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HomeMy WebLinkAboutNC0034860_Permit Issuance_20050718Al MA ©ern NCDENR Gary Elder, Plant Engineer Schneider Mills P.O. Box 519 Taylorsviille, North Carolina 28681 Dear Mr. Elder. Michael F. Easley Governor William G. Ross, Jr., Secretary North Carolina Department of Environment and Natural Resources Alan W. Klimek, P.E., Director Division of Water Quality July 18, 2005 Subject: Issuance of NPDES Permit NCD034860 Schneider Mills W WTP Alexander County Division personnel have reviewed and approved your application for renewal of the subject permit. Accordingly, we are forwarding the attached NPDES discharge permit. This permit is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the US. Environmental Protection Agency dated May 9,1994 (or as subsequently amended). This final permit includes following major changes from the draft permit sent to you on May 11, 2005: • For Outfall 001: monitoring for silver has been removed from the permit based on the DMRs review; limits for BOD, COD, TSS, Sulfide, and Phenols have been increased due to the expected increase in the production as a result of plants consolidation. • For Outfall 002: Measurement frequency for flow has been changed to Weekly, and Sample type was changed to Instantaneous; sample type for TSS and Iron has been changed to Grab. • The Division cannot grant your request to remove limits for phenols and chromium These parameters are required byFederal guidelines for woven fabric finishing [40 CFR 410.42 (a)]. If a ryparts, measurement frequencies or sampling requirements contained in this permit are unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty (30) days following receipt of this letter. This request mist be in the form of a written petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed with the Office of Administrative Hearings (6714 Mail Service Center, Raleigh, North Carolina 27699-6714). Unless such demand is made, this decision shall be final and binding. Please note that this permit is not transferable except after notice to the Division. The Division may require modification or revocation and reissuance of the permit. This permit does not affect the legal requirements to obtain other permits which may be required bythe Division of Water Quality or permits required by the Division of Land Resources, the Coastal Area Management Act or any other Federal or Local governmental permit that maybe required. If you have any questions concerning this permit, please contact Sergei Chernikov at telephone number (919) 733-5083, extension 594. cc: Central Files NPDES Permit File Mooresville Regional Office/Surface Water Protection Aquatic Toxicology Unit Mr. Roosevelt Childress, EPA Region IV N. C. Division of Water Quality / NPDES Unit 1617 Mail Service Center, Raleigh, NC 27699-1617 Internet: h2o.enr.state.nc.us Sincerely, ORIGINAL SIGNED BY SUSAN A. WILSON Alan W. Klimek, P.E. Phone: (919) 733-5083 fax: (919) 733-0719 DENR Customer Service Center 1800 623-7748 Permit NCO034860 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY PERMIT TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, Schneider Mills, Inc. is hereby authorized to discharge wastewater from a facility located at Schneider Mills NC Highway 16 North Alexander County to receiving waters designated as Muddy Fork Creek within the Catawba River Basin, in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III and IV hereof. This permit shall become effective September 1, 2005. This permit and authorization to discharge shall expire at midnight on July 31, 2010. Signed this day July 18, 2005. ORIGINAL SIGNED BY SUSAN A. WILSON Alan W. Klimek, P.E., Director Division of Water Quality By Authority of the Environmental Management Commission Permit NCO034860 SUPPLEMENT TO PERMIT COVER SHEET All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked. As of this permit issuance, any previously issued permit bearing this number is no longer effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the permit conditions, requirements, terms, and provisions included herein. Schneider Mills, Inc. is hereby authorized to: 1. Continue discharging 0.780 MGD of treated process -contact and domestic wastewater via outfa11001 from a treatment facility with the following components: • Bar screen • Instrumented flow metering device • Aeration basin with two mechanical aerators • Clarifier • Sludge return pumps • Aerobic digester • Cascade aeration and • Sludge drying beds 2. Continue discharging non -contact wastewater from two (2) settling ponds connected in series via outfall 002 (flow not limited). The discharge consists of: • Water treatment plant (WTP) filter backwash This facility is located at Schneider Mills. Inc. off NC Highway 16 North in Alexander County. 3. Discharge from said wastewater treatment works through Outfall 001 and Outfall 002 to Muddy Fork Creek (see attached map), classified C waters within the Catawba River Basin. � t� 1. l� IIpshramSamp7eTttiit' \ ' - Schneider Mills, Inc. O Lf'alls 001 and 002 ON PointoS o EEE c. T �n � F � w -� � , ,rl - � � i � T� .A vl I Schneider Mills, Inc. Facility Loeafion SCateGrld auad: D14 NW Taylomr le, NC not to scale Lathiade 35° 55 13' N Lmgitude 81011' 28" w PernittedFlo . 0.780MGD NPDFS PemritNo. NC0034860 R�lvint!Strmm Muddy Fodc Cm& Drainage Basin: Catawba Riv Basrti North StreamClam C Sub -Basin: 03-08-32 Catawba C-urity Permit NCO034860 A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (001) During the period beginning on the effective date of the permit and lasting until expiration, the permittee is authorized to discharge treated wastewater through Outfall 001. Such discharges shall be limited and monitored by the permittee as specified below: ,,.F.L�:1_ v 4 n yr nY� ii,5 �,'• ' t -�: ;`yk s', . �LS.r:.. .:F-.4. •. � it'��? .3 •� -iiS ■■## 4'�y. eraEli li ! p jl � .�;etiA M �C�t� s)RN�E Wit? R^3A4iR' - J o ion.l- t Yly ' i''.��R,���. :: Flow 0.780 MGD Continuous Recording Influent or Effluent BOD, 5 day, 200C 21.3 mg/L 138.6 lbs/day 42.6 mg/L 277.2 ibs/da Weekly Composite Effluent Total Suspended Solids SS 131.3 lbs/day 288.8 lbs/day Weekly Composite Effluent COD 719.3 lbs/day 1118.3 lbs/day Weekly Composite Effluent NH3 as N (April 1 through October 31 1.9 mg/L 9.5 mg/L Weekly Composite Effluent NH3 as N (November 1 through March 31 4.7 mg/L 23.5 mg/L Weekly Composite Effluent Dissolved Oxygen2 Weekly Grab Effluent Total Nitrogen (NO2 + NO3 + TKN Quarterly Composite Effluent Total Phosphorus Quarterly Composite Effluent Chronic Toxicity, Quarterly Composite Effluent Temperature (°C) Weekly Grab Effluent H4 Weekly Grab Effluent Sulfide 4.2 lbs/day 8.4lbs/da 2/Month Composite Effluent Phenols 2.1 lbs/day 4.2lbs/da 2/Month Composite Effluent Total Chromium 109 1022 2/Month Composite Effluent Conductivity Weekly Grab Upstream & Downstream Temperature, °C Weekly Grab Upstream & Downstream Dissolved Oxygen Weekly Grab Upstream & Downstream Table Footnotes: 1. Upstream = at least50 feet upstream from the outfall. Downstream = at or near NCSR 1313. 2. Daily average effluent concentration of dissolved oxygen shall not fall below 5.0 mg/L. 3. Chronic Toxicity (Ceriodaphnia) at 46 %; quarterly during March, June, September, December; See Special Condition A. (3.) 4. pH shall not fall below 6.0 nor exceed 9.0 standard units. Effluent shall contain no floating solids or foam visible in other than trace amounts. Permit NCO034860 A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (002) During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge treated wastewater through Outfall 002. Such discharges shall be limited and monitored by the Permittee as specified below: PARAMETERS EFFLUENT LIMITS MONITORING REQUIREMENTS Monthly Average— Daily Maximum Measurement Frequency Sample Type Sample Location, Flow Weekly Instantaneous Influent or Effluent Total Suspended Solids (TSS) 30 mg/L 45 mg/L 2/Month Grab Effluent Settleable Solids 0.1 mL/L 0.2 mL/L Weekly Grab Effluent Iron Weekly Grab Effluent H2 Weekly Grab Effluent Total Residual Chlorine Monthly Grab Effluent Turbidity3 Weekly Grab Upstream & Downstream Table Footnotes: 1. Upstream = at 1east50 feet upstream from the outfall. Downstream = at or near NCSR 1313. 2. pH shall not fall below 6.0 nor exceed 9.0 standard units. 3. Discharge shall not cause stream turbidity to exceed 50 NTU. If natural background turbidity exceeds 50 NTU, discharge shall not increase receiving -stream turbidity. Effluent shall contain no floating solids or foam visible in other than trace amounts. Permit NCO034860 SUPPLEMENT OT EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS SPECIAL CONDITIONS A. (3.) 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 46%. 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 March, June, September, and December. Effluent sampling for this testing shall be performed at the NPDES permitted final effluent discharge below all treatment processes. If the test procedure, performed as the first test of any single quarter, results in a failure or ChV below the permit limit, then multiple -concentration testing shall be performed at a minimum, in each of the two following months, as described in "North Carolina Phase H 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 H 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 TBP3B for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to be sent to the following address: Attention: NC DENR DWQ / Environmental Sciences Section 1621 Mail Service Center Raleigh, North Carolina 27699-1621 Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 30 days after the end of the reporting period for which the report is made. Test data shall be complete, accurate, include all supporting chemical/physical measurements and all concentration/response data, and be certified by laboratory supervisor and ORC or approved designate signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream. Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility name, permit number, pipe number, county, and the month/year of the report with the notation of "No Flow" in the comment area of the form. The report shall be submitted to the Environmental Sciences Branch at the address cited above. Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be required during the following month. Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water Quality indicate potential impacts to the receiving stream, this permit may be re -opened and modified to include alternate monitoring requirements or limits. NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism survival, minimum control organism reproduction, and appropriate environmental controls, shall constitute an invalid test and will require immediate follow-up testing to be completed no later than the last day of the month following the month of the initial monitoring. ' a'eso sr"6r ' A UNITED STATES ENVIRONMENTAL PROTECTION AGENCY <m >W REGION 4 ATLANTA FEDERAL CENTER o a /t61 FORSYTH STREET 14 PROZEO ATLANTA, GEORGIA 30303-89 MAY 1 6 2005 1YMAY 1 R 2005 Sergei Chemikov, Ph.D North Carolina Department of Environment and Natural Resources Division of Water Quality NPDES Unit 1617 Mail Service Center Raleigh, NC 27699-1617 SUBJ: Draft NPDES Permit Schneider Mills Permit No. NCO034860 Dear Dr. Chemikov: In accordance with the EPA/NCDENR MOA, we have completed review of the draft permit referenced above and have no comments. We request that we be afforded an additional review opportunity only if significant changes are made to the draft permit prior to issuance or if significant comments objecting to the permit are received. Otherwise, please send us one copy of the final permit when issued. Sincerely, Marshall Hyatt, Environmental Scientist Permits, Grants, and Technical Assistance Branch Water Management Division Internet Address (URL) • http://www.epa.gov Recycled/Recyclable • Printed with Vegetable 01 Based Inks on Recycled Paper (Minimum 30% Postconsumer) mailb6x:///CVDocuments%20and%20Settings/sergei chernikov/Applica... Subject: Schneider Mills, NCO034860 From: Sergei Chernikov <sergei.chernikov@ncmail.net> Date: Tue, 14 Jun 2005 11:25:14 -0400 To: Marshall <Hyatt.Marshall@epamail.epa.gov> Marshall, I need to make a few corrections to the above referenced permit. Unfortunately, records of the modification (December 9, 2002) to the permit were missing from our files and I did not make appropriate changes when permit was drafted. Hopefully, you have the December 9, 2002 letter in your files. The following corrections have to be made for Outfall 002: 1) Measurement Frequency for flow has to be changed to Weekly, and Sample type has to be changed to Instantaneous. 2) Sample Type for TSS and Iron has to be changed to Grab. For Outfall 001 monitoring for Silver has to be discontinued. One of the conditions of the previous permit was: " ... if silver is not detected after one year from the permit effective date (4 additional data points), the Division will consider the permittee's request to discontinue quarterly silver monitoring." DMR review indicated the silver was not detected in the effluent since 06/11/02. Pemittee also informed us that they are closing down Alexander Mills facility and will be consolidating operation at Taylorsville Plant. As a result production will be increased to 42,000 lb/day from 40,000 lb/day beginning mid -August. I propose to recalculate their effluent limits based on new number. The difference should be insignificant. The new permit will become effective September 1, 2005. Please review proposed changes. Thank you! Sergei Sergei Chernikov, Ph.D. Environmental Engineer NPDES Unit 1617 Mail Service Center Raleigh, NC 27699-1617 phone: 919-733-5083 ext. 594 fax: 919-733-0719 of 1 6/15/2005 10:08 AM Schneider Mills, Inc. PO Box 519 (828) 632-8181 Phone Taylorsville, NC 28681 (828) 632-9834 Fax May 20, 2005 Sergei Chemikov NC Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Dear Sir, We have closed our plant at Alexander Mills and we are moving the equipment and production to our Taylorsville Plant. Moving the machinery will be complete in late July to mid August. Production should be up by mid August to early September. Expected production would be approximately 6000 lb. per day increase or 42,000 lb. a day total. These are forecasted at levels of last quarter orders. Thank you for working with us during our restructuring. Thank you, 4 . Ek" Gary D. Elder f-1 r Y2 6 20D5 EILM' DENR - WATER OUALITYIJ POINT SOURCE BRANCH Schneider Mills, Inc. PO Box 519 Taylorsville, NC 28681 May 11, 2005 Sergei Chernikov NC Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Subject: Amendment to Permit NPDES NCO034860 Schneider Mills WWTP Alexander County Dear Mr. Chernikov, (828) 632-8181 Phone (828) 632-9834 Fax In our last permit it was stated that if silver is not detected after one year from the J x effective date, that the Division will consider discontinuing quarterly silver monitoring. �> Silver has not been detected since our last permit was issued. We request this bet en V11 our new permit. Due to no detection since November 1, 2002 the effective date of our last J permit <` y We would like for you to consider taking phenols and total chromium off of our new permit also. We noticed in this draft permit on the limitation page that Bod, Sulfide and Phenol limits have been lowered due to the reduction in the production volume. We would like for the limits to stay the same as they are now. Closing of our Alexander Mills Plant and consolidate their loom and orders to the Taylorsville Plant will raise our production at this plant. The machinery should be completed late July. We should expect an increase of production shortly after that. On the supplement to Permit Cover Sheet under #2 on this page for 002. It is stated that the discharge is air conditioning condensate water treatment plant (WTP) filter backwash, boiler blow down and storm water runoff. The only dischaz -e from 002 is water treatment plant (WTP) filter backwash. Also on a 02 on the limitatt pnso�age under flow measurement sample type it has recording it needs to be changed to instantaneous. We have no flow recorder installed. - ?— llso under sample type for 002 we would like fob TSS and iron to stay Grab_ ti sample instead of composite. We have always taken Grab samples for 002. We would like for you to consider these changes to the draft permit. If you have any questions, please call Darren Webb or Gary Elder at (828) 632-8181. t Sincerely, ,g 9WJ' / l Darren Webb O.R.C. M//V/04 Roo. GUG�r' Schneider Mills, Inc. PO Box 519 (828) 632-8181 Phone Taylorsville, NC 28681 (828) 632-9834 Fax _J May 11, 2005 Sergei Chernikov NC Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Subject: Amendment to Permit NPDES NCO034860 Schneider Mills WWTP Alexander County Dear Mr. Chernikov, In our last permit it was stated that if silver is not detected after one year from the effective date, that the Division will consider discontinuing quarterly silver monitoring. Silver has not been detected since our last permit was issued. We request this be taken off our new permit. Due to no detection since November 1, 2002 the effective date of our last permit. We would like for you to consider taking phenols and total chromium off of our new permit also. If you have any questions, please call Darren Webb or Gary Elder at (828)632-8181. Sincerely, Darren Webb O.R.C. r p N 2 N 0 W( DERR - WATER QUALITY POINT SOURCE BRANCH •..r�.�a-s..�..i...W1.a:�'.�hW1[...+.r.1/....Ja W.veFt'ML�� omicur NORTH CAROUNA ENVIRONMENTAL- r� 2 MANAGEMENT-. , )MMISSIOWNPDES UNIT 1617 MAIL• iSERVICE - ` CENTERS{':.. WEIGH, NG276WI617 NORTH CAROLINA DTIFICATION OF INTENT TO ISSUE A NPDES'-- CATAWBA COUNTY NASTEWATER PFRMIT' the basis ot�thoraugh:staff nv --and applicabon dVNC eras .Statuta14321, `Public 92=500:::end other--fawlul cards -and tegalations, the. being first duly sworn, s s: That he or h :Carolina° Environmental agement .Conimisslon:prd- asAd4ssue:a4Nation- Pollu- %." she 1s .. of the ; .Dlscharge4,�_ Elimination )em== (NPOES):. 'fir Hickory Daily Record, a newspaper pub- harge=pemrlt -to: they per- .$) lished at Hickory,North Carolina; that in Misted • below. effective 49 i from:Ithe. publish Aate- of the issues of the said newspaper for the nd Y following days, to wit: tenL-icontments ::regarding,. pmpbsed permit :wff tie ac-. ed::umll 4,30::days-*after.ther•. 01 isirtdate' of .this.nottce.: Afl / ......... . meats;;�jeceived. prioX�-•to . dke4m' considered: in the A. deterttilnations -:regarding . ptnposed perrrtita.TTthie : p .................................................................... . )�cf. the!•NC 'Division.:.of to bf O&Ky ;'may decide a/y�ublle interest f a * 5 y ' there appeared spaced lest the draftpreritand lines of advertising as per attached named tr supporffn ;• mtamtation iflesed:ta r►nhiecon• : advertiser: ns rZresent ln:the-dML pe1;. - are=aveflablatuppootx�reguest The Hickory Daily Record is a qualified news- Y 4 f� 1-597 nfomiationtito>theNCDIvI+ paper within the meaning of lion of the of4YaterQuafity"at=ths re': adifress-ar: call=the°FoiM General tatutes of N. C. rce�Brandl�tat��19=733-• /► 3, �;extensioe520°k Please �� 1C ides, the w•NPDES peftk ......... Affiant rberkttachod).;in any: com= flcetlOrU,' Interested,"persons' erQiiafdy at 512:N sai�- Sworn to and subscribed before me, r < Street;-;"Relelgh? NC ;04At48":::between Swthe rs-o:00pm wiewintorrriatfon•anfile=; � , a this ........................ ..................... day of Imll_ "furore: ..:.. wm lied-&2renewalDES :�IC00368715`s for:: •: its �..-\ 2O O y...................................... , ........ rcedent, Olvlsion :Plant !TP �', In Catavib'a': County: -�pertriitted°facility t-dis- rges�tl8ated .w8SteiKatef"`t0 So. _ , , ..-... ... ...-.. ...... ....................... ;. t3rai>dt�fn~use:=Catawba Curren Notary Public er:�Basfric' 4amno- chtodne and total residual >.waterMqualit Almifed::.This ;tage.ma: affect, tiit<ir�: aw ns:in s-parhon of -the My Commission Expires at . arshed. /�20 9 iNGs.Lions•�Foundagon� Inc. ...................... 39,:�Sfierrills;FaM .NC t73]'has. plledifof renewal PrVAC004425V for Its mp:,Dogw Wt-,WWTP.=in teWba: Courty.:-Th% -pemtit- iadfii}r? disaharges�<.treated nestia wastewater:.:;to :': the untain Creek:arm of. lake' rinanlri�the� Catawba -River sin ::Ciaranbv`•fecd collform watec.::qusutY : amrtey: -=r tus _�s- diargernlaysaifect_frthrn3 alto- �catiats in isa`pardmof-Moun- Wd'Oreek.: ^f H -gr�limited'�. Tfrts�disohalge': ect tubr awioddons in `ihisporbot>'of MOWTW'Creek. _ The.t�fv�oi"Carwvet;<�P.Q..Boz Raver Basin::. Currently,OBOD, ammonla;:.DO, -#ecal � coliforrn, an&chlorine.,am,water- quality II;i :This.dfsc M9- may afi- fect., hrre-<sllotafions . in -this porfion,of.the river basin. SchneideCMllls JncjP..O.Box 519,,=7a#mv€Ile,° .*NC,,°28681, Alexander .County,- Aas applied for renewal. of its NPDES dis- ing to thmft e F) Muddy- Creek • rm :the Catawba River Basin. 'This facility operates t6 .._outfalls; '.001 *.(treated wastawater), and: 002: (stow ater, non -contact wastewater). Currently BCD, TSS; ammo- nia, sulfide, phenois, and chro- mium Lare -water quality limited. This discharge +may affect fu- ture allocations In this portion of the Catawba River Basin. PUBLISH: May 2012MS To: Permits and Engineering Unit Water Quality Section Attention: Sergei Chernikov Date: May 16, 2005 NPDES STAFF REPORT AND RECO] County: Alexander MRO No.: 05-21 Permit No. NCO034860 PART I - GENERAL INFORMATION 1. Facility and address: Schneider Mills, Inc. Post Office Box 519 Taylorsville, North Carolina 28681 2. Date of investigation: May 6, 2005 SOC PriorTY?rdjdLr' h MAY 2 3 2005 3. Report prepared by: Michael L. Parker, Environmental Engineer H [ON UENR - WATER QUALITY I POINT SOURCE BRANCH yy 4. Persons contacted and telephone number: Gary Elder, Darren Webb, (828) 632-8181. 5. Directions to site: From the intersection of NC Hwy 16 and NC Hwy 90 in the Town of Taylorsville, travel north on NC Hwy 16 approximately 1.2 miles. Schneider Mills is located on the right side of NC Hwy 16. 6. Discharge Point(s), List for all discharge points: Outfall 001: Latitude: 35° 56' 10" Longitude: 81° 11' 29" Outfall 002: Latitude: 35° 56' 11" Longitude: 81" 11' 29" Attach a USGS map extract and indicate treatment facility site and discharge point on map. U.S.G.S. Quad No.: D14NW U.S.G.S. Quad Name: Taylorsville, NC 7. Site size and expansion area consistent with application? There is area available for expansion and upgrading, if necessary. 8. Topography (relationship to flood plain included): Flat to moderate slopes; the W WT facilities appear to be above the 100 year flood plain. Page Two 9. Location of nearest dwelling: The nearest dwelling is located approximately 400+ feet from the WWT facilities. 10. Receiving stream or affected surface waters: Muddy Fork Creek (for both outfalls) a. Classification: C b. River Basin and Subbasin No.: Catawba 030832 C. Describe receiving stream features and pertinent downstream uses: Moderate size creek with sandy bottom and flat to moderate stream gradient. General "C" classification uses downstream. PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS 1. a. Volume of wastewater to be permitted: 0.780 MGD (ultimate design capacity of outfall 001, no flow limit for outfall 002) b. Current permitted capacity of the wastewater treatment facility: 0.780 MGD (outfall 001) C. Actual treatment capacity of the current facility (current design capacity): 0.780 MGD d. Date(s) and construction activities allowed by previous Authorizations to Construct issued in the previous two years: There have been no ATCs issued in the past two years. e. Please provide a description of existing or substantially constructed wastewater treatment facilities: The industrial and domestic WWT facilities (outfall 001) consist of a manual bar screen, instrumented influent flow measurement, an aeration basin with 2 mechanical aerators, a final clarifier, an aerated sludge digestion tank, four sludge drying beds, and cascade post aeration. The water treatment plant WWT facilities (outfall 002) consist of two settling ponds in series. f. Please provide a description of proposed wastewater treatment facilities: There are no proposed WWT facilities at this time. g. Possible toxic impacts to surface waters: This facility has a consistent record of passing toxicity tests during the term of the current permit. h. Pretreatment Program (POTWs only): N/A 2. Residuals handling and utilization/disposal scheme: Residuals are stabilized in the aerobic digester and dewatered on the drying beds. The dried residuals are then transported to Foothill Environmental in Lenoir where they are eventually landfilled in the Caldwell County landfill. Page Three 3. Treatment plant classification: Class II (no change from previous rating) 4. SIC Code(s): 2221, 4941 Wastewater Code(s) 55, 21, 02 Main Treatment Unit Code: 02003 PART III - OTHER PERTINENT INFORMATION 1. Is this facility being constructed with Construction Grant Funds or are any public monies involved (municipals only)? Public monies were not used in the construction of this facility. 2. Special monitoring or limitations (including toxicity) requests: Schneider Mills has requested that quarterly silver monitoring be removed from the permit. The justification provided by Schneider Mills is that silver has not been detected during the term of the current permit. The Fact Sheet prepared for the current permit indicated that silver could be removed as a parameter if the permittee provided sufficient data (12 months or more) reflecting non -detects for silver. Schneider Mills now has accumulated more than four years worth of data, and has requested (via letter dated May 11, 2005) that silver monitoring be removed from the permit. This Office has no objection to this request, and recommends monitoring for silver be removed. Schneider Mills also requested in the May 11, 2005 letter that the monitoring and effluent limits for Phenols and Total Chromium be removed from the permit. Schneider Mills did not include justification for the removal of these parameters, however, effluent data indicates that they have been at or near detection levels for the past few years. It is the MRO's understanding that the effluent limitations for these parameters are based on guidelines contained in 40 CFR 410.43(a), and it may not be possible to remove the testing for these parameters given that they are based on Federal categorical guidelines. This Office defers comment to the NPDES Unit for a review and decision on this matter. 3. Important SOC, JOC or Compliance Schedule dates (Please indicate): This facility is neither under and SOC nor is one being considered at this time. 4. Alternative Analysis Evaluation: Spray Irrigation: Inadequate area available to assimilate the amount of wastewater from this facility. Connection to Regional Sewer System: Sewer is not available in this area. Subsurface: Inadequate area available to assimilate the amount of wastewater from this faility. Other disposal options: None that we are aware. Page Four PART IV - EVALUATION AND RECOMMENDATIONS The permittee, Schneider Mills, Inc., has applied for permit renewal. Schneider Mills is primarily engaged in the weaving of man-made fibers into cloth. Modifications to the permit requested during this renewal are noted in Part III, No. 2 above. There have been no WWTP modifications since the permit was last reissued. The WWT facilities appear to be adequate to treat the wastewater to meet existing effluent limits. Dutfall 001 is the discharge from the industrial and domestic wastewater treatment facilities, which includes industrial process wastewater, air conditioning condensate, and boiler blowdown. Industrial wastewater is generated by water jet looms and sizing operations. Wastewater from the filter backwash serving Schneider Mill's water treatment plant is discharged through outfall 002. Pending a final technical review by the NPDES Unit, it is recommended that the permit be renewed. f Signature of report preparer Date Water QualitAegional Supervisor Date hAdsrldsrUlschneidr.sr DENR / DWQ / NPDES Unit FACT SHEET FOR NPDES PERNHT DEVELOPMENT NPDES Permit No. NCO034860 Facility Information Applicant/Facility Name Schneider Mills, Inc. Applicant Address P.O. Box 519, Ta lorsville, North Carolina 28610 Facility Address 1170 Hwy 16 North Permitted Flow (MGD) 0.780 Outfall 001 ; Outfall 002 not limited Type of Waste Industrial process wastewater. Primary SIC Codes 2221; 4941 W W Code Prim. 55, 21, 02; Treatment Unit Code 02003 Facility/Permit Status Class II, Major / Renewal Drainage Basin / County Catawba Basin / Alexander County Miscellaneous Receiving Stream Muddy Fork Creek Regional Office Mooresville Stream Classification C State Grid / USGS Too Quad D 14 NW / I Ta lorsville, NC 303(d) Listed? Not listed Permit Writer Ser ei Chemikov Subbasin 03-08-32 Date: March 31, 2005 Drainage Areas . mi.) 8.0 Lat. 350 56' 10" Long. 81° 11' 29" Lat. 350 56' 11" Long. 81° 1P 29" Summer 7Q10 (cfs) 1.4 Winter 7Q10 (cfs) 2.2 30Q2 (cfs) 3.0 Average Flow (cfs) 8.8 IWC (%) 46% INTRODUCTION Schneider Mills, Inc. (also herein referred to as Schneider Mills 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 (superscripted numbers in order of appearance, See References). Facility Description. Schneider Mills is a synthetic textile weaving facility discharging process - contact wastes and non -process wastes through two separate outfalls. hnfluent to the onsite wastewater treatment plant (WWTP) includes waste from "water jet weavers" (roughly 85%) and fiber coating or "sizing" waste (about 15 %). Sanitary sewer (-1,200 gallon per day) comprises only 0.03 % of the WWTP influent. The WWTP discharges through Outfall 001 with a permitted flow of 0.780 MGD. Non -contact wastewater (Outfall 002; flow not limited) includes air-conditioning condensate, boiler blowdown, Water Treatment Plant (WTP) filter backwash, and stormwater. Schneider Mills has been in business in North Carolina since 1951. At this location Division records date from 1972. Fact Sheet Renewal — NPDES Permit NCO034860 Page 1 PERMITTING APPROACH Limits for parameters regulated under 40CFR 410 Subpart D have been recalculated to reflect new production level. Based on data provide by the permittee, limit calculations assume 40,000 lbs/day as the average production rate over three years (2001, 2002 and 2003). Parameters required under 40CFR are summarized in Table 2. Table 1. Parameter Limits Calculation 40CFR 410.42 (a) Monthly Average 40CFR 410.42 (a) Daily Maximum per 1000 lbs. Per 1000 lbs. Sulfide 0.1 x 40 4.0 lbs/day 0.2 x 40 8.0 lbs/day Phenols 0.05 x 40 2.0 lbs/day 0.1 x 40 4.0 lbs/day Total Chromium 0.05 x 40 2.0 lbs/day 0.1 x 40 4.0 lbs/day Table 2. Annlienble 40CFR Part D Permit T,imits :Rnmmnry Monthly Average Daily Maximum BOD, 5-day 132 lbs* 20.3 m 264 lbs/day 40.6 m COD 685 lbs/day 1065 lbs/da TSS 125 lbs/day 275 lbs/day Sulfide 4.0 lbs/day 8.0 lbs/da Phenols 2.0 Ibs*y 4.0 lbs/da Total Chromium 2.0 lbs/day 4.0 lbs/day Further Consideration of Total Chromium. Technology based calculations for chromium (40CFR) were compared to the acute and chronic NC State Standards (Chronic = 50 µg/L; Acute = 1022 µg/L — %Z FAV for freshwater) to evaluate which permit limits are more stringent, i.e. more environmentally conservative. Chronic Chromium -- Weekly Average Limit Considering dilution (IWC 46 %): 50 UgIL 109 µg/L 0.46 compared to technology based: 2.0 lbs/day = 0.780 MGD (flow) x 8.34 x (y) mg/L y = 0.307 mg/L or 307 µg/L Therefore: because 109 µg/L is less than the technology -based limit of 307 µg/L, the more environmentally conservative 109 µg/L will be implemented to protect against the chronic affects of chromium as a Weekly Average. Acute Chromium -- Daily Maximum Limit Considering: 1,022 µg/L (freshwater %a FAV, intentionally not accounting for dilution) Fact Sheet Renewal -- NPDES NCO034860 Page 2 compared to Technology based : 8.0 lbs/day = 0.780 MGD (permitted flow) x 8.34 x (y) 1 mg/L y-- 1.230 mg/L or 1,230 µg/L Therefore: because the Y2 FAV of 1,022 µg/L is less than the technology based limit of 1,230 µg/L,1,022 µg/L is more environmentally conservative and will be implemented as a Daily Maximum to protect against acute toxic affects. Reasonable Potential Analysis Reasonable potential analysis was conducted for: Cd, Cr, Ni, Pb, Ag and Zn. (see attached). Toxicity Testing Current Requirement: Quarterly Chronic Toxicity @ 46% MAR, JUN, SEP, DEC Recommended Requirement: Quarterly Chronic Toxicity @ 46% MAR, JUN, SEP, DEC The facility has been consistently passing its WET tests (see attached). Compliance Summary DMRs have been reviewed for the period January 2002 through March 2005. Facility has a good compliance record. During the review period, the following NOVs (notices of violation) have been issued: 01/08/04 — Sulfide; 07/15/03 — Sulfide. A compliance evaluation inspection conducted on January 11, 2005 determined that the facility is in compliance. Instream Monitoring Instream monitoring is required for Conductivity, Temperature, and Dissolved Oxygen. Analysis of the instream monitoring data indicates that facility has insignificant negative effect on the stream water quality (see attached). Proposed Changes • Monitoring Frequencies: TRC monitoring has been added to the outfall 002. • Limits: Based on the application flow data, calculations were conducted in accordance with federal guidelines. Based on the calculation results, limits were reduced for most parameters. Calculated COD limit exceeded current limit, but since the permittee has been able to consistently meet the current limit, the decision has been made to leave it unchanged. Similar decision has been made regarding TSS limit. A daily maximum limit for ammonia nitrogen has been added to the permit. A daily maximum value is five times the monthly average value. State Contact If you have any questions on any of the above information or on the attached permit, please contact Sergei Chernikov at (919) 733-5038 ext. 594. Fact Sheet Renewal -- NPDES NCO034860 Page 3 CHANGES TO THE FINAL PERMIT Following changes were made to the final permit: Ourfall 002: 1) Measurement frequency for flow has been changed to Weekly, and Sample type was changed to Instantaneous. 2) Sample type for TSS and Iron has been changed to Grab. Changes for Outfall 002 were part of Permit Modification for previous permit. However, NPDES file did not contain the record of this Modification and electronic version of the Permit was outdated. Permit supplement page: The permittee has notified us that discharge from Outfall 002 consists of "Water treatment plant filter backwash" only. The appropriate changes were made. Outfall 001: 1) Monitoring for silver was discontinued. Previous permit stipulated that " ... if silver is not detected after one year from the permit effective date (4 additional data points), the Division will consider the permittee's request to discontinue quarterly silver monitoring". Based on the DMRs review, silver monitoring was discontinued. 2) Permittee informed the Division that they are closing down Alexander Mills facility and will be consolidating operation at Taylorsville Plant. As a result, production will be increased to 42,000 lb/day. The limits were recalculated to reflect new production level (COD and TSS were recalculated by adding 5% to the existing limit). Table 1. Parameter Limits Calculation 40CFR 410.42 a Monthly Average 40CFR 410.42 (a) Daily Maximum per 10001bs. Per 1000 lbs. Sulfide 0.1 x 42 4.2 lbs/day 0.2 x 42 8.4 lbs/day Phenols 0.05 x 42 2.1 1bs/day 0.1 x 42 4.2 lbs/day Total Chromium 0.05 x 42 1 2.1 lbs/day 1 0.1 x 42 4.2 lbs/day Table 2. Applicable 40CFR Part D Permit Limits Summary Monthly Average Daily Maximum BOD, 5-day 138.6 lbs/day 21.3 m 277.2 lbs/day 42.6 m COD 719.3 lbs/day 1118.3 lbs/da TSS 131.3 lbs/day 288.8 lbs/da Sulfide 4.2 lbs/day 8.4 lbs/da Phenols 2.1 lbs/day 4.2 lbs/da Total Chromium 2.1 lbs/day 4.2 lbs/day Fact Sheet Renewal -- NPDES NCO034860 Page 4 04/12/2005 07:21 FAX 1 828 632 9834 SCHNEIDER MILLS IM002 SCHNEIDER MILLS, INC. P.O. BOX 519 - TAYLORSVILLE, N.C. 28681 cl TELEPHONE 704-632-8181 !U C 8 6l) ,,;,o "&�� olooy a b j g t Ido:'j Q A) , -V�� jv-q--� Aq-41 &+-o Ujcftu�l Ajl�4 010 a-h-v C3�aAa.-11F�ru , Y&cu 0 ji mt!�D- EXECUTIVE OFFICES: 462 7th Avenue, New York, N.Y. 10018 REASONABLE POTENTIAL ANALYSIS Schneider Mills WWTP NCO034860 Time Period 2000-2005 Ow (MGD) 0.78 WWTP Class II 7Q10S (cfs) 1.4 1WC (%) @ 7Q10S 46.34 7Q10W (cfs) 2.2 @ 701OW 35.46E 30Q2 (cfs) 3 @ 3002 28.724 Avg. Stream Flow, QA (cfs) 8.8 @ QA 12.079 Reeving Stream Muddy Fork Creek Stream Class C Outfall 001 Qw = 0.78 MGD STANDARDS & PARAMETER TYPE CRITERIA (2) PQL Units REASONABLE POTENTIAL RESULTS RECOMMENDED ACTION i11 NCWQSI NFAV/ Chronic Acute n pDOE Max PredC, Agow8bleCw Cadmium NC 2 15 ug/L 12 0 6.1 Acute: 15 VA,4 _ _- Chronic: 4 -- Chromium NC 50 1,022 ug/L 48 15 79.9 Acxtte: 1,022 — ---__ — 108TI __-nic: ��' Acute: 34 Lead NC 25 N 33.8 ug/L 12 0 10.2 _ _ ChronEc�--— -- ---- i ^-------- — Nip Nickel NC 88 261 ug/L 12 1 13.7 Acute: 261 � �— --- -- -- _ _--__ _ -A/o -- — — Silver NC 0.06 AL 1.23 ug/L 14 1 76.2--- Acute: 1.23 M4 — Chronic: 0 - _ -Ativ�-----��?~'-�' Acute: 67 � % Zinc NC 50 AL 67 ug/L 20 20 153.1 _ _ ___ -- Chronic: 108 ' ----#/ _-- 1 �N -II% • Legend. •' Freshwater Discharge C = Carcinogenic NC = Non -carcinogenic A = Aesthetic 34860 -rpa 2005, rpa 4/1/2005 REASONABLE POTENTIAL ANALYSIS Cadmium Chromium Date Data BDL=1/2DL Results Date Data BDL=112DL Results 1 < 5 Z5 Std Dev. 0.6201 1 < 10 5.0 Std Dev. 4.9561 2 < 5 2.5 Mean 1,2083 2 < 5 2.5 Mean 4.7188 3 <. 2 1.0 C.V. 0.5131 3 6 6.0 C.V. 1,0503 4 < 2 1.0 n 12 4 < 5 2.5 n 48 5 < 2 1.0 5 < 5 2.5 6 < 2 1.0 Mult Factor = 2.4500 6 < 5 2.5 Mult Factor = 2.3500 7 < 2 1.0 Max. Value 2.5 uglL 7 < 5 2.5 Max Value 34.0 ug/L 8 < 2 1.0 Max. Pred Cw 6.1 ug/L 8 < 5 2.5 Max Pred Cw 79.9 ug/L 9 < 2 1.00 9 < 5.0 2.5 10 < 2 1.00 10 5.0 5.0 11 < 2 1.00 it < 5.0 2.5 12 < 1 0.50 12 <. 5.0 2.5 13 13 < 5.0 2.5 14 14 5,0 5.0 15 15 6.0 6.0 16 16 8.0 8.0 17 17 < 10.0 5.0 18 18 < 5.0 2.5 19 19 < 5.0 2.5 20 20 < 5.0 2.5 21 21 <. 5.0 2.5 22 22 < 68.0 34.0 23 23 < 5.0 2.5 24 24 < 5.0 2.5 25 25 < 5.0 2.5 26 26 < 5.0 2.5 27 27 < 5.0 2.5 28 28 < 5.0 2.5 29 29 < 5.0 2.5 30 30 < 5.0 2.5 31 31 < 5.0 2.5 32 32 < 5.0 2.5 33 33 < 5.0 2.5 34 34 < 10.0 5.0 35 35 < 5.0 2.5 36 36 < 5.0 2.5 37 37 < 5.0 2.5 38 38 < 5.0 2.5 39 39 5.0 5.0 40 40 5.0 5.0 41 41 5.0 5.0 42 42 5.0 5.0 43 43 10.0 10.0 44 44 10.0 10.0 45 45 10.0 10.0 46 46 10.0 10.0 47 - 47 5.0 5.0 48 48 10.0 10.0 49 49 50 50 51 51 52 52 53 53 54 54 55 55 56 56 57 57 58 58 59 59 60 60 199 199 200 1 200 34860 -rpa 2005, data -2- 4/1/2005 REASONABLE POTENTIAL ANALYSIS Lead Nickel Date Data BDL=1/2DL Results Date Data BDL=1/2DL Results 1 < 10 5.0 Std Dev. 1.1172 1 ; ,_ 5 2.5 Slot Dev. 15393 2 < 10 5.0 Mean 2.7917 2 5 2.5 Mean 4.1250 3 < 5 2.5 C.V. 0.4002 3 _- 5 2.5 C.V. 0.3732 4 < 5 2.5 n 12 4 5 2.5 n 12 5 < 5 2.5 5 - 7 7.0 6 < 5 2.5 Mult Factor = 2.0400 6 _ 10 5.0 Mult Factor = 1.9600 7 < 5 2.5 Max. Value 5.0 ug4 7 -_ 5 2.5 Max. Value 7.0 ug/L 8 < 5 2.5 Max. Fred Cw 10.2 ug/L 8 =_- 10 5.0 Max. Fred Cw 13.7 ug/L 9 < 5 2.5 9 _ 10 5.0 10 < 5 2.5 10 10 5.0 11 < 5 2.5 11 10 5.0 12 < 2 1.0 12 10 5.0 13 13 14 14 15 15 16 16 17 17 18 18 19 19 20 20 21 21 22 22 23 23 24 24 25 25 - 26 26 27 27 28 28 29 29 30 30 31 31 32 32 33 33 34 34 35 35 36 36 37 37 38 38 39 39 40 40 41 41 42 42 43 43 44 44 45 45 46 46 47 47 48 48 49 49 50 50 51 51 52 52 53 53 54 54 55 55 56 56- 57 57 58 58 59 59 60 60 199 199 200 200 34860 -rpa 2005, data -3- 4/1/2005 REASONABLE POTENTIAL ANALYSIS Silver Zinc Date Data BDL=1/2DL Results Date Data BDL=1/2DL Results 1 5 2.5 Std Dev. 4.4936 1 54 54.0 Std Dev. 16.5080 2 5 2.5 Mean 5.0000 2 56 56.0 Mean 44.2500 3 5 2.5 C.V. 0.8987 3 51 51.0 C.V. 0.3731 4 5 2.5 n 14 4 57 57.0 n 20 5 10 5.0 5 36 36.0 6 10 5.0 Mull Factor = 3.8100 6 44 44.0 Mult Factor = 1.7200 7 10 5.0 Max. Value 20.0 ug/L 7 36 36.0 Max. Value 89.0 ug/L 8 10 5.0 Max. Fred Cw 76.2 ug/L 8 34 34.0 Max. Fred Cw 153.1 ug/L 9 10 5.0 9 29 29.0 10 10 5.0 10 49 49.0 11 10 5.0 11 35 35.0 12 20 20.0 12 22 22.0 13 5 2.5 13 35 35.0 14 5 2.5 14 72 72.0 15 15 55 55.0 16 16 89 89.0 17 17 37 37.0 18 18 35 35.0 19 19 22 22.0 20 20 37 37.0 21 21 22 22 23 23 24 24 25 25 26 26 27 27 28 28 29 29 30 30 31 31 32 32 33 33 34 34 35 35 36 36 37 37 38 38 39 39 40 40 41 41 42 42 43 43 44 44 45 45 46 46 47 47 48 48 49 49 50 50 51 51 52 52 53 53 54 54 55 55 56 56 57 57 58 58 59 59 60 60 199 199 200 200 34860 -rpa 2005, data -4- 4/1/2005 NC0034860 Schneider Mills 02/03/2005 02/10/2005 02/17/2005 02/24/2005 01/06/2005 01/13/2005 01/20/2005 01 /27/2005 12/02/2004 12/07/2004 12/16/2004 12/21 /2004 11 /04/2004 11/11/2004 11 /18/2004 11 /23/2004 10/07/2004 10/14/2004 10/21 /2004 10/28/2004 09/02/2004 09/09/2004 09/14/2004 09/21 /2004 08/05/2004 08/12/2004 08/19/2004 08/26/2004 07/15/2004 07/22/2004 07/29/2004 06/03/2004 06/08/2004 06/17/2005 06/24/2004 05/06/2004 05/13/2004 05/2012004 05/27/2004 04/08/2004 04/15/2004 04/22/2004 04/29/2004 03/02/2004 03/11 /2004 03/18/2004 Temp CC) 5.5 7.4 7.1 8.3 9.8 12.8 3.0 6.4 7.0 11.0 4.0 2.0 15.0 8.0 10.0 15.0 13.0 15.0 16.0 15.0 20.0 19.0 18.0 13.0 21.0 19.0 20.0 19.0 19.0 20.0 20.0 17.0 18.0 21.0 19.0 13.0 17.0 17.0 18.0 10.0 9.0 13.0 10.0 10.0 4.0 7.0 D.O. (mg/L) 11.2 9.9 10.7 8.4 8.7 8.1 13.1 10.8 9.8 7.9 10.6 11.1 7.8 10.3 8.6 7.3 7.8 7.4 6.8 6.4 4.9 7.9 7.6 8.4 5.4 4.9 4.5 5.0 5.0 5.9 4.6 6.7 5.5 5.3 9.2 6.6 6.4 6.9 5.3 8.8 10.4 7.0 8.2 8.7 11.7 9.6 Conductivity Temp umhos/cm) (°C) 42 5.5 42 7.7 50 7.6 62 8.5 40 10.4 82 12.4 62 3.3 72 6.2 62 7.0 41 11.0 64 4.0 42 2.0 52 15.0 74 9.0 72 11.0 71 15.0 72 14.0 84 15.0 71 16.0 71 16.0 49 21.0 74 20.0 67 19.0 67 14.0 81 22.0 71 19.0 42 20.0 52 20.0 42 20.0 51 21.0 42 20.0 42 18.0 50 19.0 54 21.0 62 19.0 62 13.0 61 18.0 78 18.0 41 19.0 48 11.0 57 9.0 49 13.0 71 11.0 52 10.0 52 6.0 48 7.0 Downstream D.O. Conductivity (mg/L) umhos/cm) 12.1 5A" 11.1 3c, 10.7 47 10.7 71 10.1 3E 9.5 81 12.8 71 11.5 8( 11.3 71 9.5 4( 11.6 6E 13.1 44 7.9 54 10.1 Ted' 9.8 6cc 8.8 87 8.8 84 8.4 8° 8.0 71 8.4 A 7.0 5( 7.4 8149' 7.6 7r 9.1 A 7.1 A 8.1 A 7.3 5( 7.5 5( 7.1 0 7.4 5c, 6.6 44 7.8 51 7.7 51 5.8 5 i 9.2 6f 9.0 64 8.0 6' 8.0 A 7.6 4; 10.4 4f 11.0 61 9.5 5; 9.4 A 10.1 5i 11.6 5; 11.2 4' 03/25/2004 8.0 10.3 57 9.0 10.6 59 02/05/2004 4.0 11.1 51 4.0 11.7 58 02/12/2004 5.0 10.9 49 5.0 10.7 58 02/19/2004 5.0 12.2 48 5.0 12.2 52 02/26/2004 5.0 11.0 52 6.0 10.4 55 01/08/2004 3.0 11.7 58 3.0 11.5 61 01/15/2004 5.0 11.4 86 6.0 10.9 89 01 /22/2004 2.0 13.0 71 3.0 12.7 77 01 /29/2004 1.0 121.00 13.1 61 2.0 13.1 59 Average 11.64 8.50 58.65 12.14 9.57 62.45 Maximum 13.08 86.00 22.00 13.11 89.00 Minimum 1.00 4.46 40.00 2.00 5.75 38.00 State of North Carolina Department of Environment and Natural Resources Division of Water Quality Michael F. Easley, Governor William G. Ross, Jr., Secretary Alan W. Klimek, P.E., Director May 11, 2005 Gary Elder, Plant Engineer Schneider Mills P.O. Box 519 Taylorsville, North Carolina 28681 Dear Mr. Elder. NCDENR NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES Subject: Draft NPDES Permit Permit NC O034860 Schneider Mills W W1'P Alexander County Enclosed with this letter is a copy of the draft permit for your facility. Please review the draft very carefully to ensure thorough understanding of the conditions and requirements it contains. The draft permit contains the following significant changes from your current permit: Limits for BOD, COD, TSS, Sulfide, Chromium and Phenols have been recalculated based on the provided production data. Limits for COD, Chromium, and TSS remain unchanged, limits for BOD, Sulfide and Phenols have been reduced due to the reduction in the production volume. A daily maximum limit for ammonia nitrogen has been added to the permit. Due to the Federal Guideline requirements the daily maximum value is five times the monthly average value. A monthly monitoring for Total Residual Chlorine (MC) for Outfall 002 has been added to the permit. State of North Carolina has recently adopted a TRC standard and this monitoring is necessary to evaluate potential TRC discharges by Schneider Mills. Please submit any comments to me no later than thirty days following your receipt of the draft Comments should be sent to the address listed at the bottom of the previous page. If no adverse comments are received from the public or from you, this permit will likely be issued in early July, with an effective date of August 1, 2005. If you have any questions or comments concerning this draft permit, contact me at the telephone number or e-mail address listed at the bottom of this page. Sincerely, 4 C S� it � ii / Sergei Chernikov, PhD. NPDES-West cc: NPDES Files Mooresville / Surface Water Protection Aquatic Toxicology Unit Mr. Roosevelt Childress, EPA Region IV NPDES Unit,1617 Mail Service Center, Raleigh, North Carolina 27699 919 733.5083, extension 594 (fax) 919 733-g719 An Equal Opportunity Affirmative Action Employer sergei.chemikov® ncmail.net Permit NCO034860 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY Draft PERMIT TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, Schneider Mills, Inc. is hereby authorized to discharge wastewater from a facility located at Schneider Mills NC Highway 16 North Alexander County to receiving waters designated as Muddy Fork Creek within the Catawba River Basin, in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III and IV hereof. This permit shall become effective This permit and authorization to discharge shall expire at midnight on July 31, 2010. Signed this day Alan W. Klimek, P.E., Director Division of Water Quality By Authority of the Environmental Management Commission Permit NCO034860 SUPPLEMENT TO PERMIT COVER SHEET All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked. As of this permit issuance, any previously issued permit bearing this number is no longer effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the permit conditions, requirements, terms, and provisions included herein. Schneider Mills, Inc. is hereby authorized to: 1. Continue discharging 0.780 MGD of treated process -contact and domestic wastewater via outfall 001 from a treatment facility with the following components: • Bar screen • Instrumented flow metering device • Aeration basin with two mechanical aerators • Clarifier • Sludge return pumps • Aerobic digester • Cascade aeration and • Sludge drying beds 2. Continue discharging non -contact wastewater from two (2) settling ponds connected in series via outfall 002 (flow not limited). The discharge consists of: • Air conditioning condensate • Water treatment plant (WTP) filter backwash • Boiler blowdown • Stormwater runoff This facility is located at Schneider Mills. Inc. off NC Highway 16 North in Alexander County. 3. Discharge from said wastewater treatment works through Outfall 001 and 4utfall 002 to Muddy Fork Creek (see attached map), classified C waters within the Catawba River Basin. 1 / f Schneider Mills, Inc. StaeGtklAted: D 14 NW / Tayloxsvik, NC Latitude: 3506G 137 N 0o lisle 81° 11' 28" W Permitted Fla . 0.780 MGD RemvinHSt� Muddy Fork Creek DsaloageBasta Catawba River Basin atr a claw C Sub•Basbi 03-08-32 ". Facility '_ - Location not to, scale North NMES N Penni o. NC0034860 Catawba County Permit NCO034860 A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (001) During the period beginning on the effective date of the permit and lasting until expiration, the permittee is authorized to discharge treated wastewater through Outfall 001. Such discharges shall be limited and monitored by the pemrittee as specified below: PARAMETERS EFFLUENT LIMITS MONITORING REQUIREMENTS Monthly Average Weekly Average Daily Maximum Measurement Frequency Sample Tye Sample Location' Flow 0.780 MGD Continuous Recording Influent or Effluent BOD, 5 day, 200C 20.3 mg/L 132 lbs/day 40.6 mg/L 264Ibs/da Weekly Composite Effluent Total Suspended Solids (TSS) 125 lbstday 275 Ibs/da Composite Effluent COD 685 lbs/day 1,065 lbs/day —Weekly Weekly Composite Effluent NH3 as N (April 1 through October 31) 2 1.9 mg/L 9.5 mg/L Weekly Composite Effluent NH3 as N (November 1 through March 31) 2 4.7 mg/L 23.5 mg/L Weekly Composite Effluent Dissolved Oxygen3 Weekly Grab Effluent Total Nitrogen (NO2 + NO3 + TKN Quarterly Composite Effluent Total Phosphorus Quarterly Composite Effluent Chronic Toxicity4 Quarterly Composite Effluent Temperature (°C) Weekly Grab Effluent H5 Weekly Grab Effluent Sulfide 4.0 lbs/day 8.0Ibs/da 2/Month Composite Effluent Phenols 2.0 lbs/day 4.0lbs/da 2/Month Composite Effluent Total Chromium 109 1022 2/Month Composite Effluent Silver Quarterly Composite Effluent Conductivity Weekly Grab Upstream & Downstream Temperature, °C Weekly Grab Upstream & Downstream Dissolved Oxygen Weekly Grab Upstream & Downstream Table Footnotes: 1. Upstream = at least50 feet upstream from the outfall. Downstream = at or near NCSR 1313. 2. NH3 as N — See Special Condition A. (4.). 3. Daily average effluent concentration of dissolved oxygen shall not fall below 5.0 mg/L. 4. Chronic Toxicity (Ceriodaphnia) at 46 %; quarterly during March, June, September, December; See Special Condition A. (3.) 5. pH shall not fall below 6.0 nor exceed 9.0 standard units. Effluent shall contain no floating solids or foam visible in other than trace amounts. Permit NC0034860 A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (002) During the period beginning on the effective date of the permit and lasting until expiration, the Pemmttee is authorized to discharge treated wastewater through Outfall 002. Such discharges shall be limited and monitored by the Permittee as specified below: PARAMETERS EFFLUENT MONITORING REQUIREMENTS LIMITS Monthly Daily Measuremen Sample Sample Location' Average Maximu t Frequency Type in Flow Continuous Recording Influent or Effluent Total Suspended 30 mg/L 45 mg1L 2/Month Composite Effluent Solids TSS Settable Solids 0.1 m L 0.2 m Weekly Grab Effluent Iron Weekly Composite Effluent HZ Weekly Grab Effluent Total Residual Monthly Grab Effluent Chlorine Turbidity3 Weekly Grab Upstream & Downstream Table Footnotes: 1. Upstream = at least50 feet upstream from the outfall. Downstream = at or near NCSR 1313. 2. pH shall not fall below 6.0 nor exceed 9.0 standard units. 3. Discharge shall not cause stream turbidity to exceed 50 NTU. If natural background turbidity exceeds 50 NTU, discharge shall not increase receiving -stream turbidity. Effluent shall contain no floating solids or foam visible in other than trace amounts. Permit NCO034860 SUPPLEMENT OT EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS SPECIAL CONDITIONS A. (3.) 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 46%. 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 H Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The tests will be performed during the months of March, June, September, and December. Effluent sampling for this testing shall be performed at the NPDES permitted final effluent discharge below all treatment processes. If the test procedure, performed as the first test of any single quarter, results in a failure or ChV below the permit limit, then multiple -concentration testing shall be performed at a minimum, in each of the two following months, as described in `North Carolina Phase H 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 H 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 TBF3B for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to be sent to the following address: Attention: NC DENR DWQ / Environmental Sciences Section 1621 Mail Service Center Raleigh, North Carolina 27699-1621 Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 30 days after the end of the reporting period for which the report is made. Test data shall be complete, accurate, include all supporting chemical/physical measurements and all concentration/response data, and be certified by laboratory supervisor and ORC or approved designate signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream. Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility name, permit number, pipe number, county, and the month/year of the report with the notation of "No Flow" in the comment area of the form. The report shall be submitted to the Environmental Sciences Branch at the address cited above. Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be required during the following month. Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water Quality indicate potential impacts to the receiving stream, this permit may be re -opened and modified to include alternate monitoring requirements or limits. NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism survival, minimum control organism reproduction, and appropriate environmental controls, shall constitute an invalid test and will require immediate follow-up testing to be completed no later than the last day of the month following the month of the initial monitoring. Schneider Mills, Inc. PO Box 519 (828) 632-8181 Phone Taylorsville, NC 28681 (828) 632-9834 Fax North Carolina Department of Environment and Natural Resources Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Dear Sirs: This is a request for renewal of NPDES permit # NC0034860. for .780 MDG at Schneider Mills, Inc. in Taylorsville, NC. Thank you, Gary Elder (Fill-in areas are scared tnr am.. h.no i."�. ..:..........._�__�, Rn"Annm..ea n114D'- ................�,,,,.,, . _...,.,,,.,..,....,..,.. ,..,. FOAU.S. ENVIRONMENTAL PROTECTIONAGENCY cv-rv-vvuu, rlppruvai expires b-31-92 EPALD. NUMBERConsolidated GENERAL INFORMATION5 Permits Program FNCGENEtReadthe"General Instructions"beforestanin . 2 13 14 15 LA GENERAL INSTRUCTIONS I. EPA N C 0O -1 - 6 Q If a preprinted label has been provided, affix it in the designated space. Review the information carefully; "rf any of it is _ III. FACILITY NAME I I S (2-� I N e t e y jVl 1 S �L:TI C incorrect cross through it and enter the correct data in the appropriate fill-in area below. Also, if any of the preprinted data is absent fthe area to the Lett Of. the label V. FACILITY �� O 13 0X S I q MAILING LIST space lsts the information that Cshould appear) please provide it in the proper fill - n arears) below. If the label is complete and correct you. need not complete Items 1, ill, V, and VI(except VI-B which must be VI. FACILITY '1 O a w L . I io . /V completed regardless). Complete all items J , LOCATION —7 if no label has been proved. Refer to the instructions for detailed item descriptions 1 Fi.9 I O Y $ U i (� e (�(, C , `� 6 I and for the legal authorization under which this data is collected. II. POLLUTANT CHARAt.TEH:151-t to the EPA.: If you answer'yes" to any Mark "X" in thebox in the third column d ' omp ate A t roug to eterine whether you need to submit any permit application fors questions, you must submit this form and the supplemental from listed in the parenthesis following the question. the supplemental for is attached. If you answer' no" to each question, you need not submit any of these fors. excluded from You may answer "no" if your a otmty Is Tit requirements; see Section C of the instructions. See also, Section D of the instructions for definitions of bold-faced terms. SPECIFIC QUESTIONS MARK "X" SPECIFIC QUESTIONS MARK "X" - YES ❑ NO ®' - FORM ATTACHED ❑ -YES NO Ivl FORM ATTACHED A s this facility a pu dly owned treatment works which results in a discharge to waters of the B. Does or will this facility (either existing or proposed) include a concentrated U.S.? (FORM 2A) animal feeding operation or aquatic animal. ❑ W ❑ production facility which results in a discharge C. Is this facility which currently results in discharges to waters of the U.S. other than to waters of the U.S.? (FORM 2B) D. Istmsproposafadlily(orhermanmose escnbed 76 17 1s 19 20 21 those described in A or B above? FORM 2C in A w B above) which will result in a discharge to waters of the U.S.? FORM 2D - -2B 22 23 24 25 E Does or will this facility treat, store, or dispose of hazardous wastes? (FORM 3) ❑ ❑ F. Do you or will you inject at this reality inn, junal or municipal effluent below the. lowermost 27 stratum containing,. ❑ ® ❑ within one quarter mile of the well` bare, underground sources of drinking water?' 0 y0U Or Ya l you inject at IS }adihy any produced water other fluids which are brought to (FORM 4) you or wit you inject at this facility uidS or special processes such as mining of sulW by the 28 29 30 31 32 33 the surface in connection with conv6ntlonal oil or natural gas production, inject fluids used for ❑ ® ❑ Frasch process, solution mining of minerals, in situ combustion of fossil luei, or recovery of ❑ ® ❑ enhanced recovery of oil or natural gas, or Inject fluids for storage of liquid hydrocarbons? geothermal energy? (FORM 4) (FORM 4) Is th s facility a proposed stationary source categories I one of thewi categories listed the is aria of the 28 - J. Is this facility a proposed stationary source 34 1 35 1 38 37 35 39 In the In and which will which emit ❑ r�1 WI ❑ is NO, we of the 2e industrial categories listed in the instructions and which will potentially ❑ lq �l ❑ 100 tons per year of any air pollutant regulated under the Clean Air Act and may affect w be emit 250 tons per year of any air pollutant regulated under the Clean Air Act and may affect 40 1 41 1 42 43 1 44 1 45 located in an attainment aura? FORM 5 1 or be located in an attainment am? FORM 5) III. NAME OF FACILITY c SKIP �3 1 15 18-29 3 as IV. FACILITY CONTACT A NAME & TITLE last, first, 8 title area co B. PHONE de 8 no. c 2 (03 a O I Qq{9 46 4a -d9 51 52 56 45 VS FACILITY MAILING ADDRESS A. STREET OR P.O. BOX - c 3 p Sig D. ZIP CODE 5 8 45 B. CITY OR TOWN C. STATE C c ^1 ' /Y u VI. FACILITY LOCATION 40 41 42 1 47 51 A STREET, ROUTE NO. OR OTHER SPECIFIC IDENTIFIER B I k -70 N•C. 140 5 6 45 B. COUNTY NAME 46 70 C. CITY OR TOWN D. STATE E. ZIP CODE F. COUNTY CODE - e i1 N.C. 15 i d0 41 12 47 51 52 54 EPA FORM 3510-1 (8-90) CONTINUED ON REVERSE VII. SIC CODES (4-di it, in order ofpriority) A. FIRST B. SECOND C (specify)) T (specify) 7 7 15 16 ti 15 16 19 oC o` C. THIRD D. FOURTH c (i specify) (specify) 7 7 /5 18 17 15 16 19 VIII. OPERATOR INFORMATION A NAME B. Is the name listed in Item c $ 'D r 1� I VIII-A also the Omer? \ 55 ❑ YES ® NO C. STATUS OF OPERATOR Enterthe appropriate letterinto the answerbox, if "Other,"s D. PHONE area code & no. F =FEDERAL M = PUBLIC (otherthan federal or state) (specify) c S = STATE 0 = OTHER (specify) Q� P=PRIVATE 58 15 i6 18 t9 2t 22 25 E. STREET OR PO 80X ze I 55 F. CITY OR TOWN G. STATE H. ZIP CODE IX. INDIAN LAND c ' Is the facility located on Indian lands? B 1 1s tfi 42 ' e� 1 ❑ YES NO X. EXISTING ENVIRONMENTAL PERMITS ANPDES Olscha es to Surface Wate D.PSD Air Emissions from Pro ad Sources C T I C T 8 s N C o s P 15 1 18 1 17 4 18 30 15 1 18 1 17 1 16 30 B. UIC Undo round ln'ecdon of Fluids - E. OTHER s (Specify) C T I � r e 9 U 8 15 4 18 1 17 18 30 1b 18 17 18 30 C. RCRA Hazardous Wastes E. OTHER s (specify) c I c r e 9 R 9 15 1r8 17 18 30 15 18 17 18 3p XI. MAP Attach to this application a topographic map of the area extending to at least one mile beyond property boundaries. The map must. show the outline of the facility, the location of each of its existing and proposed intake and discharge structures, each of its hazardous waste treatment, storage, or disposal facilities, and each well where it injects fluids underground. Include all springs, rivers and other surface water bodies in the map area. See instructions for revise requirements. XII. NATURE OF (Provide a brief descrition BpBUSINESS q� cp O �p & J 19..) Xill. CERTIFICATION see instructions I certify under penalty of law that I have personally examined and am familiar with the information submitted in this application and alf attachments and that, based on my inquiry of those persons immediately responsible for obtaining the information contained in the application. I believe that the information is true, accurate and complete. I am aware that there are significant penalties for submitting false information, including the possibiZ' of Bna and imprisonment. A. NAME & OFFICIAL TITLE (type or pdnt) B. SIGNATURE C. DATE SIGNED COMMENTS FOR OFFICIAL USE c C 1s to 55 EPA FORM 3510-1 (5-90) COUNTY I I MUDDY WATER FORK CREEK HOLDING POTABLE PONDS WATER y04 off) l;pd, 3coo GPD WATER TREATMENT — PLANT 39e 1041 GP). HOLDING TANK BACKWASH SETTL POND POND '8'3 0 GPd G d PROCESS SANITARY BOILERS fo fro � WATER WATER 30� 301 GPd o GPd, Perm,'- -WASTE OUTFALL TEATMENT 001 •7?0 mGl STORM DISCHARGE i y, o G Pd, OUTFALL 002 �yoo GPd \ COOLING 5a% VAPo r ,45o GPd, .335 i?7GD MUDDY FORK 9 CREEK Schneider Mills, Inc. P.O. Box 519 1 170 Highway 16 North Taylorsville, North Carolina 28681 (828) 632-8181 phone (828) 632-9834 fax January 17, 2005 RE: Sludge Management Plan Schneider Mills, Inc. 0034860 To Whom it May Concern: The sludge flows from digester to sand beds for drying. After drying, they are raked to center and loaded on covered dump trucks. This acyclic solid waste is hauled to Foothill Environmental at 2800 Cheraw Road in Lenoir, N.C. 28645. All paperwork is handled through Republic Services, Inc. (Profile #WA-11828) in Eden, N.C. 27288. The contact person is Joyce Dishman at 336/623-8384. Hauling is by private contractor at the time needed. Thank you, Gary D.TzIder Plant Engineer w - � �� WAT�c'Q - O� QG c �y FAX TRANSMITTAL DATE: October 2, 2001 TO: Daren Webb, ORC of WWTP Schneider Mills RE: NPDES Permit NCO034860 Regarding Question about Sulfide FROM: Joe R. Corporon DWQ / NPDES Unit Michael F. Easley, Governor State of North Carolina William G. Ross, Jr., Secretary Department of Environment and Natural Resources Alan W. Klimek, PE, Director Division of Water Quality Number of pages 1 + 2 Fax: 828-632-9434 Phone: 828-632-8181 Daren, I contacted Hugh Wise of EPA about your sulfide problem. I hope this helps (See attached correspondence). Thanks again. North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 (919) 733-7015 Q� A A NCDENR Customer Service 1 800 623-7748 Annual Sulfide Problem Subject: Annual Sulfide Problem Date: Fri, 09 May 2003 11:17:04 -0400 From: Joe Corporon <joe.corporon@ncmail.net>�G To: wise.hugh@epa.gov Hugh, you have been identified as "the man to ask." I have an NPDES textile permittee in North Carolina with a problem meeting sulfide limits (5.2 lbs/day mo ave.; 17lbs/day daily max.). This problem apparently appears annually near Spring with fluctuating temperatures, and has no identifiable correlation to production. They operate, in part, a large pond with surface aeration. Our only thought was that perhaps the pond is "rolling" with temperature, mixing dormant sulfide from residuals accumulated in circulation "dead spots." Any history, thoughts, or solutions would be much appreciated? Thanks. Joe Corporon NPDES Unit Division of Water Quality 1 of 1 5/9/03 1 L 17 AM Re: Annual Sulfide Problem Subject: Re: Annual Sulfide Problem Date: Fri, 09 May 2003 12:56:04 -0400 From: Wise.Hugh@epamail.epa.gov To: Joe Corporon <joe.corporon@ncmail.net> Joe, One thought occurs to me. What this aerated lagoon may be experiencing each Spring is the well-known (to folks operating biological wastewater treatment plants) seasonal transition from psychrophilic organisms to mesophilic organisms. Treatment efficiency normally drops off during the transition period until the different population of organisms becomes established. Assuming the loading of sulfur -bearing materials coming into the lagoon stays fairly constant throughout, I would expect that by early Summer the discharge from the lagoon comes back into compliance with the sulfide limits. Hope this helps, Hugh I of 1 5/9/03 1:39 PM