NC0006190_Permit Issuance_20020515

NPDES DOCUMENT SCANNING COVER SHEET
NC0006190
Maiden Plant WWTP
NPDES Permit:
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Owner Name Change
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
May 15, 2002
Thin document is printed on reune paper - ignore any
cozztent on the re‘rerse side

State of North Carolina
Department of Environrnent
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Gregory J. Thorpe, Ph.D., Acting Director
May 15, 2002
Gene Hudgens, Plant Manager
Delta Apparel, Inc.
100 West Pine Street
Maiden, North Carolina 28650
AVA
NCDENR
Subject: Issuance of NPDES Permit NC0006190
Maiden Plant
Catawba County
Dear Mr. Hudgens:
Division staff have reviewed and approved your application for an NPDES discharge permit. Accordingly,
the Division is forwarding the subject NPDES permit. This permit is issued pursuant to the requirements of
North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and
the U.S. Environmental Protection Agency dated May 9,1994 (or as subsequently amended).
The following items appear in this FINAL permit:
• The draft permit included the addition of weekly influent and effluent color monitoring, as well as a
monthly average color limit requiring color reduction of > 90% between influent and effluent
samples. Delta Apparel objected to this draft limit, and requested additional time to evaluate color
control before any color limits are implemented. Subsequent to this draft permit, a public hearing
was held on August 28, 2001, for several NPDES permit renewals (including Delta) with color
discharges to the South Fork Catawba River watershed. Based on the public hearing and additional
data requested from Delta, the Hearing Officer prepared a Findings and Recommendations Report.
The report recommended that the effluent color limit for Delta be changed to phased ADMI
concentration -based limits. The Division Director concurred with this recommendation. The
phased limits incorporated in this final permit require the facility to meet average monthly effluent
color concentration limits of 863 ADMI (first 12 months), 720 ADMI (next 12 months), and 575
ADMI (remainder of permit). The average monthly effluent limit of 863 ADMI represents an 85%
color reduction from Delta's highest reported average monthly influent concentration (in October
2001), and this treatment level is technologically attainable. The final phased ADMI limit of 575
ADMI represents a 90% color reduction from the highest reported monthly average influent
concentration. The change from a percentage reduction limit to a concentration -based limit was
based on the fact that Delta's influent color has increased substantially since the 2000 baseline color
study, and a concentration -based limit will essentially cap color discharges to levels which should
minimize or eliminate adverse impacts on aesthetic quality. The Division will continue to evaluate
the potential for Delta to reduce color discharges further at the next permit renewal. This final
permit also requires Delta to monitor influent color on a weekly basis, and to record the type and
quantity of polymer used, as well as cost of polymer addition on a monthly basis.
• Addition of instream monthly summer monitoring for color, to track the success of the color
reduction measures.
• Addition of a Color Reopener Special Condition, which provides for additional monitoring and/or
color reduction studies if warranted by future stream conditions.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer Visit us on the INTERNET © www.enr.state.nc.us

Permit No. NC0006190
Delta Apparel- Maiden Plant
Page 2
• Please note that an Authorization to Construct (ATC) permit will be needed to convert the
temporary pilot study polymer treatment system for color removal to a permanent color treatment
system.
• Update to the chronic toxicity test language, which now requires different follow-up procedures for a
test failure.
• Deletion of weekly effluent monitoring for settleable solids, which was originally placed in the permit
as an indicator for color.
• Deletion of the effluent sheet for phased flow at 1.5 MGD, since the facility was able to implement a
production increase without a corresponding increase in flow, due to water conservation and reuse
efforts.
• Addition of instream monthly summer copper monitoring. The receiving stream is listed as impaired
for copper, and a copper Total Maximum Daily Load (TMDL) will be prepared over the next year.
Therefore, the instream monitoring is considered necessary to support the copper TMDL for Clark
Creek.
• Increase the effluent dissolved oxygen monitoring frequency from weekly to 3/Week based on
monitoring requirements specified in 15A NCAC 2B.0500.
• Decrease the effluent total .phosphorus and total nitrogen monitoring frequency from weekly to
monthly, based on monitoring requirements specified in 15A NCAC 2B.0500. This discharge is
currently located outside of the defined Lake Wylie Nutrient Management Area and not subject to
nutrient limitations. As indicated in the Catawba River Water Quality Basin Plan (1999), the full
effects of the nutrient management strategy are still being realized as facilities within the management
area implement TN and TP reduction measures. If future water quality conditions in Lake Wylie
indicate the need for additional nutrient controls, a reassessment of the defined management area
may be necessary.
• Decrease the effluent zinc, chloride, and sulfate monitoring frequency from weekly to 2/month,
based on monitoring requirements for non -limited toxicants specified in the NPDES Monitoring
Frequency Policy.
• Based on comments received from US EPA, the ammonia limit should be expressed as a monthly
average limit as well as a daily maximum limit. This final permit only contains a monthly average
limit. Therefore, a new Special Condition A (4)- Ammonia Reopener- has been added to this final
permit. The Division may reopen this permit and add a daily maximum ammonia limit if there is
reasonable potential for this discharge to exceed allowable concentrations. If there is not reasonable
potential, then a daily maximum ammonia limit will be developed and added at the next permit
renewal.
Please note that the receiving stream (Clark Creek) is listed as an impaired water in North Carolina's 303(d)
list. The stream segment containing the Delta discharge is listed as biologically impaired due to unknown
causes, while the most downstream segment is listed as impaired due to copper, fecal coliform bacteria, and
turbidity. The Division's Special Watersheds Unit will perform a thorough assessment of watershed
conditions and develop a comprehensive restoration plan by 2003. If there is noncompliance with permitted
effluent limits and degradation of Clark Creek can be attributed to point source dischargers, then mitigative
measures may be necessary.
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.

Permit No. NC0006190
Delta Apparel- Maiden Plant
Page 3
This permit is not transferable except after notice to the Division. The Division may require modification or
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, the Division of Land Resources, the Coastal Area Management Act, or any other
federal or local governmental permit.
If you have any questions concerning this permit, please contact Tom Belnick at telephone number (919)
733-5083, extension 543.
Sincerely-,
cc: Dee Stewart, EPA Region 4
Donna Lisenby, Catawba Riverkeeper, 2295 Starnes Road, Edgemoor, SC 29712
Mooresville Regional Office, Water Quality Section
Point Source Compliance Enforcement Unit
Central Files
NPDES File
Aquatic Toxicology Unit
Technical Assistance & Certification Unit

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 June 1, 2002.
This permit and the authorization to discharge shall expire at midnight on July 31, 2005.
Signed this day May 15, 2002
v 4.0"4
Gregory ""• • .•e, Ph.D.
Divisio T f W er Quail
By Authority of the Environmental Management Commission

Permit No. NC0006190
SUPPLEMENT TO PERMIT COVER SHEET
Delta Apparel, Inc.
is hereby authorized to:
1. Continue to operate an existing 1.0 MGD 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
• dual secondary clarifiers
• post aeration
• 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.

L
Latitude: 35° 34' 38"
Longitude: 81° 14' 13"
USGS Quad #: E14SW
River Basin #: 03-08-35
Receiving Stream: Clark Creek
Stream Class: C
Nt
Delta Apparel, Inc.
Catawba County
NC0006190 '

Permit No. NC00061 y0
S
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
MONITORING REQUIREMENTS
EFFLUENT LIMITATIONS
CHARACTERISTICS
Monthly
Average
Daily Maximum
Measurement
Frequency
Sample
Type
Sample Location'
Flow
r
1.0 MGD
Continuous
Reconf'mg
Influent or Effluent
BOD, 5-day, 20°C
162 pounds/day
325 pounds/day
3/Week
Composite
Effluent
COD
2900 pounds/day
6800 pounds/day
Weekly
Composite
Effluent
Total Suspended Solids
785 pounds/day
1853 pounds/day
3/Week
Composite
Effluent
NH3 as N
3.0 mg/L
3/Week
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
437 pg/L
Weekly
Composite
Effluent
PH
6 < pH < 9
. 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
2/Month
Composite
Effluent
Sulfates
2/Month
Composite
Effluent
Total Nitrogen
(NO2+NO3+TKN)
Monthly
Composite
Effluent
Total Phosphorus
Monthly
Composite
Effluent
Chronic Toxicity3
Quarterly
Composite
Effluent
Color*
863 ADMI (6/1/02-5/31/03)
720 ADMI (6/1/03-5/31/04)
575 ADMI (6/1/04-7/31/05)
Weekly
Composite
Influent and Effluent
Color (April - October)
Monthly
Grab
Upstream & Downstream
Total Copper (April - October)
Monthly
Grab
Upstream & Downstream
Dissolved Oxygen
3M/eeks
Grab
Upstream & Downstream
Temperature
3Meeks
Grab
Upstream & Downstream
Conductivity
3/Weeks
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 11%; March, June, September. December. refer to Special Condition A (2).
4. The effluent color limit is a phased monthly average ADMI concentration limit. Refer to Special Condition A (3).
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 Ceriodaphnfa dubia at an effluent concentration of 11%. The permit holder shall perform at a
minimum, quarterly monitoring using test procedures outlined in the "North Carolina Certodaphnta
Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent versions or "North Carolina
Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent
versions. 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, using the parameter
code TGP3B for the pass/fail results and THP3B for the Chronic Value. Completed Aquatic Toxicity Test
Forms shall be filed with the Environmental Sciences Branch no later than 30 days after the end of the
reporting period for which the report is made. Additionally. DWQ Form AT-3 (original) is to be sent to the
following address:
Attention: Environmental Sciences Branch
North Carolina Division of Water Quality
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
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 Branch 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.
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). COLOR PERMITTING REQUIREMENTS FOR TIER 4 FACILITY
This facility has been classified as a Tier 4 color discharger. The permittee will conduct color monitoring
of instream stations (upstream, downstream) on a monthly basis during summer season (April -October).
The permittee will record whether a color plume was observed around the outfall pipe during the monthly
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 grabs. Samples will be analyzed by a state certified
laboratory. The influent monitoring station nwlll�� n �located n�y Drior to Msubmission: er . l�typee cility
and
must also provide the following monthly
quantity of polymer added; and 2) cost of polymer addition.
The permittee has received phased effluent color limits that become effective at the permit effective date.
These limits require compliance with a monthly average concentration limit of 863 ADMI (6/ 1 /02-
5/31 /03), 720 ADMI (6/ 1 /03-5/31 /04), and 575 ADMI (6/ 1 /04- permit expiration).
The permittee will also prepare a Pollution Prevention/Best Management Practices (BMPs) report. This
report will address the potential for the facility to reduce effluent color by incorporating pollution
prevention measures and/or BMPs prior to treatment. This report could include an evaluation of the
dyeing process, looking at the potential for dye substitution, improving dyeing efficiencies, etc. The report
could also investigate whether any BMPs could be implemented that would reduce the amount of color
discharged to the treatment plant. The permittee could do this work independently, or request voluntary
assistance from the North Carolina Division of Pollution Prevention and Environmental Assistance. The
permittee will also prepare a Color Reduction Study, which will involve an end -of -pipe treatment
evaluation that develops cost estimates for reducing effluent color beyond the required effluent color
limitations. Both reports will be submitted within 24 months of the permit effective date.
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.
A (4). AMMONIA REOPENER
The Division may re -open this permit to require daily maximum limits for ammonia. After calculating
allowable concentrations, the Division will perform an analysis of past ammonia data to determine if there
is a reasonable potential for this discharge to exceed these potential limits. If there is, this permit will be
re -opened. If there is not, the permit will not be re -opened, but will contain daily maximum limits for
ammonia upon renewal.

&Id aitiC.t1f'
3e' ° S74,
yZ
1SW
'14 PRO�O
May 2, 2002
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
Mr. Dave Goodrich, Supervisor
NPDES Unit
Division of Water Quality
North Carolina Department of Environment and
Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
SUBJ: NPDES Permit for Delta Apparel, Inc.
Permit No. NC0006190
Dear Mr. Goodrich:
.;02
v.. 'i - 's: )-ER C'•';il.17Y
Su'j \C F ,f CH
In accordance with the EPA/NCDENR MOA, we have completed our review of the draft
permit referenced above and received by EPA Region 4 on April 17, 2002. We request that we
be afforded an additional review opportunity only it' significant changes are made to the permit
prior to issuance, or if additional significant comments to the permit are received. Otherwise,
please send us one copy of the final permit when issued. It is noted that the ammonia limit is
expressed as only a monthly average limit with a ammonia re -opener clause addressing a possible
future daily maximum limit. EPA Region 4 understands that this evaluation will be done in
October, 2002, and the permit re -opened if necessary. If you have any questions, please feel free
to contact me [phone] or at [e-mail]
07\si
10'\1/2('\Vr WI°
Sincerely,
Dee Stewart
Program Manager
Permits, Grants and Technical Assistance Branch
NPDES & Biosolids Section
Water Management Division
Internet Address (URL) • http://www.epa.gov
Recycled/Recyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer)

Re: Delta Apparel
Subject: Re: Delta Apparel
Date: Wed, 13 Feb 2002 14:58:23 -0500
From: [e-mail]
To: [e-mail]
Thanks Tom. I am looking forward to getting the revised draft. If you
remember, throw in the 1998 mod and I will put it in the file.
Dee
Tom Belnick
<tom.belnick@n
cmail.net>
02/11/2002
02:44 PM
Hi Dee- here's the lowdown at this point:
To:
cc:
Subject:
Dee Stewart/R4/USEPA/US@EPA
Re: Delta Apparel
1. Color. There was a public hearing that focused strictly on the color
issue for several dischargers back on 8/28/01. Delta objected to the
proposed color limit in the draft calling for 90% removal; they did not
think they could achieve this, and wanted more time to evaluate color
removal technologies. There were a few commenters at the hearing who
supported the color limit, with the Catawba Riverkeeper being the
primary focal point. DWQ subsequently requested additional data from
Delta on their color removal testing using polymer addition. Based on
the new data, the NPDES Unit recommended changing the color limit to
absolute ADMI values (based on 85% removal initially, going to 90%
removal in the third year of the permit), and with the limit still
effective with the permit renewal. The Hearing Officer for the 8/28/01
Public Hearing just submitted his recommendations to the DWQ Director,
so we will proceed with permit finalization after the Director makes his
final decision (within 30 days). I will submit a revised Fact Sheet and
Final Permit to you for review prior to final issuance. If we proceed
to quantitative color limits, we will also discuss the changes with the
Catawba Riverkeeper.
2. Effluent Guideline Limits. DWQ prepared a permit modification on
January 28, 1998 which added an effluent sheet for 1.5 MGD, and also
re-evaluated the EGLs for current production at 1 MGD. I used the exact
EGLs in the 1998 permit mod for the permit renewal, despite an increase
in production. Let me know if you need the 1998 mod, which was cc'd to
Roosevelt.
Let me know if you have further questions. I'll be on vacation Tuesday
-Friday, but back in next Monday.
[e-mail] wrote:
Tom,
I have the following questions/comments concerning the Delta
Apparel
1 of 2 2/18/02 10:52 AM

Re: Delta Apparel
Maiden Plant, NC0006190.
1) Delta opposed color provisions in a 8/20/01 letter. What is
the
status of the color conditions in the draft permit?
2) I noticed that there was a public hearing on this permit. Were
significant public comments received? If so, was the draft
significantly revised based on comments? (I did not see a
revised
draft in the file)
3) Fact sheet stated that effluent guideline limits were frozen
from
the previous permit, but it appears that there were some changes.
TSS
daily max increased, COD daily max increased, TSS monthly average
increased, and BOD daily max increased by 1/2 lb/day. Why? I did
not
see an explanation or any EGL calculations in FS and it appears
that the
FS contradicts the permit limit. Please clarify.
Thanks for your response.
Dee Stewart
EPA R4
404/562-9334
Mailto:[e-mail]
N.0 DENR-DWQ/NPDES Unit
1617 Mail Service Center, Raleigh NC 27699-1617
Work: [phone] ext. 543
Fax: [phone]
2 of 2 2/18/02 10:52 AM

NC0006190; Delta Appare
• Subject: NC0006190; Delta Apparel
Date: Wed, 17 Apr 2002 11:09:32 -0400
From: Tom Belnick <[e-mail]>
To: [e-mail]
Hi Dee- Its been a few months since we discussed this permit. I've just updated the material and will send
them down to you (hopefully I'll hand off to Roosevelt who is up here today). The updated packet will
include the following items:
• Revised (FINAL) Fact Sheet- which now includes the Hearing Officer Report for the Public
Hearing.
• Final Permit- which reflects changes made to the draft color limit, changing it from a percent
removal to an absolute concentration limit.
• Written comments received on draft permit.
• The 1998 permit mod that you requested earlier.
Let me know if you need additional info, and what comments you have on these revisions. I'm hoping to
prioritize this one, since we're just starting to issue some of the final permits for color dischargers involved
in the 8/28/01 public hearing. Thanks.
Mailto:[e-mail]
N.0 DENR-DWQ/NPDES Unit -
1617 Mail Service Center, Raleigh NC 27699-1617
Work: [phone] ext. 543
Fax: [phone]
1 of 1 4/17/02 11:10 AM

a i
CM at, _ -6c reVrehr /goof- fu 1 Nri,637
/ A rut i ISSW44Cr i I{
NCDENR / DWQ
FINAL FACT SHEET FOR NPDES PERMIT DEVELOPMENT
Delta Apparel, Inc.
NPDES No. NC0006190
Facility Information
(1.) Facility Name:
Maiden Plant
(2.) Permitted Flow,MGD:
1.0 MGD
(6.) County:
Catawba
(3.) Facility Class:
III
(7.) Regional Office:
Mooresville
(4.) Facility Status:
Existing
(8.) USGS Topo Quad:
E14SW
(Maiden NC)
(5.) Permit Status:
Renewal
Stream Characteristics
(1.) Receiving Stream:
Clark Creek
(2.) Subbasin:
030835
(8.) Drainage Area (rni2):
66.00
(3.) Stream Index No.:
11-129-5-(0.3)
(9.) Summer 7Q10 (cfs)
12
(4.) Stream Class:
C
(10.) Winter 7Q10 (cfs):
25.5
(5.) 303(d) Listed:
YES
(11.) 30Q2 (cfs):
34
(6.) 305(b) Status:
(12.) Average Flow (cfs):
78.00
(7.) Use Support:
PS
(13.) IWC (%):
11% at 1 MGD
Conditions Incorporated into Draft Permit Renewal
Proposed Conditions
Parameters Affected
Basis for Condition(s)
Add weekly effluent and influent
color monitoring. as well as a
monthly average color limit
requiring 90% color reduction
between influent and effluent
samples.
Effluent- Color Limit
Per DWQ NPDES Color
Permitting Policy dated 6/5/01.
This facility was classified as a
Tier 4 color discharger based on
a significant color plume and
downstream aesthetic impact.
Add Color Special Condition
Special Condition- Color
Per DWQ NPDES Color
Permitting Policy dated 6/5/01.
Special Condition provides for
permit reopener for more
stringent color requirements if
needed. and also details the
color monitoring requirements.
Add instream (up/down)
monthly summer monitoring.
Instream- Color
Per DWQ NPDES Color
Permitting Policy dated 6/5/01.
Update the chronic toxicity test
language.
Effluent- Chronic Toxicity
Toxicity test language updated
9/99 with specific folowup
requirements.

NPDES PERMIT FACT SHEET
Page 2
Delta Apparel, Inc.
NPDES No. NC0006190
Remove weekly monitoring
requirement
Effluent- settleable solids
This parameter had been added
as an indicator of color in the
previous permit. New permit will
have direct color monitoring.
Delete effluent sheet for phased
flow at 1.5 MGD.
Effluent Sheet- for phased flow
at 1.5 MGD
Facility has been able to increase
production without need for
additional flow, due to water
conservation and reuse efforts.
These limits are production -
based. Maintain same
production -based limits as last
permit with same monitoring
frequencies.
Effluent Guideline Limits- BOD5,
TSS, pH, sulfide, phenols, COD
Facility is subject to federal
effluent guideline limits per 40
CFR 410 Subpart E. Although
production has increased,
maintain same limits due to
impaired stream status and
facility's ability to meet current
limits. Although there are
effluent guidelines for chromium,
the more stringent water -quality
limit is applied in this permit
(see below).
Maintain same WQ-based limits
as last permit with same
monitoring frequencies.
WQ-Based Effluent Limits
NH3, DO, Chromium
No reason to delete NH3 or DO.
Although chromium showed no
reasonable potential, the WQ-
based limit is more stringent
than the corresponding
production -based limit.
Therefore, WQ-based limit must
be maintained.
Add instream (up/down)
monthly summer monitoring.
Instream- Copper
A copper TMDL will be prepared
for Clark Creek, and this
instream data will assist in
TMDL development. The facility
is already monitoring copper in
effluent on a weekly basis. The
effluent copper data showed
reasonable potential, but no
effluent limit is applied based on
Action Level Policy and results of
effluent toxicity testing.
Increase monitoring from weekly
to 3/Week
Effluent- Dissolved Oxygen
Per monitoring requirements
specified for textile processing in
15A NCAC 2B.0500.
Decrease monitoring frequency
from weekly to monthly.
Effluent- TP and TN
Per 15A NCAC 28.0500
monitoring requirements
specified for Catawba River
Basin for facilities with Qd> 1.0
MGD.
Decrease monitoring frequency
from weekly to 2/Month.
Effluent- zinc, chloride, sulfate
NPDES Policy is 2/Month
monitoring frequency for non -
limited toxicant, Grade 3 facility.
Zinc and chloride did not show
reasonable potential to exceed
the state Action Levels, and
there is no applicable criteria for
sulfate.
Page 2
Version: April 17, 2002

NPDES PERMIT FACT SHEET
Page 3
Delta Apparel, Inc.
NPDES No. NC0006190
Additional Changes Incorporated into Final Permit Renewal
Proposed Conditions
Parameters Affected
Basis for Condition(s)
Change the effluent color limit
Effluent- Color Limit
A 90% color removal rate was
proposed in the draft (a 90%
proposed in the draft permit.
color removal rate between
Based on the subsequent public
influent and effluent samples
hearing and additional data
based on monthly average
requested from Delta, the Public
values) to a phased monthly
Hearing Officer prepared a
average absolute ADMI
Findings and Recommendations
concentration (863 ADMI units
Report. The report recommends
for year 1: 720 ADMI units for
that the effluent color limit be
year 2; and 575 ADMI units for
changed to phased ADMI
remaining permit period).
concentration -based limits,
which are incorporated in this
final permit. The phased limits
represent an 85-90% reduction
in color from Delta's highest
reported average monthly
influent concentration (in
October 2001). The change from
a percentage reduction limit to a
concentration -based limit was
based on the fact that Delta's
influent color has increased
substantially since the 2000
baseline color study, and a
concentration -based limit will
essentially cap color discharges
to levels which did not appear to
aesthetically -impact the
receiving stream. The Division
will continue to evaluate the
potential for Delta to reduce
color discharges further at the
next permit renewal.
Add Special Condition A (4)-
Effluent- Ammonia
This permit has a monthly
Ammonia Reopener- which
average ammonia limit based on
provides for the permit to be
water quality. EPA commented
reopened to allow addition of a
that the permit should have both
daily max limit if reasonable
monthly average and daily max
potential exists. Otherwise, daily
effluent limits for ammonia. The
max limit will be added at next
Ammonia Special Condition was
permit renewal.
added to resolve this issue.
PROJECT NOTES
A. Facility Summary
This is a permit renewal for a 1.0 MGD (Grade III) textile facility which knits, dyes, and
manufactures cotton t-shirts. The facility discharges 100% process wastewater, while all
domestic wastewater is treated at the Town of Maiden WWTP. At current permitted flow (1
MGD), each aeration basin would provide approximately 60 hours retention time. Sludge is
land applied under permit WQ0006984.
Page 3
Version: April 17, 2002

NPDES PERMIT FACT SHEET Delta Apparel, Inc
Page 4 NPDES No. NC000619
Facility was originally permitted in 1970s and operated as Duckhead Apparel. A 1992 A
authorized relocation of outfall from Shady Branch to current location on Clark Creek. Base
on planned production increases, permit was modified in January 1998 to allow expansio
from 1.0 to 1.5 MGD after receiving an ATC. Permit was modified in 2000 to change name fro
Delta Mills Inc to Delta Apparel Inc.
Facility discharges through a 7,500-foot pipe to Clark Creek, approximately 100-ft above the
Town of Maiden's discharge point, and several miles below the Town of Newton discharge.
Clark Creek flows into South Fork Catawba River, then into Lake Wylie. Most of Clark Creek is
considered impaired, and the DWQ Special Watersheds Unit will develop a comprehensive
restoration plan by 2003. The subject stream segment is C Class, Partially Supporting, and
listed in the Draft 2000 303d list as biologically impaired due to unknown causes. In the most
downstream portion of the creek (WS-IV class), fecal coliform, copper, and turbidity are
identified as causes of impairment, with TMDLs proposed for fecals and copper.
B. Permit Development
Renewal Application. The NPDES permit renewal application was received on 2/1/2000. The
renewal application included the necessary application form and production data. As required
by 40 CFR 122 for Primary Industry Categories, the permittee also submitted a priority
pollutant analysis of its effluent.
Production Data/Facility Status. The facility is currently legally operating under the previous
permit which expired on 7/31/2000. The production -based limits in the January 1998 permit
were based on production values of 72,050 lbs/day (used for monthly average) and 85,000
lbs/day (used for daily max). For the permit renewal, the facility provided production data for
the 1997-2000 calendar years. Production (in lbs finished product/year) has increased 48%
over this timeframe. The maximum monthly (5-week) production reported was 4,184,505 lbs
finished product in October 2000, which translates to a daily maximum production of 119,557
lbs finished product/day. This increased production was achieved without additional
wastewater discharge. In 1999 Delta replaced its existing dyeing and bleaching equipment with
modem low ratio dyeing machines at an approximate cost of $2.4 million, which reduced
Delta's water consumption by 30%. Consequently, the phased 1.5 MGD effluent sheet will be
deleted, since the facility has expanded production while maintaining compliance with the 1
MGD effluent limits.
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 documented increase in production between 1997-2000, the Division has elected to
freeze the EGL limits at the January 1998 permit levels (which were based on 1995-97
production rates) due to the impaired stream status and the ability of the permittee to already
meet these more stringent limits. 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 permit included water -
quality based effluent limits for ammonia, dissolved oxygen, and chromium. All three of these
limits have been retained in the draft renewal. Based on reasonable potential analysis (RPA;
attached) of chromium data for the period 9/99-8/00, there is no reasonable potential to
exceed the instream chromium water quality standard. However, since the WQ-based limit is
more stringent than the corresponding effluent guideline limit, the WQ-based chromium limit is
retained with a weekly monitoring frequency.
The previous ' permit included monitoring -only for copper, zinc, and chloride, which are
regulated by the NC Action Level Policy. The RPA showed no potential for zinc or chloride to
exceed state action levels, therefore no WQ-based limits will be added, but monitoring will be
retained at a reduced monitoring frequency of 2/Month. The RPA for copper did show potential
to exceed the state action level. Per the Division Action Level Policy, no copper limit is applied
Page 4
Version: April 17, 2002

NPDES PERMIT FACT SHEET Delta Apparel, Inc.
Page 5
NPDES No. NC0006190
since it has not been demonstrated to cause effluent toxicity. However, monitoring of the
effluent for copper will remain at a weekly frequency. In addition, due to the impending copper
TMDL to be prepared for Clark Creek, copper monitoring has been added to instream stations
during summer (monthly) to assist in the TMDL development. There is no Class C WQS or EPA
WQC for sulfate, therefore monitoring will be reduced from weekly to 2/Month based on NPDES
monitoring policy requirements.
The submitted priority pollutant analysis (PPA) showed no reported detections of
Pesticide/PCBs, Base/Neutral/Acids, or Volatile organic compounds. Detected total metals are
summarized in Table 1 below. Based on this PPA data, no additional WQ-based limits are
warranted at this time. Most reported effluent concentrations are below applicable
criteria/standards, without consideration of an 8.74 dilution factor. The action level metals
copper and zinc will be monitored as discussed above.
Table 1. Delta Mills Detected Chemicals from Priority Pollutant Analysis
o s e'.
'` 1 o c. _ ,
I ,rt a. G - -
CCbncluston
Antimony
2.5
4,300 (EPA, HH)
No action needed
Cadmium
0.21
2.0 (NC WQS, Aq Life)
No action needed
Copper
44
7 (NC AL, Aq Life)
See above discussion
Nickel
4
88 (NC WQS, Aq Life)
No action needed
Selenium
0.4
5 (NC WQS, Aq Life)
No action needed
Silver
0.01(=MQL)
0.06 (NC AL, Aq Life)
No action needed
Zinc
13
50 (NC AL, Aq Life)
See above discussion
Footnotes:
HH- Human -health standard/criteria; WQS- water quality standard; AL- Action Level; Aq Life- Aquatic Life
MQL- Minimum quantitation level
Color. There are no Federal water quality criteria for color. The state has a narrative water
quality standard for color, which allows color only in such amounts "as shall not render the
waters injurious to public health, secondary recreation or to aquatic life and wildlife or
adversely affect the palatability of fish, aesthetic quality or impair the waters for any designated
uses." The aesthetic impact has been the overriding concern with textile dischargers.
Delta Mills joined the South Fork Catawba River Water Quality Alliance, which funded a
comprehensive color monitoring study of the South Fork Catawba River watershed from April
through November 2000. Based on this monitoring data, the Division developed an NPDES
Color Permitting Policy (attached) which addressed the color issue. Delta Mills was classified as
a Tier 4 color discharger requiring color limits, based on the significant aesthetic downstream
impact that the discharge exerts. During summer low flow conditions, the color plume was still
visible at the furthest downstream station located 7.8 miles below the outfall in Clark Creek.
The draft permit included the addition of weekly influent and effluent color monitoring, as well
as a monthly average color limit requiring color reduction of > 90% between influent and
effluent samples. Delta Apparel objected to this draft limit, and requested additional time to
evaluate color control before any color limits were implemented. Subsequent to the draft
permit, a public hearing was held on August 28, 2001, for several NPDES permit renewals
(including Delta) with color discharges to the South Fork Catawba River watershed. Based on
the public hearing and additional data requested from Delta, the Hearing Officer prepared a
Findings and Recommendations Report. The report recommended that the effluent color limit
for Delta be changed to phased ADMI concentration -based limits, which are incorporated in the
final permit, and which take effect on the permit effective date.. The Division Director
concurred with this recommendation. The phased limits require the facility to meet average
monthly effluent color concentration limits of 863 ADMI (first 12 months), 720 ADMI (next 12
months), and 575 ADMI (remainder of permit). The average monthly effluent limit of 863 ADMI
represents an 85% color reduction from Delta's highest reported average monthly influent
concentration (in October 2001), and this treatment level is technologically attainable. The
Page 5
Version: April 17, 2002

F.
NPDES PERMIT FACT SHEET Delta Apparel, Inc.
Page 6
NPDES No. NC0006190
final phased ADMI limit of 575 ADMI represents a 90% color reduction from the highest
reported monthly average influent concentration. The change from a percentage reduction limit
to a concentration -based limit was based on the fact that Delta's influent color has increased
substantially since the 2000 baseline color study, and a concentration -based limit will
essentially cap color discharges to levels which did not appear to aesthetically -impact the
receiving stream. The Division will continue to evaluate the potential for Delta to reduce color
discharges further at the next permit renewal. This final permit also requires Delta to monitor
influent color on a weekly basis, and to record the type and quantity of polymer used, as well
as cost of polymer addition on a monthly basis. Table 2 summarizes the color data collected
for Delta during Summer 2000.
Table 2. Delta Mills Color Monitoring Data for Summer 2000
Samplae
trearn.
r Ca i a1'or
~-awnstr ami _
° Wit. _
- ito?r
- -- ar r e +
= :Vi ilfs::. _ : -:i
T._ or .. i
04/11/00
78
54
1550
70
04/25/00
156
149
921
180
05/16/00
49
65
1740
72
05/31/00
60
75
1780
70
06/13/00
66
61
1110
62
06/27/00
77
89
1180
65
07/11/00
<20
91
1360
44
07/25/00
76
80
1380
65
08/08/00
48
71
1590
50
08/22/00
48
99
1650
41
09/06/00
86
91
1520
57
09/19/00
133
133
1830
170
10/03/00
41
71
1350
50
10/17/00
26
122
1810
50
11/14/00
35
81
2097
51
Notes:
Upstream station located 0.87 miles above outfall.
Downstrean station located 2.0 miles below outfall.
ADMI color reported at pH 7.6
C. DMR Data.
Effluent Chemical Data. Table 3 summarizes the effluent data set reported for a one-year
period from 9/99 to 8/00. There were no violations of monthly average permit limits. The BOD
mass loading rates equate to monthly average BOD concentrations of 1.9-2.7 mg/1.
Table 3. Delta Mills Effluent Data for Calendar Year 9/99-8/00
,- o ete -
i
n #Inilxlge "
r 10onderitra o L : _ . _ _ r _ _. _. _
Jr- Jr
G.k) pania?r _i
-,
1era .- t
Flow
0.72- 0.90 MGD
1.0 MGD
YES
BOD5
14- 18 lbs/day
1621bs/day
YES
NH3-N
<0.5 - 0.6 mg/1
3.0 mg/1
YES
TSS
59- 109lbs/day
7851bs/day
YES
COD
675- 1174 lbs/day
2900 lbs/day
YES
Sulfide
< 0.7- 2.3 lbs/day
8.0 lbs/day
YES
Phenol
<0.03 - 0.15 lbs/day
4.0 lbs/day
YES
Page 6
Version: April 17, 2002

NPDES PERMIT FACT SHEET
Page 7
Delta Apparel, Inc.
NPDES No. NC0006190
Chromium
0.7-59 ug/1 (Daily Max)
437 ug/1 (DM)
YES
TN
5 - 26 mg/1
No Limit
No Limit
TP
2
2- 12 mg/1
No Limit
No Limit
Settleable Matter
Generally < 0.1 ml/1
No Limit
No Limit
Sulfate
50-16,200 mg/1
No Limit
No Limit
Conductivity
Generally 3000-6000 umho/cm
No Limit
No Limit
Copper
10-120 ug/1
No Limit
No Limit
Zinc
25-110 ug/1
No Limit
No Limit
Chloride
643-23,200 ug/1
No Limit
No Limit
Effluent Toxicity Data. The facility passed the quarterly chronic toxicity test 17 of 19 times
between 1996-2000. The two failures were reported in 2000, with reported values of 4.1% and
<3%, versus an IWC of 11%. Passing results must be > 11%. Delta believes that the toxicity
failures resulted from the concentration of salts used in textile dyes, due to the reduction in
wastewater flow after implementation of water conservation measures. In response, Delta
began increasing the use of low -salt dyes in its dyeing processes. The last three toxicity test
conducted in 2000 received passing grades.
Instream Data. The facility collects instream data for temperature, DO, and conductivity.
Table 4 summarizes DO data for Summer 2000, which shows there were several occasions
when the instream DO was near the WQS of 5 mg/1. As indicated above, Delta is currently
treating oxygen -consuming wastes (BOD, NH3) to low levels.
Table 4. Delta Mills/Instream DO data for Summer 2000
Date
Upstream DO
Mg/1
Downstream DO
Mg/1
6/28/00
6.2
5.1
7/12/00
5.2
5.0
7/13/00
5.8
5.0
8/1/00
5.4
5.1
8/2/00
5.3
5.1
8/3/00
4.8
5.0
8/31/00
5.8
5.0
9/13/00
5.4
5.3
9/26/00
5.5
5.3
D. Waste Load Allocation Data.
The last WLA based on effluent guideline calculations were prepared 1995 (last renewal) and
1997 (permit mod). The last Level B DO model analysis conducted in 1997 predicted an
increase to 300 lb/day BOD5 would not impact the DO downstream of the outfall. However,
BOD5 limits have been frozen at 162 lbs/day since 1995. Since actual instream data collected
during Summer 2000 shows DO values near the water quality standard of 5.0 mg/1, it is
recommended that BOD and NH3 limits be maintained at current loads.
E. Enforcement
There were no enforcement cases against Delta from 1/94 to 3/00. In August 2000 the facility
received an NOV and assessment of civil penalty for $2,097 for two chronic toxicity failures
reported in March and April 2000.
F. Mooresville Region Data.
The MRO submitted a staff report dated 6/26/00, and recommended permit renewal pending
approval of the Waste Load Allocation. The MRO conducted a compliance evaluation inspection
on 1 /21 /99 and found the facility to be well maintained and in good operational condition.
Page 7
Version: April 17, 2002

QPA
REASONABLE POTENTIAL ANALYSIS•
Prepared by: Tom Belnick, 10/30/00
Facility Name =
Delta Mills
NPDES # =
NC0006190
Qw(MGD)=
1
Qw (cfs) =
1.5472
7Q10s (cfs)=
12
IWC(%)=
11.44I
Chronic CCC w/s7Q10 dil.
Acute CMC w/no dil.
Frequency of Detection
Conclusion
Parameter
FINAL RESULTS, ug/I
FINAL RESULTS, ug/I
#Samples
# Detects
Arsenic
Max. Pred Cw
Allowable Cw
Cadmium
•4.
Max. Pred Cw
'
Allowable Cw
Chromium
t ,I<
Max. Pred Cw
135.7 Nv ram"
II?'"
Allowable Cw
437.1 b,41�V
- 1022
52
45
L) ni i T
Lead
Max. Pred Cw
Allowable Cw
Copper (A.L.)
Max. Pred Cw
180.0
oA Liv+ e0b
Allowable Cw
61.2
7.3
52
52
MONITOR
Nickel
Max. Pred Cw
Allowable Cw
Silver (A.L.)
Max. Pred Cw
Allowable Cw
Zinc (A.L.)
Max. Pred Cw
165.0
Allowable Cw
437.1
67
52
52
_ fVIONIT01t-
Cyanide
Max. Pred Cw
Allowable Cw
Mercury
Max. Pred Cw
Allowable Cw
Molybdenum
Max. Pred Cw
Allowable Cw
Selenium
Max. Pred Cw
Allowable Cw
Fluoride
Max. Pred Cw
Allowable Cw
Chloride(A.L.)
Max. Pred Cw
67280.0
Allowable Cw
2010645.2
860,000
52
52
MONITOR,
Modified Data: Use 0.5 Detection Limit for non -detects
we-E1«y
WeEKL'
ZifyloNTH

Division of Water Quality
Point Source Branch/NPDES Unit
June 5, 2001
MEMORANDUM
To: Tommy Stevens
Through: Coleen S
Bill Reid
Dave Go ' rich
From: Tom Belnick
ectrzbik.7
Subject: NPDES Color Permitting Policy
Catawba River Basin Color Dischargers
This NPDES Color Permitting Policy addresses eight color dischargers in the South Fork
Catawba River watershed (subbasins 030835 and 030836). The policy provides for a tiered
permitting approach, ranging from color monitoring for facilities showing no color plume, up to
color reduction limits for facilities exhibiting major color plumes and downstream aesthetic
impacts.
Background. The South Fork Catawba River watershed was identified in previous basin plans
as having a high concentration of textile dischargers, along with public concerns and
complaints regarding color from such discharges. In August 1999 the Division met with
selected color dischargers in the watershed to address the color issue. As a result of this
meeting, eight color dischargers (Pharr Yarns, Delta Mills, Yorkshire, Cramerton, Lincolnton,
Gastonia -Long Creek, Hickory, and Cherryville) elected to form the South Fork Catawba River
Water Quality Alliance and undertake a comprehensive color monitoring study to identify
current color problem areas in the watershed. The color monitoring was conducted twice per
month from April through November 2000, and included color monitoring of effluent,
upstream and downstream stations, as well as reference sites. The study included analytical
color measurements (ADMI units), visual observations, and photographs. The study period
included an extremely dry summer, and should represent worst case conditions. In addition,
the study represents the most current assessment of color conditions in the watershed, given
the changing nature of textile facilities across the state. The Alliance submitted individual
reports to the Division for each sampling event, as well as a Final Color Study Report (AWARE
Environmental, Inc., March 2001). One color discharger in the watershed (City of Newton)
elected to evaluate color independently from the Alliance members, using similar monitoring
protocols.
Color Regulation. According to state regulation [15A NCAC 02B.0211(3)(f)], colored effluent is
allowed in "only such amounts as shall not render the waters injurious to public health,
secondary recreation or to aquatic life and wildlife or adversely affect the palatability of fish,
aesthetic quality or impair the waters for any designated uses." To date, there are no data to
show that the colored effluent is posing a human health concern, or that color is a source of
impact on the aquatic biota. Therefore, aesthetic concerns are the primary issue associated
with the narrative color standard.
NPDES Color Permitting Policy
Page 1 of 5

Data Evaluation. The evaluation of color as an aesthetic impact is difficult since it is a
subjective determination. In addition, a host of factors, such as hue, instream turbidity,
suspended matter, dilution, light conditions, and downstream access all play a part in
determining when a color impact might be perceived by the public.
The ADMI method used to measure color quantitatively in the study takes into account the
entire visible spectrum, and was originally developed to be related to visual perceptibility.
During data review, it was realized that ADMI color measurements do not always predict the
potential for a color impact. For example, a color plume with downstream aesthetic impact
was observed at Cherryville on several sampling events, although the effluent ADMI color was
low (summer average = 63 ADMI) and similar to upstream values. The plume was likely due to
the particular hue of the effluent and the low instream dilution, rather than an absolute ADMI
value. In this situation, consideration of a numerical instream ADMI color standard would be
ineffective. However, requiring some percentage reduction in effluent color would help to
minimize the size of the color plume. Conversely, some facilities with greater colored effluent
(e.g., Pharr Yarns and Yorkshire with summer averages of 844 and 3449 ADMI units,
respectively) did not produce major instream color plumes, most likely due to the effluent hue
as well as the large dilution available. Therefore, in order to evaluate the data, it was realized
that no single criterion, but rather a combination of ADMI measurements, photographs, and
plume descriptions were needed to fully assess the instream color conditions.
Specific data utilized from the Final Color Study Report submitted by the Alliance included: 1)
frequency of plumes observed at the outfall (see Appendix A, Table 5-2); 2) frequency of
visual color change at the downstream station (see Appendix A, Table 5-1); and 3) statistical
color difference between upstream and downstream stations during summer (see Appendix A,
Table 4-2). The study reported that Pharr Yarns was the only facility that did not produce a
color plume at the outfall at any time during the study, while for the remaining facilities, color
plumes were reported observed at the outfalls from 60% to 100% of the time. The study also
reported that visual changes in downstream color were observed at the following frequencies:
Hickory (20%), Cherryville (60%), Delta Mills (87%), and 0% for the remaining facilities.
Finally, the study reported the largest measured summer increases in ADMI color at the
downstream station at the following facilities: Gastonia -Long Creek (23% increase), Hickory
(31% increase), and Delta Mills (58% increase). Downstream stations were located between 0.5
to 2.5 miles below the outfalls, generally at accessible bridge locations. Thus, comparison of
various downstream impacts must be made with this fact in mind.
The data from the report was supplemented with visual observations made by Division staff
during an August 22, 2000 site visit to all outfalls and downstream stations. The consensus
from the site visit was that significant color plumes were evident at outfalls from Delta Mills,
Cherryville, Hickory, and Gastonia -Long Creek. These were not single incidents, as report
photographs attest to their recurrence during the study. Color pictures of these plumes taken
from various sampling dates are included in Appendix A. Color plumes at the other facility
outfalls were either nonexistent or much less noticeable.
Tiered Classification. The NPDES Color Permitting Policy establishes four tiers of action
based on varying aesthetic color impacts to the receiving waters. The tier groupings were
based on the data reported in the Final Color Study Report, as well as field observations made
by Division staff. The Tier 1 facility showed no visible color plume during the color study. Tier
2 facilities showed minor color plumes at the outfall and limited downstream color impact.
Tier 3 facilities showed significant color plumes at the outfall and at times greater downstream
NPDES Color Permitting Policy
Page 2 of 5

color impact. Finally, the Tier 4 facility showed significant plumes at the outfall and
significant downstream color impacts. The data are summarized in Table 1.
It should be noted that Gastonia -Long Creek was originally placed in Tier 3 based on color
study results. However, after the color study was completed, their major color discharger
(Fleishman's Yeast) was removed, resulting in a Tier 2 re -ranking. Also, Cherryville is
currently ranked as Tier 3 based on color study results, but is scheduled to lose their lone
textile discharger in July 2001. After this color source is removed, Cherryville can request a
re -ranking with subsequent reduction in permitting requirements.
TABLE 1- Tiered Classification
Tier
Facility
Frequency of
Plumes
Observed at
Outfalli
(n= 15, events)
Frequency of
Visual Change at
Downstream
Station2
% Difference in
Summer ADMI
(Upstream to
Downstream)3
Distance from
Outfall to
Downstream
Station (miles)
1
Pharr Yarns
(NC0004812)
0%
0%
-5%
0.59
2
Cramerton
(NC0006033)
100%
(n= 3)
0%
8%
1.6
Lincolnton
(NC0025496)
60%
0%
12%
2.0
Yorkshire
(NC0005274)
67%
0%
4%
2.56
Gastonia -Long
Creek4
(NC0020184)
100%
0%
23%
0.53
3
Hickory
(NC0040797)
100%
20%
31%
1.64
Chenyville5
(NC0044440)
100%
60%
-8%
1.57
4
Delta Mills
(NC0006190)
100%
87%
58%
2.01
Footnotes:
1.
2.
3.
4.
Final Color Study Report, Table 5-2, AWARE Environmental Inc., March 2001.
Final Color Study Report, Table 5-1, AWARE Environmental Inc., March 2001.
Final Color Study Report, Table 4-2, AWARE Environmental Inc., March 2001.
Ranking accounts for removal of major color discharger (Fleichman's Yeast) in April 2001, after the
Color Study was completed.
5. Ranking does not account for scheduled removal of lone textile SIU in July 2001. After textile
removal, facility may request re -ranking.
Color Permitting Policy. All eight Catawba Basin facilities are currently up for permit
renewal, and the basin renewal schedule will extend the permits into 2005. Based on the tier
groupings, progressive permitting actions have been developed for these facilities, ranging from
color monitoring (Tier 1), pollution prevention studies (Tier 2), engineering cost studies for
end -of -pipe treatment (Tier 3), and finally color reduction limits (Tier 4). Color monitoring will
remain a baseline condition for all facilities, as long as color remains a component of the
discharge. Instream stations will be monitored for color monthly during summer, when low
flows represent the most likely period for instream aesthetic impacts. Effluent will be
monitored for color monthly on a year-round basis, to track the consistency of the color input.
NPDES Color Permitting Policy
Page 3 of 5

All color dischargers will also receive a Color Reopener Special Condition, which will allow
permits to be reopened and additional restrictions imposed if color problems persist. The color
limits for the Tier 4 facility will be expressed as a 90% color reduction requirement between
influent and effluent. As discussed previously, a color limit expressed as a percentage
reduction in effluent color should significantly reduce the size of the instream color plume and
aesthetic impact, while avoiding the complications of any single numerical ADMI color limit
The color permitting requirements are summarized in Table 2, and specific permitting
language is included in Appendix B.
TABLE 2- NPDES Color Permitting Poll
Tier
Facility '`lnt
3 .. ��_
1
Pharr Yarns
Tier 1 facilities will receive color monitoring -only, consisting of monthly
effluent sampling, and summer -only (April -October) instream monitoring
(up'stream, downstream). If observed, plume descriptions should be
recorded. In addition, a Color Reopener Special Condition will be added
that allows permits to be reopened and additional requirements imposed if
color problems persist.
2
Cramerton
Tier 2 facilities will receive Tier 1 requirements plus preparation of a
Pollution Prevention (P2)/Best Management Practices (BMPs) report.
This report will address the potential for the facility to reduce effluent color
by incorporating P2 measures and/or BMPs prior to treatment. For example,
the facility could investigate the dyeing process, looking at the potential for
dye substitution, improved dyeing efficiency, etc. The facility could d4this
work independently with their dye supplier or other resource, or request
voluntary assistance from the NC Division of Pollution Prevention and
Environmental Assistance. The report will be submitted within 12 months of
the permit effective date.
Lincolnton
Yorkshire
Gastonia- Long
Creek'
3
Hickory
Tier 3 facilities will receive Tier 2 requirements plus preparation of a Color
Reduction Study. The color reduction study will involve an end -of -pipe
treatment evaluation to develop costs to reduce influent color by 75% and
90%. The reports will be submitted within 24 months of the permit effective
date.
Cherryville2
4
Delta Mills
Tier 4 facilities will receive color reduction limits (90% color reduction
between influent and effluent) to be implemented by the permit effective date.
Footnotes:
1. Ranking accounts for removal of major color discharger (Fleichman's Yeast) in April 2001, after the
Color Study was completed.
2. Ranking does not account for scheduled removal of lone textile SIU in July 2001. After textile
removal, facility may request re -ranking with less stringent permitting requirements.
Additional Facilities. As previously mentioned, the City of Newton (NC0036196) was
originally identified as a color discharger to the South Fork Catawba River watershed, along
with the Alliance members. However, the City of Newton elected to evaluate color conditions
independently from the Affiance. The Division conducted a site visit to the Newton WWTP
prior to permit renewal, and observed a minor color plume at the outfall. In the permit
renewal issued to Newton on March 2, 2001, the permit included monthly summer color
monitoring, as well as a Color Reopener Special Condition. Based on the current tiered
classification, Newton would rank as a Tier 2 facility. Therefore, it is recommended that the
NPDES Color Permitting Policy
Page 4 of 5

Newton permit be reopened, and color requirements consistent with Tier 2 facilities be
incorporated. This would include the additional requirement for a P2/BMP report.
One facility with colored effluent and a significant color plume which was not evaluated in the
color study is the City of Gastonia- Crowders Creek WWTP (NC0074268). This discharge is
also located in the Catawba River Basin (subbasin 030837). Several recent color complaints
have been received for this facility, and Division staff observed a significant color plume during
a recent site visit. This facility is also up for permit renewal. It is recommended that Tier 3
color requirements be placed in the permit renewal.
Conclusion. It is the overall goal of this permitting policy to reduce the magnitude of color
plumes to a level where aesthetic color complaints are infrequent. The Point Source Branch
requests your comments and concurrence with our permitting policy. Please feel free to call
me at extension 543 if you have any questions or comments.
cc: (without Appendix)
Greg Thorpe, Deputy Director
Mooresville Region, Water Quality (Rex Gleason)
Dianne Reid, Classification/Standards Unit
Tom Poe, Pretreatment Unit
Darlene Kucken, Basinwide Unit
NPDES Unit staff
NPDES Color Permitting Policy
Page 5 of 5

Ar&,n
t?tin-Pr
s
C� : am_ �xs,
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Gregory J. Thorpe, Ph.D.
February 8, 2002
MEMORANDUM
TO:
FROM:
SUBJECT:
Re:
Greg Thorpe
Bobby Blowe
Findings and Recommendations
Public Hearing held on August 28, 2001
Renewal of NPDES permits
NC0005274
NC0006190
NC0074268
NC0020184
NC0025496
NC0044440
NC0040797
Yorkshire Americas, Inc.
Delta Apparel, Inc.
City of Gastonia, Crowder's Creek
City of Gastonia, Long meek
City of Lincolnton
City of Cherryville
City of Hickory, Henry Fork
WATER QUALITY
SECTION
As you requested, I served as Hearing Officer for a public hearing to obtain comments
relative to the proposed color removal requirements necessary for the renewal of the above listed
draft NPDES permits. The hearing was held at 7:00 p.m. on August 28, 2001 at the Citizen's
Resource Center in Dallas, NC. The hearing was held in response to numerous complaints about
the colored effluent plumes from some of the above permitted facilities. These plumes are
primarily due to the large number of textile dischargers in the Catawba River Basin.
BACKGROUND
15A NCAC 02B.0211(3)(f) states, in part, that colored wastes are allowed only in " such
amounts as shall not render the waters injurious to public health, secondary recreation or to
aquatic life and wildlife or adversely affect the palatability of fish, aesthetic quality or impair the
waters for any designated uses". Noticeably colored effluent from the above facilities, as well as
others, in the Catawba River Basin has been the subject of an ever increasing number of
complaints over the years. However, there has been no evidence collected by the Division, nor
presented by others, to indicate that these facilities are having anything other than an aesthetic
impact on the receiving stream.
Construction Grants and Loans Section 1633 Mail Service Center Raleigh, NC 27699-1633 [phone]
E-Mail9dress www.nccgl.net FAX [phone]
Ago ikeA
Customer Service
1 800 623-7748 •

The Division and several of the major color dischargers met in 1999 to discuss ways to
address the color issue. From this meeting, the South Fork Catawba River Water Quality
Alliance was formed to conduct color monitoring and assess the color problems in the watershed.
The data collected by the Alliance was incorporated into a final Color Study Report that was
submitted to the Division in March of 2001. This report documented noticeable color plumes
from the various discharge locations ranging from "no plume observed" at the Pharr Yarns
WWTP to " > 8.3 miles" for Delta Apparel. Water Quality Section staff also conducted
independent color evaluations during a site visit to the discharge locations in August of 2000.
Numerous photographs and water samples were taken, documenting the color problems in the
watershed. Based upon the findings of the Color Study Report prepared by AWARE
Environmental, Inc. and field visits by Water Quality Section staff, a NPDES Color Permitting
Policy for Catawba River Basin Color Dischargers was developed by the NPDES Unit and
approved by the Director on June 13, 2001. A copy of the policy is attached as Attachment A.
The NPDES Color Permitting Policy places the color dischargers into one of four tiers.
Basically, Tier 1 dischargers will only be required to monitor for color. Tier 2 dischargers will
be required to monitor for color, plus prepare a Best Management Practices Report to address the
potential for reducing effluent color. Tier 3 dischargers must comply with the Tier 1 and Tier 2
requirements, plus conduct a color reduction study to identify the cost associated with reducing
influent color by 75% and 90%. Tier 4 facilities will be required to achieve a 90% color
reduction between their influent and effluent. The tier system, with associated dischargers, is
explained in detail in the policy.
SITE VISITS
Jackie Nowell, Natalie Sierra, Dave Goodrich, Tom Belnick and I departed Raleigh the
day before the hearing to conduct site visits at the various discharges and see the effects of color
first hand. Our first stop was Gastonia's Crowder's Creek facility where we met with the
Director of Utilities, Don Carmichael and others. While supporting the Division's attempts to
reduce color, Mr. Carmichael was concerned that the Crowder's Creek facility had been placed
in Tier 3, since that facility was not a part of the original Alliance study. His concerns stemmed
from the fact that funds to meet the Tier 3 requirements had not been budgeted by either
Gastonia or Kings Mountain, who is the primary source of color at the Crowder's Creek plant. I
am uncertain as to why this facility was not a part of the original color study since their effluent
was extremely red on the day of our visit and appeared to constitute approximately 50% of the
flow in the receiving stream. The color of the receiving stream remained extremely red at the
Forbes Road bridge approximately one mile downstream.
Next we joined Carol Kemker from EPA -Region IV at the Yorkshire America's, Inc. dye
manufacturing plant. We toured their wastewater facility, discussed the improvements that they
had made, and hiked down to the discharge location. On the day of our visit, there was no
discernible color or plume in the receiving stream.
2

Gastonia's Long Creek discharge location was our next stop. Don Carmichael and other
city representatives met us there and explained that there had been a dramatic color reduction in
their effluent since the closure of the Fleischman's Yeast manufacturing facility. From our
vantage point directly above the discharge pipe, the effluent appeared to be very clear with
perhaps a very light green tint. The plume did not appear to be noticeable in the receiving
stream.
We spent the night in Hickory, which is worth mentioning only because Hickory is
located in the upper end of the watershed and we experienced a fairly intense rain event there
overnight. While we did not retrace our steps of the previous day, the additional stream flow
from stormwater runoff may have masked the color of the dischargers we visited on the 28t to
some degree.
Our first stop on the 28th was Hickory's Henry Fork wastewater treatment facility. The
color of effluent at the discharge location was the color of weak tea, but immediately turned to a
very dark color upon contact with the receiving stream, which appeared to be heavily laden with
sediment. It quickly dissipated, however, and was not noticeable a short distance downstream at
the next bridge. One of the difficulties of addressing a color problem in the stream was
demonstrated during our lab visit. Separate samples of plant effluent and water from tithe stream
appeared to be indistinguishable when compared in lab flasks, contradicting the actual conditions
at the discharge location.
Delta Apparel, Inc. was our next stopwhere we met with the plant manger, the
wastewater treatment ORC, and their lawyers. Delta Apparel, Inc. employs approximately 400
people and is the only permitted discharger in the basin to be placed in Tier 4 in accordance with
the Division's NPDES Color Permitting Policy. The concerns expressed in this meeting centered
around the proposed 90% color reduction requirement and the fact that all of their monitoring to
date used the Platinum -Cobalt method rather than the ADMI process required by their draft
permit. It is uncertain how the data from the two testing methods would relate and whether a
90% reduction by the Platinum -Cobalt method would equate into a 90% ADMI reduction. (Note:
According to the Standard Methods for the Examination of Water and Wastewater, the Platinum -
Cobalt method is not applicable to most highly colored industrial wastewaters, whereas the
ADMI test was developed by the American Dye Manufacturer's Institute for colored waters and
wastewaters.) The Delta representatives were especially concerned that they couldn't meet a
90% reduction of color when producing lightly colored influent. Apparently, their dye operation
varies widely in response to the needs of their customers, and it would be very difficult to clean
up relatively clean water. Ironically, the plant manager did not want to be held to a specific
number limit either. Rather, he suggested that Delta be placed in Tier 3 for at least another
twelve months so they can continue monitoring through all four seasons using the ADMI
method.
Delta's influent color was extremely black or deep purple on the day of our visit. They
were continuing to add polymer and appeared to be removing a good bit of color, although the
effluent was still very dark. At the discharge location, the dark effluent quickly dissipated within
about 50 yards downstream of release. This situation represents a tremendous improvement
over that which was observed by Division staff on previous visits, although it remains unclear if
the previous night's rain was a factor.
3

The Lincolnton facility was our next stop. We were told by the wastewater treatment
plant personnel that approximately 65% of their flow comes from industrial sources, and that
there are six textile plants with dyeing operations contributing to their influent. The receiving
stream upstream of their discharge was a reddish brown color on the day of our visit. The city's
discharge, however, was a dark gray to black and created a very noticeable plume. The color of
the entire receiving stream was noticeably darker at a bridge about a quarter -mile downstream.
Again, it was impossible to determine if either the upstream or downstream color had been
influenced by the recent rain.
Our last stop was the City of Cherryville's wastewater treatment facilities. We were told
that their only textile discharger was no longer in business. As a result, their effluent discharge
appeared colorless.
PUBLIC HEARING
Approximately 39 people attended the public hearing. Those providing oral comments
were Representatives from the City of Gastonia, City of Lincolnton, Cooperative Extension
Service of Gaston . County, the Catawba River Keeper and a Cove Keeper.. Copies of all written
comments received are contained in Attachment B to this report.
All speakers were supportive of the tier system as outlined in the NPDES Color
Permitting Policy for Catawba River Basin Color Dischargers. The municipal representatives
were primarily concerned over the rate impact of conducting additional studies and the cost of
possible new construction. The River Keeper, Cove Keeper, and Cooperative Extension Service
were all concerned over the as yet unknown impacts of color on aquatic life. The River Keeper
also wanted Lincolnton's WWTP and Gastonia's Crowder's Creek WWTP moved to tier 4. All
of the speakers were very supportive of the tier system approach.
Delta Apparel had previously asked for additional time to submit technical data
supporting their voluntary efforts to reduce color in their effluent. Therefore, the comment
period was extended until September 23, 2001. Additional comments were also received from
the City of King's Mountain who is concerned that too many additional requirements will force
mills to close, eliminating jobs and leaving the remaining customers with excessively high user
rates, and from a private citizen urging us to hold firm with a 90% reduction requirement for
Delta Apparel, Inc.
After the close of the hearing record, additional data was requested from Delta Apparel,
Inc. in an effort to determine the amount of polymer being added and the resulting color
reduction achieved as measured by the ADMI method. Delta took exception to our requests for
the additional information and objects to a 90% removal requirement. Copies of correspondence
with Delta are attached in Attachment C.
4

FINDINGS & RECOMMENDATIONS
At best, color removal for aesthetic purposes appears to be an inexact science, which is
mastered as often by trial and error as by scientific calculations. I believe that the tiered
approach, as outlined in the NPDES Color Permitting Policy for Catawba River Basin Color
Dischargers, provides an appropriate mechanism for attenuating the impacts of color
dischargers —not only in the Catawba River basin, but in others as well.
Based upon comments received at the hearing, the additional data finally submitted by
Delta Apparel, Inc., and visual observations during our site visit, I recommend the following:
• Yorkshire Americas, Inc. —On the day of our visit, this facility no longer seemed to
have a color problem. However, due to the nature of their business, I believe that they are
appropriately included in Tier 2 and should be required to prepare a Pollution Prevention
/ Best Management Practices report.
• Gastonia -Long Creek & Cherryville—With the closure of the major industrial color
contributors to their wastewater treatment plants, these facilities no longer seem to have
color problems. Therefore, I recommend that they both be moved into Tier 1 with a color
reopener special condition.
• Hickory -Henry Fork —I believe that this facility is appropriately placed in Tier 3.
• Gastonia-Crowder's Creek --Since this facility was not a part of the original color study,
and since this permit cycle will expire on July 31, 2005, I concur with the Tier 3
designation. However, Gastonia should be advised that this facility will be placed in Tier
4 at the next permit renewal unless there is a significant improvement in the color of their
effluent.
• Lincolnton—Based upon the comments received at the public hearing and the actual
conditions observed during our site visit, I believe that Lincolnton should more
appropriately be designated as a Tier 3 facility. A Tier 3 designation requires the
preparation of a color reduction study within 24 months of the permit's effective date.
The Division would then have time to determine if this facility should move to Tier 4 for
the next permit cycle.
• Delta Apparel, Inc. —Based upon the test data available to us at this time, I concur with
Delta's argument that it would be difficult for them to consistently meet a 90% color
reduction when their dye use varies from 65% to 2% as stated in their attorney's letter of
September 21, 2001. However, data collected by the NPDES Unit reveals that other
textile and municipal facilities are able to achieve 90-plus percent color removal and
produce an effluent with ADMI ranges of between 400 to <25 units (see Attachment D).
Therefore, I believe that Delta is appropriately designated as a Tier 4 facility and should
have a specific color limit —expressed either as a percentage reduction or in ADMI units.
The ADMI test data submitted by Delta for the period of July 24, -2001 through December
4, 2001, indicates that they have achieved color reductions varying from 46% to 93%.
The highest monthly influent color average during this time frame was 5754 ADMI units.
The highest monthly effluent color average during this time was 860 ADMI units. (The
effluent color on the day of our visit was 748 ADMI units) I believe that it would be
5

appropriate to assign a color limit to Delta that we are reasonably comfortable that they
can achieve and gradually ratchet it down, over time, to a point that the color discharged
would neither be objectionable nor detrimental to the stream.
Therefore, it is my recommendation that the permit contain a phased monthly average
ADMI limit. Phase I of the permit cycle would run for 12 months from the date of
issuance and contain an ADMI limit of 863 units, which represents an 85% reduction from
their highest monthly influent concentration for which data is available. Delta's data
indicates that a limit of 863 ADMI units is attainable. Phase II of the cycle would follow
for the next 12 months and require them to meet a monthly average ADMI limit of 720
units. The fmal phase, running through the end of the permit cycle in 2005, would require
compliance with a monthly average ADMI limit of 575 units. The final ADMI limit of
575 units represents a 90% reduction from their highest influent average of 5754 units,
which occurred in October of 2001. Influent ADMI values, as well as the brand name,
quantity and cost of any polymer additions should also be reported monthly. The permit
should also contain a color re -opener clause that would allow additional requirements to
be imposed should conditions warrant.
Finally, I'd like to commend the efforts of the staff of the NPDES unit for their work in
developing the color policy, their research and assistance in collecting and analyzing data, and
preparing for the hearing. There doesn't appear to be a great deal of technical literature available
on color removal and their input has been invaluable.
ATTACHMENTS:
A. NPDES Color Permitting Policy for the Catawba River Color Dischargers
B. Public Hearing comment
C. Correspondence with Delta Apparel, Inc. 4-
Data supplied by Delta Apparel, Inc.
b Comparison of data from Delta Apparel, Inc. to other color dischargers
6

,5yel-ev1149014 DAM
NPDES Permit No.
Abbr. No.
Permittee
Contact
Salutation
Address
City
State
ZIP
Faclllty Name
Address
City
State
ZIP
Location 1
Location 2
County
Receiving Stream
Classification
River Basin
Subbaatn No.
WWTP Statue
Design Q
Regional Office
Letter cc #1
Lotter cc #2
Permit Writer
Ext.
Signature Block 1
Signature Block 2
Signature Block 3
NC0006190
6190
Delta Apparel. Inc.
Gene Hudgens. Plant Mgr.
Mr. Hudgens
100 West Pine Street
Maiden
North Carolina
28650
Maiden Plant
100 West Pine Street
Maiden
North Carolina
28650
100 West Pine Street
Maiden
Catawba
Clark Creek
C
Catawba
030835
Existing
1.0/1.5 MGD
Mooresville
Tom Belnick
543
Tom Belnlck
NPDES Unit
Permit Type
Discharge Status
SIC #1
SIC #2
SIC #3
WW Code #1
WW Code #2
WW Code #3
W W Code #4
WW Code #5
Renewal
Existing
2257
55
Basin Code
Major 03
Minor 08
Latitude
Submtner 35
D 35
M 34
S 38
Longitude: _ �:__
D — 81
M 14
S 13
Typo Ownership PV-I
Fecitlty Type Major
Main Tmt Unit Codo 02003
USGS Quad Map No. E14SW
Quad Map Name Maiden NC
Stream Index No. 11-129-5-(0.3)
Facility Class I11
Public Notice Date:
Issue Date:
11/15/00
01/02/01
303(d) listed (Y/N)
305(b) listed (Y!N)
Use Support (S, ST, PS, NS)
Drainage Area (sq. mi.):
S7010 (cis):
W7010 (cfs):
30Q2 (cfs):
()Avg (cis):
IWC (1):
USGS Sta. No.
YES
PS
66.00
12
25.5
34
78.00
11.00

Whole Effluent Toxicity Testing Self -Monitoring Summary
FACILITY REQUIREMENT
December 18, 2000 •
liT.A11 1r N FFI3 MAR APR MAY JUN JUL AUG SEP OCT NOV DEC
CTI Of North Carolina Pcrm 24hr LC50 ac moat rims 0hd (grab) 1996 —
NC0082970/001 Begin:8/I/1996 Frequency: A NonComp: 1997 --
County: New Hanover Region: WIRO Subbasin: CPF17 1998 —
PF: VAR Special 1999 —
7QI0: TIDAL IWC(%):NA Omer: 2000 -
-
— >100 — — ..... — - - -
- — — >100 — — — -- — —
... — >100 — — — — — --
- -- Lale — — — NR
— >100
Cyprm Foote Mineral CoJ001 Pcrm 24hr p/f ac monit: 90% Rhd (grab) 1996 — -- — — Pass —
NC0033570/001 Begin:I/1/1999 Frcqucncy: A NonComp: 1997 -- — — — — Pass
County. Cleveland Region: MRO Subbasin: BRD05 1998 — — — — — Pass
PF: NA Special 1999 — — — — Fail
7Q10: 0.9 IWC(%):17 Order 2000 — Pass — — —
— Fail,Pass Pass — — —
Dan River Inc. Harris Facility Penn chr lira: 0.75%
NC0083275/001 Begin:2/1/1999 Frequency: Q + Mar Jun Sep Dec
County. Rutherford Region: ARO Subbasin: BRD02
PF: 0,91 special
7010: 186 1 W C(%).0.75 Oniv:
+ NonComp:Single
1996 — >100 — >100 — — >100 65.1 >100
1997 — >100 >100 — >100 Late
1998 >100 -- >100 — >100 — — >100 — — >100
1999 — Pass — — Pass — — Pass — Pass
2000 — — Pass — — Pas9 — — Pass —
Dare County- Reverse Osmosis/001 Perm 24hr p/f ac monit: 90% mysid
NC0070157/001 Bcgin:5/1/1995 Frcqucncy:Q Jan Apr Jul Oet
County: Dare Region: WARO Subbasim CH055
PF: NA Spacial
7Q10: 0 IWC(%):NA Order:
NonComp:
1996 Fail Pass — Pass — — Pass(s) — — Pass
1997 Pass(s) — — Pass — — Pass — — Fail.Pass
1998 Pass — — Fail,Pass — Fail,Pass — — Pass
1999 Pass — — Pass — — Pass — — Pass
2000 61 B1 — Pass — — Pass — Pass
Dare County -Reverse Osmosis/002 Penn 24hrp/f acmow: 90%mysid 1996 Fail Fail
NC0070157/002 Bcgin:5/I/1995 Frcqucncy: Q P/F Jan Apr Jul Oct NonComp: 1997 Fail(s),Pass —
County: Dare Region: WARO Subbasin: CH055 1998 Pass —
PF: NA Spacial 1999 pass —
7Q10:0 IWC(%):100 Order: 2000 Ell —
Fail,Fail Fail Failt Fail
Pass
Pass
Pass
Fail
Fail,Pass
Pass(s)
Pass(s) — Pess(s).Fail —
Pass — — Fail,Pass —
Pass — — Pass —
Pass — — Pass —
Pass — — Fail,Failt
Delta Mills P2-perm chr lim: I 1%; if pf 1.5 P-2 chr lim 16% 1996 — — 31
NC0006190/001 Bcgin:3/1/1998 Frequency: Q Mar Jun Scp Dcc + NonComp:ChV Avg 1997 -- 16
County: Catawba Region: MRO Subbasin: CTB35 1998 -- -- 31
PF: 1.0 Special 1999 — 16
7010: 12 IWC(%):11 Order: 2000 — 4.1
<3
- 31
- 16
- 31
Ell
Late 15.6,15.6
>44
Late
31
15
31
31
NR/31
>44
16
31
Denton WWTP Penn chr lim: 90% 1996 Pass Pass
NC0026689/001 Bcgin:4/I2000 Frequency: Q Feb May Aug Nov + NonComp:Single 1997 Fail Pass
County: Davidson Region: WSRO Subbase YADOB 1998 --- Pass
PF: 0.30 Special 1999 .- Pass
7Q10: 0.0 IWC(%):100 Order: 2000 — 21.2
>90
Pass — — Pass — — Fail Fad
Pass — — Fed Pass — Pass —
Pass — — Pass — — Fod,Pass
>90 •- 51.9 73.48 >90 >90
36.7 >90 — Pass — — Pass
Dixie Yarns, Inc. Perm chr lim: 90% (Grab)
NC0083763/001 Bcgin:5/1/2000 Frcqucncy: Q Jan Apr Jul Oct
County: Staoly Region: MRO Subbasin: YADI2
PF: 01172 Special
7Q Id (1 IWC(%):100 Order:
+ NonComp:Singlc
1996 NR Late Pass Pass — — NR/Fail Pass — Pass
1997 Pass -- — Pass — Pass — — Pass
1998 -- Pass — Pass — — Late Pass -- Pass —
1999 Pass — — NR/Pass — Fail Pass — NR Pass
2000 Fail Pass — Pass — -- Fail >100 >100 NR
Duke Power -Allen 002 Perm chr lim: 16% (Grab) 1996 Pass — — Pass — — Pass — — Pees
NC0004979/002 Begin 10/1/1996 Frcqucncy: Q P/F + Jan Apr Jul Oct NonComp:Singlc 1997 Fail Fail Pass Pass -- — Pass — Pass
County: Gaston Region: MRO Subbasin: CTB34 1998 Pass — — Pass
-- Pass — — Pau
PF: 11.6 ' Special 1999 Pass — Pass --- Pass -- — Pass
7Q10: 95.0 IWC(%):16 (helm 2000 Pass — BI — Late Pass -- Pass
Duke Power-Belews Creek/003 Penn chr lim: 19 % (Grab) 1996 -- Pass — Pass — Pass — Pass
NC0024406/003 Begin:7/1/1998 Frcqucncy: Q P/F + Feb May Aug Nov + NonComp:Singlc 1997 •-• Pass — Pass — Pass — Fal,Pass
County: Stokes Region: WSRO Subbasin: ROA01 1998 •- Pass — — Pass — — Pass — — Pass
PF: 7.7 Special 1999 -- Pass — — Pass — — Pass — — Pass
7Q10: 24.0 IWC(%)33.0 Order: 2000 -- Pass — -- Pass — — Late Pass —
!7/j`j
Duke Power -Buck Steam Pcrm chr lim: 0.7% 1996 — >100 — — >100 — — >100 — — >100
NC0004774/002 Begin:2/12000 Frequency: Q Mar Jun Scp Dec + NonComp:Single 1997 -- >100 — — >100 — — >100 — — >100
County: Rowan Region: MRO Subbasin: YAD04 1998 — >100 •-• >100 -- -- >100 — — >100
PF: NA Special 1999 -- >100 >100 >100 — — >100
7Q111: 111311 IWC(%): 0.598 Omer: 2000 -- — 6t — Pass — Pass
Y Prc 1996 MCI Available
LEGEND:
PERM = Permit Requirement LET = Administrative Letter • Target Frequency = Monitoring frequency. Q- Quarterly; M. Monthly; BM- Bimonthly; SA- Semiannually; A- Annually; OWD- Only when discharging; D- Discontinued monitoring requirement
Begin - First month required 7QI0 = Receiving stream low Bow criterion (cfs) += quarterly monitoring increases to monthly upon failure or NR Months that testing must occur - ex. Jan, Apr, Jul, Oct NonComp = Current Compliance Requirement
PF = Permitted flow (MGD) IWC% - Instrcam waste concentration P/F = Pass/Fail test AC = Acute CHR = Chronic
Data Notation: f • Fathead Minnow; . - Ccriodaphnia sp.; my - Mysid shrimp; ChV - Chronic value: P - Mortality of stated percentage at highest concentration; at - Performed by DWQ Aquatic Tox Unit; bt - Bad test
Reporting Notation: --- = Data not required; NR - Not reported Facility Activity Status: I - Inactive. N • Newly Issucd(To construct); H • Active but not discharging; 1-More data available for month in question: • = ORC signature needed
16

DMR Data Review- EFFLUENT
Facility: Delta Mills
NC00 6190
Preparer: Tom Belnick
Date: 10/27/00
Month
Eff
AvgQ
MGD
Eff Eff
AvgBOD AvgNH3
Ib/d iiisiViVa
Eff
AvgTSS
Ib/d
Eff
AvgCOD
Ib/d
Eff Eff
MinDO TN
mg/I mg/I
Eff Eff Eff
TP AvgSulfide AvgPhenol
mg/I Ib/d b/d
Aug-00
-78
1 q. z
4-0.5
9Z RS9
(0 3
5
I Z
41
0.03
L0. 0 Y
JuI-oo
. 72.
I I -I
40.5
59
/0 S9
E,.7
7
7
Z .7
Jun-00
.76
1(I
0.l0
79
i0Z0
6.6
/3
c.6/
e.03
May-oo
.77
15
.p-5
89,
1179
6.9
I.
L.7
c .01L
•03
Apr-00
.77
)(-/
- (o
6U
1077
7 /
Z(o
- 6
Mar-00
-e-)Q
1S
c-5
80
lI6Z
7. /
(5
9
-8
C-0Y
- 0'1
Feb-00
. 8 (o
I S
G• 5
6 (0
/ 0 Z(o
7.8
5
)1
- 7
Jan-00
Dec-99
. 8co
1 6
•.5
66
989
O
11
Z.
• 7
• 0 Y
.7q
18
G,S
1 Oct
675
.-/•7
7.L/
Zi
%
• 7
-0S
Nov-99
•90
18
c- L
81
9a7
6,q
22
Z
2-3
-0 `1
Oct-99
Sep-99
88
14
,.. S
G0
780
7.9
1
G 6
.03
- 62-
15
•5
105
9 01
7. 1
7 S
• 6
i / S
Limits:
1. 0
I 2.
3.0
785
00
7 5
-
8.0 L-1. 0
EfF Coho(6t c.�►v Imo-6t�U-o .rr,+A Ic..%,v)
_S (-{'(Pa 6l( - C 0. / rn //X
- yh Ca e so -1(3000 21 - lb, Zen Aly-P
(AA 1�
Z. Z
Z.3
2.Y
Z. 3
Z.z
z. z
Z.I
Z- Z
Z.7
Z.
/.9
Z.Z
�C�
filef,Q /4/63v). in8

DMR Data Review- Color Summary
Facility: Delta Mills
NCO() 6190
Preparer: Tom Belnick
Date: 1/12/01
Month
04/11/00
04/25/00
05/16/00
05/31/00
06/13/00
06/27/00
07/11/00
07/25/00
08/08/00
08/22/00
09/06/00
09/19/00
10/03/00
10/17/00
Upstream Downstream Effluent
ADMI Color ADMI Color ADMI Color
78
156
49
60
66
77
<20
76
48
48
86
133
41
26
54
149
65
75
61
89
91
80
71
99
91
133
71
122
1550
921
1740
1780
1110
1180
1360
1380
1590
1650
1520
1830
1350
1810
Notes:
Upstream- 0.87 miles
Downstream- 2.01 miles
ADMI color reported at pH 7.6
tipplerl&A
0 04\
,1 ( °\ .,
104
Clark Creek
Flow, cfs
70
180
72
70
62
65
44
65
50
41
57
170
50
JAB.
s7Q10= 12
IWC= 11% @ 1MG

DMR Data Review- INSTREAM DO
Facility: Delta Mills
NC00 6190
Preparer: Tom Belnick
Date: 2/14/00
Month
Up Down
DO MinDO
mg/1 mg/I
Sep-99
Oct-99'
Nov-99
Dec-99
Jan-00
Feb-00
Mar-00
Apr-00
May-00
Jun-00
Jul-00
Aug-00
Sep-00
5.8
6.8
6.8
7.9
7.0
9.6
8.2
7.0
6.1
6.2
5.8
5.8
5.4
5.9
6.6
6.6
8.2
7.2
9.0
7.6
6.3
5.6
5.1
5.0
5.0
5.3
WQS

IWC Calculations
Regional WWTP
NC00
Prepared By: Tom Belnick, NPDES Unit
Enter Design Flow (MGD):
Enter s7Q10(cfs):
Enter w7Q10 (cfs):
1
12
25.5
Residual Chlorine
7Q10 (CFS)
DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (UG/L)
UPS BACKGROUND LEVEL (I
IWC (%)
Allowable Conc. (ug/l)
Fecal Limit
(If DF >331; Monitor)
(If DF <331; Limit)
Dilution Factor (DF)
NPDES Servor/Current Versions/IWC
Ammonia (NH3 as N)
(summer)
12 7Q10 (CFS)
1 DESIGN FLOW (MGD)
1.55 DESIGN FLOW (CFS)
17.0 STREAM STD (MG/L)
0 UPS BACKGROUND LEVEL
11.44 IWC (%)
149 Allowable Conc. (mg/I)
200/100m1
8.74
Ammonia (NH3 as N)
(winter)
7Q10 (CFS)
DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (MG/L)
UPS BACKGROUND LEVEL
IWC (%)
Allowable Conc. (mg/I)
12
1
1.55
1.0
0.22
11.44
7.0
25.5
1
1.55
1.8
0.22
5.73
27.8
10/27/00

TELEPHONE RECORD
Date: Project:
Time:
❑ Return Mr./ Mrs.
❑ Call to Address
❑ Call from
Telephone:
Representing:
FAX:
Subject:
SUMIV1
/
NOTE
l' Z l �1 R -P 1 i' Iia Joe t l -aI%f//"k i d)
pb-yn-qq21
0, 4-, &'/ left/pi, Md
m1,-1-5( exf 23
-P J!iv( 4'cli / /ems
-6010,- u, eft. J . f'Jk /h -
h//Jtd(
o- 4
�©.,C.'/ de(e I r ill PV 4 .
g il, 11.,_ Md--e --9 7/' 7/0 /
—eo2, w p., Pru
4OO/
ezti., ), .4, e
i .
- 4JJ) b - etLrW d
c ,(2:1--_-_--____
NEEDED F -UP ACTION(S)
1.
BY WHOM/WHEN
1.
2.
2.
3.
3.
4.
4.
5.
5.
cc:

NOTES/ SUMMARY (cont.)
Tc 1,y7411 61-6- yz-g-d32_z

Date:
TELEPHONE RECORD
Project:
i\ Time:
Return Mr. Mrs. Representing: resentin IJe /I.1__❑
P 9
❑ Call to Address
❑ Call from
Telephone:
FAX:
Subject:
47i7S SUMMAP
of qu3J72J3S3S
a tbau, f, OP Ili
—dlj 4ea/),e/t
NEEDED FOLLOW-UP ACTION(S)
1.
2.
3.
4.
5.
BY WHOM/WHEN
1.
2.
3.
4.
5.

REASONABLE POTENTIAL ANALYSIS
Prepared by: Tom Belnick, 10/30/00
Facility Name =
Delta Mills
NPDES # =
NC0006190
1
Qw (MGD) =
1
Qw (cfs) =
1.5472
7Q 10s (cfs)=
12
1 WC (%) =
11.44
Chronic CCC w/s7Q10 dil.
Acute CMC w/no dil.
Frequency of Detection
Conclusion
Parameter
FINAL RESULTS, ug/I
FINAL RESULTS, ug/I
#Samples
# Detects
Arsenic
~ -- - - - -
_ --- --
f-iii4 _
--_--
Max. Pred Cw
------------------------
---
--- - -- —
Allowable Cw
Cadmium-----
----
Max. Pred Cw
Allowable Cw
Chromium
_r �<
, _
Max. Pred Cw
��_1v_ _
135.7j (` rl_
52
45
_
LI rh I T
Allowable Cw
437.1
�1
- 1022
Lead
Max. Pred Cw
_
Allowable Cw
Copper (A.L.)
Max. Pred Cw
180.0 . I
���
h L�'a fi
52
Allowable Cw
61.2
-- 7.3
52
piQNj7Qk
Nickel
I
Max. Pred Cw
Allowable Cw
Silver (A.L.)
Max. Pred Cw
Allowable Cw
Zinc (A.L.)
Max. Pred Cw
165.0
Allowable Cw
437.1
67
52
52
t'1ONl Tot
Cyanide
Max. Pred Cw
Allowable Cw
Mercury
-
Max. Pred Cw
-- ---
Allowable Cw
Molybdenum
Max. Pred Cw
Allowable Cw
Selenium
52
Max. Pred Cw
Allowable Cw
Fluoride
Max. Pred Cw
Allowable Cw
Chloride(A.L.)
52
AQNWTa
Max. Pred Cw
67280.0
Allowable Cw
---------- -----
2010645.2
----- -----------
860,000
I
-detects
Modified Data: Use 0.5 Detection Limit for non
WEEi(Cy
WOEKL'

Parameter =
Standard =
Dataset=
Chromium
ug/I
DMREler cjk
50
ModifiedData Nondetects
4.9
2
1.75 <3.5
8
1.75 <3.5
3.5
4.9
4.4
4.5
2.5 <5
25 <50
25 <50
25 <50
3.5
4.7.
1.75<3.5
9.4
7.8
8.6
3.5
3.5
0.7
10''!
12
3,5
15
35
3.5
5.8
13
3.5
3.5
25
10
38
3.5.
16
19
44
59
19
29
3.5.
0.7
4.4
3.5.
6
7.3
3.5
7.4
3.5
11
RESULTS
Std Dev.
12.275
Mean 11.053
C.V. 1.111
Sample# 52.000
Mutt Factor =
Max. Value
Max. Pred Cw
Allowable Cw
2.300
59.000 pg/I
135.700 Ng/I
437.097 Ng/I

Parameter =
Copper (A.L.
Standard =
7 pg/I
Dataset=
DMR8/00-9/99
ModifiedData
Nondetects
RESULTS
37
Std Dev.
20.668
53
Mean
45.750
34
C.V.
0.452
10
Sample#
52.000
23
15
Mult Factor =
1.500
30
Max. Value
120.000
Ng/l
35
Max. Pred Cw
180.000
pg/I
pg/I
63
Allowable Cw
61.194
50
60
30
20
26
44
---_- 47
73
49
43
25
--- 47
50
47
34
34
77
46
25
29
38
32
20
47
36
44
27
49
59
58
87
57
83
56
53
40
33
62
120
23
83
49
67

Parameter =
Zinc (A.L.)
Standard =
50
pg/I
Dataset=
DMR8/00-9/99J
ModifiedData
Nondetects
RESULTS
52
Std Dev.
20.641
37
Mean
45.808
40
C.V.
0.451
34
Sample#
52.000
37
30
Mult Factor =
1.500
33
Max. Value
110.000
pg/I
34
Max. Pred Cw
165.000
pg/I
pg/I
35
Allowable Cw
437.097
50
50
40
30
33
44
28
27
25
35
52
48
52
50
43
38
93
73
46
25
25
25
25
71
28
47
28
52
110
73
79
49
99
30
69
43
38
40
97
33
32
36
39
1

Parameter =
Chloride(A.L.)
Standard =
230000
1pg/I
Dataset=
DMR8/00-9/99
ModifiedData
Nondetects
RESULTS
1050
Std Dev.
3135.287
696
Mean
1996.288
800
C.V.
1.571
52.000
924
Sample#
806
744
Mult Factor =
2.90
643
Max. Value
23200.00
pg/I
920
Max. Pred Cw
67280.00
pg/l
960
Allowable Cw
2010645.16
pg/I
668
745
829
999
1690
1380
1520
864
841
1250
1500
1290
1320
1450
993
955
981
781
~
846
_
727
1030
�
1690
2860
803
731
801
3460
3520
2940
23200
2800
1680
2430
2990
2990
T
3800
2870
-
----
3150
1690
2400
2170
1770
2860

41/t/D0:: fri.:,
Division of Water Quality fi PJ CIA le
��� •Lc•�f�(
August 5, 1999 k
MEMORANDUM
TO: Dave Goodrich
THROUGH: Matt Matthews ("`1
FROM: Kristie Robeson
SUBJECT: NPDES Permit Modifications
Revised Chronic Toxicity Language
Due to recent discussions with EPA Region IV, the Division is further modifying its
Whole Effluent Toxicity Enforcement Policy. Therefore, the -chronic toxicity language to be
used in permits will once again change. Listed below are the nine facilities that currently have
a Phase II chronic toxicity testing requirement in their NPDES permits. Our office previously
sent you a memo dated 5/10/99 requesting modification of these nine permits to include the
new chronic toxicity language. However, through discussions with EPA, our office was told
that they would not approve permits which contained that toxicity language. The chronic
language has since been revised and approved by EPA Region IV. Our office now
recommends modifying the permits for the nine facilities listed below to include the revised
permit language for chronic toxicity testing.
CMUD-McAlpine WWTP
NPDES Permit No. NC0024970
Mecklenburg County
CMUD-Mallard Creek WWTP
NPDES Permit No. NC0030210
Mecklenburg County
CMUD-McDowell Creek WWTP
NPDES Permit No. NC0036277
Mecklenburg County
Concord Rocky River WWTP
NPDES Permit No. NC0036269
Cabarrus County
Delta Mills
NPDES Permit No. NC0006190
Catawba County
Duke Power -Lincoln Turbine
NPDES Permit No. NC0080781
Lincoln County

Takeda Chemical Products
NPDES Permit No. NC0059234
New Hanover County
Winston-Salem Archie Elledge WWTP
NPDES Permit No. NC0037834
Forsyth County
Winston -Salem -Lower Muddy Creek WWTP
NPDES Permit No. NC0050342
Forsyth County
Please find attached the appropriate chronic toxicity test condition language to be
used in these nine permit modifications. You should also note that this language contains our
new mailing address, which should be used in future toxicity permit language. Should you
have any questions, please feel free to contact me or Matt Matthews at 733-2136.
Attachment
cc: Rex Gleason-MRO
Rick Shiver-WIRO
Larry Coble-WSRO
Colleen Sullins
Shannon Langley -Point Source Compliance/Enforcement Unit

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 %.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in the "North Carolina
Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent versions or "North Carolina
Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The tests
will be performed during the months of . 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, using the parameter code TGP3B for the pass/fail results and
THP3B for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to be sent to the following address:
Attention: Environmental Sciences Branch
North Carolina Division of
Water Quality
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch 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 Branch 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.
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.
QCL Version 5/99

apt o v yt - a1
- LAApiff deAbi Ateg4,6e,ce,,.4 pc
/-* on'
tvahtaim 61i)4- I 17/1°z-
4LTg
&I) (of -12'?O
rer vrqin
c PacKa
- eo � Y✓1 gQilii �l�l - Wl / p ��� fZ7 340 :life(
PC dZr el%J- 143.(1I
- 466 a 4M- /6 I4k/
o 70 re w14o\-4-/fv‘I-434 4-6,)11- Ed-oi c,101-c
&a , l il'I et x ? SkA rvi
htin 7
-s ?
P.1.0-e/44, '5q. F ,i' 4- tl1.S i //e
MISC.
®o Co.0-7 5tro K a 0-M vah-ii, ill ` Dx 10 / lox ftrobit414 md1-1 /60w/
51.4,C ..) (F s%Lb% r - 4V,Pii = 7Y8
111)41 I fru, h 4 A/ 0,6v.44,4 -
1'ZZI o2

•
Delta Mills Color Data-2001
NC0006190
Date
Influent
ADMI
Treated
Effluent
ADMI
Percent
Removal
7/24/01 3880 -t4 f 1060
7/31/01 3590 1180
876761 2550 763
8/14/01 31501tti 963
8/21/01 3220 883
8/28/01 2360 748
4/01 4640 362 92
9/11/01 6680 (t ' 728 89
9/18/01 4510 821 82
9/25/01 604 909 85
1 7730 775 90
10/9/01 5190 1 Si 546 89
10/16/01 693 S - 570 92
10/23/01 3150 516 84
10/30/01 5770. 496 91 __-�
11 /7/01 2250 a 1210 46
_Si11/13/01 4140 ..k 662 84
11/20/01 10400 744 93
11/27/01 3050 827 73
73
6L�
70
69
73
68
\ 1\1
•
117
Delta Mills Color Data-2000
NC0006190
Untreated
Date Effluent
ADMI
12/4/01 4650 1070 77
4/11/00
4/25/00
5/16/00,
5/31/00
6/13/00
6/27/00
7/11/00
7/25/00
8/8/00
8/22/00
9/6/00
9/19/00
10/3/00
10/17/00
11/14/00
1620
915
1660
1770
1100
1140
1190
1360
1550
1620
1490
1820
1340
1820
2090
min
max
avg
2250
10400
4694
362
1210
792
46
93
79
915
2090
1499
Notes:
1. All ADMI values at natural pH
2. For 2001 data, influent= composite sample and effluent=grab sample.
3. For 2000 data, untreated effluent= composite sample.
.vim
„zAic
444044 e)444."
/kid
ddo
+10,41
�0 044'41
lil'o5-
�4 C"
Gttl I n
CS1Sti AO
M0
Cervio14-= gbZ
lt+T`
.h 7 M00;vi

Summary of Color Reduction in North Carolina
Facility
Influent/or
Untreated Eff
(ADMI)
Treated Eff
(ADMI)
Percent Color
Reduction
(% reduction)
Treatment
Method
Volume
Treated
(MGD)
Treatment
Cost
($)
Bleach/Dye Mix
Flynt Fabrics
3000
200-400
87-93
reducing agent
0.5
$112,000 capital
40%bleach; 60% dyes
$103,500 O&M (300 d/yr)
America!
?
<50
?
polymer
0.15
$285,000 capital
?
$135,000 O&M (300d/yr)
Cone Mills
(Greensboro)
Cone Mills
3000
<100
>97
ultrafiltration+
polymer
ultrafiltration+
1.25
$895,000 capital
$250,000/yr O&M
100% dyed denin
(Cliffside)
3000
<100
>97
polymer+
0.9
$1,500,000 capital
100% dyed denim
AquaDisk filter
$60,000/yr O&M
City of Eden
500-10,000
.
(Mebane)
avg 2,000
<100
>95
polymer
13.5
$100,000 capital
? '
$651,000/yr O&M
3 textile inputs
Belmont Dyers
2900
<25
99
electrochemical +
polymer
0.5
$4,500,000 capital
$1,200,000 O&M (325d/yr)
5% bleach; 95% dyes
Delta Apparel
1436
?
?
polymer
1
?
?
Data Sources:
Color Reduction and Removal Seminar, Charlotte, NC, June 17, 1998

City of Eden- Mebane WWTP
NC0025071
Effluent Color Limit = 300 ADMI instantaneous max
Effluent collected 3/Week for first year, and 3/Quarter thereafter
Treated Percent
Date Effluent Influent Removal
ADMI ADMI %
11/2/01 74 1200-2400 94-97
11/3/01 65 1200-2400 95-97
11/4/01 133 1200-2400 89-94
7/9/01 78 1200-2400 94-97
7/10/01 81 1200-2400 93-97
7/12/01 126 1200-2400 89-95
4/6/01 148 1200-2400 88-94
4/9/01 163 1200-2400 86-93
4/10/01 160 1200-2400 87-93
1/9/01 135 1200-2400 89-94
1/10/01 158 1200-2400 87-93
1 /11 /01 136 1200-2400 89-94
Notes- based on conversation with ORC Terry Shelton (336-623-9921, ext 308) on 1 /11 /02:
1. Influent color generally averages 1200-2400 ADMI.
2. POTW currently treats - 6.5 MGD, of which - 4 MGD is from 3 textiles
3. Polymer cost is still - $600,000/year, which is billed back to the 3 textiles.
4. Polymer is only color treatment; they use liquid Stockhaeusen 188KE(?).
5. Influent color generally runs dark (deep purple, black).
6. Eden has been treating color since - 1992/93.

Page I-1
Permit No.: KY0062995
A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of this permit and lasting through the term of this permit,
permittee is authorized to discharge from outfall serial number: 001, Municipal Discharge.
Such discharges shall be limited and monitored by the permittee as specified below:
EFFLUENT CHARACTERISTICS DISCHARGE LIMITATIONS
lbs/day Other Units(Specify)
Monthly Weekly Monthly Weekly Measurement Sample Sampling
Avg. Avg. Avg. Avg. Frequency Type Location
N/A N/A Report Report*** Continuous N/A Influent or
Flow, Design (3.6 mgd) Effluent
Biochemical Oxygen Demand 751 1201 25 mg/1 40 mg/1 3/week Composite EffluentInfluent &
(5-day), Carbonaceous
Total Suspended Solids 901 1351 30 mg/1 45 mg/1 3/week Composite EffluentInfluent &
Fecal Coliform Bacteria, N/100 N/A N/A 200 400 3/week Grab Effluent
Ammonia (as N) 120 180 4 mg/1* 6 mg/1* 3/week Composite Influent &
330 495 11 mg/1** 16.5 mg/1** Effluent
Dissolved Oxygen shall not be less than 7 mg/1
3/week Grab Effluent
Total Residual Chlorine (TRC) N/A N/A 0.011 mg/1 0.019 mg/1*** 3/week Grab Effluent
Biomonitoring shall not exceed 4.80 acute toxicity unit(s)
See PART IV, Pages IV-1 and IV-2 Effluent
Chloride
43,585 87,170 2531 mg/1 5062 mg/1*** 1/day Composite Effluent
N/A N/A N/A 100 ADMI*** 1/day Effluent
Color, ADMI
Copper, Total Recoverable N/A N/A N/A 0.173 mg/1*** See PART I, Page I-2 Effluent
See PART I, Page I-2 Effluent
MONITORING REQUIREMENTS
Grab
Additional Parameters
In addition to the specified limits, the monthly average effluent CBOD5 and suspended solids concentration shall not exceed 15% of the respective monthl:
average influent concentration (65% removal).
The pH of the effluent shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored three times per week by gra
sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
The effluent shall not cause a visible sheen on the receiving water.
*
♦*
***
Effective May 1 - October 31
Effective November 1 - April 30
Daily maximum limitation
Po lam% /J
//
JJXX / 1
7 2 i -e % F/ )

KENTUCKY POLLUTANT
DISCHARGE ELIMINATION
mil
SYSTEM
PERMIT
PST NO.: KY0062995
AUTHORIZATION DISCHARGE DISC�ELIMINATIONGE UNDER H SYSTEM
gE��CKY POLLUTANT
-suant to Authority in KRS 224,
City of Jamestown
P.O. Box 587 42629
Jamestown, Kentucky
authorized to discharge from a facility located at
Russell County Regional Wastewater Treatment Plant
Half Acre Road
Jamestown, Russell County, Kentucky
receiving waters named
Lake Cumberland (Cumberland River) / Mile point 475.6
i accordance with effluent limitations, monitoring requirements, and other conditions
at forth in Parts I, II,
III, and IV hereof. The permit consists of this cover sheet ad Part I 2 pages, Part II 4 pages, Part III 1 page, and Part IV 2 pages.
This permit shall become effective on AUG 1 2001
This permit and the authorization to discharge shall expire at midnight,
November 30, 2003
JUN 2 7 2001
Date Signed
ck A. W 'son, Director
vision of Water
obert W. Logan
Commissioner
DEPARTME FOR ENVIRONMENTAL PROTECTION 40601
Division of Water, Frankfort Office Park,
14 Reilly Road, Frankfort, Kentucky
Printed on Recycled Paper

Date:
Time:
TELEPHONE RECORD n�
Project:
fiC00 0 (41n
❑ Return Mri Mrs.
❑ CaII to Address
❑ CaII from
Representing:
Telephone: FAX:
Subject:
TES/ SUMMARY
itAd 916
\A)lc-t rneJSA lta /'e: -6 fe rmr�
t1� l\ot,J w-e a(-ev',J'efrC I i.4,1•I-S-
oY1Y14 c,�t�� cua4"-A 104-)1Ct SOE3 7'T7°O7
LzFF somc �bru,wvr�
NEEDED FOLLOW-UP ACTION(S)
1.
2.
3.
4.
5.
cc:
BY WHOM/WHEN
1.
2.
3.
4.
5.
Signed

Whole Effluent Toxicity Testing Self -Monitoring Summary
December 19, 2001
FACILITY REQUIREMENT YEAR JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC
E.1. Dupont Denemours/001 Pcnn24hrpffaclim: 90%shad
NC0000663/001 Begin:9/1/1996 Frequency: Q + Jan Apr Jul Oct
County. Brunswick Region: WIRO Subbasim CPF17
PF: 2.3 Special
7Q10: 918 IWC(%)A.38 Order:
NonComp:Singlc
1997 Pass — — Fail FalI,>100 Pass Pass — — Pass
1998 Pass — — Pass — — Pass — — Pass
1999 Pass — — Pass Pass — Pass
2000 el — — Pass — — Pass -- Pass
2001 Pass — — Pass Pass — NR
Easco Aluminum Perm chr lim: 2,4% (Grab)
NC0086231/001 Bcgim 10/1/I998 Frequency. Q P/F + Mar Jun Sep Dc
County. Hertford Region: WARO Subbasin: CH001
PF: 0.024 Special
7Q10: 3.0 IWC(%)2.4 Order:
+ NonComp: Single
1997 -- — — — -. '- — — .- -. — -.
1998 — — — — -- N — N
1999 — — Pass — — Lale Pass — Lale Pass — NR
2000 NR/Pass — Pass -- Pass -- — Pass -- — Pass
2001 — — Pass Pass -- NR/Pass
Eaton Corp/001 Pent chr lim: 90
NC0003379/001 Begin:5/1/2000 Frequency: Q P/F Jan Apr Jul Oct
County: Person Region: RRO Subbasin: NEUOI
PF: Special
7Q10: 0.0 1 W C(%):100.0 Order:
+ NonComp:Singlc
1997
1998
1999
2000
2001
Ecnsta Division Pcnn chr lim: 21%(Grab) 1997 Pass — Pass — — Pass — — Pass
NC0000078/00I Begin: l0/I/1995 Frequency: Q P/F + Jan Apr Jul Oct NonComp:Single 1998 Pass — — Pass — — Pass — — Pass — —
County: Transylvania Region: ARO Subbasin: FRBOI 1999 Pass -- — Pass — — Pass — — Pass — -•
PF: 27.5 Special 2000 Pass — Pass — — Pass — Pass — — `
7Q10: 154 IWC(%)21 Order: 2001 Pass -• — Pass -- — Pass Pass '›r f(Z
Eden WWTP/Mebane Bridge Perm chr lim: 6% 1997 --- — Pass — — Pass — — Pass — — Pass \\
NC0025071/001 Begin:7/1/1997 Frequency: Q P/F + Mar Jun Sep Dec + NonComp:Single 1998 -- — Pass — — Pass — — Pass — — Pass r-�,
County: Rockingham Region: WSRO Subbasin: ROA03 1999 — Pass — Pass — Pass — Pass l .�
PF: 13.5 Special 2000 -- — Pass — Pass — — Pass — Pass
7Q10: 386 IWC(%):6.3 Order: 2001 -- — Pass — Pass — — Pass — tea
iciNt
Eden -Dry Creek WWTP Penn 24hr p/f ac lim: 90%; upon cap 1.0MGD chr lim 0.4% 1997 •- — Fail,Pass — Pass — — Pass — — Pass
NC0025151/001 Begin:7/I/I997 Frequency: Q P/F + Mar Jun Sep Dec + NonComp:Single 1998 -- — Pass Pass — •- Pass — — Pass \
County: Rockingham Region: WSRO Subbasin: ROA03 1999 — — Pass — Pass — — Pass — — Pass
PF: 0.5 Special 2000 — — Pau — — Pass — — Pass — Pass
7Q10: 313 IWC(%):0.24 Order: 2001 -- Pass — Fail Pass Pass Pass
Ekstam, Gibbs, & Roebuck LLC Pemt chr lim: 58% 1997 -- H — — H — H — — H
NC0051195/001 Bcgin:3112000 Frequency: Q Feb May Aug Nov + NonComp:Singlc 1998 .- li — — H — — Fi — Fd —
e
County: Martin Region: WARO Subbasin: TARO6t999 •- NRNRNRM — — H — — H -• ( t '
PF: 0.30 Special 2000 _ H — — NR/H — — H — — H — V
7QI0: 0.34 IWC(%):58.0 Order: 2001 — H — — NR/H — — NILO H
Elizabeth City WWTP Pam chr lim: 10% 1997 — — Fail,Fail Pass — FaB,Fai1 Pass — Fail NR Pass Pass V �.
NC0025011/001 Begin:2/12001 Frequency: Q Mar Jun Scp Dec + NonComp:Singlc 1998 -- — Pass — — Pass — — Pass — — Pass
141SCounty: Pasquotank Rcgion: WARO Subbasin: PAS50 1999 -- — Late Pass — Pass — — Pass — — Pass n �p
PF: 4.5 Special 2000 -- — Pass — — Pass — — Late Pass — Late
N...*.+4.....--
7Q10: TIDAL IWC(%):10.0 • Order: 2001 Pass — Pass — — Pass — Pass —
Elizabethtown NYWTP Pcnp chr lira: 4.6%
NC0026671/001 Begin:7/1/1996 Frequency: Q Mar Jun Sep Dec + NonComp:Singlc
County: Bladcn Region: FRO Subbasin: CPFI6
PF: 1.225 Special
7Q10: 815 IWC(%):4.6 Order:
1997 --
1998 •-
1999 --
2000 .-
2001 •-
Fail
Pass
Pass
Pass
Pass
Pass
Pass
Pass Pass Fail Pass — Pass
Pass -. — Pass — — >100
Late Pass Pass — — Pass
Lade Pass --- Late Pass — Pass
Pass — Pass ---
Elkin WWTP Pcrm chr lint: 0.87% 1997 --- >90 — — >90 — -- >90 -- >90
NC0020567/001 Begin:7/1/1999 Frequency: Q P/F + Mar Jun Sep Dec + NonComp:Singlc 1998 — >100 — >90 -- -- >90 — — >100
County. Sony Region: WSRO Subbasin: YADO2 1999 — — >100 >100 •-- -- Pass — Pass
PF: 1.8 Special 2000 — — Pass Pass -- -- Pass — — Pass
7Q10: 317.0 IWC(%):0.87 Order. 2001 — Pass Pass — Pass —
EUerbe WWTP Pcrm chr lint 61% 1997 Fail Pass — Pass — — Pass — — Fail Pass
NC0021784/001 Begin:3/1/1999 Frequency: Q Jan Apr Jul Oct + NonComp:Singlc 1998 Pass — — Fail Pass — Pass — — Pass —
County: Rielmonl Region: FRO Subbasin: YAM 1999 Pass — — Pass -- — Pass — — Pass — —
PF: 0.18 Special 2000 Lade Fail 27.4,45.96 Fail 84.9 Bt >90,Pass — — Pass — —
7Q10: 0.18 IWC(%)�1.0 Order: 2001 Pass — — Pass — — Pass — -- Pass
Y Prc 1997 Data Available
LEGEND:
PERM = Permit Requirement LET = Administrative Letter - Target Frequency = Monitoring frequency: Q- Quarterly; M- Monthly; BM- Bimonthly, SA- Semiannually; A- Annually; OWD- Only when discharging; D- Discontinued monitoring requirement
Begin = First month required 7Q10 = Receiving stream low flow criterion (cfs) += quarterly monitoring increases to monthly upon failure or NE Months that trsring must occur - ex. Jan. Apr. Jul, Oct NonComp - Current Compliance Requirement
PF = Permincd flow (MGD) IWC 4 = Instrcam waste concentration P/F = Pass/Fail test AC - Acute CHR = Chronic
Data Notation: f - Fathead Minnow; • - Ceriodaphnia sp.; my - Mysid shrimp; ChV - Chronic value; P - Mortality of stated percentage at highest concentration; at • Performed by DWQ Aquatic Tox Unit; bt - Bad test
Rcponing Notation: --• = Data not required; NR - Not reported Facility Activity Status: 1- Inactive. N - Newly Issued(To construct); H - Active but not discharging; t-More data available for month in question; • = ORC signature needed
18

Whole Effluent Toxicity Testing Self -Monitoring Summary April 23, 2002
FACILITY REQUIREMENT YEAR JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC
Dare County-(RO)/001 Penn 24hr p/f ac monit: 90% mysid
NC0070157/00I Bcgin:5/1/1995 Frequency: Q Jan Apr Jul Oct
County. Dare Region: WARO Subbasin: PAS56
PF: NA Spacial
7Q10: 0 1WC('/.):NA Order:
Dare County-(RO)/002 Penn 24hr p/f ac monit:')0 mysid
NC0070157/002 Bcgin5/I/1995 Frequency: Q P/F Jan Apr Jul Oct
County- Dare Region: WARO Subbasin: PAS56
PF: NA Spacial
7Q10: 0 1WC(%):100 Ord=:
NonComp:
NonComp:
1998 Pass - - Fa1,Pass - - Fa8,Pass - - Pass
1999 Pass - - Pass - - Pass - - Pass
2000 81 81 - Pass - - Pass - Pass
2001 pass -- - Pass - - Pass - Pass
2002 Pass
1998 Pass - - Pass - - Pass - - Pass
1999 Pass - - Pass - - Pass - - Pass
2000 BI - - Fad Fae.Pass - Pass - - Fal.Failt
2001 Pass - - Pass - - Pass - - Pass
2002 Fa1,Pass -
Delta Mills P-2 perm chr lim: 11%; if exp I.SMGD chr lim 16% 1998 - - 31 - - 31 - - 31 - - 16
NC0006190/001 Bcgin:3/1/1998 Frequency: Q MarJunScp Dec + NonComp:ChV Avg 1999 - - 16 - - Bt - - 15 - - 31
County Catawba Region: MRO Subbasin: CTB35 2000 - - 4.1 <3 Late 15.6.15.6 - -- 31 - - 15.6
PF: 1.0 Special 2001 - -- 31.1 - - 15.6 - -- 15.6 - - 31.1
7010: 12 IWC(%):I1 Order: 2002 - -
Denton WWTP Perm chr lim: 90% 1998 - Pass - - Pass - - Pass - - Fa4.Pass
NC0026689/001 Begin:4/1/2000 Frequency: Q Fcb May Aug Nov + NonComp:Singlc 1999 - Pass - - >90 - - 51.9 73.48 >90 >90
County. Davidson Region: WSRO Subbasin YADO8 2000 - 21.2 >90 - 36.7 >90 - Pass - - Pass
PF: 0.30 5paial 2001 - Pass - - Pass - - Fad.>100 NR Pass Pass
7010: 0.0 IWC(%):100 Order: 2002 - Fall >100
Dixie Yarns, Inc. Perm chr lim: 90% (Grab) 1998 - Pass - Pass - - late Pass - Pass - -
NC0083763/001 Bcgin5/I/2000 Frequency: Q Jan Aprlul Oct + NonComp:Singlc 1999 Pass - - NR/Pass - - Fall Pass - NR Pass
County. Stanly Region: MRO Subbasin: YAD12 2000 Fail Pass - Pass - - Fail >100 >100 NR Pass -
PF: 0.072 Spacial 2001 Fa1,Pass >100 97.5 Late H H H - H Fail >100 >100
7Q10: 0 IWC(%):100 Order: 2002 Pass -
Duke Power -Allen 002 Penn chr lim: 16% (Grab)
NC0004979/002 Bcgim 10/1/1996 Frequency: Q P/F + Jan Apr Jul Oct
County: Gaston Region: MRO Subbasin: CTB34
PF: 11.6 Special
7Q10: 95.0 IWC(%):16 Order
NonComp:Single
1998 Pass
1999 Pass
2000 Pass
2001 pass
2002 >92
Pass - - Pass -- Pass
Pass - - Pass - - Pass
Bt - - Late Pass - Pass -
Pass - - Pass - - Fail >64
>64
Duke Power-Belews Creek/003 Perm chr lim: 19 % (Gmb) 199E - Pass - - Pass - - Pass - - Pass
NC0024406/003 Begin2/1/1998 Frequency: Q P/F + Fcb May Aug Nov + NonComp:Singlc 1999 - Pass - - Pass - - Pass - - Pass
County Stokes Region: WSRO Subbasin: ROA01 2000 - Pass - - Pass - - Late Pass - Pass
PF: NA Special 2001 - Pass - - Pass - - Pass - - Pass
7Q10: 80.0 IWC(%):NA Order 2002 - Pass
Duke Power -Buck Steam Pent chr lim:0.7%(grab) 1998 - - >100 - - >100 - -- >100 - - >100
NC0004774/002 Begin:2/I/2000 Frequency:Q Mar Jun Scp Dec + NonComp:Singlc 1999 - - >100 - - >100 - >100 - - >100
County. Rowan Region: MRO Subbasin: YADO4 2000 - - 81 - - Pass -- -- Pass - - Pass
PF: NA Special 2001 - - Pass - - Pass --- -- Pass - Pass
7010: 1010 IWC(%): 0.598 Order: 2002 -- -
Duke Power-CliRSide Penn chr lim: 5.6% (Grab) 1998 -- -- Pass - Pass - - Pass - -- Pass
NC0005088/002 Begin:3/1/1999 Frequency: Q P/F + Mar Jun Sep Dec + NonComp:Singlc 1999 - Pass - Pass - - Pass - Pass
County. Rutherford Region: ARO SuMlasin: BRD02 2000 - - Ell - - Pass - - Pass - -- Pass
PF: 8.8 Special 2001 - - Pass - - Pass - - Pass - - Pass
7010: 287 IWC(%):4.53 Order: 2002 - -
Duke Power -Dan River Penn chr lim: 0.88%(Grab)
NC0003408/002 Begin:6/1/1997 Frequency: Q + Mar Jun Scp Dec + NonComp:Singlc
County: Rockingham Region: WSRO Subbasin: ROA03
PF: 1.8 Special
7010: 314.0 IWC(%)0.879 Order:
1998 -
1999 -
2000 -
2001 -
2002 --
Pass
Pass
Bt
Pass
- - Pass - - Pass - - Pass
- - Pass - - Pass - -- Pass
- Pass - - Pass - Pass
- - Pass - - Pass - -- Pass
Duke Power -Lincoln Turbine Perm chr lim: 23 % (Grab) 1998 - - 65.05 - - 32.5 - - 65,05 - - >92
NC0080781/001 Begin:11/1/2001 Frequency:Q Mar Jun Sep Dec + NonComp:Single 1999 - - >92 - - >92 - - >92 - - 6505
County: Lincoin Region: MRO Subbasin: CTB33 2000 - >92 - - >92 - - 65.05 -- -- 65.05
PF: 0.4 Special 2001 - - >92 - - >92 - - >92 - - Late
7010: 2.1 IWC(%)23 order: 2002 >92 -
Y Pre 1998 Dara Available
LEGEND:
PERM = Permit Requirement LET= Administrative Letter - Target Frequency = Monitoring frequency: Q. Quarterly; M- Monthly; BM- Bimonthly, SA- Semiannually; A- Annually; OWD- Only when discharging; D- Discontinued monitoring requirement
Begin = First month required 7010 = Receiving stream low flow criterion (cfs) += quarterly monitoring increases to monthly upon failure or NR Months that testing must occur - ex. Jan, Apr, Jul, Oct NonComp = Current Compliance Requirement
PF = Permitted flow (MOD) IWC'/. = Instrcam waste concentration P/F = Pass/Fail test AC = Acute CHR = Chronic
Data Notation f - Fathead Minnow, • - Ceriodaphnia sp.; my - Mysid shrimp; ChV - Chronic value; P - Mortality of stated percentage at highest concentration; at - Performed by DWQ Aquatic Tox Unit; bt - Bad test
Reposing Notation: -= Data not required; NR - Not reported Facility Activity Status: 1 - Inactive. N - Newly Issued(fo construct); H - Active but not discharging; 1-More data available for month in question; • = ORC signature needed
16

Data posted to form I of http://www.cytec.com/contact/genera
1 of 1
Subject: Data posted to form 1 of http://www.cytec.com/contact/genera
Date: Fri, 11 Jan 2002 14:55:34 -0500
From: [e-mail]
To: [e-mail], [e-mail]
Good day Tom,
Your e-mail has been forwarded to one Amber Crandell who works with
Industrial waste water treatment chemicals. Amber cabe contacted at
tel: [phone] for furhter discussion in regards t pricing.
Best regards,
Mark Knowles
Cytec product referral
[e-mail]
Forward Header
Subject: Data posted to form 1 of http://www.cytec.com/contact/gene
Author: [e-mail] at Internet
Date: 01/11/2002 2:35 PM
******************************************************************** **********
name: tom belnick
position: Environmental Scientist
org: North Carolina DENR/DWQ/NPDES
city: Raleigh
state: North Carolina
zip: 27699-1617
country: US
phone: [phone],ext 543
fax:
email: [e-mail]
industry: regulatory
subject: SUPERFLOC polymer C-591
produc information:
general information: on
B4:
address:
1617 Mail Service Center
comments:
Submit to Cytec
Hello- We're looking harder at the control of color in wastewater in NC. I have
read of this product being used for color removal, and would like to get some
rough cost estimates ($/1,000 gal bulk shipments) to keep on hand. Thank you
very much.
Received: from www (www.cytec.com [164.84.106.2201) by stnt0l.cytec.com with
SMTP
(IMA Internet Exchange 3.14) id 00705F39; Fri, 11 Jan 2002 14:42:21 -0500
Date: 11 Jan 2002 14:35:50 -0500
To: <[e-mail]>
MIME -Version: 1.0
Content -Type: Text/plain; charset=iso-8859-1
Content -Transfer -Encoding: 8bit
Subject: Data posted to form 1 of http://www.cytec.com/contact/generalfoim.html
tLP_ 33Yib
Ib. /I
1/11/02 3:24 PM

Re: clam Creek Color/Dye Discharge
eviditient
Subject:
Date:
From:
Organization:
To:
CC:
Re: Clark Creek Color/Dye Discharge
Tue, 18 Sep 2001 08:01:37 -0400
Bobby Blowe <[e-mail]>
DENR/DWQ/Construction Grants and Loans Section
[e-mail]
[e-mail], Dave Goodrich <[e-mail]>,
Jackie Nowell <[e-mail]>
Thank you for your comments. They will be included as a part of the hearing record which will remain
open through Sept 23rd.
[e-mail] wrote:
Hello Mr. Blowe,
Mr. Michael Parker of the NCDENR suggested that I contact you regarding the hearing for color/dye standards
for Clark Creek, receiving stream for Delta Mills waste water discharge. I was unaware that there was a public
hearing for the proposed color reductions for Clark Creek. Our property in Lincolnton boarders Clark Creek. We
moved here 2 years ago and I was shocked to see the Creek run red/brown from what turned out to be
industrial dye from Delta Mills some 15 miles upstream. Neighbors told me horror stories of the decline of the
water quality and the reluctance of anyone to do something about it.
I contacted Representative Daniel Barefoot and Senator Hoyle about what appears to be a stream that is teated
much like an open sewer. I went to a public meeting on the restoration of the northern section of the Creek and
am doing water testing for the Extension Agency here in Lincoln County. We need to get the word out to the
folks in Lincoln County that you are taking comments on the reduction of color/dye in Clark Creek. How much
longer will you be taking comments? Can you extend the hearing process to include a hearing in Lincolnton?
After all we are the "people down stream" that are most affected by what is put into the water upstream.
As a property owner on Clark Creek I absolutely believe that Delta Mills should be held to a 90% reduction of
the color/dye they discharge. How long have they been dumping enough dye into the Creek that it runs red all
the way to the South Fork? I wish they would spend an hour or so with me and walk along the Creek here in
Lincolnton. What they would see is a Creek void of fish, frogs and even snakes. An empty river except for the
ruddy color from their discharge. I have heard the argument that the dye is nontoxic, that it is like Kool-Aid. How
much Kool-Aid would you need to put in the water to run red for 15 miles? Even Kool-Aid may be toxic at that
level of concentration. If even if the dye is not toxic no one can deny that the color changes the character of the
water. Do not property owners have the right to have the waters flowing over their property to be "as water
should be in appearance?"
Stay firm at a 90% color reduction. They have dumped at 0% reduction for decades and have benefited
economically from the use of a public resource. Now it is time for them to be good neighbors and clean up their
mess. Thank you.
1 of 1 9/18/01 10:04 AM

r Old/ glen
7325 Watercrest Road
Charlotte,rt1_Carolina 28210
4ntary t14, g060
Mr. Dave Goodrich- DWQ
NPDES Permit Section
North Carolina Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Dear Mr. Goodrich:
DENR - WATER DUALITY
ITY
POINT SOURCE BRANCH
As you know, I am the Technical Review Chairman of the Lake Wylie Covekeepers section of
the Catawba Riverkeeper organization. We would like to formally comment during the
upcoming NPDES permit renewal process for the following dischargers:
Discharger
Permit No.
Current Permit
Expiration
Gastonia WWTP- Long Creek
NC0020184
1/31/2000
Newton WWTP
NC0036196
7/31/2000
Hickory -Henry WWTP
NC0040797
7/31/2000
Lincolnton WWTP
NC0025496
7/31/2000
Cherryville WWTP
NC00'1'1140
7/31/2000
Stanley WWTP
NC0020036
7/31/2000
Maiden WWTP
NC0039594
7/31/2000
Delta Mills Maiden WWTP
NC000619d
7/31/2000
Lowell WWTP
NC0025861
9/30/2001
Collins and Aikman d/b/a
Cramerton Auto Products, L.P.
NC0006033
9/30/2001
Pharr Yarns WWTP
NC0004812
9/30/2001
Consistent with FOI Act requirements, we will be contacting the NCDENR regional office at
Mooresville to request dischargers' application documents, draft permits and background
materials. Please notify me as soon public comment hearings are scheduled.
We also wish to continue our ongoing commentary and involvement with the permit renewal
process around the following dischargers:
Crompton and Knowles
Clariant Corporation
Permit NC0005274 Permit expired 5/31/1996
Permit NC0004376 Permit expired 8/31/1996
Thank you for your continuing cooperation and attention to our requests.
Michael L. Jones
cc: Donna Lisenby, Catawba Riverkeeper®
Michael Parker, NCDENR Mooresville Regional Office

X-Idol- inclviQA 6?iI
NPDES Public Hearing
Catawba Color Dischargers
August 28, 2001
TABLE - NPDES Color Permitting Policy for Catawba River Basin
NM()
Tier
Facility
Color Permitting Requirement
1
Pharr Yarns^
Tier 1 facilities will receive color monitoring -only, consisting of monthly
effluent sampling, and summer -only (April -October) instream monitoring
(upstream, downstream). If observed, plume descriptions should be •
recorded. In addition, a Color Reopener Special Condition will be added
that allows permits to be reopened and additional requirements imposed if
color problems persist.
2
Cramerton ,
Tier 2 facilities will receive Tier 1 requirements plus preparation of a
Pollution Prevention (P2)/Best Management Practices (BMPs) report.
This report will address the potential for the facility to reduce effluent color
by incorporating P2 measures and/or BMPs prior to treatment. For example,
the facility could investigate the dyeing process, looking at the potential for
dye substitution, improved dyeing efficiency, etc. The facility could do this
work independently with their dye supplier or other resource, or request
voluntary assistance from the NC Division of Pollution Prevention and
Environmental Assistance. The report will be submitted within 12 months of
the permit effective date.
Lincolnton
Yorkshire
Gastonia- Long
Creek'
3
Hickory
Tier 3 facilities will receive Tier 2 requirements plus preparation of a Color
Reduction Study. The color reduction study will involve an end -of -pipe
treatment evaluation to develop costs to reduce influent color by 75% and
90%. The reports will be submitted within 24 months of the permit effective
date.
Cherryville2
Gastonia-
Crowders
Creek
4
Delta Mills
Tier 4 facilities will receive color reduction limits (90% color reduction
between influent and effluent) to be implemented by the permit effective date.
Footnotes:
1. Ranking accounts for removal of major color discharger (Fleichman's Yeast) in April 2001, after the
Color Study was completed.
2. Ranking does not account for scheduled removal of lone textile SIU in July 2001. After textile
removal, facility may request re -ranking with less stringent permitting requirements.

WOMBLE
CARLYLE
SANDRIDGE
& RICE
200West Second Street
Winston-Salem, NC 27101
Mailing Address:
Post Office Drawer 84
Winston-Salem, NC 27102
Telephone: [phone]
Fax: [phone]
Web site: www.wcsr.com
via csifnile and U.S. mail
Gr gory J. Thorpe, Ph.D.
cting Director
ivision of Water Quality
North Carolina Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
•
December 28, 2001
Re: Request for Additional Information
NPDES Draft Permit
Permit No. NC0006190
Delta Apparel -Maiden Plant
Catawba County
Dear Mr. Thorpe:
Pef
c:7 M 't f-Vd/1/rt
ji F.02024
r4,1 0 7 2002
DIV, OF WATER
DIRECTOR'S OFT:ICE
This letter supplements our December 21, 2001 correspondence provided on behalf of Delta
Apparel, Inc. ("Delta") to the November 21, 2001 Request for Additional Information from the
Division of Water Quality ("DWQ"). Again, Delta reiterates its objections to DWQ's proposed color
restrictions to Delta's effluent in the South Fork Catawba River.
Without waiving any objection to the use of the enclosed data, Delta provides the following
in response to the threat of enforcement in DWQ's November 21, 2001 letter:
• DWQ's request: "Amount of polymer added on a daily basis for the period May 1,
2001 through August 21, 2001." This information is attached as Exhibit A.
• DWQ's request: "Any associated influent/effluent color measurement of color
reduction [during May 1, 2001 through August 21, 2001.]" Any data not previously
provided in Delta's September 21, 2001 response is attached as Exhibit B. The tests
represented by Exhibit B were conducted utilizing the HACH DR2000
Spectrophotometer Platinum Cobalt color meter (Platinum Cobalt test), not ADMI
methodology.
• DWQ's request: "Results of all ADMI color measurements collected during the
Cytec polymer trials to the present date to determine the color removal percentages
based on ADMI methods." This information is attached as Exhibit C.
GEORGIA / NORTH CAROLINA / SOUTH CAROLINA / VIRGINIA / WASHINGTON D.C.

WOMBLE MIF
CARLYLE r
SANDRIDGE
& RICE
PLLC
Gregory J. Thorpe, Ph.D.
December 28, 2001
Page 2
As Delta previously commented to the color restrictions proposed in its draft NPDES
permit, at the present time, additional monitoring is needed to understand the process and effect of
color removal at Delta. Delta's voluntary tests have not been conducted throughout an entire year
to evaluate the effects of Delta's production changes, chronic toxicity impacts, or other external
factors. Therefore the enclosed data does not support a permit limitation relating to color. The
enclosed data, however, does demonstrate several points.
First, the data demonstrates that DWQ's reliance upon a comparison between influent and
effluent to regulate color ultimately runs counter to its goal to reduce effluent color. If a 90% color
reduction comparing influent to effluent is achieved (which occurs infrequently), it is due to the high
ADMI color content of Delta's influent rather than a reduction in effluent color. Thus, a permit
limitation based upon an influent to effluent comparison creates an incentive to increase influent
color so that a higher percentage reduction is obtained. For example, Delta could increase its
production of dyed textiles at the Maiden Plant to raise its influent ADMI color levels. This course
of action may allow Delta to meet a percentage comparison limitation, but would do little to reduce
effluent color entering Clark Creek.
Second, the data shows that Delta's current means to address color -the Cytec polymers --
impacts Delta's ability to meet its chronic toxicity permit condition -a condition which may have
detrimental environmental impacts. As DWQ knows, Delta exceeded its chronic toxicity permit
limit in August. Delta and Delta's consultant, Cytec, believe that the polymer usage in August
(which was in the 300 + gallon range) was related to the chronic toxicity exceedance. Delta does
not currently understand the relationship between polymer use and chronic toxicity and it therefore
needs additional time to monitor this relationship. (As you know, Delta's chronic toxicity is
measured quarterly.) Because DWQ will not waive violations of existing permit limitations during
Delta's attempts to study or meet a color limitation, the relationship between chronic toxicity and
polymer dosage requires more study to avoid any detrimental impacts upon Clark Creek.
Finally, the data demonstrates that the percentage of color removal fluctuates significantly
(notwithstanding Delta's maintenance of a relatively constant polymer dosage) due to the factors we
detailed in our September 21, 2001 correspondence. These factors consist of production variables,
such as dye and bleach use, and external factors such as water density. Delta anticipates that water
density will add increasing complexity to color removal in the coming winter months. At this time,
Delta does not understand the relationships among production and external factors and the
fluctuations in its color removal percentage. At a minimum, however, the data does not support a
90% limitation.

WOMBLE pir
CARLYLE
SANDRIDGE
& RICE
PLLC
Gregory J. Thorpe, Ph.D.
December 28, 2001
Page 3
If any conclusion can be drawn from the limited data, it is that Delta's effluent consistently
meets 1200 ADMI when using the polymers. Delta's effluent, without polymer treatment, is
frequently as high as 6000 ADMI. A permit condition requiring a monthly effluent average of 1200
ADMI is supported by the data and represents as much as an 80% color reduction from untreated
levels.
Delta has reiterated throughout the permitting process that it is committed to reducing its
effluent color. Delta voluntarily participated in the Alliance study and conducted numerous color
trials to find a technology capable of effective and consistent color removal. It was by Delta's
voluntary efforts (and significant expense) that a technology--Cytec polymer, which appears viable,
was discovered. (The Cytec technology is expensive -the amount of polymer dosage demonstrated
on Exhibit A would cost at least $500,000.00 annually. This is a significant expense to meet a
regulation that is based on aesthetics only and where no detrimental environmental impact exists.)
A proper limitation can only be derived by continued efforts by Delta to monitor color
reduction and open communication with DWQ to formulate a rational limitation which will not
disturb other permit conditions. Aesthetics should not be gained at the expense of other
environmental issues or at an expense that imposes a financial burden on the company.
Very truly yours,
4,c. 44,0'4.. /1/.0,14..
Lori P. 1-Iinnant

� Mc ,4iJa,r J )
—�2UU 1 " l: 01.63
C.5o11 6``L
LP Co low _ke v ea goLeet'__CYet_Scie.
.eq' _l. 5 — LRO L L1, L — a o G-c 1ss, 4cc,3 (27 - 3 31 && is ,
y 2,1 -. - "t,L 1y G-c 1s , 4w3 3 3�t
- Lq D . 6-cis , c2, (y o21 - a i C�-� �s �4c� n - 364 G-&J ,
I J11,4v - a -! G-c.,.ls • A,, 30 -- 3og 6-cis
-7r,i.ly a - :2 ��ls 45 3 t - 30ls
e. G--cL 1s , -c,IY 2 - s
- ;. a. L G-A.. s_, TO, v - s r
c l� - 173 6-ads , :hay 30 - 54 Gals
(Q '- G 6c, I s . Lit/ 3 1 - 4 (e 6-ed. 5
_a_ c.- 0-0 — I n Q Cr L1 s
u•R.. 2t - 1 33 C-J
- 6--als.
AGte G 1 - ;2.is
L_.ci L 2 3 - 2 r1 s,
t Q2S - 1 '-Li irct s.
e ate �1 R -�, l.s ,4r � — 2()
0 3 - '1 G-c 1 s
"au) 2., 2 - 2'7S
Itiue.
ri�y i
_ ✓'y_ �)�D — 22 L, (o (rrr I5
au - c 3 G-&fs.
- i 8 Ce c-0.1
) - Z r1cf
9 G-a,s, Au 5 1 — 344 GLts,
Al 5 - 3a_-.ls
-�,is, Att_3 -Flo
I 7 9 G-ds . - 4 - 36L/ Gr�kL
Li_ La- - / S' 3 Grc�L� Auj 20 - 3,0 GCJs,
44.0 (364 G-o Ls_� a EXHIE
— 1 s � , Arl a - 3 o 5
t 7s- _cretk, 14k_. 23 — 3 Zo

7 6—
o
------- - 3 - a L � ,,L ' •____! z 0_0
Li 2
2�-o' z 1�' 3n75
. 700
-0.6
[' I Ce^�ova 7_
67„
°7v
nn

cs)
•
0
=3s
(DO !7_0_
10-
-1�
-6
Ireee.,c1 Arnov&4
610
E
z
C
L?
a -ce
1
'Z7
O
32
107
. '700
41. o
`70
oz,
564
73 %
SS d7

0
DA. R S e4. /U /Gem.fQ!/L$,•i
77 f, 13°16
5 sa
Hot-o 5P-C. 5,2.9
3'5-d
1 f-II-of . Tu-�', KIDS
t- is-61
1l-2.c of
it-at-01
1= '
E-4 . 305 CF)
3sS
so
r
77%
11-22-ot a-T4
l.i - a3 -o i L= c-c . 306
:704. Coo a Slot 60
�.��. _ so -.
. 11 - 3 o 0 t L 1-t , 41,
7/ c76
j-e-A, L22.5
a-p -- e 1 (l So 90 �o

Remover. i

•
WOMBLE
CARLYLE
SANDRIDGE
& RICE
A PR(,
1 L\IN1.11 C(>),II'.k7:5
via f7' simi
Gr- ory J. Thorpe, Ph.D
A ' ing Director
...vision of Water Quality
North Carolina Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
200 West Second Street
Winston-Salem, NC 27101
Mailing Address:
Post Office Drawer 84
Winston-Salem, NC 27102
Telephone: [phone]
Fax: [phone]
Web site: w4Vw.wcsrcom
December 21, 2001
Re: Request for Additional Information
NPDES Draft Permit
Permit No. NC0006190
Delta Apparel -Maiden Plant
Catawba County
Dear Mr. Thorpe:
Lori P. Hinnant
Phone: [phone]
Fax: [phone]
Email: lhinnant [e-mail]
1001a
IAN 0220
02 `VI
DI v, C1• WATER
OQU� 7-Y
This firm represents Delta Apparel, Inc. ("Delta"). This letter is to notify the Division of
Water Quality ("DWQ") that Delta plans to respond to DWQ's request for additional information
by December 28, 2001. This response date is timely and complies with the 10-business day
mandate in DWQ's November 21 letter. Despite the date (November 21, 2001) on DWQ's letter,
the postmark indicates mailing on December 6, 2001, and the correspondence was apparently
misdirected by the post office to another company. Thus Delta did not receive the letter until
December 14, 2001.
DWQ's letter provides that the Division will consider enforcement action against Delta
unless Delta takes the action dictated in the letter. In this instance, the Division has no such
enforcement authority because DWQ is not entitled to the infoimation.I However, in its continued
spirit of cooperation, Delta will supply the requested information, but does so without waiving any
objection or right it has relating to DWQ's Color Policy for the South Fork Catawba River,
Delta currently has no legal obligation to conduct any color study. But for Delta's
efforts to voluntarily address the color issue, Delta could have ceased doing anything
after submittal of the Alliance data, receipt of DWQ's Color Policy and receipt of the
draft permit.
GEORGIA / NORTH CAROLINA / SOUTH CAROLINA / VIRGINIA / WASHINGTON D.C.

,
WOMBLE/�•
CARLYLE
SANDRIDGE
& RICE
I'LLC
Gregory J. Thorpe, Ph.D.
December 21, 2001
Page 2
including but not limited to, those objections contained in its previous comments provided to
Hearing Officer John Robert Blowe on September 21, 2001.-
The requested information relates to a recent voluntary color study conducted by Delta. As
you know, DWQ, for the first time, has created permit limitations with regard to effluent color in
Delta's draft NPDES permit. Delta previously submitted comments to the draft permit and asserted
that the color restrictions imposed were without the requisite evidentiary foundation and could not
be supported. The data DWQ is now requesting was not considered by DWQ in arriving at the
limitations contained in the draft permit. Moreover, the data concerning percent reduction between
influent and effluent utilizing ADMI measurements was initiated by Delta (1) after receipt of the
draft permit, and to (2) to build evidence for challenging any final permit limitation with regard to
color.
Delta has reiterated throughout the permitting process that it is committed to addressing color
in the South Fork Catawba River. Delta's voluntary actions, taken at great expense, evidence its
commitment. Delta continues to believe, and the results of all of the color studies conducted to date
evidence, that any permit limitation on color can only be derived by Delta's continued efforts to
monitor color reduction and the effects on other permit parameters. (After all, we don't want to
achieve color reduction, which is driven totally by aesthetics, at the expense of toxicity or other
permit parameters, which in fact have detrimental environmental impacts.) In any event, Delta will
provide the requested data because it further evidences that imposition of any color limitation is
premature.
Very truly yours,
Lori P. Hinnant
Since the public hearing for Delta's draft permit occurred on August 28, 2001,
pursu t to N.C. Gen. Stat. § 143-215.1(c)(4), the Commission has "90 days .. .
[from the public hearing] to grant or deny" Delta's permit. Thus, Delta's final permit
was d e by law on or before November 26, 2001.

31JDIZI 1•;• ti MIMIC firAFIlla 113.5g OCCTI SCELCIILICCI,
• ";:corcein ite the proposed renewal and issuaner.of tho-
. toliowinglIPDES Pennits4. • :
-Perrnitpurntet NC000S274 to YorlialtirsAmericanz.
••4j loaf die Yonne. Nikstreater Treatment Mutt
• FaiXty rotated ir4imerdVOri3ton Countfylbe tloa
- • tigtiharge—drfreated industrial wastewater and
stotntwater into theSouthfork-CatatebalUven '
- Permit mullet MC0006150-0 Delta Apparetine'•
ffr1 dirt Deltas Wastewater Treatinent Plant located in
• tvfaiden (CatzwbaCounry) fostredilersugnoftreated
'f.incrustriatwastewarerintaChntareir4 ;
• Petitnit number Ntxtriztiflatio the Gankatin,
tit the Crowder* Creek. Wartawater Treatment Plant-
, Itiaated ir Gastionin(Gaston dourtity)fee died iseharge
9ffreatecirmitileipalwastewaterinotteowdersCtse*
Pennftriumber NCOM84EtertheiCity of Gastonia..
• N. die. Lang -Creelc Wastewster Treatment Dant-,
tevatedirticrtatnitii(Castonceinnee>rte-thediaellarge.-
inendua Soodeltdr-
Otlidtalliiitwg" • - •
:..-.E'esniitnumbetiNCif13254PfatoitheCiti ofirecotittiffr
• for itoLineotniOnVit stewstetTfeannent Plant !Owe&
iti..Lftreotritort (Lineortitoarirja fat, ilvmdischargnof
: treitecHitunietpid, wastewater ftts•the Sbuth For*
• •••• Catawbiltivore-,-.
number Nt0044440ii t City o-
,;.511tirjrtiiire,f6r the CherryvilleiMstewstecTivatnitaft
, PrInt-tocaredin Cherly,M (flaitonCbunty) rthe
.661tatircffi.*gciPtigliciPOWastcolaWmt:b4112;`
Creek 74.7.:;-•
,ecrretiinittilitikrataochtfiiti*akemily;i0
theifotry Forttl?7intewa ter Treatment Plant rota tedirri
•
• fEekory (CainwtaCblinty)fonthed II -charge of trratett:
4inuniiipairatimatetintadiclieriryPortrRivet.
......ptIRPOSE.: Each o* thew rides has appffed bt
• ferretrat ot tilefristPlaES pErruit ThrtIc diseharger�t..-
. treated domesftoriminpalstairewetes into waters.; .
•
eithaiattewhoRiverbitsimAstittsbasieofptielirnirtarye.
-staff review ,anct argficatioirof Article 21 of Chapter- -
•141,.-Eknend Staraten of Noriii=earolins; and mime,
rawfur stanctardt and-reguladonn the North Carolina
Environitontal ManagementCorrrmissiooroposesto •
iss-ge..ta NVDES. perm it Mr: einti-.faxil subject to-• •
specprilhitzst 1imftations and special: conditirmso
• TheDitvotrofliteDivisionofVeatetQuality pursuant
.'roNCCIS 1.41.215.1(sX3}ind Regutation 1 5, NCite.
21W,Settion.010Citias determined the& Frits thetairdie
• itnerostthat s meeting be heldtorteeive all pertinent
publienornirienttla whet/tette, itsuroxidifjk or deny,
,
PRIA.1.1)118...The1karingwiltbe:tisanctucted intim
foiWnguarlet: •1
A.AttexpranatintroftheNortherridinnEntOrormitntatt,
ii.rurieritCornmissiinnepeansittngproindinewilk,
•• PrresentedtrytheDivisiterofWatet Ettsaik,
•
-.1?3?Fg14.k46°,49.titto**If.OrvotgAcid+PT01419.
•
4heanadnirpleapp1iontk..::
• 1.1111111re Cbmnient- Cbmnient* staternenisidati and:
•olifeihrforiattint ritiy m ittectinwrili rigprio ton
;;'..,:arthoingiterrreetinwortrayberPresenctedcmsllyatdier
*minPersons &siring to srcak-vfili-indicate thin
1ktintarthrtinieofregistratfortiatthernsteinw *that.
parsons' &sizing to spook. rote det set* tortia*
friatviinnitiCriliy be Retliseretion of the;
2....:,'.:ple5rttf Often Orat proserrOstiontlharesteeed (hretit
-Thushould- leetietianpahied..rep three, weitter***
.": cOpien. whieliwili be filed -with Division staff at the--
rintearitesttitireteL_
• brOeisontpro-sentrogleithisortiP.
'yetF gtLaw howeven thehearingo !freer map-
eiliquistionsfbrerafiriCeitek:
Thilearingicrordtdaylittrosedatithecconcitntoni,
• ..i.citNli2kifillifatliatffnine;:.
CitirennResotriecantra !,',7
1363:Chenriirellfraftwai
INBIKNOGIViaist2f030,-
•
cop* of. dr *aft NP6Or
,,,,•:::'aridlOtiristfoiAlgdicrocair*ei(.thidi.seharge(a).T.or .
An:Carl irthisRtverir "
"...?:,;1!,tCfAviarlsrtitsfriVarerObstgyINPIMiithttta,
•
'•l6i7tfailgervienConter
• _
„/,4•,-E.
Rktrekh,NorthearolineVISIVEttirr •-
-nornbat (?191.2733.4c1M.
..atetssion51321* •:: 'i•••
alstetiatfoniand other rtifiinn;eiraii
'ott:tif.WItteriltatity NastitralabniirStrreit;
RoierriS75•ntateitithdare Elidictkr Rattier. 1,156Tft,
•••'?.
•
yJw

• " WArF9
' '117-:
G
r C
Pine PA( 450°:1_,
Michael F. Easley, Govemor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Gregory J. Thorpe, Ph.D.
Acting Director
Division of Water Quality
Certified Maid 7000 1530 0002 2100 2274
Return Receipt Requested
November 21, 2001
Mr. Gene Hudgens, Plant Mgr.
Delta Apparel, Inc.
100 West Pine Street
Maiden, North Carolina 28650
Dear Mr. Hudgens:
Subject: Request for Additional Data
NPDES Permit NC0006190
Delta Apparel- Maiden Plant
Catawba County
I am writing in response to your letter of October 23, 2001 refusing to supply the information requested by
Tom Belnick in his letter dated October 9, 2001. I ask again that you provide to DWQ the following
information:
• Amount of polymer added on a daily basis for the period May 1, 2001 through August 31, 2001. In
addition, any associated influent/effluent color measurements of color reduction performance during
this period.
• Results of all ADMI color measurements collected during the Cytec polymer trials to the present date,
to determine the color removal percentages based on ADMI methods.
You misunderstand the nature of DWQ's October 9, 2001 request that Delta Apparel provide DWQ with
the results of your addition of polymer to reduce color in the discharge from your wastewater treatment
facility. DWQ seeks the color data in order to place the appropriate effluent color limit in NPDES Permit No.
NC0006190. Any information in Delta Apparel's possession regarding this data is relevant to the
establishment of the final permit limit, whether that information was generated prior to or subsequent to the
public notice of the draft permit.
You also misunderstand the nature of the draft permit that was the subject of the public hearing on
August 28, 2001. DWQ is not required to issue the draft permit. It may alter the permit after public hearing,
particularly if information comes to light that would support a different effluent color limit. DWQ can also
renotice a draft permit if necessary.
DWQ has clear authority to request the above information. N.C. General Statute §143-215.1 (c)(1)
provides:
...The Commission may conduct any inquiry or investigation it considers necessary before acting on an
application and may require an applicant to submit plans, specifications, and other information the
Commission considers necessary to evaluate the application....
Furthermore, Part II Section B.8 of Delta Apparel's current permit provides that Delta must submit such
information:
The permittee shall furnish to the Permit Issuing Authority, within a reasonable time, any information
which the Permit Issuing Authority may request to determine whether cause exists for modifying, revoking
and reissuing, or terminating this permit or to determine compliance with this permit.
NR
Customer Service
1 800 623-7748
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone]

SENDER: COMPLE
E THIS SECTION
• Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
• Print your name and address on the reverse
so that we can return the card to you.
• Attach this card to i:he back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
R'Ir. Gene Hudgens, Plant Manager
Delta Apparel, Inc.
100 West Pine Street
Maiden, North Carolina 28650
COMPLETE THIS SECTION ON DELIVERY
A. Received by (Please Print Clearly) ,
C. Signature
X
B. Date of Delivery
^ y—a
❑ Agent
11� El Addressee
D. Is delivery address different from item 1? ❑ Yes
If YES, enter delivery address below: ❑ No
3. Service Type
Certified Mail
❑ Registered
❑ Insured Mail
❑ Express Mail
❑ Return Receipt for Merchandise
❑ C.O.D.
4. Restricted Delivery? (Extra Fee)
❑ Yes
2. Article Number (Copy from service label)-1000 OC3C--3 k- I- I
PS Form 3811, July 1999 Domestic Return Receipt 102595-99-M-1789

NCe►06190
Delta Apparel
�vernber 21, 2001
If Delta Apparel does not supply the requested information within 10 business days following receipt of
this letter, DWQ will consider Delta Apparel to be in violation of its permit and take appropriate enforcement
action. If you have any questions about this data request, please contact Tom Belnick at (919)-733-5083,
extension 543.
cc: Coleen Sullins, Water Quality Section
Bill Reid, Point Source Branch
Bobby Blowe, CG&L
Shannon Langley, NPDES Compliance
Rex Gleason, MRO Water Quality
NPDES Permit File; NC0006190
ru
ru
O
r-R
ru
7000 1530 0002
Sincer 1y, p
O(
V Gregory J. Thorpe, Ph.D.
U.S. Postal Service
CERTIFIED MAIL RECEIPT
(Domestic Mail Only: No Insurance Coverage Provided)
Postage
Certified Fee
Retum Receipt Fee
(Endorsement Required)
Restricted Delivery Fee
(Endorsement Required)
Total
Mr. Gene Hudgens, Plant Manager
Sent Delta Apparel, Inc.
Street 100 West Pine Street
Maiden, North Carolina 28650
City, 9
Postmark
Here
PS Form 3800, May 2000 See Reverse for Instructions

DELTA
APPAREL, INCORPORATED
October 23, 2001
Mr. Tom Belnick
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Water Quality Section
NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Re: Request for Additional Data
NPDES Permit NC0006190
Delta Apparel -Maiden Plant
Catawba County
Dear Tom:
0
V
�.r
Cr)
U
On October 9, 2001, we received your letter requesting additional information for
Division Hearing Officer John Robert Blowe and we are confused by your request. First, the
data concerning the amount of polymer added during the time period before the July 24, 2001
issuance of the draft permit has been adequately provided to Mr. Blowe in our September 23`a
public comments. We have also previously provided all relevant ADMI data to Mr. Blowe. Any
information after the July 24, 2001 issuance of the draft permit is not relevant since it was not
relied upon by the NPDES Unit in its decision to mandate a 90% permit limitation.
Secondly, as you are aware, Mr. Blowe closed the public record on this matter on
September 23, 2001. It is our understanding that Mr. Blowe's consideration of Delta's draft
permit must proceed upon the public record established as of that date. Any materials submitted
and relied upon by the Department after the closing of a public record could be challenged as
inappropriate by third parties.
In closing, Delta respectfully declines to provide the requested information. Given the
level of involvement by third parties surrounding the Department's color reduction efforts in the
South Fork Catawba River, we are concerned that providing any of the data you request would
not be in Delta's or the Department's best interest. Please feel free to contact me if you have any
questions.
Sincerely,
Gene Hudgens
v
100 W. Pine Street • P.O. Box 37 • Maiden, N.C. 28650 • [phone] • FAX [phone]
Change your shirt.

`State of North Carolina
• Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Gregory J. Thorpe, Ph.D., Acting Director
October 9, 2001
Gene Hudgens, Plant Mgr.
Delta Apparel, Inc.
100 West Pine Street
Maiden, North Carolina 28650
AwirA
NCDENR
Subject: Request for Additional Data
NPDES Permit NC0006190
Delta Apparel -Maiden Plant
Catawba County
Dear Mr. Hudgens:
In order to complete the evaluation of Delta's NPDES renewal request, the Division
Hearing Officer is requesting the following data be submitted by October 23, 2001.
• Amount of polymer added on a daily basis for the period May 1, 2001 through
August 31, 2001. In addition, any associated influent/effluent color
measurements of color reduction performance during this period.
• Results of any ADMI color measurements collected during recent months to
determine color removal percentages based on ADMI methods.
If you have any questions concerning this data request, please call me at (919) 733-
5083, extension 543.
S' erely,
014
om Belnick
NPDES Unit
cc:
Bobby Blowe, CG&L
NPDES File
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer Visit us on the INTERNET @ www.enr.state.nc.us

WOMBLE
CARLYLE
SANDRIDGE
& RICE
A PROFESSIONAL LIMITED
LIABILITY COMPANY
200 West Second Street
Winston-Salem, NC 27101
Mailing Address:
Post Office Drawer 84
Winston-Salem, NC 27102
Telephone: [phone]
Fax: [phone]
September 21, 2001
John Robert Blowe
Hearing Officer
Division of Water Quality
Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: NPDES Draft Permit
Permit No. NC0006190
Delta Apparel -Maiden Plant
Catawba County
Dear Mr. Blowe:
Lori P. Hinnant
Direct Dial: [phone]
Direct Fax: [phone]
E-mail: [e-mail]
On August 28, 2001, you and others from the NPDES Unit and an EPA representative visited
the Delta Apparel ("Delta") plant in Maiden, North Carolina. During your visit, Delta provided
written comments to the referenced draft permit and discussed its concerns and objections to the
color reduction requirements. As Delta explained, since February 2000, it has been voluntarily
conducting studies to remove color from its effluent. Dave Goodrich, Supervisor, NPDES Unit,
requested that Delta supplement into the record the results of the studies. Accordingly, we now
incorporate by reference Delta's August 28, 2001 written comments and provide the requested
supplemental information.
Again, Delta opposes the color reduction conditions in its draft permit for several reasons.
First, the evidence in the record demonstrates that Delta requires additional time to continue
monitoring and studying the process of wastewater color reduction. Second, the draft condition
formulated by DWQ lacks any technical foundation and is arbitrary. Finally, the current draft permit
color limitation is not technologically feasible.

John Robert Blowe
September 21, 2001
Page 2
I. The Evidence in the Record Demonstrates that More Time Is Needed to Monitor Color
Removal.
A. The Results of Delta's Voluntary Color Removal Trials Have Produced Varying
and Inconclusive Results.
Over the last several years, Delta has voluntarily utilized various color removal technologies
in its efforts to reduce the color of its effluent. Delta has learned that color removal is not a simple
process. Rather, it is the result of complex chemical reactions. Whether a particular removal
technology will "work" is purely one of empirical observation, i.e., Delta must install the technology,
observe, and test its wastewater. To date, Delta has been unable to predict whether any particular
technology will remove color in the plant's wastewater system.'
We attach, as Exhibit A, a time -line and data from the color removal trials conducted at the
plant. Summaries of the trials are listed below:
Clariant Trial (February 8 - February 16, 2000)
Product
Clariant introduced chemicals into the wastewater stream intended to remove color
by chemical reduction/hydrolysis.
Methodology
Start of trial: untreated effluent ADMI2 color of 1970 units.
End of trial: treated effluent ADMI color of 1160 units
Comparison
The trial measured untreated effluent at the beginning of the trial to treated effluent
at the end of the trial.
1 For instance, sometimes a color removal technology may perform well in bench trials using
beaker tests. The technology may not function, however, when introduced into Delta's entire
wastewater system.
2 The ADMI ("American Dye Manufacturers Institute") color test is a methodology to
determine the color strength of a solution in "color units."

John Robert Blowe
September 21, 2001
Page 3
Plant Production Variables
At the time of the trial, 50% of the plant's production was optical whites. (Delta
learned that residual peroxide (used for bleaching) counteracts the effectiveness of
reduction/hydrolysis chemicals).
• Other Permit Parameters
The Clariant product affected other permit parameters. For instance, chronic toxicity
("conductivity") fluctuated during testing.
• Results
No observable effluent color change was noted at discharge point.
Bio-Chem Resources Trial (July 10 - October 2000)
Product
Pulverized silica was added to wastewater to act as color precipitant.
Methodology
Start of trial: July 10, 2000 with ADMI Color of 1190 units (on July 11, 2000).
End of trial: October 17, 2000 with ADMI color of 1820 units.
Comparison
Testing was conducted only on discharge effluent.
Plant Production Variables
None recorded.
Other Permit Parameters
No testing of other permit parameters, such as chronic toxicity, was conducted in
conjunction with trial.
Results
There was no visible color reduction at any time during the trial.
Cytec Trial (January 23 - May 2001)
• Product

John Robert Blowe
September 21, 2001
Page 4
The Cytec Trial relied upon the introduction of highly charged and cationic liquid
polymers into the plant's wastewater.
Methodology
Trial began by testing only one part of plant's wastewater system (Train 1).
The other portion of the wastewater system remained untreated, acting as a control
(Train 2). The test used the HACH DR 2000 Spectrophotometer Platinum Cobalt
color meter (Platinum Cobalt test) to measure color.
Comparison
All comparisons for the effectiveness of the polymers were created by comparing
Train 1 to Train 2. Therefore, only treated effluent to untreated effluent testing was
conducted.
Plant Production Variables
Over the period of the trial, dye use was generally increased.
Other Permit Parameters
No testing of other permit parameters, such as chronic toxicity, was conducted in
conjunction with trial. However, a chronic toxicity condition was noted at the plant
during high use of the polymer.
Results
The Cytec polymers have shown the most promise in reducing the color of Delta's
effluent.
B. Many Variables Affect Delta's Ability to Remove Color.
A significant variable affecting Delta's ability to remove color is dye use fluctuation. Dye
use changes dramatically based upon production demands. An example of the dramatic fluctuation
in dye usage that Delta typically experiences is set forth below:
June 27, 1999 — 22 % dye use
July 4, 1999 — 2% dye use — 1-b0 d/1 y
July 11, 1999 — 23% dye use
August 22, 1999 — 33% dye use

John Robert Blowe
September 21, 2001
Page 5
August 29, 1999 — 42% dye use
September 5, 1999 — 32% dye use
December 19, 1999 — 32 % dye use
December 26- 1999 — 3% dye use — Nv L I CA 1
January 9, 2000 — 30% dye use
Importantly, color removal technologies do not remove color in a constant or linear
relationship. For example, if one ounce of a color removal product is needed to treat one gallon of
dye, it does not follow that two ounces will be needed to treat two gallons of dye. Therefore, instead
of a linear relationship, the relationship between dye and color removal product is an exponential
one. This relationship means that Delta is unable to predict what amount of color removal product
will be needed to achieve a constant amount of color removal as dye use fluctuates
Furthermore, due to recent production demand changes, the plant's history of dye use is not
an accurate measure to predict future dye use. Delta has increased its dye ratios to levels never
before employed on a year-round basis. Currently, dye ratio sometimes reaches 65%. Tests have not
been run to determine how wastewater created by such increased dye ratios will (if at all) respond
to color removal technologies. Significantly, no monitoring has occurred during any color removal
test over the range of dye use being currently experienced by the plant. This information is needed
in order to generate reliable information concerning what reductions are achievable. Simply
considering the color reductions from the color removal trials do not accurately reflect Delta's
current ability to remove color.
The uncertainty of achieving successful color removal with dye use fluctuations is
complicated by another variable -- water density. In the coming winter months, Delta's wastewater
will become colder and its density will increase. It is our understanding that as water density
increases, color removal technologies are hampered since inducing color precipitation from
wastewater is a function of water density. The ability of any color removal technology to operate
under cold water conditions is unknown since Delta has not performed any color removal trials
during winter months at high dye ratios.
At this time, Delta has insufficient data to know what color reductions are possible in light
of the variables present in its operation such as dye use and water density. Accordingly, more
monitoring is needed to understand the process of color removal at Delta.
C. Chemicals Utilized to Remove Color Can Adversely Affect Other Permit
Limitations.
The DWQ stated in its June 5, 2001 NPDES Color Permitting Policy ("Color Policy") that
"[t]o date, there are no data to show that the colored effluent is posing a human health concern, or
that color is a source of impact on the aquatic biota." Simply stated, the color in Delta's effluent
does not adversely affect fish or aquatic life or cause an exceedance of water quality standards.

John Robert Blowe
September 21, 2001
Page 6
However, other characteristics within Delta's wastewater, such as chronic toxicity, may adversely
affect fish or aquatic life. Chronic toxicity, among other parameters, is affected by the chemistry of
Delta's wastewater, which chemistry in turn is affected by color removal products during color trials.
Therefore, while attempting to address the subjective aesthetics of the South Fork Catawba River
watershed, Delta must proceed with caution to insure that effluent characteristics that do affect fish
and aquatic life (and water quality standards) are properly maintained.
The impact of color removal products upon chronic toxicity is poorly understood at this time.
For instance, on August 14, 2001, the DWQ Mooresville Regional Office inspected the plant and
discovered a condition of chronic toxicity. (See Notice of Violation (NOV) attached as Exhibit B).
On the date of the inspection, Delta was operating with high dye ratios and thus was utilizing large
amounts of Cytec polymer for color removal. Delta is unclear of the factors which, in conjunction
with the polymer, led to the chronic toxicity condition. Nevertheless, as the incident demonstrates,
color removal products will affect the ability of Delta to comply with other permit parameters. Delta
needs additional time to determine the amounts of color removal product which may be maintained
in its wastewater system without detriment to other permit limitations.
II. The Draft Permit Color Reduction Limitation Formulated by DWQ Lacks Any
Technical Basis and Is Arbitrary.
DWQ has no available data demonstrating the degree of color which must be removed by
Delta in order to improve downstream aesthetic water quality. Rather DWQ relied upon its Color
Policy and its visual observations of Clark Creek in drafting Delta's permit limitation. Notably,
there is no data in the Color Policy to support a percentage reduction standard. Instead, the Color
Policy relied upon the report of the South Fork Catawba River Water Quality Alliance, Inc.
("Alliance") which simply monitored and recorded ADMI color in the South Fork Catawba River
watershed. The Alliance report did not consider or evaluate reductions, percentages or permit
limitations.
DWQ's visual inspection of the watershed is also not sufficient to support a specific permit
limitation percentage. Delta does not contest that DWQ may, from its visual inspections, determine
that color in the South Fork River watershed needs to be addressed. However, without technical
data, any percentage reduction is arbitrary. DWQ does not know what percentage is needed to meet
the goal of aesthetic quality in the South Fork Catawba River watershed. As such, DWQ has no
more basis to establish a 10% or 50% reduction than it does a 90% reduction. Technical data must
connect DWQ's choice for a percentage reduction with its observation that color must be
addressed. This technical data is lacking to support Delta's draft permit (and the Color Policy).
Delta understands that DWQ arrived at the 90% reduction standard between influent and
effluent based on its perceived results of Delta's most successful voluntary reduction program thus
far — the Cytec polymers. However, Delta never evaluated influent to effluent color. Further, while
using the Cytec polymers, the color removal results were determined using the Platinum Cobalt
methodology. This test is distinct from the ADMI methodology and the percentages obtained are

John Robert Blowe
September 21, 2001
Page 7
likewise distinct. DWQ never reviewed any of the results from Delta's voluntary studies prior to
DWQ's issuance of the draft permit. If DWQ had considered the results from Delta's color removal
trials, it could not have reached the conclusion that a 90% reduction is achievable.
The draft permit also does not specify how Delta can prove or quantify a 90% reduction
between influent and effluent. It is our understanding that DWQ expects the ADMI methodology to
be used to establish the percentage of color reduction. The studies above indicate that relying upon
the ADMI methodology to quantify effective color removal is arbitrary. Delta's experience has
demonstrated that a permit limitation based upon an ADMI percentage may not achieve the purpose
of color removal: to improve the aesthetics of Clark's Creek and the South Fork Catawba River.3
The ADMI test quantifies color units —it does not provide a gauge for indicating the visibility of
the color units. For instance, straw colored wastewater can have a high ADMI reading, but have
low visibility in North Carolina rivers. Purple wastewater, such as that typically encountered at
Delta, may have a low ADMI reading, but demonstrate high stream visibility. During the Clariant
Trial, monitoring revealed a 41% reduction of ADMI color in the plant's wastewater.
Notwithstanding this fact, Delta did not observe any improvement in the color of Clark Creek during
the trial. The Clariant product was, in effect, removing color from Delta's wastewater which had
low visibility. Therefore, while the ADMI methodology demonstrated color removal, the highly
visible and remaining color units resulted in no net visible color change at the discharge point.
Whether any particular color removal technology employed by Delta can lower the ADMI
reading of its effluent and address highly visible effluent color has not been adequately tested.
Simply stated, the goal to remove color in the streams can only be achieved by testing various
technologies to determine which technology effectively removes the color creating visual impact
from the wastewater. Delta needs more time to accomplish this goal.
Fluctuations in dye (and bleach) use also make the 90% color reduction limitation arbitrary.
For instance, if, at the start of a study, dye production is higher than at the end of the study, there
will be less color present in Delta's wastewater. Likewise, during the production of optical whites,
bleach is used, and effluent color is diluted. Color reduction can thus be the result of dye (or bleach)
use fluctuations rather than a reflection of the success of the particular color removal technology.
DWQ's failure to consider this factor in establishing the 90% color reduction limitation
demonstrates its lack of technical basis in drafting Delta's color limitation.
3 The DWQ also discovered the limitations of the ADMI methodology in quantifying the effluent's
color impact. DWQ acknowledged that "[d]uring data review, it was realized that ADMI color
measurements do not always predict the potential for a color impact." (See DWQ Color Policy, page
2).

.
.•
John Robert Blowe
September 21, 2001
Page 8
In the absence of evidence supporting a specific percentage reduction to meet aesthetic
requirements in the South Fork Catawba River watershed, the percentage reduction within Delta's
draft permit is without basis and is arbitrary. DWQ simply has no data to support the condition in
Delta's draft permit.
III. The Draft Permit Color Limitation Is Not Technologically Feasible.
Delta's voluntary color removal tests demonstrate that the 90% color reduction between
influent and effluent is not technologically feasible. None of the above color trials demonstrated
Delta's ability to remove 90% ADMI color between influent and effluent (or even by a treated
effluent to untreated effluent comparison). Rather, each trial resulted in varying percentages of
removal comparing treated and untreated effluent. It is unknown at this time whether the
percentages obtained were in fact due to the employed color removal technology or were a result (or
combined result) of other variable factors such as dye use. The color removal trials did not generate
enough information to discover what percentage reductions are consistently obtainable.
Furthermore, the 90% color limitation between influent and effluent does not account for dye
use fluctuation. Even assuming that a 90% reduction could be met, the limitation requires Delta's
wastewater to contain a minimum quantity of dye. If Delta is producing optical whites, its
wastewater will have low ADMI color and Delta will not be able to achieve a 90% color reduction.
A 90% color reduction simply cannot be obtained in wastewater which has no or little color.
IV. The June 5 Color Policy Constitutes a Rule That Has Been Improperly Adopted.
As discussed above, Delta participated in the formation of the Alliance to monitor and study
color in the South Fork Catawba River watershed. Relying upon the data generated in the Alliance
study, DWQ developed its Color Policy. This "policy" contains standards for color reduction. As
such, the "policy" constitutes a rule.
A rule is "any agency regulation, standard, or statement of general applicability that
implements or interprets an enactment of the General Assembly...." Within the Color Policy,
DWQ implements state color laws and "establishes four tiers of action." The Color Policy places
Delta in Tier 4 and states that "Tier 4 facilities will receive color reduction limits (90% color
reduction between influent and effluent) to be implemented by the permit effective date." Delta's
draft permit even references the Color Policy in requiring a 90% reduction between influent and
effluent stating "[t]his facility was classified as a Tier 4 color discharger ... in the NPDES Color
Permitting Policy."
Therefore, in the Color Policy, DWQ concluded that Delta is a Tier 4 facility and "will
receive" a 90% color limitation. DWQ then incorporated the limitation into Delta's draft permit.
This limitation constitutes a color standard and therefore, as set forth above, is a rule. In North
Carolina, before a rule may be implemented, the regulated community public must have an

John Robert Blowe
September 21, 2001
Page 9
opportunity to comment. See North Carolina's Administrative Procedures Act, N.C. Gen Stat. §§
150 B-1 et seq. DWQ never sought comments on its Color Policy. Thus, DWQ's use of the Color
Policy as a rule violates North Carolina law and should not be permitted.
V. Delta Needs Additional Time to Adequately Determine What Color Removal
Reductions Are Consistently Achievable.
Delta is committed to improving the aesthetics of the South Fork Catawba River watershed.
As demonstrated by Delta's voluntary efforts to remove color before and after the formation of the
Alliance, Delta will continue to study color removal at its facility. At this time, for the reasons
discussed above, the technical data needed to produce a rational and considered color reduction
permit limitation does not exist and is affected by many variables which have not been adequately
studied by DWQ or Delta. Delta believes it will require 24 months to adequately determine what
color removal reductions are consistently achievable. DWQ has stated that it would instituted
enforcement action, i.e., seek penalties, if Delta violates any permit limitation. With the threat of
enforcement, Delta cannot accept a permit limitation which is arbitrary and not based upon adequate
technical data. Delta therefore requests a recommendation that its draft permit not contain any color
reduction permit limitation and that additional studies be conducted as appropriate over the next 24
month period.
matter.
We appreciate the opportunity to make these comments and your careful consideration of this
Very truly yours,
Lori P. Hinnant
fekt_Jcifm-001
cc Mr. Gene Hudgens

DELTA
APPAREL, INCORPORATED
August 28, 2001
VIA HAND DELIVERY AND FACSIMILE (919-733-0719)
Mr. Tom Belnick
NPDES Unit
Division of Water Quality
North Carolina Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: NPDES Draft Permit
Permit No. NC0006190
Delta Apparel -Maiden Plant
Catawba County
Dear Mr. Belnick:
On behalf of Delta Apparel, Inc. ("Delta Apparel"), I am providing comments to the July
25, 2001 NPDES draft permit issued by the Division of Water Quality ("DWQ"), North Carolina
Department of Environment and Natural Resources ("DENR"), to our Maiden plant. We
respectfully request that these comments be made part of the record and considered prior to
issuance of our final permit. Specifically, Delta Apparel opposes the draft conditions relating to
the verification of color reduction of its effluent and the requirements for an Authorization to
Construct Permit.
At the outset, we should note, and DWQ acknowledges, that the color in Delta Apparel's
effluent is not and has not caused or resulted in a violation of any water quality standard or
adversely affected fish or aquatic life. The color of the effluent is simply a matter of aesthetics
and therefore is subjective and relative. In fact, DWQ said that: "The evaluation of color as an
aesthetic impact is difficult since it is a subjective determination. In addition, a host of actors,
such as hue, instream turbidity, suspended matter, dilution, light conditions, and downstream
access all play a part in determining when a color impact might be perceived by the public."
(DWQ June 5, 2001 NPDES Color Permitting Policy.) Despite the admitted uncertainties in this
area, Delta Apparel is committed to reducing color discharges in the South Fork Catawba River
Basin and more particularly, in its effluent discharge to Clark Creek. This commitment is
evidenced by the voluntary actions we have taken without a permit restriction.
In October 1999, we voluntarily participated in the formation of the South Fork Catawba
River Water Quality Alliance, Inc. ("Alliance") to study color in the South Fork Catawba River.
100 W. Pine Street • P.O. Box 37 • Maiden, N.C. 28650 • [phone] • FAX [phone]
Change your shirt.

Mr. Tom Belnick
August 28, 2001
Page 2
The Alliance is comprised of municipalities and industry. The DWQ requested that certain
criteria be considered in our study. We not only considered those criteria but additional factors
as well. As a result of the Alliance's study, DWQ developed its June 5, 2001 NPDES Color
Permitting Policy ("Color Policy"). The Color Policy establishes four tiers of action based on
DWQ's perception of the aesthetic color impacts to the receiving streams.
Prior to and simultaneous with participating in the color study with the Alliance, we
initiated a color reduction/removal program. First, we utilized a Clariant Corporation product but
it did not produce a significant color reduction. We then continued the reduction experiment
with other technologies. The subsequent experiments did not reduce color in the effluent the
degree we had hoped. We are currently conducting another study utilizing a color reducer from
Cytec Industries, Inc. This study involves the introduction of polymers and has thus far
produced positive results. We plan to continue to introduce polymers to reduce the color but also
study the effect, if any, this treatment has on other limitations in our permit.
As of yet, however, there is no available data that reliably demonstrates what minimum
degree of color removal at Delta Apparel is needed in order to improve the downstream aesthetic
water quality. This information is necessary so that Delta Apparel can optimize color removal
levels in relation to cost and technology.
Despite the lack of reliable and consistent data regarding color reduction, the draft permit
incorporates action contained in the Color Policy and demands that Delta Apparel achieve a 90%
color reduction between influent and effluent samples. This requirement is flawed for two
reasons.
First, it is our understanding that DWQ arrived at the 90% reduction standard based on its
perceived results of our voluntary reduction program. However, in all of our voluntary studies,
the company not once evaluated influent to effluent values. In fact, we compared one treated
effluent to untreated effluent utilizing the HACH DR 2000 Spetrophotometer Platinum Cobalt
color meter.
Second, the permit does not specify how we prove or quantify a 90% reduction. As
mentioned above, during our voluntary color reduction program, we analyzed the color in our
effluent utilizing the HACH DR 2000 Spetrophotometer Platinum Cobalt color meter. This
methodology was used in lieu of the American Dye Manufacturers Institute ("ADMI") testing
methodology. This distinction in methodology is important since DWQ developed the
restrictions in our permit from data developed under the ADMI methodology.
Simply put, the color restrictions contained in our draft permit are derived from the
DWQ Color Policy. In developing the Color Policy, DWQ relied exclusively on the data
compiled by the Alliance. The Alliance data was gathered utilizing ADMI methodology. Thus,

Mr. Tom Belnick
August 28, 2001
Page 3
the data contained in the Color Policy from which the restrictions in our draft permit were
developed have no correlation to the data developed under our voluntary program.
Further, the data developed by ADMI methodology has been criticized by DWQ as not
being representative of true color impact. As DWQ acknowledged in its Color Policy, ADMI
color measurements do not predict the potential for a color impact to the receiving stream. DWQ
said: "During data review, it was realized that ADMI color measurements do not always predict
the potential for a color impact." (DWQ Color Policy, page 2). According to DWQ's Color
Policy, a color plume with downstream aesthetic impact was observed at one facility on several
sampling events, although the effluent ADMI color was low and similar to upstream values.
DWQ therefore concluded that consideration of a numerical instream ADMI color standard
would be ineffective. DWQ concluded: "However, requiring some percentage reduction in
effluent color would help to minimize the size of the color plume. Conversely, some facilities
with greater colored effluent (e.g., Pharr Yarns and Yorkshire with summer averages of 844 and
3449 ADMI units, respectively) did not produce major instream color plumes, most likely due to
the effluent hue as well as the large dilution available. Therefore, in order to evaluate the data, it
was realized that no single criterion, but rather a combination of ADMI measurements,
photographs, and plume descriptions were needed to fully assess the instream color conditions."
(DWQ Color Policy, page 2).
The 90% reduction requirement is arbitrary. There is no data in the Color Policy to
support a percentage reduction standard. The Color Policy relied upon the Alliance report,
which reported ADMI units, not percentages. Nor has DWQ conducted any independent study
to conclude that the 90% reduction between influent and effluent samples is warranted,
achievable or feasible. Further, DWQ's statement in the draft permit that this 90% standard is
"technologically and economically feasible" has no basis in fact, especially since the results of
our voluntary color reduction program has never compared influent to effluent utilizing ADMI
technology.
Finally, Delta Apparel believes that a color requirement in its NPDES permit is
premature based upon its continued assessment and evaluation of data. In fact, the company's
most recent color testing was completed on August 15, 2001. Therefore, Delta Apparel
respectfully requests that it be allowed to continue its color reduction study with CYTEC and the
color restrictions be removed.
Sincerely,
1(4\11
j1114—
Gene Hudgen
Plant Manager

f't.410
40 CFR Ch. I (7-1-93 Edition)
Environmental Protection Agency
Pt.410
control technology currently available
(BPT).
[51 FR 24999, July 9, 1986]
PART 410-TEXTILE MILLS POINT
SOURCE CATEGORY
GENERAL PROVISIONS
Sec.
410.00 Applicability.
410.01 General definitions.
410.02 Monitoring requirements. [Reserved]
Subpart A -Wool Scouring Subcategory
410.10 Applicability; description of the wool
scouring subcategory.
410.11 Specialized definitions.
410.12 Effluent limitations representing the
degree of effluent reduction attainable
by the application of the best practicable
control technology currently available
(BPT).
410.13 Effluent limitations representing the
degree of effluent reduction attainable
by the application of the best available
technology economically achievable
(BAT).
410.14 Pretreatment standards for existing
sources (PSES).
410.15 New source performance standards
(NSPS).
410.16 Pretreatment standards for new
sources (PSNS).
410.17 Effluent limitations representing the
degree of effluent reduction attainable
by the application of the best conven-
tional pollutant control technology
(BCT). [Reserved]
Subpart B-Wool Finishing Subcategory
410.20 Applicability; description of the wool
finishing subcategory.
410.21 Specialized definitions.
410.22 Effluent limitations representing the
degree of effluent reduction attainable
by the application of the best practicable
control technology currently available
(BPT).
410.23 Effluent limitations representing the
degree of effluent reduction attainable
by the application of the best available
technology economically achievable
(BAT).
410.24 Pretreatment standards for existing
sources (PSES).
410.25 New source performance standards
(NSPS).
410.26 Pretreatment standards for new
sources (PSNS).
Sec.
410.27 Effluent limitations representing the
degree of effluent reduction attainable
by the application of the best conven-
tional pollutant control technology
(BCT). [Reserved]
Subpart C-Low Water Use Processing
Subcategory
410.30 Applicability; description of the low
water use processing subcategory.
410.31 Specialized definitions.
410.32 Effluent limitations representing the
degree of effluent reduction attainable
by the application of the best practicable
control technology currently available
(BPT).
410.33 Effluent limitations representing the
degree of effluent reduction attainable
by the application of the best available
technology economically achievable
(BAT).
410.34 Pretreatment standards for existing
sources (PSES).
410.35 New source performance standards
(NSPS).
410.36 Pretreatment standards for new
sources (PSNS).
410.37 Effluent limitations representing the
degree of effluent reduction attainable
by the application of the best conven-
tional pollutant control technology
(BCT). [Reserved]
Subpart D-Woven Fabric Finishing
Subcategory
410.40 Applicability; description of the
woven fabric finishing subcategory.
410.41 Specialized definitions.
410.42 Effluent limitations representing the
degree of effluent reduction attainable
by the application of the best practicable
control technology currently available
(BPT).
410.43 Effluent limitations representing the
degree of effluent reduction attainable
by the application of the best available
technology economically achievable
(BAT).
410.44 Pretreatment standards for existing
sources (PSES).
410.45 New source performance standards
(NSPS).
410.46 Pretreatment standards for new
sources (PSNS).
410.47 Effluent limitations representing the
degree of effluent reduction attainable
by the application of the best conven-
tional pollutant control technology
(BCT). [Reserved]
Sec.
Subpart E-Knit Fabric Finishing
Subcategory
410.50 Applicability; description of the knit
fabric finishing subcategory.
410.51 Specialized definitions.
410.52 Effluent limitations representing the
degree of effluent reduction attainable
by the application of the best practicable
control technology currently available
(BPT).
410.53 Effluent limitations representing the
degree of effluent reduction attainable
by the application of the best available
technology economically achievable
(BAT).
410.54 Pretreatment standards for existing
sources (PSES).
410.55 New source performance standards
(NSPS).
410.56 Pretreatment standards for new
sources (PSNS).
410.57 Effluent limitations representing the
degree of effluent reduction attainable
by the application of the best conven-
tional pollutant control technology
(BCT). [Reserved]
Subpart F-Carpet Finishing Subcategory
410.60 Applicability; description of the car-
pet finishing subcategory.
410.61 Specialized definitions.
410.62 Effluent limitations representing the
degree of effluent reduction attainable
by the application of the best practicable
control technology currently available
(BPT).
410.63 Effluent limitations representing the
degree of effluent reduction attainable
by the application of the best available
technology economically achievable
(BAT).
410.64 Pretreatment standards for existing
sources (PSES).
410.65 New source performance standards
(NSPS).
410.66 Pretreatment standards for new
sources (PSNS).
410.67 Effluent limitations representing the
degree of effluent reduction attainable
by the application of the best conven-
tional pollutant control technology
(BCT). [Reserved] •
Subpart G-Stock and Yam Finishing
Subcategory
410.70 Applicability; description of the
stock and yarn finishing subcategory.
410.71 Specialized definitions. (Reserved)
410.72 Effluent limitations representing the
degree of effluent reduction attainable
by the application of the best practicable
control technology currently available
(BPT).
Sec.
410.73 Effluent limitations representing the
degree of effluent reduction attainable
by the application of the best available
technology economically achievable
(BAT).
410.74 Pretreatment standards for existing
sources (PSES).
410.75 New source performance standards
(NSPS).
410.76 Pretreatment standards for new
sources (PSNS).
410.77 Effluent limitations representing the
degree of effluent reduction attainable
by the application of the best conven-
tional pollutant control technology
(BCT). (Reserved]
Subpart H-Nonwoven Manufacturing
Subcategory
410.80 Applicability; description of the
nonwoven manufacturing subcategory.
410.81 Specialized definitions. [Reserved]
410.82 Effluent limitations representing the
degree of effluent reduction attainable
by the application of the best practicable
control technology currently available
(BPT).
410.83 Effluent limitations representing the
degree of effluent reduction attainable
by the application of the best available
technology economically achievable
(BAT).
410.84 Pretreatment standards for existing
sources (PSES).
410.85 New source performance standards
(NSPS).
410.86 Pretreatment standards for new
sources (PSNS).
410.87 Effluent limitations representing the
degree of effluent reduction attainable
by the application of the best conven-
tional pollutant control technology
(BCT). [Reserved]
Subpart I-Fetted Fabric Processing
Subcategory
410.90 Applicability; description of the
felted fabric processing subcategory.
410.91 Specialized definitions. [Reserved]
410.92 Effluent limitations representing the
degree of effluent reduction attainable
by the application of the best practicable
control technology currently available
(BPT).
410.93 Effluent limitations representing the
degree of effluent reduction attainable
by the application of the best available
technology economically achievable
(BAT).
410.94 Pretreatment standards for existing
sources (PSES).
410.95 New source performance standards
(NSPS).
210
211

§410.00
Sec.
410.96 Pretreatment standards for new
sources (PSNS).
410.97 Effluent limitations representing the
degree of effluent reduction attainable
by the application of the best conven-
tional pollutant control technology
(BCT). [R.eserved]
AUTHORITY: Secs. 301, 304 (b), (c), (e), and
(g), 306 (b) and (c), 307 (b) and (c), and 501 of
the Clean Water Act (the Federal Water Pol-
lution Control Act Amendments of 1972, as
amended by the Clean Water Act of 1977) (the
"Act"); 33 U.S.C. 1311, 1314 (b), (c), (e), and
(g), 1316 (b) and (c), 1317 (b) and (c), and 1361;
86 Stat. 186 et seq., Pub. L. 92-500; 91 Stat.
1567, Pub. L. 95-217.
SOURCE: 47 FR 38819, Sept. 2. 1982, unless
otherwise noted.
GENERAL PROVISIONS
§ 410.00 Applicability.
This part applies to any textile mill
or textile processing facility which dis-
charges or may discharge process
wastewater pollutants to the waters of
the United States, or which introduces
or may introduce process wastewater
pollutants into a publicly owned treat-
ment works.
§ 410.01 General definitions.
In addition to the definitions set
forth in 40 CFR part 401, the following
definitions apply to this part:
(a) Sulfide shall mean total sulfide
(dissolved and acid soluble) as meas-
ured by the procedures listed in 40 CFR
part 136.
(b) Phenols shall mean total phenols
as measured by the procedure listed in
40 CFR part 136.
(c) Total Chromium shall mean
hexavalent and trivalent chromium as
measured by the procedures listed in 40
CFR part 136.
(d) The term commission finishing
shall mean the finishing of textile ma-
terials, 50 percent or more of which are
owned by others, in mills that are 51
percent or more independent (i.e., only
a minority ownership by company(ies)
with greige or integrated operations);
the mills must process 20 percent or
more of their commissioned production
through batch, noncontinuous process-
ing operations with 50 percent or more
of their commissioned orders processed
in 5000 yard or smaller lots.
40 CFR Ch. I (7-1-93 Edition)
(e) The term product, except where a
specialized definition is included in the
subpart, shall mean the final material
produced or processed at the mill.
§ 410.02 Monitoring requirements. [Re-
served]
Subpart A -Wool Scouring
Subcategory
§410.10 Applicability; description of
the wool scouring subcategory.
The provisions of this subpart are ap-
plicable to process wastewater dis-
charges resulting from the following
types of textile mills: wool scouring,
topmaking, and general cleaning of raw
wool.
§ 410.11 Specialized definitions.
In addition to the definitions set
forth in 40 CFR part 401 and § 410.01 of
this part, the following definitions
apply to this subpart:
(a) The term wool shall mean the dry
raw wool as it is received by the wool
scouring mill.
(b) The term oil and grease shall mean
total recoverable oil and grease as
measured by the procedure listed in 40
CFR part 136.
(e) The term commission scouring shall
mean the scouring of wool, 50 percent
or more of which is owned by others, in
mills that are 51 percent or more inde-
pendent (i.e., only a minority owner-
ship by company(ies) with greige or in-
tegrated operations); the mills must
process 20 percent or more of their
commissioned production through
batch, noncontinuous processing oper-
ations.
§ 410.12 Effluent limitations represent-
ing the degree of effluent reduction
attainable by the application of the
best practicable control technology
currently available (BPT).
(a) Except as provided in 40 CFR
125.30 through 125.32, any existing point
source subject to this subpart must
achieve the following effluent limita-
tions representing the degree of efflu-
ent reduction attainable by the appli-
cation of the best practicable control
technology currently available (BPT):
Environmental Protection Agency
Pollutant or pollutant property
BPT limitations
Maximum for
any 1 day
Average of
daily values
for 30 con-
secutive days
BOD5
COD............- .............
TSS
Oil and grease
Sulfide ...
Phenol
Total chromium
pH-
KgAdtg (or pounds per 1,000
Ib) of wool
10.6
138.0
32.2
7.2
0.20
0.10
0.10
(+ )
5.3
69.0
16.1
3.6
0.10
0.05
0.05
(1)
+Within the range 6.0 to 9.0 at all times.
(b) Additional allocations equal to
the effluent limitations established in
paragraph (a) of this section are al-
lowed any existing point source subject
to such effluent limitations that scours
wool through "commission scouring"
as defined in § 410.11.
§ 410.13 Effluent limitations represent-
ing the degree of effluent reduction
attainable by the application of the
best available technology economi-
cally achievable (BAT).
(a) Except as provided in 40 CFR
125.30 through 125.32, any existing point
source subject to this subpart must
achieve the following effluent limita-
tions representing the degree of efflu-
ent reduction attainable by the appli-
cation of the best available technology
economically achievable (BAT): .
Pollutant or pollutant property
COD
Sulfide
Phenols -.--.
Total chromium
BAT limitations
Maximum for
any 1 day
Average of
daily values
for 30 con-
secutive days
Kg/kkg (or pounds per 1,000
Ib) of wool
136.0
0.20
0.10
0.10
69.0
0.10
0.05
0.05
(b) Additional allocations equal to
the effluent limitations established in
paragraph (a) of this section are al-
lowed any existing point source subject
to such effluent limitations that scours
wool through "commission scouring"
as defined in §410.11.
§410.20
§ 410.14 Pretreatment standards for
existing sources (PSES).
Any existing source subject to this
subpart that introduces process
wastewater pollutants into a publicly
owned treatment works must comply
with 40 011. 0ift 403.
§41 standards
ndarN
16eww (NSPS).
performance
Any new source subject to this sub-
part must achieve the following new
source performance standards (NSPS):
Pollutant or pollutant property
NSPS
Maximum for
any 1 day
Average of
daily values
for 30 con-
secutive days
BOD5
COD
TSS
Sulfide
Phenols
Total chromium
pH
Kg/kkg (or pounds per 1,000
Ib) of wool
3.6
52.4
30.3
0.20
0.10
0.10
(' )
1.9
33.7
13S
0.10
0.05
0.05
(' )
1 Within the range 6.0 to 9.0 at all times.
Note: Additional allocations for "commission scouring" are
not available to new sources.
§ 410.16 Pretreatment standards for
new sources (PSNS).
Any new source subject to this sub-
part that introduces process
wastewater pollutants into a publicly
owned treatment works must comply
with 40 CFR part 403.
§ 410.17 Effluent limitations represent-
ing the degree of effluent reduction
attainable by the application of the
best conventional pollutant control
technology (BCT). [Reserved]
Subpart B-Wool Finishing
Subcategory
§ 410.20 Applicability; description of
the wool finishing subcategory.
The provisions of this subpart are ap-
plicable to process wastewater dis-
charges resulting from the following
types of textile mills: wool finishers,
including carbonizing, fulling, dyeing,
bleaching, rinsing, fireproofing, and
other such similar processes.
212
213

5410.44
40 CFR Ch. I (7-1-93 Edition)
Environmental Protection Agency
§410.51
Lions representing the degree of efflu-
ent reduction attainable by the appli-
cation of the best available technology
economically achievable (BAT):
Pollutant or pollutant property
BAT limitations
Maximum for
any 1 day
Average of
daily values
for 30 con-
secutive days
Kg/kkg (or pound per 1,000
Ib) of product
COD 60.0
Sulfide 0.20
Phenols 0.10
Total Chromium 0.10
30.0
0.10
0.05
0.05
(b) Except as provided in paragraph
(e) of this section for commission fin-
ishing operations, the following limita-
tions establish the quantity or quality
of pollutants or pollutant properties,
controlled by this section and attrib-
utable to the finishing of woven fabrics
through simple manufacturing oper-
ations employing a synthetic fiber or
through complex manufacturing oper-
ations employing a natural fiber, which
may be discharged by a point source
subject to the provisions of this sub-
part, in addition to the discharge al-
lowed by paragraph (a) of this section.
Pollutant or pollutant p+ut,e.ty
BAT limitations
Maximum for
any 1 day
Average of
daily values
for 30 con-
secutive days
COD
Kglkkg (or pounds per 1,000
Ib) of product
20.0
10.0
(c) Except as provided in paragraph
(e) of this section for commission fin-
ishing operations, the following limita-
tions establish the quantity or quality
of pollutants or pollutant properties,
controlled by this section and attrib-
utable to the finishing of woven fabrics
through simple manufacturing oper-
ations employing a natural and syn-
thetic fiber blend or through complex
manufacturing operations employing a
synthetic fiber, which may be dis-
charged by a point source subject to
the provisions of this subpart, in addi-
tion to the discharge allowed by para-
graph (a) of this section.
Pollutant or pollutant property
BAT limitations
Maximum for
any 1 day
Average of
daily values
for 30 con-
secutive days
COD
Kglkkg (or pounds per 1,000
Ib) of product
40.0
20.0
(d) Except as provided in paragraph
(e) of this section for commission fin-
ishing operations, the following limita-
tions establish the quantity or quality
of pollutants or pollutant properties,
controlled by this section and attrib-
utable to the finishing of woven fabrics
through complex manufacturing oper-
ations employing a natural and syn-
thetic fiber blend, which may be dis-
charged by a point source subject to
the provisions of this subpart, in addi-
tion to the discharge allowed by para-
graph (a) of this subpart.
Pollutant or pollutant property
BAT limitations
Maximum
for any 1
day
Average of
daily values
for 30 con-
secutive
days
COD
Kg/kkg (or pounds per
1,000 Ib) of product
60.0
30.0
(e) Additional allocations equal to
the effluent limitations established in
paragraphs (a), (b), (c), and (d) of this
section are allowed any existing point
source subject to such effluent limita-
tions that finishes woven fabrics
through "commission finishing" as de-
fined in §410.01.
[47 FR 38819, Sept. 2, 1982, as amended at 48
FR 39624, Sept. 1, 1983]
§ 410.44 Pretreatment standards for
existing sources (PSES).
Any existing source subject to this
subpart that introduces process
wastewater pollutants into a publicly
owned treatment works must comply
with 40 CFR part 403.
§410.455 New source performance
standards (NSPS).
Any new source subject to this sub-
part must achieve the following new
source performance standards (NSPS):
SIMPLE MANUFACTURING OPERATIONS
Pollutant or pollutant property
NSPS
Average of
Maximum for daily values
any 1 day for 30 con-
secutive days
BOD5
COD
TSS
Sulfide
Phenols
Total Chromium
pH'
Kglkkg (or pounds per 1.000
lb) of produce
3.3 1.7
41.7 26.9
8.8 3.9
0.20 0.10
0.10 0.05
0.10 0.05
C) (+)
'Within the range 6.0 to 9.0 at all times.
NOTE: Additional allocations for "commission finishers" are
not available to new sources.
COMPLEX MANUFACTURING OPERATIONS
Pollutant or pollutant property
NSPS
1 Average of
Maximum for daily values
any 1 day for 30 con-
secutive days
BOD5
COD
TSS
Sulfide
Phenols
Total Chromium
pH'
Kglkkg (or pounds per 1,000
Ib) of product
3.7 1.9
68.7 44.2
14.4 6.4
0.20 0.10
0.10 0.05
0.10 0.05
(') (')
+ Within the range 6.0 to 9.0 at all times.
NOTE: Additional allocations for "commission finishers" are
not available 10 new sources.
DESIZING
Pollutant or pollutant property
NSPS
Maximum for
any 1 day
Average of
daily values
for 30 con-
secutive days
Kg/kkg (or pounds per 1,000
ib) of product
BOD5 5.5 2.8
COD 59.5 38.3
TSS 15.6 6.9
Sulfide 0.20 0.10
Phenols 0.10 0.05
Total Chromium 0.10 0.05
PH (') (' )
+ Within the range 6.0 to 9.0 a1 all times.
Now: Additional allocations for "commission finishers" are
not available to new sources.
§ 410.46 Pretreatment standards for
new sources (PSNS).
Any' new source subject to this sub-
part that introduces process
wastewater pollutants into a publicly
owned treatment works must comply
with 40 CFR part 403.
§ 410.47 Effluent limitations represent-
ing the degree of effluent reduction
attainable by the application of the
best conventional pollutant control
technology (BCT). [Reserved]
Subpart E-Knit Fabric Finishing
Subcategory
§ 410.50 Applicability; description of
the knit fabric finishing sub-
category.
The provisions of this subpart are ap-
plicable to process wastewater dis-
charges resulting from the following
types of textile mills: knit fabric fin-
ishers, which may include any or all of
the following unit operations: Bleach-
ing, mercerizing, dyeing, printing,
resin treatment, water proofing, flame
proofing, soil repellency application
and a special finish application.
§ 410.51 Specialized definitions.
In addition to the definitions set
forth in 40 CFR part 401 and §410.01 of
this part, the following definitions
apply to this subpart:
(a) The term simple manufacturing op-
eration shall mean all the following
unit processes: desizing, fiber prepara-
tion and dyeing.
(b) The term complex manufacturing
operation shall mean "simple" unit
processes (desizing, fiber preparation
and dyeing) plus any additional manu-
facturing operations such as printing,
water proofing, or applying stain re-
sistance or other functional fabric fin-
ishes.
(c) For NSPS (§ 410.55) the term ho-
siery products shall mean the internal
subdivision of the knit fabric finishing
subcategory for facilities that are en-
gaged primarily in dyeing or finishing
hosiery of'any type.
218
219

§ 41 U'.52
40 CFR Ch. I (7-1-93 Edition)
Environmental Protection Agency
§ 410.55
§ 410.52 Effluent limitations represent-
ing the degree of effluent reduction
attainable by the application of the
best practicable control technology
currently available (BPT).
(a) Except as provided in 40 CFR
125.30 through 125.32, any existing point
source subject to this subpart must
achieve the following effluent limita-
tions representing the degree of efflu-
ent reduction attainable by the appli-
cation of the best practicable control
technology currently available (BPT):
Pollutant or pollutant property
BPT limitations
Maximum for
any 1 day
Average of
daily values
for 30 con-
secutive days
BOD5
COD
TSS
Sulfide
Phenols
Total chromium
pH
Kglkkg (or pounds per 1,000
lb) of product
5.0
60.0
21.8
0.20
0.10
0.10
C)
2.5
30.0
10.9
0.10
0.05
0.05
(' )
Within the range 6.0 to 9.0 at all times.
(b) Except as provided in paragraph
(d) of this section for commission fin-
ishing operations, the following limita-
tions establish the quantity or quality
of pollutants or pollutant properties,
controlled by this section and attrib-
utable to the finishing of knit fabrics
through simple manufacturing oper-
ations employing a natural and syn-
thetic fiber or through complex manu-
facturing operations employing a syn-
thetic fiber, which may be discharged
by a point source subject to the provi-
sions of this subpart, in addition to the
discharge allowed by paragraph (a) of
this section.
Pollutant or pollutant property
BPT limitations
Maximum
for any 1
day
Average of
daily values
for 30 con-
secutive
days
COD
Kg/kkg (or pounds per
1,000 D) of product
20.0
10.0
(c) Except as provided in paragraph
(d) of this section for commission fin-
ishing operations, the following limita-
tions establish the quantity or quality
of pollutants or pollutant properties,
controlled by this section and attrib-
utable to the finishing of knit fabrics
through complex manufacturing oper-
ations employing a natural and syn-
thetic fiber blend, which may be dis-
charged by a point source subject to
the provisions of this subpart, in addi-
tion to the discharge allowed by para-
graph (a) of this section.
Pollutant or pollutant property
Kgikkg (or pounds per
1,000 Ib) of product
COD 40.0 20.0
(d) Additional allocations equal to
the effluent limitations established in
paragraphs (a), (b), and (c) of this sec-
tion are allowed any existing point
source subject to such effluent limita-
tions that finishes knit fabrics through
"commission finishing" as defined in
§ 410.01.
[47 FR 38819, Sept. 2, 1982, as amended at 48
FR 39624, Sept. 1, 19831
§ 410.53 Effluent limitations represent-
ing the degree of effluent reduction
attainable by the application of the
best available technology economi-
cally achievable (BAT).
(a) Except as provided in 40 CFR
125.30 through 125.32, any existing point
source subject to this subpart must
achieve the following effluent limita-
tions representing the degree of efflu-
ent reduction attainable by the appli-
cation of the best available technology
economically achievable (BAT):
Pollutant or pollutant property
BAT limitations
Maximum for
any 1 day
Average of
daily values
for 30 con-
secutive days
COD
Sulfide
Phenols
Total Chromium
Kg/kkg (or pounds per 1,000
Ib) of product
60.0
0.20
0.10
0.10
30.0
0.10
0.05
0.05
(b) Except as provided in paragraph
(d) of this section for commission fin-
ishing operations, the following limita-
tions establish the quantity or quality
of pollutants or pollutant properties,
controlled by this section and attrib-
utable to the finishing of knit fabrics
through simple manufacturing oper-
ations employing a natural and syn-
thetic fiber or through complex manu-
facturing operations employing a syn-
thetic fiber, which may be discharged
by a point source subject to the provi-
sions of this subpart, in addition to the
discharge allowed by paragraph (a) of
this section.
Pollutant or pollutant property
COD
BAT limitations
Average of
daily values
for 30 con-
secutive
days
Kg/kkg (or pounds per
1,000 Ib) o1 product
(c) Except as provided in paragraph
(d) of this section for commission fin-
ishing operations, the following limita-
tions establish the quantity or quality
of pollutants or pollutant properties,
controlled by this section and attrib-
utable to the finishing of knit fabrics
through complex manufacturing oper-
ations employing a natural and syn-
thetic fiber blend, which may be dis-
charged by a point source subject to
the provisions of this subpart, in addi-
tion to the discharge allowed by para-
graph (a) of this section.
Pollutant or pollutant property
BAT limitations
Average of
Maximum for daily values
any 1 day for 30 con-
secutive days
COD
Kg/kkg (of pounds per 1,000
Ib) of product
40.0
20.0
(d) Additional allocations equal to
the effluent limitations established in
paragraphs (a), (b), and (c) of this sec-
tion are allowed any existing point
source subject to such effluent limita-
tions that finishes knit fabrics through
"commission finishing" as defined in
§ 410.01.
[47 FR 38819, Sept. 2, 1982, as amended at 48
FR 39624, Sept. 1, 1983]
§ 410.54 Pretreatment standards for
existing sources (PSES).
Any existing source subject to this
subpart that introduces process waste-
water pollutants into a publicly owned
treatment works must comply with 40
CFR part 403.
§ 410.55 New source performance
standards (NSPS).
Any new source subject to this sub-
part must achieve the following new
source performance standards (NSPS):
SIMPLE MANUFACTURING OPERATIONS
Pollutant or pollutant property
BOD5
COD
TSS
Sulfide
Phenols
Total chromium
pH
NSPS
Maximum for
any 1 day
Average of
daily values
for 30 con-
secutive days
Kglkkg (or pounds per 1,000
Ib) of product
3.6
48.1
132
020
0.10
0.10
(')
1,9
31.0
5.9
0.10
0.05
0.05
(')
1 Within the range 6.0 to 9.0 at all times.
NOTE: Additional allocations for "commission finishers" are
not available to new sources.
COMPLEX MANUFACTURING OPERATIONS
Pollutant or pollutant property
NSPS
Maximum for
any 1 day
Average of
daily values
for 30 con-
secutive days
BOD5
COD
TSS
Sulfide
Phenols
Total Chromium
pH
Kg/kkg (or pounds per 1,000
Ib) o1 product
4.8
51.0
122
0.20
0.10
0.10
(' -)
2.5
32.9
5.4
0.10
0.05
0.05
(' -1
Within the range 6.0 to 9.0 at all times.
NOTE: Additional allocations for "commission finishers" are
not available to new sources.
220
221

Re: Delta Mills NC0006190
MIo ca.,n.mF
Mo„h„,i
Subject: Re: Delta Mills NC0006190
Date: Tue, 18 Sep 2001 14:54:42 -0400
From: Michael Parker <[e-mail]>
Organization: NC DENR - Mooresville Regional Office
To: Tom Belnick <[e-mail]>
Tom:
This issue is covered in 2B .0503(4)(d). Allen McRee is aware of the
requirement, is aware of what is necessary to get a waiver, and is aware
that a connection to the effluent flow meter would allow Delta to collect
influent flow proportional composite samples. I think the permit should be
issued with the usual language, and that Delta should either spend the $500
to comply or request a waiver, if appropriate. By the way, we have granted
waivers down here before so it won't be precedent setting.
MLP
Tom Belnick wrote:
> Mr Mike- Allen McRee with Delta called me last week about the draft
> permit boilerplate language. The draft added composite sampling of the
> influent to determine color removal. Allen noticed that the boilerplate
> language states that composite samples must be flow -proportioned, and he
> is concerned since they dont have a flow meter installed on the influent
> sampler. Instead, he would like to collect time composites every 10
> minutes. Do you folks ever allow such requests?
> Mailto:[e-mail]
> N.0 DENR-DWQ/NPDES Unit
> 1617 Mail Service Center, Raleigh NC 27699-1617
> Work: [phone] ext. 543
> Fax: [phone]
Michael Parker - [e-mail]
Environmental Engineer II
North Carolina Dept. of Environment & Natural Resources
Division of Water Quality
919 N. Main Street
Mooresville, NC 28115
Ph: 704.663.1699 Fax: [phone]
Michael Parker <[e-mail]>
Environmental Engineer II
NC DENR - Mooresville
Division of Water Quality
1 of 2 9/24/01 10:25 AM

m gio Co ✓1Ci,i v
NPDES PERMIT FACT SHEET Delta Apparel, Inc.
• . Page 8
Proposed Schedule for Permit Issuance
Draft Permit to Public Notice:
Permit Scheduled to Issue:
07/18/01
09/03/01
NPDES No. NC0006190
State Contact
If you have any questions on any of the above information or on the attached
permit, please contact Tom Belnick at [phone], extension 543.
Copies of the following are attached to provide further information on the permit
development:
■ Draft Permit
• Reasonable Potential Analysis (majors only)
• NPDES Color Permitting Policy
NPDES Recommendation by:
Signature
Date
Regional Office Comments
St.t. itivlittij celiie.4, �5 C, - cbi? v . ` l�
s' LLeter rye cA114— -,
" �q-Gr l �fces
Regional Recommendation
by:
Reviewed and accepted bv:
Signature
Date
Regional Supervisor:
'
Signature
Date
NPDES Unit Supervisor:
Signature
Date
tc. l z,S�ryc
Page 8
Version: June 26, 2001

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Bill Holman, Secretary
Kerr T. Stevens, Director
September 15, 2000
Mr. Gene Hudgens
DELTA APPAREL, INC.
PO Box 37
Maiden, North Carolina 28650
PAO fiter(
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: NPDES Permit Modification — Name Change
Permit NC0006190
DELTA APPAREL, INC.
(Formerly Delta Mills, Inc. (Maiden))
Catawba County
Dear Mr. Hudgens:
In accordance with your request received August 10, 2000, the Division is forwarding the subject permit
modification. This modification documents the change in name at the subject facility. All other terms and conditions in the
original permit remain unchanged and in full effect. This permit modification is issued under 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 December 6, 1983.
If any parts, measurement frequencies or sampling requirements contained in this permit modification 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 a written petition conforming to Chapter 150B of the North Carolina General
Statutes, filed with the Office of Administrative Hearings, Post Office Drawer 27447, Raleigh, North Carolina 27611-7447.
Unless such demand is made, this decision shall be final and binding.
This permit does not affect the legal requirement to obtain other permits which may be required by the Division of
Water Quality, the Division of Land Resources, Coastal Area Management Act, or any other Federal or Local government
permit that may be required. If you have any questions concerning this permit, please contact Valery Stephens at the
telephone number or address listed below.
Sincerely,
T. Stevens
cc: Central Files
Mooresville Regional Office, Water Quality Section
NPDES Unit
Point Source Compliance Enforcement Unit
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 919 733-5083, extension 520 (fax) 919 733-0719
VISIT US ON THE INTERNET © http:I/h2o.enr.state.nc.us/
[e-mail]

Permit 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, Incorporated
is hereby authorized to discharge wastewater from a facility located at
Maiden Plant
100 West Pine Street
Maiden
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.
This permit shall become effective September 15, 2000.
This permit and authorization to discharge shall expire at midnight on July 31, 2000.
Signed this day September 15, 2000.
rr T. Stevens, Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit NC0006190
¢'1
SUPPLEMENT TO PERMIT COVER SHEET
Delta Apparel, Incorporated., is hereby authorized to:
1. Continue to operate an existing wastewater treatment facility with the following components:
• Heat exchanger
• Bar Screen
• Dual aeration basins
• Dual Secondary clarifiers
• Post aeration
• Parshall flume with recording flow meter
• Sludge storage lagoon
The facility is located at 408 South Main Street, Maiden in Catawba County.
2. Discharge from said treatment works at the location specified on the attached map into Clark Creek,
classified C waters in the Catawba River Basin.

To: Permits and Engineering Unit
Water Quality Section
Attention: Charles Weaver
SOC PRIORITY PROJECT: No
Date: June 26, 2000
NPDES STAFF REPORT AND RECOMMENDATIONS
County: Catawba
NPDES Permit No.: NC0006190
MRO No.: 00-28
PART I - GENERAL INFORMATION
1. Facility and Address: Delta Mills, Inc.- Maiden Plant
Post Office Box 37
408 South Main Avenue
Maiden, N.C. 28650
2. Date of Investigation: June 13, 2000
3. Report Prepared By: Michael L. Parker, Environ. Engr. II
4. Person Contacted and Telephone Number: Allen McRee, [phone], ext. 234
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 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
J U L - 7 2000
DENR - WATER QUALITY
P I9.T S''URCE BUAUC
USGS Quad No.: E 14 SW
7. Site size and expansion area consistent with application: Yes. Limited area available for
expansion, if necessary.
8. Topography (relationship to flood plain included): Gentle slopes (less than 5%). The site
does not appear to be located in a flood plain.
9. Location of Nearest Dwelling: There are no dwellings located within 200 feet of the WWTP
site.

Page Two
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
a. Volume of Wastewater: 1.5 MGD (Design Capacity)
b. What is the current permitted capacity: 1.5 MGD
c. Actual treatment capacity of current facility (current design capacity): 1.5 MGD
d. Date(s) and construction activities allowed by previous ATCs issued in the previous
two years: N/A
e. 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, d 1 secondary clarifiers; aftow-cgnaliza#ien-basin, post aeration,
�. disinfection sludge-dewatering-fasilities; a parshall flume with a recording flow
meter, and an aerated sludge storage lagoon.
f. Description of proposed WWT facilities: There are no proposed WWT facilities at
this time.
g•
Possible toxic impacts to surface waters: recent toxicity testing performed by this
facility reflects test failures for February, March, and April 2000. An investigation
conducted by Delta found high conductivity levels possibly the result of a certain
type of dyestuffs that were currently being used. Corrective measures have been
taken and the company anticipates compliance with the June toxicity test.
h. Pretreatment Program (POTWs only): Not Needed.
2. Residual handling and utilization/disposal scheme:
a. If residuals are being land applied specify DWQ Permit No. WQ0006984.
Residuals Contractor: Bionomic Services, Inc.
Telephone No. [phone]
b. Residuals stabilization: Class B

Page Three
3. Treatment Plant Classification: Class III (no change from previous Permit renewal).
4. SIC Code(s): 2257 Wastewater Code(s): 55 MTU Code(s): 02003
PART III - OTHER PERTINENT INFORMATION
1. Is this facility being constructed with Construction Grant Funds or are any public monies
involved (municipals only)? No
2. Special monitoring or limitations (including toxicity) requests: None at this time.
3. Important SOC/JOC or Compliance Schedule dates: N/A
4. Alternative Analysis Evaluation
a. Spray Irrigation: Insufficient area.
b. Connect to regional sewer system: The Delta Mills plant site has access to the Town
of Maiden's WWTP, however, insufficient capacity exists in the Town's WWTP to
treat the process wastewater generated by this facility.
c. Subsurface: N/A
PART IV - EVALUATION AND RECOMMENDATIONS
Delta Mills (DM) has requested renewal of the subject permit. The only changes in the
permit is to the facility description page for the addition of aerators to the sludge storage basin. No
other changes and/or modifications are proposed for this facility at this time.
DM has always had a significant amount of color in their effluent. Such being the case, DM
has chosen to participate in the South Fork Catawba River Water Quality Alliance with seven (7)
other downstream color dischargers to conduct organized color monitoring at designated locations
along the South Fork River. By participating in this Alliance, DM is assured by the Division that no
color monitoring or color reduction requirements will be imposed in the permit. However, should
DM cease it's participation in this Alliance, the Division may reopen the permit to add a
requirement for color monitoring, if deemed necessary. DM has not as yet installed any color
removal equipment. DM has, however, examined several methods of color reduction, some of which
have shown very positive results.
Pending receipt and approval of the WLA, it is recommended that the Permit be renewed as
requested.
er--4id2G 6 2�
Water Quality Regional Su -, sor
h:ldsrldsr001deltamil.dsr
to

DELTA
A.P. P. A. R. E. L
Delta Mills, Inc.
Maiden Plant
P.O. Box 37
100 West Pine Street
Maiden, N.C. 28650
Mr. Charles H. Weaver, Jr.
NCDENR / Water Quality / NPDES Unit
1617 Mail Service Center
Raleigh, N.C. 27699-1617
Re: NPDES Permit NC0006190 Renewal
Dear Mr. Weaver,
January 26, 2000
ECG
nU [5
DENR - WATER QUALITY
POINT SOURCE BRANCH
Delta Apparel, Inc. requests that our NPDES permit be renewed for our Maiden Plant.
The only change at our WWTP is the upgrade of the Post Aeration electrical system,
which includes the addition of 7 small aerators to the sludge lagoon in June 1999.
On August 17, 1999 we attended the meeting on South Fork Catawba River Color
Action Plan held in the Mooresville Regional Office. The meeting was conducted by
NCDENR personnel from Raleigh and Mooresville, including Dianne Reid and Rex
Gleason. As a result of this meeting Delta Apparel, Inc. has helped form the South Fork
Catawba River Water Quality Alliance, Inc. The purpose of the Alliance is to conduct the
organized monitoring and color study of the South Fork Catawba River with seven other
discharge permittee locations along a 40 mile section of the river. The plans and schedule
have been reviewed by Dianne Reid and Rex Gleason and they agree that it is a better
way of monitoring the river. Provided Delta Apparel continues to participate with the
Alliance in the color study, no color monitoring or color reduction requirements shall be
imposed by this Permit. If at any time during the term of this Permit, it is reported by the
Alliance that Delta Apparel has ceased its participation in the South Fork Color Study,
the Director may reopen this Permit for the purpose of imposing such monitoring
requirments for color, and a requirment to perform such color reductions, as the Director
deems necessary pursuant to 15A NCAC 2H .0114. A copy of the plans and schedule are
enclosed for your review.
Enclosed are our original and two copies of our renewal application. If you have any
questions, please write or call me at 828-428-9921 Ext.234.
Sincerely,
Allen McRee, ORC
Plant Engineer
CC: Dianne Reid
Rex Gleason
P. O. Box 37. 408 S. Main Avenue • Maiden, North Carolina 28650
[phone] • FAX [phone] & 428-8312
Enclosure
001
ytfti)

ATTACHMENT A
PLAN FOR SOUTH FORK
CATAWBA RIVER COLOR STUDY
DECEMBER 1, 1999
BACKGROUND
The North Carolina Department of Environment and Natural Resources (NCDENR) proposes
to require color monitoring and a color reduction evaluation as part of the NPDES permit for
the following eight (8) dischargers:
Facility Name
Permit #
Receiving Water
Delta Mills WWTP
NC0006190
Clark Creek
Lincolnton-S. Fork WWTP
NC0025496
S. Fork Catawba River
Cherryville WWTP
NC0044440
Indian Creek
Hickory -Henry Fork WWTP
NC0040797
Henry Fork
Gastonia -Long Cr WWTP
NC0020184
S. Fork Catawba River
Crompton & Knowles
NC0005274
S. Fork Catawba River
Town of Cramerton
NC0006033
S. Fork Catawba River
Stowe Pharr Yarns WWTP
NC0004812
S. Fork Catawba River
NCDENR has proposed addition of NPDES permit conditions that require weekly monitoring
during year 1 April -October, and monthly monitoring during year 2. Monitoring will include
effluent, upstream and downstream ADMI color, pH, temperature, plume, and visual color.
NCDENR also proposes permit conditions which will require conduct of a color removal study
to evaluate methods and costs for 25, 50, 75 and 99 percent color removal from each
discharge.
NCDENR has recently issued a draft of the Catawba River Basinwide Water Quality Plan.
This plan calls for monthly color monitoring over a two year period in the South Fork system.
PROPOSED PLAN
Rather than each of the eight dischargers performing independent non -coordinated color
studies, it is proposed to conduct an organized group color evaluation which will include:
• Standardized color analysis

• Coordinated sampling
• Consideration of dry and wet weather events
• Basin wide analysis
• Evaluation of point and non -point sources
This will provide a sound basis to determine if there is a color problem, the location of the
problems in the basin, and possible sources. This will also provide a basis for determining the
need for future studies to define acceptable color increases and requirements for color
reductions.
STUDY PLAN
The initial study will be conducted over two years to obtain a color baseline for the South Fork
of the Catawba River including Clark Creek, Indian Creek and Henry Fork.
Phase I will develop a study plan which would be submitted to NCDENR. Steps which will be
included in setting up the plan include:
• Review of historical color data on the river system;
• Meet with committee to develop conceptual plan;
• Meet with NC DENR to review conceptual plan;
• Define color testing procedure, set up color standards, determine available
laboratories, check quality control and negotiate cost and select a
laboratory;
• Set up standard monitoring locations on the river;
• Determination of discharge plumes;
• Set up rainfall monitoring stations;
• Develop study plan in conjunction with committee; and
• Submit plan to state.
Phase 11 of the study will be the conduct and reporting on 19 months of river monitoring.
Since this study will be coordinated with the users and utilize a single standardized laboratory,
it will be proposed to conduct 16 sampling events during year 1 and 10 events during year 2.
This will provide a much stronger data base and will be a significant improvement over

individual testing. Wet weather tests will be included in this program. The plan is expected to
include:
• Coordination of composite sampling of discharges;
• River flow monitoring;
• Analysis of non -point discharges;
• Conduct of 40 mile river run to include upstream and downstream samples
• visual plume analysis;
• visual analysis of abnormal discharges;
• pH;
• temperature;
• use of color QC standards;
• Analysis of upstream, downstream and color samples;
• Submit reports for each sampling event;
• Prepare year end report;
• Two to four technical review meetings per year;
• Mid -course (July 1S1 yr) technical meeting to review study and make changes
in study plan as needed;
• Mid -course meeting with NCDENR (March 2' yr) to review problem areas;
• Coordinate stakeholder efforts;
• 48 hour notice to the State or sampling events;
• Photographs of color plumes; and
• Work with advisory board.

PRELIMINARY PROJECT SCHEDULE
Conceptual Meeting with NCDENR - September 1999
Draft Study Plan - January 2000
Finalize Study Plan - March 2000
Initiate River Study - April 2000
Mid Project Technical Review July 2000
Year 1 Report December 2000
Mid Project Problem Area Definition - March 2001
Complete River Monitoring October 2001
Draft Study Report - January 2002
NCDENR Meeting/Report Review March 2002
Finalize Report May 2002
waterqualityalliance

Delta Mills, Inc. Maiden Plant
Maiden, N.C.
Catawba County
NPDES Permit No. NC0006190
PRESENT OPERATING STATUS
Wastewater from the dye and bleaching process goes to the heat reclaimer equipment for
heat recovery from the hot (120 deg.F) wastewater. Also at this time lint is filtered 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 ft. L X 90 ft. W X 12 ft. D and
contains 1,250,000 gals. with 60 hours retention at 1 MGD. From aeration the flow goes
into dual clarifiers to settle solids. Each clarifier is 38 ft. in dia. and 10 ft. deep with a
capacity of 80,000 gals. From the clarifiers the flow goes through the old chlorine
contact chamber and the float and cable flow recorder. From here the flow goes into the
post aeration basin that is 50 ft. L X 25 ft. W X 9 ft. D with a capacity of 84,000 gals.
From here the flow goes to the parshal flume with an ISCO flow recorder and
refrigerated composite sampler. From here the flow travels 7,500 ft. through a 14 in. line
to Clark Creek.

Delta Mills, Inc. Maiden Plant
Maiden, N.C.
Catawba County
NPDES Permit NC0006190
POTENTIAL FACILITY CHANGES
We have no plans to expand treatment capacity or replace major equipment. However,
we do have plans to remove/reduce effluent color by whatever means is best for us. At
present we have conducted one trial using polymer with good results. We plan to run
another trial in Jan. 2000 using a reducing agent technology. As standard policy, we have
different vendors run jar test in an effort to find the best solution for us.

Delta Mills, Inc. Maiden Plant
Maiden, N. C.
Catawba County
NPDES Permit No. NC0006190
SLUDGE MANAGEMENT
Solids that settle and thicken in the clairfiers are wasted at a rate of 50,000 gals. —
100,000 gals. per week. The waste rate can vary with the mix liquor total solids, flow and
sludge dept in clarifiers. Sludge is wasted into our sludge storage lagoon with a capacity
of approximately 1,800,000 gals. During wasting and storage the sludge is aerated with 7
surface aerators. Decant is pumped back into the aeration basins. Once the lagoon is near
capacity, we have a professional contractor haul the solids to various sections on 240
acres of pasture for land application. Land application of biosolids is carried out within
the regulations stated in our permit no. WQ0006984.

WASTEWATER TREATMENT PLANT SCHEMATIC
AERATION BASIN #2
VOLUME a 1,222, 000 gallons
(2) 50 h.p. floating aerators
/8o1X9o'w x /2'o
0.S mGo
BAR SCREEN
AERATION BASIN #1
VOLUME - 1,222.000 gallons
(2) 50 h.p. floating aerators
180'L x9o'W X 12' 0
0.Srn o
SLUDGE
RETURN
SLUDGE
STORAGE
LAGOON
.S i r ce.,at Are a.
CLARK CREEK
CLARIFIER #2
SLUDGE PUMP STATION
1,500 4+. Prom E44iu.entd
Flow trteo..staremeAci cKd
Sc „1pler
SLUDGE RETURN
A
�-- REAERATION
BASIN
(2) 10 h.p. floating
aerators
1.0 MGD
U—EFFLUENT R.OW
MEASUREMENT
DEVICE
woo
WASTE
SLUDGE
CLARIFIER #138' diameter
10' sidewater depth
SLUDGE
PUMP STATION
PCHLORINE CONTACT
& 2.0 MGD FLOW
MEASUREMENT
Del+c.._ ,' ll s, 1
frialtdeN PI a,u f
IV,O 5 AlCb0o 6tQo
Ce.,-4.0.4..W bc, Cc, .
L

m
0.10
ON 5
�LL
RR. Y61
i O
;�-
9
Delta Mills, Inc.
Maiden Plant
Maiden, NC
Catawba County
Discharge 001
7-11ASd33d)
s)rrSSZo
Topographical Map
v
d FLLn
soo
..---1111111161M11.
olF--
via L.41111. Li
O W
O'Fd
0. w
in
.74
O co
rn
1
1
0
M
N
1-
w
W J
(L W
O i
W
Q N
cz
W W
ZX
Z_
CC
O1-
Z
Z aQ
0
U
1-
w
w
w
oz
O o Z CN
v
O *Z
a E
rm ;,f
N
T
a)
c) E
a)
N
00 O To E , s
o G y,LT
C7 EN v O—
N 2 01 A O mo
F N .O U
�10 O
F >, O Y O C U
10 .c 0 Q N
N O
a) c N
oFQ t E 0 c U
22 N v"0 o r w
p0 ._ N •` 0 Z d
O m 6. O >
JQU' O. U E N C c
N 6 co 0 R
c I -CI v oto
-. A
m o c .0 .0 - c
.... O. Y U a •-
c c
N O 00 = 0
CD 0T L in
O. O a) 0
'O O. N V a)H
Q Q O 0 .-+
aoo ccw
5 0 I- o. aoo N

ENVIRONMENTAL
S C I ENCE CORP .
Mr. Wayne Althouse
Burlington Research Inc.
1302 Belmont Street
Burlington, NC 27215
Date Received 01/07/00 07:30
Description
Sample ID 0A132-001
Collected By •
Collection Date : 01/05/00 12:00
Parameter
REPORT OF ANALYSIS
12065 Lebanon Rd.
Mt. Juliet, TN 37122
[phone]
1-800-767-5859
Fax [phone]
Tax I.D. 62-0814289
Est. 1970
January 13,2000
ESC Sample # : L8556-06
ESC Key :
Site ID .
Project # :
Result Det. Limit Units Method Prep PID Analyzed AID
Pesticide/PCBs
Aldrin BDL 0.50 ug/1 608 01/07/00 1428 366 01/11/00 0000 366
Alpha BHC BDL 0.50 ug/1 608 01/07/00 1428 366 01/11/00 0000 366
Beta BHC BDL 0.50 ug/1 608 01/07/00 1428 366 01/11/00 0000 366
Delta BHC BDL 0.50 ug/1 608 01/07/00 1428 366 01/11/00 0000 366
Gamma BHC BDL 0.50 ug/1 608 01/07/00 1428 366 01/11/00 0000 366
Chlordane BDL 5.0 ug/1 608 01/07/00 1428 366 01/11/00 0000 366
4,4-DDD BDL 0.50 ug/1 608 01/07/00 1428 366 01/11/00 0000 366
4,4-DDE BDL 0.50 ug/1 608 01/07/00 1428 366 01/11/00 0000 366
4,4-DDT BDL 0.50 ug/1 608 01/07/00 1428 366 01/11/00 0000 366
Dieldrin BDL 0.50 ug/1 608 01/07/00 1428 366 01/11/00 0000 366
Endosulfan 1 BDL 0.50 ug/1 608 01/07/00 1428 366 01/11/00 0000 366
Endosulfan II BDL 0.50 ug/1 608 01/07/00 1428 366 01/11/00 0000 366
Endosulfan sulfate BDL 0.50 ug/1 608 01/07/00 1428 366 01/11/00 0000 366
Endrin BDL 0.50 ug/1 608 01/07/00 1428 366 01/11/00 0000 366
Endrin aldehyde BDL 0.50 ug/1 608 01/07/00 1428 366 01/11/00 0000 366
Heptachlor BDL 0.50 ug/1 608 01/07/00 1428 366 01/11/00 0000 366
Heptachlor epoxide BDL 0.50 ug/1 608 01/07/00 1428 366 01/11/00 0000 366
Methoxychlor BDL 0.50 ug/1 608 01/07/00 1428 366 01/11/00 0000 366
Toxaphene BDL 10. ug/1 608 01/07/00 1428 366 01/11/00 0000 366
PCB 1016 BDL 5.0 ug/1 608 01/07/00 1428 366 01/11/00 0000 366
PCB 1221 BDL 5.0 ug/1 608 01/07/00 1428 366 01/11/00 0000 366
PCB 1232 BDL 10. ug/1 608 01/07/00 1428 366 01/11/00 0000 366
PCB 1242 BDL 5.0 ug/1 608 01/07/00 1428 366 01/11/00 0000 366
PCB 1248 BDL 5.0 ug/1 608 01/07/00 1428 366 01/11/00 0000 366
PCB 1254 BDL 5.0 ug/1 608 01/07/00 1428 366 01/11/00 0000 366
PCB 1260 BDL 5.0 ug/1 608 01/07/00 1428 366 01/11/00 0000 366
Pest/PCBs Surrogates
Decachlorobiphenyl 57. % Rec. 608 01/07/00 1428 366 01/11/00 0000 366
Tetrachloro-m-xylene 76. % Rec. 608 01/07/00 1428 366 01/11/00 0000 366
Base/Neutral Extractables
Acenaphthene BDL 10. ug/1 625 01/11/00 1528 390 01/13/00 0227 345
Acenaphthylene BDL 10. ug/1 625 01/11/00 1528 390 01/13/00 0227 345
Anthracene BDL 10. ug/1 625 01/11/00 1528 390 01/13/00 0227 345
Benzidine BDL 50. ug/1 625 01/11/00 1528 390 01/13/00 0227 345
Benzo(a)anthracene BDL 10. ug/1 625 01/11/00 1528 390 01/13/00 0227 345
Benzo(b)fluoranthene BDL 10. ug/1 625 01/11/00 1528 390 01/13/00 0227 345
Benzo(k)fluoranthene BDL 10. ug/1 625 01/11/00 1528 390 01/13/00 0227 345
Benzo(g,h,i)perylene BDL 10. ug/1 625 01/11/00 1528 390 01/13/00 0227 345
BDL - Below Detection Limit
Det. Limit - Estimated Quantitation Limit(EQL)
Page 6 of 10

ENVIRONMENTAL
SCIENCE CORP .
Mr. Wayne Althouse
Burlington Research Inc.
1302 Belmont Street
Burlington, NC 27215
Date Received
Description
Sample ID
Collected By
Collection Date :
Parameter
01/07/00 07:30
OA132-001
01/05/00 12:00
Benzo(a)pyrene
Bis(2-chlorethoxy)methane
Bis(2-chloroethyl)ether
Bis(2-chloroisopropyl)ether
4-Bromophenyl-phenylether
2-Chloronaphthalene
4-Chlorophenyl-phenylether
Chrysene
Dibenz(a,h)anthracene
3,3-Dichlorobenzidine
2,4-Dinitrotoluene
2,6-Dinitrotoluene
Fluoranthene
Fluorene
Hexachlorobenzene
Hexachloro-1,3-butadiene
Hexachlorocyclopentadiene
Hexachloroethane
Indeno(1,2,3-cd)pyrene
Isophorone
Naphthalene
Nitrobenzene
n-Nitrosodimethylamine
n-Nitrosodiphenylamine
n-Nitrosodi-n-propylamine
Phenanthrene
Benzylbutyl phthalate
Bis(2-ethylhexyl)phthalate
Di-n-butyl phthalate
Diethyl phthalate
Dimethyl phthalate
Di-n-octyl phthalate
Pyrene
1,2,4-Trichlorobenzene
Acid Extractables
4-Chloro-3-methylphenol
2-Chlorophenol
2,4-Dichlorophenol
2,4-Dimethylphenol
4,6-Dinitro-2-methylphenol
REPORT OF ANALYSIS
Result Det. Limit Units
BDL 10. ug/1
BDL 10. ug/1
BDL 10. ug/1
BDL 10. ug/1
BDL 10. ug/1
BDL 10. ug/1
BDL 10. ug/1
BDL 10. ug/1
BDL 10. ug/1
BDL 10. ug/1
BDL 10. ug/1
BDL 10. ug/1
BDL 10. ug/1
BDL 10. ug/1
BDL 10. ug/1
BDL 10. ug/1
BDL 10. ug/1
BDL 10. ug/1
BDL 10. ug/1
BDL 10. ug/1
BDL 10. ug/1
BDL 10. ug/1
BDL 10. ug/1
BDL 10. ug/1
BDL 10. ug/1
BDL 10. ug/1
BDL 10. ug/1
BDL 10. ug/1
BDL 10. ug/1
BDL 10. ug/1
BDL 10. ug/1
BDL 10. ug/1
BDL 10. ug/1
BDL 10. ug/1
BDL 10. ug/1
BDL 10. ug/1
BDL 10. ug/1
BDL 10. ug/1
BDL 10. ug/1
BDL - Below Detection Limit
Det. Limit - Estimated Quantitation Limit(EQL)
12065 Lebanon Rd.
Mt. Juliet, TN 37122
[phone]
1-800-767-5859
Fax [phone]
Tax I.D. 62-0814289
Est. 1970
January 13,2000
ESC Sample # : L8556-06
ESC Key :
Site ID .
Project # :
Method Prep PID Analyzed AID
625 01/11/00 1528 390 01/13/00 0227 345
625 01/11/00 1528 390 01/13/00 0227 345
625 01/11/00 1528 390 01/13/00 0227 345
625 01/11/00 1528 390 01/13/00 0227 345
625 01/11/00 1528 390 01/13/00 0227 345
625 01/11/00 1528 390 01/13/00 0227 345
625 01/11/00 1528 390 01/13/00 0227 345
625 01/11/00 1528 390 01/13/00 0227 345
625 01/11/00 1528 390 01/13/00 0227 345
625 01/11/00 1528 390 01/13/00 0227 345
625 01/11/00 1528 390 01/13/00 0227 345
625 01/11/00 1528 390 01/13/00 0227 345
625 01/11/00 1528 390 01/13/00 0227 345
625 01/11/00 1528 390 01/13/00 0227 345
625 01/11/00 1528 390 01/13/00 0227 345
625 01/11/00 1528 390 01/13/00 0227 345
625 01/11/00 1528 390 01/13/00 0227 345
625 01/11/00 1528 390 01/13/00 0227 345
625 01/11/00 1528 390 01/13/00 0227 345
625 01/11/00 1528 390 01/13/00 0227 345
625 01/11/00 1528 390 01/13/00 0227 345
625 01/11/00 1528 390 01/13/00 0227 345
625 01/11/00 1528 390 01/13/00 0227 345
625 01/11/00 1528 390 01/13/00 0227 345
625 01/11/00 1528 390 01/13/00 0227 345
625 01/11/00 1528 390 01/13/00 0227 345
625 01/11/00 1528 390 01/13/00 0227 345
625 01/11/00 1528 390 01/13/00 0227 345
625 01/11/00 1528 390 01/13/00 0227 345
625 01/11/00 1528 390 01/13/00 0227 345
625 01/11/00 1528 390 01/13/00 0227 345
625 01/11/00 1528 390 01/13/00 0227 345
625 01/11/00 1528 390 01/13/00 0227 345
625 01/11/00 1528 390 01/13/00 0227 345
625 01/11/00 1528 390 01/13/00 0227 345
625 01/11/00 1528 390 01/13/00 0227 345
625 01/11/00 1528 390 01/13/00 0227 345
625 01/11/00 1528 390 01/13/00 0227 345
625 01/11/00 1528 390 01/13/00 0227 345
Page 7 of 10

ENVIRONMENTAL
S C I ENCE CORP .
REPORT OF ANALYSIS
Mr. Wayne Althouse
Burlington Research Inc.
1302 Belmont Street
Burlington, NC 27215
January 13,2000
12065 Lebanon Rd.
Mt. Juliet, TN 37122
[phone]
1-800-767-5859
Fax [phone]
Tax I.D. 62-0814289
Est. 1970
ESC Sample # : L8556-06
Date Received 01/07/00 07:30
ESC Key :
Description
Site ID .
Sample ID 0A132-001
Project # :
Collected By
Collection Date : 01/05/00 12:00
Parameter Result Det. Limit Units Method Prep PID Analyzed AID
2,4-Dinitrophenol BDL 10. ug/1 625 01/11/00 1528 390 01/13/00 0227 345
2-Nitrophenol BDL 10. ug/1 625 01/11/00 1528 390 01/13/00 0227 345
4-Nitrophenol BDL 10. ug/1 625 01/11/00 1528 390 01/13/00 0227 345
Pentachlorophenol BDL 10. ug/1 625 01/11/00 1528 390 01/13/00 0227 345
Phenol BDL 10. ug/1 625 01/11/00 1528 390 01/13/00 0227 345
2,4,6-Trichlorophenol BDL 10. ug/1 625 01/11/00 1528 390 01/13/00 0227 345
Surrogate Recovery
Nitrobenzene-d5 52. % Rec. 625 01/11/00 1528 390 01/13/00 0227 345
2-Fluorobiphenyl 64. % Rec. 625 01/11/00 1528 390 01/13/00 0227 345
p-Terphenyl-d14 170 % Rec. 625 01/11/00 1528 390 01/13/00 0227 345
Phenol-d5 58. % Rec. 625 01/11/00 1528 390 01/13/00 0227 345
2-Fluorophenol 50. % Rec. 625 01/11/00 1528 390 01/13/00 0227 345
2,4,6-Tribromophenol 52. % Rec. 625 01/11/00 1528 390 01/13/00 0227 345
Tom Mellette, ESC Representative
BDL - Below Detection Limit
Det. Limit - Estimated Quantitation Limit(EQL)
Laboratory Certification Numbers:
AIHA - 09227, AL - 40660, CA - I-2327, CT- PH-0197, FL - E87487, GA - 923, IN - C-TN-01
KY - 90010, NC - ENV375,DW21704, ND - R-140, SC - 84004, TN - 2006, VA - 00109, WV - 233
Notes:
The reported analytical results relate only to the sample submitted
This report shall not be reproduced, except in full, without the written approval from ESC.
Page 8 of 10

ENVIRONMENTAL
S C I ENCE CORP .
Mr. Wayne Althouse
Burlington Research Inc.
1302 Belmont Street
Burlington, NC 27215
Date Received 01/07/00 07:30
Description
Sample ID 0A132-002
Collected By
Collection Date : 01/05/00 12:00
Parameter
Volatile Organics
Acrolein
Acrylonitrile
Benzene
Bromodichloromethane
Bromoform
Bromomethane
Carbon tetrachloride
Chlorobenzene
Chlorodibromomethane
Chloroethane
2-Chloroethyl vinyl ether
Chloroform
Chloromethane
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
1,1-Dichloroethane
1,2-Dichloroethane
1,1-Dichloroethene
trans-1,2-Dichloroethene
1,2-Dichloropropane
cis-1,3-Dichloropropene
trans-1,3-Dichloropropene
Ethylbenzene
Methylene Chloride
1,1,2,2-Tetrachloroethane
Tetrachloroethene
Toluene
1,1,1-Trichloroethane
1,1,2-Trichloroethane
Trichloroethene
Trichlorofluoromethane
Vinyl chloride
Total Xylenes
Surrogate Recovery
Toluene-d8
Dibromofluoromethane
4-Bromofluorobenzene
REPORT OF ANALYSIS
January 13,2000
ESC Sample #
ESC Key :
Site ID .
Project # :
12065 Lebanon Rd.
Mt. Juliet, TN 37122
[phone]
1-800-767-5859
Fax [phone]
Tax I.D. 62-0814289
Est. 1970
L8556-07
Result Det. Limit Units Method Prep PID Analyzed AID
BDL 50. ug/1 624 01/07/00 1435 303 01/08/00 1531 303
BDL 50. ug/1 624 01/07/00 1435 303 01/08/00 1531 303
BDL 1.0 ug/1 624 01/07/00 1435 303 01/08/00 1531 303
BDL 1.0 ug/1 624 01/07/00 1435 303 01/08/00 1531 303
BDL 1.0 ug/1 624 01/07/00 1435 303 01/08/00 1531 303
BDL 1.0 ug/1 624 01/07/00 1435 303 01/08/00 1531 303
BDL 1.0 ug/1 624 01/07/00 1435 303 01/08/00 1531 303
BDL 1.0 ug/1 624 01/07/00 1435 303 01/08/00 1531 303
BDL 1.0 ug/1 624 01/07/00 1435 303 01/08/00 1531 303
BDL 1.0 ug/1 624 01/07/00 1435 303 01/08/00 1531 303
BDL 1.0 ug/1 624 01/07/00 1435 303 01/08/00 1531 303
BDL 5.0 ug/1 624 01/07/00 1435 303 01/08/00 1531 303
BDL 1.0 ug/1 624 01/07/00 1435 303 01/08/00 1531 303
BDL 1.0 ug/1 624 01/07/00 1435 303 01/08/00 1531 303
BDL 1.0 ug/1 624 01/07/00 1435 303 01/08/00 1531 303
BDL 1.0 ug/1 624 01/07/00 1435 303 01/08/00 1531 303
BDL 1.0 ug/1 624 01/07/00 1435 303 01/08/00 1531 303
BDL 1.0 ug/1 624 01/07/00 1435 303 01/08/00 1531 303
BDL 1.0 ug/1 624 01/07/00 1435 303 01/08/00 1531 303
BDL 1.0 ug/1 624 01/07/00 1435 303 01/08/00 1531 303
BDL 1.0 ug/1 624 01/07/00 1435 303 01/08/00 1531 303
BDL 1.0 ug/1 624 01/07/00 1435 303 01/08/00 1531 303
BDL 1.0 ug/1 624 01/07/00 1435 303 01/08/00 1531 303
BDL 1.0 ug/1 624 01/07/00 1435 303 01/08/00 1531 303
BDL 5.0 ug/1 624 01/07/00 1435 303 01/08/00 1531 303
BDL 1.0 ug/1 624 01/07/00 1435 303 01/08/00 1531 303
BDL 1.0 ug/1 624 01/07/00 1435 303 01/08/00 1531 303
BDL 1.0 ug/1 624 01/07/00 1435 303 01/08/00 1531 303
BDL 1.0 ug/1 624 01/07/00 1435 303 01/08/00 1531 303
BDL 1.0 ug/1 624 01/07/00 1435 303 01/08/00 1531 303
BDL 1.0 ug/1 624 01/07/00 1435 303 01/08/00 1531 303
BDL 1.0 ug/1 624 01/07/00 1435 303 01/08/00 1531 303
BDL 1.0 ug/1 624 01/07/00 1435 303 01/08/00 1531 303
BDL 3.0 ug/1 624 01/07/00 1435 303 01/08/00 1531 303
88. % Rec. 624 01/07/00 1435 303 01/08/00 1531 303
82. % Rec. 624 01/07/00 1435 303 01/08/00 1531 303
79. % Rec. 624 n 01/07/00 1435 303 01/08/00 1531 303
Tom Mellette, ESC Representative
BDL - Below Detection Limit
Det. Limit - Estimated Quantitation Limit(EQL)
Laboratory Certification Numbers:
AIHA - 09227, AL - 40660, CA - I-2327, CT- PH-0197, FL - E87487, GA - 923, IN - C-TN-01
KY - 90010, NC - ENV375,DW21704, ND - R-140, SC - 84004, TN - 2006, VA - 00109, WV - 233
Notes:
The reported analytical results relate only to the sample submitted
This report shall not be reproduced, except in full, without the written approval
from ESC.
Page 9 of 10

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
January 28, 1998
Mr. Gene Hudgens
Plant Manager
Delta Apparel, Inc.
100 West Pine Street
Maiden, North Carolina 28650
Subject: NPDES Permit Modification
Permit No. NC0006190
Delta Mills Maiden WWTF
Catawba County
Dear Mr. Hudgens:
In accordance with the request for a discharge permit modification received on June
25, 1997, the Division is forwarding herewith the subject NPDES permit. This permit
modification 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 December 6, 1983.
Delta Mill's modification request pertained to an increase of the average monthly flow
limit from 1.0 MGD to 1.5 MGD. You should be aware that existing limits for certain
parameters have changed. These limits are based on the production numbers that were
reported by the Delta Mills facility. All comments on the draft permit, submitted by Applied
Water Technology on December 15, 1997, were incorporated into this permit modification.
As Applied Water Technology requested in their letter, the consideration of the downstream
relocation of the outfall has been eliminated.
As previously mentioned, the Division of Water Quality and the Division of Pollution
Prevention and Environmental Assistance are working in cooperation in an effort to reduce
color. DWQ and DPPEA are developing a voluntary program that will assist facilities
attempting to reduce color. Statewide workshops and conferences will be held to publicize the
effort. Delta Mills is encouraged to participate and provide feedback to the Division. For
additional information see the attached Management Strategies for Controlling Color, or call
John Burke at [phone].
If any parts, measurement frequencies or sampling requirements contained in this
permit are unacceptable to you, you have the right to an adjudicatory hearing upon written
request within thirty (30) days following receipt of this letter. This request must be in the form
of a written petition, conforming to Chapter 150B of the North Carolina General Statutes, and
filed with the Office of Administrative Hearings, Post Office Drawer 27447, Raleigh, North
Carolina 27611-7447. Unless such demand is made, this decision shall be final and binding.
Please take note that this permit is not transferable. Part II, E.4. addresses the
requirements to be followed in case of change in ownership or control of this discharge. This
permit does not affect the legal requirements to obtain other permits which may be required by
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper
06190 cov ltr

1/12/2000 1:11:02 PM
List Entries over Time for Q.C.MONTHLY LBS
Delta Mills, Inc. - Maiden Plant N A D t. S AJ C ovo 6 / 4 p
12:00:00 AM To 12:00:00 AM
Ccc-kcwibc4, Co:4„A�
Page 1
Day
Jan 97
Feb 97
Mar 97
Apr 97
May 97
Jun 97
Jul 97
Aug 97
Sep 97
Oct 97
Nov 97
Dec 97
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
2.374355
29
30
3.296000
1.222434
2.004000
1.827320
31
2.861111
2.582000
1.418660
1.436765
2.126886
2.893658
1.764711
P ro cA: on.) D c .$c
Mt 11;ON-S Q; 1 6s ((P aisiefj
� v .I cot I oig = �s, seo7, qao lbs.

1/12/2000 1:11:08 PM
List Entries over Time for Q.C.MONTHLY LBS
Delta Mills, Inc. - Maiden Plant PDEs"s Ate.. 000 6 t 90
12:00:00 AM To 12:00:00 AM
Cc.�w�w C0L4"Ay
Page 2
Day
Jan 98
Feb 98
Mar 98
Apr 98
May 98
Jun 98
Jul 98
Aug 98
Sep 98
Oct 98
Nov 98
Dec 98
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
2.578018
29
30
2.946622
2.986780
2.807443
2.524440
31
2.547086
2.785541
2.331519
2A81370
2.583510
2.977709
2.079921
Q r_Q_Lsci a Dojo:.
vY� , LU o,.s p 4- l b s .CFt,,i,t,.l)
.7; l jo(% Pi B = 31)(oat4,g59,$�005.

h 1,
111212000 1:13:19 PM
List Entries over Time for Q.C.MONTHLY LBS
Delta Mills, Inc. - Maiden Plant
12:00:00 AM To 12:00:00 AM
Ccs�aw6w. Cou#y
Page 3
Day
Jan 99
Feb 99
Mar 99
Apr 99
May 99
Jun 99
Jul 99
Aug 99
Sep 99
Oct 99
Nov 99
Dec 99
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
2.543459
29
30
2.397430
2.577643
2.606937
2.880282
31
3.012163
2.404902
2.271729
2.964064
2.614486
3.370686
2.409673
P r o dkc ' i i P4
t'Atil c.)>.1.s o c l b s( nusk.A.)
To$0,1 Qor lqqq = 31.,os3A-SS.4 lbs.

0
O.
Iv, /orn //e_ftsc'
From; Alle,l /?G&e�
2/28/2001 11:47:09 AM
LfstEntries over Time far 4C.GMONTHLY LBS
Darla Altilfs, tnc. • Maiden Plant
12:00:00 AM To 12:00:00 AM
4P!°are 1,
Ci-e_,_ Lobe,,. C ty Piga1
Pi0ES Alt a00%fQa
Day Jan 00 Feb 00 Mar 00 I Apr 00 May 00 { Jinn 00 J u100 Aug 00 ' Sep 00 ' Oct 00 Nov 00 Dec 00
3
a _.
6
t-
. 8
9
10
11
12
13
14
15
16
17
$?
19
20
23
24 —
25
26
27
28
Q 24 ! 2.738287
30
31 3.272178
ri
0
00
.0
0
lL
3.825488
— 3.149661 —
2.939047
3.103615 3.203933
2.992108 3.317709 2.827638 ' 4.184545 2.746875
Pr Q cl{.i(S 1 G M [+ i jti
+ S.
To r, 1 POf 6otl = 3 8) 36d, i S tbs ,
J..-o -: +�ckN. 4,�rrf, tfif 0Atr C3'-i`. G1IG irlGC{ pet Axis ,

NPDES Analyses, Aquatic Toxicity Testing, Field Services,
Infrastructure Evaluation, Chemical Product Environmental Assessments,
Toxicity Reduction Evaluations
BURLINGTON
RESEARCH
ANALYTICAL REPORT
CUSTOMER: Delta Apparel, Inc.
REPORT TO: Mr. Allen McRee
SAMPLE DESC: PPA ANALYSIS
SAMPLE TYPE: WASTEWATER, EFFLUENT COMP
COLLECTED: 01/04/00 12:00 to 01/05/00 12:00
WORK ORDER #: 0A132-001
RECEIVED: 01/06/00
REPORTED: 01/20/00
PO NUMBER: #001394
PARAMETER
DATE/TIME/ANALYST MQL RESULT
Base-Neutral/Acid Extractables
EPA 625
Started 01/11/00 15:28
Analyzed 01/13/00 by ESC at See attached
Attached
Organo-chlorine Pesticides
EPA 608
Started 01/07/00 14:28
Analyzed 01/11/00 by ESC at See attached
Attached
Antimony, Total by ICPMS
EPA 200.8
Started 01/07/00 12:25 0.00002
Analyzed 01/11/00 by RTW at BRI - Burlington
0.0025 mg/L
Arsenic, Total by GF
EPA 206.2
Started 01/07/00 12:25 0.005 <0.005 mg/L
Analyzed 01/10/00 by SJH at BRI - Burlington
Beryllium, Total by ICPMS
EPA 200.8
Started 01/07/00 12:25 0.00006 <0.00006 mg/L
Analyzed 01/11/00 by RTW at BRI - Burlington
Cadmium, Total by ICPMS
EPA 200.8
Started 01/07/00 12:25 0.00004 0.00021 mg/L
Analyzed 01/11/00 by RTW at BRI - Burlington
Chromium, Total by ICPMS
EPA 200.8
Started 01/07/00 12:25 0.0007 <0.0007 mg/L
Analyzed 01/11/00 by RTW at BRI - Burlington
Copper, Total by ICPMS
EPA 200.8
Started 01/07/00 12:25 0.002
Analyzed 01/11/00 by RTW at BRI - Burlington
0.044 mg/L
Lead, Total by ICPMS
EPA 200.8
Started 01/07/00 12:25 0.0002 <0.0002 mg/L
Analyzed 01/11/00 by RTW at BRI - Burlington
Mercury, Total by FIAS
EPA 245.1
Started 01/09/00 12:00 0.0002 <0.0002 mg/L
Analyzed 01/10/00 by SJH at BRI - Burlington
Nickel, Total by ICPMS
EPA 200.8
Started 01/07/00 12:25 0.002
Analyzed 01/11/00 by RTW at BRI - Burlington
0.004 mg/L
Selenium, Total by ICPMS
EPA 200.8
Started 01/07/00 12:25 0.0003
Analyzed 01/11/00 by RTW at BRI - Burlington
0.0004 mg/L
Burlington - Corporate Offices
1302 Belmont Street • Burlington, NC 27215-6935
Phone [phone] • Fax [phone]
Page 1
Eden
370 W. Meadow Road • Eden, NC 27288
Phone [phone] • Fax [phone]
BR-2 6/99

II
NPDES Analyses, Aquatic Toxicity Testing, Field Services,
Infrastructure Evaluation, Chemical Product Environmental Assessments,
Toxicity Reduction Evaluations
BURLINGTON
RESEARCH
(0A132-001 continued)
PARAMETER
DATE/TIME/ANALYST MQL RESULT
Silver, Total by ICPMS
EPA 200.8
Started 01/07/00 12:25 0.00001 0.00001 mg/L
Analyzed 01/11/00 by RTW at BRI - Burlington
Thallium, Total by ICPMS
EPA 200.8
Started 01/07/00 12:25 0.00001 <0.00001 mg/L
Analyzed 01/11/00 by RTW at BRI - Burlington
Zinc, Total by ICPMS
EPA 200.8
Started 01/07/00 12:25 0.005
Analyzed 01/11/00 by RTW at BRI - Burlington
0.013 mg/L
MQL = Minimum Quantitation Limit
Burlington - Corporate Offices
1302 Belmont Street • Burlington, NC 27215-6935
Phone [phone] • Fax [phone]
Page 2
Eden
370 W. Meadow Road • Eden, NC 27288
Phone [phone] • Fax [phone]
BR-2 6199

NPDES Analyses, Aquatic Toxicity Testing, Field Services,
Infrastructure Evaluation, Chemical Product Environmental Assessments,
Toxicity Reduction Evaluations
BURLINGTON
RESEARCH
ANALYTICAL REPORT
CUSTOMER: Delta Apparel, Inc.
REPORT TO: Mr. Allen McRee
SAMPLE DESC: PPA ANALYSIS
SAMPLE TYPE: WASTEWATER, EFFLUENT GRAB
COLLECTED: 01/05/00 12:00
WORK ORDER #: 0A132-002
RECEIVED: 01/06/00
REPORTED: 01/20/00
PO NUMBER: #001394
PARAMETER
DATE/TIME/ANALYST MQL RESULT
Cyanide, Total
EPA 335.2
Started 01 / 17/00 16:00 0.005 <0.005 mg/L
Analyzed 01/19/00 by MTT at BRI - Burlington
Phenol, Total
SM-5530C 18TH
Started 01/19/00 18:55 0.005 <0.005 mg/L
Analyzed 01/20/00 by TAR at BRI - Burlington
Purgeable Organics, 624
EPA 624
Started 01/07/00 14:35 Attached
Analyzed 01/08/00 by ESC at See attached
MQL = Minimum Quantitation Limit
Certifications:
BRI - Burlington
NC Chemistry: #85, Biomonitc ring: #002, Drinking Water: #37743, Radiation License: #001-0904-0G
VA SWCB ID: #000061, Drinking Water: #00018
SC Laboratory ID: #99042
EPA Chemistry Lab ID: NC00137, Bioassay Lab ID: NC2721500
Burlington - Corporate Offices
1302 Belmont Street • Burlington, NC 27215-6935
Phone [phone] • Fax [phone]
Page 3
Eden
370 W. Meadow Road • Eden, NC 27288
Phone [phone] • Fax [phone]
BR-2 6,99

,r.1 Aa FA:
2002 e►letA,/ri/ —
Michael F. Easley, Govemor
William G. Ross Jr., Secretary
r / Ret,/
Nortt} Carolina Department of Environment and Natural Resources
)41 pi etf ke(ir 0
btm
i11C!) r1 I 1 �1 w p_e r'M i F►.1(
February 8, 2002
MEMORANDUM
TO:
FROM:
SUBJECT:
Re:
Greg Thorpe
Bobby Blowe
Findings and Recommendations
Public Hearing held on August 28, 2001
Renewal of NPDES permits
NC0005274
NC0006190
NC0074268
NC0020184
NC0025496
NC0044440
NC0040797
Yorkshire Americas, Inc.
Delta Apparel, Inc.
City of Gastonia, Crowder's Creek
City of Gastonia, Long Creek
City of Lincolnton
City of Cherryville
City of Hickory, Henry Fork
OLLIAij{
As you requested, I served as Hearing Officer for a public hearing to obtain comments
relative to the proposed color removal requirements necessary for the renewal of the above listed
draft NPDES permits. The hearing was held at 7:00 p.m. on August 28, 2001 at the Citizen's
Resource Center in Dallas, NC. The hearing was held in response to numerous complaints about
the colored effluent plumes from some of the above permitted facilities. These plumes are
primarily due to the large number of textile dischargers in the Catawba River Basin.
BACKGROUND
15A NCAC 02B.0211(3)(f) states, in part, that colored wastes are allowed only in " such
amounts as shall not render the waters injurious to public health, secondary recreation or to
aquatic life and wildlife or adversely affect the palatability of fish, aesthetic quality or impair the
waters for any designated uses". Noticeably colored effluent from the above facilities, as well as
others, in the Catawba River Basin has been the subject of an ever increasing number of
complaints over the years. However, there has been no evidence collected by the Division, nor
presented by others, to indicate that these facilities are having anything other than an aesthetic
impact on the receiving stream.
Construction Grants and Loans Section 1633 Mail Service Center
Raleigh, NC 27699-1633 [phone]
E-Mai dress www.nccgl.net FAX [phone]
/.1Q1d\
Customer Service
1 800 623-7748

The Division and several of the major color dischargers met in 1999 to discuss ways to
address the color issue. From this meeting, the South Fork Catawba River Water Quality
Alliance was formed to conduct color monitoring and assess the color problems in the watershed.
The data collected by the Alliance was incorporated into a final Color Study Report that was
submitted to the Division in March of 2001. This report documented noticeable color plumes
from the various discharge locations ranging from "no plume observed" at the Pharr Yarns
WWTP to " > 8.3 miles" for Delta Apparel. Water Quality Section staff also conducted
independent color evaluations during a site visit to the discharge locations in August of 2000.
Numerous photographs and water samples were taken, documenting the color problems in the
watershed. Based upon the findings of the Color Study Report prepared by AWARE
Environmental, Inc. and field visits by Water Quality Section staff, a NPDES Color Permitting
Policy for Catawba River Basin Color Dischargers was developed by the NPDES Unit and
approved by the Director on June 13, 2001. A copy of the policy is attached as Attachment A.
The NPDES Color Permitting Policy places the color dischargers into one of four tiers.
Basically, Tier 1 dischargers will only be required to monitor for color. Tier 2 dischargers will
be required to monitor for color, plus prepare a Best Management Practices Report to address the
potential for reducing effluent color. Tier 3 dischargers must comply with the Tier 1 and Tier 2
requirements, plus conduct a color reduction study to identify the cost associated with reducing
influent color by 75% and 90%. Tier 4 facilities will be required to achieve a 90% color
reduction between their influent and effluent. The tier system, with associated dischargers, is
explained in detail in the policy.
SITE VISITS
Jackie Nowell, Natalie Sierra, Dave Goodrich, Tom Belnick and I departed Raleigh the
day before the hearing to conduct site visits at the various discharges and see the effects of color
first hand. Our first stop was Gastonia's Crowder's Creek facility where we met with the
Director of Utilities, Don Carmichael and others. While supporting the Division's attempts to
reduce color, Mr. Carmichael was concerned that the Crowder's Creek facility had been placed
in Tier 3, since that facility was not a part of the original Alliance study. His concerns stemmed
from the fact that funds to meet the Tier 3 requirements had not been budgeted by either
Gastonia or Kings Mountain, who is the primary source of color at the Crowder's Creek plant. I
am uncertain as to why this facility was not a part of the original color study since their effluent
was extremely red on the day of our visit and appeared to constitute approximately 50% of the
flow in the receiving stream. The color of the receiving stream remained extremely red at the
Forbes Road bridge approximately one mile downstream.
Next we joined Carol Kemker from EPA -Region IV at the Yorkshire America's, Inc. dye
manufacturing plant. We toured their wastewater facility, discussed the improvements that they
had made, and hiked down to the discharge location. On the day of our visit, there was no
discernible color or plume in the receiving stream.
2

Gastonia's Long Creek discharge location was our next stop. Don Carmichael and other
city representatives met us there and explained that there had been a dramatic color reduction in
their effluent since the closure of the Fleischman's Yeast manufacturing facility. From our
vantage point directly above the discharge pipe, the effluent appeared to be very clear with
perhaps a very light green tint. The plume did not appear to be noticeable in the receiving
stream.
We spent the night in Hickory, which is worth mentioning only because Hickory is
located in the upper end of the watershed and we experienced a fairly intense rain event there
overnight. While we did not retrace our steps of the previous day, the additional stream flow
from stormwater runoff may have masked the color of the dischargers we visited on the 28th to
some degree.
Our first stop on the 28th was Hickory's Henry Fork wastewater treatment facility. The
color of effluent at the discharge location was the color of weak tea, but immediately turned to a
very dark color upon contact with the receiving stream, which appeared to be heavily laden with
sediment. It quickly dissipated, however, and was not noticeable a short distance downstream at
the next bridge. One of the difficulties of addressing a color problem in the stream was
demonstrated during our lab visit. Separate samples of plant effluent and water from the stream
appeared to be indistinguishable when compared in lab flasks, contradicting the actual conditions
at the discharge location.
Delta Apparel, Inc. was our next stop where we met with the plant manger, the
wastewater treatment ORC, and their lawyers. Delta Apparel, Inc. employs approximately 400
people and is the only permitted discharger in the basin to be placed in Tier 4 in accordance with
the Division's NPDES Color Permitting Policy. The concerns expressed in this meeting centered
around the proposed 90% color reduction requirement and the fact that all of their monitoring to
date used the Platinum -Cobalt method rather than the ADMI process required by their draft
permit. It is uncertain how the data from the two testing methods would relate and whether a
90% reduction by the Platinum -Cobalt method would equate into a 90% ADMI reduction. (Note:
According to the Standard Methods for the Examination of Water and Wastewater, the Platinum -
Cobalt method is not applicable to most highly colored industrial wastewaters, whereas the
ADMI test was developed by the American Dye Manufacturer's Institute for colored waters and
wastewaters.) The Delta representatives were especially concerned that they couldn't meet a
90% reduction of color when producing lightly colored influent. Apparently, their dye operation
varies widely in response to the needs of their customers, and it would be very difficult to clean
up relatively clean water. Ironically, the plant manager did not want to be held to a specific
number limit either. Rather, he suggested that Delta be placed in Tier 3 for at least another
twelve months so they can continue monitoring through all four seasons using the ADMI
method.
Delta's influent color was extremely black or deep purple on the day of our visit. They
were continuing to add polymer and appeared to be removing a good bit of color, although the
effluent was still very dark. At the discharge location, the dark effluent quickly dissipated within
about 50 yards downstream of release. This situation represents a tremendous improvement
over that which was observed by Division staff on previous visits, although it remains unclear if
the previous night's rain was a factor.
3

The Lincolnton facility was our next stop. We were told by the wastewater treatment
plant personnel that approximately 65% of their flow comes from industrial sources, and that
there are six textile plants with dyeing operations contributing to their influent. The receiving
stream upstream of their discharge was a reddish brown color on the day of our visit. The city's
discharge, however, was a dark gray to black and created a very noticeable plume. The color of
the entire receiving stream was noticeably darker at a bridge about a quarter -mile downstream.
Again, it was impossible to determine if either the upstream or downstream color had been
influenced by the recent rain.
Our last stop was the City of Cherryville's wastewater treatment facilities. We were told
that their only textile discharger was no longer in business. As a result, their effluent discharge
appeared colorless.
PUBLIC HEARING
Approximately 39 people attended the public hearing. Those providing oral comments
were Representatives from the City of Gastonia, City of Lincolnton, Cooperative Extension
Service of Gaston County, the Catawba River Keeper and a Cove Keeper. Copies of all written
comments received are contained in Attachment B to this report.
All speakers were supportive of the tier system as outlined in the NPDES Color
Permitting Policy for Catawba River Basin Color Dischargers. The municipal representatives
were primarily concerned over the rate impact of conducting additional studies and the cost of
possible new construction. The River Keeper, Cove Keeper, and Cooperative Extension Service
were all concerned over the as yet unknown impacts of color on aquatic life. The River Keeper
also wanted Lincolnton's WWTP and Gastonia's Crowder's Creek WWTP moved to tier 4. All
of the speakers were very supportive of the tier system approach.
Delta Apparel had previously asked for additional time to submit technical data
supporting their voluntary efforts to reduce color in their effluent. Therefore, the comment
period was extended until September 23, 2001. Additional comments were also received from
the City of King's Mountain who is concerned that too many additional requirements will force
mills to close, eliminating jobs and leaving the remaining customers with excessively high user
rates, and from a private citizen urging us to hold firm with a 90% reduction requirement for
Delta Apparel, Inc.
After the close of the hearing record, additional data was requested from Delta Apparel,
Inc. in an effort to determine the amount of polymer being added and the resulting color
reduction achieved as measured by the ADMI method. Delta took exception to our requests for
the additional information and objects to a 90% removal requirement. Copies of correspondence
with Delta are attached in Attachment C.
4

FINDINGS & RECOMMENDATIONS
At best, color removal for aesthetic purposes appears to be an inexact science, which is
mastered as often by trial and error as by scientific calculations. I believe that the tiered
approach, as outlined in the NPDES Color Permitting Policy for Catawba River Basin Color
Dischargers, provides an appropriate mechanism for attenuating the impacts of color
dischargers —not only in the Catawba River basin, but in others as well.
Based upon comments received at the hearing, the additional data finally submitted by
Delta Apparel, Inc., and visual observations during our site visit, I recommend the following:
• Yorkshire Americas, Inc. —On the day of our visit, this facility no longer seemed to
have a color problem. However, due to the nature of their business, I believe that they are
appropriately included in Tier 2 and should be required to prepare a Pollution Prevention
/ Best Management Practices report.
• Gastonia -Long Creek & Cherryville—With the closure of the major industrial color
contributors to their wastewater treatment plants, these facilities no longer seem to have
color problems. Therefore, I recommend that they both be moved into Tier 1 with a color
reopener special condition.
• Hickory -Henry Fork —I believe that this facility is appropriately placed in Tier 3.
• Gastonia-Crowder's Creek —Since this facility was not a part of the original color study,
and since this permit cycle will expire on July 31, 2005, I concur with the Tier 3
designation. However, Gastonia should be advised that this facility will be placed in Tier
4 at the next permit renewal unless there is a significant improvement in the color of their
effluent.
• Lincolnton—Based upon the comments received at the public hearing and the actual
conditions observed during our site visit, I believe that Lincolnton should more
appropriately be designated as a Tier 3 facility. A Tier 3 designation requires the
preparation of a color reduction study within 24 months of the permit's effective date.
The Division would then have time to determine if this facility should move to Tier 4 for
the next permit cycle.
• Delta Apparel, Inc. —Based upon the test data available to us at this time, I concur with
Delta's argument that it would be difficult for them to consistently meet a 90% color
reduction when their dye use varies from 65% to 2% as stated in their attorney's letter of
September 21, 2001. However, data collected by the NPDES Unit reveals that other
textile and municipal facilities are able to achieve 90-plus percent color removal and
produce an effluent with ADMI ranges of between 400 to <25 units (see Attachment D).
Therefore, I believe that Delta is appropriately designated as a Tier 4 facility and should
have a specific color limit —expressed either as a percentage reduction or in ADMI units.
The ADMI test data submitted by Delta for the period of July 24, 2001 through December
4, 2001, indicates that they have achieved color reductions varying from 46% to 93%.
The highest monthly influent color average during this time frame was 5754 ADMI units.
The highest monthly effluent color average during this time was 860 ADMI units. (The
effluent color on the day of our visit was 748 ADMI units) I believe that it would be
5

appropriate to assign a color limit to Delta that we are reasonably comfortable that they
can achieve and gradually ratchet it down, over time, to a point that the color discharged
would neither be objectionable nor detrimental to the stream.
Therefore, it is my recommendation that the permit contain a phased monthly average
ADMI limit. Phase I of the permit cycle would run for 12 months from the date of
issuance and contain an ADMI limit of 863 units, which represents an 85% reduction from
their highest monthly influent concentration for which data is available. Delta's data
indicates that a limit of 863 ADMI units is attainable. Phase II of the cycle would follow
for the next 12 months and require them to meet a monthly average ADMI limit of 720
units. The final phase, running through the end of the permit cycle in 2005, would require
compliance with a monthly average ADMI limit of 575 units. The final ADMI limit of
575 units represents a 90% reduction from their highest influent average of 5754 units,
which occurred in October of 2001. Influent ADMI values, as well as the brand name,
quantity and cost of any polymer additions should also be reported monthly. The permit
should also contain a color re -opener clause that would allow additional requirements to
be imposed should conditions warrant.
Finally, I'd like to commend the efforts of the staff of the NPDES unit for their work in
developing the color policy, their research and assistance in collecting and analyzing data, and
preparing for the hearing. There doesn't appear to be a great deal of technical literature available
on color removal and their input has been invaluable.
ATTACHMENTS:
A. NPDES Color Permitting Policy for the Catawba River Color Dischargers
B. Public Hearing comment
C. Correspondence with Delta Apparel, Inc. -i-
X. Data supplied by Delta Apparel, Inc.
A.b Comparison of data from Delta Apparel, Inc. to other color dischargers
6

ATTACHMENT A
NPDES COLOR PERMITTING POLICY FOR THE CATAWBA RIVER COLOR
DISCHARGERS

1
MEMORANDUM
To: Tommy Stevens
Through: Coleen S li
Bill Reid
Dave Go : rich
From: Tom Belnick
Division of Water Quality
Point Source Branch/NPDES Unit
June 5, 2001
•
Subject: NPDES Color Permitting Policy
Catawba River Basin Color Dischargers
This NPDES Color Permitting Policy addresses eight color dischargers in the South Fork
Catawba River watershed (subbasins 030835 and 030836). The policy provides for a tiered
permitting approach, ranging from color monitoring for facilities showing no color plume, up to
color reduction limits for facilities exhibiting major color plumes and downstream aesthetic
impacts.
Background. The South Fork Catawba River watershed was identified in previous basin plans
as having a high concentration of textile dischargers, along with public concerns and
complaints regarding color from such discharges. In August 1999 the Division met with
selected color dischargers in the watershed to address the color issue. As a result of this
meeting, eight color dischargers (Pharr Yarns, Delta Mills, Yorkshire, Cramerton, Lincolnton,
Gastonia -Long Creek, Hickory, and Cherryville) elected to form the South Fork Catawba River
Water Quality Alliance and undertake a comprehensive color monitoring study to identify
current color problem areas in the watershed. The color monitoring was conducted twice per
month from April through November 2000, and included color monitoring of effluent,
upstream and downstream stations, as well as reference sites. The study included analytical
color measurements (ADMI units), visual observations, and photographs. The study period
included an extremely dry summer, and should represent worst case conditions. In addition,
the study represents the most current assessment of color conditions in the watershed, given
the changing nature of textile facilities across the state. The Alliance submitted individual
reports to the Division for each sampling event, as well as a Final Color Study Report (AWARE
Environmental, Inc., March 2001). One color discharger in the watershed (City of Newton)
elected to evaluate color independently from the Alliance members, using similar monitoring
protocols.
Color Regulation. According to state regulation [15A NCAC 02B.0211(3)(f)], colored effluent is
allowed in "only such amounts as shall not render the waters injurious to public health,
secondary recreation or to aquatic life and wildlife or adversely affect the palatability of fish,
aesthetic quality or impair the waters for any designated uses." To date, there are no data to
show that the colored effluent is posing a human health concern, or that color is a source of
impact on the aquatic biota. Therefore, aesthetic concerns are the primary issue associated
with the narrative color standard.
NPDES Color Permitting Policy
Page 1 of 5

1
Data Evaluation. The evaluation of color as an aesthetic impact is difficult since it is a
subjective determination. In addition, a host of factors, such as hue, instream turbidity,
suspended matter, dilution, light conditions, and downstream access all play a part in
determining when a color impact might be perceived by the public.
The ADMI method used to measure color quantitatively in the study takes into account the
entire visible spectrum, and was originally developed to be related to visual perceptibility.
During data review, it was realized that ADMI color measurements do not always predict the
potential for a color impact. For example, a color plume with downstream aesthetic impact
was observed at Cherryville on several sampling events, although the effluent ADMI color was
low (summer average = 63 ADMI) and similar to upstream values. The plume was likely due to
the particular hue of the effluent and the low instream dilution, rather than an absolute ADMI
value. In this situation, consideration of a numerical instream ADMI color standard would be
ineffective. However, requiring some percentage reduction in effluent color would help to
minimize the size of the color plume. Conversely, some facilities with greater colored effluent
(e.g., Pharr Yarns and Yorkshire with summer averages of 844 and 3449 ADMI units,
respectively) did not produce major instream color plumes, most likely due to the effluent hue
as well as the large dilution available. Therefore, in order to evaluate the data, it was realized
that no single criterion, but rather a combination of ADMI measurements, photographs, and
plume descriptions were needed to fully assess the instream color conditions.
Specific data utilized from the Final Color Study Report submitted by the Alliance included: 1)
frequency of plumes observed at the outfall (see Appendix A, Table 5-2); 2) frequency of
visual color change at the downstream station (see Appendix A, Table 5-1); and 3) statistical
color difference between upstream and downstream stations during summer (see Appendix A,
Table 4-2). The study reported that Pharr Yarns was the only facility that did not produce a
color plume at the outfall at any time during the study, while for the remaining facilities, color
plumes were reported observed at the outfalls from 60% to 100% of the time. The study also
reported that visual changes in downstream color were observed at the following frequencies:
Hickory (20%), Cherryville (60%), Delta Mills (87%), and 0% for the remaining facilities.
Finally, the study reported the largest measured summer increases in ADMI color at the
downstream station at the following facilities: Gastonia -Long Creek (23% increase), Hickory
(31% increase), and Delta Mills (58% increase). Downstream stations were located between 0.5
to 2.5 miles below the outfalls, generally at accessible bridge locations. Thus, comparison of
various downstream impacts must be made with this fact in mind.
The data from the report was supplemented with visual observations made by . Division staff
during an August 22, 2000 site visit to all outfalls and downstream stations. The consensus
from the site visit was that significant color plumes were evident at outfalls from Delta Mills,
Cherryville, Hickory, and Gastonia -Long Creek. These were not single incidents, as report
photographs attest to their recurrence during the study. Color pictures of these plumes taken
from various sampling dates are included in Appendix A. Color plumes at the other facility
outfalls were either nonexistent or much less noticeable.
Tiered Classification. The NPDES Color Permitting Policy establishes four tiers of action
based on varying aesthetic color impacts to the receiving waters. The tier groupings were
based on the data reported in the Final Color Study Report, as well as field observations made
by Division staff. The Tier 1 facility showed no visible color plume during the color study. Tier
2 facilities showed minor color plumes at the outfall and limited downstream color impact.
Tier 3 facilities showed significant color plumes at the outfall and at times greater downstream
NPDES Color Permitting Policy
Page 2 of 5

color impact. Finally, the Tier 4 facility showed significant plumes at the outfall and
significant downstream color impacts. The data are summarized in Table 1.
It should be noted that Gastonia -Long Creek was originally placed in Tier 3 based on color
study results. However, after the color study was completed, their major color discharger
(Fleishman's Yeast) was removed, resulting in a Tier 2 re -ranking. Also, Cherryville is
currently ranked as Tier 3 based on color study results, but is scheduled to lose their lone
textile discharger in July 2001. After this color source is removed, Cherryville can request a
re -ranking with subsequent reduction in permitting requirements.
TABLE 1- Tiered Classification
Tier
-. � j �
- � Fa,
� 5 Y. , Y
z
L a.)• A�: ��
- ♦ h•t. .i,i' i7
lyN �Pr � �Rr
4 .',:,
- ;u � !. +
- . .) •ati ,'1±-�}
�`-
x-, �, �fxequencyem.
x ems ,• .
yYv. ��y.7�.r- a.-:a� e
� {® ti rve {Y e. A f,,y,
�Y`/'���}�y3;y7��1 �r����'� t+"
D w-t't,
�<a.,• `scat-_
(�� {5n
of
Visual Change at
- - - tr'�' +��
�C Downs{.L eam
'¢ice /-•.]
-1 tO i.
• - .
� .�.:�_
% eea0
5� � II '
-3:,.- � -�-� - •.�
F ']` ay •r;.s.
5�., .ii- K�,y.
�
i fY r' J' • Y
•
1 aJ,to
��i.•t:- ._-��{�•
�. lA{:.Y ~.i��•-y� { �._
r ,.
x ' +' " Tr -s
1
Pharr Yarns
(NC0004812)
0%
0%
-5%
0.59
2
Cramerton
(NC0006033)
100%
(n= 3)
O%
8%
1.6
Lincolnton
(NC0025496)
60%
0%
12%
2.0
Yorkshire
(NC0005274)
67%
00/0
4%
2.56
Gastonia -Long
Creek'
(NC0020184)
100%
00/0
23%
0.53
3
Hickory
(NC0040797)
100%
20%
31%
1.64
Cherryville5
(NC0044440)
100%
,
60%
-8%
1.57
4
Delta Mills
(NC0006190)
100%
87%
58%
2.01
Footnotes:
1. Final Color Study Report. Table 5-2, AWARE Environmental Inc., March 2001.
2. Final Color Study Report, Table 5-1, AWARE Environmental Inc., March 2001.
3. Final Color Study Report, Table 4-2, AWARE Environmental Inc., March 2001.
4. Ranking accounts for removal of major color discharger (Fleishman's Yeast) in April 2001, after the
Color Study was completed.
5. Ranking does not account for scheduled removal of lone textile SIU in July 2001. After textile
removal, facility may request re -ranking.
Color Permitting Policy. All eight Catawba Basin facilities are currently up for permit
renewal, and the basin renewal schedule will extend the permits into 2005. Based on the tier
groupings, progressive permitting actions have been developed for these facilities, ranging from
color monitoring (Tier 1), pollution prevention studies (Tier 2), engineering cost studies for
end -of -pipe treatment (Tier 3), and finally color reduction limits (Tier 4). Color monitoring will
remain a baseline condition for all facilities, as long as color remains a component of the
discharge. Instream stations will be monitored for color monthly during summer, when low
flows represent the most likely period for instream aesthetic impacts. Effluent will be
monitored for color monthly on a year-round basis, to track the consistency of the color input.
NPDES Color Permitting Policy
Page 3 of 5

All color dischargers will also receive a Color Reopener Special Condition, which will allow
permits to be reopened and additional restrictions imposed if color problems persist. The color
limits for the Tier 4 facility will be expressed as a 90% color reduction requirement between
influent and effluent. As discussed previously, a color limit expressed as a percentage
reduction in effluent color should significantly reduce the size of the instream color plume and
aesthetic impact, while avoiding the complications of any single numerical ADMI color limit.
The color permitting requirements are summarized in Table 2, and specific permitting
language is included in Appendix B.
TABLE 2- NPDES Color Permitting Polic
Tier
i -
Facility
_ ., .. .1}
Colo e ement , - (y is?7+�� • , . Sys -=
�y�� +F 1 t(S�f..f,Ty }(� "Tj�}'�,.}�.5,��.� ry .1 ySy{y�, ��[' Y
,.^�`v`= G%�Yzil>' ...i. :}i4i�.'+'f�Alf w'e 'Y'c Y`..ttS.._.'.J. .. .... .. .�. �4.�: �Jl�..� �� yy/'�`- - .. , f ..-1--V .W-,,,,^,`t' TT •
1
Pharr Yarns
Tier 1 facilities will receive color monitoring -only, consisting of monthly
effluent sampling, and summer -only (April -October) instream monitoring
(upstream, downstream). If observed, plume descriptions should be
recorded. In addition, a Color Reopener Special Condition will be added
that allows permits to be reopened and additional requirements imposed if
color problems persist.
2
Cramerton
Tier 2 facilities will receive Tier 1 requirements plus preparation of a
Pollution Prevention (P2)/Best Management Practices (BMPs) report.
This report will address the potential for the facility to reduce effluent color
by incorporating P2 measures and/or BMPs prior to treatment. For example,
the facility could investigate the dyeing process, looking at the potential for
dye substitution, improved dyeing efficiency, etc. The facility could dc.this
work independently with their dye supplier or other resource, or request
voluntary assistance from the NC Division of Pollution Prevention and
Environmental Assistance. The report will be submitted within 12 months of
the permit effective date.
Lincolnton
Yorkshire
Gastonia- Long
Creek'
3
Hickory
Tier 3 facilities will receive Tier 2 requirements plus preparation of a Color
Reduction Study. The color reduction study will involve an end -of -pipe
treatment evaluation to develop costs to reduce influent color by 75% and
90%. The reports will be submitted within 24 months of the permit effective
date.
Cherryville2
4
Delta Mills
Tier 4 facilities will receive color reduction limits (90% color reduction
between influent and effluent) to be im lemented b the ermit effective date.
Footnotes:
1. Ranking accounts for removal of major color discharger (Fleichman's Yeast) in April 2001, after the
Color Study was completed.
2. Ranking does not account for scheduled removal of lone textile SIU in July 2001. After textile
removal, facility may request re -ranking with less stringent permitting requirements.
Additional Facilities. As previously mentioned, the City of Newton (NC0036196) was
originally identified as a color discharger to the South Fork Catawba River watershed, along
with the Alliance members. However, the City of Newton elected to evaluate color conditions
independently from the Alliance. The Division conducted a site visit to the Newton WWTP
prior to permit renewal, and observed a minor color plume at the outfall. In the permit
renewal issued to Newton on March 2, 2001, the permit included monthly summer color
monitoring, as well as a Color Reopener Special Condition. Based on the current tiered
classification, Newton would rank as a Tier 2 facility. Therefore, it is recommended that the
NPDES Color Permitting Policy
Page 4 of 5

Newton permit be reopened, and color requirements consistent with Tier 2 facilities be
incorporated. This would include the additional requirement for a P2/BMP report.
One facility with colored effluent and a significant color plume which was not evaluated in the
color study is the City of Gastonia- Crowders Creek WWTP (NC0074268). This discharge is
also located in the Catawba River Basin (subbasin 030837). Several recent color complaints
have been received for this facility, and Division staff observed a significant color plume during
a recent site visit. This facility is also up for permit renewal. It is recommended that Tier 3
color requirements be placed in the permit renewal.
Conclusion. It is the overall goal of this permitting policy to reduce the magnitude of color
plumes to a level where aesthetic color complaints are infrequent. The Point Source Branch
requests your comments and concurrence with our permitting policy. Please feel free to call
me at extension 543 if you have any questions or comments.
cc: (without Appendix)
Greg Thorpe, Deputy Director
Mooresville Region, Water Quality (Rex Gleason)
Dianne Reid, Classification/Standards Unit
Tom Poe, Pretreatment Unit
Darlene Kucken, Basinwide Unit
NPDES Unit staff
NPDES Color Permitting Policy
Page 5 of 5

1
APPENDIX A
NPDES Color Permitting Policy
Supporting Material
Final Color Study Report (AWARE Environmental, Inc, March 2001)
Table 4-2: Summary of ADMI Color Results- River Samples
Table 4-3: Summary of ADMI Color Results- Discharge Samples
Table 5-1: Summary of General Observations- Downstream Sampling Locations
Table 5-2: Summary of General Observations- Discharge Plumes Within Mixing Zones
Color Study Photos (AWARE Environmental, various sampling event reports during 2000)
Photo of Gastonia Plume
Photo of Hickory Plume
Photo of Chenyville Plume
Photo of Delta Mills Plume

MIMI Mil NMI 1111111 11011 IMO NMI IMO MIN ON MIMI 111111 IMP INN MN MN MO
TABLE 4-2
SUMMARY OF ADMI COLOR RESULTS - RIVER SAMPLES
Sit0..__Ple
ip!i',
:.::::,.;,,;,......:;.:-.;..i.p.',,,,,,trif[
- 1103P114.-.'
!,..:;:,Sio,iiiii.,
.
....,:' Saniplelci6iition,':. ' ::::.-'., ' ".'
1:::. ,. ,. :.„ ' , ,:„...-:, ;•.-...0.::,,,..,iit , ,'.i-,';;;-;. 4- ,.'''' • ,.: -
• .i, .,, '; ";1' ,,i..,..0,:-. .1 .,.... ,
:._ . ADMICOlor at.pit 7.6 (c...'111"'.• ''' -.
%Differenee (Upstream to Downstream)
-,-!:--'‘ --,
LININ% ..,
AM', ' F.!
_ .
:
‘,.:Ar:,.,:,' ' '
4
Tdr,17,.4,,,. ,
. . ,
Dry Weather ,------.-
- : ',. -:.
-:;. • ::-:
-' Wet '
7,-: .1.yi- Weather
' -' T. Average
, _
.14,;•,,,.sli;]1_,..i:
:!0.:Pp jr.:0•!:',
...4
' ,t,40, , •411P,2A:
,,AV
410 gpr
,, , ,:
ii .7 as)
.1.,iwiivi.
A
Henry Fork
Upstream Hickory
20 - 109
90
40
46
--
C
Henry Fork
Downstream Hickory
21 - 119
101
47
63
12%
16%
D
South Fork
Downstream of NCDENR No. C4380000
20 - 141
110
51
66
9%
8%
E
South Fork
Instream Monitoring Location
24 - 137
116
63
63
5%
21%
i''..',,t-'i....;:-
F
South Fork
Upstream Lincolnton
20 - 125
108
63
57
-7%
0%
- .,.,:.:40744:=1
H
South Fork
Downstream Lincolnton
24 - 155
121
72
64
11%
13 %
I
South Fork
Upstream Gastonia
26 - 164
120
77
64
-1%
K
South Fork
Downstream Gastonia/Upstream Yorkshire Am
46 - 143
119
90
81
-1%
16%
M
South Fork
Downstream Yorkshire Am./Upstream P. Yarns
47 - 157
117
78
84
-2%
-14%
.'-,;!--''..:;..:,4•Vi'WV!,,
0
South Fork
NCDENR No. C6500000
49 - 166
121
76
84
3%
-3%
P
South Fork
Downstream Pharr Yarns/Upstream Cramerton
43 - 160
113
75
80
-3%
-4%
R
South Fork
Downstream Cramerton
39 - 180
122
75
87
8%
0%
.
S
Clark Creek
Upstream Delta Apparel
20 - 156
113
62
46
--
--
U
Clark Creek
Downstream Delta Apparel
54 - 149
113
65
84
0%
5%
U-2
Clark Creek
Downstream Delta Apparel #2
57 - 157
107
62
70
-5%
-5%
V
Clark Creek
NCDENR No. C4800000 _
52 - 117
94
61
69
-13%
-2%
MMitectfilitVgli
W
Indian Creek
Upstream Cherryville
33 - 151
104
59
63
--
--
40110.gitiVii
Y
Indian Creek
Downstream Cher ville
33 - 134
97
55
58
-7 %
-7 %
Y-2
Indian Creek
Downstream Cher ville #2
25 - 151
107
--
46
10%
--
Attlkt ""'!r:iHil
Z
Indian Creek
NCDENR No. C5170000
25 - 170
112
55
66
5%
0%
;•:;:,1,0.'5f16e.oltrin
--,....,----
" ' — • . . . •' ..__ _.__ _._ _.__
er wearrier average inciucies samp mg events , uz, .
(2) Spring dry weather includes sampling events 4/11, 5/16, 5/31. Summer Dry Weather includes sampling events 6/13, 6/27, 7/11, 8/8, 8/22, 10/3, 10/17 when stream
flows were <30Q2
treams flows during this period were less than the 30Q2.
53
FINAL 3/01

M— I I N lie I— 1— M—— INN INN I s—
TABLE 4-3
SUMMARY OF ADMI COLOR RESULTS - DISCHARGE SAMPLES
Sam le,
P.
77� a
rl..,
:I ��ii at.f,
.:. .,= S, _..-.. ,.
Satre lua ,910
P •,�
.[+�y,;..�......�
1.174'i �M�.+a a
� r. !`v+: d�- ld iwy� `d
•1 F-i:fC%'.y�,
:� , 3= r .
..� i...k...� �ell'41 1.
_ � � � �
...,;� ,
-i.' u�!:r�' 7 k
N`IP .'-
C _,}'nO�
a w41, '' '
..�'!r �.. I ri
-,7 ., 3 �,� „
'' € ,
� SleeT�o�aiap �;. �� �.,;t ,��, �
�. ,. �,' :. r -;.:; < w: ,
:1*..'. .Xi '.,4 �t ...: ;I'S :3�. r b
. {. ti �:� wq,°:1 �f..,}ii•,,�„ ,.SY2° V:r,•S Y�:. Y,. �Tv. �1
)c'. L:..: `.
. r i 1 s 'l ' �[Ap {gel,
^ `.3 s�yn _nc.h n 51`4�� (; S
'f . _ :'I:L ..
,� r Dolor at 11 .6 :.(e,u :
M ;
�: - � .;��
Ran¢e ..:
_,.
r?,.y!,-, ..
�'. ti1',
E l�k a
.J'�.P`�4.-
c 4� �t'i. R
�
� wr1 � �' ��„ >>
,.Weathe
.
i,. `t
^l
� r tar'. Iy
y�,?1.::.i �1" Ty�f
... ._. '-
:';: , . .c
'�� D V.�eatler'A;ver e x ,,
"b
rY
_ ••�•-
s ,,,,,
r'y5,11
.xi1.
- •�ft1�
a4F+Yi+.-.
''�•}yltflVla ■aw.■,.{•
�..t1i1G... !ti/4L1
B
Henry Fork
Hickory - Henry Fork WWTP
62 - 193
138
92
147
G
South Fork
Lincolnton WWTP
34 - 293
111
114
127
J
South Fork
Gastonia Long Creek WWTP
133 - 849
417
254
536
L
South Fork
Yorkshire Americas
1480 - 5260
2995
4553
3449
N
South Fork
Pharr Yarns
550 - 1160
898
876
844
Q
South Fork
Cramerton WWTP
38 - 237
111
_
176
68
T
Clark Creek
Delta Apparel
921 - 1830
1413
1690
1436
X
Indian Creek
Cherryville WWTP
20 - 99
47
61
63
Z-2(3)
McAlpine Ck.
•
River Standard
20 - 67
--
--
__
Z-3(3)
NA
Black Dye Standard
628 - 882
--
--
--
erage includes sampling events 4/25, 7/25, 9/6,
(2)Spring dry weather includes sampling events 4/11, 5/16, 5/31. Summer Dry Weather includes sampling events 6/13, 6/27, 7/11, 8/8, 8/22, 10/3, 10/17.
(3)Wet weather and dry weather average not applicable to River Standard (Z-2) and Black Dye Standard (Z-3). Samples were collected/prepared at initiation of
study in April 2000.
54
FINAL 3/01

air gm NM MN M MI NW N WI WM I 1.111 11111 11111111 '— N 911
TABLE 5-1
SUMMARY OF GENERAL OBSERVATIONS - DOWNSTREAM SAMPLING LOCATIONS
Discharger
L.,.:.. II' .,',,.f,, C I.
�.r`- A °?J M
fi 1...,i, .1
.�.
' ,1
... � I�
Receiving
g
Stream
:.3
... •..t ,.,..i„:.
if2.i (
�. ° 1 .., rI 2P
,•J�fi kl,• av
,3 ri?:r,'
'..F�Iii�Z'TMtb l.ili 14+
' �.
bang ,un Ses treColor U tream vs Downstream $aruple: Location
Has the'discharge
r:. �S
ever affecteg�dslite >�
,F..,Y
'.., clA♦, a al ',..
Y. fsJk�!; k. •(
n. �^ux y. �r" :�yy� L•}
wS:.R.kK ei•:'Yr'1.�1r .. �1�'`�+•+0 .�
I..
What xs the frequency that a
;e an a In downstream color
�::.. g
a:�,.. s. •,� .,-- ��;
,�;,., ,` t
e.. ., .• a.r
aH y n.. y� �;6z':
•: ., ,-•.'.I� '� M ,. !
,y.J h :ti
mow• C 'i• )hTa
� : h.Yl{I�' `'e,I.WWY•��
I'�� tC(t���1 .even
-
F+ :; ' I r ' ,
,, , k v T
t � � rY,�•
r , > z ,.�,.�: e;ral Q4���"g .AliS �
S y"+ 1.,'. :< � �x J ."k• ^'I ';y't•••
-i' �y(� 'i�,.,1L•o l* �• Rb „# i 1�- , �' .ti
e FF .. :y h4:$ I r ,y !•b FA,,s
r. ..r rI..`t1 KM ,!3 ;N:. w` .i.. . �+ ,
�-¢.,fi" ,':'y� �y:i '>, � {(},-`: �, .,�. '� 7 z�, ti,.,:.
a. �%14 '"'y�- [ F^ r�,
��,. �e ,. r,. f•. ..'�:Y`! �s I� i4��:��j,.
'
Hickory
WWTP
Henry Fork
Yes
20 %
River color changes from light brown with a greenish tint (upstream) to a clearer natural
brown (downstream). Not obvious if directly related to the discharge. River color
downstream appears natural. Change in downstream color was only observed when
stream flows were less than 30Q2.
Lincolnton
WWTP
South Fork
No
--
--
Gastonia
WWTP
South Fork
No
--
-- :
Yorkshire
Americas
WWTP
South Fork
No
--
-- -
Pharr Yarns
WWTP
South Fork
No
--
--
Cramerton
WWTP
South Fork
No
--
--
Delta WWTP
Clark Creek
Yes
87%
Stream is a dark plum color downstream of discharge for several miles. Stream color
becomes a lighter plum at the end of Clark Creek. Significant change in color at
downstream location, even during high flow conditions. Impacts color of South Fork
during low flow conditions. Following significant precipitation, there is not as much
color due to hi:her flows and increased entrained sediment,
Cherryville
WWTP
Indian Creek
Yes
60%
No observed change in stream color from upstream to downstream when flows are
> 30Q2. River color has been observed to change from light brown with a greenish tint
(upstream) to a light murky pinkish/purple (downstream) when flows are <30Q2.
Downstream color similar to Cherryville WWTP plume color, but much lighter and
significantly less color than at discharge location. Unnatural color at downstream bridge
only observed during low flow conditions (i.e. stream flows below 30Q2); however,
unnatural color not always present during low flow. Hue and amount of color varies
slightly between sampling events. ADMI color of Cherryville discharge typically lower
than background color of river.
80
FINAL 3/01

I lilt M •I M .— w i — — s NIP ram vim um
TABLE 5-2
SUMMARY OF GENERAL OBSERVATIONS - DISCHARGE PLUMES WITHIN MIXING ZONE
r
Discharge
g
.. {
C::t
«,
.x a ' `:3'
.. / .......
Receiv-
in g
scream
4 ,' '1:
r i .
:,a +en
si., iva .AI,,
,
Hasa.
plume
ever been
observed.
.'dprtn a
r.,,
4,Shcll ltl7 $.r..;$$RI
. �
.{„rew �. �;
'4 m`t
.....evenbF-i...,>,
What is the
frequency,
thata plume
was`:observedr
t� i!
dutuz r,,:.sa:t,�,.
11h�g'. f.�
.:r.:u,.,. .� ,,;
:l,i.r h';?�,j•' -,
events... ��. .?r
'Tjrpical
color/hue.'.
f
A a
, :..
1,S $rge
} 51 u
;y��. �� k'.
._,, �
;w ��.
.��. .Y.
.
Typical
colorlhue
of plume .
<: a d
ff �..>��. ��,:;
t. . y :y 1;�, cf [
: tau 4'
�;
� dt&c}��.�$i .lei
,�
{ i t...e, yG,
`:0'1 1 8a:•n'rCa
,Width
' ,; of plume bodyand
r pltittie tail : 4 i
:4;:
.,y �ft�°'YQ off r�ver�
; . xe,. '% i 4.".:. Lyr d
3 �;r. T, �S
•:: a Y : wad�h•
Point of pltune:
dlssipa ton;'no
- _
vtstble sttt o(.,
;i3 �,.. >r.
� ,;' plurr}etatl (eta',
{ 1
r
r4
.., �•: � Ge e D p.O4,
Y�`'a : , h :•� tt :f bservattQus i
5r.,t' �, r: a
tT t 1tik. °!¢
5 ':-fi r. S. "
S. .era,
�� n
��'
a �'.'1�)1
.�. ± V�?-..
....,..,:;;AA
!N `' $''
4
i
W r
r
,' ,r, t.: '�;a.s
�k,a•
v• .n.•�{^,
_ 1.,
i s rM: ry
.'7 r.
,��sk� a;�i,•
�:f �"
41. 4t.v. ,
h it .,'\ �i- Y41 .. !" � ,i K (uY I
..l` 4 kw`
w•. -z: �;� L� � .4�, .�- �ri r<.�,.
i..� h 4 ra,u rr!E �Irti
y T`' kr l l :�Y Mrt'„5 •r r
,. . "� ,.. 7..., $4r [ La } r.
• 1, Ri< 4 f�'�A" •.i'VY!�3'j.or:. .Y '
-:" .0 e�.� ��J.I?e:'�.�;�1:. a7��EP+e.rS Y°:�S"t
Hickory
WWTP
Henry
Fork
Yes
100%
light
salmon
brown
brownish
maroon
• 15 ft.
• 40%
• 35 ft.
• 100%
can't
follow
can't
follow
Cannot follow plume past discharge point. At downstream location
plume is not visible. Background color of river is typically turbid
light brown with a greenish hue. The greenish background color of
the river makes the plume more noticeable and the plume appears
darker than the actual discharge color. The color at head of plume
appears darker and is more noticeable during very low river flows.
Color begins to fade in body of plume. Plume is lighter during
higher stream flows.
Lincolnton
WWTP
South
Fork
Yes
60%
shades of
v.v. pale
brown,
gray or
salmon
various
shades of
light
brown;
similar to
stream
color
• 20 ft.
• 20%
• 75 ft.
• 75%
100 ft.
500 ft.
Plume, when present, is typically the same color as the discharge.
Since there is very little visible color in discharge, plume is
typically extremely pale in color and heavily faded. Not usually
very noticeable, even at the head of the plume near discharge pipe.
Color of discharge blends well with natural background color of
river. Occasional foam at discharge pipe due to discharge, which
dissipates within a short distance.
Gastonia
WWTP
South
Fork
Yes
100%
various
shades of
light to
pale
golden
yellow
translucent
dark black
brown
• 40 ft.
• 33%
• 125 ft.
• 100%
225 ft.
700 ft.
Discharge color is a light, pale yellow. However, at the discharge
pipe, plume is a clear dark brown color. Head of plume appears
less turbid and cloudy than stream. Not much visible color in
discharge samples; therefore, discharge color quickly fades in
stream. Discharge color is much Tess noticeable downstream of the
point of discharge w/in 100 ft and fades quickly thereafter.
Difficult to discern between natural river color and plume color
downstream after "100 feet.
Yorkshire
Americas
WWTP
South
Fork
Yes
67%
shades of
dark red
to dark
orange-
brown
shades of
red brown
• 1 ft.
• 2%
• 15 ft.
• 33%
200 ft.
approx.
500 ft.
Plume at discharge pipe is typically same color as discharge, but
lighter because of low discharge flow. Plume is not always
present. When present, plume blends in and fades quickly. Plume
exhibits some shades of red and brown, which while similar to
natural clay color of stream, are distinguishable. Sometimes plume
is as small as several 2 to 4-ft patches of color.
(1) This value is the percentage of sampling events that a plume was observed at the
discharge location nut of a total of 15 camntinn
PVPrifC
(2) Color/Hue of plume at the discharge pipe, which is where the plume is least dispersed and the highest amount of color is noticeable.
81
FINAL 3/01

a — — I` ! 11111rI INK w in I I I M O .— 1 Mall
TABLE 5-2 (continued)
SUMMARY OF GENERAL OBSERVATIONS - DISCHARGE PLUMES WITHIN MIXING ZONE
• Dischara -.
g
,v ' e
t1 r,
,p ..
Receiv
inp
.. alt
, ..
Stream i,
Has•.a
plume
=:ever been
obsei ed
-
-
tt-dorm
L '.Ri �'T
.What is the
rr uency ,
� _
that a plume
as•ob rued
k sc .
.t Ur
kSt ',iw
,
fcai�
� I :
color%hue.'
�� of
'..
e,..
v h..
Typical
+':Fo1olrlhue' ;
of plume
:h d .
ea ,
� � �
'P`U 4y
'r "' t
.,:Width '
p Vp
, of+�ilum bad o d'
T ,. 'JI:'q� y
pliiipe tail -, ? ;.:
ft nd
a of ivex
` i. ( L , �'
�"��1tk,:A dth): yir,. t"
l - , .a��
P aptilt a ew
>' ��, f glum.
�. .?t11J • attd li 7
sxg lt, na �
-
vtsiwe'stgn of.;
tL "p Ye.i wi'.fY�>�i,i: -
3...
�< •,, „, � r
�n,� General
r . �,x, . -, u r Ubseirwations:;
1 i .e
s. a" !
•�k^^..hf�,�s�+7;�7
+ �x-r,
,. +fh >r i..1:
�I • . �
, "� i i a :
r.h.,p`.`.FI
1.
P�'ySH .��
? , ,t.
ti . .
''I'
Iln
catnp g
° � NSNP .a�h:4� �.
� evilant7'iiw,
o:
,7;
S
$-�.
-8II1Il11Itg
'r ,M,
li • 7, , k .t
e its?11 , :
Y
i�et>
� '��,'..
k'
�+
..
�„�• +
Rf� � �
pl ��pp
�Ih- _
?..a t
,a b "
. �� kt
� #�,�•�„
c • ' 3'
r: .�5ry y-..n
S',P...('
�+.��k�
'i �Y'� Y
' z.4a .
,:rN, ,,,
r v �+• ;
'n�t�'it�� ,,
��p�,�t
,n, `
11 lthrYi.(�
ru,a
T 7�4` .
��:,r'A".
,J i11C�f�
s�
4'•' °+-,�• , T '` .,.
'+::•�y.;;',d,k .,'„•,,•. . L"e'�.rx-.
� . a�- .r, , h , 2 �" �� �
r, D �i+ i l l
� �J- .fl. 3u � � ' S' ,
&' dIl Au rti
.,i�
Y' 7.,.i .
t +r, h" " "'',Peel
+ t. {
Pharr
Yarns
WWTP
South
Fork
No
0%
light to
dark
orange-
reddish
brown
not
applicable
not
applic-
able
not
applic-
able
not applicable
No plume observed during sampling events.
Cramerton
WWTP
South
Fork
Yes
100%(3)
v. pale
smokey
gray
black
• 10 ft.
• 5% to
10%
• 25 ft,
• 15%
20 ft.
•
<400
ft.
Discharge color is a pale, smokey gray color. Plume at discharge
pipe is a darker grayish black. Plume is noticeable at discharge
pipe, but tends to mix and fade quickly after 50 ft. Plume is not
very noticeable from center of stream in boat. Because discharge
color is very light, plume color is heavily faded within -100 ft.
and barely noticeable thereafter.
Delta
WWTP
Clark
Creek
Yes
100%
dark plum
black
(opaque)
dark plum
black
(opaque)
• 15 ft.
• 50%
(body
only)
• 30 ft.
• 100%
200 ft.
(only
during
rain
event)
> 8.3
miles
Head of plume is plum black at discharge pipe and very noticeable
in the stream. Color of body of plume is a dark plum black.
Plume completely -325
mixes across width of stream at ft.
downstream from pipe and stream becomes a plum color. Deeper
areas appear darker plum/black. Color does not fade well, even at
downstream bridges. Stream remains plum color through Clark
Creek (8.3 miles) and during very low flows contributes to the
blacker color in the South Fork. Plume dissipated within 200 ft.
following significant precipitation.
Cherryville
WWTP
Indian
Creek
Yes
100%
various
shades of
v. pale
grays and
pinks
shades of
dark
purple
• 5 ft.
• 33%
• 15 ft.
• 100%
can't
follow
- 2.
miles
Discharge color is very pale with little visible color. At discharge
pipe, plume is clear shade of plum and is typically very noticeable,
Color mixes and becomes very pale during high stream flows.
During lower stream flows (below 30Q2), discharge may turn
water in stream a pale purplish pink at downstream bridge. Max
distance downstream discharge color ever observed during
sampling is at Sample Location Y-3, 2.9 miles from discharge
pipe. Color barely visible at this point and not readily
distinguishable.
111 Thic Vohs is the nerrenrlor of c,mnlino ovenrc rhir n nlumn War nheoru..rt ,r rho rticrho roo I.......hh... ...,. ..c........I .-r 1C--�_,:_
-
(2)
(3)
Color/Hue of plume at the discharge pipe, which is where the plume is least dispersed and the highest amount of color is noticeable.
Access to Cramerton plume is limited and requires boat rental. Therefore only 3 events performed during study.
82
FINAL 3/01

3
APPENDIX B
NPDES Color Permitting Policy
Special Condition Language
The following language will need to be incorporated into NPDES permits as Special Conditions,
using the applicable tier language.
A (1). Color Permitting Requirements for Tier 1 Facility
This facility has been classified as a Tier 1 color discharger. The permittee will conduct color
monitoring of instream stations (upstream, downstream) on a monthly basis during summer
season (April -October). The permittee will record whether a color plume was observed around
the outfall pipe during the monthly instream sampling events, and include that information on
the monthly discharge monitoring report. Effluent samples will be collected monthly for color
on a year-round basis. Color samples will be analyzed for ADMI color at natural pH. Effluent
samples will consist of 24-hour composites, while instream samples will be collected as grabs.
Samples will be analyzed by a state certified laboratory.
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.
A (2). Color Permitting Requirements for Tier 2 Facility
This facility has been classified as a Tier 2 color discharger. The permittee will conduct color
monitoring of instream stations (upstream, downstream) on a monthly basis during summer
season (April -October). The permittee will record whether a color plume was observed around
the outfall pipe during the monthly instream sampling events, and include that information on
the monthly discharge monitoring report. Effluent samples will be collected monthly for color
on a year-round basis. Color samples will be analyzed for ADMI color at natural pH. Effluent
samples will consist of 24-hour composites, while instream samples will be collected as grabs.
Samples will be analyzed by a state certified laboratory.
The permittee will prepare a Pollution Prevention/Best Management Practices (BMPs) report.
This report will address the potential for the facility to reduce effluent color by incorporating
pollution prevention measures and/or BMPs prior to treatment. This report could include an
evaluation of the dyeing process, looking at the potential for dye substitution, improving dyeing
efficiencies, etc. The report could also investigate whether any BMPs could be implemented
that would reduce the amount of color discharged to the treatment plant. The permittee could
do this work independently, or request voluntary assistance from the North Carolina Division
of Pollution Prevention and Environmental Assistance. The report will be submitted within 12
months of the permit effective date.
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.

A (3). Color Permitting Requirements for Tier 3 Facility
This facility has been classified as a Tier 3 color discharger. The permittee will conduct color
monitoring of instream stations (upstream, downstream) on a monthly basis during summer
season (April -October). The permittee will record whether a color plume was observed around
the outfall pipe during the monthly instream sampling events, and include that information on
the monthly discharge monitoring report. Effluent samples will be collected monthly for color
on a year-round basis. Color samples will be analyzed for ADMI color at natural pH. Effluent
samples will consist of 24-hour composites, while instream samples will be collected as grabs.
Samples will be analyzed by a state certified laboratory.
The permittee will prepare a Pollution Prevention/Best Management Practices (BMPs) report.
This report will address the potential for the facility to reduce effluent color by incorporating
pollution prevention measures and/or BMPs prior to treatment. This report could include an
evaluation of the dyeing process, looking at the potential for dye substitution, improving dyeing
efficiencies, etc. The report could also investigate whether any BMPs could be implemented
that would reduce the amount of color discharged to the treatment plant. The permittee could
do this work independently, or request voluntary assistance from the North Carolina Division
of Pollution Prevention and Environmental Assistance. The permittee will also prepare a Color
Reduction Study, which will involve an end -of -pipe treatment evaluation that develops cost
estimates for reducing influent color by 75% and 90%. Both reports will be submitted within
24 months of the permit effective date.
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.
A (4). Color Permitting Requirements for Tier 4 Facility
This facility has been classified as a Tier 4 color discharger. The permittee will conduct color
monitoring of instream stations (upstream, downstream) on a monthly basis during summer
season (April -October). The permittee will record whether a color plume was observed around
the outfall pipe during the monthly instream sampling events, and include that information on
the monthly discharge monitoring report. Influent and effluent samples will be collected
monthly for color on a year-round basis. Color samples will be analyzed for ADMI color at'
natural pH. Effluent samples will consist of 24-hour composites, while instream samples will
be collected as grabs. Influent samples can be collected as grab or composite samples.
Samples will be analyzed by a state certified laboratory.
The permittee has received color reduction limits that become effective by the permit effective
date. These limits require a 90% color reduction between influent and effluent samples.
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.

ATTACHMENT B
PUBLIC HEARING COMMENT

Re: Clark Creek Color/Dye Discharge
Subject: Re: Clark Creek Color/Dye Discharge
Date: Wed, 19 Sep 2001 19:50:03 EDT
From: [e-mail]
To: [e-mail]
In a message dated 09/18/2001 10:59:27 AM Eastern Daylight Time, [e-mail] writes:
In my previous response, I failed to ask for your name so that it may accompany your comments in the hearing
record. [e-mail] wrote:
Hello Mr. Blowe,
Mr. Michael Parker of the NCDENR suggested that I contact you regarding the hearing for color/dye standards
for Clark Creek, receiving stream for Delta Mills waste water discharge. I was unaware that there was a public
hearing for the proposed color reductions for Clark Creek. Our property in Lincolnton boarders Clark Creek. We
moved here 2 years ago and I was shocked to see the Creek run red/brown from what turned out to be industrial
dye from Delta Mills some 15 miles upstream. Neighbors told me horror stories of the decline of the water quality
and the reluctance of anyone to do something about it. I contacted Representative Daniel Barefoot
and Senator Hoyle about what appears to be a stream that is teated much like an open
sewer. I went to a public meeting on the restoration of the northern section of the Creek and
am doing water testing for the Extension Agency here in Lincoln County. We need to get the
word out to the folks in Lincoln County that you are taking comments on the reduction of
color/dye in Clark Creek. How much longer will you be taking comments? Can you extend
the hearing process to include a hearing in Lincolnton? After all we are the "people down
stream" that are most affected by what is put into the water upstream.
As a property owner on Clark Creek I absolutely believe that Delta Mills should be held to a 90% reduction of the
color/dye they discharge. How long have they been dumping enough dye into the Creek that it runs red all the way
to the South Fork? I wish they would spend an hour or so with me and walk along the Creek here in Lincolnton.
What they would see is a Creek void of fish, frogs and even snakes. An empty river except for the ruddy color from
their discharge. I have heard the argument that the dye is nontoxic, that it is like Kool-Aid. How much Kool-Aid
would you need to put in the water to run red for 15 miles? Even Kool-Aid may be toxic at that level of
concentration. If even if the dye is not toxic no one can deny that the color changes the character of the water. Do
not property owners have the right to have the waters flowing over their property to be "as water should be in
appearance?" Stay firm at a 90% color reduction. T! hey have dumped at 0% reduction for decades and have
benefited economically from the use of a public resource. Now it is time for them to be good neighbors and clean
up their mess. Thank you.
Headers
Return -Path: <[e-mail]>
Received: from rly-zc05.mx.aol.com (rly-zc05.mail.aol.com [172.31.33.5]) by air-zc02.mail.aol.com (v80.27) with
ESMTP id MAILINZC28-0918105927; Tue, 18 Sep 2001 10:59:27 -0400
Received: from scc078.its.state.nc.us (scc078.its.state.nc.us [149.168.194.67]) by rly-zc05.mx.aol.com (v80.21)
with ESMTP id MAILRELAYINZC52-0918105900; Tue, 18 Sep 2001 10:59:00 -0400
Received: from ncmail.net (204.211.169.12) by scc078.its.state.nc.us (5.5.031)
id 3B92373400079942 for [e-mail]; Tue, 18 Sep 2001 10:59:01 -0400
Message -ID: <[e-mail]>
Date: Tue, 18 Sep 2001 10:58:57 -0400
1 of 2 9!R/07 4:47 PM

Re: Clark Creek Color/Dye Discharge
From: Bobby Blowe <[e-mail]>
Organization: DENR/DWQ/Construction Grants and Loans Section
X-Mailer: Mozilla 4.7 [en] (Win95; I)
X-Accept-Language: en
MIME -Version: 1.0
To: [e-mail]
Subject: Re: Clark Creek Color/Dye Discharge
References: <158.120f835.28d8061 [e-mail]>
Content -Type: multipart/alternative;
boundary="------------5A71 ED385941085551634933"
John M. Waters, Lincolnton
2 of 2 2/R/02 4:47 PM

Clark Creek Color/Dye Discharge
Subject: Clark Creek Color/Dye Discharge
Date: Mon, 17 Sep 2001 22:06:18 EDT
From: [e-mail]
To: [e-mail]
CC: [e-mail]
Hello Mr. Blowe,
Mr. Michael Parker of the NCDENR suggested that I contact you regarding the hearing for color/dye standards for
Clark Creek, receiving stream for Delta Mills waste water discharge. I was unaware that there was a public hearing
for the proposed color reductions for Clark Creek. Our property in Lincolnton boarders Clark Creek. We moved here
2 years ago and I was shocked to see the Creek run red/brown from what turned out to be industrial dye from Delta
Mills some 15 miles upstream. Neighbors told me horror stories of the decline of the water quality and the reluctance
of anyone to do something about it.
I contacted Representative Daniel Barefoot and Senator Hoyle about what appears to be a stream that is teated
much like an open sewer. I went to a public meeting on the restoration of the northern section of the Creek and am
doing water testing for the Extension Agency here in Lincoln County. We need to get the word out to the folks in
Lincoln County that you are taking comments on the reduction of color/dye in Clark Creek. How much longer will you
be taking comments? Can you extend the hearing process to include a hearing in Lincolnton? After all we are the
"people down stream" that are most affected by what is put into the water upstream.
As a property owner on Clark Creek I absolutely believe that Delta Mills should be held to a 90% reduction of the
color/dye they discharge. How long have they been dumping enough dye into the Creek that it runs red all the way to
the South Fork? I wish they would spend an hour or so with me and walk along the Creek here in Lincolnton. What
they would see is a Creek void of fish, frogs and even snakes. An empty river except for the ruddy color from their
discharge. I have heard the argument that the dye is nontoxic, that it is like Kool-Aid. How much Kool-Aid would you
need to put in the water to run red for 15 miles? Even Kool-Aid may be toxic at that level of concentration. If even if
the dye is not toxic no one can deny that the color changes the character of the water. Do not property owners have
the right to have the waters flowing over their property to be "as water should be in appearance?"
Stay firm at a 90% color reduction. They have dumped at 0% reduction for decades and have benefited economically
from the use of a public resource. Now it is time for them to be good neighbors and clean up their mess. Thank you.
of 1 9/18/01 8:02 AM

DELTA
APPAREL, INCORPORATED
August 28, 2001
Via Hand Delivery
John Robert Blowe
Hearing Officer
Division of Water Quality
Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: NPDES Draft Permit
Permit No. NC0006190
Delta Apparel -Maiden Plant
Catawba County
J
Dear Mr. Blowe:
This letter follows up on our August 28, 2001 comments to Tom Belnick, NPDES
Unit, provided to you this morning. As you know, you and others from the NPDES Unit
visited our plant today to discuss our draft NPDES permit and to observe the current
conditions of our effluent at several points on Clark Creek. During our visit, Dave
Goodrich, Supervisor, NPDES Unit, recommended that we supplement our written
comments with additional materials, including technical data of our voluntary efforts to
reduce color in our effluent. Mr. Goodrich believed the additional data would be helpful to
the Department in considering and evaluating our comments concerning our objections to
the proposed color restrictions.
We therefore request that the hearing record remain open until Friday, September
14, 2001, so that we may submit the requested data.
Sincerely,
tz-f/
ene Hudgens
Plant Manager
100 W. Pine Street • P.O. Box 37 • Maiden, N.C. 28650 • [phone] • FAX [phone]
Change your shirt.

DELTA
APPAREL, INCORPORATED
inaliaSI
August 28, 2001
VIA HAND DELIVERY AND FACSIMILE (919-733-0719)
Mr. Tom Belnick
NPDES Unit
Division of Water Quality
North Carolina Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: NPDES Draft Permit
Permit No. NC0006190
Delta Apparel -Maiden Plant
Catawba County
Dear Mr. Belnick:
On behalf of Delta Apparel, Inc. ("Delta Apparel"), I am providing comments to the July
25, 2001 NPDES draft permit issued by the Division of Water Quality ("DWQ"), North Carolina
Department of Environment and Natural Resources ("DENR"), to our Maiden plant. We
respectfully request that these comments be made part of the record and considered prior to
issuance of our final permit. Specifically, Delta Apparel opposes the draft conditions relating to
the verification of color reduction of its effluent and the requirements for an Authorization to
Construct Permit.
At the outset, we should note, and DWQ acknowledges, that the color in Delta Apparel's
effluent is not and has not caused or resulted in a violation of any water quality standard or
adversely affected fish or aquatic life. The color of the effluent is simply a matter of aesthetics
and therefore is subjective and relative. In fact, DWQ said that: "The evaluation of color as an
aesthetic impact is difficult since it is a subjective determination. In addition, a host of actors,
such as hue, instream turbidity, suspended matter, dilution, light conditions, and downstream
access all play a part in determining when a color impact might be perceived by the public."
(DWQ June 5, 2001 NPDES Color Permitting Policy.) Despite the admitted uncertainties in this
area, Delta Apparel is committed to reducing color discharges in the South Fork Catawba River
Basin and more particularly, in its effluent discharge to Clark Creek. This commitment is
evidenced by the voluntary actions we have taken without a permit restriction.
In October 1999, we voluntarily participated in the formation of the South Fork Catawba
River Water Quality Alliance, Inc. ("Alliance") to study color in the South Fork Catawba River.
100 W. Pine Street • P.O. Box 37 • Maiden. N.C. 28650 • [phone] • FAX [phone]
Change your shirt.

Mr. Tom Belnick
August 28, 2001
Page 2
The Alliance is comprised of municipalities and industry. The DWQ requested that certain
criteria be considered in our study. We not only considered those criteria but additional factors
as well. As a result of the Alliance's study, DWQ developed its June 5, 2001 NPDES Color
Permitting Policy ("Color Policy"). The Color Policy establishes four tiers of action based on
DWQ's perception of the aesthetic color impacts to the receiving streams.
Prior to and simultaneous with participating in the color study with the Alliance, we
initiated a color reduction/removal program. First, we utilized a Clariant Corporation product but
it did not produce a significant color reduction. We then continued the reduction experiment
with other technologies. The subsequent experiments did not reduce color in the effluent the
degree we had hoped. We are currently conducting another study utilizing a color reducer from
Cytec Industries, Inc. This study involves the introduction of polymers and has thus far
produced positive results. We plan to continue to introduce polymers to reduce the color but also
study the effect, if any, this treatment has on other limitations in our permit.
As of yet, however, there is no available data that reliably demonstrates what minimum
degree of color removal at Delta Apparel is needed in order to improve the downstream aesthetic
water quality. This information is necessary so that Delta Apparel can optimize color removal
levels in relation to cost and technology.
Despite the lack of reliable and consistent data regarding color reduction, the draft permit
incorporates action contained in the Color Policy and demands that Delta Apparel achieve a 90%
color reduction between influent and effluent samples. This requirement is flawed for two
reasons.
First, it is our understanding that DWQ arrived at the 90% reduction standard based on its
perceived results of our voluntary reduction program. However, in all of our voluntary studies,
the company not once evaluated influent to effluent values. In fact, we compared one treated
effluent to untreated effluent utilizing the HACH DR 2000 Spetrophotometer Platinum Cobalt
color meter.
Second, the permit does not specify how we prove or quantify a 90% reduction. As
mentioned above, during our voluntary color reduction program, we analyzed the color in our
effluent utilizing the HACH DR 2000 Spetrophotometer Platinum Cobalt color meter. This
methodology was used in lieu of the American Dye Manufacturers Institute ("ADMI") testing
methodology. This distinction in methodology is important since DWQ developed the
restrictions in our permit from data developed under the ADMI methodology.
Simply put, the color restrictions contained in our draft permit are derived from the
DWQ Color Policy. In developing the Color Policy, DWQ relied exclusively on the data
compiled by the Alliance. The Alliance data was gathered utilizing ADMI methodology. Thus,

Mr. Tom Belnick
August 28, 2001
Page 3
the data contained in the Color Policy from which the restrictions in our draft permit were
developed have no correlation to the data developed under our voluntary program.
Further, the data developed by ADMI methodology has been criticized by DWQ as not
being representative of true color impact. As DWQ acknowledged in its Color Policy, ADMI
color measurements do not predict the potential for a color impact to the receiving stream. DWQ
said: "During data review, it was realized that ADMI color measurements do not always predict
the potential for a color impact." (DWQ Color Policy, page 2). According to DWQ's Color
Policy, a color plume with downstream aesthetic impact was observed at one facility on several
sampling events, although the effluent ADMI color was low and similar to upstream values.
DWQ therefore concluded that consideration of a numerical instream ADMI color standard
would be ineffective. DWQ concluded: "However, requiring some percentage reduction in
effluent color would help to minimize the size of the color plume. Conversely, some facilities
with greater colored effluent (e.g., Pharr Yarns and Yorkshire with summer averages of 844 and
3449 ADMI units, respectively) did not produce major instream color plumes, most likely due to
the effluent hue as well as the large dilution available. Therefore, in order to evaluate the data, it
was realized that no single criterion, but rather a combination of ADMI measurements,
photographs, and plume descriptions were needed to fully assess the instream color conditions."
(DWQ Color Policy, page 2).
The 90% reduction requirement is arbitrary. There is no data in the Color Policy to
support a percentage reduction standard. The Color Policy relied upon the Alliance report,
which reported ADMI units, not percentages. Nor has DWQ conducted any independent study
to conclude that the 90% reduction between influent and effluent samples is warranted,
achievable or feasible. Further, DWQ's statement in the draft permit that this 90% standard is
"technologically and economically feasible" has no basis in fact, especially since the results of
our voluntary color reduction program has never compared influent to effluent utilizing ADMI
technology.
Finally, Delta Apparel believes that a color requirement in its NPDES permit is
premature based upon its continued assessment and evaluation of data. In fact, the company's
most recent color testing was completed on August 15, 2001. Therefore, Delta Apparel
respectfully requests that it be allowed to continue its color reduction study with CYTEC and the
color restrictions be removed.
Sincerely,
ene Hudgens
Plant Manager/
N--.

ATTACHMENT C
CORRESPONDENCE WITH DELTA APPAREL, INC.

•DEC-28-01 FRI 01:53 PM WOMBLE CARLYLE
FAX NO. 336 721 3660 P. 01
IKON FAX TRANSMITTAL
NAME: Lori Hinnant
CLIENT/MATTER #: 41986.0003.8
TO: Gregory J. Thorpe, PhD
#PAGES:
12-28-01 PU 1 :49 RCVD
FAX# [phone]
ATTORNEY #: 1023
r ..
CONTACT PHONE: [phone] ;_
BRING THIS TRANSMITTAL TO IKON
FOR IKON USE ONLY
TIME STAMP:
SENT BY:
IKON Faxing Policy: "We strive to deliver incoming faxes within 15 minutes of arrival. We
rrserb'C the right to return outgoing faxes within one hour of transmittal."

*DEC-28-01 FRI 01:53 PM WOMBLE CARLYLE
:j
WOMBLE
CARi YLE
SANDRIDGE
RICE
Aego, r'' fNA1 LtM!tto
14 11111 I1Y c ObtrANv
200 West Second Strom
• Winston-Salun, NC 27101
Mailing Atldress:
Post office Drawer 84
Winston-Salem, NC 27102
7rleplu>tit: [phone]
Tax; (336) 72I-3660
\Vc t, Cite: www.wcsr.rgm
FAX NO. 336 721 3660 P. 02
December 28, 2001
via facsimile and U.S. mail
Gregory J. Thorpe, Ph.D.
Acting Director
Division of Water Quality
North Carolina Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
•
Re: Request far Additional Information
NPDES Draft Permit
Permit No. NC0006I90
Delta Apparel -Maiden Plant
Catawba County
Dear Mr. Thorpe:
This letter supplements our December 21, 2001 correspondence provided on behalf of Delta
Apparel, Inc. ("Delta") to the November 21, 2001 Request for Additional information from the
Division of Water Quali iy ("DWQ"). Again, Delta reiterates its objections to DWQ's proposed color
restrictions to Delta's effluent in the South Fork Catawba River.
Without waiving any objection to the use of the enclosed data, Delia provides the following
in response to the threat of enforcement in DWQ's November 21, 2001 letter:
• DWQ's request: "Amount of polymer added on a daily basis for the period May 1,
2001 through August 21, 2001." This information is attached as Exhibit A.
• DWQ's request; "Any associated influent/effluent color measurement of color
reduction [during May 1, 2001 through August 21, 2001.]" Any datanot previously
provided in Delta's September 21, 2001 response is attached as Exhibit B. The tests
represented by Exhibit B were conducted utilizing the HACH DR2000.
Spectrophotometer Platinum Cobalt color meter (Platinum Cobalt test), not ADMI
methodology.
• DWQ's request: "Results of all ADMI color measurements collector during the
Cytcc polymer trials to the present date to determine the color rcrnova] percentages
based on ADMI methods." This information is attached as Exhibit C.
( oaGIA / NORTH CAROLINA / SOUTH CAROLINA / VIRGINIA / WASHINGTON O C.

'DEC-28-01 FRI 01:53 PM WOMBLE CARLYLE
FAX NO. 336 721 3660
. P. 03
..a
WOMt.F IW
CARME
SANDRIDGF.
& RICE
ri..iG
Gregory J. Mope, Phh,I).
December 28, 2001 -
:.:. Page 2
As Delta previously commented to the color restrictions proposed in its draft NPDES
permit, at the present time, additional monitoring is needed to understand the process and effect of
color removal at Delta. Delta's voluntary tests have not been conducted throughout an entire year
to evaluate the effects of Delta's production changes, chronic toxicity impacts, or other external
factors. Therefore the enclosed data dots not support a pen -nit limitation relating to color. The
enclosed data, however, does demonstrate several points.
First, the data demonstrates that DWQ's reliance upon a comparison between influent and
effluent to regulate color ultimately runs counter to its goal to reduce effluent color. If a 90% color
reduction comparing influent to effluent is achieved (which occurs infrequently), it is due to the high
ADM color content of Delta's influent rather than a reduction in effluent color. Thus, a permit
limitation based upon an influent to effluent comparison creates an incentive to increase influent
color so that a higher percentage reduction is obtained. For example, Delta could increase its
Production of dyed textiles at the Maiden Plant to raise its influent ADMT color levels_ This course
of action may allow Delta to meet a percentage comparison limitation, but would do little to reduce
effluent color entering Clark Creek.
Second, the data shows that Delta's current means to address color -the Cytec polymers --
impacts Delta's ability to meet its chronic toxicity permit condition -a condition which may have
detrimental environmental impacts. As DWQ knows, Delta exceeded its chronic toxicity pewit
limit in August. Delta and Delta's consultant, Cylec, believe that the polymer usage in August
(which was in the 300 + gallon range) was related to the chronic toxicity exceedance. Delta does
not currently understand the relationship between polymer use and chronic toxicity and it therefore
needs additional time to monitor this relationship. (As you know, Delta's chronic toxicity is
measured quarterly.) Because DWQ will not waive violations of existing permit limitations during
Delta's attempts to study or meet a color limitation, the relationship between chronic toxicity and
polymer dosage requires more study to avoid any detrimental impacts upon Clark Creek.
Finally, the data demonstrates that the percentage of color removal fluctuates significantly
(notwithstanding Delta's maintenance of a relatively constant polymer dosage) due to the factors we
detailed in our September 21, 2001 correspondence. These factors consist of production variables,
such as dye and bleach use, and external factors such as water density, Delta anticipates that water
density will add increasing complexity to color removal in the coming winter months. At this time,
Delta does not understand the relationships among production and external factors and the
fluctuations in its color removal percentage. At a minimum, however, the data does not support a
90% limitation.
•
•

TEC-28-01 FRI 01:54 PM WOMBLE CARLYLE FAX NO. 336 721 3660
vvomm r
CAR YLE
SANDRll10E
IL: Mai
I'f 1C
Gregory J. Thorpe, Phi)::
December 28 2001 .141
.. ... Page 3
If any conclusion can be drawn from the limited data, it is that Delta's effluent consistently
meets 1200 ADMI when using the polymers. Delta's effluent, without polymer treatment, is
frequently as high as 6000 ADMI. A permit condition requiring a monthly effluent average of 1200 4 z
ADMI is supported by the data and represents as much as an 80% color reduction from untreated
levels. , .. y''r.Y
..I U.i N.YIL
Delta. has reiterated throughout the permitting process that it is committed to reducing its
effluent color. Delia voluntarily participated in the Alliance study and conducted numerous color
trials to find a technology capable of effective and consistent color removal. It was by Delta's
voluntary efforts and significant expense) that a technology--Cytec polymer, which appears viable, ..,• w..=
was discovered_ (The Cytec technology is expensive --the amount ofpolymcr dosage demonstrated
on Exhibit A would cost at least S500,000.GO annually. This is a significant expense to meet a
regulation that is based on aesthetics only and where no detrimental environmental impact exists.)
• V 1....JIp1{`
A proper limitation can only be derived by continued efforts by Delta to monitor color
reduction and open communication with DWQ to formulate a rational limitation which will not
disturb other permit conditions. Aesthetics should not be gained at the expense of other
environmental issues or at an expense that imposes a financial burden on the company.
Very truly yours,
foitic,il•vvvvoi),F
Lori P. Ilinnant

DEC-28-01 FRI 01:54 PM WOMBLE CARLYLE FAX NO. 336 721 3660
5e-lfr-L. APPLY` e-12 .±
P
D. O . • ... i..5 — l? s' G-4 �j.�, 7 — is ,
A_( 1.6 '7 Ge, ��.� a.._.._.:.r.... ► u 1,� ,,(a �..� & Ltd , ci. ,23
G.-o 1,0 r _ l2 ern. u ed
-1 q 0 T EL.t,/ c 1-.. - a 21 0-4„is_, - Ai,
. S! G-�, s _Alga 30 -- -30$
/2, -a — 30g Ct4s
-13.�.. �. i. 3 0-o. �s.�.. J u 1( ~ - — � ' I r�� _ -
SA. r `f - - 2 L r1 (64 (2. r.2L
ts _ _ 74% -
r
L t.N. L %. ` I )6.[•d 0 2- °� rl. ,��s • _
7.1
Y . •. � ;;;.7
Z..ck e..,2 3 "! 9 a-4.1s fir �1 �� �...h. _t'..t5 , . - _�...
•
1 .e ra.Js_ .�.r_ .� 61 4101SilLAL
.- to ......g 2.'7o (js
Is.
. r.
•
Vitt
11
- r.^.. rr .��^ `.�ar7i+�i.�� � �wwwllrTw.r✓ _ - vrY\.Y. Y _I..�,. '• ��
-' _.ram .., vat,
.:w.
�..�..1 _�. � z 7 -GIs, Q •----4:
ors,; !. ( V I I 6-4. t s . - ,�.�1 - �a _ �re t s ; - - • _ .
Adif_../..a- "-- /10 0..adics. . 2.0.....:_-__3.--
L/ ... .13_.- _..1(P ri _Gal, ... !_. ..r..0o 4 -o lc,
14......./ _. _ e... .. &a is r ... ....___Act P IL...._....-s,L2.6. 5.
w

•
'DEC-28-01 FRI 01:54 PM WOMBLE CARLYLE
FAX N0, 336 721 3660
#iacr-Lee_L_Cc.LbLe_aeda/ _44
.11
ti
p r�,r �•
_ •awl _
1 _4; _ 3
`mow w
.� --ES1g
�-- 01
••Ir••rr
7 AL
tk,...I,Ir80
--nn
rt
•
wl
•
: \w1
•
•
to
wdq
Sz5

'DEC-28-01 FRI 01:55 PM WOMBLE CARLYLE
_......��. •r 0.0
y
•
•
FAX N0. 336 721 3660
75`a76
A..,, A.
•
4 &..0 -.Jr_9276
�.^. 39.60 S 47Q ..�...
V
Ffp
• 0...•••• "A. ASA
1 w •w
7a t
.,..
rymeiloilile
w N.►MI.F
•
v7•
... ..•1A.iw.
•
gD45lo
.0.al1
0.6
•
•�111— 7(.0
..v—
. •

DEC-28-01 FRI 01:55 PM WOMBLE CARLYLE FAX NO. 336 721 3660
DRe5 14,141s
L E17 --n
4 5 Z. 7
•
Sl
Apo.•Nrt•if
..... �:r.S.ti.C.V
it-140.;..f.1
�YrrrWr-Yrr Ill/-\R1M I.1rA1�1• W�rrn.r
,244 ••�Y 1I1•rl-
_L Lam' -o I
t 1_-_g_r 1
.L�
- ��+rr .ref✓�� .-ram - �..�-.�w •
•••1.rV.fr•
•
' n ... .•f. rN' .1�
9S
•
.:.ly•liF !:
• }: k
- rFMh^
. tLto
1.- a 3 -6 1,r.r..... 3 3 I_.... .....MMI.
K-'* tCLIS .. •......
+�..rrw-•.r+--r.wrwrw w••► wow •-r-ea
• •- • ••••••w-
w.\rr•NAN •
mow.- •
•
••••• ..�.--r.•-r•.-ram -_
1 u..vi Gnw.itiw

11EC-28-01 FRI 01:55 PM WOMBLE CARLYLE
••-
..•
a.•
dig
•.r
•
FAX N0. 336 721 3660
Resift its'
i7AS t. 7f/a. -
ff. Vida
r+
- N f. 1.rl 6.
EfC I Piet
r.
• :
or•f •• .•Rb. `'VVf. •f•i•MOVI
M �*•1 i rr
gj.
•n:

DEC-28-01 FRI 01:55 PM WOMBLE CARLYLE
FAX NO. 336 721 3660
P. 10
alabs International
•• I>„t1 _' 11 . l • 1
INTERNATIONAL •pate:17-Dec-01
CLIENT:
Lab Order:
Project:
Lab ICE:
Analyses
Delta Apparel, Inc.
1-101120110
B01120110-04
Client Sample ID:
Tag Number:
Collection Begin:
Collection End/Date:
Matrix:
Influent Composite
12/3/2001 11:43:00 AM
12/4/2001 11:21:00 AM
WASTEWATER
Result
Limit Units Date Prepared Date Analyzed
COLOR, ADMI M2i 20E
Analyst: MSJ
Adjusled ADMI
3,130 25.0 12/6/2001 7:25:00 AM
12/6/2001 7:49:00 A
Adjusted p1.1 7.48
0
12/6/2091 7:25:00 AM
12/6/2001 7:49:00 A
lnitia1 ADM1
4,650 25.0 12/6/2001 7:25:00 AM
12/6/2001 7:49:00 A
Initial pH 9.85
0
12/6/2001 7:25.00 AM
12/6/2001 7:49:00 A
Crriilir•ntions: Simatabs - Uurlington
EPA Chemistry Lab ID: NC00137, Bioassay Lab ID; NC2721500
NC Chemistry: H85, Diomonitoring,:13002, Drinking Water:1i37743, #37738, Radiation License: B00I-904-0G
SCo °I atnry ID:1199042
1302 Belmont SireVcl • utnY ofno,0Ke
r1gnW.lar: 40018
Phone [phone] • FAX [phone]
Phone (888) 27d-5227
Eden g
370 W. Meadow Road • Eden, NC 27288
Phone [phone] • FAX [phone]

DEC-28-01 FRI 01:56 PM WOMBLE CARLYLE
FAX NO, 336 721 3660 P. 11
Sim alabs International
INTERNATIONAL Date:I7-Deb01
CLIENT: Delta Apparel, Inc.
Lab Order: B01120110
Project;
Lab 1D: B01120110-03
Analyses
•:
Client Sample ID: C_L.B % Litte JIB
Tag Number: Grab `I O)iC\'�
�
;(4,(
Collection Begin: 1 Ct.
Collection End/Date: 12I4t2001 8:06:00 AM
Matrix': WASTEWATER
Result Limit Units Date Prepared Date Analyzed
COLOR, ADMI M2120E
Analyst: MSJ
Adjusted ADMI 925 25.0 12/6/2001 7:25:00 AM 12/6/2001 7:49:00 A
Adjusted pH 7.52 0 12/6/2001 7:25:00 AM 12/6/2001 7:49:00 A
Initial ADMI 1,070 25.0 12/6/2001 7:25:00 AM 12/6/2001 7:49:00 A
Initial pH 8.55 0 12/6/2001 7:25:00 AM 12/6/2001 7:49:00 A
Certiticntions: Simalabs-'Burlington
EPA Chemistry Lab lfD: NC00137, Bioassay Lab ID: NC2721500
NC Chemistry: U S, lliomonitoring: 4002, Drinking Water: 437743, 437738, Radiation License: tl001-904-0G
L boratory ID: /199042
1302 Belmont Street • 33ur ing ti , '27. 1 J-59+l35cr 000016
Phone [phone] • FAX [phone]
Phone [phone]
Eden 7
370 W. Meadow Road • Eden, NC 27288
Phone [phone] • FAX [phone]

DEC-28-01 FRI 01:56 PM WOMBLE CARLYLE
•
FAX NO. 336 721 3660
P. 12
Simla labs International
INTERNAT/ONAL bate: 06 Dec-o l
Delta Apparel,
Lab Order; 801110627
Project:
Lab ID: B01110627-04
Analyses
COLOR, ADMI •
Adjusted ADMI ^~^
Adjusted p11
Initial AbMI
Initial pH
Result Limit Units
M2120 E
2,99Q
7.56
3,050
9.59
Client Sample 1D: Influent Composite
Tag Number:
Collection Begin:
Collection End/Date:
• Matrix:
11/26/2001 11:41:00 AM
11/27/2001 11136;00 AM
WASTEWATER
Date Prepared Date Analyzed
25.0 Analystt
11/29/2001 7:30:00 AM 11/29/2001 7:33:00
0
11/29/2001 7:30:00 AM 11/29/2001 7:33:00
25.0 11/29/2001 7:30:00 AM 11/29/2001 7:33:00
0 11/29/2001 7:30:00 AM 11/29/2001 7:33:00
Ccrtifjrntions: Simalabs- Burlington
E A ChctnisnyLab lb: NC00137. Bioassay Lab ID: NC2721500
NC Chmistry; #85, Blomonitoring: #002, Drinking Water: /l37743,#37738, Radiation Lictnsc: 4001-904.00,
SC IPtif�j�1�1,,0ratary ID: #99042
1302 Eldmont Strrel • tor T►46P, 1VC-117V4'YI93 °r /1000I8
Phone [phone] • FAX (336) S70-4698 35
Phone [phone]
Eden
370 W. Meadow Road • Eden, NC 272884
Phone (336) 623-Pent - rA V ..

DEC-28-01 FRI 01:56 PM WOMBLE CARLYLE
Simalabs International
CLIENT:
Lab Order:
Project:
Lab ID:
Analyses
Delta Apparel, Inc.
1301110627 .
D01110627-03 •
FAX NO. 336 721 3660
INTERNATIONAL Date: 06-Dec-01
Client Sample ID: C113 Grab
Tag Number:
Collection Eegin:
Collection EndlDate: 11/27/2001 9:01:00 AM
Matrix: WASTEWATER
Result Limit Unit
COLOR, ADMI
Adjusted ADMI
Adjusted pH
Initial AbMI
Initial pH
M2120E
867 25.0
s Date Prepared Date Analyzed
Analyst: MSJ
11/29/2001 7:30:00 AM 11/29/2001 7:33:00
7.08 0
827 25.0
7.51 0
11/29/2001 7:30:00 AM 11/29/2001 7:3100
11/29/2001 7:30:00 AM 11/29/2001 7:33:00
CC) tit -cations: Simu1abs - Burlington
EPA Chemistry Lab ID: t3C00137, Bioassay Lab ID: NC2721500
NC Chemistry:1/85, Biomonitoring: #002, Drinking Water: 437743,
SCD 1.1.aratory ID: #99042
hu19Cr: 0o0181302 Belmont Street • ng on, NL. )dOSVO 72-635
Phone (336) 570,4661 • FAX [phone]
11/29/2001 7:30:00 AM 11/29/2001 7:33:00
#37738, Radiation License:1f001-904.0G
Eden 3
370 W. Meadow Road • Eden, NC 27288
onn• .. r►v

`DEC-28-01 FRI 01:56 PM WOMBLE CARLYLE
FAX NO, 336 721 3660
P. 14
Sintalabs International
CLIENT:
Lab Order:
Project:
Lab ID:
Analyses
=; ':„ I
INTERNATIONAL Date:06-Dec-OJ
Delta Apparel, Inc.
I10111051I
1301110511-04
Client Sample ID:
Tag Number:
Collection Begin:
Collection End/Date:
Matrix:
Result Limit Units Date Prepared Date Analyzed
COLOR, ADM: M2120i=
Adjusted ADM! 9,570
25.0
Adjusted pH
Initial ADMI
Initial pHT
7.57
0
10,40]
10.2
25.0
0
Crrti1ica1ions: Simalabs-Burlington
Influent
Composite
11/19/2001 11:28:90 AM
11/20/2001 I1:38:00 AM
WASTEWATER
Analyst: MSJ
11/21/2001 4:15:00 PM 11/21/2001 4:40:00
11/21/2001 4:15:00 PM 11/21/2001 4:40:00
11/21/2001 4:15:00 PM 11/21/2001 4:40:00
11/21/2001 4:15:00 PM 11/21/2001 4:40:00
FPA.Chcrtustiy Lab ID: NC00137, Biaas3ay Lab II): NC2721500
NC Chemistry: 1185, Biomonitoring: #002, Drinking Wztcr: #37743, /i37739, Radiation License; #001-904-0G
Si IlaboS,,ratory 11): #99042
1302 Belmont Strce(t•u{r7�ngoneNL 2917`g93°r. i/60oi8
Phone [phone] • FAX [phone]
Plum,• ea Dot Ii.
370 W. Meadow Road • Eden' NC 27288
l�hnn. /2241
Eden f

`DEC-28-01 FRI 01:57 PM WOMBLE CARLYLE
FAX NO, 336 721 3660
Sunalalbs International
INTERNATIONAL Date: 06-Dec-01
CLIENT: Delta Apparel, Inc,
Lab Order: 1301 1 10511
Project:
Lab : 1301110S11-03
Analyses
Result
Client Sample ID: CLB
Tag Number: Grab
.Collection Begin:
Collection End/Date: 11/20/200I 9:46:00 AM
Matrix: WASTEWATER
Limit Units bate prepared
COLOR, ADMI M2120E
Adjusted ADMI 785
— 25.0
Adjusted pli 7-44
0
Initial ADMI
Initial pl-I
Date Analyzed
/ 1/21/2001 4:15:00 PM
11/21/2001 4:15:00 PM
744 25.0
8.00 0
Crrtitcaiions: Simatabs -Burlington
EPA Chemistry Lab ID; NC00137, B ioassay Lab ID: NC2721500
NC Chemistry: 485, Biomonitoring: #003, Drinking Water: 437743, 437738, Radiation License: 4001.904-00
St ahoratory ID: 499042
1302 Belmont Srreeiie : •• 9B:4000ppbb1DD rink•n WatWater:100018
��--
ur ington, NC: 272151-6935
Phone [phone] • FAX [phone]
P rlAnr (ARR1 'JY. c-.,-.
11/21/2001 4:15:00 PM
' 11/21/2001 4:15:00 PM
Analyst: MSJ
11/21/2001 4:40:00
11/21/2001 4;40:00
11/21/2001 4:40:00
11/21/2001 4:40:00
Eden 3
370 W. Meadow Road • Eden NC 27288
Pltnnr I4141 412 on-. ri'r

bEC-28-01 FRI 01:57 PM WOMBLE CARLYLE
Simalabs International
CLIENT: Delta Apparel, Inc.
Lab Order: B01110343
Project:
Lab fU:
Ana 1yse4
B01110343-03
•
FAX NO. 336 721 3660
1 N T E R N A T I.O N A L
Date: 20 Noy_DI
Client Sample ID; Influent Composite
Tag Number:
Collection Begin: 11/12/2001 11:26.00 AM
Collection End/Date: 11/13/2001 11:38;00 AM
Matrix: WASTEWATER
Date Prepared Date Analyzed
Result Limit Units
COLOR, ADMI
Adjusted ADMI
Adjusted pH
Initial ADMI
Initial pH
M2120E=
4,050 . 25.0
7.40 0 11/15/2001 10:30:00 A 11/15/2001 10:40:00
_ . 4,140 25.0
11/15/2001 10:30:00 A 11/15/2001 10:40:00
9.97 0 —'
11/15/200110:30:00A 11/15/2001 10:40:00
Anal st: MSJ
11115/2001 10:30:00 A 11/15/2001 10;40:00
Certifications: Simalabs. Eturlington
/iPA Chemistry Lab ID: NC00137, Bioassay Lab ID:14C2721500
INC Chemistry: MSS, Biomonitnring:11002; Drinking Wier. 137743, f/37738, Radiation License:11001-904-0G
Stu hqigelww ID:199042
1302 Belmont Strain• KY: iVile 123)1415i M3tcr: 11000I8
Phone [phone] • PAX [phone]
Phone [phone]
Eden
370 W. Meadow Road • Eden, NC 272887
Phone (3 6,s 1,a... Ao�1 ra._ --

`DEC-28-01 FRI 01:57 PM WOMBLE CARLYLE
Sitnalabs International
CLINT;C Delta Apparel, Inc.
Lab Order: B01110343
Project:
Lab ID:
Analyses
B01110343-04
COLOR. ADMI
Adjusted ADM!
Adjusted pH
FAX NO. 336 721 3660
INTERNATIONAL Date:20-Nov-01
Result Limit Units
M2120E
566 25.0
7.50
Initial ADMI 662
Initial pH
8.08
0
Client Sample 17): CLB Grab
Tag Number:
Collection Begin:
Collection End/Date: 11/13/2001 10:40:00 AM
Matrix: WASTEWATER
Date Prepared Date Analyzed
•
Analyst; MSJ
11/15/2001 10:30:00 A 11/15/2001 10:40:00
11/15/2001 10:30:00 A 11/15/2001 10:40:00
25.0 11/15/2001 10:30:00 A 11/15/2001 10:40:00
0 11/15/2001 10;30:00 A 11/15/2001 10:40:00
Certifrerttin ns: Simalabs- Burlington
EPA Chemistry Lab ID: NC00137, Binmsay Lab ID: NC2721500
NC Chcmistry: //85, Biomonitoring: //002, Drinking Water. i137743, #37738, Radiation License: !/001-904.00
SCl3ttktifff ' I)7: i/99042
1302 Belmont Strop. %W 1 OP j21 rI,1sjug cr:;9000I8
Phone [phone] • FAX [phone]
Phone lARA1 17.4.c1-17
• Eden
370 W- Meadow Road • Eden, NC 272838
Phone [phone] • PAY /a aa\ <.%) en.+n

.DEC-28-01 FRI 01:57 PM WOMBLE CARLYLE
FAX NO. 336 721 3660
P. 18
r
Sintalabs International
•
CLI ENT:
Lab Order:
Project:
Lab ID:
Anllyses
--T-
• I.td',T•E R.:1\1A TI ON•A L
Delta Apparel, Inc.
L01110140
130111010-04
COLOR, ADMI
Adjueted ADMI
Adjusted pH
Initial ADMI
Initial pH
Ccrt iicatinny: Slmalabs - llui lington
EPA (•hemisrry Lab ID: NCO.' 37; Ftioais I:6Ip: NC272150p •, -
Cie IDS#99042 rutdrmg: ii002; t)rinl�ing Way:* it3774I, r 3773R, Radiation incense; /100I�-904-0G' .
1302 .:•_
Belmont StrcY6e `BFYif1 oriS?0)tP0?, 2'1?3D$ ! ilaool'8 Eden
Phone [phone]• • FAX [phone] W. Meadow Roan •• _ Eden, NC27,4 ,'
• Phone [phone]a17 • • ' • Phone [phone] • KAX ro��l �,;
Date: I7-Nav-Ol
Cent Sample ID: Influent
Tat; Number: Composite • • •
: Collection Begin: 1 I/6/2001 1 ] :18:00 AM
Collection-Lrtd/Date: 11I7/2001 10:40:00 AM
Matrix,; ,WASTEWAT]~R.
"Bate I repared • D" to
'nlzd:
z,550 25:0 • Arialysi:
11/e/a001 7:30:OO.AM II/8/20.01 7:48:00 A
7.71 • . 0 • •t1i81,
001 7:30:00 AM 11/8/2001 7:48:00 A
2.250 25.0
11/8/2001 7:30:00 AM 11/8/2001 7:48:00 A
9.79 0 11/8/2001 7:30:00 AM 11/8/2001 7;48;00 A ,
•
•

DEC-28-01 FRI 01:58 PM WOMBLE CARLYLE
FAX NO. 336 721 3660
P. 19
Sirtialabs Internatio
CLIENT: Delta App
Lab Order:
Project:
Lab ID;
'Analyses Result Limit Units
Date Prepared . Date Analyzed
COLOR, ADMI _ __r�M2120�`
Adjusted ADMI - Analyst: MSJ
�^ �- �8. 25.6. •- , 11/8/2001 7:30:00 AM , •11 /8/2001 7:48:00 A '
Adjusted pH ~ 7.70 0 ~�
Initial led P 11/8/2001 7:30:00 AM • 11/8/2Q01 7:48:00 A
1,210 _ ' 25.0 . ��� • 11/8/2001 7:3D`_DO . • i 1/8' .. 7=48:00 A
11/8/2001 7:30:00 AM, 11/3(2601 7:d8:00 A - -..
130111014
e,
130111014 0-03
I N T.E R.1v A-7•,1 a 14.A L
Ewe: 17 Nov OI
] Inc. '.,
Client Sample ID: C.L.$,- - .
.• Tag Number: • Grab
Collection Begin: i
Collection EndiDate; 11/7/2001 9:05:00 Alvl -
Matriz: WASTEWATER
Initial pH
Certifications: Simalabs-Burlington '
EPA ChemistryLab ID: NC00137, 'Bioassay �sbID; NC2721500
NC Chemistry: #85, Bion onitorittg: 1002, Drinking Water: #37743,
S43tt.fi jy ID: #99042
1302 Belmont StreYito V(i4{� 0 -t k g ; 00018
Phone [phone] • FAX (336} 570-4694
Phone [phone] , • • • -
•
•
167738, Ttadiarion License: 4001-904-0G
Eden .
370 W. Meadow Road • Eden, NC 27288?
Phone [phone] f • FAX (3361 6);-Stt7o

`DEC-28-01 FRI 01:58 PM WOMBLE CARLYLE
FAX NO. 336 721 3660
I •.� Order:
M:
•z1alalas International IN T E R N A T l 0• N A
L Date: 07 Nov-01
IP;N'T; Delta Apparel, Inc.
B01100748 Client Sample ID; Influent
801100748-04
r FOR, ADMI
: rsted ADMI
:rusted pH
`�al ADMI 5,770
25.0
9.77 0
Result Limit Units
— M2120E
5,550 25.0
L. J: t'• cations: Simalabs . Rarlmgton
EPA Chemistry Lab ID: NC00137, Bioassay Lab ID; NC2721500
NC TC� Challis-try:118S, Biomnnitoring: 11002, Drinking Water: t137743,
nurf.Maz Q{N ID: 1199042
1 Q2 c"_; -±ont SireKte $ IRE,A9Q 12}hy i,f1 'Sttr;I/00018
[phone] • FAX [phone]
Pitnne /RAQ1 774
7.54
0
Tag Number; Composite
Collection Begin: 10,29/2001 1 I :46:00 AM
Collection End/Date: 10/30/2001 11:21;00 AM
Matrix: WASTEWATER
Date prepare Date ea Analyzed
Analyst: MSJ
11/1/2001 8:35:00 AM 11/1/2001 8:48:00 A_
11/1/2001 835:00 AM 11/1/2001 8:48:00 A
11/1/2001 8;35:00 AM 11/1/2001
1/1/2001 8:48:00 A
8:35:0011/1/200111/1/2001 8:48:00 A
#37738, Radiation I,icentc; #00I-901.0G
Eden
y370 W. Meadow Road • Eden, NC 272884

DEC-28-01 FRI 01:58 PM WOMBLE CARLYLE
FAX NO. 336 721 3660
P. 21
Sinialabs International
CLIENT: Delta Apparel, Inc.
Lab Order: 1301 I00748
Project:
Lab ID:
Analyses
B01100748-03
COLOR, ADM1
Adjusted ADM!
Adjusted pH�� 7.58 0
Initial ADMI 496 25.0
INTERNATIONAL
Initial pH
Certifications:
Result Limit Units
M2120E
446 25.0 •
Date: 07 Nov-OJ
Client Sample 1D: C.L.B.
Tag Number: Grab
Collection Begin:
Collection End/Date: 10/30/2001 9:18A0 AM
Matrix: WASTEWATER
Date Prepared bate Analyzed
Analjrst: MSJ
11/1/2001 8:35:00 AM 11/1/2001.8:48:00 A
11/1/2001 825:00 AM 11/1/2001 8:48:00 A
11/1/2001 8:35:00 AM 11/1/2001 8:48:00 A
11/1/2001 8:35:00 AM 11/1/2001 8:445:00 A
7.95
Sim slabs -Burlington
1?.PA Chemistry Lib 11): N000117, Bioassay Lab ID: NC2721500
NC Chemistry:1/85, Biomonitoring: #002, Thinking Water, #37743,
1 302 Belmont StreS +' V�� IDo� {J0f 115_SM ;
> h�o I n t.Y #OOOI S
Phone [phone] • FAX [phone]
Pllnn, 04aat 17.4
0
#37738, Radiation License: a001-904-00
Eden
370 W Meadow Road • Eden, NC 272883
Phone (3;Al r„ v ,,,., --- ---

'DEC-28-01 FRI 01:58 PM WOMBLE CARLYLE
FAX NO. 336 721 3660
P. 22
COLOR, ADMI
Adjusted ADMI
Adjustod pl I�y
In(tint ADMI
Inilial pN
Sirnalabs
Ci,Ylv[Y'1':
Lab Order;
Project:
Lab ID:
Analyses
Result Limit units bate prepared Date Analyzed
International
Delta Apparel, Inc.
•130110057S
II01100578-03
INTERNATIONAL
Date: OS Nov-01
Client Samp1e Ill: Influent omposite
Tag Number:
Collection Begin: 10/22/2001 11:38:00 AM
Collection End/Date: I0/23/2001 11:09:00 AM
Matrix: WASTEWATER
M2120E 4) ��..•
3,950 25.0 25 0 ��„ Analyst: MSJ
7.47 10/24/2001 4:00:00 PM 10/24/2001 4:43:00
0 10/24/2001 4:00:00 PM 10/24/2001 4:43:00
3,150 25.0
10/24/2001 4:00:00 PM 10/24/2001 4:43:00
8.54 0
10/24/2001 4:00:00 PM 10/24/2001 4:43:00
Certifications: Simalalu-Burlington
EPA Cl cintsiry Lab ID: NC00I37, Bioassay Lab ID: NC2721500
NC Chemistry: #85, Bioannitoring: #002, Drinking Water: It37743,
SCTIuhiliorrly 1D: #99042
1302 Belmont StreYia• t i c.A0W12IjryrilringM3tcr:1i00018
Phone [phone] • FAX [phone]
Phone [phone]
#37738, Radiation License: #001-904.0(1
Eden
370 W. Meadow Road • Eden, NC 272887
Phonc (336) 67.3.nn, 1 • 'PAYr

DEC-28-01 FRI 01:59 PM WOMBLE CARLYLE
FAX NO. 336 721 3660
P. 23
Siilnalahs International 1 N TERNA TIONA L
Date: 05-Nov_01
Client Sample ID: C B Grab
Tag Number;
Collection Begin:
Collection End/Date: 10/23/2001 8:09:00 AM
Analyses Matrix: WAST)✓WATBR
Result _ Limit ,Units —
CLIENT: nelta Apparel,
Pparel, Inc.
Lab Order:
Project:
Lab ID:
COLOR, ADM;
Adjustod ADM! - M2124}
- ---��. 615 �$ 0 Analyst: MSJ
Adju:;ted 0 10/24/2001 4:00:00 10/24/2001 4:43:00
7480
Initial ADp
516 10/24/2001 4:00:00 PM 10/24/2001 4:43:00
25.0
10/24/2001 4:00:00 PM 10/24/2001 4:43:00
B01100578
B01100578-04
Initial phl
8.05 0
10/24/2001 4.00:00 PM 10/24/2001 4:43:00
Date Prepared DatcAna_
L~Ecl
Cerfificn lions: Siinrlabs - Burlington ~ ~ --_ ___.__
EPA Chemistry Lab r1): NC0o137, Bioassay Lab ID: NC277 1500
NC Chemistry: #85, )3iofrtonitdring; #002, Drinking Water #37743, #37138, Radiation License: #001-904-0G
S urhn1 RborCrtory ID:1199042
�N
1302 Belmont Strc f on
RY ii\ 0 i,14n9 riVPiggi'": Ft000I8 Eden
Phone [phone] • FAX [phone] W. Meadow Road •
Aden, NC 272888
Phone (8a ) 274-5227 Phone (3361 OR-R4l t . tav i,.,.. _.

DEC-28-01 FRI 01:59 PM WOMBLE CARLYLE
FAX NO. 336 721 3660
P. 25
Simalabs International
INTERNATIONAL bate: 27-Oc1-01
CLIENT: Delta Apparel, Inc.
Lab Order: 1301100434
Project:
Lab 11D: R01100434-03
Analyses
COLOk, ADM!
Adjusted ADM!
Adjusted pH
Initial AaMr��~�
Initial pH
Result
Limit Units
`7.00 0 _ 10/17/2001 2:15:00 PM 10/17/2001 6:10:00
5'70 25.0 0/17/2001 2:15:00 PM 10/17/2001 6:10:00
_ _
7.55 0
Client Sample ID: CLB
Tag Number: Grab
Collection Begin:
Collection End/Date: 10/16/2001 11:00:00 AM
Matrix: WASTEWATER
Date Prepared Date Analyzed
Analyst: AR,._.
M2120E(4)
580 25.0 10/17/2001 2:15:00 PM 10/17/2001 6:10:00
Certitication.a: SimMabs • Burtingtoq
EPA Chemistry Lab ID: NC.:00137, )iioassayLab 1D: NC2721500
NC Chemistry: ff85, Bioninnitaring: ii002, Drinking Wata: i137743, #37738, Radiation License: i1001-904-0G
SC Laboratory CO: i/99042
drli9 r ioo0181302 Delmont Street • Bun'gton NC aDrinking5
Phonic (336) 570.46 51 • 'FAX [phone]
Phone [phone]
10/17/2001 2:15:00 PM 10/17/2001 6:10:00
Eden 3
370 W. Meadow Road • Eden, NC 27288
Phone [phone] • FAX [phone]g

DEC-28-01 FRI 01:59 PM WOMBLE CARLYLE
FAX NO. 336 721 3660
P, 26
Lab Order:
Project:
Lab ID:
Analyses
Sinialabs International I N T E R N A T I
CLIENT: A L pate: 18-Oct-01
Apparel, Inc, `�`— �� -
A01100264 Client Sample ID: Influent Composite ^�
Tag Number;
Collection Begin: 10/8/2001 1.1;18:00 AM
Collection End/Date: 10/9/2001 11:38:00 AM
-�— —�_` Matrix: WASTEWATER
Result Limit Units .__.
PreparedDate Analyzed
B01100264-04
COLOR, ADM!
Adjusted ADMI
Adjusted pH
Initial ADMI
` — 5,190
Initial pH
N.
--•.�__ M2120E(4L_
5,260 25.0
� 25,0 10/10/2001 2:45:00 PM 10/10/2001 3:09:00
7.5d 0 _—_—_—_
10/10/2001 2:45:00 PM 10/10/2001 3:09:00 _
—� —` 25.0 10/10/2001 2:45:00 PM 10/10/2001 3:09:00
10/10/2001.2:45:00 PM 10/10/2001 3:09:00
Date
Certifications: Sims labs -Iiurtingtot���
EPA Chemistry Lb ID: NC00 ] 37, Bioassay Lab ID: NC2721500
NC Chemistry: tIBS, Biomouitoring: ft002, Drinking Water //37743,
SC Laboratory ID: //99042
V.k] 302 I3elrnont $free uNWt. $ 'one 61, Drinkin . Watrr: II00018
Phone [phone] • FAX [phone]C 935
Phone [phone]_517 .
Analyst: MSJ
U37738, Radiation License: /t00]-9Q4.013
Eden
370 W. Meadow Road • Eden, NC 27288
Phone lsx4talo _,

`DEC-28-01 FRI 01:59 PM WOMBLE CARLYLE
FAX NO. 336 721 3660
P. 27
Simalabs international
Lab Order:
Project:
Lab I1): BO1100264-03
INTERNATIONAL
CLIENT: Delta
Apparel, inc.
/301100264
Analyses
Result Limit Units
CO[.GR: ADMI
M_ 2 E(4
503 25.0
7.74 0
Adjusted ADM
•
Adjusted pH
initialADMI
546 25.0
Initial pH
t
8,04 • 0
Date: 18-Oct- 01
Client Sample ID: CLB
Tag Number; Grab
Collection Begin:
Collection End/Date: 10/9/2001 9:09:00 AM
Matrix: WASTEWATER
Date Prepared Date Analyzed
Anal st; MSJ
10� /10/2001 2:45:00 PM 10/10/2001 3:09:00
10/10/2001 2:45:00 PM 10/10/2001 3:09:00
10/10/2001 2:45:00 PM 10/10/2001 3:09;00
10/10/2001 2:45:00 PM 10/10/2001 3:09:00
Certifications; Sirnalabs - )turlington
EPA Chemistry Lab ID; NCQ0137, Bioasany Lab ED: NC2721500
NC Chemistry: /185,13ieroonitoring: y002,1)rinking Water:1137743, *377313, Radiation License: /l001-904-0G
S boratory 11):1/99042
1302 Belmont Street • tt- s #00041 Dr;r n Water tinnni8
---
Phone [phone]blt.tngton, Nu 27��-�9��
FAX [phone]
Phone [phone]
Eden
370 W. Meadow Road • Eden, NC 272883
Phone (336) 623-R9, f . M1 v ice' -' _ ___-

bEC-28-01 FRI 02:00 PM WOMBLE CARLYLE
FAX NO. 336 721 3660
P. 28
Simalabs International
CLI ENT:
Lab Order:
Project:
Lab ID: D01100018-04
Delta Apparel, Inc.
1301100078
INTERNATIONAL Date:18-Ocr-DI
Analyses
Client Sample ID:
Tag Number:
Collection Begin:
Collection Eltll/Dale:
Matrix:
Influent
Composite
10/1/2001 1.1:30:00 AM
10/2/2001 11:36:00 AM
WASTE WA'1 ER
Result s Limit Units
COLOR, ADM! M2120E(4)
Adjusted ADM!
Adjusted pH
6,840
25.0
7.47 0
InitialADMI
Initial pH
7,730 25.0
10.2 0
Date Prepared Date Analyzed
10/4/2001 8:30:00 AM
Analyst: MSJ
10/4/2001 8:42:00 A
10/4/2001 8:30:00 AM
10/4/2001 8:30:00 AM
10/4/2001 8:30:00 AM
10/4/2001 8:42:00 A
10/4/2001 8:42:00 A
10/4/2001 8:42:00 A
Cer1;11catiomg: Simalabs -Burlington
EPA C:hcmistry Iab ID: N000137, Bioassay Lab ID: NC2721500
NC Chemistry:1185, Bionaonitoring; N002, Drinking Water: 4:7743, 437738, Radiation License: 4001-904.00
SC Laboratory ID: #99042
Au4Wil: #000061, Drinki ig Water: #000I 8
1302 Belmont Street • Burlington, NC 27215.6935
Phone (336) 570,4661 • FAX [phone]
r11
Eden 5
370 W. Meadow Road • Eden, NC 27288
Phone [phone]t • FAY f2341 41Q_cR71)

4DEC-28-01 FRI 02:00 PM WOMBLE CARLYLE
•
FAX NO. 336 721 3660
Simalabs international
CLIENT: Delta Apparel, Inc. Client Sample ID: CLB
Lab Order: 801100078 Tag Number: Grab
Project: Collection Begin:
Lab ID: B01100078-03 Collection End/Date: 10/2/2001 11:04:00 AM
Matrix: WASTEWATER
` ; i j't'• ! 1. r.> 4
INTERNATIONAL Date:18-Oct-01
Analyses
Result Limit Units Date Prepared Date Analyzed
COLOR ADMI M2120EJ4)
Adjusted ADMI 700 25.0
Analyst: MSJ
10/4/2001 8:30:00 AM 10/4/200i 8:42:00 A
Adjusted pH 7.59 0 10/4/2001 8:30:00 AM 10/4/2001 B:42:00 A
Initial ADMI 775 25.0 1014/2001 8:30:00 AM 10/4/2001 8:42:00 A
Initial pH 7.96
0 10/4/2001 8:30:00 AM 10/4/2001 8:42:00 A
Certifications: Sint2labs - Burlington
EPA Chcmimy Lab fir: NC00137, Bioassay lab ID: NC272] 500
NC Chemistry:4115, Biomonitorinl;: #002, Drinking Water. 437743. #37733, Radiation License: #001-904-0G
SC Laboratory ID: #99042
V 1•t51i f913 / 00006l, Drinking Water: A000]8 Eden 4
1302 Belmont Street • Burlington, NC 27215-6935 370 W. Meadow Road • Eden, NC 27288
Phone [phone] • FAX [phone] Phone [phone] • FAX [phone]

`DEC-28-01 FRI 02:00 PM WOMBLE CARLYLE
FAX NO. 336 721 3660
P, 30
Adjusted pH
Initial ADMI
Initial pH
Sirnalabs International
CLIENT: Delta Apparel, Inc.
Lab Order: n0I090649
'Project:
Lab ID: 1301090649-04
Analyses
COLOR, ADM'
INTERNATIONAL
Date: 08-Oct-01
Client Sample ID: Influent Composite
Tag Number:
Collection Begin; 9/24/2001 6:36:00 AM
Collection ]v,nd/Date: 9/25/2001 6:09:00 AM
Matrix; WASTEWATER
Result Limit Units Date Prepared Date Analyzed
M212M4)
Adjusted ADM/
— -- 6,070 25.0
Certifications: Simalabs-Burlington
_ Analyst; MSJ
9/26/200/ 4:40:00 PM 9/26/2001 4:45:00 P
7.53 0 926/2001 4:40:00 PM 9/2
6/2001 4:45:00 P
6.040 25.0 �----•----...
9/26/2001 4:40:00 PM 9/26/2001 4:45:00 P
9.74 0 9/26/2001 4:40:00 PM 9/26/2001 4:45:00 P
EPA Chemistry Lola ID: NC00137, Bioassay Lab ID: NC272150(
NC Chemistry: #BS, Biomonitoring: 4002, Drinking Water. 1137 '43, #37738, Radiation License: ROO I_904-0G
5C Laboratory ID: /1990.12
VA SWCB ID: /i000067, Drinking Water #000I8
1302 Belmont Street, Burlington, NC 27215-6935 T11.336.570.4661 MAX 336.570.40R
5

DEC-28-01 FRI 02:00 PM WOMBLE CARLYLE
Simalabs International
CLIENT:
Lab Order:x
Project:
Lab ID:
Analyses
FAX NO. 336 721 3660
INTERNATIONAL Date: 08-Oct--01
Delta Apparel, Inc.
}301090649
80 1090649-05
COLOR, ADM!
Adjusted ADMI
Adjusted pH
Initial ADM1
initial pH
Result
Certifications:
Slmalabs - Burlington
P. 31
Analyst: MSJ
844 25.0 9/26/2001 4:40:00 PM 9/26/2001 4:45:00 P
7.41 0 9/26/2001 4:40;00 PM 9/26/2001 4:45:00 P
909 25.0 9/26/2001 4:40:00 PM 9/26/2001 4:45;00 P
Client Sample ID: CL,I3
Tag Number:
Collection Begin:
Collection l;nd/Date, 9/25/2001 7:29:00 AM
Matrix: WASTEWATER
Limit Units Date Prepared Date Analyzed
M2120E(4)
8.7r 0 9/26/2001 4:40:00 PM 9/26/2001 4:45:00 P
EPA Chcmishy Lab ID: NC00137, Bioassay Lib ID; NC2721500
NC Chemistry: i185, Biomonitoring:4002, DrinkingWater:I/37743, #37738, Radiation License: #001-904-00
SC Laboratory I0: #94042
VA SWCB ID: #000061, Drinking Water. ii000I8
1302 Delmont Street, Burlington, NC 27215-6935 TEL.[phone] FAX [phone]
6

'DEC-28-01 FRI 02:01 PM WOMBLE CARLYLE
FAX NO. 336 721 3660
•
•
Simalabs
International
CLIENT:
Lab Order:
Project:
Lab 1D:
Analyses
INTERNATIONAL Date:ll-Oct-01
Delta Apparel, Inc.
B01090416
• B01090416-04
Client Sample ID:
Tag Number:
Collection Begin:
Collection End/Date:
Matrix:
Influent
Composite
9/17/2001 6:28:00 AM
9/1 g/2001 6:05:00 AM
WASTEWATER
COLOR, ADMI
Adjusted ADMI
Adjusted pH
Initial ADMI
Initial p11
Certifications;
Result
Limit Units
M2120E(dl
3,860 25.0
7.58 0
4,510 25.0
9.16 0
Date Prepared Date Analyzed
9/19/2001 3:15:00 PM
9/19/2001 3:15:00 PM
9/19/2001 3:15:00 PM
9/19/2001 3:15:00 PM
Analyst: MSJ
9/19/2001 3:36:00 P
9/19/2001 3:36:00 P
9/19/2001 3:36:00 P
9/19/2001 3:36:00 P
Simalabs - Burlington
E 'A Chemistry Lab ID: NC00137, ioassay Lab lb: 1-4C2721500
NC Chemistry 485, Biomoniroring: //002, Drinking Water: #37743, #37738, Radiation License: #001-904.013
SC Laboratory ID: #99042
VA SWCB ID:1000061, Drinking Water: #00018
1302 Belmont Strict, Burlington. NC 27215-6935 TEI..336.570.4661 FAX [phone]f 9R

OEC-28-01 FRI 02:01 PM WOMBLE CARLYLE
FAX NO. 336 721 3660
P. 33
Simlalabs Xnternatiorlai
INTERNATIONAL Date: 1i_0c1-01
CLIENT: Delta Apparel, Inc. Client Sample ID: CLB
Lab Order: D01090416 Tag Number•' Grab
Project:
Collection Begin:
Lab ID: 801090416-03 Collection End/Date; 9/18/2001 7:36:00 AM
Matrix: WASTEWATER
Aha lyscs
Result
Limit Units Dale Prepared Date .Analyzed
COLOR, ADMI M2120E(4)
Adjusted ADM( _ Analyst: MSJ
-••— _ �� 631 25,0 9/19/2001 3:15:00 PM 9/19/2001 3:36:Q0 P
Adjusted p11 7.58 0 9/19/2001 3:15:00 PM 9/19/2001 3:35:00 P
Initial ADMI 821 25.0 9/19/2001 3:15:00 PM 9/19/2001 3:36:00 P
p1-1
•
9/19/2001 3:15:00 PM 9/19/2001 3:36:00 P
Ccrtiffications: Simalahs - Burlington
EPA Chemistry Lab ilk: NC00137,13ioassayLab ID: NC2721500
NC Chemistry: 885, Biomonitoring:11002, Drinking Water:11177,13,1137738, Radiation License: *001-904-0G
SC Laboratory ID:ii99042
VA SWCB ID: #000061, Drinking Water: i100018
1302 Belmont Street, Burlington, NC 27215.6935 TFL.336.570.4661 FAX [phone]

DEC-28-01 FRI 02:01 PM WOMBLE CARLYLE
FAX NO. 336 721 3660
P. 34
Sunalabs International
CLIENT:
Lab Order:
Project:
Lab 1i);
Analyses
•
INTERNATIONAL Date: 03-Oct-01
Delta Apparel, Inc, Client Sample ID:
B01090190 Tag Number:
Collection Begin:
B01090190-02 Collection End/Date:
Matrix:
COLOR, ADMI
Adjusted ADMI 6,840 25.0 9/12/20014:16:00 PM
_Adjusted pFi 7.61' 0 9/12/2001 4:16:00 PM
Initial ADMI 6,680 25.0 9/12/2001 4:16:00 PM
Result
Influent Composite
9/10/2001 6:28:00 AM
9/11/2001 6:49;00 AM
WASTEWATER.
Limit Units
Date Prepared pate Analyzed
M2120E(4)
Initial pH 9.87 0 9/12/2001 4:16:00 PM
Certifications: Simotubs - Burlington
Analyst: MSJ
9/12/2001 4:16:00 P
9/12/2001 4:16:00 P
9/12/2001 4:16:00 P
9/12/2001 4:16:00 P
EPA Chemistry Lab ID: NC0013 7, Bioassay Lab ID: NC/721500
NC Chemistry: R85, Biomonitoring: //002, Drinking Water: il37743,1/37738, Radiation License: #00t-904-00
SC Laboratory ID: #99042
VA SWCB 1D: #000061, Drinking Water.1100018
1302 Belmont Street, Burlington, NC 27215.6935 TEL.[phone] FAX 336.570,4698
10

DEC-28-01 FRI 02:01 PM WOMBLE CARLYLE
FAX NO. 336 721 3660
P, 35
Sihnnlabs Internatioivai
INTER NA TION AL
Date; 03-Oct-01
CLIENT: Delta Apparel, Inc. Client Sample ID: C.L.B. Grab
Lab Order: B01090190 Tag Number-
Project: Collection I3egin:
Lab ID: D01090190.03 Collection End/Date: 9/11/200I 5:46:06 AM
Matrix: WASTEWATER
R
Analyses Result Limit Units
Date Prepared Date Analyzed
COLOR, AbMI M2120E(4)
Adjusted AQMI Analyst: MSJ
700 25.0 9/12/2001 416:00 PM 9/12/2001 4:16:00 P
Adjusted pH� 0,......7,78 0 9/12/2001 4:16:00 PM 9/12/2001 4:16:00 P
initial AbMI ^^ 728 25.0 9/12/2001 4:16:00 PM 9/12/2001 4:16:00 P
Initial pH 8.17 0 9/12/2001 4:16:00 PM 9/12/2001 4:16:00 P
Cerlitleations: Siu»abbs.. Burlington
MIA Chemistry Lab ID: 14C00137,13icassay Lib ID: NC:2721500
NC Chemistry: #85, Iliontonitgring: #002, Drinking Water: #37743, #37738, Radiation License: #001-904-0G
SC Laboratory ID: #99042
VA SWC13 ID:1/00006I, Drinking W.itcr: /100018
1302 Belmont Street, Burlington, NC 27215-6935 TEL.[phone] FAX [phone]
1.r

DEC-28-01 FRI 02:01 PM WOMBLE CARLYLE
FAX h[0. 336 721 3660
P. 36
Sinaalabs International
CLIENT: Delta Apparel, Inc.
Lab Order: )301090032
Project:
Lab ID: B01090032-03
INTERNATIONAL,
Date: 29-Sep-01
Analyses
COLOR, ADMI
M2120E(4) Analyst: MSJ,
Adjusted ADMI
-, 4'�0 25'0 9/5/2001 4:30:00 PM 9/5/2001 4:30:00 PM
__Adjusted pH 7.65 -- ��
Initial Adjusted
_— 0-� 9/5/2001 4:30:00 PM 9/5/2001 4:30:00 PM
_._, 4,640 25.0 Initial pH 9/5/2001 4:30:00 PM 9/5/2001 4:30:00 PM
9.7'8 0 9/5/2001 4:30:00 PM 9/52001 4:30:00 PM
Result Limit Units Date Prepared Date Analyzed
Client Sample ID: Influent Composite
Tag Number:
Collection Begin; 9/3/2001 6:30:00 A1v1
Collection End/Date: 9/4/200I 6:46:00 AM
Matrix: WASTEWATER
Certifications: Simalabs-Burlington —�
El'A Chemistry Lab ED: NC00137, Bioassay Lab ID: NC2721S00
NC Chemistry: #85, Biomoniloring: #002, Drinking Water: #37743, /137738, Radiation License: #/001-904-0G
SC Laboratory ID: #99042
VA SWCB 1D: #000061, Drinking Water:400018
1302 Belmont Street, Burlington, NC 27215-6935 TEL.,336.570.4661 FAX [phone]
3

'DEC-28-01 FRI 02:02 PM WOMBLE CARLYLE
FAX NO, 336 721 3660
P. 37
Simalabs International
INTERNATI.ONAL Date:29-Sep-OI
CLIENT: Delta Apparel, Inc.
Lab Order: D01090032
Project:
Lab ID:
B01090032-04
Analyses
COLON, ADMI
Adjusted ADMI 315 25.0
Client Sample ID: CLB Grab
Tag Number:
Collection Begin:
Collection End/Date: 9/4/2001 6:06:00 AM
Matrix: WASTEWATER
• ke.qult Limit Units
Adjusted pH
Inilf3l ADMI
Initial p11
M2120E(4)
7.r1 0
Certilica li ons:
362 25.0
7.38 0
Date Prepared Date Analyzed
9/5/2001 4:30:00 PM
9/5/2001 4:30:00 PM
9/5/2001 4:30:00 PM
9/5/2001 4:30:00 PM
Analyst: MSJ
9/5/2001 4:30:00 PM
9/5/2001 4:30:00 PM
9/5/2001 4:30:00 PM
8/5/2001 4:30:00 PM
Siatalabs - Tooling ton
EPA Chemistryl,ab ID: NC00137, Bioassay Lab lt): NC2721500
NC Chemistry: #85, Biomonitoring:1/002, Drinking Warw. #37743, *37738, Radiation License: //001-904-OG
SC Laboratory ID: //99042
VA SWC8 ID: //000061, Drinking Water: 400018
1302 Belmont Street, Burlington, NC 27215.6935 T] L.336.570.4661 FAX [phone]
4

DEC-28-01 FRI 02:02 PM WOMBLE CARLYLE
FAX NO. 336 721 3660
P. 38
Sihimlabs International INTERNATIONAL
CLIENT:
Lab Order:
Project:
Lab ID:
Delta Apparel, Inc,
801080724
B01080724-05
•
Analyses
COLOR, ADM1
Adjusted ADMI
Adjusted pH
Initial ADMI
Initial pH rn�
Ceri itaironst SimaIabs - lsurtingwn
EPA ChemistryLab ID: NC00137, B ssayLab 1D: NC272I500
NC Chemistry: t 85, Biornonitoring: #002, Drinking Water: /137743,1437738, Radiation License: /1001-904-0G
SC Laboratory ID: II99042
VA SW(:}3 In: k000061, Drinking Water, ff000I8
1302 Belmont Street, Burlington, NC 27215-6935 TEL.336,570.466I FAX 336,570.4698
Date: 14-Sep-01
Client Sample ID: Influent
Tag Number:
Collection Begin:
Collection End/Date:
Matrix:
Result Limit Units
Composite
8/27/2001 I0:36:00 AM
8/28/2001 10:21:00 AM
WASTEVVATER
Date Prepared Da te nalyzed
M2120E(4)
2sII0 Analyst:
25.0 8/29/2001 4:00:00 PM 8/30/2001 9:16:00 A
7.68 0 8/29/2001 4:00:00 PM 8/30/2001 9:16:00 A
—�~ 25.0
8/29/2001 4:00:00 PM 8/30/2001 9:16:00 A
2,360
8.96
0 8/29/2001 4:00:00 PM 8/30/2001 9:16:00 A
1r

°DEC-28-01 FRI 02:02 PM WOMBLE CARLYLE
FAX NO. 336 721 3660
P. 39
Sihmalabs International
INTERNATIONAL pate:14-Sep-01
CLIENT:
Lab Order; B01080724
Project:
Lab ID:
Ana lyses
- Delta Apparel, Inc.
I301080724-06
COLOR, ADMI
Adjusted ADM(
Adjusted pH..
initial ADMI
Initial pH
Client Sample ID: C1B
Tag Number: Grab
Collection Begin:
Collection End/Date: 8/28/2001 5:46:00 AM
Matrix: WASTEWATER
Result Limit Units
M2120E(4)
Date Prepared
Date Analyzed
725 25.0 8/20/2001 4:00:00 PM
7.64 0 8/29/2001 4:00:00 PM
748 25.0 8/29/2001 4:00:00 PM
8.20 0
Ctrtirteirinna: 5imslabs -Burlington
8/20/2001 4:00:00 PM
Analyst: MSJ
8/30/2001 9:16:00 A
8/30/2001 9:16:00 A
8/30/2001 9:16:00 A
8/30/2001 9:1SS:00 A
EPA Chemistry lab 113: NC00137, Bioassay Lab ID: NC272L500
NC Chemistry: i18S, Hiomonitering: 4002, Drinking Watcr. 1137743, 113773 8, Radiation Liccnse: 4001-904-OG
SC Laboratory ID;1$99042
VA 5WC13ill; 4000061, Drinking Water:400018
1302 Belmont Street, Burlington, NC 27215-6935 TEL.[phone] FAX 336.570.469E
/2

DEC-28-01 FRI 02:02 PM WOMBLE CARLYLE
FAX NO. 336 721 3660
P. 40
Sirnalabs International
CO ENT:
Lab Order:
Project:
Lab 1D:
1 NTE RNATI ONAL Date: 31-Aug-01
Delta Apparel, Inc.
B01080543
B01080543-04
Analyses
COLOR, ADMI
Adjusted ADMI
Adjusted pH
Initial ADMI
Initial pti
Client Sample ID:
Tag Number:
Collection Begin:
Collection End/Date:
Matrix:
Result Limit Units
Cerrif e*tiouse
M2120E(4)
2,730 25.0
7.65 0
3,220
9.06
Sirualabs - Burlington
Influent Composite
8/20/2001 11:03:00 AM
8/21/2001 10:54:00 AM
WAS'1'F WA'fl R
25.0
0
Date Prepared Date Analyzed
_ • Analyst: MSJ
8/22/2001 1:15:00 PM 6/22/2001 1:33:00 P
8/22/2001 1:15:00 PM 8/22/2001 1:33:00 P
8/22/2001 1:15.00 PM 8/22/2001 1:33:00 P
8/22/2001 1:15:00 PM 8/22/2001 1:33:00 P
):t'A Chemistry Lab ID: NC00137, Bioassay Lab 11): NC2721500
NC Clhemishy:1185, biomonitoring: 11002, Drinking Water.. #37743, #37738, Radiation License:11001-904.OG
SC Laboratory ID: #99042
VA SWCB ID: #000061, Drinking Water; #00018
1302 Belmont Strcct, Burlington, NC 27215.6935 TEL.[phone] FAX [phone]
5

DEC-28-01 FRI 02:03 PM WOMBLE CARLYLE
FAX NO. 336 721 3660 P. 41
Simalabs International
I N "3-E R NATIONAL Date:31-Aug-OI
CLIENT: Delta Apparel, Inc. Client Sample ID: CIB Grab
Lab Order: B01080543 Tag Number:
Project: Collection 13cgin:
Lab It): B01080543-03 Collection End/Datc: 8/21/2001 5:51:00 AM
Matrix: WASTEWATER
Analyse.!
Result Limit Units Date Prepared Date Analyzed
COLOR, ADM M2120E(4) •
Adjustnd A i II 802 25.0
Analyst: MSJ
8/22/2001 1:15:00 PM 8/22/2001 1:33:00 P
Adjusted pH 7.64 0
Initial AIDMI 883 25.0
8/22/2001 1:15:00 PM 8/22/2001 1:33:00 P
8/22/2001 1:15:00 PM 8/22/2001 1:33:00 P
Initial pH 8.19 0
8/22/2001 1:15:00 PM 8/22/2001 1:33:00 P
Certifications: Simalabs-Burlington
E?A Chcmisuy Lab J17 NC00137, Bioassay Lab ID: NC2721500
NC Chemistry: #85, Biomonitoring: #002, Drinking Water: 437743, #37738, Radiation Licenst: #001-901-0G
SC Laboratory ID: 499042
VA SWC131D: #000061, Drinking Water: #000I 8
1302 Belmont Street, Burlington, NC 27215-6935 TEL.[phone] FAX [phone]

DEC-28-01 FRI 02:03 PM WOMBLE CARLYLE
FAX NO. 336 721 3660
P. 42
Shn:labs International 1 N 'T E
CLIENT:
Lab Order:
Project:
Lab ID:
Annlyscs
Delta Apparel, Inc.
B01080382
B010 8 03 82-05
COLOR, ADMr
•
nn2i20EI41
Adjusted ADM( 3,440 25.0
AdjUSted pH
Initial ADMI
Initial p1i
•
7.51 0
3,150 25.0
9.73 0
R
NA
TIONA 1. Date: 27-Aug_01
Client Sample ID; Infuent
Tag Number:
Collection Begin: 8/13/2001 11:00:00 .AM
Collection End/Date: 8/14/2001 10:56:00 AM
Ma trix: WASTEWATER
Result Limit Units Date Date Prepared Pa
p Analyzed
8/15/2001 3:14:00 PM
8/15/2001 3:14:00 PM
8/15/2001 3:14:00 PM
8/15/2001 3:14:00 PM
Analyst: MSJ
8/15/2001 3:14:00 P
8/15/2001 3:14:00 P
8/15/2001 3:14:00 P
8/15/2001 3:14:00 P
Certilleatintns: Sirnalabs .. Burlington
EPA Chemistry Lab 1D: NC00137, Bioassay Lab 113: NC2721500
NC Chemistry: t185, Fiiomonitoring: #002, Drinking Water: #37743, /137738, Radiation License: #001-904-0(1
SC Laboratory 1D: #99042
VA SWC13 ID; #000061, Drinking Water, #00018
1302 Belmont Strcct, Burlington, NC 27215-6935 TEL.336.570,4661 FAX 336,570.4698
11

DEC-28-01 FRI 02:03 PM WOMBLE CARLYLE
FAX Na 336 721 3660
P. 43
Sinialabs International
CLIENT: Delta Apparel, Inc.
Lab Order: B01080382
Project:
Lab l'i): B01080382-06
Analyses
INTERNATIONAL Date:27Aug-o1
Client Sample TD: CIT3
Tag Number:
Collection Begin:
Collection End/Date: 8/14/20015:46:00 AM
Matrix: WASTEWATER
Result Limit Units Date Prepared Date Analyzed
COLOR, ADMI M2120E(,9
Analyst: hNSJ
wAdjusted ADMI 899 25,0 8/15/2001 3:14:00 PM 8/15/2001 3:14:00 P
Adjusted phi 7.47 0 8/15/2001 3:14:00 PM 8/15/2001 3:14:00 P
lnIIIalADMI 963 25.0 8/15/2001 3:14:00 PM 8/15/2001 3:14:00 P
Initial pH 8.14 0 8/15/2001 3:14:00 PM 8/15/2001 3:14:00 P
Certifications: Simalabs- Burlington
EPA Chemistry Lab ID: NC00137, Bioassay Lab ID: NC2721500
NC Chemistry: #85, Biornonitoring: f/002, Drinking Water #37743, #37738, Itadiation License: 0001-904-Ot3
SC Laboratory 1]>: //99042
VA SWCI3 ID: #000061, Drinking W'aler: 100018
1302 Belmont Street, Burlington, NC 27215-6935 T 1 _336.570.4661 FAX 336.570,4698
12

)EC-28-01 FRI 02:03 PM WOMBLE CARLYLE
FAX NO. 336 721 3660
P. 44
Sirnalabs Z
CLIENT:
Lab Order:
Project:
Lab ID:
Analyses
nternationaX
Delta Apparel, Inc.
B01080145
E01080145-05
COLOR, ADMI
Adjusted ADMI
Adjusted pH
Initial ADMI
Initial pH
CCrlilicaL o,%:
INTERNATIONAL
Date; 22 Aug-01
Client Sample ID: Influent Composite
Tag Number:
Collection Begin: 8/6/2001 6:00:00 AM
Collection End/Date: 8/6/2001 6:00.00 AM
Matrix: WASTEWATER
Result Limit Units
M2120E(4)
2,120 25.0
7.46
2,500
10.4
0
25.0
0
Date Prepared Date Analyzed
8/8/2001 4:00:00 PM
Simaiabs - Burlington
ErA Chemistry Lab ID: NC00137, Bioassay Lab II3: NC:'2721500
NC Chemistry: 85,13iomoniioring: (/002, Drinking Water:437743, 437738, Radiation License:I4001-904-OG
SC Laboratory iD: 499042
VA SWCB ID: n000061, Drinkieg Water: 400018
1302 Belmont Street, Burlington, NC 27215-6935 TEL.336.570.466I FAX [phone]
8/8/2001 4:00:00 PM
8/8/2001 4:00:00 PM
8/8/2001 4:00:00 PM
' Analyst: MSJ
8/8/2001-4:15:00 PM
8/8/2001 4:15:00 PM
8/8/2001 4:15:00 PM
8/8/2001 4:15.00 PM
5

UEC-28-01 FRI 02:03 PM WOMBLE CARLYLE
FAX NO. 336 721 3660
P. 45
Simalabs International
INTERNATIONAL Date:22-Aug-01
CLIENT:
Lab Order:
Project:
Lab ID:
Delta Apparel, Inc. Client Sample ID: C11313asin
B01080145 Tag Number:
Collection Begin:
801080145-06 Collection End/Date: 8/7/2001 7:30;00 AM
Matrix: WASTEWATER.
Analyses
Result Limit Units Date Prepared Date Analyzed
COLOR, ADMI
Adjusted ADMI
Adjusted pH
Initial ADMI
M21201:(4) Analyst: MSJ
728 25.0
7.57 0
Initial pH
CerriCcatiors;
763 25.0
8/8/2001 4:00:00 PM
8/8/2001 4:00:00 PM
8/8/2001 4:00:00 PM
B.60 0 8/8/2001 4:00:00 PM
8/8/2001 4:15:00 PM
8/8/2001 4:15:00 PM
8/8/2001 4:15:00 PM
8/8/2001 4:15:00 PM
Simalabs - Burlington 1
EPA Chemistry Lab ID: NC001.37, Biourzay Lab ID: NC2721500
NC Chemistry: #8S, Biomonitoring: #002, Drinking Water #37743, #37738, Radiation License:1001-904-0G
SC Laboratory ID: #99042
VA SWCB ID:11000061, Drinking Water. #00018
1302 Belmont Street, Burlington, NC 27215.6935 TEL.[phone] FAX [phone]
6

UEC-28-01 FRI 02:04 PM WOMBLE CARLYLE
FAX NO. 336 721 3660 P. 46
Simalabs International
INT E R N A T 1 0 NAL pate: , 22-4ug_0/
CLIENT: * Delta Apparel, Inc.
Lab Order: B01080021
Project:
Lab ID:
B01080021-05
Client Sample ID-
Tag Number: 6rtb C
Collection Begin:
Collection End/Date: 7/31 /2001 6:30:00 AM
Matrix: WASTEWATER.
Analyses Result Limit Units Date Prepared Date Analyzed
COLOR, ADMI
Adjusted ADMI
Adjusted pH
Initial ADMI
Initial pH
M2120E(4)
4,000 25.0
7.62 0
3,590 25.0
Analyst: MSJ
8/1/2001 3:45:00 PM 8/1/2001 4:00:00 PM
8/1/2001 3:45:00 PM 8/1/2001 4:00:00 PM
011/2001 3:45:00 PM 8/1/2001 4:00:00 PM
13.80 0
8/1/2001 3:45:00 PM 8/1/2001 4:00:00 PM
Cei �i6cafions: Simalabs -Burlington
EPA Chemistry lab ID NC00137, Bioassay Lab 113: NC2721500
NC Chemistry: //85, Biomonitoring: 8002, Drinking Water: 1137743,137738, Ra:144/k n License: //001-904-03
SC Laboratory ID; 899042
VA SWCB 1D: 8000061, Drinking Water. #00018
1302 Belmont Street, Burlington, NC 27115.6935 TEL.336,570.4661 FAX 336,570.4698

1)EC-28-01 FRI 02:04 PM WOMBLE CARLYLE
FAX NO. 336 721 3660
P. 47
1NTERNA'FIONAL
Simalabs International J
CLIENT ----Delta Apparel, lne.
-Lab Order: 1101080021
'Project:
Lab go1080021-06
Result
Analyses
—
GO1_01 DIUIi_
- Adjusted ADM'
Adjusted pH
initial ADM'
Initial pH
Date: 22 Aug-01
Client Sample 1D 1 •a r C-0' n nasitn % g—
Tag Number:
Collection Begin: 7/30/2001 7:10:00 AM
Collection End/Date: 7/31/2001 11:00:00 AM
Matrix: WASTEWATER
Date Prepared Date Analyzed
Limit Units
M2120E 4 Analyst: MSJ
1,130 25.0 _ 8/1/2001 3:45�00 PM
7.46 0 8/1/2001 3:45:00 PM
1 1 BO 25 0 8/1/2001 3:45:00 PM
9.45 0
8/1/2001 3:45:00 PM
811/2001 4:00:00 PM
8/1/2001 4:00:00 PM
8/1/2001 4:00:00 PM
8/1/2001 4:00:00 PM
Certification:: Simalabs- Burlington
EPA C:hcmistry Lab ID: NC00137, Bioassay Lob ID: NC2721S00
NC Chemistry. #55, I1iomonitoting: $002, Drinking Water i/37743,1137738, Radiation License- #001-904-0G
SC Laboratory la #99042
VA S WCI3 ID: $000061, Drinking Water: #00018
1302 Belmont Street, Burlington, NC 27215-6935 TEL.[phone] FAX 336.570,4698

DEC-28-01 FRI 02:04 PM WOMBLE CARLYLE
FAX NO. 336 721 3660
P. 48
Simalabs International
INTERNATIONAL Datc:07-Aug-01
CLIENT: Delta Apparel, Inc_
Lab Order: 13010705 52 .
'roj ecL:
Lab 10; BO1070552-07
Analyses
Relault
Client Sample ID:
Tag Nuinber:
Collection Begin:
Collection End/Date:
Matrix:
Influent
Composite
7r23/2001 8:00:00 AM
7/24/2001 11:00:00 AM
WASTEWATER
Limit Units Date Prepared Date Analyzed
COLOR, ADMI
M2120E(4)
_Adjusted ADM! 2,350 25.0 7/25/2001 4:50:00 PM
Adjusted pH _7.44 0 7/25/2001 4:50:00 PM
Initial ADM( 3,880 25.0
10.6 0
Initial pH
7/25/2001 4;50:00 PM
7/25/2001 4:50:00 PM
Analyst: MS.!
7/25/2001 4:56:00 P
7/25/2001 4:56:00 P
7/25/2001 4:56:00 P
7/25/2001 4:56:00 P
eel -lineations: Simalabs-)lurlington
EPA Chemistry Lab ID: NC00137, Bioassay L b 117: NC27215 00
NC Chemistry: #85,13iomunitodng:11002, Drinking Water: 437743, #37738, Radiation License: 0001-904.0G
SC Laboratory 11): 499042
VA SWCB ID: 1/000061, Drinking Water:000012
1302 Belmont Street, Burlington, NC 27215-6935 TEL.[phone] FAX [phone]

DEC-28-01 FRI 02:04 PM WOMBLE CARLYLE
FAX NO, 336 721 3660
P. 49
Simalabs International
I N T E R N A T I O N A1- Date: 07-Aug-01
CLTF.NI`: Delta Apparel, Inc.
Lab Order: 1301070552
Project:
Lab ID; 1301070552-0G
Analyses
COLOR, ADMt
Adjusted ADMI
Adjusted pH
Initial ADM(
initial pH
etrtitkCAtiORS:
Result
Client Sample ID:
Tag Number:
Collection Begun:
Collection End/Date:
Matrix:
Chlorine Basin
Grab
7/24/2001 8:00:00 AM
WASTEWATER:
Limit Units Date Prepared Date Analyzed
M2120E(4)
1,130 25,0
7.63
1,060
0
25.0
8.08 0
Analyst: MSJ
7/25/2001 4:50:00 PM 7/25/2001 4:56:00 P
7/25/2001 4:50:00 PM 7/25/2001 4:56:00 P
7/25/2001 4:50:00 PM 7/25/2001 4:56:00 P
7/25/2001 4:50:00 PM 7/25/2001 4:56:00 P
Simalabs - Burlington
EPA (:hcmistry Lab ll): NC0013 7, Bioassay Lab ID: NC2721500
NC Chemistry: 485,Biomonitoring: #002, Thinking Water:4137743, #37738, Radiation 1-.icaase:I/001-904-0G
SC Laboratory ID: 499042 -
VA SWC1R ID: 4000061, Drinking Waer:1100018
1302 Belmont Street, Burlington, NC 27215-6935 TEL.[phone] FAX [phone]

WOMBLE ir
CARLYLE
SANDRIDGE
& RICE
.1 ti'41 . 11 ::•>ir %I •
200 West Second Street
Winston-Salem. NC 27101
Mailing Address:
Posr Office Drawer 84
Winston-Salem. NC 27 102
Telephone: [phone]
Fax: [phone]
Web site: www.wcsr.com
.wcsr.Ctnu
December 21, 2001
via facsimile
Gregory J. Thorpe, Ph.D
Acting Director
Division of Water Quality
North Carolina Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Request for Additional Information
NPDES Draft Permit
Permit No. NC0006190
Delta Apparel -Maiden Plant
Catawba County
Dear Mr. Thorpe:
Lori P. Hinnant
Phone: [phone]
Fax: [phone]
Email : lltinnan t©wcaT.conn
This firm represents Delta Apparel, Inc. ("Delta"). This letter is to notify the Division of
Water Quality ("DWQ") that Delta plans to respond to DWQ's request for additional information
by December 28, 2001. This response date is timely and complies with the 10-business day
mandate in DWQ's November 21 letter. Despite the date (November 21, 2001) on DWQ's letter,
the postmark indicates mailing on December 6, 2001, and the correspondence was apparently
misdirected by the post office to another company. Thus Delta did not receive the letter until
December 14, 2001.
DWQ's letter provides that the Division will consider enforcement action against Delta
unless Delta takes the action dictated in the letter. In this instance, the Division has no such
enforcement authority because DWQ is not entitled to the information.' However, in its continued
spirit of cooperation, Delta will supply the requested information, but does so without waiving any
objection or right it has relating to DWQ's Color Policy for the South Fork Catawba River,
Delta currently has no legal obligation to conduct any color study. But for Delta's
efforts to voluntarily address the color issue, Delta could have ceased doing anything
after submittal of the Alliance data, receipt of DWQ's Color Policy and receipt of the
draft permit.
GtEORGIA / NORTH CAROI.INA / SOUTH CAROLINA / VIRGINIA / WASHINGTON D.C.

WOMBLE
CARLYLE F
Sk'4DRIDGE
& RICE
PLL(
Gregory J. Thorpe, Ph.D.
December 2 I, 2001
Page 2
including but not limited to, those objections contained in its previous comments provided to
Hearing Officer John Robert Blowe on September 21, 2001.2
The requested information relates to a recent voluntary color study conducted by Delta. As
you know, DWQ, for the first time, has created permit limitations with regard to effluent color in
Delta's draft NPDES permit. Delta previously submitted comments to the draft permit and asserted
that the color restrictions imposed were without the requisite evidentiary foundation and could not
be supported. The data DWQ is now requesting was not considered by DWQ in arriving at the
Limitations contained in the draft permit. Moreover, the data concerning percent reduction between
influent and effluent utilizing ADMI measurements was initiated by Delta (1) after receipt of the
draft permit, and to (2) to build evidence for challenging any final permit limitation with regard to
color.
Delta has reiterated throughout the permitting process that it is committed to addressing color
in the South Fork Catawba River. Delta's voluntary actions, taken at great expense, evidence its
commitment. Delta continues to believe, and the results of all of the color studies conducted to date
evidence, that any permit limitation on color can only be derived by Delta's continued efforts to
monitor color reduction and the effects on other permit parameters. (After all, we don't want to
achieve color reduction, which is driven totally by aesthetics, at the expense of toxicity or other
permit parameters, which in fact have detrimental environmental impacts.) In any event, Delta will
provide the requested data because it further evidences that imposition of any color limitation is
premature.
Very truly yours,
Lori P. Hinnant
Since the public hearing for Delta's draft permit occurred on August 28, 2001,
pursuant to N.C. Gen. Stat. § 143-215.1(c)(4), the Commission has "90 days...
[from the public hearing] to grant or deny" Delta's permit. Thus, Delta's final permit
was due by law on or before November 26, 2001.

Michael F. Easley, Govemor
William G. Ross Jr., Secretary
y North Carolina Department of Environment and Natural Resources
—I Gregory J. Thorpe, Ph.D.
,r Acting Director
Division of Water Quality
Certified Mail 7000 1530 0002 2100 2274
Return Receipt Requested
November 21, 2001
Mr. Gene Hudgens, Plant Mgr.
• Delta Apparel, Inc.
100 West Pine Street
Maiden, North Carolina 28650
Dear Mr. Hudgens:
Subject: Request for Additional Data
NPDES Permit NC0006190
Delta Apparel- Maiden Plant
Catawba County
I am writing in response to your letter of October 23, 2001 refusing to supply the information requested by
Tom Belnick in his letter dated October 9, 2001. I ask again that you provide to DWQ the following
information:
• Amount of polymer added on a daily basis for the period May 1, 2001 through August 31, 2001. In
addition, any associated influent/effluent color measurements of color reduction performance during
this period.
• Results of all ADMI color measurements collected during the Cytec polymer trials to the present date,
to determine the color removal percentages based on ADMI methods.
You misunderstand the nature of DWQ's October 9, 2001 request that Delta Apparel provide DWQ with
the results of your addition of polymer to reduce color in the discharge from your wastewater treatment
facility. DWQ seeks the color data in order to place the appropriate effluent color limit in NPDES Permit No.
NC0006190. Any information in Delta Apparel's possession regarding this data is relevant to the
establishment of the final permit limit, whether .that information was generated prior to or subsequent to the
public notice of the draft permit.
You also misunderstand the nature of the draft permit that was the subject of the public hearing on
August 28, 2001. DWQ is not required to issue the draft permit. It may alter the permit after public hearing,
particularly if information comes to light that would support a different effluent color limit. DWQ can also
renotice a draft permit if necessary.
DWQ has clear authority to request the above information. N.C. General Statute § 143-215.1 (c) (1)
provides:
...The Commission may conduct any inquiry or investigation it considers necessary before acting on an
application and may require an applicant to submit plans, specifications, and other information the
Commission considers necessary to evaluate the application....
Furthermore, Part II Section B.8 of Delta Apparel's current permit provides that Delta must submit such
information:
The permittee shall furnish to the Permit Issuing Authority, within a reasonable time, any information
which the Permit Issuing Authority may request to determine whether cause exists for modifying, revoking
and reissuing, or terminating this permit or to determine compliance with this permit.
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone]
Customer Service
1 800 623-7748

N'0006190
Delta Apparel
November 21, 2001
If Delta Apparel does not supply the requested information within 10 business days following receipt of
this letter, DWQ will consider Delta Apparel to be in violation of its permit and take appropriate enforcement
action. If you have any questions about this data request, please contact Tom Belnick at (919)-733-5083,
extension 543.
Sincerely,
Gregory J. Thorpe, Ph.D.
cc: Coleen Sullins, Water Quality Section
Bill Reid, Point Source Branch
Bobby Blowe, CG&L
Shannon Langley, NPDES Compliance
Rex Gleason, MRO Water Quality
NPDES Permit File; NC0006190

DELTA
APPAREL, INCORPORATED
October 23, 2001
Mr. Tom Belnick
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Water Quality Section
NPDES Unit 1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Re: Request for Additional Data
NPDES Permit NC0006190
Delta Apparel -Maiden Plant
Catawba County
Dear Tom:
Fl�T- OU
eobb(r-eie),/
r - "
U
On October 9, 2001, we received your letter requesting additional information for
Division Hearing Officer John Robert Blowe and we are confused by your request. First, the
data concerning the amount of polymer added during the time period before the July 24, 2001
issuance of the draft permit has been adequately provided to Mr. Blowe in our September 23"I
public comments. We have also previously provided all relevant ADMI data to Mr. Blowe. Any
information after the July 24, 2001 issuance of the draft permit is not relevant since it was not
relied upon by the NPDES Unit in its decision to mandate a 90% permit limitation.
Secondly, as you are aware, Mr. Blowe closed the public record on this matter on
September 23, 2001. It is our understanding that Mr. Blowe's consideration of Delta's draft
permit must proceed upon the public record established as of that date. Any materials submitted
and relied upon by the Department after the closing of a public record could be challenged as
inappropriate by third parties.
In closing, Delta respectfully declines to provide the requested information. Given the
level of involvement by third parties surrounding the Department's color reduction efforts in the
South Fork Catawba River, we are concerned that providing any of the data you request would
not be in Delta's or the Department's best interest. Please feel free to contact me if you have any
questions.
Sincerely,
Gene Hudgens
100 W. Pine Street • P.O. Box 37 • Maiden, N.C. 28650 • [phone] • FAX [phone]
Change your shirt.

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Gregory J. Thorpe, Ph.D., Acting Director
October 9, 2001
Gene Hudgens, Plant Mgr.
Delta Apparel, Inc.
100 West Pine Street
Maiden, North Carolina 28650
AVA
NCDENR
Subject: Request for Additional Data
NPDES Permit NC0006190
Delta Apparel -Maiden Plant
Catawba County
Dear Mr. Hudgens:
In order to complete the evaluation of Delta's NPDES renewal request, the Division
Hearing Officer is requesting the following data be submitted by October 23, 2001.
• Amount of polymer added on a daily basis for the period May 1, 2001 through
August 31, 2001. In addition, any associated influent/effluent color
measurements of color reduction performance during this period.
• Results of any ADMI color measurements collected during recent months to
determine color removal percentages based on ADMI methods.
If you have any questions concerning this data request, please call me at (919) 733-
5083, extension 543.
��e�r�ely,
om Beenick
NPDES Unit
cc:
Bobby Blowe, CG&L
NPDES File
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer Visit us on the INTERNET © www.enr.state.nc.us

WomBLE
CARLYLE
SANDRIDGE
& RICE
A PROFESSIONAL LIMITED
LIABILITY COMPANY
200 West Second Street
Winston-Salem, NC 27101
Mailing Address:
Post Office Drawer 84
Winston-Salem, NC 27102
Telephone: [phone]
Fax: [phone]
September 21, 2001
John Robert Blowe
Hearing Officer
Division of Water Quality
Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: NPDES Draft Permit
Permit No. NC0006190
Delta Apparel -Maiden Plant
Catawba County
Dear Mr. Blowe:
Lori P. Hinnant
Direct Dial: [phone]
Direct Fax: [phone]
E-mail: [e-mail]
On August 28, 2001, you and others from the NPDES Unit and an EPA representative visited
the Delta Apparel ("Delta") plant in Maiden, North Carolina. During your visit, Delta provided
written comments to the referenced draft permit and discussed its concerns and objections to the
color reduction requirements. As Delta explained, since February 2000, it has been voluntarily
conducting studies to remove color from its effluent. Dave Goodrich, Supervisor, NPDES Unit,
requested that Delta supplement into the record the results of the studies. Accordingly, we now
incorporate by reference Delta's August 28, 2001 written comments and provide the requested
supplemental information.
Again, Delta opposes the color reduction conditions in its draft permit for several reasons.
First, the evidence in the record demonstrates that Delta requires additional time to continue
monitoring and studying the process of wastewater color reduction. Second, the draft condition
formulated by DWQ lacks any technical foundation and is arbitrary. Finally, the current draft permit
color limitation is not technologically feasible.

• John Robert Blowe
September 21, 2001
Page 2
I. The Evidence in the Record Demonstrates that More Time Is Needed to Monitor Color
Removal.
A. The Results of Delta's Voluntary Color Removal Trials Have Produced Varying
and Inconclusive Results.
Over the last several years, Delta has voluntarily utilized various color removal technologies
in its efforts to reduce the color of its effluent. Delta has learned that color removal is not a simple
process. Rather, it is the result of complex chemical reactions. Whether a particular removal
technology will "work" is purely one of empirical observation, i.e., Delta must install the technology,
observe, and test its wastewater. To date, Delta has been unable to predict whether any particular
technology will remove color in the plant's wastewater system.'
We attach, as Exhibit A, a time -line and data from the color removal trials conducted at the
plant. Summaries of the trials are listed below:
Clariant Trial (February 8 - February 16, 2000)
• Product
Clariant introduced chemicals into the wastewater stream intended to remove color
by chemical reduction/hydrolysis.
Methodology
Start of trial:: untreated effluent ADMI2 color of 1970 units.
End of trial: treated effluent ADMI color of 1160 units
• Comparison
The trial measured untreated effluent at the beginning of the trial to treated effluent
at the end of the trial.
' For instance, sometimes a color removal technology may perform well in bench trials using
beaker tests. The technology may not function, however, when introduced into Delta's entire
wastewater system.
2 The ADMI ("American Dye Manufacturers Institute") color test is a methodology to
determine the color strength of a solution in "color units."

John Robert Blowe
September 21, 2001
Page 3
Plant Production Variables
At the time of the trial, 50% of the plant's production was optical whites. (Delta
learned that residual peroxide (used for bleaching) counteracts the effectiveness of
reduction/hydrolysis chemicals).
Other Permit Parameters
The Clariant product affected other permit parameters. For instance, chronic toxicity
("conductivity") fluctuated during testing.
Results
No observable effluent color change was noted at discharge point.
Bio-Chem Resources Trial (July 10 - October 2000)
Product
Pulverized silica was added to wastewater to act as color precipitant.
Methodology
Start of trial: July 10, 2000 with ADMI Color of 1190 units (on July 11, 2000).
End of trial: October 17, 2000 with ADMI color of 1820 units.
Comparison
Testing was conducted only on discharge effluent.
Plant Production Variables
None recorded.
Other Permit Parameters
No testing of other permit parameters, such as chronic toxicity, was conducted in
conjunction with trial.
Results
There was no visible color reduction at any time during the trial.
Cytec Trial (January 23 - May 2001)
• Product

John Robert Blowe
September 21, 2001
Page 4
The Cytec Trial relied upon the introduction of highly charged and cationic liquid
polymers into the plant's wastewater.
Methodology
Trial began by testing only one part of plant's wastewater system (Train 1).
The other portion of the wastewater system remained untreated, acting as a control
(Train 2). The test used the HACH DR 2000 Spectrophotometer Platinum Cobalt
color meter (Platinum Cobalt test) to measure color.
Comparison
All comparisons for the effectiveness of the polymers were created by comparing
Train 1 to Train 2. Therefore, only treated effluent to untreated effluent testing was
conducted.
Plant Production Variables
Over the period of the trial, dye use was generally increased.
Other Permit Parameters
No testing of other permit parameters, such as chronic toxicity, was conducted in
conjunction with trial. However, a chronic toxicity condition was noted at the plant
during high use of the polymer.
Results
The Cytec polymers have shown the most promise in reducing the color of Delta's
effluent.
B. Many Variables Affect Delta's Ability. to Remove Color.
A significant variable affecting Delta's ability to remove color is dye use fluctuation. Dye
use changes dramatically based upon production demands. An example of the dramatic fluctuation
in dye usage that Delta typically experiences is set forth below:
June 27, 1999 — 22 % dye use
July 4, 1999 — 2% dye use
July 11, 1999 — 23% dye use
August 22, 1999 — 33% dye use

John Robert Blowe
September 21, 2001
Page 5
August 29, 1999 — 42% dye use
September 5, 1999 — 32% dye use
December 19, 1999 — 32 % dye use
December 26- 1999 — 3% dye use
January 9, 2000 — 30% dye use
Importantly, color removal technologies do not remove color in a constant or linear
relationship. For example, if one ounce of a color removal product is needed to treat one gallon of
dye, it does not follow that two ounces will be needed to treat two gallons of dye. Therefore, instead
of a linear relationship, the relationship between dye and color removal product is an exponential
one. This relationship means that Delta is unable to predict what amount of color removal product
will be needed to achieve a constant amount of color removal as dye use fluctuates
Furthermore, due to recent production demand changes, the plant's history of dye use is not
an accurate measure to predict future dye use. Delta has increased its dye ratios to levels never
before employed on a year-round basis. Currently, dye ratio sometimes reaches 65%. Tests have not
been run to determine how wastewater created by such increased dye ratios will (if at all) respond
to color removal technologies. Significantly, no monitoring has occurred during any color removal
test over the range of dye use being currently experienced by the plant. This information is needed
in order to generate reliable information concerning what reductions are achievable. Simply
considering the color reductions from the color removal trials do not accurately reflect Delta's
current ability to remove color.
The uncertainty of achieving successful color removal with dye use fluctuations is
complicated by another variable -- water density. In the coming winter months, Delta's wastewater
will become colder and its density will increase. It is our understanding that as water density
increases, color removal technologies are hampered since inducing color precipitation from
wastewater is a function of water density. The ability of any color removal technology to operate
under cold water conditions is unknown since Delta has not performed any color removal trials
during winter months at high dye ratios.
At this time, Delta has insufficient data to know what color reductions are possible in light
of the variables present in its operation such as dye use and water density. Accordingly, more
monitoring is needed to understand the process of color removal at Delta.
C. Chemicals Utilized to Remove Color Can Adversely Affect Other Permit
Limitations.
The DWQ stated in its June 5, 2001 NPDES Color Permitting Policy ("Color Policy") that
"[t]o date, there are no data to show that the colored effluent is posing a human health concern, or
that color is a source of impact on the aquatic biota." Simply stated, the color in Delta's effluent
does not adversely affect fish or aquatic life or cause an exceedance of water quality standards.

John Robert Blowe
September 21, 2001
Page 6
However, other characteristics within Delta's wastewater, such as chronic toxicity, may adversely
affect fish or aquatic life. Chronic toxicity, among other parameters, is affected by the chemistry of
Delta's wastewater, which chemistry in turn is affected by color removal products during color trials.
Therefore, while attempting to address the subjective aesthetics of the South Fork Catawba River
watershed, Delta must proceed with caution to insure that effluent characteristics that do affect fish
and aquatic life (and water quality standards) are properly maintained.
The impact of color removal products upon chronic toxicity is poorly understood at this time.
For instance, on August 14, 2001, the DWQ Mooresville Regional Office inspected the plant and
discovered a condition of chronic toxicity. (See Notice of Violation (NOV) attached as Exhibit B).
On the date of the inspection, Delta was operating with high dye ratios and thus was utilizing large
amounts of Cytec polymer for color removal. Delta is unclear of the factors which, in conjunction
with the polymer, led to the chronic toxicity condition. Nevertheless, as the incident demonstrates,
color removal products will affect the ability of Delta to comply with other permit parameters. Delta
needs additional time to determine the amounts of color removal product which may be maintained
in its wastewater system without detriment to other permit limitations.
II. The Draft Permit Color Reduction Limitation Formulated by DWQ Lacks Any
Technical Basis and Is Arbitrary.
DWQ has no available data demonstrating the degree of color which must be removed by
Delta in order to improve downstream aesthetic water quality. Rather DWQ relied upon its Color
Policy and its visual observations of Clark Creek in drafting Delta's permit limitation. Notably,
there is no data in the Color Policy to support a percentage reduction standard. Instead, the Color
Policy relied upon the report of the South Fork Catawba River Water Quality Alliance, Inc.
("Alliance") which simply monitored and recorded ADMI color in the South Fork Catawba River
watershed. The Alliance report did not consider or evaluate reductions, percentages or permit
limitations.
DWQ's visual inspection of the watershed is also not sufficient to support a specific permit
limitation percentage. Delta does not contest that DWQ may, from its visual inspections, determine
that color in the South Fork River watershed needs to be addressed. However, without technical
data, any percentage reduction is arbitrary. DWQ does not know what percentage is needed to meet
the goal of aesthetic quality in the South Fork Catawba River watershed. As such, DWQ has no
more basis to establish a 10% or 50% reduction than it does a 90% reduction. Technical data must
connect DWQ's choice for a percentage reduction with its observation that color must be
addressed. This technical data is lacking to support Delta's draft permit (and the Color Policy).
Delta understands that DWQ arrived at the 90% reduction standard between influent and
effluent based on its perceived results of Delta's most successful voluntary reduction program thus
far -- the Cytec polymers. However, Delta never evaluated influent to effluent color. Further, while
using the Cytec polymers, the color removal results were determined using the Platinum Cobalt
methodology. This test is distinct from the ADMI methodology and the percentages obtained are

John Robert Blowe
September 21, 2001
Page 7
likewise distinct. DWQ never reviewed any of the results from Delta's voluntary studies prior to
DWQ's issuance of the draft permit. If DWQ had considered the results from Delta's color removal
trials, it could not have reached the conclusion that a 90% reduction is achievable.
The draft permit also does not specify how Delta can prove or quantify a 90% reduction
between influent and effluent. It is our understanding that DWQ expects the ADMI methodology to
be used to establish the percentage of color reduction. The studies above indicate that relying upon
the ADMI methodology to quantify effective color removal is arbitrary. Delta's experience has
demonstrated that a permit limitation based upon an ADMI percentage may not achieve the purpose
of color removal: to improve the aesthetics of Clark's Creek and the South Fork Catawba River.3
The ADMI test quantifies color units —it does not provide a gauge for indicating the visibility of
the color units. For instance, straw colored wastewater can have a high ADMI reading, but have
low visibility in North Carolina rivers. Purple wastewater, such as that typically encountered at
Delta, may have a low ADMI reading, but demonstrate high stream visibility. During the Clariant
Trial, monitoring revealed a 41% reduction of ADMI color in the plant's wastewater.
Notwithstanding this fact, Delta did not observe any improvement in the color of Clark Creek during
the trial. The Clariant product was, in effect, removing color from Delta's wastewater which had
low visibility. Therefore, while the ADMI methodology demonstrated color removal, the highly
visible and remaining color units resulted in no net visible color change at the discharge point.
Whether any particular color removal technology employed by Delta can lower the ADMI
reading of its effluent and address highly visible effluent color has not been adequately tested.
Simply stated, the goal to remove color in the streams can only be achieved by testing various
technologies to determine which technology effectively removes the color creating visual impact
from the wastewater. Delta needs more time to accomplish this goal.
Fluctuations in dye (and bleach) use also make the 90% color reduction limitation arbitrary.
For instance, if, at the start of a study, dye production is higher than at the end of the study, there
will be less color present in Delta's wastewater. Likewise, during the production of optical whites,
bleach is used, and effluent color is diluted. Color reduction can thus be the result of dye (or bleach)
use fluctuations rather than a reflection of the success of the particular color removal technology.
DWQ's failure to consider this factor in establishing the 90% color reduction limitation
demonstrates its lack of technical basis in drafting Delta's color limitation.
3 The DWQ. also discovered the limitations of the ADMI methodology in quantifying the effluent's
color impact. DWQ acknowledged that "[d]uring data review, it was realized that ADMI color
measurements do not always predict the potential for a color impact." (See DWQ Color Policy, page
2).

John Robert Blowe
September 21, 2001
Page 8
In the absence of evidence supporting a specific percentage reduction to meet aesthetic
requirements in the South Fork Catawba River watershed, the percentage reduction within Delta's
draft permit is without basis and is arbitrary. DWQ simply has no data to support the condition in
Delta's draft permit.
III. The Draft Permit Color Limitation Is Not Technologically Feasible.
Delta's voluntary color removal tests demonstrate that the 90% color reduction between
influent and effluent is not technologically feasible. None of the above color trials demonstrated
Delta's ability to remove 90% ADMI color between influent and effluent (or even by a treated
effluent to untreated effluent comparison). Rather, each trial resulted in varying percentages of
removal comparing treated and untreated effluent. It is unknown at this time whether the
percentages obtained were in fact due to the employed color removal technology or were a result (or
combined result) of other variable factors such as dye use. The color removal trials did not generate
enough information to discover what percentage reductions are consistently obtainable.
Furthermore, the 90% color limitation between influent and effluent does not account for dye
use fluctuation. Even assuming that a 90% reduction could be met, the limitation requires Delta's
wastewater to contain a minimum quantity of dye. If Delta is producing optical whites, its
wastewater will have low ADMI color and Delta will not be able to achieve a 90% color reduction.
A 90% color reduction simply cannot be obtained in wastewater which has no or little color.
IV. The June 5 Color Policy Constitutes a Rule That Has Been Improperly Adopted.
As discussed above, Delta participated in the formation of the Alliance to monitor and study
color in the South Fork Catawba River watershed. Relying upon the data generated in the Alliance
study, DWQ developed its Color Policy. This "policy" contains standards for color reduction. As
such, the "policy" constitutes a rule.
A rule is "any agency regulation, standard, or statement of general applicability that
implements or interprets an enactment of the General Assembly...." Within the Color Policy,
DWQ implements state color laws and "establishes four tiers of action." The Color Policy places
Delta in Tier 4 and states that "Tier 4 facilities will receive color reduction limits (90% color
reduction between influent and effluent) to be implemented by the permit effective date." Delta's
draft permit even references the Color Policy in requiring a 90% reduction between influent and
effluent stating "[t]his facility was classified as a Tier 4 color discharger ... in the NPDES Color
Permitting Policy."
Therefore, in the Color Policy, DWQ concluded that Delta is a Tier 4 facility and "will
receive" a 90% color limitation. DWQ then incorporated the limitation into Delta's draft permit.
This limitation constitutes a color standard and therefore, as set forth above, is a rule. In North
Carolina, before a rule may be implemented, the regulated community public must have an

John Robert Blowe
September 21, 2001
Page 9
opportunity to comment. See North Carolina's Administrative Procedures Act, N.C. Gen Stat. §§
150 B-1 et seq. DWQ never sought comments on its Color Policy. Thus, DWQ's use of the Color
Policy as a rule violates North Carolina law and should not be permitted.
V. Delta Needs Additional Time to Adequately Determine What Color Removal
Reductions Are Consistently Achievable.
Delta is committed to improving the aesthetics of the South Fork Catawba River watershed.
As demonstrated by Delta's voluntary efforts to remove color before and after the formation of the
Alliance, Delta will continue to study color removal at its facility. At this time, for the reasons
discussed above, the technical data needed to produce a rational and considered color reduction
permit limitation does not exist and is affected by many variables which have not been adequately
studied by DWQ or Delta. Delta believes it will require 24,months to adequately determine what
color removal reductions are consistently achievable. DWQ has stated that it would instituted
enforcement action, i.e., seek penalties, if Delta violates any permit limitation. With the threat of
enforcement, Delta cannot accept a permit limitation which is arbitrary and not based upon adequate
technical data. Delta therefore requests a recommendation that its draft permit not contain any color
reduction permit limitation and that additional studies be conducted as appropriate over the next 24
month period.
matter.
We appreciate the opportunity to make these comments and your careful consideration of this
Very truly yours,
Lori P. Hinnant
ftv,,,y4PAA-04
cc Mr. Gene Hudgens

DEL TA
APPAREL, INCORPORATED
August 28, 2001
VIA HAND DELIVERY AND FACSIMILE (919-733-0719)
Mr. Tom Belnick
NPDES Unit
Division of Water Quality
North Carolina Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: NPDES Draft Permit
Permit No. NC0006190
Delta Apparel -Maiden Plant
Catawba County
Dear Mr. Belnick:
On behalf of Delta Apparel, Inc. ("Delta Apparel"), I am providing comments to the July
25, 2001 NPDES draft permit issued by the Division of Water Quality ("DWQ"), North Carolina
Department of Environment and Natural Resources ("DENR"), to our Maiden plant. We
respectfully request that these comments be made part of the record and considered prior to
issuance of our final permit. Specifically, Delta Apparel opposes the draft conditions relating to
the verification of color reduction of its effluent and the requirements for an Authorization to
Construct Permit.
At the outset, we should note, and DWQ acknowledges, that the color in Delta Apparel's
effluent is not and has not caused or resulted in a violation of any water quality standard or
adversely affected fish or aquatic life. The color of the effluent is simply a matter of aesthetics
and therefore is subjective and relative. In fact, DWQ said that: "The evaluation of color as an
aesthetic impact is difficult since it is a subjective determination. In addition, a host of actors,
such as hue, instream turbidity, suspended matter, dilution, light conditions, and downstream
access all play a part in determining when a color impact might be perceived by the public."
(DWQ June 5, 2001 NPDES Color Permitting Policy.) Despite the admitted uncertainties in this
area, Delta Apparel is committed to reducing color discharges in the South Fork Catawba River
Basin and more particularly, in its effluent discharge to Clark Creek. This commitment is
evidenced by the voluntary actions we have taken without a permit restriction.
In October 1999, we voluntarily participated in the formation of the South Fork Catawba
River Water Quality Alliance, Inc. ("Alliance") to study color in the South Fork Catawba River.
100 W. Pine Street • P.O. Box 37 • Maiden. N.C. 28650 • [phone] • FAX [phone]
Change your shirt.

Mr. Tom Belnick
August 28, 2001
Page 2
The Alliance is comprised of municipalities and industry. The DWQ requested that certain
criteria be considered in our study. We not only considered those criteria but additional factors
as well. As a result of the Alliance's study, DWQ developed its June 5, 2001 NPDES Color
Permitting Policy ("Color Policy"). The Color Policy establishes four tiers of action based on
DWQ's perception of the aesthetic color impacts to the receiving streams.
Prior to and simultaneous with participating in the color study with the Alliance, we
initiated a color reduction/removal program. First, we utilized a Clariant Corporation product but
it did not produce a significant color reduction. We then continued the reduction experiment
with other technologies. The subsequent experiments did not reduce color in the effluent the
degree we had hoped. We are currently conducting another study utilizing a color reducer from
Cytec Industries, Inc. This study involves the introduction of polymers and has thus far
produced positive results. We plan to continue to introduce polymers to reduce the color but also
study the effect, if any, this treatment has on other limitations in our permit.
As of yet, however, there is no available data that reliably demonstrates what minimum
degree of color removal at Delta Apparel is needed in order to improve the downstream aesthetic
water quality. This information is necessary so that Delta Apparel can optimize color removal
levels in relation to cost and technology.
Despite the lack of reliable and consistent data regarding color reduction, the draft permit
incorporates action contained in the Color Policy and demands that Delta Apparel achieve a 90%
color reduction between influent and effluent samples. This requirement is flawed for two
reasons.
First, it is our understanding that DWQ arrived at the 90% reduction standard based on its
perceived results of our voluntary reduction program. However, in all of our voluntary studies,
the company not once evaluated influent to effluent values. In fact, we compared one treated
effluent to untreated effluent utilizing the HACH DR 2000 Spetrophotometer Platinum Cobalt
color meter.
Second, the permit does not specify how we prove or quantify a 90% reduction. As
mentioned above, during our voluntary color reduction program, we analyzed the color in our
effluent utilizing the HACH DR 2000 Spetrophotometer Platinum Cobalt color meter. This
methodology was used in lieu of the American Dye Manufacturers Institute ("ADMI") testing
methodology. This distinction in methodology is important since DWQ developed the
restrictions in our permit from data developed under the ADMI methodology.
Simply put, the color restrictions contained in our draft permit are derived from the
DWQ Color Policy. In developing the Color Policy, DWQ relied exclusively on the data
compiled by the Alliance. The Alliance data was gathered utilizing ADMI methodology. Thus,

Mr. Tom Belnick
August 28, 2001
Page 3
the data contained in the Color Policy from which the restrictions in our draft permit were
developed have no correlation to the data developed under our voluntary program.
Further, the data developed by ADMI methodology has been criticized by DWQ as not
being representative of true color impact. As DWQ acknowledged in its Color Policy, ADMI
color measurements do not predict the potential for a color impact to the receiving stream. DWQ
said: "During data review, it was realized that ADMI color measurements do not always predict
the potential for a color impact." (DWQ Color Policy, page 2). According to DWQ's Color
Policy, a color plume with downstream aesthetic impact was observed at one facility on several
sampling events, although the effluent ADMI color was low and similar to upstream values.
DWQ therefore concluded that consideration of a numerical instream ADMI color standard
would be ineffective. DWQ concluded: "However, requiring some percentage reduction in
effluent color would help to minimize the size of the color plume. Conversely, some facilities
with greater colored effluent (e.g., Pharr Yarns and Yorkshire with summer averages of 844 and
3449 ADMI units, respectively) did not produce major instream color plumes, most likely due to
the effluent hue as well as the large dilution available. Therefore, in order to evaluate the data, it
was realized that no single criterion, but rather a combination of ADMI measurements,
photographs, and plume descriptions were needed to fully assess the instream color conditions."
(DWQ Color Policy, page 2).
The 90% reduction requirement is arbitrary. There is no data in the Color Policy to
support a percentage reduction standard. The Color Policy relied upon the Alliance report,
which reported ADMI units, not percentages. Nor has DWQ conducted any independent study
to conclude that the 90% reduction between influent and effluent samples is warranted,
achievable or feasible. Further, DWQ's statement in the draft permit that this 90% standard is
"technologically and economically feasible" has no basis in fact, especially since the results of
our voluntary color reduction program has never compared influent to effluent utilizing ADMI
technology.
Finally, Delta Apparel believes that a color requirement in its NPDES permit is
premature based upon its continued assessment and evaluation of data. In fact, the company's
most recent color testing was completed on August 15, 2001. Therefore, Delta Apparel
respectfully requests that it be allowed to continue its color reduction study with CYTEC and the
color restrictions be removed.
Sincerely,
Hudgens
Plant Manager

ATTACHMENT D
COMPARISON OF DATA FROM DELTA APPAREL, INC. TO OTHER COLOR
DISCHARGERS

Delta Mills Color Data-2001 Delta Mills Color Data-2000
NC0006190 NC0006190
Treated Percent Untreated
Date Influent Effluent Removal Date Effluent
ADMI ADMI % ADMI
7/24/01 3880 1060 73 4/11/00 1620
7/31/01 3590 1180 67 4/25/00 915
8/6/01 2550 763 70 5/16/00 1660
8/14/01 3150 963 69 5/31/00 1770
8/21/01 3220 883 73 6/13/00 1100
8/28/01 2360 748 68 6/27/00 1140
9/4/01 4640 362 92 7/11/00 1190
9/11/01 6680 728 89 7/25/00 1360
9/18/01-;'' 4510 821 82 8/8/00 1550
9/25/01 6040 909 85 8/22/00 1620
10/2/01 7730 775 90 9/6/00 1490
10/9/01 5190 546 89 9/19/00 1820
10/16/01 , : 6930 570 92 10/3/00 1340
10/23/01' 3150 516 84 10/17/00 1820
10/30/01 5770 496 91 11/14/00 2090 `
11/7/01 2250 1210 46
11/13/01 4140 662 84
11/20/01 10400 744 93
11/27/01 - 3050 827 73
12/4/01 4650 1070 77
min 2250 362 46 915
max 10400 1210 93 2090
avg 4694 792 79 1499
Notes:
1. All ADMI values at natural pH
2. For 2001 data, influent= composite sample and effluent=grab sample.
3. For 2000 data, untreated effluent= composite sample.

Summary of Color Reduction in North Carolina
Facility
Influent/or
Untreated Eff
(ADMI)
Treated Eff
(ADMI)
Percent Color
Reduction
(% reduction)
Treatment
Method
Volume
Treated
(MGD)
Treatment
Cost
($)
Bleach/Dye Mix
Flynt Fabrics
3000
200-400
87-93
reducing agent
0.5
$112,000 capital
40%bleach; 60% dyes
< I trk,
C !avian,` Ci`s r4c1
$103,500 O&M (300 d/yr)
d jt c. trf on w/ rea c.11,
America)
?
<50
?
polymer
0.15
$285,000 capital
?
Cone Mills
(Greensboro)
Cone Mills
$W (3"
3000
<100
>97
+ DM-
ultrafiltration+
polymer
ultrafiltration+
1.25
$135,000 O&M (300d/yr)
-4/Ae "�{
$895,000 capital ,r�6`
$250,000/yr O&M (»,01)
cQye fl y I" l $12GtD(
100% dyed denin —
re,
Iv(
(Cliffside)
3000
<100
>97
polymer+
AquaDisk filter
0.9
$1,500,000 capital
$60,000/yr O&M
100% dyed denim ,,
City of Eden
500-10,000
(Mebane)
avg 2,000
<100
>95
polymer
13.5
$100,000 capital •
? •
$651,000/yr O&M
3 textile inputs
Belmont Dyers
2900
<25
99
electrochemical +
polymer
0.5
A4,500,000 capital
$1,200,000 O&M (325d/yr)
5% bleach; 95% dyes
Delta Apparel
1436
?
?
polymer
1
?
?
Data Sources:
Color Reduction and Removal Seminar, Charlotte, NC, June 17, 1998
' K a rcdvc-(7/4//uoL co)of I^ }-14.,1A
,StIAAL.64 eau 1, a �( `Jr-/NF 0444 reek »
ch‘IP dye,
. Co')Y1 w/
IAe e- I h s4t5o
r'QQ LtI J t i- di'' Li-

City of Eden- Mebane WWTP
NC0025071
Effluent Color Limit = 300 ADMI instantaneous max
Effluent collected 3/Week for first year, and 3/Quarter thereafter
Treated Percent
Date Effluent Influent Removal
ADMI ADMI %
11/2/01 74 1200-2400 94-97
11/3/01 65 1200-2400 95-97
11/4/01 133 1200-2400 89-94
7/9/01 78 1200-2400 94-97
7/10/01 81 1200-2400 93-97
7/12/01 126 1200-2400 89-95
4/6/01 148 1200-2400 88-94
4/9/01 163 1200-2400 86-93
4/10/01 160 1200-2400 87-93
DaIf 1/9/01 135 1200-2400 89-94
1/10/01 158 1200-2400 87-93
1 /11 /01 136 1200-2400 89-94
Notes- based on conversation with ORC Terry Shelton (336-623-9921, ext 308) on 1/11/02:
1. Influent color generally averages 1200-2400 ADMI.
2. POTW currently treats - 6.5 MGD, of which - 4 MGD is from 3 textiles
3. Polymer cost is still - $600,000/year, which is billed back to the 3 textiles.
4. Polymer is only color treatment; they use liquid Stockhaeusen 188KE(?).
5. Influent color generally runs dark (deep purple, black).
6. Eden has been treating color since - 1992/93.

Page I-1
Permit No.: KY0062995
A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of this permit an lasting through the term of this permit
permittee is authorized to discharge from outfall serial number: 001, Municipal Discharge.
Such discharges shall be limited and monitored by the permittee as specified below:
EFFLUENT CHARACTERISTICS
Flow, Design (3.6 mgd)
Biochemical Oxygen Demand
(5-day), Carbonaceous
Total Suspended Solids
Fecal Coliform Bacteria, N/100
DISCHARGE LIMITATIONS
lbs/day Other Units(Specify)
Monthly Weekly Monthly Weekly Measurement Sample Sampling
Avg. A•yg• Avg. Avg. Frequency Type Location
MONITORING REQUIREMENTS
N/A N/A Report Report*** Continuous N/A Influent or
Effluent
751 1201 25 mg/1 40 mg/1 3/week Composite Influent &
Effluent
901 1351 30 mg/1 45 mg/1 3/week Composite Influent &
Effluent
N/A N/A 200 400 3/week Grab Effluent
Ammonia (as N) 120 180 4 mg/1* 6 mg/1* 3/week Composite Influent &
330 495 11 mg/1** 16.5 mg/1** Effluent
Dissolved Oxygen shall not be less than 7 mg/1 3/week Grab Effluent
Total Residual Chlorine (TRC) N/A N/A 0.011 mg/1 0.019 mg/1*** 3/week Grab Effluent
Biomonitoring shall not exceed 4.80 acute toxicity unit(s) See PART IV, Pages IV-1 and IV-2 Effluent
Chloride 43,585 6?,170 2531 mg/1 5062 mg/1*** 1/day Composite Effluent
Color, ADMI N/A N/A N/A 100 ADMI*** 1/day Grab Effluent
0.173 mg/1*** See PART I, Page I-2 Effluent
Copper, Total Recoverable N/A N/A N/A
Additional Parameters See PART I, Page I-2 Effluent
In addition to the specified limits, the monthly average effluent CBOD5 and suspended solids concentration shall. not exceed 15% of the respective month3
average influent concentration (85% removal).
The pH of the effluent shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored three times per week by gre
sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
The effluent shall not cause a visible sheen on the receiving water.
• Effective May 1 - October 31
** . Effective November 1 - April 30
*** Daily maximum limitation
fuer-04,4,y. /4:.1t7#• Cftfil9Vi�P .J�d�
bi(Ale IVel) iv ;1(i'k
to•
(T;
7:7,
•rwt•
•

A (1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - FINAL
0)1tflivv.) LI xi';3 )6/a
Permit No. NC0006190
During the period beginning after expansion above 1.0 MGD and lasting until expiration, the Permittee is authorized to discharge from outfall(s) serial number
001. Such discharges shall be limited and monitored by the Permittee as specified below:
Flow (MGD)
1.5
Daily Maximum.:
aria rem
equer
Continuous
BOD5
Total Suspended Solids
NH3-N
Dissolved Oxygen2,5
226 Lbs/day *✓ �'�
984 Lbs/day �f SDyMM r„ l 2.8 mg/I 1,5131,
550 Lbs/day rJ / 3/week
2400 Lbs/day ►'
COD
Chromium
Sulfide
Phenols
Settleable Solids
PH3
3600 Lbs/day
9 Lbs/day �,
4.5 Lbs/day ✓
8800 Lbs/day V
3/week
3/week
Weekly
Weekly
308 ug/I ! Weekly
22 Lbs/day ✓'/ Weekly
Weekly
11 Lbs/day ✓
Weekly
3/week
Recording
I or E
Composite
Composite
Composite
Grab
E
E, U, D
Composite
Composite
Grab
Grab
Grab
Grab
E
f'otal -Residual-Chlori ne4
Temperature °C5
Weekly
3/week
Grab
Grab
E
E, U, D
Total Nitrogen
Total Phosphorus
Copper
Zinc
Chloride
Sulfates
Monthly
Monthly
Conductivity5
Weekly
Weekly
Weekly
Weekly
3/week
Composite
Composite
Composite
Composite
Composite
Composite
Grab
E
E, U, D
Chronic Toxicity6
Quarterly
Composite
Notes:
1 Sample Locations: E - Effluent, I - Influent, U - Upstream at SR 2007, D - Downstream at SR 1274.
2 The daily average dissolved oxygen effluent concentrations shall not be less than 5 mg/I.
3 The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
4 Monitoring requirement applies only if chlorine is added for disinfection.
5 Instream monitoring for temperature, conductivity, and dissolved oxygen shall be conducted three times per week during of June, July, August and September, and once
per week during the rest of the year. Effluent monitoring shall be conducted three times per week for the term of the permit..
6 Chronic Toxicity (Ceriodaphnia) Phase II @ 16%; March, June, September, December. See Special Conditions A (3) of the Supplement to Effluent Limitations.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

A (1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - FINAL
Permit No. NC0006190
During the period beginning on the effective date of the permit and lasting until expansion above 1.0 MGD, the Permittee is authorized to discharge from
outfall(s) serial number 001. Such discharges shall be limited and monitored by the Permittee as specified below:
<::.:...::.:::..::.:.::.:..... ....: .:..:.........
.............................:......
.,Monthl
.. Averageer
Weekt
e::..:::.:...::.::::
Dail :.Maximum:
..:..:::_
; .Measurement; .....'<>`:::Sam
Frequency.,
le >
>:,Saris 18
aoatio .
Flow (MGD)
1.0
Continuous
Recording
I or E
BOD5
162 Lbs/day
f cr.1 17 t...)1
- 325 Lbs/day
3/week
Composite
E
Total Suspended Solids
785 Lbs/day ;.
/ SDp
1853 Lbs/day ,..
-' 3/week
Composite
E
NH3-N
3.0 mg/I
Cr7 ia.A
3/week
Composite
E
Dissolved Oxygen2,5
Weekly
Grab
E, U, D
COD
2900 Lbs/day
/
6800 Lbs/day i.
; Weekly
Composite
E
Chromium
of 7 j LIi
437 µg/1 ✓
Weekly
Composite
E
Sulfide
8.0 Lbs/day
c7 7 L/L'9
16.0 Lbs/day
Weekly
Grab
E
Phenols
4.0 Lbs/day
' 7 i4i L/i
8.0 Lbs/day
Weekly
Grab
E
Settleable Solids
Weekly
Grab
E
PH3
3/week
Grab
E
Weekly
Grab
E
Residualsehlorine4
Temperature °C5
3/week
Grab
E, U, D
Total Nitrogen
Monthly
Composite
E
Total Phosphorus
Monthly
Composite
E
Copper
Weekly
Composite
E
Zinc
Weekly
Composite
E
Chloride
Weekly
Composite
E
Sulfates
Weekly
Composite
E
Conductivity5
3/week
Grab
E, U, D
Chronic Toxicity6
Quarterly
Composite
E
Notes:
' Sample Locations: E - Effluent, I - Influent, U - Upstream at SR 2007, D - Downstream at SR 1274.
2 The daily average dissolved oxygen effluent concentrations shall not be Tess than 5 mg/I.
3 The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
Monitoring -requirement applies only if chlorine is added for disinfection.
5 Instream monitoring for temperature, conductivity, and dissolved oxygen shall be conducted three times per week during of June, July, August and September, and once
per week during the rest of the year. Effluent monitoring shall be conducted three times per week for the term of the permit..
6 Chronic Toxicity (Ceriodaphnia) Phase it @ 11 %; March, June, September, December. See Special Conditions A (2) of the Supplement to Effluent Limitations.
There shall be no discharge of floating solids or visible foam in other than trace amounts.