NC0005312_Permit Issuance_20050329

0 WAT�c�Q
March 29, 2005
Mr. Alex Moore, Director of Operations
Interface Fabrics Group South, Inc.
304 East Main Street
Elkin, North Carolina 28621
Michael F. Easley, Govemor
State of North Carolina
William G. Ross, Jr., Secretary
Department of Environment and Natural Resources
Alan W. Klimek P.E., Director
Division of Water Quality
Subject: Issuance of NPDES Permit NC0005312
Interface Fabrics Group South, Inc.
Elkin Facility
Surry County
Dear Mr. Moore:
The Division of Water Quality (the Division) hereby issues this final permit for the subject facility. This permit is
issued to the Interface Fabrics Group South, Inc. (Interface), 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.
Reestablishing Discharge Parameters of Concern. The Division acknowledges Interface's written request to
exclude from the permit certain discharge parameters unrelated to textile wastes (February 4, 2005). CMI, Inc.,
the wastewater treatment plant (WWTP) owner and local groundwater remediation responsible party, has
responded to Interface's letter stating that they wish to maintain the option to use tliis WWTP to treat future
groundwater remediation wastes (February 24, 2005). CMI, Inc. further states that, "The issue of whether
Interface wishes to treat contaminated groundwater with its industrial discharges should remain a contractual
issue between the parties as lessee and owner."
Upon review of Interface's renewal application, -the Division notes that the Permittee has identified several permit
parameters common to both textile processes and groundwater contaminants expected locally. These include
chloroform, benzene, and ethylbenzene. However, toluene and 1,1 dichloroethane are not "expected to be present"
in textile wastes and appear relic to the previous permit. Therefore, the Division has removed toluene and 1,1
dichloroethane from the final permit. It follows that chloroform, benzene, and ethylbenzene shall remain in the
permit as drafted (see revised A. (1.) Effluent Limitation and Monitoring Conditions).
Please be advised that, should Interface decide to include contaminated groundwater for future treatment with
existing permitted flows, the Permittee must submit a request to the Division to modify this permit. In response to
this request, the Division will likely require a suite of analyses and monitoring schedules, based on best
professional judgment, sufficient to establish full waste characterization. This suite may include, but may not be
limited to, volatile compounds, semi -volatile compounds, and metals, based on similar projects statewide.
Applying Effluent Guidelines. For this renewal, the Division considered applicable technology -based federal
regulations for Textile Mills Point Source Category (40 CFR 410) together with North Carolina's water quality
stream standards and criteria. The Division understands that there were no significant changes in treatment -system
processes except for adjustments to production, as provided by your corporate environmental officer, Jamie
Iuliano, on November 17, 2004.
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone]
NCDEHR
Customer Service
1 800 623-7748

Interface Fabrics Group South, Inc. -- Elkin Facility
Issuance of NPDES Permit NC0005312
Page 2
The Division has reviewed these production data and recalculated limits accordingly [see permit Effluent
Limitations and Monitoring Requirements, A.(1)]. Changes from the previous permit are summarized here:
• BODs, COD, TSS, Sulfides, Phenols, and Chromium — Mass -based limits have been
recalculated for this renewal, based on revised production data provided by the Permittee.
• Mercury, selenium, barium, and fluorine -- removed from the permit based on the absence of
reasonable potential to exceed North Carolina water quality standards.
Concerning Fecal Limits — The Division acknowledges your request to modify your fecal coliform permit limits
from Daily Maximum limits to Weekly Average limits. Although Interface Fabrics does receive a small portion of
its flow from the Town of Elkin, Weekly Average limits are reserved for municipal discharges only (15A NCAC
2B.0500 rules). This request is therefore denied.
If any parts, measurement frequencies, or sampling requirements contained in this permit are unacceptable, you
have the right to an adjudicatory hearing, upon written request submitted within thirty (30) days after receiving this
letter. Your request must be in the form of a written petition conforming to Chapter 150B of the North Carolina
General Statutes, and must be 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.
This permit is not transferable except after notifying the Division of Water Quality. The Division may require
modification, or revocation and re -issuance of this permit. Please notice that this permit does not affect your legal
obligation to obtain other permits required by the Division of Water Quality, the Division of Land Resources, the
Coastal Area Management Act, or other federal or local governments.
If you have questions, or if we can be of further service, please contact Joe Corporon at [Joe.Cori oron(a�ncmail.net]
or call [phone], extension 597.
Respectfully.
ORIGINAL SIGNED BY
Mark McIntire
Alan W. Klimek, P.E.
Enclosure: NPDES Permit NC00053 12
cc: Winston-Salem Regional Office, Water Quality Section
NPDES Unit
Aquatic Toxicology Unit
EPA Region 4, Attention Marshall Hyatt

i Pernut NC0005312
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
(NPDES)
In compliance with the provisions 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,
Interface Fabrics Group South, Inc.
is hereby authorized to discharge wastewater from a facility located at the
Interface Fabrics Group South, Inc.
304 East Main Street, Elkin
Surry County
to receiving waters designated as the Yadkin River located within the Yadkin Pee -Dee River Basin in
accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts
I, II, and III hereof.
This permit shall become effective May 1, 2005.
This permit and authorization to discharge shall expire at midnight on December 31, 2008.
signed this day March 29, 2005.
ORIGINAL SIGNED BY
Mark McIntire
Alan W. Klimek, PE, Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit NC0005312 •
4
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are
hereby revoked, and as of this issuance, any previously issued permit bearing this number is
no longer effective. Therefore, the exclusive authority to operate and discharge from this
facility arises under the permit conditions, requirements, terms, and provisions described
herein.
Interface Fabrics Group South, Inc.
is hereby authorized to:
1. continue to operate an existing 4.0 MGD extended aeration system treating combined
industrial wastewater and contaminated groundwater, consisting of
• a manual bar screen, fine screening, pH adjustment using lime
• equalization basin,
• aeration basin
• dual clarifiers
• gas chlorination with chlorine contact chamber
• post -chlorination aeration tank,
• aerobic digester, and sludge drying beds
located at Interface Fabrics Group Inc., 304 East Main Street, Elkin, Surry County, and
•
2. discharge from said treatment works at the location specified on the attached map into the
Yadkin River classified Class C waters in the Yadkin -Pee Dee River Basin.

Interface Fabrics Group South, Inc.
Elkin Facility
State (;rid/Quad: C 15 NE / Elkin South, NC Permitted Flow: 4.0 MGD
Receiving Stream: Yadkin River Sub -Basin: 03-07-02
Stream Class: C Drainage Basin: Yadkin -Pee Dee River Basin
Outfall 001
Lat 36° 14' 40"
Long 80 ° 50' 22"
(discharge flows east)
North
NPDES Permit No. NC0005312
Curry County

•
Permit No. NC0005312
A (1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is
authorized to discharge from Outfall 001. Such discharges shall be limited and monitored by the Permittee as
specified below:
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Weekly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample
Location]
Flow
4.0 MGD
Continuous
Recording
I or E
BOD, 5 day, 20°C
479 lbs/day
9581bs/day
Daily
Composite
E
COD
5,617 lbs/day
11,233 lbs/day
Weekly
Composite
E
Total Suspended Solids
1,221 lbs/day
2,443 lbs/day
Daily
Composite
E
Sulfides
16 lbs/day
33 lbs/day
2 / Month
Grab
E
Phenols
7 lbs/day
17 lbs/day
2 / Month
Grab
E
Chromium
7 lbs/day
17 lbs/day
2 / Month
Composite
E
Fecal Coliform
(geometric mean)
200 / 100 ml
400 / 100 ml
2 / Month
Grab
E
Total Residual Chlorine
28 µg/L2
Daily
Grab
E
pH 3
Daily
Grab
E
Temperature
Daily
Grab
E
Total Nitrogen (NO2 +
NO3 + TKN)
Weekly
Composite
E
Total Phosphorus
Weekly
Composite
E
Chronic Toxicity 4
Quarterly
Composite
E
Total Lead 5
Quarterly
Grab
E
Total Arsenic 5
Quarterly
Grab
E
Benzene 5
Quarterly
Grab
E
Ethylbenzene 5
Quarterly
Grab
E
Chloroform 5
Quarterly
Grab
E
Footnotes:
1. Sample locations: I = Influent; E = Effluent
2. Compliance with this limit shall commence 18 months after the permit effective date. The permittee shall
monitor for chlorine only if chlorine is used at the facility.
3. Effluent pH shall not fall below 6.0 nor exceed 9.0 standard units.
4. Chronic Toxicity (Ceriodaphnia) P/F at 1.9%; February, May, August, November; See Special
Condition A.(2).
5. Monitoring shall coincide with whole effluent toxicity sampling; analyses by North Carolina -certified
analytical methods shall utilize the lowest available practical quantitation levels (PQLs).
Units: MGD = million gallons per day
lbs/day = pounds per day BOD = biochemical oxygen demand
m1= milliliter pg/L = micrograms per liter
Discharge shall contain no floating solids or foam visible in other than trace amounts.

qr
SUPPLEMENT TO EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS
A. (2.) CHRONIC TOXICITY PERMIT LIMIT (QUARTERLY)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to Ceriodaphnia
dubia at an effluent concentration of 1.9 %.
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 February, May, August, and November. 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 nunimum, 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:
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 competed no later than the last day of the month
following the month of the initial monitoring.

Re: Interface Fabrics -- NC0005312 DRAFT
f
Subject: Re: Interface Fabrics -- NC0005312 DRAFT
From: [e-mail]
Date: Thu, 03 Mar 2005 09:21:26 -0500
To: Joe Corporon <[e-mail]>
sorry about that! I have no comments. Will this email suffice or
would you like a letter?
1 of 1
3/3/2005 9:24 AM

Feb ,24 05 04:29p BPA ENV & ENG
336 273-4057 p.l
BPA Environmental & Engineering, Inc.
February 24, 2005
Mr. Joe Corporon
NC DENR, DWQ
NPDES Permit Section
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: NPDES Permit Renewal - NC 0005312
Interface Fabrics Group WWTP
BPA Project No. 0216.008
Dear Mr. Corporon:
This letter is in reference to BPA correspondence to your office dated March 26, 2004 regarding the
subject Permit and recent correspondence to your office regarding the Permit renewal from Jamie Iuliano,
Interface Fabrics, Elkin, dated February 4, 2005.
As indicated in the Interface letter, the wastewater treatment plant property (WWTP) is currently owned
by CMI. Interface is the current operator of the WWTP under a services agreement executed between
CMI and Interface at the time Interface purchased most of the CMI facilities in Elkin. That agreement can
be terminated by either party and the operation of the WWTP would return to the control of CMI as owner
of the plant. In addition, the agreement between CMI and Interface explicitly provides for the treatment
of "wastewater associated with remediation of contamination" and includes specifications on notice prior
to the discharge of such wastewater into the WWTP and other requirements. The clear understanding of
the parties in executing this agreement was that it included future treatment of contaminated groundwater.
Investigation and remediation of the chlorinated solvents underlying the property is being conducted by
CMI under a voluntary remedial action program thru an Administrative Agreement for Registered
Environmental Consultant -Directed Assessment and Remedial Action with the IHSB of NC DENR dated
March 11, 2004. BPA Environmental & Engineering, Inc. is currently the REC for the ongoing
investigations/remedial actions. The REC Program Remedial Investigation Workplan for the WWTP
property was submitted to Mr. Kim Caulk of the IHSB on March 31, 2004.
Extensive soil and groundwater investigations of the WWTP parcel were conducted by SPATCO, BPA,
ENSR, and Sevee & Maher during the period 1991-2002. Results of the 1991-2002 Phase I
2641-G Randleman Road, Greensboro, NC 27406-5159 • Phone [phone] • Fax [phone]

Feb 24 05 04:29p BPA ENV & ENG
336 273-4057
p.2
Mr. Joe Corporon
February 24, 2005
Page 2
soil/groundwater investigations conducted at the WWTP property have identified a groundwater plume of
dissolved chlorinated volatile organic compounds (VOCs) which exceed 15A NCAC 2L Standards beneath
portions of the floodplain of the WWTP property. The plume consists predominately of 1,1,1-
trichloroethane ( 1,1,1 TCA), and its degradation products 1, I-dichloroethane (1,1 DCA), and 1,1-
dichloroethylene (1,1 DCE). The plume is aligned along the banks of the Yadkin River to the south and
southwest of the Equalization Basin. The solvents are known to occur in the regolith and shallow
bedrock aquifers in both dissolved and DNAPL phases (Figures 1 and 2). The source(s) of the solvent
plume have not been clearly identified. The vertical and horizontal extent of the solvent plume within
the deeper portions of the bedrock aquifer has also not been well defined.
Phase II investigations to locate and delineate potential sources, to further assess the vertical and
horizontal extent of solvents within the regolith and bedrock aquifers, and to support risk assessment of
the WWTP parcel will be performed as part of the REC investigative phase(s).
Proposed remedial activities will be dependent on the results of the Phase II investigations and the risk
assessment of the WWTP property. Should the investigations identify a buried waste source, the source
materials and any associated contaminated alluvial or regolith materials will be removed to the extent
possible. Presuming the risk assessment indicates negligible impacts to receptors upon source removal
and that groundwater quality data indicates an active environment for the natural degradation of the
solvents, monitored natural attenuation (MNA) may be a feasible remedial option.
Should a defined waste source not be present, and/or existing solvent concentrations and groundwater
chemistry not support MNA, evaluation of active groundwater treatment options will also be made.
Remedial options may include installation of an alignment of pump and treat barrier wells along the river
combined with air sparging of hot spots within the plume and continued active recovery and treatment
until contaminant levels are reduced to concentrations where sustained MNA can be demonstrated to be
viable.
As part of the Phase 11 investigations, geophysical and soil vapor surveys of the floodplain area were
conducted during 2004. Test pit exploration of suspected source areas and drilling and sampling of
supplementary monitoring wells are scheduled for 2005.
It is unknown at this time whether or not limited pump and treat remediation of hot spots will be necessary
to reduce concentrations of VOCs to levels where MNA is a viable remedial option. The Interface request
to remove treatment of contaminated groundwater from permitted uses of the WWTP facility presupposes
the final results of the REC Phase II remedial investigations and consequent preferred remedial actions.
Should active groundwater remediation be required, the cost of a stand-alone pump and treat system could
total $250,000 plus permitting, maintenance, and monitoring costs. Maintaining the Permit provision
authorizing the treatment/discharge of contaminated groundwater, along with the 4 MGD of industrial

Feb 24 05 04:29p BPA ENV & ENG
336 273-4057
p.3
Mr. Joe Corporon
February 24, 2005
Page 3
wastewater, could save the unnecessary and significant future expenditure of limited escrow cleanup funds
for a stand -along groundwater treatment system. The issue of whether Interface wishes to treat
contaminated groundwater along with its industrial discharges should remain a contractual issue between
the parties as lessee -operator and owner. BPA/CMI have no issue with modifying the effluent monitoring
schedule to reflect the actual constituents of concern, perhaps allowing for the monitoring of the
constituents of concern only upon startup and operation of any active groundwater pump and treat system,
should a system be required at some future date.
Please contact me if you have any questions or need any additional information. We would also appreciate
having an opportunity to meet with you if DWQ is inclined to eliminate the provision on treating
contaminated groundwater from the Permit, prior to issuance of the final Permit. Thank you for your time
and attention on this matter.
Sincerely,
BPA ENVIRONMENTAL & E GINEERING, INC.
R. Edward Hed, ecock, P.E., P.G.
Principal
cc: Jim Ovenden, CMI
Jamie Juliano, Interface
Kim Caulk, IHSB
Charlie Carter, McNair Law Firm

PARCEL 2
CMI FLYASH DISPOSAL
AREA PROPERTY
CHATHAM, INC. PROPERTY
h
Y MW-01-2
MWE-
FLYASH
BASIN
FAMW-
(BQL)
9
MWE-2
� 1
0
FPMW-3
(BQL)
B
FPMW-2
Yp.DKNR,VtiR
FLOC) A
�yer-- EBMvIIT
O 1992)
MW-01-1 i & MAIIER)
I fg7
4,, (153,139.3)
? /BILLION (PPB)
USYR
'OUR
NOTES: BASE MAP AFTER SPATCO ENVIRONMENTAL
SERVICES DRAWING NO. 9-1790, FIGURE 2
MONITORING WELL LOCATIONS AFTER BUNN
ENGINEERING SURVEY MAP, PROJECT NO.
B020603; 6/8/04. LOCATIONS ARE APPROXIMATE
50
0
100
150
APPROXIMATE SCALE IN FEET
CMI INDUSTRIES, INC.
BPA Environmental & Engineering, Inc.
ISOCONCENTRATION MAP OF TOTAL
VOCs IN OVERBURDEN WELLS
MARCH 2004
FIGURE I

v
CHATHAM, INC. PROPERTY
•MW-01-2
FLOOD PLAIN
l lUSYR
MW-01-1
1
MWE-9
\7 >
PARCEL 2
CMI FLYASH DISPOSAL
AREA PROPERTY
MWE-2
1
FLYASH
BASIN IS
FPMW- 2
/
h) FAMW-1
EBMW
® 1992)
MAHER)
LLION (PPB)
JR
FPMW-3
NR�v�R
�( ADK
NOTES: BASE MAP AFTER SPATCO ENVIRONMENTAL
SERVICES DRAWING NO. 9-1790, FIGURE 2
MONITORING WELL LOCATIONS AFTER BUNN
ENGINEERING SURVEY MAP, PROJECT NO.
B020603; 6/8/04. LOCATIONS ARE APPROXIMATE
50
0
100
150
APPROXIMATE SCALE IN FEET
CMI INDUSTRIES, INC.
BPA Environmental & Engineering, Inc.
ISOCONCENTRATION MAP OF TOTAL
VOCs IN SHALLOW BEDROCK WELLS
MARCH 2004
FIGURE 2

Interfa
Interface Fabrics
304 East Main Street
Elkin, North Carolina 28621
336.835.2211
336.526.2037 fax
February 4, 2005
Mr. Joe Corporon
NPDES Unit
North Carolina Department of Natural Resources
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
;, f
RE: NPDES Wastewater Permit Renewal for Interface Fabrics, Elkin (NC0005312)
Dear Mr. Corporon,
Pursuant to our phone call on January 18, 2005, Interface Fabrics (Interface) is formally
commenting on the draft NPDES Wastewater Permit NC0005312 originally received on January
10, 2005 as revised January 18, 2005. Interface's response comments on the revised draft permit
attached to the January 18, 2005 e-mail.
Interface recognizes and accepts that the proposed permit limitations represent a significant
reduction in effluent limits applicable to the facility. Interface also recognizes and accepts that it
must engineer, permit, and install a de -chlorination system within eighteen months of the issuance
of the final NPDES permit. We appreciate the flexibility provided by the Department in setting
this schedule.
Regarding the effluent monitoring requirements for Other Pollutants of Concern, the Fact Sheet
notes that these pollutants are included as part of an ongoing groundwater remediation for
petroleum hydrocarbons, and therefore shall remain in the permit. Interface respectfully requests
elimination of this monitoring requirement based upon the history of testing for these chemicals at
this site.
GohY).K Os. 1-GAsM-
The wastewater treatment plant IL) ' ���rtPnrty is man d by CMt Ind The facility is operated
ye. The property has been identified as an Inactive Hazardous Substances site due to
historical waste disposal activities, and current groundwater issues are being managed by that
division of DENR. CMI was identified as the responsible party the wastewater treatment plant
property contamination, and it subsequently entered into an agreement with NCDENR for full
remediation of the wastewater treatment plant property. CMl has engaged a Registered
Environmental Consultant (BPA) to oversee the remediation of the property.
Detailed investigations have been conducted at the wastewater treatment plant property for the last
11 years. During this process, the wastewater treatment system was evaluated as a potential
source of pollutants to groundwater and was affirmatively excluded as a source.
Environmental studiesconducted by CMI during the 1990s, and due -diligence investigations of
the property by Interface in 2001 detected chlorinated solvents in soil and in groundwater beneath
portions of the wastewater treatment plant property along the north floodplain of the Yadkin
River, resulting from previous waste disposal activities. Groundwater monitoring identified a
plume of dissolved chlorinated solvents in this area with concentrations of several VOCs greater
than North Carolina NCAC 2L Groundwater Quality Standards. Dense non -aqueous phase liquid
(DNAPL) was found in well EBMW-12. Water quality results from groundwater monitoring in
the floodplain show that except for one aromatic hydrocarbon, chlorinated VOCs dominate the

However, should the Department determine that additional effluent monitoring is required as part
of the permit, Interface requests that the monitoring parameters be modified to include only the
relevant pollutants of concern for the property. Specifically, Interface asks that the list of
monitored pollutants be modified to include only 1,1,1-TCA, 1,1-DCA, and 1,1-DCE; deleting
benzene_ toluene. ethylbenzene, and chloroform. Mr. Kim Caulk of NCDENR Inactive Hazzaarlous
Sites branch is the DENR contac�erson of r this_site. We have briefly consulted with him on this
issue, and request that he should be included in the Department's consideration of this request.
We have copied him on this letter.
In summary, given the elimination of the wastewater treatment facility as a source of the
groundwater contamination and the decision not to treat contaminated groundwater at the facility,
Interface believes the inclusion of the pollutants of concern in Interface's NPDES permit is no
longer necessary. Interface respectfully requests deletion of this monitoring requirement. If the
Department determines that additional effluent monitoring is required as part of the groundwater
activities, Interface requests that the monitoring parameters be modified to include the relevant
pollutants of concern from the pmp> inclusion of l,l I-TC'A, t,l_I)CA and 1 1-DCE; deLgti
orbenzene, toluene, ethylbenzene, and ihlnrnfnrm)
If you have any question regarding any of the above referenced information, please contact me at
336-526-0383 or via email at Jamie.iulianona,interfacefabrics.com. I look forward to your
response.
p-eN I act✓ Wit
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chemical profile of the groundwater beneath the floodplain to the east of the so-called "west
stream." Overall, recent water quality results have shown that concentrations of TCA and its
degradation by-products 11 DCE and I I DCE in particular have substantially decreased in the
solvent plume over the last couple of years. This is apparent in both the overburden and bedrock
groundwater quality.
At one time, the wastewater treatment plant was considered as a potential method of remediation
for the contaminated groundwater by CMI. The NPDES permit was revised at the request of CMI
to allow treatment of the contaminated groundwater at the facility. Interface does not desire to
treat contaminated groundwater at the facility. Therefore, because the facility is not a source of A..fa `' '
the groundwater contamination and will not be used to treat mundwater�Interface believes ''��(cLE) DEA
inclusion of the pollutants of concern in Interface's NPDES permit are no longer necessary.
Interface respectfully requests deletion of this monitoring requirement from the pending permit. _ w46 fe_
diOfTan
-to 40e-ai
Sincerely,
Jamie lu iano
Environmental Manager
Interface Fabrics, Elkin
Cc: Wendy Porter, Director of Environmental Management, Interface Inc.
Alex Moore, Director of Operations, Interface Fabrics, Elkin
Kim Caulk, NCDENR Inactive Hazardous Substance Sites
Ed I ledgecock, BPA, REC for CMI Remedial Activities
occc_ ' cw ��-4(sw4 bFs �i e14�4e3 LOE,
ley will ��-b1 ( eg16-6
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REGIONAL OFFICE COMMENTS
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NPDES SUPERVISOR: DATE:
JAN 1 8 �nnF JAN 1 2005
DENR - WATER QUALITY
POINT SOURCE BRANCH
Pact Sheet
Renewal -- NPDES NC0005312
Pag 6
0
Amami

Table 9.
Toxicants -- Summary of Acute Reasonable Potential Analysis
Parameter
Samples
(n)
Hits
(n)
Maximum
Predicted
Allowable
Concentration'
RP
y/n
Comments
Flow
—
—
—
—
—
4.0 MGD used for RPA
Total Arsenic
11
8
402.6 lbs.
Not Applicable
—
No acute criteria
Total Lead
11
2
20.3 µg/L
34 µg/L
No
See Table 8
Total Mercury
11
0
Not detected
-
—
No acute criteria
Total Selenium
11
1
8.5 µg/L
56 µg/L
No
See Table 8
Other Parameters of Concern (POC). Other organic compounds remain POCs because they are
unnatural to the local environment and relate to an ongoing onsite groundwater remediation for
petroleum hydrocarbons. The following therefore shall remain in the permit: benzene, toluene,
ethylbenzene, chloroform, and 1,1 dichloroethane (DCA). As previously permitted, these parameters
shall be monitored Quarterly and do not have permit limits. Concerning Barium and Fluorine, North
Carolina's barium standard exists for WS (water supply) waters only. Fluorine has no standard.
Therefore, these parameters shall be removed from the permit.
RENEWAL SUMMARY
• BOD5 , COD, TSS, Sulfides, Phenols, and Chromium — Mass -based limits have been
adjusted (lowered) for this renewal based on revised production data, in accordance with EPA
guidance.
• mercury, selenium, barium, and fluorine -- removed from the permit based on reasonable
potential.
PROPOSED SCHEDULE OF ISSUANCE
Draft Permit to Public Notice:
Permit Scheduled to Issue:
NPDES UNIT CONTACT
If you have que
contact Joe Co
egard.
January 5, 2005.
March 1, 2005
y of the above information or on the attached permit, please
5083 ext. 597.
-� y16 ��5
NAME:%r ! DATE:
Fact Sheet
Renewal -- NPDES NCt0053I2
Page 5

Corrections to Draft Permit -- NC0005312
Subject: Corrections to Draft Permit -- NC0005312
From: Joe Corporon <[e-mail]>
Date: Tue, 18 Jan 2005 11:25:04 -0500
To: Marshall Hyatt <[e-mail]>
CC: Mark McIntire [e-mail]>, jamie.iuliano
terfacefabricsgroup.com
Marshall -- please see attached corrections to Fact Sheet and permit EFF page -- You may have already caught these, but I made some
calculation errors for CBOD and TSS (see Fact Sheet Tables 3 and 7). We've also added a typical compliance schedule (18 months) to
accomodate the new TRC limit.
Thanks,
Joe
05312 -- EFF FINAL.doc
Content -Encoding: base64
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'05312 Interface -- Fact Sheet FINAL.doc Content -Type: application/msword
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1 of 1 1/18/2005 11:28 AM

Draft Permit reviews (3)
Subject: Draft Permit reviews (3)
From: John Giorgino <[e-mail]>
Date: Wed, 12 Jan 2005 14:26:12 -0500
To: Joe Corporon <[e-mail]>
Hi Joe,
I have reviewed the following:
NC0037508 - Moore County
NC0026000 - Tabor City
NC0005312 - Interface Fabrics
DtircT►04117 Pf-(6)
76'6 a(c—
NC0037508- Moore County: footnote #7 from Section A(1) lists the chr lim @ 2.6%. The chr lim should be 41%. SIn
section A(3) it is correct.
Thanks for forwarding the permits to me.
John
1 of 1
1/13/2005 6:53 AM

NORTH CAROLINA
SURRY COUNTY
AFFIDAVIT OF PUBLICATION
Before the undersigned, a Notary Public of said County and State, duly
commissioned, qualified and authorized by law to administer oaths,
personally appeared Ferris W. Simpson who being first duly
sworn, deposes and says: that he (she) is Business Manager
(Publisher or other officer or employee authorized to make affidavit) of
MOUNT AIRY NEWSPAPERS, INC., engaged in the publication of a
newspaper known as MOUNT AIRY NEWS, published, issued, and
entered as periodicals class mail in the city of Mount Airy in said County
and State; that he (she) is authorized to make this affidavit and sworn
statement; that the notice or other legal advertisement, a true copy of
which is attached hereto, was published in MOUNT AIRY NEWS on the
following dates:
9-a M,_LG(-'1--
and that the said newspaper in which such notice, paper, document or
legal advertisement was published was, at the time of each and every
such publication, a newspaper meeting all of the requirements and
qualifications of Section 1-597 of the General Statutes of North Carolina
and was a qualified newspaper within the meaning of Section 1-597 of
the General Statutes of North Carolina.
This ' 1 day of
ignature of person making affidav
Sworn to and subscribed before me, this
, 2005
Notary Public
My Commission expires: August 17, 2009
, 2005
day of
Official Seal
Sandra V Sutphin
Notary Public - North Carolina
Sum. County
PUBLIC NOTICE
STATE OF NORTH
CAROLINA
ENVIRONMENTAL
MANAGEMENT
COMMISSION/ NPDES ,
1617 MAtLUNIT SERVICE
CENTER
RALEIGH, NC
27699-1617
NOTIFICATION OF
/' INTENT TO ISSUE A
NPDES WASTEWA-
TER PERMIT
On the basis of thor-
ough staff review and
application of NC Gen-1
eral Statute 143.21,
Public law 92-500 and
other lawful standards
and regulations, the
North Carolina Environ- .
I mental Management
Commission proposed
to issue a National Pol-
lutant Discharge Elimi- j
nation System (NPDES)
wateswater discharge
permit to the person(s)
listed below effective 45 •
days from the publish
date of this notice.
Written comments re-
garding the proposed
permit will be accepted
until 30 days after the
publish date of this no-
tice. At comments re-
ceived prior to that date
are considered in the fi-
nal determinations re-
garding the proposed'
• permit. The Director of
the NC Division of Wa-
ter Quality may decide I
to hold a public meeting
for the proposed permit
should the Division re-
ceive a significant de- j
gree of public interest.
Copies of the draft per-
mit and other supporting
information on file used
to determine conditions
present in the draft per-
mit are available upon
request and payment. of
• the cost of reproduction.
Mail comments and/or
request for information
to the NC Division of
Water Quality at the
' above address or call
Ms Carolyn Bryant at
[phone], exten-
sion 520. Please in-
clude the NPDES per-
, mit number (attached)
in any communication.
' Interested persons may
also visit the Division of
Water Quality at 512 N.
Salisbury Street, Ra-
i leigh, NC 27604-1148
between the hours of
8:00 a.m. and 5:00 p.m.
to review information on
file.
Interface Fabrics Group
South, Inc.
(NC0005312) located in
Sorry County, has ap-
plied for renewal of its
permit discharging 4.0'
MGD of treated waste-1
water to the Yadkin Riv-
er, within the Yadkin
River Basin, Fecal Coll -
form and Total Residual
Chlorine (TRC) are wa-
ter quality limited. This
discharge may in affect ,
future wasteload elloca- i
tion to the receiving
stream.
January 7, 2005

IFG Draft - NC0005312
Subject: IFG Draft - NC0005312
From: Mike Mickey <[e-mail]>
Date: Thu, 06 Jan 2005 15:28:54 -0500
To: Joe Corporon <[e-mail]>
Joe - The draft permit has a 28 ug/1 residual chlorine limit. The cover letter didn't mention this change. Should they be given 18 months to
comply? Otherwise, everything else looked fine.
Mike.
Mike Mickey
NC DENR Winston-Salem Regional Office
Division of Water Quality, Water Quality Section
585 Waughtown Street
Winston-Salem, NC 27107
Voice: [phone] ext 289
FAX: [phone]
1 of 1 1/7/2005 7:09 AM

DENR / DWQ / NPDES Unit
FACT SHEET FOR NPDES PERMIT
NPDES Permit NC00053 12
INTRODUCTION
Interface Fabrics Group, Inc. (also herein referred to as IFG or the permittee) requires a National Pollutant
Discharge Elimination System (NPDES) permit to dispose treated wastewater to the surface waters of the
state. The permittee's 5-year NPDES permit has expired and they have requested renewal from the Division
of Water Quality (the Division). This Fact Sheet summarizes background information and rationale used by
the Division's NPDES Unit to determine permit limits and conditions. This document also contains
references to information sources relevant to this permit renewal.
FACILITY RECORDS REVIEW
Facility Description. IFG (Table 1) is a synthetic textile weaving and fmishing facility discharging treated
process -contact wastewater to a single outfall. Process discharges are permitted to 4.0 MGD regulated
under technology -based federal guidelines 40 CFR 410.50, Subparts C, D, E, G, and H (see Permitting
Approach / Federal Regulations). Guidelines specifically applicable include 410.5 1(b) defining a complex
manufacturing operation. The wastewater treatment system consists of combined industrial wastewater and
contaminated groundwater, consisting of a manual bar screen, fine screening, pH adjustment using lime,
equalization basin, aeration basin, dual clarifiers, gas chlorination, a chlorine contact chamber, post -
chlorination aeration tank, aerobic digester, and sludge drying beds.
Table 1.
Interface Fabrics Group South, Inc
Facility Information
Applicant/Facility Name
Interface Fabrics Group South, Inc., Elkin Facility
Applicant Address
P.O. Box 179, 9 Oak street, Guilford, ME 04443
Facility Address
304 East Main Street, Elkin North Carolina 28621
Permitted Flow (MGD)
4.0 MGD
Type of Waste(s)
— 92 % Industrial process wastewater; - 8 % domestic sewer.
Facility/Permit Status
Class III, Major / Renewal
Drainage Basin / County
Yadkin -Pee Dee River Basin / Surry County
Miscellaneous
Receiving Stream
Yadkin River
Regional Office
Winston-Salem
Stream Classification
C
State Grid /
USGS Topo Quad
C 15 NE /
Ellin South, NC
303(d) Listed?
Not listed
Permit Writer
Joe R. Corporon
Subbasin
03-07-02
Date:
05Jan05
Drainage Area (sq. mi.)
870
. -++
Lat. 36° 14' 40" Long. 80° 50' 22"
Summer 7Q10 (cfs)
314
Winter 7Q10 (cfs)
450
30Q2 (cfs)
Average Flow (cfs)
1390
IWC (%)
1.9 %
Fact Sheet
Renewal -- NPDES Permit NC0005312
Page 1

PERMIT HISTORY AND COMPLIANCE REVIEW
Previous Permit and Waste Load Allocation (WLA). Division WLA records for IFG date from
1986. The latest permit became effective September 1, 1999 and expired on January 31, 2004. The
Division prepared a WLA in February 1994 and developed effluent limits and monitoring considering
an in -stream waste concentration (1WC) of 1.9 %. The permit was modified several times during the
previous cycle to: reflect owner change; revise TN and TP monitoring from monthly to weekly; revise
the Division's expiration date. The Division received an application to renew (Standard Form 2C and
supplements) on August 1, 2003.
Whole Effluent Toxicity (WET) Tests and Notices of Violation (NOVs). 1FG (formerly CMI, Inc.) has
experienced no failed toxicity tests during the Division's period of record (since before January 1997).
Division records document "pass" through February 2004 (25 calendar quarters).
Verifying Existing Stream Conditions. The Division has verified that this facility discharges to the
Yadkin River [stream segment 12-53], a Class C stream within the Yadkin -Pee Dee River Basin. This
stream segment is not "impaired" [not 303(d) listed]. No stream segments within this subbasin were rated
impaired based on recent stream monitoring (1998-2001), however some impacts to water quality were
observed.
Review of Production Data. The Permittee supplied annual production data for four years (2000 through
2003) as average pounds per day produced discretely under each 40CFR 410 subpart. Annual averages
assume a 5-day workweek. Production under each subpart varies from year to year, both increasing and
decreasing, i.e., the data are quite variable with many annual production averages greater than, or lesser than
20 % of the permit cycle average. For example, production under Subpart E for five years shows no year
within 20% of the cycle average.
PERMITTING APPROACH
Federal Regulations. Technology -based regulations applicable to this facility are described in 40CFR 410,
Textile Mills Point Source Category, as defined in the following subparts:
• Subpart C — Low Water Use Processing
• Subpart D — Woven Fabric Finishing
• Subpart E — Knit Fabric Finishing
• Subpart G — Stock and Yarn Finishing
• Subpart H — Nonwoven Manufacturing, and also specifically
• 410.42 (b), 410.52 (b) — defining a complex manufacturing operation.
Production -- Establishing a Long-term Average. The Permittee presented production as Calendar
Average Production and Maximum Weekly Average Production in pounds per day (see attached
correspondence dated November 17, 2004). The Division concurs that these data reasonably represent this
facility's production history. In keeping with EPA Region 4 guidance (March 27, 2003), the Division has
applied these production figures as a long-term average to calculate technology -based permit limits under
each of the five Subparts listed above. The following tables summarize these calculations.
Fact Sheet
Renewal -- NPDES NC0005312
Page 2

Tables 2 through 6 present limits calculations per subpart. Renewal limits are additive, i.e., a sum of all
subparts (see summation, Table 7). Under each subpart, the Division used the Operating Rate Cycle Average
(lbs / day) to calculate both Daily Maximums and Monthly Averages.
Table 2.
Calculations. Subpart C - Extrusion and Texturizin
410.32 (BPT) and 410.33 (BAT)
(lbs / 1000 lbs)
Operating Rate Cycle
Average (lbs / day)
Renewal Contribution
(lbs / day)
Parameter
For Daily
Maximum
For Monthly
Average
Daily
Maximum
Monthly
Average
Daily
Maximum
Monthly
Average
BOD, 5-day
1.4
0.7
21,368
21,368
30
15
COD
2.8
1.4
21,368
21,368
60
30
TSS
1.4
0.7
21,368
21,368
30
15
pH
6.0-9.0
6.0-9.0
---
-
6.0-9.0
6.0-9.0
Table 3.
Calculations. Subpart D - Woven Fabric Finishin
more stringent than 410.43
410.42 (a) &. (b) (BPT)
Ibs / 1000 Ibs
Operating Rate Cycle
Average (lbs / day)
Renewal Contribution
(Ibs / day)
Parameter
For Daily
Maximum
For Monthly
Average
Daily
Maximum
Monthly
Average
Daily
Maximum
Monthly
Average
342
BOD, 5-day
6.6
3.3
103,748
103,748
684
COD
60 + 20 = 80
30 + 10 = 40
103,748
103,748
8296
4148
TSS
17.8
8.9
103,748
103,748
1846
923
Sulfide
0.20
0.10
103,748
103,748
21
12
Total Phenols
0.10
0.05
103,748
103,748
10
5
Total Chromium
0.10
0.05
103,748
103,748
10
5
pH
6.0-9.0
6.0-9.0
-
-
6.0-9.0
6.0-9.0
Table 4.
Calculations, Subpart E - Knit Fabric Finishin
(more stringent than 410.53)
410.52 (a) & (b) (BPT)
Ibs / 1000 Ibs
Operating Rate Cycle
Average lbs i day)
Renewal Contribution
(lbs / day)
Parameter
For Daily
Maximum
For Monthly
Average
Daily
Maximum
Monthly
Average
Daily
Maximum
Monthly
Average
BOD, 5-day
5.0
2.5
901
901
4.5
2
COD
60 + 40 =100
30 + 20 = 50
901
901
90
45
TSS
21.8
10.9
901
901
20
10
Sulfide
0.20
0.10
901
901
0.18
0.09
Total Phenols
0.10
0.05
901
901
0.09
0.045
Total Chromium
0.10
0.05
901
901
0.09
0.045
pH
6.0-9.0
6.0-9.0
-
-
6.0-9.0
6.0-9.0
Table 5.
Calculations, Subpart G - Stock and Yarn Finishin
(more stringent than 410.73)
410.72 (a) (BPT)
lbs / 1000 lbs
Operating Rate Cycle
Average (lbs / day)
Renewal Contribution
(lbs / day)
Parameter
For Daily
Maximum
For Monthly
Average
Daily
Maximum
Monthly
Average
Daily
Maximum
Monthly
Average
BOD, 5-day
6.8
3.4
26,825
26,825
182
91
COD
84.6
42.3
26,825
26,825
2267
1134
TSS
17.4
8.7
26,825
26,825
466
233
Sulfide
0.24
0.12
26,825
26,825
11
3.2
Total Phenols
0.12
0.06
26,825
26,825
6.4
1.6
Total Chromium
0.12
0.06
26,825
26,825
6.4
1.6
PH
6.0-9.0
6.0-9.0
-
-
6.0-9.0
6.0-9.0
Fact Sheet
Renewal -- NPDES NC0005312
Page 3

Table 6. Calculations, Subpart 1-1 - Nonwoven Manufacturing
(more stringent than 410.73)
410.72 a) (IIPT)
Ibs / 1000 Ibs
Operating Rate Cycle
Average (lbs / day)
Renewal Contribution
(lbs / day)
Parameter
For Daily
Maximum
For Monthly
Average
Daily
Maximum
Monthly
Average
Daily
Maximum
Monthly
Average
BOD, 5-day
4.4
2.2
13,035
13,035
57
29
COD
40.0
20.0
13,035
13,035
520
260
TSS
6.2
3.1
13,035
13,035
81
40
Sulfide
0.046
0.023
13,035
13,035
0.6
0.3
Total Phenols
0.023
0.011
13,035
13,035
0.29
0.14
Total Chromium
0.023
0.011
13,035
13,035
0.29
0.14
PH
6.0-9.0
6.0-9.0
-
-
6.0-9.0
6.0-9.0
Table 7. Additive Limits Calculations - Comparison to Previous Limits
Previous Permit Limits
(lbs / day)
Renewal Limits
(lbs / day)
Percent Change
Parameter
Daily
Maximum
Monthly
Average
Daily
Maximum
Monthly
Average
Daily
Maximum
Monthly
Average
BOD, 5-day
2,434.6
645.5
958
479
-61 %
-26 %
COD
37,645
9,017
11,233
5,617
-70 %
-38 %
TSS
6,274.5
1,601.5
2,443
1,221
-61 %
-24 %
Sulfide
74.8
19.2
33
16
-56 %
-17 %
Total Phenols
37.4
9.6
17
7
-54 %
-27 %
Total Chromium
37.4
9.6
17
7
-54 %
-27 %
pH
6.0-9.0
6.0-9.0
6.0-9.0
6.0-9.0
-
-
Toxicant Chronic and Acute Impact - Pollutants of Concern (POCs). To establish POCs, the Division
reviewed the permit application, discharge monitoring reports (1999 through 2003), and the Basin Plan. The
Division then used the standard Reasonable Potential Analysis (RPA) to calculate a maximum predicted
concentration for each POC. Each maximum was then compared to the POC's freshwater Chronic Standard
(Table 8) and also to its Final Acute Value (r/a FAV) for freshwater (Table 9). If by the above method, a
POC showed reasonable potential to exceed its '/Z FAV, the Division included a permit limit as a Daily
Maximum to protect the receiving stream against acute toxic affects. Similarly, if the maximum exceeded
the chronic standard, a Weekly Average limit was added to the permit. Findings are summarized below
(see Renewal Summary, Table 10).
Table 8. Toxicants -- Summary of Chronic Reasonable Potential Anal sis
Parameter
Samples
(n)
hits
(n)
Maximum
Predicted
Allowable
Concentrations
RP
y/n
Comments
Flow
-
--
-
-
-
4.0 MGD used for RPA
Total Arsenic
11
8
402.6 µg/L
2,582 µg/L
No
Detected, therefore
continue monitor
Total Lead
11
2
20.3 µg/L
1,291 µg/L
No
Detected, therefore
continue monitor
Total Mercury
11
0
0.1 µg/L
1.0 µg/L
No
Delete from Permit
Total Selenium
11
1
8.5 µg/L
258 µg/L
No
Delete from Permit
Fact Sheet
Renewal -- NPDES NC0005312
Page 4

Table 9. Toxicants -- Summary of Acute Reasonable Potential Analysis
Parameter
Samples
(n)
Hits
(n)
Maximum
Predicted
Allowable
Concentration'
RP
y/n
Comments
Flow
—
-
-
—
—
4.0 MGD used for RPA
Total Arsenic
11
8
402.6 lbs.
Not Applicable
—
No acute criteria
Total Lead
11
2
20.3 µg/L
34 µg/L
No
See Table 8
Total Mercury
11
0
Not detected
—
--
No acute criteria
Total Selenium
11
1
8.5 µg/L
56 µg/L
No
See Table 8
Other Parameters of Concern (POC). Other organic compounds remain POCs because they are
unnatural to the local environment and relate to an ongoing onsite groundwater remediation for
petroleum hydrocarbons. The following therefore shall remain in the permit: benzene, toluene,
ethylbenzene, chloroform, and 1,1 dichloroethane (DCA). As previously permitted, these parameters
shall be monitored Quarterly and do not have permit limits. Concerning Barium and Fluorine, North
Carolina's barium standard exists for WS (water supply) waters only. Fluorine has no standard.
Therefore, these parameters shall be removed from the permit.
RENEWAL SUMMARY
• BOD5 , COD, TSS, Sulfides, Phenols, and Chromium — Mass -based limits have been
adjusted (lowered) for this renewal based on revised production data, in accordance with EPA
guidance.
• mercury, selenium, barium, and fluorine -- removed from the permit based on reasonable
potential.
PROPOSED SCHEDULE OF ISSUANCE
Draft Permit to Public Notice: January 5, 2005.
Permit Scheduled to Issue:
March 1, 2005
NPDES UNIT CONTACT
If you have questions regarding any of the above information or on the attached permit, please
contact Joe Corporon at [phone] ext. 597.
NAME: DATE:
Fact Sheet
Renewal -- NPDES NC0005312
Page 5

•
Interface
Interface Fabrics
304 East Main Street
Elkin, North Carolina 28621
336.835.2211
336.526.2037 fax
November 17, 2004
Mr. Joe Corporon
NPDES Unit
North Carolina Department of Natural Resources
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: NPDES Wastewater Permit Renewal for Interface Fabrics, Elkin (NC0005312)
Dear Mr. Corporon,
Pursuant to our conference call on October 25, 2004, Interface Fabrics is submitting updated
production information.
The wastewater treatment plant receives process wastewater from Interface's textile
manufacturing facility located in Elkin, wastewater from the dyeing and finishing operations
located at the adjacent West Point Stevens facility, and sanitary wastewater from Interface's
facility as well as a small portion of the Town of Elkin.
As discussed during our conference call, the Interface facility has undergone significant
changes in the last 9 months. In March of 2004, the Interface Fabrics permanently closed a
sister facility located in Aberdeen, North Carolina. All production previously made at the
Aberdeen facility has been transitioned to the Elkin facility. The full impact of that transition
has not yet occurred as equipment is still being installed and product lines converted at the
Elkin facility. With this consolidation, the Elkin facility is the only manufacturer for
Interface Fabrics in the entire southeast.
It is important to note that during the period of time that production data is being evaluated
for the Elkin facility (2000-2004 YTD), several key issues affected facility production. It is
important to consider the effects of these issues in establishing production based limitations
for the facility that will be in place for at least the next five years and will be the basis for any
anti -backsliding demonstration in the event that effluent limits need to be increased in the
future.
• Interface purchased the facility in 2000, the first year of the production history. At
the time of the purchase the prior owner was facing bankruptcy (subsequently CMI
entered into a liquidating bankruptcy) and as such, production was significantly
curtailed.
• For the first eighteen months of ownership, Interface needed to transition production
of the facility to its product lines and increase sales to achieve greater utilization of
the production capacity. Such transition curves typically take over 2 years to achieve
before reaching targeted production levels.
• The terrorist attacks on September 11, 2004 significantly impacted the commercial
interiors marketplace. Following the attacks, our industry faced an unprecedented
decline attributed to businesses cutting discretionary spending (office furniture and
other commercial interior upgrades) during this period of uncertainty. Many of our

customers and competitors have ceased doing business during these difficult
economic times. We are only now beginning to see a return of business in our sector.
Interface has invested heavily in the Elkin facility with the goal of a competitive, centralized,
integrated manufacturing to support our business needs worldwide. The wastewater
treatment facility is an essential element of our ability to achieve existing production capacity
at the facility, thus ensuring the economic viability of the Elkin facility.
As requested, we have updated production data for calendar year 2003 and year-to-date 2004,
the time period since the renewal application was filed. Attached are three tables:
1. Table 1 includes production data for Interface's Elkin facility and the adjacent West
Point Stevens facility. Production is provided relevant to the applicable effluent
guidelines. The production data is presented in three ways:
a. Calendar Average Production (denoted as Av#/day) is the actual facility
production divided by the number of calendar days.
b. Maximum Production (denoted as Max#/day) takes the single largest weekly
production during the time period and divides by the number of operating
days during that production week.
c. Operating Rate (denoted as Operating Rate #/day) takes the actual facility
annual production and divides by the facility's operating time. The operating
time is the percentage of time the facility was "in production". It excludes all
production downtime (defined as time the machine was not expected to be
making product, including scheduled outages for scheduled maintenance) for
the applicable production departments. The percentage of "in production"
time includes time the machine was down due to machine runnability
problems or other issues not scheduled as time down. This is representative
of the realistically achievable production if the equipment were operated on a
typical 24/7 operating schedule. The operating rate is not the machine
capacity, nor is it the rate the machine operates at only when the machine is
running.
2. Table 2 is the updated table originally provided as part of the renewal application,
representing a summary of the data from Table 1.
3. Table 3 contains calculated effluent limitations based upon the production data
contained in Tables 1 and 2. For completion, we have included the Calendar
Average Production figures, Maximum Production figures, and the Operation Rate
figures described above.
Consistent with EPA guidance for production based effluent limitations, we strongly support
the use of Operating Rate as the basis for the development of effluent limitations for the Elkin
facility. Interface as recently undergone NPDES permit renewal in two other states (Maine
and Massachusetts). Both states have utilized the Operating Production Rate as the
application production level for production based effluent limits. These two permits have
included production based limits for two permit cycles.
Lastly, we request that the Department include the contribution from sanitary wastewater in
the development of effluent limitations for the facility.
In closing, Interface has recognized that effluent limits applicable to the facility would likely
be reduced during permit renewal. As such, Interface has invested over $1.4 million at the
wastewater treatment plant in an effort to improve treatment efficiency. Interface requests
effluent limits be established utilizing methodologies consistently accepted by EPA in North

Carolina and also in other states where Interface operates. Because of the significance of the
effluent limitations to the economic viability of the Elkin facility, Interface respectfully
requests the opportunity to review and comment on any proposed effluent limitation prior to
formal issuance of the draft NPDES permit.
In addition, pursuant to our permit renewal, Interface Fabrics is requesting a change in our
effluent limitations. Currently Interface Fabrics has a Fecal Coliform limitation of 200
colonies per 100 ml Monthly Average and 400 colonies per 100 ml Daily Maximum. The
established monitoring frequency is twice per month. Interface Fabrics is requesting a
change of effluent limitations to reflect a Weekly Maximum Limit rather than a Daily
Maximum Limit. Interface Fabrics receives a significant amount of sanitary waste from
plant operations and a portion of discharge from the Town of Elkin; as such Interface Fabrics
is requesting to reflect the fecal coliform limits that are typically issued to municipal
wastewater treatment facilities.
If you have any questions regarding any of the information that is provided, please contact
me at 336-526-0383 or via email at [e-mail]. I look forward to
your response.
Sincerely,
amie I iano
Enviro mental Manager
Interface Fabrics, Elkin
c:
Wendy Porter, Director Environmental Management, Interface, Inc.

Table 1
Detailed Production Data - Interface Fabrics Elkin Facility (includes production data from West Point Stevens, excludes contribution from Sanitary wastewater
Year
Subpart C - Low Water Use Processing Subcategory
IFG Extrusion
IFG Texturizinc
Total
Operating
Av#/d
Max#/d
Op Time
Av#/d
Max#/d
Op Time
Av#/d
Max#/d
Rate #/d
2000
1,456
2,043
83.3
9,002
12,637
51.0
10,458
14,680
19,399
2001
1,874
2,631
82.7
6,698
9,403
37.0
8,572
12,034
20,368
2002
3,095
4,344
64.8
10,777
15,129
40.0
13,872
19,473
31,719
2003
3,285
5,854
73.7
3,554
9,326
28.0
6,839
15,180
17,172
2004 YTD
3,083
5,368
60.3
3,025
6,032
23.1
6,109
11,400
18,184
Average
2,559
4,048
73
6,611
10,505
36
9,170
14,553
21,368
Maximum
3,285
5,854
83
10,777
15,129
51
13,872
19,473
31,719
Year
Subpart D - Woven Fabric Finishing Subcategory
IFG Dyeing (Piece)
WPS Dyeing
IFG Flame Proofing
IFG Soil Relellency
IFG Special Finish
Operating
Av#/d
Max#/d
Op Time
Av#/d
Max#/d
Av#/d
Max#/d
Av#/d
Max#/d
Av#/d
Max#/d
Op Time
2000
7,304
10,253
29.7
7,458
10,470
6,408
8,996
458
643
38,906
54,618
53.3
2001
5,385
7,560
34.3
7,458
10,470
4,218
5,921
301
423
25,609
35,951
39.9
2002
4,738
6,651
43.9
7,458
10,470
5,465
7,672
390
548
33,180
46,580
49.6
2003
4,578
6,427
52.59
5,309
7,452
3,954
7,552
282
539
24,008
45,852
43.34
2004 YTD
12,408
27,220
39
5.505
7,727
3,933
7,982
281
570
23,881
48,464
40
Average
6,883
11,622
40
6,638
9,318
4,796
7,625
342
545
29,117
46,293
45
Maximum
12,408
27,220
53
7,458
10,470
6,408
8,996
458
643
38,906
54,618
53
Year
Subpart D - Cont.
WPS Water Proofing
WPS Bleaching
Total
Operating Rate
Av#/d
Max#/d
Av#/d
Max#ld
Av#/d
Max#/d
#Id
2000
9,323
13,088
1,865
2,618
71,721
84,980
121,654
2001
9,323
13,088
1,865
2,618
54,159
60,325
102,397
2002
9,323
13,088
1,865
2,618
62,418
71,921
100,679
2003
7,077
9,935
1, 769
2,483
46,977
67,823
82,720
2004 YTD
7,314
10,211
1,809
2,484
55,131
91,963
111,291
Average
8,472
11,882
1,834
2,564
58,081
75,402
103,748
Maximum
9,323
13,088
1,865
2,618
71,721
91,963
121,654

Table 1
Year
Subpart E - Knit Finishing Subcategory
IFG Flame Proofing
IFG Soil Repellancy
IFG Special Finish
Total
Normalized
Av#/d
Max#/d
Av#/d
Max#/d
Av#/d
Max#/d
Av#/d
Max#/d
#Id
2000
267
375
19
27
1,621
2,276
1,907
2,303
2,297
2001
176
247
13
18
1,067
1,498
1,256
1,516
1,512
2002
34
48
2
3
207
291
243
294
293
2003
15
36
1
3
94
221
110
224
223
2004
YTD
6
29
0
2
38
179
44
181
181
Average
100
147
7
11
605
893
712
904
901
Maximum
267
375
19
27
1,621
2,276
1,907
2,303
2,297
Year
Subpart G - Stock and Yarn Finishing
Subcategory
Operating
Dyeing (Package)
Av#!d
Max#/d
Op Time
Rate #lday
2000
14,848
20,845
33
44,994
2001
9,948
13,965
46.3
21,486
2002
7,346
10,313
33.5
21,928
2003
5,407
14,187
24.6
21,980
2004
YTD
4,185
7,225
17.6
23,738
Average
8,347
13,307
31
26,825
Maximum
14,848
20,845
46
44,994
Year
Subpart H - Nonwoven Manufacturing
Subcategory
WPS Total
Normalized
Av#/d
Max#/d
#/d
2000
10,794
15,153
15,112
2001
10,794
15,153
15,112
2002
10,794
15,153
15,112
2003
8,565
12,024
11,991
2004
YTD
3,594
7,872
7,850
Average
8,908
13,071
13,035
Maximum
10,794
15,153
15,112
Notes:
Av#/day is actual production divided by number of calendar days
Max#/day is weekly maximum production divided by the number of operating days during that week
Operating Time is the percentage of time the machines operated during the year (actual operating hours whether making product or not).
Operating rate is the av#/day divided by operating time
Normalized rate (for WPS data only) is production if sustained Max#/day for all 52 weeks of the year
Sanitary Wastewater is also received and treated at the Interface wastewater treatment facility
Bolded numbers are used in effluent limts tab

Table 2
Production Data for NDPES Effluent Permit Calculations
Year
Subpart C - Low Water Use Processing
Total
Operating Level
Av#/d
Max#/d
#/day
2000
10,458
14,680
19,399
2001
8,572
12,034
20,368
2002
13,872
19,473
31,719
2003
6,839
15,180
17,172
2004
YTD
6,109
11,400
18,184
Year
Subpart D - Woven Fabric Finishing Subcategory
Total
Operating Rate
Av#/d
Max#/d
#/d
2000
71,721
84,980
121,654
2001
54,159
60,325
102,397
2002
62,418
71,921
100,679
2003
46,977
67,823
82,720
2004
YTD
40,503
84,236
102,168
Year
Subpart E - Knit Finishing Subcategory
Total
Normalized
Av#/d
Max#/d
#/d
2000
1,907
2,303
2,297
2001
1,256
1,516
1,512
2002
243
294
293
2003
110
224
223
2004
YTD
44
181
181
Year
Subpart G - Stock and Yarn Finishing Subcategory
Total
Operating
Av#/d
Max#Id
#/d
2000
14,848
20,845
44,994
2001
9,948
13,965
21,486
2002
7,346
10,313
21,928
2003
5,407
14,187
21,980
2004
YTD
4,185
7,225
23,738
Year
Subpart H - Nonwoven Manufacturing Subcategory
Total
Normalized
Av#/d
Max#/d
#/d
2000
10,794
15,153
15,112
2001
10,794
15,153
15,112
2002
10,794
15,153
15,112
2003
8,565
12,024
11,991
2004
YTD
4,185
12,024
11,991

Table 2
Yea
TOTAL INDUSTRIAL
Total
Operating Rate
Av#/d
Max#/d
#/d
2000
109,728
137,961
203,456
200'
84,729
102,993
160,875
2002
94,673
117,155
169,731
2003
67,898
109,438
134,087
2004
55,026
115,066
156,262
Av#/day is actual production divided by number of calendar days
Max#/day is weekly maximum production divided by the number of operating days during that week
Operating Time is the percentage of time the machines operated during the year (actual operating hours whether making product or not).
Operating rate is the av#/day divided by operating time
Normalized rate (for WPS data only) is production if sustained Max#/day for all 52 weeks of the year

Table 3
Calculation of Potential Effluent Limitations based upon Calendar Average Production, Maximum Weekly Average Production,
Subpart C - Low Water Use Yarn Processin
Avg AVERAGE
9,170
Avg MAXIMUM
14,553
Avg Operating Rate
21,368
Elkin Capacity
35758
EPA Categorical Limits
Daily Max
Daily Ave
Daily Max
Daily Ave
Daily Max
Daily Ave
Daily Max
Daily Ave
Daily Max
Daily Ave
BOD
1.4
0.7
12.84
6.42
20.37
10.19
29.92
14.96
50.06
25.03
COD
2.8
1.4
25.68
12.84
40.75
20.37
59.83
29.92
100.12
50.06
TSS
1.4
0.7
12.84
6.42
20.37
10.19
29.92
14.96
50.06
25.03
Subpart D - Woven Fabric Finishing
Avg AVERAGE
58,081
Avg MAXIMUM
75,402
Avg Operating Rate
103,748
Elkin Capacity
143304.7
EPA Cate orical Limits
Daily Max
Daily Ave
Daily Max
Daily Ave
Daily Max
Daily Ave
Daily Max
Daily Ave
Daily Max
Daily Ave
BOD
6.6
3.3
383.33
191.67
497.66
248.83
684.74
342.37
945.81
472.91
COD
60
30
3,484.86
1,742.43
4,524.15
2,262.07
6,224.89
3,112.44
8,598.28
4,299.14
TSS
17.8
8.9
1,033.84
516.92
1,342.16
671.08
1,846.72
923.36
2,550.82
1,275.41
Sulfide
0.2
0.1
11.62
5.81
15.08
7.54
20.75
10.37
28.66
14.33
Phenol
0.1
0.05
5.81
2.90
7.54
3.77
10.37
5.19
14.33
7.17
T. Chromium
0.1
0.05
5.81
2.90
7.54
3.77
10.37
5.19
14.33
7.17
Subpart E - Knit Finishing
Avg AVERAGE
712
Avg MAXIMUM
904
Avg Operating Rate
901
Elkin Capacity
2677
EPA Categorical Limits
Daily Max
Daily Ave
Daily Max
Daily Ave
Daily Max
Daily Ave
Daily Max
Daily Ave
Daily Max
Daily Ave
BOD
5
2.5
3.56
1.78
4.52
2.26
4.51
2.25
13.39
6.69
COD
60
30
42.72
21.36
54.22
27.11
54.07
27.03
160.62
80.31
TSS
21.8
10.9
15.52
7.76
19.70
9.85
19.64
9.82
58.36
29.18
Sulfide
0.2
0.1
0.14
0.07
0.18
0.09
0.18
0.09
0.54
0.27
Phenol
0.1
0.05
0.07
0.04
0.09
0.05
0.09
0.05
0.27
0.13
T. Chromium
0.1
0.05
0.07
0.04
0.09
0.05
0.09
0.05
0.27
0.13
Subpart G - Stock & Yam Finishing
Avg AVERAGE
8,347
Avg MAXIMUM
13,307
Avg Operating Rate
26,825
Elkin Capacity
EPA Categorical Limits
Daily Max
Mon Ave
Daily Max
Daily Ave
Daily Max
Daily Ave
Daily Max
Daily Ave
Daily Max
Daily Ave
BOD
6.48
3.24
54.09
27.04
86.23
43.11
173.83
86.91
0.00
0.00
COD
84.6
42.3
706.14
353.07
1,125.78
562.89
2,269.41
1,134.71
0.00
0.00
TSS
17.4
8.7
145.23
72.62
231.54
115.77
466.76
233.38
0.00
0.00
Sulfide
0.24
0.12
2.00
1.00
3.19
1.60
6.44
3.22
0.00
0.00
Phenol
0.12
0.06
1.00
0.50
1.60
0.80
3.22
1.61
0.00
0.00
T. Chromium
0.12
0.06
1.00
0.50
1.60
0.80
3.22
1.61
0.00
0.00

Table 3
TOTAL
Potential Permit Limits
Avg AVERAGE
Avg MAXIMUM
Avg Operating Rate
Elkin Capacity
Avg AVERAGE
Avg MAXIMUM
Avg Operating Rate
Elkin Capacity
Daily Max
Daily Ave
Daily Max
Daily Ave
Daily Max
Daily Ave
Daily Max
Daily Ave
Daily Max
Daily Ave
Daily Max
Daily Ave
Daily Max
Daily Ave
Daily Max
Daily Ave
Daily Max
Daily Ave
BOD
2434.6
646.5
453.82
226.91
608.78
304.39
892.99
446.49
1,009.26
504.63
81.36%
64.90%
74.99%
52.92%
63.32%
30.94%
58.55%
21.94%
COD
37645
9017
4,259.40
2,129.70
5,744.89
2,872.44
8,608.20
4,304.10
8,859.02
4,429.51
88.69%
76.38%
84.74%
68.14%
77.13%
52.27%
76.47%
50.88%
TSS
6274.5
1601.5
1,207.44
603.72
1,613.78
806.89
2,363.04
1,181.52
2,659.24
1,329.62
80.76%
62.30%
74.28%
49.62%
62.34%
26.22%
57.62%
16.98%
Sulfide
74.8
19.2
13.76
6.88
18.45
9.23
27.37
13.68
29.20
14.60
81.60%
64.16%
75.33%
51.94%
63.41%
28.73%
60.97%
23.97%
Phenol
37.4
9.6
6.88
3.44
9.23
4.61
13.68
6 84
14.60
7.30
81.60%
64.16%
75.33%
51.94%
63.41%
28.73%
60.97%
23.97%
T. Chromium
37.4
9.6
6.88
3.44
9.23
4.61
13.68
6.84
14.60
7.30
81.60%
64.16%
75.33%
51.94%
63.41%
28.73%
60.97%
23.97%

REASONABLE POTENTIAL ANALYSIS
Interface Fabrics Group South, Inc.
NC000531 2
Time Period Jan
Ow (MGD) 4
7010S (cfs) 314
7010W(cfs) 450
30Q2 (cfs) 0
Avg. Stream Flow, QA (cfs) 1390
Reeving Stream Yadkin
WWTP Class IV
IWC(%) @ 7Q10S 1.9363
Cg7 7010W 1.3591
@ 30Q2 N/A
@ QA 0.4441
Stream Class C
Outfall 001
Qw = 4 MGD
PARAMETER
TYPE
(1)
STANDARDS &
CRITERIA (2)
PQL
Units
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
NC 4V05/
Chronic
'.i FAV /
Acute
n A Der. Max Pred Cw
Allowable Cw
Arsenic
NC
50
ug/L
11 8 402.6
Note: n<12
Limited data set
Acute:
Chronic:
N/A
2,582
No RP
Chromium
NC
50
1.022
ug/L
0 0 N/A
Acute:
Chronic:
1,022
2,582
Acute:
N/A
Lead
NC
25
N
33.8
ug/L
11 2 20 3
Note: n<12
Limited data set
Acute.
Chronic:
34
No RP
1,291
No RP
Mercury
NC
0.012
0.0002
ug/L
11 0 0.1000
Note: n<12
Limited data set
Acute:
Chronic:
N/A
1
No RP
Selenium
NC
5.0
56
ug/L
11 1 8.5
Note: n<12
Limited data set
Acute:
Chronic:
56
No RP
258
No RP
' Legend:
C = Carcinogenic
NC = Non -carcinogenic
A = Aesthetic
Freshwater Discharge
05312 --Interface RPA, rpa
7/28/2004

REASONABLE POTENTIAL ANALYSIS
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
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
199
200
Arsenic
Date Data BDL=1/20L Results
Mar-2002 7.0 7.0 Std Dev. 18.7527
Aug-2002 10.0 10.0 Mean 15.6818
May-2002 < 5.0 2.5 C.V. 1.1958
Nov-2002 7.0 7.0 n 11
Feb-2003 < 5.0 2.5
May-2003 .. 12.0 12.0 Mutt Factor = 6.1000
Apr-2003 < 5.0 2.5 Max. Value 66.0 ug/L
Aug-2003 12.0 12.0 Max. Pred Cw 402.6 ug/L
Nov-2003 31.0 31.0
Feb-2004 66.0 66.0
May-2004 20.0 20.0
05312 --Interface RPA, data
7/28/2004

REASONABLE POTENTIAL ANALYSIS
Lead
Date Data BDL=1/2DL Results
1 Mar-2002 5 5.0 Std Dev. 1.2933
2 Aug-2002 3 3.0 Mean 1.5455
3 May-2002 < 2 1.0 C.V. 0.8369
4 Nov-2002 < 2 1.0 n 11
5 Feb-2003 < 2 1.0
6 May-2003 < 2 1.0 Mult Factor = 4.0500
7 Apr-2003 < 2 1.0 Max. Value 5.0 ug/L
8 Aug-2003 < 2 1.0 Max. Pred Cw 20.3 ug/L
9 Nov-2003 . < 2 1.0
10 Feb-2004 < 2 1.0
11 May-2004 < 2 1.0
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
199
200
Mercury
Date
1 Mar-2002
2 Aug-2002
3 May-2002
4 Nov-2002
5 Feb-2003
6 May-2003
7 Apr-2003
8 Aug-2003
9 Nov-2003
10 Feb-2004
11 May-2004
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
199
200
Data BDL=1/2DL Results
.< 0.2 0.1 Std Dev. 0.0000
• 0.2 0.1 Mean 0.1000
< 0.2 0.1 C.V. 0.0000
< 0.2 0.1 n 11
< 0.2 0.1
< 0.2 0.1 Mull Factor = 1.0000
< 0.2 0.1 Max. Value 0.1 ug/L
< 0.2 0.1 Max. Pred Cw 0.1 ug/L
< 0.2 0.1
< 0.2 0.1
0.2 01
-2-
05312 --Interface RPA, data
7/28/2004

REASONABLE POTENTIAL ANALYSIS
Selenium
Date Data BDL=1/2DL Results
1 Mar-2002 < 5 2.5 Std Dev. 0.7538
2 Aug-2002 < 5 2.5 Mean 2.7273
3 May-2002 < 5 2.5 C.V. 0.2764
4 Nov-2002 < 5 2.5 n 11
5 Feb-2003 < 5 2.5
6 May-2003 -< 5 2.5 Mull Factor = 1.6900
7 Apr-2003 < 5 2.5 Max. Value 5.0 ug/L
8 Aug-2003 '< 5 2.5 Max. Pred Cw 8.5 ug/L
9 Nov-2003 < 5 2.5
10 Feb-2004 5 5.0
11 May-2004 < 5 2.5
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
199
200
05312 --Interface RPA, data
7/28/2004

i �' a- )
Table 1. Project Information Table 2. Parameters of Concern
Facility Name
WWTP Grade
NPDES Permit
Outfall
Flow, Qw (MGD)
Receiving Stream
Stream Class
7Q10s (cfs)
7Q10w (cfs)
30Q2 (cfs)
QA (cfs)
Time Period
Data Source(s)
Interface Fabricsme-
Iv
NC0005312
001
4.0
Yadkin
C
314.0
450.0
1390.0
Jan
DMR
Par01
Par02
Par03
Par04
Par05
Par06
Par07
Par08
Par09
Par10
Par11
Par12
Par13
Par14
Par15
Name Type Chronic Modifier Acute PQL Units
Arsenic
Beryllium
Cadmium
Chromium
Copper
Cyanide
Fluoride
Lead
Mercury
Molybdenum
Nickel
Phenols
Selenium
Silver
Zinc
NC
C
50
6.5
NC
2
NC
50
NC
7
AL
NC
5
15
1022
7.3
22
NC 1800
25
0.012
3500
88
1
NC
NC
A
NC
A
NC
5
N 33.8
NC
0.06
AL
NC
50 AL
261
56
1.23
67
ug/L
ug/L
ug/L
ug/L
ug/L
10 ug/L
ug/L
ug/L
0.0002 ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
05312 --Interface RPA, input
7/21/2004

REASONABLE POTENTIAL ANALYSIS
Interface Fabrics Inc.
NC0005312
Time Period Jan
Qw (MGD) 4
70105 (cfs) 314
7010W (cfs) 450
3002 (cfs) 0
Avg. Stream Flow, OA (cfs) 1390
Rec'ving Stream Yadkin
WWTP Class IV
!WC (%) ® 7Q10S 1.9363
(c? 7010W 1.3591
3002 N/A
Q QA 0.4441
Stream Class C
Outfall 001
Caw = 4 MGD
PARAMETER
TYPE
(1)
STANDARDS &
CRITERIA (2)
PQL
Units
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
NCWOS/
Chronic
ii PAV/
Acute
n # Det. Max Pred Cw
Allowable Cw
Arsenic
NC
50
ug/L
11 402.6
Note: n<12
Limited data set
Acute:
Chronic:
N/AIrrt
V O F
% `S/f tIlt4 LW" -
2,582
No RP
Chromium
NC
50
1,022
ug/L
7 7 564.7
Note: n<12
Limited data set
Acute:
Chronic:
1,022
No RP
2,582
No RP
Acute:
N/A
Lead
NC
25
N
33.8
ug/L
11 \ 2 J 20.3
Note: n<12
Limited data set
Acute:
Chronic:
34
No RP ems`6 "
t { aP"'
1,291
.1Maki
No RP M
a ` b( L1
Mercury
NC
0.012
0.0002
ug/L
11 0 0.1000
Note: n<12
Limited data set
Acute'
Chronic:
N/A
1
No RP
Selenium
NC
5.0
56
ug/L
11 1 8.5
Note: n<12
Limited data set
Acute.
Chronic:
56
No RP
258
No RP
' Legend:
C = Carcinogenic
NC = Non -carcinogenic
A = Aesthetic
Freshwater Discharge
05312 --Interface RPA, rpa
7/21/2004

REASONABLE POTENTIAL ANALYSIS
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
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
199
200
Arsenic
Date Data BDL=1/2DL Results
Mar-2002 7.0 7.0 Std Dev. 18.7527
Aug•2002 =- 10.0 10.0 Mean 15.6818
May-2002 E} 5.0 2.5 C.V. 1.1958
Nov-2002 7.0 7.0 n 11
Feb-2003 5.0 2.5
May-2003 12.0 12.0 Mult Factor = 6.1000
Apr-2003 5.0 2.5 Max. Value 66.0 ug/L
Aug-2003 !' 12.0 12.0 Max. Pred Cw 402.6 ug/L
Nov-2003 31.0 31.0
Feb-2004 1. 66.0 66.0
May-2004 20.0 20.0
05312 --Interface RPA. data
7/21/2004

REASONABLE POTENTIAL ANALYSIS
Chromium
Date Data BDL=1/2DL Results
1 Mar-2002 52 52.0 Std Dev. 17.9045
2 Aug-2002 3 3.0 Mean 12.7143
3 May-2002 3 3.0 C.V. 1.4082
4 Nov-2002 4 4.0 n 7
5 Feb-2003 5 5.0
6 May-2003 16 16.0 Mult Factor = 10.8600
7 Apr-2003 6 6.0 Max. Value 52.0 ug/L
8 Aug-2003 { Max. Pred Cw 564.7 ug/L
9 Nov-2003
10 Feb-2004
11 May-2004
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
199
200
Lead
Date Data BDL=1/2DL Results
1 Mar-2002 5 5.0 Std Dev 1.2933
2 Aug-2002 3 3.0 Mean 1.5455
3 May-2002 < 2 1.0 C.V. 0.8369
4 Nov-2002 < 2 1.0 n 11
5 Feb-2003 < 2 1.0
6 May-2003 < 2 1.0 Mult Factor = 4.0500
7 Apr-2003 < 2 1.0 Max. Value 5.0 ug/L
8 Aug-2003 < 2 1.0 Max. Pred Cw 20.3 ug/L
9 Nov-2003 < 2 1.0
10 Feb-2004 < 2 1.0
11 May-2004 < 2 1.0
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
199
200
-2
05312 --Interface RPA, data
7/21/2004

REASONABLE POTENTIAL ANALYSIS
Mercury
Date Data BDL=1/2DL Results
1 Mar-2002 < 0.2 0.1 Std Dev. 0.0000
2 Aug-2002 < 0.2 0.1 Mean 0.1000
3 May-2002 < 0.2 0.1 C.V. 0.0000
4 Nov-2002 < 0.2 0.1 n 11
5 Feb-2003 < 0.2 0.1
6 May-2003 < 0.2 0.1 Mult Factor = 1.0000
7 Apr-2003 < 0.2 0.1 Max. Value 0.1 ug/L
8 Aug-2003 < 0.2 0.1 Max. Pred Cw 0.1 ug/L
9 Nov-2003 < 0.2 0.1
10 Feb-2004 < 0.2 0.1
11 May-2004 < 0.2 0.1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
199
200
Selenium
Date Data BDL=1/2DL Results
1 Mar-2002 < 5 2.5 Std Dev. 0.7538
2 Aug-2002 < 5 2.5 Mean 2.7273
3 May-2002 < 5 2 5 C.V. 0.2764
4 Nov-2002 < 5 2.5 n 11
5 Feb-2003 < 5 2.5
6 May-2003 < 5 2.5 Mult Factor = 1.6900
7 Apr-2003 < 5 2.5 Max. Value 5.0 ug/L
8 Aug-2003 < 5 2.5 Max. Pred Cw 8.5 ug/L
9 Nov-2003 < 5 2.5
10 Feb-2004 5 5.0
11 May-2004 < 5 2.5
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
199
200
05312 --Interface RPA, data
3 7/21/2004

Subpart C - Low Water Use Processing Subcategory
a
C
aCOS
Q
0
Rate #Id 1
CAj
(P
20,368
31,719
17,172
21,3681
a)
n
C)
O
12,034
19,473
L 15,180
11,400
co
19,473
M
V
-
CC
N
13
O
10,458
N
N
O)
a)
O
13,872
I-
'0
O
O
O
O0
0
r
co
co
rn
Q
IFG Texturizing
Op Time
51.0
37.01
O
O
O
co
r'
(ri
O
C7
O
V
N
N
CO
0
N
N
6..032
0
N
(.O
V
.-
COO
r-
ii
N
m
0
O
O
LO-
X
2
9,0021
co
0
r
n
3,554
(n
o
.-
0
10,777
10
(O
O
(h
O
Q
IFG Extrusion
Op Time
co
(h
co
�._ 822
co
(O
0
R.
co
r
60.3
0r-
0
co
,0000
0
co
X
co
N
N.c
O
O
V
O
2
co
1,8741
O
in
co
2,5591
3,285
L
,I"O
r
CO-
N
[O
O
-
CO
>
}
1 2000
2001
2002
2003
2004 YTD
Average
X
m
a)
a
0
E
a
0
0
(n
rn
a)
0
A
0
O
v
O
N
LL
U
0
a
(n
0
LL
a
is
0
(a0
t1')
O
O)
cO
O
O
O
(D
(NI
O
co
O
v
O
0
0
(D
O
(D
O
a)
(D
0
a)
O
O
O
N
O
O
0
0
co
O
co
co
O)
(D
0
0
0
0
U
d
n
O
T
O LL
Cn c,,
01 ta=
0
LE E `
a1
ll E
co>
LL Q
C
>
as
O
0
as
a
O
x
O
x
A
x
a
0
co
O
CO
O
CO
co
U
O
M
O
N
CO
N
O
r
CO
N
O
O
O
O
Cr)
01
cD
N
0)
10
r
(D
ti
O
O
r
co
a)
0)
a)
CD
CO CO
0V N
(D '
N. 0 0
✓ �r
9 O
T
O
7 6)
O
0O (N
v v
O IR
CO
C)
rn
co-
co
0)
r
r CO
r (*)
r (J1
0
co
(n
0
(n
(a
u0
rn
0
(+1
10
0
Ch
(D
(O
O
O
v
d
E
a
0
x
x
(0
v
r
O)
N
M
O
N
O
r
co
A
O
(D
O
O
co
M
O
O
(D
O
co
M
r
C
O
O
N
(n
N
CO
-
CI)
CO
0
N
N
N
N
co
O
O
N
N
(D
co
co
co
CD
0
N
N
N
O
O
V
O
O
0
0
O
N
N
0
O
N
N
0
0
0
›-
0
0
CN
0)
E
Subpart D - cont.
Operating Ratel
1,
ii
(O
1-
102,3971
N-
CO
O
0CV
r
ONO
O)
N
rr---
R
Ps
O
(O
T
xp
C
84,980
COO
CO
67,8231
D)
n
CD
4
,a
ii
n _
CD
O
v
N
46,977
55.131
CO
CD
CO
N
r
Ct
WPS Bleaching
(D
CD
co
(h
2,484
2,5641
_O
b
(00
(p
Ov
CO
m
CV
N
N
N
N
Lo
uo
uo
rn
a)
cg
0
co
co
CO
N.
CO
CO
CO
e.-
e.-
.-
r-
r-
Q
WPS Water Proofing
CO
13,0881
CO
O
O
11,8821
O
O
a
0
Om)
N
0
r-
^
CD-O
rO-
CD
CO
9,323
9,323
7,077
V
N
CO
a
CC,)
M
C
CO
Qi
R.
O
0)
Q
N
}
1 2000
o
O
CV
1 2002
2003
2004 YTD
Average
E
`
z
m

Table 1
Year
Subpart E Knit Finishin Subcategory
IFG Flame Proofing
IFG Soil Repellancy
IFG Special Finish
Total
Normalized
Av#/d
Max#/d
Av#/d
Max#/d
Av#/d
Max#/d
Av#/d
Max#/d
#/d
2000
267
375
19
27
1,621
2,276
1,907
2,303
2,297
2001
176
247
13
18
1,067
1,498
1,256
1,516
1,512
2002
34
48
2
3
207
291
243
294
293
2003
15
36
1
3
94
221
110
224
223
2004
YTD
6
29
0
2
38
179
44
181
181
Average
100
147
7
11
605
893
712
904
901
Maximum
267
375
19
27
1,621
2,276
1,907
2,303
2,297
Year
Subpart G - Stock and Yarn Finishing
Subcategory
Operating
Dyeing (Packa9e)
Av#/d
Max#/d 1Op Time
Rate #/day
2000
14,848
20,845
33
44,994
2001
9,948
13.965
46.3
21,486
2002
7,346
10,313
33.5
21,928
2003
5,407
14,187
24.6
21,980
2004
YTD
4,185
7,225
17.6
23,738
Average
8,347
13,307
31
26,825
Maxrrnum
14,848
20,845
46
44,994
Year
Subpart H - Nonwoven Manufacturing
Subcategory
WPS Total
Normalized
Av#/d
Max#/d
#Id
2000
10,794
15,153
15,112
2001
10,794
15,153
15,112
2002
10,794
15,153
15,112
2003
8,565
12,024
11,991
2004
YTD
3,594
7,872
7,850
Average
8,908
13,071
13,035
Maximum
10,794
15,153
15,112
Notes:
Av#/day is actual production divided by number of calendar days
Max#/day is weekly maximum production divided by the number of operating days during that week
Operating Time is the percentage of time the machines operated during the year (actual operating hours whether making product or not).
Operating rate is the av#/day divided by operating time
Normalized rate (for WPS data only) is production if sustained Max#/day for all 52 weeks of the year
Sanitary Wastewater is also received and treated at the Interface wastewater treatment facility
Bolded numbers are used in effluent Iimts tab

Table 2
Production Data for NDPES Effluent Permit Calculations
Year
Subpart C - Low Water Use Processing
Total
Operating Level
Av#/d
Max#/d
#/day
2000
10,458
14,680
19,399
2001
8,572
12,034
20,368
2002
13,872
19,473
31,719
2003
6,839
15.180
17,172
2004
YTD
6,109
11,400
18,184
Year
Subpart D - Woven Fabric Finishing Subcategory
Total
Operating Rate
Av#/d
Max#/d
#Id
2000
71,721
84,980
121.654
2001
54,159
60,325
102,397
2002
62,418
71,921
100,679
2003
46,977
67,823
82,720
2004
YTD
40,503
84,236
102,168
Year
Subpart E - Knit Finishing Subcategory
Total
Normalized
Av#/d
Max#/d
#/d
2000
1,907
2,303
2,297
2001
1,256
1,516
1,512
2002
243
294
293
2003
110
224
223
2004
YTD
44
181
181
Year
Subpart G - Stock and Yarn Finishing Subcategory
Total
Operating
Av#/d
Max#/d
#/d
2000
14,848
20,845
44,994
2001
9,948
13,965
21,486
2002
7,346
10.313
21,928
2003
5.407
14.187
21,980
2004
YTD
4.185
7.225
23,738
Ycar
Subpart H - Nonwoven Manufacturing Subcategory
Total
Normalized
Av#/d
Max#Id
#Id
2000
10,794
15,153
15,112
2001
10.794
15,153
15,112
2002
10,794
15,153
15,112
2003
8,565
12,024
11,991
2004
YTD
4,185
12,024
11,991

Table 2
TOTAL INDUSTRIAL
Total
Operating Rate
Av#!d
Max#/d
#/d
2000
109,728
137,961
203,456
200"
84,729
102,993
160,875
200
94,673
117,155
169,731
2002,
67,898
109,438
134.087
200.1
55,026
115,066
156,262
Av#/day is actual production divided by number of calendar days
Max#/day is weekly maximum production divided by the number of operating days during that week
Operating Time is the percentage of time the machines operated during the year (actual operating hours whether making product or not).
Operating rate is the av#/day divided by operating time
Normalized rate (for WPS data only) is production if sustained Max#/day for all 52 weeks of the year

Calculation of Potential Effluent Limitations based upon Calendar Average Production, Maximum Weekly Average Production,
Subpart C - Low Water Use Yam Processin
Avg AVERAGE
9,170
Avg MAXIMUM
14,553
Avg Operating Rate
21,
_
Elkin Capacity
35758
EPA Categorical Limits
Daily Max
Daily Ave
Daily Max
Daily Ave
Daily Max
Daily Ave
Daily Max
Daily ve
Daily Max
Daily Ave
BOD
1.4
0.7
12.84
6.42
20 37
10 19
29 92
14.96
50.06
25.03
COD
2.8
1.4
25.68
12.84
40.75
20.37
5983
29.92
100.12
50.06
TSS
1.4
0.7
12.84
6.42
20.37
10.19
29.92
14.96
50.06
25.03
Subpart D - Woven Fabric Finishing
Avg AVERAGE
58,081
Avg MAXIMUM
75,402
Avg Operatin a
( 103,74
Elkin Capacity
143304.7
EPA Categorical Limits
Daily Max
Daily Ave
Daily Max
Daily Ave
Daily Max
Daily Ave
Daily Max
Da�li y-Rve
Daily Max
Daily Ave
BOD
6.6
3.3
383.33
191.67
497.66
248.83
684.74
342.37
945.81
472.91
COD
60
30
3,484.86
1,742.43
4,524.15
2,262.07
6,224.89
3,112.44
8,598.28
4,299.14
TSS
17.8
8.9
1,033.84
516.92
1,342.16
671.08
1,846.72
923.36
2,550.82
1,275.41
Sulfide
0.2
0.1
11.62
5.81
15.08
7.54
20.75
10.37
28.66
14.33
Phenol
0.1
0.05
5.81
2.90
7.54
3.77
10.37
5.19
14.33
7.17
T Chromium
0.1
0.05_ 5.81
2.90
7.54
3.77
10.37
5.19
14.33
717
Subpart E - Knit Finishing
Avg AVERAGE
712
Avg MAXIMUM
904
Ra Avg Operating
901
Elkin Capacity
2677
EPA Categorical Limits
Daily Max
Daily Ave
Daily Max
Daily Ave
Daily Max
Daily Ave
Daily Max
Daily Ave
Daily Max
Daily Ave
BOD _
5
2.5
3.56
1.78
4.52
2.26
4.51
2.25
13.39
6.69
COD
60
30
42.72
21.36
54.22
27.11
54.07
27.03
160.62
80.31
TSS
21.8
10.9
15.52
7.76
19.70
9.85
19.64
9.82
58.36
29.18
Sulfide
0.2
0.1
0.14
0.07
0.18
0.09
0.18
0.09
0.54
0.27
Phenol
0.1
0.05
0.07
0.04
0.09
0.05
0.09
0.05
0.27
0.13
T. Chromium
0.1
0.05
0.07
0.04
0.09
0.05
0.09
0.05
0.27
0.13
Subpart G - Stock & Yam Finishing
Avg AVERAGE
8,347
Avg MAXIMUM
13,307
Avg Operating
(26,825
Elkin Capacity
EPA Categorical Limits
Daily Max
Mon Ave
Daily Max
Daily Ave
Daily Max
Daily Ave
Daily Max
Daily Ave
Daily Max
Daily Ave
BOD
6 48
3.24
54.09
27.04
86.23
43.11
173.83
86.91
0.00
0.00
COD
84.6
42.3
706.14
353.07
1,125.78
562.89
2,269.41
1,134.71
0.00
0.00
TSS
17.4
8.7
145.23
72.62
231.54
115.77
466.76
233.38
0.00
0.00
Sulfide
0.24
0.12
2.00
1.00
3.19
1.60
6.44
3.22
0.00
0.00
Phenol
0.12
0.06
1.00
0 50
1.60
0.80
3.22
1.61
0.00
0.00
T. Chromium
0.12
0.06
1 00
0.50
1.60
0.80
3.22
1.61
0.00
0.00

Table 3
TOTAL k
Potential Permit Limits
5' ;c l , e,,
Avg AVERAGE
Avg MAXIMUM
Avg Operating Rate
Elkin Capacity
Avg AVERAGE
Avg MAXIMUM
Avg Operating Rate
Elkin Capacity
Dairy Max
Daily Ave
Daily Max
Daily Ave
Daily Max
Daily Ave
Daily Max
Daily Ave
Daily Max
Daily Ave
Daily Max
Daily Ave
Daily Max
Daily Ave
Daily Max
Daily Ave
Daily Max
Daily Ave
BOD
2434.6
646.5
453.82
226.91
608.78
304.39
892.99
446.49
1,009.26
504.63
81.36%
64.90%
74.99%
52.92
63.32%
30.94%
58.55%
21.94%
COD
37645
9017
4.259.40
2.129.70
5,744.89
2,872.44
8,608.20
4,304.10
8,859.02
4,429.51
88.69%
76.38%
84.74%
68.14
77.13%
52.27%
76.47%
50.88%
TSS
6274.5
1601.5
1,207.44
603.72
1,613.78
806.89
2,363.04
1,181.52
2,659.24
1,329.62
80.76%
62.30%
74.28%
49.62°
62.34%
26.22%
57.62%
16.98%
Sulfide
74.8
19.2
13.76
6.88
18.45
9.23
27.37
13.68
29.20
14.60
81.60%
64.16%
75.33%
51.94
63.41%
28.73°/m°o��
60.97%
23.97%
Phenol
37.4
9.6
6.88
3.44
9.23
4.61
13.68
6.84
14.60
7.30
81.60%
64.16%
75.33%
51.94
63.41%
28 73,60.97%
23.97%
T. Chromium
37.4
9.6
6.88
3.44
9.23
4.61
13.68
6.84
14.60
7.30
81.60%
64.16%
75.33%
51.94
63.41%
28.73 60.97%
7°I
23.97%

•. � BPA Environmental & Engineering, Inc.
March 26, 2004
Mr. Joe Corporon
NC DENR, DWQ
NPDES Permit Section
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: NPDES Permit Renewal Application - NC 0005312
Interface Fabrics Group WWTP
BPA Project No. 0216.008
Dear Mr. Corporon:
Thank you for the assistance and information you and Mr. Mickey have provided regarding the NPDES
permit renewal for the referenced site. As we have discussed, BPA is currently assisting CMI, the
property owner, in a REC-directed voluntary remedial action under jurisdiction of the Inactive Hazardous
Waste Branch. The Supplement to Permit Cover Sheet for the existing permit authorizes treatment and
discharge of contaminated groundwater with the industrial wastewater. This provision could save
unnecessary and significant future expenditure of escrowed monies for a stand-alone groundwater treatment
system. We understand that this Supplement will continue to be included in the 2004 renewal. Please
contact either Ed Hedgecock or me if this should change.
Sincerely,
BPA ENVIRONMENTAL & ENGINEERING, INC.
Ju1i`a' I. Geniac
Geologist
R. Edward He c ecock, P.E., P.G.
Principal
cc: Jim Ovenden, CMI
Mike Mickey, NC DENR
MAR 2 9 2004
2641-G Randleman Road, Greensboro, NC 27406-5159 • Phone [phone] • Fax [phone]

DES WASTEWATER
APPLICATION
PERMIT RENEWAL
(PERMIT NO. NC0005312)
INTERFACE FABRICS GROUP SOUTH, INC
ELKIN FACILITY
SURRY COUNTY, NORTH CAROLINA
July 2003
Submitted to: North Carolina DENR
NPDES Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Prepared by: Interface Fabrics Group Inc.
Corporate Environmental
Affairs
PO Box 179, 9 Oak Street
Guilford, ME 04443
Contact:
Shannon Cox
Environmental Specialist
207.876.3331 (ext. 134)
INTERFAC E
Fabrics Group

INTERFACE
Interface Fabrics Group
July 28, 2003
Dave Goodrich
Supervisor, NPDES Unit
North Carolina Department of Natural Resources
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: NPDES Wastewater Permit Renewal Application for Interface Fabrics Group
South, Inc. (NC0005312)
Dear Dave:
Enclosed please find three copies of the NPDES Wastewater Permit renewal application
for Interface Fabrics Group South ("IFGS"), permit NC0005312, located in Elkin. Per
our pervious telephone conversation, pollutant testing for radioactivity and dioxin were
waived from the testing requirements to control costs and because these pollutants are not
commonly associated with textile manufacturing. The application consists of an updated
Form 1 and Form 2C, as well as all applicable attachments.
There have been several relevant changes at the facility since the last permit renewal that
warrant mentioning in this cover letter. These issues include facility ownership changes,
pollutant sources, historical and projected production, proximity of groundwater drinking
water wells, and storm and wastewater permits for the facility. Each is discussed below.
Facility Ownership
The IFGS facility was originally part of a larger facility owned and operated by CMI, Inc.
CMI sold a portion of the property to Interface Fabrics Group in May 2000. The
wastewater discharge permit was transferred to Chatham Inc. (a wholly owned subsidiary
to Interface Fabrics Group Inc.) at the time of the sale. CMI retained ownership of the
abutting Fiber Woven and Knitting facilities. CMI subsequently leased these facilities to
WestPoint Stevens. Wastewater from the fiber woven facility is discharged to IFGS
wastewater treatment plant covered under permit NC0005312. The actual production for
the WestPoint Stevens manufacturing process is included in Form 2C.
CAMBORNE CHATHAM GUILFORD OF MAINE INTEK TEKNIT TEKSOLUTIONS TOLTEC
P.O. Box 179, 9 0ak Street, Guilford, ME 04443-0179 207.876.3331 207.876.3812 fax
www.interfacefabricsgroup.com

In 2001, IFGS and the Town of Elkin began exploration of a consolidated municipal and
industrial wastewater treatment facility. In May 2002, operation of the wastewater
treatment plant was transferred to the Town of Elkin while IFGS maintained ownership
of the facility. The wastewater discharge permit was transferred to the Town of Elkin at
that time. The town operated the facility from May 2002 until March 30, 2003. In March
2003, the Town of Elkin returned operational control of the wastewater treatment plant to
IFGS (IFGS changed its name from Chatham Inc. to Interface Fabrics Group South in
December 2002). IFGS applied for a transfer of the permit from the Town in April 2003.
Pollutant Sources
The wastewater treatment plant receives process wastewater from the yarn
manufacturing, dyeing, and finishing operations located at the IFGS facility and
wastewater from the dyeing and finishing operations located at the adjacent West Point
Stevens facility. Production figures and the applicable Effluent Guidelines for these
operations are contained in Form 2C.
Additionally, the wastewater treatment facility receives sanitary wastewater from the
IFGS facility as well as a portion of the Town of Elkin. 1FGS currently employs
approximately 600 people and the Town of Elkin has a population of 4,200 residents
(2000 Census statistics). IFGS requests that the renewed permit continue to reflect the
treatment of sanitary wastewater.
Production
IFGS has provided actual production for the IFGS facility and the adjoining WestPoint
Stevens facility in Form 2C and Appendix A for the years 2000-2003 year-to-date. The
applicable effluent guidelines have been identified for each production unit. It is
important to note that the actual historical production during this period does not reflect
the production capacity of the facility. During this period, facility production decreased
substantially due to the financial problems that CMI faced and due to a significant decline
in the textile industry. LFGS's plans for the facility are to increase the production at this
facility to its current capabilities. To that end, in October 2002, IFGS announced the
closure of its facility in Aberdeen, NC and consolidation of that business to the Elkin
facility. That change is currently in progress with consolidation completion targeted for
the end of 2003. IFGS respectfully requests a dialogue with NCDENR on the appropriate
production based effluent limitations for this facility.
Groundwater Drinking Water Wells
A review of the property surrounding the IFGS facility, conducted by two consultants in
2001 and 2000, indicate that there are no potable water supply wells within a 1,500-foot-
radius of the facility complex. The nearest water supply well to the facility was about'h
miles to the west along NC Highway 268. All nearby residences and commercial
businesses receive potable water from the Elkin Municipal water supply.
Interface Fabrics Group South, Inc. 2

Stormwater and Wastewater Permits
The IFGS facility currently has one stormwater permit, one general wastewater permit, in
addition to the NPDES permit being renewed in this application. The stormwater permit
is NPDES individual permit (NCS000333) that covers stormwater exposed to industrial
activity. The general wastewater permit (NCG500000) covers intermittent overflows
from the onsite raw water reservoirs. Both the stormwater discharge and the raw water
reservoir discharge flow to the Yadkin River from Outfall 002 as shown on Figure 1-1.
I sincerely appreciate your assistance in preparing this renewal application. I look
forward to discussing the permit renewal with you in the near future. I can be reached at
800-762-3331 ext. 134 or via email at Shannon.cox@,interfacefabricsgroup.com.
Sincerely, �^
Shannon Cox
Environmental Specialist
Interface Fabrics Group, Inc.
Enclosures (3)
cc: Mike Hargett - Vice President of Operations, Interface Fabrics Group South, Inc.
Wendy Porter — Director Environmental Management, Interface Fabrics Group, Inc.
Will Fritz — Environmental Engineer, Interface Fabrics Group South, Inc.
Interface Fabrics Group South, Inc. 3

INTERFACE FABRICS GROUP SOUTH INC.
ELKIN FACILITY
SURRY COUNTY, NORTH CAROLINA
FIGURE 1-1
FACILITY LOCATION
NPDES WASTEWATER APPLICATION
7/31/2003
0
ACAD-2002
FILE CHATHAM/ELKIN
FOLDER SITE LOCATION
DATE 7/31/03
SCALE 1"=1000'
b Ron Nelson
Guilford, Facility
B

RAW MATERIAL
RECEIVING
YARN
MANUFACTURING
- EXTRUSION
- TEXTURIZING
NW -
PACKAGE
DYEING
Do -
WARPING
SLASHING
WEAVING
FINISHING
- FLAME PROOFING
- SOIL REPELLENCY
- LATEX COATING
-SHEARING
- NAPPING
- DRYING
f
INSPECTION
WAREHOUSE
DISTRIBUTION
PIECE
DYEING
INTERFACE FABRICS GROUP SOUTH INC.
ELKIN FACILITY
TERFACE SURRY COUNTY, NORTH CAROLINA
FAB R I CS GROUP
FIGURE 1-3
PRODUCTION FLOW SCHEMATIC
NPDES WASTEWATER APPLICATION
7/31 /2003
ACAD-2002
FILE CHATHAM/ELKIN
FOLDER PRODUCTION FLOW SCHEMATIC
DATE 7/31/03
SCALE NONE B8
by Ron Nelson
Guilford, Facility

z
0 o
i= a_
Q 0
0 0
a_ 0
> 0
Lu Los
DRYERS
0
o_
0
0
0
0
Sri
YARN MFG
DYEING &
FINISHING
OPERATIONS
>BIG ELKIN CREEK
897,000 GPD
STEAM
D4
SETTLING
FILTRATION
w
U)
0
J
w
82,000 GPD
483,000 GPD
10,000 GPD
I
EVAPORATION/
OTHER LOSSES
560,000 GPD
0
o_
0
0
0
0
BOILER
FEED
WATER
CLEARWELL
210,795 GPD
164,000 GPD
WEST POINT
STEVENS
WOVEN FIBER
PLANT
OVERFLOW (10")
DISCHARGE #1
(TO STORMWATER CULVERT)
(INTERMITTENT)
LARGE
RESERVOIR
(10") { (12") 733,000 GPD
L
0
0_
0
0
0
ri
OFFICE AC (6„) TO
RETURN OFFICES
t
IFGS
WASTEWATER
TREATMENT
PLANT
OVERFLOW
SMALL
RESERVOIR
210,795 GPD
475,410 GPD
CONDENSER
COOLING POND
15,000 GPD
COMPRESSOR
COOLING WATER
IMPINGER
SANITARY
WASTEWATER
67,150 GPD
EVAPORATION
FLY ASH
BASIN
INTERFACE FABRICS GROUP SOUTH INC.
ELKIN FACILITY
SURRY COUNTY, NORTH CAROLINA
(10")
TO YADKIN RIVER
FIGURE 1 -4
WATER USE SCHEMATIC
NPDES WASTEWATER APPLICATION
7/31/2003
ELKIN CITY WATER SUPPLY
(BY REQUEST ONLY)
ACAD-2002
FILE CHATHAM/ELKIN
WATER USE SCHEMATIC
DATE 7/31/03
SCALE NONE
by Ron Nelson
Guilford, Facility
B8

1—T
SCREENING
all 3—E
PRE —AERATION
(EQ BASIN)
TREATMENT FLOW
UNIT CODE SIZE RETENSION (MGD)
1—T SCREENING
6 SCREENS
10 DAYS
0.897
3—E PRE —AERATION
2.9 MG
24 HR
0.897
3—B AERATED LAGOONS
2.1 MG
24 HR
1.397
1—U SETTLING/AEROBIC DIGESTION
0.376 MG each
9 HR
.07 each
5—A AEROBIC DIGESTION
0.040 MG
10 DAYS
0.004
5—H DRYING BEDS
6 BEDS
— — —
0.003
5—P LAND APPLICATION
260.3 ACRES
NA
0.0007
2—F DISINFECTION
0.086 MG
2 HR
0.897
4—A DISCHARGE TO
SURFACE WATERS
20 INCH BANK OUTFALL PIPE
NA
0.897
INTERFACE
FABRI CS GROUP
3—B
AERATED
LAGOONS
t
1—U
SETTLING
2 SECONDARY CLARIFIERS)
2—F
DISINFECTION
(CHLORINE)
5—A
AEROBIC DIGESTION
4—A
DISCHARGE TO
SURFACE WATERS
5—H
DRYING BEDS
OUTFALL 001
5—P
LAND APPLICATION
INTERFACE FABRICS GROUP SOUTH INC.
ELKIN FACILITY
SURRY COUNTY, NORTH CAROLINA
FIGURE 1-5
WASTEWATER TREATMENT PLANT SCHEMATIC
NPDES WASTEWATER APPLICATION
7/31/2003
ACAD-2002
FILE CHATHAM/ELKIN
WASTEWATER TREATMENT SCHEMATIC
DATE 7/31/03
SCALE NONE B8
by Ron Nelson
Guilford, Facility

Production Data for NDPES Effluent Permit Calculations
Year
Subpart C - Low Water Use Processing Subcategory
Total
Operating Level
Av#/d
Max#/d
#/day
2000
10,457
14,680
19,397
2001
8,572
12,034
20,369
2002
13,872
19,474
31,718
2003
12,737
17,881
32,207
Year
Subpart D - Woven Fabric Finishing Subcategory
Total
Operating Level
Av#/d
Max#/d
#/day
2000
73,502
103,186
132,455
2001
54,961
77,157
111,865
2002
62,308
87,470
107,914
2003
48,577
68,194
94,726
Year
Subpart E - Knit Finishing Subcategory
Total
Operating Level
Av#/d
Max#/d
#/day
2000
125
176
235
2001
454
637
1,137
2002
392
550
790
2003
105
148
246
Year
Subpart G - Stock and Yarn Finishing Subcategory
Total
Operating Level
Av#/d
Max#/d
#/day
2000
14,848
20,845
44,995
2001
9,948
13,965
21,486
2002
7,346
10,313
21,929
2003
6,070
8,522
21,300
Year
Subpart H - Nonwoven Manufacturing Subcategory
Total
Operating Level
Av#/d
Max#/d
#Iday
2000
10,794
15,153
15,112
2001
10,794
15,153
15,112
2002
10,794
15,153
15,112
2003
8,565
12,024
11,991
• Max #Iday is calculated from maximum weekly production divided by an assumed five day work week. Operating level is calculated from
actual production and actual operating hours.

North Carolina Ceriodaphnia
Chronic Pass/Fail Reproduction Toxicity Test
LC50/Acute Toxicity Test
Effluent Concentration: 1.9%
Date
Passed
Failed
% Reduction
2/9/2000
X
2.81%
5/10/2000
X
-13.70%
8/16/2000
X
2.65%
11/15/2000
X
-0.55%
2/14/2001
X
-2.22%
5/9/2001
X
1.62%
8/22/2001
X
-1.36%
11 / 14/2001
X
-6.64%
2/6/2002
X
-11.65%
5/22/2002
X
-4.25%
6/19/2002
X
-12.84%
9/18/2002
X
4.21%
11/13/2002
X
3.27%
2/12/2003
X
2.01%
4/14/2003
X
0.00%
5/19/2003
X
0.00%