins, two clarifiers, a chlorine contact chamber, a reaeration basin, and a 1.8 MGD sludge storage lagoon. Each aeration basin and its o!aL_IL LSIr associated clarifier receive one-half of the total wastewater flow. , ' s�-a Prr C4- ) Each aeration basin has a volume of 1.2 MG and is equipped with three 50 h.p. floating aerators. Each clarifier is 38 feet in diameter with a 10-foot sidewater depth. The surface loading rate is calculated to be141 gallons per day per square foot at a flow of 1.0 MGD. The chlorine contact chamber is i can tive since t ere is no sanitary waste discharged to the WWTP. The reaeration basin contains two 10 h.p. floating aerators. Currently, all of the treated wastewater flows from the reaeration basin through a parshall flume for effluent flow measurement, and then is discharged into Clark Creek which is the receiving water designated under Delta's NPDES permit, NC0006190. Sludge is wasted to a 1.8 MGD sludge storage lagoon. ,,-. , , a rA �.h /0 d Sa °I P e/ -� PROJECT DESCRIPTION Delta Apparel would like to increase their production rates at this facility as soon as possible. Production by Delta for the last six to seven months of 2008 indicates that sales have increased and will continue increasing. Production for the first month of 2009 indicates an upturn as well. By not being able to increase the production rate at this facility, the amount of additional business that can be accepted by the facility will be limited. 6,,,jczckc.�!7�/ .�i' '�� 3 (Cik�a Currently, Delta is operating at an average production rate of approximately 600,000 pounds of cloth per week, based on 2008 data. The goal of this facility is to increase the production rate to an estimated average production rate per week of 800,000,.Wieeteefr pounds of cloth. Production at this rate will enable Delta to be more cost competitive and enable them to produce a sufficient amount of their products to meet customer demand, and to take advantage of immediate production opportunities as the overall economy rebounds. r-i • Delta Apparel, Inc. March 2009 Page 5 This production increase will ultimately result in an increase in the average amount of wastewater generated at this facility of approximately 200,000 gallons per day. Since monthly flows at this facility averaged 1.03 MGD in 2008, with a daily maximum of 1.28 MGD, the facility has been able to treat these flows to levels below its current permit limits. Within the last two years, the facility produced a monthly flow average of 1.18 MGD (in November 2007), and even that flow resulted in an otherwise compliant effluent. This alternatives evaluation reveals that of the options available to be considered, the only applicable options are surface water discharge, wastewater reuse, and a combination of the surface water discharge and reuse; however, the most cost effective choice would be for Delta to continue discharging to surface water, namely Clark Creek. The latter two of these potential alternatives will require upgrading the on -site WWTP to provide additional treatment for the increased flow; whereas, surface water discharge only incurs an increase to Delta in the flow -variable cost of their current treatment. For wastewater reuse to be workable, the wastewater will require additional treatment. Delta must be able to have treated wastewater that is free of color and chlorides if this treated water is to 'R be reused in the dyehouse. Since this facility relies on the quality of their product, Delta must be able to depend on the treated water to be consistent with their quality standards. Not only will Delta have to treat the wastewater more thoroughly for reuse, pilot studies will need to be performed to determine if enough treatment is being applied. The size of flow, 1.2 MGD, is the major factor limiting the options available for treatment of this wastewater. An evaluation of the available disposal alternatives, their relative costs, and applicability are discussed in the following sections. EVALUATION OF DISPOSAL ALTERNATIVES A. Connection to a Sewer Collection System 1. Existing Sewerage System There is an existing sewer line and manhole located on Delta Apparel's property. Delta is currently discharging the facility's sanitary wastewater to this sewer system, which discharges into the Town of Maiden's wastewater treatment plant. The maximum capacity that the Town of Maiden's WWTP can handle is 1.0 MGD. 1=1 The volume of industrial wastewater currently generated by Delta Apparel's facility averaged above 1.0 MGD in 2008, which is also above the maximum capacity of wastewater that the Town's WWTP is designed to treat. When production is increased at Delta, the volume of wastewater generated will be approximately 1.2 MGD. This 1.2 MGD flow is more than the Town's domestic WWTP was designed to handle, and if discharged would preclude any capacity for the town's domestic flows; therefore, n • r-1 f f Delta Apparel, Inc. March 2009 Page 6 discharging this entire wastewater flow to this WWTP is not an option that is available to Delta Apparel. Currently, the Town of Maiden's WWTP is only receiving approximately 400,000 gallons per day of wastewater. It is possible that Delta could discharge on a temporary basis the 200,000 gallons per day increase to the Town's WWTP. Unfortunately, this could only be on a temporary basis because the Town will need the remaining WWTP capacity for its domestic growth. When the flow from these other sources is received, there will not m► be enough capacity available for Delta to use for the increased flow amount. In addition, the Town has also experienced infiltration problems in the past and if the Town agreed to accept this additional flow on either a temporary or permanent basis, Delta would not be mi able to discharge to the Town on any rainy days, otherwise the Town's effluent would not meet the permit's effluent flow limits. The town would also require Delta to pretreat its industrial wastewater before discharge to the Town's WWTP and would require negotiation of pretreatment levels and wastewater treatment charges. Unfortunately, Delta and the Town have recently extensively explored this possibility as well as other similar options, and no agreement could be reached due to the costs to Delta and the tight `-' pretreatment level requirements. Therefore, this option, despite the prior good faith attempts by Delta and the Town, is not an option that is available to Delta Apparel. 'a 2. Planned Sewerage System n There is no planned sewerage system in this area that would be available to Delta Apparel at this time, nor is it likely that any system will be planned for this area in the near future. Therefore, this alternative is not an option that is available to Delta. B. Land Based Disposal 1. On -Site Land Based Disposal There are a number of options listed under the land based disposal alternative that could be considered: nitrification systems, low pressure pipe systems, drip irrigation systems, WI mound systems, and spray irrigation systems. However, the only land -based option that is even remotely feasible to consider for this large wastewater flow, 1.2 MGD, is a spray irrigation system. Spray irrigation could be used for this amount of flow; however, there is not enough land available on the approximately 25-acre Delta site (See Site Diagram in Map Pocket) for Delta to use this system to dispose of their wastewater. The land ,., requirement for the 1.2 MGD flow is approximately 84 acres. In fact, it is not possible for any reasonable portion of this wastewater to be land applied on -site. The land requirement for only the additional 200,000 gpd flow is approximately 14 acres. I' 1 2. Off -Site Land Based Disposal Delta Apparel, Inc. March 2009 Page 7 �► There is no adjacent land available for Delta Apparel to acquire for use in this disposal system (See Catawba County Tax Map in Map Pocket and Google Earth® Aerial Map attached). Delta Apparel is almost completely surrounded by other developed properties. These properties are either commercial or industrial and currently have buildings located on these lots. Based on a review of the Catawba County tax map, and confirmed by Catawba County GIS personnel (Greta Bumgarner on 2/18/2009), there is insufficient open land available or a farm nearby to land apply all or a portion of this wastewater. A letter from Delta Apparel confirming this lack of available adjacent land is attached. r, C. Wastewater Reuse Fral Wastewater reuse at this facility is a possible alternative to consider for the 1.2 MGD wastewater stream. However, the cost of reusing the wastewater will be quite expensive. To make this option viable, Delta must provide additional treatment to the wastewater so that the effluent quality will be acceptable for use in the manufacturing operations. The two main parameters of concern for treatment and reuse are color and chlorides removal. To reuse the wastewater at this facility, this wastewater will need to be treated for not only additional color removal, but also for the presence of chlorides. Since the current treatment operations do not address either of these two issues to the degree necessary for reuse, additional treatment systems will be needed if an acceptable level of effluent quality for reuse is to be achieved. The technology available to address the removal of color and chlorides is very expensive. The reuse of this wastewater would not be cost effective when compared to continuing to discharge to surface waters. Reverse osmosis would be the treatment system necessary to remove chlorides. The cost provided in this analysis is based on information provided by Koch Membrane Systems (see attached). To remove all TSS and to reduce the effluent organic load, Koch has recommended a UF system to precede the RO system; and has suggested that a temperature reduction to less than 100° F might also be necessary. The UF capital cost is estimated to be approximately $1 million, and the RO capital cost is estimated to be approximately $750,000 (see attached). To remove color, carbon adsorption was evaluated. Information provided by Calgon Carbon (see attached) is based on a .2 MGD flow rate using Filtrasorb® #300 for four (4) carbon vessels of 20,000 pounds capacity each, in two parallel trains of two vessels each. The Calgon system is estimated to have an installed cost of approximately $1,000,000 (see below). As with the reverse osmosis system, the carbon adsorption system would require additional treatability studies before final sizing could commence. The cost of these studies is not included in these cost estimates. 0 Delta Apparel, Inc. March 2009 Page 8 Equipment or Item Capital Cost Estimate Reverse Osmosis System: Ultrafiltration Unit $1,000,000 Reverse Osmosis Unit $750,000 Design, Permitting, etc. @ 25% $437,500 Sub -Total $2,187,500 Carbon Adsorption: 4 vessels @$200,000 each $800,000 Design, Permitting, Installation, etc. @ 25% $200,000 Sub -Total $1,000,000 Total $3,187,500 Annual recurring operating cost estimates for reverse osmosis (including UF) were estimated by Koch Membrane Systems to be $300,000. Annual operating costs for the carbon adsorption are based on information provided by Calgon Carbon, and only include the cost of carbon replacement. Carbon replacement would be approximately $30,000 per vessel, with an assumed monthly replacement cycle for two vessels each. This yields an estimated annual carbon replacement cost of approximately $720,000. Of course, in a water reuse scenario, Delta Apparel would be able to reduce the volume of raw water purchased from the Town of Maiden by the amount reused. This cost would ''' offset some of the annual operating costs presented below. For purposes of this analysis, an 80 percent volume reduction is assumed (i.e., 20 percent would still require treatment and discharge). According to Delta Apparel, in 2008 their cost for raw water from the town was approximately $3,000 per MG. At a WWTP flow of 1.2 MGD, the annual savings is estimated to be approximately $1.051 million. The costs associated with handling the additional flow of 200,000 gpd and for additional treatment for the removal of chlorides and color are provided below. Vat ral C=1 RI !=1 MCI , fail mil Delta Apparel, Inc. March 2009 Page 9 Wastewater Reuse Additional Treatment Equipment Ca ' ital Cost Comments & Estimate Annual OperatingCost Estimate Reverse Osmosis (with UF) $2,187,500 1.2 MGD (chlorides) $300,000 Activated Carbon Adsorption $1,000,000 1.2 MGD (color) $720,000 Less Annual Water Savings - ($1,051,000) Plus Cost to Treat 0.2 MGD - $91,031 Total Cost for Wastewater Reuse $3,187,500 1.2 MGD $60,031 It is quite possible that even with additional treatment, the wastewater quality will not be acceptable for reuse at this facility. Pilot studies will inevitably need to be performed to determine the exact treatment scenario that will be needed to provide an acceptable effluent quality. The costs associated with implementing extensive pilot studies have not been included in this analysis. D. Surface Water Discharge This is the current disposal method being used at Delta Apparel for the wastewater discharge of 1.0 MGD. The facility's on -site wastewater treatment system is operating near its maximum capacity; however, effluent limits are still being continuously met, and in almost all cases, the WWTP discharge values are well below the permitted limitations. When actual monthly flows have approached the requested WWTP flow limit of 1.2 MGD, as in November 2007, the WWTP effluent was still compliant with its current limits, as shown below based on the November 2007 Discharge Monitoring Report (DMR) averages. Discharge Parameter Permit Limit Actual Value % Below Permit Limit Flow 1.0 MGD 1.17 MGD - BOD5 1621bs 10.4 lbs 94 TSS 785 lbs 132.9 lbs 83 COD 2900 lbs 1173.6 lbs 60 Color, ADMI 549 su 154 su 72 Chronic Toxicity >11% 15.6%* 42 * Based on values from September and December 2007 n r, r, rWO Delta Apparel, Inc. March 2009 Page 10 For a flow increase from 1.0 MGD to 1.2 MGD, no additional capital expenses, or equipment will be required, only plant flow -variable operating costs will increase. These costs include electricity, chemicals, and sludge disposal and hauling. Based on Delta Apparel's 2008 records, these combined costs were approximately $1,247 per million gallons of treated wastewater. Consequently, under this option the annual cost to treat the additional 200,000 gpd of wastewater, averaged over 365 days for a total of 73 MG per year, is estimated to be $91,031. E. Disposal Combinations Surface Water Discharge and Wastewater Reuse Combination The only disposal combination that is available for Delta to consider is the combination of surface water discharge and wastewater reuse. Under this option, initial treatment of the additional 0.2 MGD would be performed by the existing WWTP, with the additional 0.2 MGD flow being diverted before surface water discharge to smaller carbon adsorption and reverse osmosis units for additional treatment and reuse. The cost values below were determined by pro -rating the 1.2 MGD full-size costs above to 0.2 MGD, a reduction factor of 0.17. Consequently, these values are expected to be low because a significant economy of scale has been lost. Surface Water Discharge and Wastewater Reuse Additional Treatment Equipment Ca s ital Cost Comments & Estimate Annual OperatingCost Estimate Reverse Osmosis (with UF) $371,900 0.2 MGD (chlorides) $51,000 Activated Carbon Adsorption $170,000 0.2 MGD (color) $122,400 WWTP Additional Costs to Treat 0.2 MGD - $91,031 Total Cost for Wastewater Reuse $541,900 0.2 MGD $264,431 oniq Trm 1, Ma, Delta Apparel, Inc. March 2009 Page 11 F. Economic Feasibility of Alternatives Both capital and recurring annual costs for each alternative evaluated above are summarized below. Economic feasibility of alternatives is based on a comparison of their present worth costs using a planning period of 20 years and a USEPA mandated interest or discount rate of 4.875 percent. Although the recurring costs are expected to escalate through the planning period, for purposes of this analysis they were assumed to remain constant throughout the planning period. The present value or present worth factor applied to the annual recurring costs is 12.5954 (see attached). Alternative Capital Cost Recurring Annual Cost Present Worth of Recurring Annual Cost* Present Worth Value of Alternativet Wastewater Reuse $3,187,500 $60,031 $756,114 $3,943,614 Surface Water Discharge N/A $91,031 $1,146,572 $1,146,572 Surface Water Discharge & Wastewater Reuse Combination $541,900 $264,431 $3,330,614 $3,872,514 *n = 20 years, USEPA annual discount rate = 4.875% tSum of Capital Cost and Present Worth Recurring Annual Cost 7 7 Attachments Delta Apparel, Inc. March 2009 Page 12 n n Fug WASTEWATER TREATMENT PLANT SCHEMATIC DELTA APPAREL, INC. <> MAIDEN, NC Bar Screen Aeration Basin #2 Vol. = 1,250,000 gallons (3) 50 H.P. Floating Aerators 180'Lx90'Wx12'D 0.5MGD Polymer Feed Points Aeration Basin #1 Vol. = 1,250,000 gallons (3) 50 H.P. Floating Aerators 180'Lx90'Wx12'D 0.5 MGD Sludge Return Flocculent 38 Ft. Dia. 10 Ft. Sidewater Depth Waste Sludge Sludge Return Flo lent T Sludge P.S. Chlorine Contact & 2.0 MGD Flow Meter Sludge Storage Lagoon Surface Area = 49,170 Sq. Ft. 1.8 MG Holding Capacity (5) 7.5 HP Surface Aerators (2) 5 HP Surface Aerators , ir 1.5 MGD Effluent Flow Measurement Device Reaeration Basin (2)10 H.P. Floating Aerators Clark Creek Discharge No. 001 (7,500 Ft. From Effluent & Flow Measurement & Sampler) DELTA APPAREL, INC. CATAWBA COUNTY MAIDEN, NC NPDES PERMIT NO. NC0006190 1 Source: Google Earth Maps Printed on 2/18/2009 Aerial View of Delta Apparel and Adjacent Property Maiden, NC Eye alt 5053 ft n DELTA APPAREL, INCORPORATED 2/24/09 Mr. Sergei Chemikov NCOivision of Water Quality-NPDES West 1617 Mail Service Center Raleigh, NC 27699-1617 RE: Alternatives Analysis Land Availability for Land -Based Disposal Alternative Delta Apparel, Inc. — Maiden Plant NPDES No. NC0006190 Dear Mr. Chemikov Our consultant, Applied Water Technology, Inc., is preparing the wastewater permit application for the proposed increased flow from our facility. During the evaluation of the land -based disposal alternative, the option of acquiring land adjacent to our facility was reviewed. Unfortunately, there is not any land adjacent to our facility that could be acquired for this use. If there are any questions regarding this issue, please contact either Charles Blackwell with Applied Water Technology at (919) 466-9246 or Jackie Harvell of our facility at (828) 428-9921 Extension 235. Sincerely, Steve Slaughter Plant Manager 100 W. Pine Street • P.O. Box 37 • Maiden, N.C. 28650 • (828) 428-9921 • FAX (828) 428-8307 Change your shirt. Land Area Required for 0.2 MGD Flow 0.1 Pul rtal rtzfl ,m, Water losses, inches Water applied, inches Month lEvapotrans (1) Percolation (2) Total (3) Precip (4) WW,Lwp (5) Total (6) Jan 0.1 18.144 18.244 3.87 14.374 18.244 Feb 0.1 18.144 18.244 4.58 13.664 18.244 Mar 1.2 18.144 19.344 5.05 14.294 19.344 Apr 1.8 18.144 19.944 3.96 15.984 19.944 _ May 3 18.144 21.144 4.67 16.474 21.144 Jun 4 18.144 22.144 5 17.144 22.144 J u l 4.5 18.144 22.644 4.03 18.614 22.644 Aug 4.1 18.144 22.244 4.87 17.374 22.244 Sep 2.9 18.144 21.044 3.91 17.134 21.044 Oct 1.8 18.144 19.944 3.31 16.634 19.944 Nov 0.6 18.144 18.744 2.98 15.764 18.744 Dec 0.1 18.144 18.244 4.18 14.064 18.244 Total 24.2 217.728 241.928 50.41 191.5 241.928 percolation(Wp)= (0.63 in/h)*(24 hr/d)*(0.04)*(30 d/mon) Wp = 18.144 Area Needed (Aw)= Q*365/Lwp Aw= [(0.2MGD*0.134 cu ft/gal*365 d/yr)/(191.5 in/yr"1ft/12 in*43560 sq ft/acre)] Aw= 14.1 acres Column explanations: 1 - data for Brevard, NC. Reference Metcalf & Eddy. 2 - data for Maiden, NC. Reference Soil Survey 3 - column 1 + column 2 4 - data for Hickory, NC. Reference NC Office of Climatology Report No. 185 5 - column 3 • column 4 6 - column 4 + column 5 Notes: Calculation procedure from Metcalf & Eddy 3rd ed, p. 960 n Land Area Required for 1.2 MGD Flow Mel ran n Water losses, inches Water applied, inches Month Evapotrans (1) Percolation (2) Total (3) Precip (4) WW,Lwp (5) Total (6) Jan 0.1 18.144 18.244 3.87 14.374 18.244 Feb 0.1 18.144 18.244 4.58 13.664 18.244 Mar 1.2 18.144 19.344 5.05 14.294 19.344 Apr 1.8 18.144 19.944 3.96 15.984 19.944- May 3 18.144 21.144 4.67 16.474 21.144 Jun 4 18.144 22.144 5 17.144 22.144 Jul 4.5 18.144 22.644 4.03 18.614 22.644 Aug 4.1 18.144 22.244 , 4.87 17.374 22.244 Sep 2.9 18.144 21.044, 3.91 17.134 21.044 Oct 1.8 18.144 19.944 3.31 16.634 19.944 Nov 0.6 18.144 18.744 2.98 15.764 18.744 Dec 0.1 18.144 18.244 4.18 14.064 18.244 Total 24.2 217.728 241.928 50.41 191.5 241.928 percolation(Wp)= (0.63 in/h)*(24 hr/d)*(0.04)*(30 d/mon) Wp = 18.144 Area Needed (Aw)= Q*365/Lwp Aw= (1.2MGD*0.134 cu ft/gal*365 d/yr)/(191.5 in/yr"lft/12 in*43560 sq ft/acre) Aw= 84.4 acres Column explanations: 1 - data for Brevard, NC. Reference Metcalf & Eddy. 2 - data for Maiden, NC. Reference Soil Survey 3 - column 1 + column 2 4 - data for Hickory, NC. Reference NC Office of Climatology Report No. 185 5 • column 3 - column 4 6 - column 4 + column 5 Notes: Calculation procedure from Metcalf & Eddy 3rd ed, p. 960 • r-, Estimation of WWTP Effluent Characteristics at 1.2 MGD Based on the WWTP November 2007 DMR Data averages where average flow = 1.17 MGD Flow Increase Multiplier = 1.2 MGD/1.17 MGD = 1.03 BOD5 (10.4 lbs/day) (1.03) = 10.7 lbs/day COD (1173.6 lbs/day) (1.03)= 1208.8 lbs/day TSS (132.9 lbs/day) (1.03) = 136.9 lbs/day 0.1 Ammonia Pa, (0.12 mg/1) (1.03) = 0.12 mg/1 Chromium (1.98 µg/1) (1.03) = 2.04 µg/1 Sulfides (0 lbs/day) (1.03) = 0 lbs/day Phenols (0.11 lbs/day) (1.03) = 0.11 lbs/day n Derivation of the Present Value Cost Factor for Recurring Annual Costs Where: PV = Present value of costs Co = Costs incurred in the present year Ct = Costs incurred in time t t = Time period after the present year n = Ending year of the life of the facility r = Current discount rate Assume: r = 4.875% and n = 20 years Then, the PV cost factor is: PV Factor = [(1+ r)" — 1] / [(r(1+r)"] = [(1+0.04875)2° — 1] / [(0.04875)(1+0.04875)20] = (2.5908 — 1) / [(0.04875)(2.5908)] = (1.5908) / (0.1263) PV Factor = 12.5954 Then, PV = Co + (PV Factor)(Ct) and PV = Co + 12.5954Ct Subj: Date: From: To: Model 10 Budgetary Quote 2/23/2009 4:17:11 PM Eastern Standard Time BJohnston©calgorjcatbon-ass.com Awtmaiibox@aol.com Charles, Here is the budgetary quote. Again, Filtrasorb 300 may or may not be the right carbon for this application. (Embedded image moved to file: pic00491.jpg) NOTE Prices are Ex -Works Shipping Point for both carbon and equipment. Installation is NOT included. Field Service supervision included. 125 ASME code design. Backwashable Plasite 4110 vinyl ester vessel lining. 8" carbon steel pipe w/cast iron fittings. 40,000 pounds Filtrasorb 300. Internal cone underdrain with polypropylene septa nozzles or external header w SS septa. (See attached file: 2008 CCC T&C's.PDF) Thank you, Brett M. Johnston Inside Technical Sales Representative Calgon Carbon Corporation Tele: 412.787.4762 Fax: 412.787.4523 Cell: 412.535.3352 M, Page 2 of 2 M bjohnston©calgoncarbon-us.com www.calgoncarbon.com Please visit our website at www.calgoncarbon.com, for all MSDS requests and Product Literature rodud # efoduct Name Model 'l{ y ri) 300 • Packaging Type quantity system rice Paymeld mreleht await WOO, OMPatsy/ern Price does not include an Wight or applicable sales tax. MastetCard, VISA and Discover cards OrNet 30days Carbon Acceptance Fee: (one-time fee before Calgon Carbon can take back any spent carbon) n f 00 Non-RCRA $1000 RCRA )N LY applicable if customer wants CCC to dispose/reactivate spent carbon !Mush Shlpmett' is necessary, there will be a service charge as fdlows: ;�a flat fee of $500 will be applied to every complete order that must ship the same day it is received. a flat fee of $400 wil be applied to every complete ceder that must ship the day attar it le received. - a flat fee of $300 will be applied to every complete ceder that must ship two days after it is received. Dude is valid for 30 days. *Subject to CCC Terms and Conditions ..Pease fax or erred your purchase order to my attention. Telephone Conversation Dotes. with CaIvan:Pax ottitkideSale.s Representative Date: February 20, 2009 With: Brett Johnston, Inside Technical Sales Representative — (412) 784-4762 Digest: Based on flowrate of 1.2 MGD (1.5 MGD maximum) a Model #10 system with 4 vessels of 20,000 lbs carbon each, using Filtrasorb® #300 could be used. (2 parallel trains of 2 each in series) Cost of one vessel w/carbon would be approx. $200,000. w/o shipping or installation. Replacement Carbon: For 1 . vessel @ $4/lb for 20,000 lbs/vessel.; say $25- $30K/vessel/charge. n Page 1 of 3 Pal Subj: RE: Chlorides Removal for 1.2 MGD Flow Date: 2/25/2009 12:59:47 PM Eastem Standard Time From: jjcanglgno©kochmembrane.com 0.1 To: Awtmailbox aol.com Rol Pool Hi Charles, In order for an RO system to work properly you have to remove all the TSS and reduce the organic Toad as well. I would recommend a UF in front of the RO assume the UF budget price to be $1MM and the RO to be $750K. The temperature may have to be reduced to be <100 F at the feed to the RO. Assume the operating cost to be $300k per yr. I hope that helps. Regards, Jack Cangiano Regional Manager Koch Membrane Systems Inc. 850 Main St. Wilmington, MA 01887 978-694-7114 jjcangiano©kochmembrane.com Fsn www.kochmembrane.com Original Message ---- From: Awtmailbox a@aol.com [mailto:Awtmailbox@aoLcom] Sent: Tuesday, February 24, 2009 12:14 PM To: Cangiano, Jack Subject: Chlorides Removal for 1.2 MGD Flow Page 2 of 3 Jack, Per our telephone conversation, here are some of the effluent characteristics. We would like to consider reuse of this w/w and would want to reduce the chlorides to <25 mg/I. Can you provide us with some preliminary budgetary costs for 1)capital installed cost, and 2}annual operating cost. Please call me if you have any questions. Thank you! Flow 1.2 MGD average, 1.5 MGD maximum Temperature 30 degrees C average, 47 degrees C maximum TSS 40 mg/I average, 114 mg/I maximum pH 7.88-9.0 COD 644 mg/l maximum, 241 mg/I average Chlorides 1000 mg/I if you need any other information, please call or e-mail. Thank You! Charles D. Blackwell Charles D. Blackwell, President/Environmental consultant APPLIED WATER TECHNOLOGY ,:IN C. (AWT) 311 South Academy Street Cary, NC 27511 Direct Phone: 919-466-9246 Cell: 919-418-6651 Main Phone: 919-773-0396 Fax: 866-850-0559 E-mail: awtmailbox a@aol.com Website: http://home.bellsouth.net/p/PWP-AWTINC A Good Credit Score is 700 or Above. See yours in just 2 easy steps!