NC0000876_Complete Files_20010525

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7 Michael F. Easley
V 0j� /� G rn ���7 L'�� I Governor
'V�/ r1��� William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Kerr T. Stevens, Director
((( Division of Water Quality
May 25, 2001
Mr. Arthur J. Toompas
Cone Mills Corporation
3101 North Elm Street
Greensboro, N.C. 27415-6540
Subject: NPDES Permit Modification
NC0000876
Guilford County
Dear Mr. Toompas:
In a May 15, 2001 letter to Mr. Dave Goodrich you outlined pending facility discharge changes that would impact
your existing NPDES permit coverage. These changes include connection of outfall 001 to the City of Greensboro's
WWTP by June 30, 2001 and a request for the discharge from outfalls 005 and 006 to be considered for general permit
coverage. Your request for general permit coverage has been forwarded to the Stormwater and General Permits Unit.
It is our understanding that the discharge from outfalls 005 and 006 consists solely of non contact cooling water
wastewater discharges. If this is the case, then these remaining discharges may qualify for coverage under wastewater
general permit NCG500000. Attached is a Notice of Intent (NOI) application form for coverage under this general permit.
In order for us to begin the process of reviewing your request for general permit coverage you will need to complete this
application and return it and all other requested information to our Division.
If you have any questions about the application process please feel free to contact me at [phone] ext. 525.
Attachments
Cc: Larry Coble - Winston Salem Regional Office
Charles Weaver — NPDES Unit
Stormwater and General Permits Unit
i�
NCDENR
Customer Service
1 800 623-7748
Sincerely,
Bradley Bennett, Supervisor
Stormwater and General Permits Unit
Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone]

DIVISION OF WATER QUALITY
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v July 18, 2001
MEMORANDUM
To: Larry Coble
Through: Matt Matthews
From: Kevin Bowden X6
Subject: Toxicity Reduction Evaluation Progress Report - May 2001
Cone Mills Corporation
NPDES Permit No. NC0000876
Guilford County
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This office has completed a review of the subject document prepared by the facility's toxicity
consultants, SIMALABS International and Aquatic Sciences Consulting. The May 30, 2001 progress
report summarizes activities undertaken from February 16 through May 15, 2001 (study period). The
White Oak WWTP discharges to North Buffalo Creek and is required to meet a 79% chronic toxicity
permit limitation.
Five (5) multiple concentration Ceriodaphnia dubia chronic toxicity tests (February 20, March
27 (split sample) and April 17 { split sample )) were initiated during the study period. Chronic values
measured 28.1%, 17.0%, 28.1%, 48.3% and >79%, respectively. The report notes that the March 27
(ChV = 17.0%) and April 17 (ChV = 48.3%) tests were invalidated because the tests failed to contain a
20% serial dilution. All test results met the 20% compliance level stipulated in the May 2000
Settlement Agreement between Cone and the Environmental Management Commission except the March
27 (ChV = 17%) test.
Cone Mills continues to review toxicity test reports, chemistry data, polymer/coagulant usage
and DMR data. Findings for the study period are summarized below:
1. The April 2001 test result (ChV > 79%) showed lowest effluent toxicity since March 2000. The
reason for reduced toxicity is unclear.
2. PAC addition ceased on January 23, 2001. No PAC was added during the study period.
3. Conductivity at the LOEC during February and April 2001 (1070 to 1560 umhos/cm) was above
the threshold of conductivity expected to cause toxicity to C. dubia (1000 to 3000 umhos/cm).
These results indicate that conductivity and constituent ions are a primary cause of effluent
toxicity.
4. Sodium concentrations followed a trend of lower levels observed since October 2000.
5. The toxicity of sodium and other metals is affected by hardness. Cone Mills' effluent hardness is
relatively low (69 mg/L as CaCO3) and sodium concentrations are high; therefore, the toxicity
from sodium may be enhanced.
6. The trend of sodium and sulfate concentrations has been lower since October 2000; however,
effluent concentrations of these two metals at the LOEC (529 mg/L and 3.0 to 7.9 mg/L),
respectively, exceeded the concentrations of these metals to be toxic to C. dubia (400 mg/L and
1.6 mg/L), respectively.
7. Alkalinity levels were lower during October and November 2000. Effluent samples during
October and November 2000 were less toxic. Alkalinity concentrations increased during
February and April 2001.
8. The toxicity of sodium, bromide and bicarbonate can vary depending on relative concentration of
other ions in solution. Uncertainty exists whether sodium, bromide and bicarbonate contributed
to observed toxicity.
No additional mock effluent or C18 solid phase extraction tests were performed during the report
period.

2 P, W
The report mentions that Cone's Chemical Management Plan (CMP) continues to be updated.
Cone obtained assurances from its vendors several years ago that manufacturing/process chemicals did ,r
not contain alkyl phenol ethoxylates (APES). An October 2000 effluent sample submitted for analysis
indicated the presence of nonyl phenols (1.44 µg/L), yet no detectable levels of octyl phenols were
observed. Cone Mills contacted its vendors in November 2000 to re-evaluate the presence of APES in
products. Written responses from Cone's vendors indicated that APES were not contained in products
with the exception of a defoamer (Callaway 5585, 0.8% ethoxylated nonyl phenol). The defoamer was
replaced with a non -APE product, Discotech P5106.
THE Date Log entries for February through April 2001 noted the following operational
activities:
February 2001
1. Residuals were removed from the polishing pond beginning January 2001 into early February.
2. Pipeline construction to connect Cone's to the City was begun. Pumps were installed at the
White Oak WWTP. Treatability testing was conducted.
3. Neutralization of influent pH remained difficult. During February, the WWTP received influent
with high pH levels which affected biological and chemical treatment. An additional sulfuric
acid line was added in front of the bar screen.
4. Installation of a pump to withdraw well mixed wastewater from the equalization basin was
postponed due to construction activities.
5. High concentrations of BOD, COD, phosphorus and TSS were observed in addition to increased
pH levels. Increased concentrations may be attributed to increased residuals in the equalization
basin.
6. Foam was observed in the aeration and reaeration ponds. Defoamer was added as needed.
7. Dye range production and frequency of caustic dye runs was average during February.
March 2001
1. The WWTP recovered from an upset caused by high pH influent. A new pump was installed to
replace the old emergency pump.
2. Lower effluent BOD and ammonia concentrations were observed. The amount of polymer being
added was reduced.
3. The second phase of pipeline construction was initiated. Construction involved laying a sewer
line from Cone to the City sewer.
4. Dye range production and frequency of caustic dye runs was average during March.
April 2001
1. Residuals were removed from the digester for land application. A seal was installed on the
digester gate valve.
2. Nutrient addition was discontinued during April.
3. Dye range production and frequency of caustic dye runs was average during April.
The initial treatability study to evaluate the effects on performance and operation of the City's
T.Z. Osborne WWTP was conducted during May 2000. The results suggested that Cone's discharge
would not contribute refractory toxicity to the Osborne WWTP. Another treatability study was
conducted during February 2001. Results from the February 2001 treatability study confirmed previous
results that the discharge would not adversely impact operation or performance of the City's T.Z.
Osborne Plant.
Cone Mills met with City representatives on May 11, 2001 to discuss treatability study results.
Planned activities for the upcoming quarter include: split sampling NPDES effluent compliance
testing and connection of the influent tee line if production is curtailed.

4.
In summary, we congratulate Cone Mills on its efforts to connect to the City of Greensboro and
become a non -discharge facility. We also congratulate the City of Greensboro for accepting this
wastestream. The discharge from the White Oak WWTP to North Buffalo Creek ceased on June 30,
2001 with the wastestream becoming tributary to the City on July 1, 2001. This accomplishment
represents years of hard work. Our office supports open and frequent communication between the City
and Cone Mills. We encourage Cone to frequently review its chemical inventory/chemical management
plan. We also support use of chemicals (process and non -process) which exhibit the least amount of
toxicity and are readily biodegradable. As an indirect discharger, Cone Mills' must continue to eliminate
toxicity at the source through Pretreatment Program implementation and source reduction strategies in
order to assist the City in meeting its NPDES final permit limitations.
Should you have any questions, please feel free to contact me at 733-2136.
cc: Coleen Sullins -Water Quality Section Chief
Dave Goodrich-NPDES Unit
Shannon Langley-NPDES Compliance/Enforcement Unit
Eric Black/Winston-Salem Regional. Office
Tom Poe -Pretreatment
Lisa Spurlin, US EPA Region IV, Water Mgt. Div., 61 Forsyth St, S.W., Atlanta GA 30303
Art Toompas, Cone Mills, 3101 North Elm Street, Greensboro, NC 27415
Rick Diehl, SIMALABS, 1302 Belmont Street, Burlington, NC 27215
John Botts, Aquatic Sciences Consulting, 15751 Bushy Park Road, Woodbine, MD 21797
Central Files

State of North Carolina
1 Department of Environment and Natural Resources
Division of Water Quality
585 Waughtown Street Winston-Salem, North Carolina 27107
April 24, 2001
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Arthur Toompas
Cone Mills -Greensboro
3101 North Elm Street
Greensboro, North Carolina 27415
SUBJECT: NOTICE OF VIOLATION
Whole Effluent Toxicity (WET) Testing
Copper and Zinc Action Level Policy
NPDES Permit No. NC0000876
Cone Mills -White Oak WWTP
Guilford County
Dear Mr. Toompas:
This is to inform you that a review of your toxicity self -monitoring report form for the month of
February 2001 indicates a violation of the toxicity limitation specified in your NPDES Permit. You
should undertake necessary actions to eliminate or reduce effluent toxicity to acceptable levels.
Previous correspondence was sent to you concerning implementation of the Division's Copper
and Zinc Action Level Policy. The correspondence included prospective permit limits for copper and/or
zinc and stated that the trigger for implementing the policy would be two or more WET limit violations
which occur during a toxicity testing calendar quarter. Please note that the second WET limit violation
has occurred and you must provide:
a) Written notification indicating acceptance of the prospective copper and/or
zinc permit limit. Notification is due by May 24, 2001.
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b) Written notification indicating your choice of option(s) 1-4 below. Notification is due by
May 24, 2001.
1. Instream measurements of dissolved metal during low flow conditions that demonstrate
compliance with the Action Level standard
2. A revision of the prospective permit limit using improved inputs that in concert with
existing or additional monitoring data demonstrates compliance with the Action Level
standard
3. Toxicity Identification Evaluation (TIE) results that definitively rule out copper and/or
zinc as causes of effluent toxicity
4. Demonstration by an alternative method approved by the Division and EPA that copper
and/or zinc is not the cause of toxicity
r

2
4
Written notification (a or b above) shall be sent to:
North Carolina Division of Water Quality
Environmental Sciences Branch
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Please note that if you choose item b) above, you will be given nine months to submit
documentation that eliminates copper and/or zinc as causative effluent toxicants. Your final report
should be comprehensive and include all data used to support your conclusion. The report is due by
January 24, 2002.
Three copies of the final report shall be submitted to:
North Carolina Division of Water Quality
Environmental Sciences Branch
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Failure to notify DWQ of your acceptance of a copper and/or zinc limit, failure to notify DWQ
of your option selection or failure to make acceptable demonstration to DWQ that copper and/or zinc are
not causative effluent toxicants within the stated time frames will result in reopening of the NPDES
Permit to include copper and/or zinc numeric limitations, as appropriate.
Additional information regarding the Division's copper and/or zinc action level policy can be
found at the following web site - http://www.esb.enr.state.nc.tis/. Click on the Aquatic Toxicology
Unit and go to the prompt "AT Downloadable Files" located at the bottom of the page.
If you have any questions concerning this correspondence, please contact me at [phone]
or Mr. Matt Matthews, Supervisor of the Aquatic Toxicology Unit at [phone].
Sincerely,
Larry Coble
Regional Water Quality Supervisor
cc: Winston-Salem Regional Office
Susan Wilson-NPDES Unit
Lydia Mayo-USEPA Region IV, Atlanta Federal Center, 61 Forsyth St., SW, Atlanta, GA 30303
Central Files
Aquatic Toxicology Unit Files
z.: "PR 2 5 2001
i
! eE„R - WATER QUALITY
L PONT SOURCE BRANCH

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State of North Carolina
Department of Environment and Natural Resources
` Division of Water Quality
585 Waughtown Street Winston-Salem, North Carolina 27107
April 2, 2001
CERTIFIEDMAIL #7099 3220 0006 8500 9660
RETURN RECEIPT REQUESTED
Mr. Arthur Toompas
Cone Mills -Greensboro
3101 North Elm Street
Greensboro, North Carolina 27415
SUBJECT: NOTICE OF VIOLATION
Whole Effluent Toxicity (WET) Testing
Copper and Zinc Action Level Policy
NPDES Permit No. NC0000876
Cone Mills -White Oak WWTP
Guilford County
Dear Mr. Toompas:
This is to inform you that a review of your toxicity self -monitoring report form for the month of
January 2001 indicates a violation of the toxicity limitation specified in your NPDES Permit. You should
undertake necessary actions to eliminate or reduce effluent toxicity to acceptable levels.
In addition, this correspondence contains important information on the Division's Copper and
Zinc Action Level Policy which is triggered by failure of two or more toxicity limit violations during
the toxicity testing calendar quarter specified by the toxicity testing special condition of your NPDES
Permit. Attachments addressing policy implementation and a copy of the Division's Toxicity Reduction
Guidance have been included with this Notice of Violation.
You should initiate follow-up toxicity testing upon a single WET test failure which occurs
during the toxicity testing calendar quarter.
Your facility is currently monitoring for copper and/or zinc and is exceeding the action level for
these parameters. The policy states that whenever a facility experiences two or more toxicity limit
violations during a toxicity testing calendar quarter, the NPDES Permit will be modified to include
numeric limits for copper and/or zinc UNLESS the permittee provides one or more of the following:
L Instream measurements of dissolved metal during low flow conditions that demonstrate
compliance with the Action Level standard
2. A revision of the prospective permit limit using improved inputs that in concert with
existing or additional monitoring data demonstrates compliance with the Action Level
standard
3. Toxicity Identification Evaluation (TIE) results that definitively rule out copper and/or zinc
as causes of effluent toxicity
4. Demonstration by an alternative method approved by the Division and EPA that copper
and/or zinc is not the cause of toxicity

The Division has evaluated your copper and/or zinc monitoring data. The Division has also
developed a prospective NPDES permit limit based on your facility's instream waste concentration, the
copper and/or zinc action level criterion and a translator procedure. Based on this data your prospective
copper permit limit is 21 µg/L and prospective zinc permit limit is 179 µg/L.
The permittee, upon experiencing two or more toxicity limit violations during a toxicity
testing calendar quarter must either provide D«'Q with:
a) Written notification indicating acceptance of the prospective copper
and/or zinc permit limit. Notification is due within 30 days after the date of
the second WET Notice of Violation.
K'
b) Written notification indicating your choice of option(s) as noted on page
one of this correspondence. Notification is due within 30 days after the date
of the second WET Notice of Violation.
Written notification (a or b above) shall be sent to:
North Carolina Division of Water Quality
Environmental Sciences Branch
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Please note that if you choose item b) above, you will be given nine months to submit
documentation that eliminates copper and/or zinc as causative effluent toxicants. Your final report
should be comprehensive and include all data used to support your conclusion(s). Should the data
indicate copper and/or zinc as the source of effluent toxicity or if the data are inconclusive as to copper
and/or zinc's role as a toxicity source, then the NPDES Permit will be reopened and the metal limits
specified above will be applied to the permit. The report is due nine months after the date of the second
WET Notice of Violation.
Three copies of the final report shall be submitted to:
North Carolina Division of Water Quality
Environmental Sciences Branch
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
You should consider submitting the above correspondence certified mail.
Failure to notify DWQ of your acceptance of a copper and/or zinc limit, failure to notify
DWQ of your option selection or failure to make acceptable demonstration to DWQ that copper
and/or zinc are not causative effluent toxicants within the stated time frames will result in
reopening of the NPDES Permit to include copper and/or zinc numeric limitations, as appropriate.
Please note that your actions to notify DWQ of prospective limit acceptance or to notify DWQ
of plan option(s) and subsequent submission of a plan are contingent upon two or more toxicity NPDES
permit limit violations occurring during a toxicity testing calendar quarter.

3
Also note that the WET limit will remain in your NPDES permit regardless of whether metals
are the source of effluent toxicity. The data resulting from your actions to disprove copper and/or zinc as
sources of effluent toxicity will determine whether NPDES Permit limits will be assigned for these
parameters. You are responsible for initiating actions to address these issues.
You may consider entering into a Special Order by Consent (SOC) with DWQ. A SOC provides
regulatory relief for specific NPDES permit limit violations and, if signed, will contain a requirement to
conduct a Toxicity Reduction Evaluation. The SOC will contain a compliance schedule, stipulated
penalties for failing to meet milestone activity dates and may contain upfront penalties to settle past
permit limit violations.
Additional information regarding the Division's copper and/or zinc action level policy can be
found at the following web site - http://vvww.esb.enr.state.nc.us. Click on the "Aquatic
Toxicology" Unit and go to the prompt "AT Downloadable Files" located at the bottom of the page.
This web site also contains EPA's "Toxicity Reduction Evaluation Guidance for Municipal Wastewater
Treatment Plants." Section 4 of this document contains pertinent information on Toxicity Identification
Evaluations.
If you have any questions concerning this correspondence, please contact me at [phone]
or Mr. Matt Matthews, Supervisor of the Aquatic Toxicology Unit at [phone].
Sincerely,
J&
,Sjr Larry Coble
Regional Water Quality Supervisor
ATTACHMENTS
cc: Winston-Salem Regional Office (no attachments)
Susan Wilson-NPDES Unit (no attachments)
Lydia Mayo-USEPA Region IV, Atlanta Federal Center, 61 Forsyth St., SW, Atlanta, GA 30303
(no attachments)
Central Files (no attachments)
Aquatic Toxicology Unit Files (no attachments)

CONE MILLS CORPORATION
3101 NORTH ELM STREET
0 P.O. BOX 26540
GREENSBORO, NC 27415-6540
G,4%--'**`-0%o,-,NE
December 22, 2000
Mr. Charles H. Weaver, Jr.
NCDENR Water Quality/NPDES Unit
1617 Mail Service Center
Raleigh NC 27699-1617
Re: NPDES Permit NC 0000876
Cone Mills Corporation White Oak
Guilford County
Dear Mr. Weaver:
- - 1
DEC 2 9 2000
We received your December 4, 2000 letter concerning renewal of the NPDES permit for our
White Oak Wastewater Treatment Plant. Our plans are to discontinue this discharge by the
expiration date of our permit and therefore, we are not planning to request a new permit.
As you may know, for many years Cone has been working towards terminating its NPDES
permit and discharging its pre-treated wastewater to the City of Greensboro sewer system.
The City of Greensboro has indicated it s willingness to accept Cone's wastewater, but one
of the conditions is that the City first must complete its upgrade of the T. Z. Osborne
Wastewater Treatment Plant. The date for completing that work has been a moving target.
The City's construction work at the Osborne Plant is now close to completion, and Cone
should be able to complete the connection by July 1, 2001.
Should we encounter a brief delay in our connection to the City of Greensboro sewer system,
we would request that a short extension of our permit be granted. However, it is not
anticipated that we will be discharging beyond June 30, 2001.
Please call me at 336.379.6226 if you feel that we need to request a renewal.
Sincerely,
(..� 1
Arthur J. Toompas
In
c: Lindy Bode Aucoin
Larry Coble

SMITH HELMS MULLISS & MOORE,
L.L.P.
300 North Greene Street
Suite 1400
Greensboro, NC 27401
PO Box 21927 (27420)
[phone]
[phone] [DIRECT]
[phone] [FAX]
[e-mail]
Attorneys at Law
November 15, 2000
BY TELECOPYAND FIRST-CLASS MAIL
Mr. Kerr T. Stevens, Director
Division of Water Quality
North Carolina Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Re: Cone Mills Corporation
NPDES Permit No. NC0000876
Guilford County
Dear Mr. Stevens:
NOV 7 2pa
D'R`CTOR s aQA��
Cone Mills respectfully requests a modification of its NPDES permit to reflect the
unavoidable delays that have occurred during the City of Greensboro's construction of the T.Z.
Osborne Wastewater Treatment Plant upgrade. The specific change requested is set forth below.
As you know, for many years Cone Mills has been working toward terminating its
NPDES permit and discharging its pre-treated wastewater to the City of Greensboro sewer
system. The City of Greensboro has indicated its willingness to accept Cone Mills' wastewater,
but one of the conditions is that the City first must complete its upgrade of the Osborne Plant.
The date for completing that work has been a moving target.
In April 1998, DENR issued to Cone Mills a revised permit, which included significantly
more stringent limits for BOD5 and ammonia. Cone Mills sought administrative review of those
limits, and in December 1998 Cone Mills and DENR reached agreement on modified permit
limits. The pre-existing permit limits would remain in effect until December 31, 2000, when the
more stringent limits would apply. At that time both parties understood that by December 31,
Cone Mills would be able to connect to the Greensboro sewer system.
Unfortunately, construction problems encountered by the City of Greensboro have made
it impossible for Cone Mills to connect to the sewer system this year. The good news is that the
City's construction work at the Osborne Plant is almost complete, and Cone Mills should be able
to complete the connection by July 1, 2001.
A T L A N T A CHARLOTTE G R E E N S B 0 R 0 R A L E I G H W I L M I N G T 0 N

Mr. Kerr T. Stevens
November 15, 2000
Page 2
In a settlement agreement entered into in May 2000, DENR recognized that the pace of
the Osborne Plant upgrade had eliminated the possibility of a prompt connection of Cone Mills'
discharge to the collection system. The Settlement Agreement therefore extended the deadline
for hooking onto the City until July 1, 2001. Cone has submitted an application to DENR for the
permits necessary to construct the pump station and pipeline to the Osborne Plant, and we are
awaiting DENR's approval.
The Settlement Agreement dealt only with toxicity issues and did not address BODS and
ammonia. Cone Mills would like for the deadline in its NPDES permit to match the more
realistic deadline in the Settlement Agreement. To accomplish this step, Cone Mills requests that
DENR take one of the following alternative steps:
1. Modify the permit to change the deadline for lowering BOD5 and ammonia limits
from December 31, 2000 to July 1, 2001; or
2. Modify the Settlement Agreement to incorporate BOD5 and ammonia as covered
parameters.
We appreciate your consideration of this request and look forward to hearing from you.
If a meeting would be helpful to expedite this matter, we are happy to come to Raleigh at a time
that is convenient for you.
Sincerely,
S-�
Stephen W. Ea
cc: Mr. Bill Reid
Mr. Larry Coble
Ms. Lindy Bode Aucoin
Mr. Arthur Toompas

DIVISION OF WATER QUALITY
November 29, 1999
MEMORANDUM
To: Larry Coble
Through: Matt Matthews it
From: Kevin Bowden 66
Subject: Toxicity Reduction Evaluation Progress Report — November 1999
EPA Administrative Order 98-156
Cone Mills Corporation
NPDES Permit No. NC0000876
Guilford County
This office has reviewed the subject document prepared by the facility's toxicity
consultant, Burlington Research, Incorporated. The progress report has been submitted to fulfill
item 15 of EPA Administrative Order 98-156 which requires that progress reports be submitted
to EPA every 90 days until the final compliance date has been achieved (December 31, 2000).
The November progress report summarizes activities undertaken from August through October
(study period). The White Oak WWTP discharges to North Buffalo Creek and is required to
meet a 79% chronic permit limitation.
Three (3) multiple concentration Ceriodaphnia dubia chronic toxicity tests (August 17,
September 22, and October 20) were initiated during the study period. Acute toxicity (measured
as 48-h LC50) was >79% for all procedures. Chronic values measured 68%, 68% and <10%,
respectively.
The plant was not idle during the study period. THE Date Log notes indicate the
following:
➢ relocation of aerators in equalization basin to enhance mixing
➢ sporadic use of sulfuric acid during August, increased use during September
➢ equalization of flow into the treatment plant through water conservation
➢ removal of 300,000-400,000 gallons of biosolids from September 27-October 15
➢ cleaned polymer feed pumps on October 19 to prevent clogging
➢ added 2 gallons of defoamer in September to reduce foaming
manual feeding of sulfuric acid in September to adjust pH in equalization basin
The report notes that monthly average polymer usage for Magnifloc 577C was close to
the White Oak goal of 30 mg/L or less during August (31 mg/L) and September (34 mg/L);
however, October (54 mg/L) polymer dosage was almost twice the White Oak goal. Monthly
average usage of Cytec AF124 remained close to the goal of 0.5 to 1.0 mg/L for August through
October (0.46 mg/L, 0.56 mg/L and 0.82 mg/L), respectively. Polyaluminum chloride (PAC)
usage during the study period remained close to the White Oak goal of 30 mg/L or less (36 mg/L,
32 mg/L and 23 mg/L), respectively.
Two individual polymer evaluations were conducted. On October 20 supernatant from a
jar containing 30 mg/L Magnifloc 577C, 30 mg/L PAC and 1.0 mg/L Cytec AF124 was
compared against supernatant from a jar containing 10 mg/L Chemtreat (a guanidine polymer
and potential replacement for Magnifloc) and 20 mg/L PAC. A sample of clarifier overflow was

2 t
used as a baseline (IC25 of 25%). IC25 values measured 12.5% for the jar containing Magnifloc,
PAC and Cytec combination and 60% for the jar containing Chemtreat and PAC. Confidence
limits were discrete indicating a significant difference in toxicity. Results suggest that the
addition of Chemtreat and PAC can reduce toxicity of clarifier overflow and possibly final
effluent.
The second polymer trial was conducted on October 22. Supernatant from ajar
containing 40 mg/L Stockhausen cationic polymer 189, 30 mg/L PAC and 1.0 mg/L
Stockhausen anionic polymer A3050 was compared against supernatant from ajar containing 40
mg/L Magnifloc 577C, 30 mg/L Stockhausen 9013 PAC and Stockhausen anionic polymer
A3050. Clarifier overflow was again used for the baseline. IC25 values were similar for all jars
indicating that the use of Stockhausen polymers were not effective in reducing toxicity of
clarifier overflow.
The Discussion section of the report notes that during August and September polymer
dosage was near the White Oak goal for Magnifloc 577C, PAC and Cytec AF 124. THE Date
Log notes indicated that polymer feed pumps were clogged and subsequently cleaned after
collection of the first toxicity sample during October. In addition, the effluent was tinted during
October. Ionic content of the October effluent was similar to that of the September effluent.
Salinity models predict that ionic concentration was sufficiently elevated to cause mortality in
79% concentration at 48 hours. Based on similarities in ionic concentrations for September and
October, the report notes that excess polymer feeding rates could have contributed to the <10%
chronic value observed for October.
For the period January 1996 through July 1999, linear regression correlation coefficients
indicate increased toxicity for conductivity versus other chemical parameters.
The report lists three on -going White Oak THE projects. The first project is
implementation of a flow -proportional polymer feed system which was completed the week of
November 5. The second project involves performing a TIE after flow proportional polymer
feed pumps are operational. The third project includes conducting a bench scale treatment
evaluation of White Oak using the City's expanded and updated design criteria. The Company
anticipates conducting the treatability study in early 2000. The City does not anticipate
accepting Cone Mills discharge until 2001, the projected completed date of the plant expansion.
Recommendations for the upcoming quarter include:
• completion of 2-3 multiple concentration toxicity tests once polymer feed is
flow proportional
• completion of weekly abbreviated chronic procedures for one month to
measure variability in the effluent
• repeat jar tests for Chemtreat polymer - Submit for 28-d biodegradability,
ASRIT and 48-h acute test - Conduct AQUATOXTM evaluation on Chemtreat
In summary, Section 2.2 of the report provides several THE Date Log notes related to
operational adjustments undertaken during the report period. We appreciate this information,
find this information to be helpful but have a few specific questions. How much did sulfuric acid
use increase in September versus August? What type of flow conservation measures were
undertaken to equalize flows into the plant? Why were two gallons of defoamer added during
September? Foaming in treatment systems may be a result of surfactant loading. Does the
September foaming incident correlate with a change in production process/chemical use or

product output and how often is defoamer added? Another issue which Cone has addressed in
past progress reports relates to information on polymer trials. While we agree that flow -paced
polymer feed will provide more accurate dosage rates and understand the amount of time
necessary to evaluate polymer usage, we are disappointed that polymer investigations have not
progressed to the point where the least toxic and most effective polymers have been selected for
use at White Oak. The importance of polymer evaluations and chemical optimization activities
were addressed at the onset of Cone's TRE. Based on information we have reviewed, TDS
continues to remain a primary effluent toxicant.
This office looks forward to reviewing the facility's next quarterly progress report.
Should you have any questions, please feel free to contact me at 733-2136.
cc: Coleen Sullins -Water Quality Section Chief
Bill Reid -Point Source Branch
Dave Goodrich-NPDES Unit
Shannon Langley-NPDES Compliance/Enforcement Unit
Eric Black/Winston-Salem Regional Office
Tom Poe -Pretreatment
Lisa Spurlin, US EPA Region IV, Water Mgt. Div., 61 Forsyth St, S.W., Atlanta GA 30303
Art Toompas, Cone Mills, 3101 North Elm Street, Greensboro, NC 27415
Central Files

CONE. .MILLS C.ORPOR.ITION
3 [OI NORTH ELN( JTRELT
P.O. Box ,6540
GREENSBORO, NC 274Ij-6j40
O'li-liDoNE -
May 11, 1999
Ms. Lisa Spurlin
Water Programs Enforcement Branch
Water Management Division
U.S. EPA Region IV
61 Forsyth Street, S.W.
Atlanta GA 30303
ADMINISTRATIVE ORDER NO. 98-156
NPDES PERMIT NO. NC0000876
13
R ,ok ER OUALITY
OEN
pp�SOURCE BRANCH
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
In compliance with Item No. 15 of the order we are submitting the enclosed quarterly
progress report. Please contact me or Mr. Rick Diehl with any questions regarding this
report.
I certify under the penalty of law that this document and all enclosures were prepared under
my direction or supervision in accordance with a system designed to assure that qualified
personnel properly gather and evaluate the information submitted. Based on my inquiry of
the person or persons who manage the system, or those persons directly responsible for
gathering the information, I certify that the information submitted is, to the best of my
knowledge and belief, true, accurate and complete. I am aware that there are significant
penalties for submitting false information, including the possibility of fine and imprisonment
for knowing violations.
Sincerely,,
Arthur J. Toomp
Corporate Environmental Manager
IJWNPDESPMT.LTR
enclosure
c: Colleen Sullin - US EPA Region IV
David Goodrich
Matt Matthews
Larry Coble
Rick Diehl
Dr. Gilbert ONeal
Cone Mills: Lindy Bode Aucoin, Mike Burleson, Jeff Wells, John Scoville

ow,
Burlington
Research
1302 Belmont Street • Burlington, NC 27215-6935 • Tel. [phone] • Fax [phone]

Y
TOXICITY REDUCTION EVALUATION
PROGRESS REPORT
CONE MILLS CORPORATION
NPDES PERMIT NO. NC0000876
MAY 1999

TOXICITY REDUCTION EVALUATION
PROGRESS REPORT
CONE MILLS CORPORATION
NPDES PERMIT NO. NC0000876
MAY 1999
Prepared for:
Cone Mills Corporation
3101 North Elm Street
Greensboro, North Carolina 27415
Prepared by:
Burlington Research, Inc.
1302 Belmont Street
Burlington, North Carolina 27215-6935
May 7, 1999

TABLE OF CONTENTS
Page
LISTOF TABLES....................................................................................................................
LISTOF FIGURES...................................................................................................................
1.0 INTRODUCTION............................................................................................................1
2.0 ACTIVITIES AND RESULTS.........................................................................................
l
2.1 WWTP Final Effluent Toxicity Monitoring.......................................................
l
2.2 Operations...........................................................................................................2
2.3 Chemical Management Program........................................................................3
2.3.1 Environmental Assessments..................................................................3
2.3.2 Polymer Evaluations
2.4 Activated Sludge Inhibition Tests......................................................................4
3.0 DISCUSSION................................................................................................................5

LIST OF TABLES
Page
1. Ceriodaphnia dubia multiple concentration chronic toxicity test endpoints,
White Oak WWTP final effluent, January 1996 through January1999 ............................9
2. Toxicity and color endpoints determined during polymer evaluation jar tests,
ConeMills TRE..................................................................................................................10
3. Gas Research Institute Salinity Toxicity Reduction model test data for
predicted toxicity of WWTP effluent samples used for monthly toxicity monitoring
October 19997 through March, 1999..................................................................................12
�f (►�11[�I��[1�1�7 �E.�
1. Ceriodaphnia dubia multiple concentration chronic toxicity chronic values (ChVs),
White Oak WWTP final effluent, January 1996 through April 1999.................................13
ii

1.0 INTRODUCTION
Item 15 of Administrative Order No. 98-156 requires submittal of toxicity reduction evaluation
(TRE) progress reports every ninety days to USEPA Region 4. This report, prepared and
submitted to meet the May 1999 deadline, summarizes results of ongoing and completed
activities for the period of February 1999 through April 1999.
While the THE Plan was submitted to EPA in August 1998, work on the THE has been ongoing
since February 1996 pursuant to requirements of the North Carolina Department of Environment
and Natural Resources, Division of Water Quality. As requested in the September 3, 1998
meeting between Cone Mills, Burlington Research, EPA Region 4, NCDENR and others, Cone
Mills submitted a summary of THE activities and findings to EPA on November 5, 1998.
2.0 ACTIVITIES AND RESULTS
2.1 WWTP Final Effluent Toxicity Monitoring
Whole effluent Ceriodaphnia dubia multiple concentration chronic toxicity tests (North Carolina
Department of Water Quality Phase II) were initiated February 13, 1999, March 31, 1999, and
April 14, 1999 at effluent concentrations of 10%, 20%, 39.5%, 59% and 79%.
Acute toxicity measured as a 48-h LC50 was evident in the February test with a measured 48-h
LC50 of 41%. No acute toxicity was evident in the March or April procedure, i.e. 48-h LC50
>79%. At test conclusion, there were two organism mortalities at the 20% effluent test
concentration in the February procedure and three mortalities at the 20% effluent test
concentration in the March procedure. In the April procedure, no mortalities were noted at test
conclusion. In the 79% concentration, complete mortality was noted in the February procedure

while March and April showed no mortality in the 79% test concentration (Table 1). A chronic
value (ChV) of < 10% and a point estimation 25% inhibition concentration (IC25) determination
of 6.7% were measured for the February test (Table 1, Figure 1). The chronic value calculated
for the March procedure was 28% and the corresponding IC25 was 16%. A chronic value of
>79% and IC25 of 67% was measured for April procedure (Table 1, Figure 1).
2.2 Operations
THE Date Log notes indicate that the White Oak manufacturing facility was idle on two
occasions during this report period: February 1 through February 7, 1999, and February 28
through March 7, 1999. Several operational adjustments were made during the reporting period
at the wastewater treatment plant, including:
- use of a new feed system for Magnifloc 577C,
- installation of a dechlorination unit,
- substitution of an emulsion polymer (Cytec AF 124) for dry polymer Praestol,
- dredging and removal of 2,000,000 gallons of biosolids from tertiary lagoon, and
- removal of mono -polymer pumps and replacement with pulsar feed pumps.
Average polymer usage during this reporting period has remained close to the White Oak goal of
30 mg/L or less for Magnifloc 577C, 30 mg/L or less for polyaluminum hydroxychloride (PAC),
and 0.5 to 1 mg/L of Praestol or Cytec AF124. PAC was not being fed to the system from
February to mid -March. During the week of March 22 to April 1, 1999, overall polymer usage
was high to control a color problem. The use of PAC was discontinued during this period until
April 8, 1999, because it was theorized that the PAC was contributing to reduced color removal.
After consulting with polymer companies, a new emulsion (Cytec AF124) was implemented as a
2

substitute for the dry polymer, Praestol. Control of effluent color was regained and PAC feeding
was resumed after implementation of Cytec AF 124.
2.3 Chemical Management Program
2.3.1 Environmental Assessments
Because of the successful color reduction seen with Cytec AF 124, a sample of the product was
submitted for an environmental' assessment on April 2, 1999 to evaluate any environmental
impact associated with the product. The product is acutely toxic with a measured 48-h LC50 of
<1.0 mg/L. Complete mortality was observed in the 1 mg/L treatment within 48 hours. The
product is slightly biodegradable, as 39% degradation was seen at the end of 28 days.
AQUATOXTm evaluation of sludge inhibition EC50 determinations, 28-day biodegradability and
acute toxicity LC50 analysis will be completed by mid -May.
2.3.2 Polymer Evaluations
During the previous report period, it was concluded that the inorganic polymer polyaluminum
hydroxychloride (PAC) provided an effective replacement for the Magnifloc 577C. Results of
the pilot trial conducted in early November 1998 indicated, however, that final effluent color
could not be adequately controlled by PAC alone. It is theorized that the absence of an effective
polymer dosing system contributed to the inability of the PAC to control color alone. After
complete implementation of the polymer flow proportional feed system, a pilot trial will be
scheduled to evaluate the reduction/elimination of Magnifloc 577C with the substitution of the
less toxic PAC as the primary flocculant, provided there is acceptable color removal. Currently,
the application rate of 30 mg/L or less PAC has reduced the application rate of Magnifloc 577C
3

from 35 to 40 mg/L to a more consistent 30 mg/L. This combination of PAC and Magnifloc
577C along with a 0.5 to 1.0 mg/L of the new emulsion polymer Cytec AF 124 has been the
standard practice for polymer application since mid -March 1999
Abbreviated chronic toxicity tests were initiated April 16, 1999 using the supernatant from a jar
test containing 30 mg/L PAC, 30 mg/L Magnifloc 577C and 0.5 mg/L Cytec AF124 to gauge the
toxicity of the new emulsion with PAC and Magnifloc 577C. The first stage clarifier overflow
was also submitted as baseline to judge any toxicity enhancement or reduction with all three
chemicals. Toxicity test results indicate that the supernatant from the jar that contained all three
treatment chemicals had an IC25 of 27% that was comparable to the untreated clarifier IC25
value of 27%. This result suggests that the use of these three products does not contribute to
enhanced chronic toxicity (Table 2).
2.4 Activated Sludge Respiration Inhibition Tests
During this reporting period two activated sludge respiration inhibition tests (ASRITs) were
applied to two composite Wastewater Treatment Plant (WWTP) samples to gauge the impact of
White Oak discharge to the T. Z. Osbourne POTW. The first procedure was performed on a
composite sample collected March 2-3, 1999. The second procedure was performed in
conjunction with the March bioassay procedure using the sample collected March 30 - 31, 1999.
An abbreviated chronic toxicity test was performed on the sample collected for the first
procedure to gauge the toxicity of the effluent sample to Ceriodaphnia. The source of sludge
microorganisms for each test came from the new aeration basin at the T. Z. Osbourne POTW that
contains nitrifying bacteria. Test concentrations for the ASRITs were 5%, 10%, 20%, 40%, and
El

' 57%. Results of the bioassays showed that the effluent was toxic (IC25 = 16% for both
procedures) but the chronic value of 28% exceeded the alternate compliance limit of 20%
required by the City of Greensboro. The EC50 calculated for each ASRIT was >57% suggesting
that the effluent was not toxic to the sludge microorganisms at a level that was almost twice the
alternate compliance limit set by the City of Greensboro. Additionally, the samples used for both
procedures were notably different from one another both in terms of plant operations and ionic
concentration. The ASRIT performed early in March was conducted on a sample when
operations were normal at the White Oak WWTP and effluent quality was good but levels of
sulfate (1700 mg/L) and sodium (908 mg/L) were elevated above the current running averages of
880 mg/L level for sulfate and 540 mg/L for sodium. In contrast, the ASRIT performed in
conjunction with the March bioassay was conducted with a sample collected when operations at
the plant were atypical and overall effluent quality was poor but levels of sulfate (931 mg/L) and
sodium (781 mg/L) were closer to the running averages for both sulfate and sodium (Table 3).
Results of both procedures suggest that the White Oak discharge would not pose a problem to
the T. Z. Osbourne plant even if operations at the White Oak plant are atypical and effluent
quality is poor.
3.0 DISCUSSION
The chronic value of <10% measured for the February monitoring event clearly corresponded to
an elevated residual chlorine level (0.2 mg/L) that was measured on the first sample. This
residual chlorine level contributed to the only monitoring event that had measurable acute
toxicity within 48-hours. Predicted toxicity levels based on ion concentration alone collected
�1

from the Gas Research Institute model for acute toxicity of freshwater organisms to saline waters
supports this observation. According to the model predictions, the ionic concentration in the
first sample was not sufficiently elevated to predict a measurable 48-hour LC50. The model
predicted that there would be 90.4% survival at 48-hours in an undiluted solution with this ionic
concentration (Table 3). It is also unlikely that overfeeding of polymer caused this toxicity
problem as the average amounts of polymer were 34 mg/L and 0.5 mg/L for Magnifloc 577C and
Praestol, respectively. Each of these levels targets the goal of 30 mg/L for Magnifloc 577C and
0.5 mg/L for Praestol. Based on this evidence, a dechlorination system was installed to eliminate
any future toxicity problems related to residual chlorine.
The March toxicity test procedure was typical with respect to historic toxicity but operationally
there were atypical circumstances. It was noted that the effluent during this period contained
many fine suspended solids and residual dye. The overall polymer dosage was elevated to
reduce the color of the effluent. The average dosage of all three polymers was 92 mg/L, 35
mg/L, and 1.3 mg/L for Magnifloc 577C, PAC and Praestol/Cytec AF 124. Although the feed
rate was high during the collection of samples (118 mg/L) it is likely that the level did not reach
toxic thresholds in final effluent until after the samples for the toxicity test were collected, due to
plant retention times. Average effluent flow during the test procedure was 1.27 MGD, which
was higher than the average effluent flow during the February or April procedures. The ionic
content of the effluent used for the first and second samples was also above the running average
for sodium and sulfate (Table 3). Despite the elevated ion levels and increased polymer dosage,
the chronic value did not fall below the 20% alternate compliance limit.
0

The April procedure was a compliant test. During this period, the average amount of Magnifloc
577C fed was 20 mg/L, the average amounts of PAC and Cytec AF 124 were 29.5 mg/L and 0.44
mg/L. Polymer use was normal at this time, i.e., the levels of Magnifloc 577C and PAC met the
target level of 30 mg/L or less while the level of Cytec AF 124 was below the target goal of 0.5
to 1.0 mg/L. There are two factors contributing to this compliant test result. The first factor is
the reduced the level of polymer fed during the collection of samples for testing. Secondly, the
level of sulfate (329 mg/L) was reduced to levels well below the running average of 855 mg/L
(Table 3). The reduced sulfate level corresponds to the tertiary lagoon dredging operations that
occurred three weeks earlier during the week of March 24, 1999. Previous THE studies have
demonstrated that the lagoon tends to act as a sink for toxic ions and chemicals and removal of
the biosolids leads to reduced ion levels in whole effluent. Overall, this test result suggests that
if polymer use is optimized and levels of sulfate are reduced through frequent dredging of the
tertiary lagoon, reduced levels of whole effluent toxicity can be expected.
As a means of on going characterization of effluent toxicity, linear regression analysis was
applied to correlate the 25% Inhibition Concentration (IC25) with chemical parameters and flow
for the period of January 1995 through March 1999. Correlation coefficients [r] for IC25 are -
0.15 for flow, -0.55 for weighted conductivity, -0.18 for TSS, -0.35 for COD, -0.24 for chloride,
-0.23 for sulfate, -0.28 for sodium, 0.17 for potassium, -0.37 for alkalinity and 0.09 for hardness.
An increasing negative correlation indicates enhanced toxicity as the respective chemical
parameter increases. As expected, the greatest negative correlation was observed for
conductivity.
7

There are two projects in progress for the White Oak WWTP. The first project is the
implementation of the new flow -proportion polymer feed system is scheduled to be completed in
two phases. Phase I involves implementation of Magnifloc 577C and PAC feed pumps set to
deliver a portion of polymer into the waste stream based on the flow rate through the flocculator
so a known constant level of polymer can be fed into the system. Presently, the pumps are
operational and are scheduled to be flow proportional by May 15, 1999. Phase II involves
installation of a flow proportional polymer feed system for Cytec AF 124. Phase II is scheduled
to be completed by July 15, 1999.
Secondly, a bench -scale treatment evaluation of White Oak effluent will be conducted to gauge
the treatability of White Oak discharge. This study is recognized as a key assessment in the
THE program as it will substantiate the acceptability and treatability of White Oak discharge by
the upgraded Osbourne treatment plant. This study can not proceed until additional information
requested from the City of Greensboro regarding plant design is forwarded to BRI. Once this
information is obtained; the treatability study will be designed and implemented.
8

1996
1997
1998
19 99
Table 1: Ceriodaphia dubia multiple concentration chronic toxicity test endpoints,
White Oak final effluent, Janury 1996 through April 1999.
Test
Date
ChV
%
IC25
20% EFFLUENT
74%/79% IWC
% I LL UL
SA Y/AF
SA Y/AF
1/17
<
10
8
5.2
12.6
10
15
0
0
2/ 14
<
10
5
4.1
6.5
9
15
0
0
3/13
<
10
5
4.2
5.8
0
1
0
0
4/03
14
13
10.6
16.9
6
14
0
0
5/15
14
13
11.5
13.7
6
8.4
4
0
6/12
28
24
21.6
26.7
10
23
0
0
6/26
48
48
48
48
9
25
3
7
7/24
14
0
19
15.2
10
22
0
0
9/ 18
14
18
14.7
22.3
10
16
8
0
10/23
28
20
15.3
25.3
10
21
0
0
11/13
14
19
16.5
22.6
10
21
0
0
12/11
28
23
8.3
26.2
10
28
0
0
1/03
48
47
45.8
49.4
10
26
10
10
1/29
14
16
13.4
19.3
9
20
0
0
2/19
>
79
> 79
NC
NC
10
30
10
26
3/05
48
41
32.5
44
10
25
4
0
4/23
14
13
8.3
16.3
10
18
4
0
5/14
28
25
23.3
27.5
10
26
5
1
6/11
14
15
11.1
18.2
10
18
10
1
7/09
48
54
40.3
61.6
10
30
10
14
8/06
28
36
31.3
41.2
10
26
10
6
9/10
28
25
20.6
27.5
9
24
9
3
10/18
28
37
31
42.2
10
24
10
11/05
28
31
28.3
33.3
10
26
10
3
12/31
NC
NC
NC
NC
10
15
10
5
1/14
NC
NC
NC
NC
10
11
10
0
2/ 11
48
40
33.2
42.7
10
23
0
0
3/18
68
69
64.8
70.3
10
22
10
12
4/29
68
49
7.1
61.1
5
19
0
0
5/29
28
24
21
26.4
10
18
2
0
6/30
68
73
NC
NC
10
26
10
18
7/15
28
28
23.6
31.5
10
23
0
0
8/12
28
26
23.7
28.4
10
23
0
0
9/23
14
11
8.2
12
8
2
0
0
10/28
48
44
38.7
46.7
10
22
10
4
11/30
28
31
29.2
33.4
10
23
4
0
12/30
>
79
> 79
NC
NC
10
23
10
22
1/06
>
79
> 79
NC
NC
10
33
10
30
2/13
<
10
7
4.84
10.2
8
6.5
0
0
3/02
28
16
9.56
21.8
5
12
1
0
3/31
28
16
14.3
19.1
7
14
10
0
4/ 14
>
79
67
37.6
72.1
10
23
10
10

Table 2. Toxicity and color endpoints determined during polymer evaluation jar tests, Cone Mills TRE.
ACUTE LC50 % CHRONIC ADMI
DATE SOURCE TREATMENT 48-H 1441168-H NOEC °,6 LOEC % CHV% IC25% IC50°,6 INITIAL DJUSTED
10/7/97
FS Clarifier Overflow
No Polymer/Filtered
>79
>79
15
30
21
5
61
15
(7J115)
FS Clarifier Overflow
10 ppm Magnifloc
>79
>79
15
30
21
4
5
23
FS Clarifier Overflow
20 ppm Magnifloc
>79
>79
30
60
42
8
11
FS Clarifier Overflow
100 ppm Magnifloc
35
21
7.5
15
11
13
25
Chem. Clarifier (Flume)
No Polymer/Filtered
>79
>79
15
30
21
43
56
Whole Effluent Grab
No Additional
>79
>79
79
>79
>79
3120M
Mixing Chamber bf Floc.
5 ppm Calgon
>79
27
10
20
14
13
14
16
27
(8C505)
Mixing Chamber bf Floc.
10 ppm Calgon
>79
28
20
39.5
28
8
18
Mixing Chamber bf Floc.
20 ppm Calgon
>79
26
<10
10
<10
413/98
Mixing Chamber bf Floc.
30 ppm Magnifloc w/ 1 ppm Praestol
68
50
10
20
14
10
15
15
(SD0781)
Mixing Chamber bf Floc.
60 ppm Magnifloc wl 1 ppm Praestol
61
58
10
20
14
13
7
14
Mixing Chamber bf Floc.
5 ppm Calgon
68
52
<10
10
<10
5
10
Mixing Chamber bf Floc.
10 ppm Calgon
68
54
<10
10
<10
13
18
Mixing Chamber bf Floc.
20 ppm Calgon
>79
55
10
20
14
20
27
Whole Effluent Grab
No Additional
>79
73
20
39.5
28
7/1/98
FS Clarifier Overflow
Untreated
61
<25
57
<25
(8F678)
Chem. Clarifier (Flume)
Untreated
>79
46
10
20
14
14
29
<25
<25
Effluent
Effluent
Polysep 7502
50 ppm Magnifloc w/ 2 ppm Praestol
<10
<10
<10
10
<10
<10
<10
34
31
8121 /98
FS Clarifier Overflow
30 ppm Magnifloc w/ 1.5 ppm Praestol
63
56
10
<10
<10
12
20
59
68
88
74
88
(8H614)
FS Clarifier Overflow
30 ppm EB5000 w/ POL-E-Z 7736
>79
71
39.5
59
48
38
28
43
86
83
FS Clarifier Overflow
30 ppm E65000 w/ 1.3 ppm R300
>79
>79
20
39.5
28
200
200
FS Clarifier Overflow
Untreated
9/2/98
FS Clarifier Overflow
Magnifloc/Praestol
>79
>79
59
79
68
>79
>79
8
(81074)
Flume
Magnifloc/Praestol
24
14
<10
10
<10
4
5
9
Final Effluent Grab
Magnifloc/Praestol
>79
74
<10
10
<10
9/14/98
FS Clarifier Overflow
28 ppm Magnifloc w/ 1.5 ppm Praestol
>79
>79
39.5
59
48
50
63
5
(81331)
Flume
28 ppm Magnifloc w/ 1.5 ppm Praestol
21
14
<10
10
<10
3
23
32
Final Effluent Grab
28 ppm Magnifloc w/ 1.5 ppm Praestol
>79
73
20
39.5
28
Continued
10

ACUTE LC50 % CHRONIC ADMI
DATE SOURCE TREATMENT 48-H 1441168-H NOEC % LOEC % CHV% IC25% IC50% INITIAL DJUSTED
9/17/98
FS Clarifier Overflow
Untreated
>79
>79
59
79
68
71
>79
88
85
(81491)
Flume
Untreated
>79
>79
20
39.5
28
32
>79
47
48
Flume
10ppm P35
>79
>79
39.5
59
48
51
74
62
60
FS Clarifier Overflow
30 ppm PAC w/ 2 ppm Al 30
>79
>79
79
>79
>79
41
>79
76
98
FS Clarifier Overflow
23 ppm Magnifloc w/ 1.4 ppm Praestol
>79
>79
39.5
59
48
39
66
45
41
9/30/98
FS Clarifier Overflow
Untreated
>79
>79
39.5
59
48
52
62
200
170
(8J006)
FS Clarifier Overflow
30 ppm EB5000 w/0.75 ppm R300
>79
>79
39.5
59
48
49
64
'
FS Clarifier Overflow
30 ppm EB5000 w/ 0.75 ppm R300
226
82
Flume
Untreated
330
248
FS Clarifier Overflow
30 ppm EB5000 w/ 2 ppm POL-E-Z 7736
>79
>79
20
39.5
28
41
62
59
53
FS Clarifier Overflow
30 ppm Magnifloc w/ 0.75 ppm Praestol
>79
27
<10
10
<10
7.7
15
107
124
10/22/98
FS Clarifier Overflow
Untreated
>79
68
20
39.5
28
25
32
55
55
(8J612)
Flume
Untreated
68
68
20
39.5
28
9
32
31
29
FS Clarifier Overflow
30 ppm PAC w/ 0.25 ppm Al 30
>79
71
39.5
59
48
45
79
55
54
10/28/99
FS Clarifier Overflow
Untreated
>79
>79
79
>79
>79
76
>79
N/A
N/A
(8J734)
11/17/98
FS Clarifier Overflow
Untreated
>79
>79
39.5
59
48
43
49
N/A
N/A
(8K444)
FS Clarifier Overflow
30 ppm 577 W/30 ppm PAC
>79
>79
>79
>79
>79
36
60
N/A
N/A
12/16/99
FS Clarifier Overflow
30 ppm 577 W/30 PAC
>79
>79
39.5
59
48
44
52
N/A
N/A
(8L461)
Flume
30 ppm 577 W/30 PAC
>79
>79
20
39.5
28
34
64
N/A
N/A
1/8/99
FS Clarifier Overflow
Untreated
>79
73
<10
10
<10
5.3
14
N/A
N/A
(9A151)
FS Clarifier Overflow
30 ppm PAC - Ashland Chemical
>79
>79
20
39.5
28
19
29
N/A
NIA
4/16199
FS Clarifier Overflow
Untreated
>79
>79
20
39.5
28
24
33
(9D364)
FS Clarifier Overflow
30 ppm PAC, 30 ppm 577
>79
>79
39.5
59
48
27
37
0.5 ppm Cytec Emulsion
10
Calgon:
EB-5000, POL-E-Z 7736 (anionic)
CYTEC:
Superfloc (Magnifloc) C-577,
PAC (poly hydroxyaluminuym chloride) Superfloc
9001,
Superfloc A-130 (anionic), Emulsion (AF-124)
Stockhausen:
Praestol
11

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WWTP final effluent, January 1996 through April 1999. _
CL om =Cpliance Limit

State of North Carolina
Department of Environment
and Natural Resources 4
Division of Water Quality
James B. Hunt, Jr., Governor D E N
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
March 30, 1998
Mr. Arthur J. Toompas
Corporate Environmental Manager
Cone Mills Corporation
3101 North Elm Street
Greensboro, North Carolina 27415-6540
Subject: Issuance of NPDES Permit NC000876
Cone Mills - White Oak Plant
Guilford County
Dear Mr. Toompas:
In accordance with your application dated June 9, 1997, the Division is forwarding the subject
State-NPDES permit. This permit is issued pursuant to the requirements of North Carolina
General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the
U. S. Environmental Protection Agency dated December 6, 1983.
Please be advised that the following changes have been incorporated into the final permit:
Pollutant loadings for the oxygen -demanding wastes listed below have been
decreased based on documented water quality problems in North Buffalo Creek.
The permit renewal includes the following BOD5 and NH3N limits:
- BOD5 (April 1 to October 31) = 52.1 lbs/day (Monthly Average)
- BOD5 (November 1 to March 31) = 104.3 lbs/day (Monthly Average)
- BOD5 (April 1 to October 31) = 10.0 mg/1 (Daily Maximum)
- BOD5 (November 1 to March 31) = 20.0 mg/I (Daily Maximum)
- NH3N (April 1 to October 31) = 1.0 mg/I (Monthly Average)
- NH3N (November 1 to March 31) = 2.0 mg/1 (Monthly Average)
Despite receiving no comments regarding the draft permit, the Division has established a
compliance schedule designed to give the facility additional time to comply with the limits
for the oxygen -demanding wastes listed above. A compliance deadline date of January 1,
1999 has been given. The Division may allow additional time if stipulated in a consent
order.
A Reasonable Potential Analysis (RPA) was performed on the most recent effluent
data for individual toxicants in order to determine the likelihood of a violation of
water quality standards during critical flow (7Q10) periods for any parameter. The
toxicant analysis indicated that, with the exception of arsenic and chlorides, all
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

Draft NPDES Permit
Permit No. NC0000876
Cone Mills - White Oak Plant
Page 2 of 2
toxicant limits will remain the same. The final permit includes the following arsenic
and chloride monitoring requirement changes:
- The RPA indicated that the predicted maximum level of arsenic was well below
the allowable load. In response, the current arsenic limit was dropped in favor
of 2/month monitoring.
- The effluent monitoring frequency for chlorides was increased from quarterly
to monthly because predicted effluent chloride levels approach the allowable
load and because this parameter may contribute to effluent toxicity.
Upon permit renewal in 2001, the facility will be required to meet a Total Nitrogen (TN) limit
of'57.3 lbs/day (annual average mass basis) at outfall 001. This limit will be incorporated because
the Legislature recently passed House Bill 515 which mandates nutrient limits for facilities that
discharge into waters of the state classified as nutrient sensitive waters (NSW).
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to an adjudicatory hearing upon written request within
thirty (30) days following receipt of this letter. This request must be in the form of a written
petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed with the
Office of Administrative Hearings, Post Office Drawer 27447, Raleigh, North Carolina 27611-
7447. Unless such demand is made, this decision shall be final and binding.
Please take notice that this permit is not transferable. Part II, EA. addresses the requirements
to be followed in case of change in ownership or control of this discharge.
This permit does not affect the legal requirement to obtain other permits which may be required
by the Division of Water Quality or permits required by the Division of Land Resources, Coastal
Area Management Act or any other Federal or Local governmental permit that may be required.
If you have any questions concerning this permit, please contact Jeff Myhra at telephone
number 919/733-5083, ext. 597.
Sincerely,
Original Signed By
David A Goodrich
A. Preston Howard, Jr., P.E.
cc: Central Files
Mr. Roosevelt Childress, EPA
Winston-Salem Regional Office / Water Quality Section
Point Source Compliance Enforcement Unit
Aquatic Toxicology Unit
NPDES Unit / Permit file

Permit No. NC0000876
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,
Cone Mills Corporation
is hereby authorized to discharge wastewater from a facility located at the
Cone Mills - White Oak Plant
2420 Fairview Street
Greensboro
Guilford County
to receiving waters designated as North Buffalo Creek in the Cape Fear River Basin in accordance with
effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III, and IV
hereof.
The permit shall become effective May 1, 1998
This permit and the authorization to discharge shall expire at midnight on June 30, 2001
Signed this day March 30, 1998
Original Signed BY
David k Goodrich
A. Preston Howard, Jr., P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

SUPPLEMENT TO PERMIT COVER SHEET
Cone Mills Corporation
is hereby authorized to:
Permit No. NC0000876
1. Continue to operate an industrial wastewater treatment plant consisting of screening,
equalization basin, CO2 and acid neutralization, dual primary clarifiers, polymer addition,
surface aeration basin, three secondary clarifiers, flow meter, chlorination, polishing pond,
effluent reaeration and automatic sampler (outfall 001) and continue to discharge non -contact
cooling water from two outfalls (outfalls 005 and 006) from a facility located at Cone Mills -
White Oak Plant, 2420 Fairview Street, Greensboro, Guilford County (See Part III of this
Permit), and
2. Discharge from said treatment works at the locations specified on the attached maps into
North Buffalo Creek (Outfall 001) and an unnamed tributary to North Buffalo Creek
(Outfalls 005 and 006) which are all classified C - NSW waters in the Cape Fear River
Basin.

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ROAD CLASSIFICATION
PRIMARY HIGHWAY LIGHT -DUTY ROAD. HARD OR
HARD SJRCACE IMPROVED SURFACE
SECONDARY HIGHWAY
HARD SJRFACE UNIMPROVED ROAD
Latitude W06'15" Longitude 79°46'15"
Map # C19SE Sub -basin • 03-06-02
Stream Class C-NSW
Discharge Class 02
Receiving Stream North Buffalo Creek
Design 0 1•25 MGD
SCALE 1:24 000
0 1 MILE
0 7000 FEET
1 0 1 KILOMETER
CONTOUR INTERVAL 10 FEET
QUAD LOCATION
Cone Mills - White Oak Plant
NC0000876
Guilford County

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ROAD CLASSIFICATION
PRIVARY HIGHWAY LIGHT -DUTY ROAD, HARD OR
HARE) SURFACE IMPROVED SURFACE
SECONDARY HIGHWAY
HARD SURFACE C=:NE= UNIMPROVED ROAD
Latitude 36'06'20- Longitude 79'46'12"
Map # C19SE Sub -basin 03-06-02
Stream Class C-NSW
Discharge Class 02
Receiving Stream North Buffalo Creek
Design 0 1.25 MGD
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0 7000 FEET
0 1 KILOMETER
CONTOUR INTERVAL 10 FEET
QUAD LOCATION Cone Mills - White Oak Plant
NCO000876
Guilford County

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DISCHARGE LOCATJON
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ROAD CLASSIFICATION
PRIVADY HIGHWAY LIGHT-DVTY ROAD. HARD OR
HARD SURFACE IMPROVED SURFACE
SECONDARY HIGHWAY
HARr SURFACE =3111111111111111=1 UNIMPROVED ROAD
Latitude 36-06'02" Longitude 79'46'02"
Map # C19SE Sub -basin 03-06-02
Stream Class C-NSW
Discharge Class 02
Receiving Stream North Buffalo Creek
Design 0 125 MGD1 - - 0- 1
SCALE 1:24 000
0 1 MILE
0 7000 FEET
1 0 1 KILOMETER
F—�
CONTOUR INTERVAL 10 FEET
QUAD LOCATION
Cone Mills - White Oak Plant
NCO000876
Guilford County
L

A.(1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINNi Permit No. NC0000876
During the period beginning on the effective date of the permit and lasting until January 1, 1999, the Permittee is authorized to discharge from outfall serial
number 001. Such discharges shall be limited and monitored by the Permittee as specified below:
EFFLUENT CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Avera a
Quarterly
Avera a
Daily
Maximum
Measurement
Fregp2ncy
Sample
Type
Sample
Location'
Flow
1.25 MGD
Continuous
Recording
I or E
BOD, 5 day, 20°C (April 1- October 31
100 lbs/day
20.0 m /1
Daily
Composite
E
BOD, 5 day, 20°C November 1 - March 31
200 lbs/day
40.0 m /I
Daily
Composite
E
COD
12,690 lbs/day
25,380 lbs/day
Weekly
Composite
E
Total Suspended Residue
292 lbs/day
500 lbs/day
Daily
Composite
E
NH3 as N (April 1 - October 31)
2.0 mg/I
Daily
Composite
E
NH3 as N (November 1 - March 31)
4.0 mg/I
Daily
Composite
E
Fecal Coliform
200 / 100 ml
400 / 100 ml
Daily'
Grab
E, U, D
Dissolved Oxygen2
Daily'
Grab
E, U, D
Total Nitrogen NO2 + NO3 + TKN
Weekly
Composite
E
Total Phos horus3
2.0 m /I
Weekly
Composite
E
Temperature
Daily'
Grab
E, U, D
Chronic Toxicit 4
Quarterly
Composite
E
Total Residual Chlorine
21 /I
Dail
Grab
E
Sulfides
36 lbs/day
72 lbs/day
Weekly
Grab
E
Phenols
18 lbs/day
36 lbs/day
Weekly
Grab
E
Chromium
63 /I
Weekly
Composite
E
Lead
32 /I
Weekly'
Composite
E, U, D
Arsenic
2/Month
Com osite
E
Fluoride
2.3 m /I
Weekly
Composite
E
Conductivity
Daily'
Grab
E, U, D
Copper
2 / Month
Composite
E
Nickel
Quarterly
Composite
E
Zinc
2 / Month
Composite
E
Chlorides
Monthly
Composite
E
H5
Daily
Grab
E
Notes:
' Sample locations: E - Effluent, I - Influent, U - Upstream at least 100 feet above the discharge point, D - Downstream (1) at Summit Avenue and (2) at North
Buffalo Creek Wastewater Treatment Plant influent conduit. Inst,eam samples shall be grab samples and shall be conducted three times per week during
June, July, August, and September and once per week during the remainder of the year. Instream monitoring for lead shall be performed monthly at
upstream and downstream location number (1).

A.(1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL (Continued) Permit No. NC0000876
Z The daily average dissolved oxygen effluent concentration shall not be less than 6.0 mg/I.
3 Compliance with the total phosphorus limit is based on quarterly average of weekly samples.
4 Chronic Toxicity Testing P/F at 79%; March, June, September, and December; See special condition A.(5). on the Supplement to Effluent Limitations and
Monitoring Requirements Page.
5 The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
EPA method 624 shall be conducted annually; See special condition A.(6). on the Supplement to Effluent Limitations and Monitoring Requirements Page.
Special permit conditions applicable to the subject outfall are listed on the Supplement to Effluent Limitations and Monitoring Requirements page.

A.(2). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL Permit No. NC0000876
During the period beginning on January 1, 1999 and lasting until expiration, the Permittee is authorized to discharge from outfall serial number 001. Such
discharges shall be limited and monitored by the Permittee as specified below:
EFFLUENT CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Quarterly
Average
Daily
Maximum
Measurement
Fre uenc
Sample
Type
Sample
Locations
Flow
1.25 MGD
Continuous
Recording
I or E
BOD, 5 day, 20°C (April 1- October 31
52.1 lbs/day
10.0 m /I
Daily
Composite
E
BOD, 5 day, 20°C November 1 - March 31
104.3 lbs/day
20.0 m /I
Daily
Composite
E
COD
12,690 lbs/day
25,380 lbs/day
Weekly
Composite
E
Total Suspended Residue
292 lbs/daV
500 Ibs/daV
Daily
Composite
E
NH3 as N (April 1 - October 31)
1.0 mg/I
Daily
Composite
E
NH3 as N (November 1 - March 31)
2.0 mg/I
Daily
Composite
E
Fecal Coliform
200 / 100 ml
400 / 100 ml
Daily'
Grab
E, U, D
Dissolved Oxygen2
Daily'
Grab
E, U, D
Total Nitrogen NO2 + NO3 + TKN
Weekly
Composite
E
Total Phos horus3
2.0 m /I
Weekly
Composite
E
Temperature
Daily'
Grab
E, U, D
Chronic Toxicit 4
Quarterly
Composite
E
Total Residual Chlorine
21 /I
Dail
Grab
E
Sulfides
36 lbs/day
72 lbs/day
Weekly
Grab
E
Phenols
18 lbs/day
36 lbs/day
Weekly
Grab
E
Chromium
63 /I
Weekly
Composite
E
Lead
32 /1
Weekly'
Composite
E, U, D
Arsenic
2/Month
Composite
E
Fluoride
2.3 m /I
Weekly
Composite
E
Conductivity
Daily'
Grab
E, U, D
Copper
2 / Month
Composite
E
Nickel
Quarterly
Composite
E
Zinc
2 / Month
Composite
E
Chlorides
Monthly
Composite
E
I..I5
Daily
Grab
E
Notes:
Sample locations: E - Effluent, I - Influent, U - Upstream at least :100 feet above the discharge point, D - Downstream (1) at Summit Avenue and (2) at North
Buffalo Creek Wastewater Treatment Plant influent conduit. Instream samples shall be grab samples and shall be conducted three times per week during
June, July, August, and September and once per week during the remainder of the year. Instream monitoring for lead shall be performed monthly at
upstream and downstream location number (1).

A.(2). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL (Continued) Permit No. NC0000876•
2 The daily average dissolved oxygen effluent concentration shall not be less than 6.0 mg/I.
3 Compliance with the total phosphorus limit is based on quarterly average of weekly samples.
4 Chronic Toxicity Testing P/F at 79%; March, June, September, and December; See special condition A.(5). on the Supplement to Effluent Limitations and
Monitoring Requirements Page.
5 The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
EPA method 624 shall be conducted annually; See special condition A.(6). on the Supplement to Effluent Limitations and Monitoring Requirements Page.
Special permit conditions applicable to the subject outfall are listed on the Supplement to Effluent Limitations and Monitoring Requirements page.

A.(3). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL
Permit No. NC0000876
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from outfall serial number
005 (Non -contact cooling water. 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
Monthly
Instantaneous
l or E
Tem erature2
Monthly
Grab
E, U, D
Total Residual Chlorine3
Monthly
Grab
E
H4
Monthly
Grab
E
Notes:
1 Sample locations: E - Effluent, I - Influent, U - Upstream 100 feet above the discharge point, D - Downstream at least 300 feet on the unnamed tributary to
North Buffalo Creek. '
2 The temperature of the effluent shall be such as not to cause an increase in the temperature of the receiving stream of more than 2.8°C and in no case
cause the ambient water temperature to exceed 29°C.
3 Residual chlorine monitoring is required only if chlorine is used as a disinfection method.
4 The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
There shall be no chromium, zinc, or copper added to the treatment system except as pre -approved additives to biocidal compounds.
Special permit conditions applicable to the subject outfall are listed on the Supplement to Effluent Limitations and Monitoring Requirements page.

A.(4). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL
Permit No. NC0000876
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from outfall serial number
006 (Non -contact cooling wateo. Such discharges shall be limited and monitored by the Permittee as specified below:
EFFLUENT CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Weekly
Avera a
Daily
Maximum
Measurement
Fre uenc
Sample
T e
Sample
Location'
Flow
Monthly
Instantaneous
I or E
Tem erature2
Monthly
Grab
E, U, D
Total Residual Chlorine3
Monthly
Grab
E
H4
Monthly
Grab
E
Notes:
' Sample locations: E - Effluent, I - Influent, U - Upstream 100 feet above the discharge point, D - Downstream at least 300 feet on the unnamed tributary to
North Buffalo Creek.
2 The temperature of the effluent shall be such as not to cause an increase in the temperature of the receiving stream of more than 2.8°C and in no case
cause the ambient water temperature to exceed 29°C.
3 Residual chlorine monitoring is required only if chlorine is used as a disinfection method.
4 The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
There shall be no chromium, zinc, or copper added to the treatment system except as pre -approved additives to biocidal compounds.
Special permit conditions applicable to the subject outfall are listed on the Supplement to Effluent Limitations and Monitoring Requirements page.

Permit No. NC0000876 '
SUPPLEMENT TO EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS
A.(5). Chronic Toxicity Pass/Fail Permit Limit (Qrtrl
The effluent discharge shall at no time exhibit chronic toxicity using test procedures outlined in the
"North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised November 1995,
or subsequent versions.
The effluent concentration at which there may be no observable inhibition of reproduction or
significant mortality is 79.0% (defined as treatment two in the procedure document). The permit
holder shall perform guarterly monitoring using this procedure to establish compliance with the
permit condition. 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.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the month in which it was performed, using the parameter
code TGP3B. Additionally, DWQ Form AT-1 (original) is to be sent to the following address:
Attention: Environmental Sciences Branch
North Carolina Division of Water Quality
4401 Reedy Creek Road
Raleigh, North Carolina 27607
Test data shall be complete and accurate and include all supporting chemical/physical measurements
performed in association with the toxicity tests, as well as all dose/response data. 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 any single quarterly monitoring indicate a failure to meet specified limits, then monthly
monitoring will begin immediately until such time that a single test is passed. Upon passing, this
monthly test requirement will revert to quarterly in the months specified above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, then
monthly monitoring will begin immediately until such time that a single test is passed. Upon
passing, this monthly test requirement will revert to quarterly in the months specified above.
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.

Permit No. NC0000876
SUPPLEMENT TO EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS (Continued)
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.(6). Annual Volatiles Monitoring Condition
The Permittee shall conduct a test for pollutants annually at the effluent from the treatment plant.
The discharge shall be evaluated using EPA Method 624 for volatile organics.
Other significant levels of organic chemicals must be identified and approximately quantified. For
the purpose of implementing this requirement, the largest 10 GC/MS peaks for chemicals other
than those specified for EPA 624 should be identified and approximately quantified.
A.(7). Biocide Condition
The permittee shall not use any biocides except those approved in conjunction with the permit
application. The permittee shall notify the Director in writing not later than ninety (90) days prior
to instituting use of any additional biocide used in cooling systems which may be toxic to aquatic
life other than those previously reported to the Division of Water Quality. Such notification shall
include completion of Biocide Worksheet Form 101 and a map locating the discharge point and
receiving stream.
A.(8). Nutrient Condition
This permit may be modified, or revoked and reissued to change the effluent limitation on nutrients
for this discharge depending upon the following:
1. The findings of a study by the Division of Water Quality determine nutrient control is
necessary.
2. Local actions do not successfully reduce the nutrient loading on the receiving waters.
3. The onset of problem conditions in the receiving waters.

. f
DIVISION OF WATER QUALITY
March 20,1998
MEMORANDUM
To: Steve Mauney
Through: Matt Matthews rn
From: Kevin Bowden ?6
Subject: Toxicity Reduction Evaluation - WWTP Point Source and Solids Assessment
Cone Mills Corporation
SOC EMC WQ No. 95-17
NPDES Permit No. NC0000876
Guilford County
This office has completed a review of the subject WWTP Point Source and Solids Assessment
document prepared by the facility's toxicity consultant, Burlington Research, Incorporated dated February
1998. This document has been submitted to fulfill item 3(b)3 of the facility's proposed Special Order by
Consent which requires Cone Mills to provide an assessment of settled solids and pore waters for the
final polishing pond, the raw wastewater basin, the ash pond and aerated sludge basin on or before March
1, 1998. Sludge from these basins was centrifuged and supernatant was analyzed for toxicity and
selected chemical parameters. The facility discharges to North Buffalo Creek and is required to meet a
79% chronic permit limitation.
Ash Pond residuals were evaluated during February 1997. Test results showed that this
wastestream was acutely nontoxic at a 14% test concentration; however, the wastestream was chronically
toxic at a 2.5% test concentration. Additional wastestream testing conducted with an October 8 sample
yielded a chronic value of >14% and chronic values for the November 5 and 18 samples measured >14%
and >28%, respectively.
Aeration Basin residuals were evaluated from a single sample collected during February and two
samples collected during June 1997. Test results indicated no acute toxicity (measured as 48-h LC50) at a
79% test concentration. The IC25 for the February 19 sample measured 60% while the IC25 for the June
11 sample measured 5.3%. Conventional parameter concentrations for COD, conductivity, sulfate, and
sodium measured 6390 mg/L, 3755 µmhos/cm (avg), 1793 mg/L (avg), and 2184 mg/l, respectively.
CTAS and MBAS concentrations measured < 0.75 mg/L for the February 19 sample and decant from the
June 13 sample indicated the presence of alkyl phenol ethoxylates. MBAS concentrations for the June 11
and June 13 sample measured 0.12 mg/L and 0.21 mg/L, respectively.
Raw Waste Lagoon residuals were evaluated during July 1997. Acute toxicity (measured as 48-h
LC50) for the July 9 sample measured 31% with chronic inhibition at 2.6%. Nonionic surfactant,
conductivity, sulfate, and sodium concentrations measured 3.61 mg/L, 4800 µmhos/cm, 1480 mg/L, and
1150 mg/L, respectively.
Tertiary Lagoon residuals were evaluated during June 1997. Chemical analyses was conducted
for the June 11 and 13 samples. Acute toxicity (measured as 48-h LC50) for the June 9 sample measured
21% with an IC25 of 12%. Concentrations for conductivity, sulfate, and sodium measured 4230
µmhos/cm, 1875 mg/L (avg), and 1008 mg/L (avg), respectively. Alkyl phenol ethoxylates were also
present in the June 13 sample.
The Discussion section mentions that solids in the aeration basin and tertiary lagoons were
possibly serving as reservoirs of sulfate and sodium ions. It should be noted that these ions were
previously identified as primary source(s) of effluent toxicity. The Company reportedly initiated actions
during 1996 to eliminate the use of products formulated with APEs. Reevaluation of the Ash Pond
discharge suggests that this wastestream is not toxic at its flow contribution to the WWTP. Data
presented in the submittal suggests that Cone Mills wasted approximately thirteen and one-half (13 1/2)
million gallons of residuals during 1997. The report mentions that sludge disposal activities have
provided greater WWTP efficiency and increased detention time. A directional mixer was installed in the

Page 2
Cone Mills WWTP Point Source and Solids Assessment
March 20, 1998
raw waste lagoon during September 1997 to assist with better mixing. Cone Mills reissued a letter to its
vendors concerning the presence of APES in product formulations. Cone reports that all submittals
received regarding the October 13 notice indicate that product formulations do not contain APEs. The
report states that activities undertaken during 1997 "to evaluate and respond to potential sources of
toxicity within the White Oak treatment system have addressed a significant component of the THE
program."
In summary, the submittal mentions that solids in the aeration basin and tertiary lagoon have been
potentially serving as "reservoirs of sodium and sulfate ions." TIE investigations previously identified
TDS as the primary source of effluent toxicity. The Company acknowledged this finding. Based on the
amount of time Cone Mills has been noncompliant with chronic toxicity, this office has concerns with
allowing additional time to achieve compliance with all final permit limitations.
Should you have any questions, please feel free to contact me at 733-2136.
cc: Coleen Sullins, Acting Water Quality Section Chief
Don Safrit-Point Source Branch
Dave Goodrich-NPDES Unit
Ron Linville/Winston-Salem Regional Office
Art Toompas, Cone Mills, 3101 North Elm Street, Greensboro, NC 27415
Tom Poe -Pretreatment
Central Files

DIVISION OF WATER QUALITY
March 18,1998
MEMORANDUM jj�(2
To: Steve Mauney
Through: Matt Matthews ff`
From: Kevin Bowden K6
Subject: Toxicity Reduction Evaluation Phase I Progress Report - February 1998
Cone Mills Corporation
SOC EMC WQ No. 95-17
NPDES Permit No. NCO000876
Guilford County
This office has completed a review of the subject Toxicity Reduction Evaluation Progress Report
prepared by the facility's toxicity consultant, Burlington Research, Incorporated dated February 1998.
This document has been submitted to fulfill item 3(b)l of the facility's proposed Special Order by
Consent which requires the submission of quarterly progress reports to the Winston-Salem Regional
Office no later than the 15th day of each February, May, August, and November. The report summarizes
activities undertaken for the months of November 1997, December 1997, and January 1998 (study
period). The facility discharges to North Buffalo Creek and is required to meet a 79% chronic permit
limitation.
Findings of completed and ongoing THE activities for the study, period include: WWTP final
effluent toxicity monitoring, WWTP operations, Chemical Management Plan, and White Oak Effluent
Toxicity Characterization Studies.
Three (3) multiple concentration Ceriodaphnia dubia chronic toxicity tests (November 5,
December 31, and January 14) were initiated during the study period. The November chronic value
measured 28%. The December and January tests failed to meet test quality control criteria and were
invalidated. Chronic values of 68% and 48% were projected for December and January. The facility
applied the Freshwater Salinity Toxicity Relationship model which predicts the acute toxicity of effluents
based on known salinity toxicity relationships to common freshwater test species. The model predicted a
98% survival for Ceriodaphnia dubia at a 79% effluent concentration. At a 100% effluent concentration
the model predicted >94% survival for Ceriodaphnia dubia and Daphnia magna at 48 hours. At a 100%
effluent concentration, the model also predicted >94% survival for Pimephales promelas at 96 hours.
Notable THE date log entries for November through mid -January included:
• dredged the tertiary lagoon for the second time during 1997 - removed 2 million gallons of
residuals
• removed approximately 15 million gallons of residuals from the digester through November
• sulfuric acid and chlorine acid usage normal
• added an additional floating mixer to the equalization basin during October
• three aerator units in aeration basin out of service in early January
• White Oak production stood from December 24 through December 28
Appendix B of this report contains information on chemical usage information received in
response to a November review. In an October 13, 1997, letter, Cone Mills requested alkyl phenol
ethoxylate (APE) product information from its suppliers. Of the responses which have been received, all
indicate the absence of APES.
Phase I toxicity identification studies have shown that TDS comprises almost half of the toxicity
observed in the effluent. Non -polar organics and surfactants are potential secondary toxicants. Effluent

Page 2
Cone Mills Quarterly THE Progress Report -February 1998
March 18, 1998
MBAS concentrations during this report period ranged from 0.11 mg/L to 0.30 mg/L. Results of
abbreviated tests conducted on the Ash Pond discharge showed an absence of acute and chronic toxicity at
test concentrations of 14% and 28%. Cone Mills installed a pilot plant powdered activated carbon (PAC)
treatment system the week of October 20 to evaluate the effectiveness of PAC on effluent toxicity.
Abbreviated chronic tests did not show an increase in acute or chronic toxicity. The submittal states that
concentrations of MBAS, COD, and TSS decreased (48%, 32%, and 58%, respectively) versus untreated
effluent with PAC treatment while concentrations of inorganic parameters increased. PAC treatment was
discontinued in late December.
The Discussion Section mentions that White Oak effluent met the City of Greensboro's 20%
compliance limit during November 1997 and although the December and January tests were invalidated,
IC25 values suggest that the 20% compliance limit would have been met for both months. The
Freshwater Salinity Toxicity Relationship model predicted negligible acute impact on Ceriodaphnia dubia.
Evaluation of chemical usage information is continuing. Product stewardship information evaluated for
thirteen products shows that all have a low to moderate impact with one exception, Magnifloc 577C.
October 1997 jar testing of this product showed no acute or chronic impact at application rates of 30
mg/L. Powdered Activated Carbon treatment was ineffective in sufficiently reducing chronic toxicity
impact. Although inorganic toxicant concentrations increased in the PAC treated effluent versus untreated
effluent, the report mentions that this increase is "artifactual" since the PAC system prevented
simultaneous collection of untreated samples. The City of Greensboro is expecting its single stage
nitrifying basin to be on-line by April 1998. Pilot plant studies will begin after nitrifying bacteria are
available.
The activities presented in Section 4.0 for the upcoming quarter have been negotiated per the terms
of the SOC. The next quarterly THE progress report is scheduled to be issued on or before May 15,
1998.
In summary, it appears that Cone Mills is implementing activities outlined by the SOC. THE Date
Log notes for January 1, 1998, indicate that "Grease Balls" were entering the WWTP. A subsequent date
log entry indicates that the treatment system was receiving "unknown substances into the WWTP that are
staying in the tertiary lagoon" and that these substances are "causing the problems we are having with our
test results." We are curious what actions were taken by Cone Mills to address the "grease balls" and
unknown substances which entered the treatment system.
We understand the proposed SOC amendment is currently under review in the Central Office.
This office has concerns with allowing additional time to achieve compliance with all final permit
limitations.
Should you have any questions, please feel free to contact me at 733-2136.
cc: Coleen Sullins, Acting Water Quality Section Chief
Don Safrit-Point Source Branch
Dave Goodrich-NPDES Unit
Ron Linville/Winston-Salem Regional Office
Art Toompas, Cone Mills, 3101 North Elm Street, Greensboro, NC 27415
Tom Poe -Pretreatment
Central Files

NCDEHNR MEETING
OCTOBER 15, 1997
1. Thank you for meeting.
2. Who's Who - Introductions
3. What are we here about?
- August 11, 1997 Notice of Violation Letter
- August 22, 1997 Response Letter
- August 4, 1997 Biological Assessment Group Report
- June 5, 1996 NPDES NC0000876 Permit
- EMC SC WQ95-17 Special Order of Consent
- March 13, 1997 SOC Amendment Request
- April 14, 1997 SOC Amendment Request
- June 9, 1997 NPDES NC0000876 Permit Renewal Request
4. Status as relates to violations, penalties, SOC, permit.
S. Solution is connection to City sewer system, progress in
negotiations.
6. Activities - THE-BRI
- Changes in Chemicals - Toxicity Improvements
- Land Application - Permits and EWR
- Polishing Pond - Dredging
- pH Neutralization - All acid, no carbon dioxide
also larger tank.
7. EPA and State - Toxicity Strategy
S. O RAF T S LOc.
G (,6AicwAL
"I. N��Dc=S r��Kr� �T

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I of 2
THE Activities, Cone Mills White Oak WWTP
CHEMICAL TOXICITY
MANAGEMENT CHARACTERIZATION
PROGRAM
TOXICITY
SOURCE
EVALUATION
ALTERNATE
DISCHARGE
EVALUATION
1995 l - ! /
DEC Initiation (1�Ve��`�r~'�iar� �ei�'vi�c�G li ) ���i tDfao�c�ci�/av1 G1c�r'c.A�S 7S� !ids
1996 \/ / /
JAN -iC?, ` e- An az n., Lades � C&Yl ]��° .>► ,YL %�l�I�= S
�� GGGtt M �„to�P ti !r � _ /
FEB � � � � � S�u. t� A it 01 M
MAR 1st Review Qi��i J�� � MA.y `jaJf� , Ae-,
�J
APR r /6DS
))�
Source E alua on
Whole Effluent TDS TIE, Trial #1 /
MAY Whole Effluent Stress Gene Assay -� �r` Grwt'kC- "1 ' r 5 1'n e,011.Ae-�(-
Synthetic Effluent Stress Gene Assay r r c�
JUN Whole Effluent TDS TIE, Trial #2 �5 5 rrn a Whi ak/Osborne
JUL 2nd Review Synthetic Effluent TDS TIE
AUG
SEP
OCT
NOV
DEC
5 Goys �' f"vYI pia( � S
3rd Review
G 15d �oo (5 Mixed Effluent, Trial #1
Grnj /
_, �'v T [ ShvW Piri Y �� wf �wr A en v F� ei�Pi
White Oak/Osborne
f' 144 As/ So` '' 'Mixed Effluent, Trial #2
Low Caustic Production %LSS cau5�L
(December) Gll'4
re�lal C'&c'--z/ 7�S

crn
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ct CAIC

CHEMICAL TOXICITY
MANAGEMENT CHARACTERIZATION
PROGRAM
TOXICITY
SOURCE
EVALUATION
ALTERNATE
DISCHARGE
EVALUATION
2 of 2
1997 �.t t�'Yj �l a I I r / �� J�'e.�°''l c�o� ['�( 5 ow-c'--S
JAN w•%a o-� �bX�`�r C`lTr' C��" / Mtg with City of Greensboro
FEB 4th Review
MAR
APR
MAY
JUN
JUL
AUG
Me
Whole Effluent EPA Phase I TIE RAS Pore Water Toxicity
Synthetic Effluent EPA Phase I TIE Ash Pond Toxicity Cr ram^ r % i {J i -+ ��r "' tom"
Activated Carbon Effluent Treatment (rO+ `�+&/� m Glib% �t
�L1� 3
A* ✓r—
Low Caustic Production ASRIT W/ NB BYomass
(3/ 10-14/97)
Effluent Surfactant Monitoring
Effluent Surfactant Monitoring
Effluent Surfactant Monitoring RAS, Tertiary Lagoon,
Raw Waste Lagoon T&C
Characterization
SEPT 5th Review
(No Usage Criterion
for Production Process)
OCT
NOV `
DEC
c:\consult\trechron.con
Low Caustic Production
(7/28-8/3/97)
_ Lp
PAC Pilot Plant Study Tertiary Lagoon Extended HT pc jr(^"r . b� `� �ot'
e vt"agnifloc Application Evaluation-� �� �� r" �nr',I,
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1995 1996 1997
�- IC25 -:8- IC25 BFL
File = H:\OPRO\BRI\IC25CHV.CON
GRAPH: IC25BFL.CON
Figure 1. Ceriodaphnia dubia multiple concentration chronic toxicity point estimation IC25, White Oak WWTP final effluent,
January 1995 - September 1997.

15
1
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File = H:\OPRO\BRI\IC25CHV.CON
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1/12 2/8 3/29
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4/27 5/17 6/28 7/12 7/26 9/27 10/4 11/1512/13
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4/3 5/15 6/12 6/26 7/24 9/18 10/23 11/1312/11
1/3 1(29 2/19 3/5 4/23 5/14 6/11 7/9 8/6 9/10
1997
Figure 2. Ceriodaphnia dubia multiple concentration chronic toxicity test surviving adults at 74%/79%a IWC, White Oak WWTP final effluent,
January 1995 -September 1997.

Greensboro
Figure 1
Location Map
Brookvew Rd.
United Holy Church \ sR 2924
y
Guilford DOC
< a
� 4
N C+r S
Greensboro
F Osborne VNt'i P
o_
O O
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C7 �'
Gee
No
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�0
41 9
IRIX
Us70A
cLeansville
jville School
r

Figure lb.
South Buffalo Cr.-Buffalo Cr.-Reedy Fork
Location Map
y�1
1%,

Cone nischarge
11.0
10.0
9.0
8.0
7.0
6.0
E
0 5.0
4.0
3.0
2.0
1.0
0.0
0
Pi t;iire 2
DO PROFILE
North Ruffalo Creek
Summer 1994
1 2 3 4 5
STREAM MILE
—f— Jun '94 --0 Jul '94 ♦ Aug '94
6

r
Cono Discharge
8.0
7.0
6.0
5.0
rn
E 4.0
O
Cl
M
2.0
1.0
WE
N. Buffalo Discharge
J
Figure 3
DO PROFILE
North Buffalo Creek
Summer 1995
0 1 2 3 4
STREAM MILE
—M—Jun'95—+—Jul'95 •-Aug'95
1
5
I

Cone Discharge
10.0
9.0
8.0
7.0
��
rn
5.0
O
4.0
3.0
2.0
1.0
0 1 2
Figure 4
DO PROFILE
North Buffalo Creek
Summer 1996
i i 1 1
3 4 5 6
STREAM MILE
--—Jun '96 —--Jul '96 • Aug '96
7 8 9 10

7
6
5
4
rn
E
Fi;;ure 5
Dissolved Oxygen vs. Stream Mile
North Buffalo Creek
Comparison of Cone Mills
Allocation Scenarios
N. Buffalo Headwater --Cone Reduced to 5/1
—+— Cone Removed
—40-- Current Allocation
Reedy Fork Confluence
North -South Confluence
Cone Mills North Buffalo \AWTP
0 1 A
00��rOrV �� oti t.,bhPoff`1" oo,o"oa,�ti ,�ti��,�� a�`J �`Oo,�o�oti doo�,���o�
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Stream Mile

r
14
12
10
rn
0 8
0
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4
2
we]
F igure 6
BUFFALO CREEK - SUMMER 1994
1 Cone Mills Upstream
2 Summit Ave.
3 North Buffalo WWTP Influent Conduit
4 North Buffalo WWTP Sampling Pier
5 Rankin Mill Rd.
(66)
--...$........... ----------------- ....__........... .........
8 8
----------------------------
--- . ...--.. .........a----------- ...........
g..._..
0
11
®
_.....
...---t........... .._...
o
1 .3 4 D
DATA SET
Mile 0 Mile 0.5 Mile .1.5 Mile 2. Mile 5

Figure 7
ia
FNL
0
rn
E 7
v
O
0 6
5
4
3
2
BUFFALO CREEK - SUMMER 1995
1 Cone Mills Upstream
2 Summit Ave.
3 North Buffalo WWTP Influent Conduit
4 North Buffalo WWTP Sampling Pier
5 Rankin Mill Rd.
(38)
.......................................................p ......
(38)
-- a .................................... (38)....._------------
0
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... ...... 8 ..__....0S).......... ...................
... 0
0
.............................. .......................
8•-----
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.............................. b...............................
0
1 2 3 4 D
DATA SET
Mile 0 Mile 0.5 Mile 1.5 Mile 2 Mile 5

Figure 8
12
A
4
2
RUFFAI0 CREEK - SUMMER 1996
1 Cone Mills Upstream
2 Summit Ave.
3 North Buffalo WWTP Influent Conduit
4 North Buffalo WWTP Sampling Pier
5 Rankin Mill Rd.
6 McCleansville Rd.
...............................................................
(39)
0
. (3 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . _ . . . . . . . . . . . . . . . . . . . . .
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... o (34)
--•- (39) 8
8 0 ..
................$......._. $----• .._... ...
e
.. w
1 2
Mile 0 Mile 0.5
DATA SET
Mile 1.5 Mile 2
Z) V
Mile 5 Mile 10

Figure 9
Box and Whisker Plots
Box and whisker plot are useful for comparing sets of data comprised of a single
variable by the visualization of selected order statistics. After the data have been
ordered from low to high, the loth, 25th, 50th, 75th, and 90th percentiles are
calculated for plot construction. Box and whisker plots display the following
important information: 1) the interquartile range (IQR) which measures the
distribution and variability of the bulk of the data (located between the 25th and
75th percentiles), 2) the desired confidence interval (1- CL) for measuring the
statistical significance of the median (50th percentile), 3) indication of skew from
comparing the symmetry of the box above and below the median, 4) the range of
the data from the lowest to highest values, and 5) the extreme values below the
loth percentile and above the 90th percentile (depicted as dots).
L
Ra nge
....... i Q R
c 1-s C L ---Me than- 50
. <-- 2 5 ...................:
C
— 10
U0..........................................................................r
Visual comparison of confidence level notches about the medians of two or more
box plots can be used to roughly perform hypothesis testing. If the box plots
represent data from samples assumed to be independent, then overlapping notches
indicate no significant difference in the samples at a prescribed level of confidence.
Formal tests should subsequently be performed to verify preliminary conclusions
based on visual inspection of the plots.

OCT-14-1997 15:11 FROM DEHNR Kinston —Salem TO P.01
NORTH CA.ROLJ-N AA
I
DEPARTMENT OF •
ENVIRONMENT HEALTH � � ql
IN
h
&
NATURAL RESOURCES ED1HH M " t,
I i
DIVISION OF WATER QUALITY
I
WINSTON-SALEM REGIONAL OFFICE
585 Waughtown Street
Winston-Salem, N.C. 27107
Phone: [phone] Fax: [phone]
TO.f/C�
FAX NUMBER: 77 j
FROM:
l
DATE: 12 =LZZ- ' � f7 -
Number of pages (including cover page)
COMMENTS:

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DIVISION OF WATER QUALITY
October 6, 1997
MEMORANDUM
TO: Dave Goodrich
Larry Coble
FROM: Jason Doll
THROUGH: Ruth Swanek QC15
JRX9L93B�BD
POINT SOURCE BRANCH
SUBJECT: Wasteload Allocation Review for Permit Renewal
Cone Mills Discharge (NPDES #NC0000876)
Guilford County
Summary
Per your request the TMDL and Modeling Unit has reviewed the reduced limits
recommended in my December 5, 1995 memo for the 1996 NPDES permit renewal for
Cone Mills (Cone). The reduced limits were recommended as a result of instream data
and a field calibrated water quality model which indicated that the Buffalo Creek system
was over allocated in terms of the cumulative pollutant load of oxygen demanding
wastes. The recommended limits were not included in the subsequent renewal, but rather,
the permit was issued on a short-term basis with existing limits in hopes of having Cone
connected to the City of Greensboro sewer system by the expiration date of December 31,
1997. Analysis of subsequent instream data and an updated modeling analysis of Buffalo
Creek have provided further support for the stringent limits recommended in my 1995
memo (attached).
Introduction & Background
Figures 1 and I are maps of the Buffalo Creek watershed. Figure 1 is a map of
North and South Buffalo Creeks through their confluence to form Buffalo Creek. Figure
lb illustrates Buffalo Creek's confluence with Reedy Fork, which joins the Haw River at
Altamahaw. The bulk of urban area in the City of Greensboro drains to North or South
Buffalo Creek. On the east side of the City, North Buffalo Creek receives the wastewater
discharges from Cone, permitted at 1.25 MGD, and the City's North Buffalo Creek
Wastewater Treatment Plant (WWTP), permitted at 16 MGD. The distance from Cone's
discharge to the Haw River is approximately 25 stream miles and is a portion of stream
for which the aforementioned model was developed. The modeled area also includes the
portion of South Buffalo Creek affected by the City's T.Z. Osborne WWTP, which is
permitted to discharge 20 MGD of wastewater to South Buffalo Creek about 4.5 miles
upstream of the confluence with North Buffalo Creek, but the facility is currently
undergoing expansion to 30 MGD. The following table summarizes the average flow
(Qavg) and 7 day, 10 year low flow (7Q10) statistics for the streams in question:

Stream
Site
Dr. Area
av
70�10_
(sq. mi.)
(feet /sec)
(feet /sec)
North Buffalo Creek
Cone Mills discharge
14.7
13.2
0.5
North Buffalo Creek
North Buffalo WWTP discharge
22
25
0.9
South Buffalo Creek
T.Z. Osborne WWTP discharge
41.8
46
2.1
Buffalo Creek
Confluence of North & South
92
102
4.7
Oxygen Consuming Wastes
Upon the pending renewal, the NPDES permit for Cone Mills should contain the
following limits for oxygen -demanding wastes:
Summer Winter
Monthly Avg. Daily Max. Monthly Avg. Daily Max.
BOD5 (mg/1): 5 10 10 20
NH3N (mg/1): 1 2 2 4
The required decrease in pollutant loading is based on documented water quality
problems in North Buffalo Creek. Evaluation of instream self -monitoring data from
Cone Mills and the Greensboro - N. Buffalo Creek WWTP has shown frequent and
ongoing violations of the 5.0 mg/l water quality standard for instream dissolved oxygen
(DO), with reported DO levels occasionally less than 2.0 mg/1, which indicates the
severity of the over allocation.
I have attached graphs (Figures 2-4) depicting the monthly average instream
dissolved oxygen levels for summer months from 1994-1996 from Cone's and
Greensboro's monitoring data. The resulting DO profiles show that the most severe DO
sag in the stream is consistently located immediately below Cone's discharge.
Furthermore, the instream DO profile depicted by the self -monitoring data closely
resembles the DO profile predicted by the QUAL2E model (Figure 5) developed for
Buffalo Creek as part of the Cape Fear Basinwide Management Plan (refer to separate
report). The QUAL2E DO profile also indicates that the most severe sag is immediately
below Cone, and recent iterations of the model have shown that a substantial benefit, in
terms of predicted instream DO levels, can be obtained through the recommended
reduction in Cone's discharge load. The largest benefit would be obtained through
removal of Cone's discharge from the over -allocated receiving stream (refer to Figure 5).
Whole Effluent Toxicity
It is our understanding that the chief obstacle to connection to the Greensboro system
is Cone's effluent toxicity. Cone's current NPDES whole effluent toxicity (WET) test
limit is a quarterly chronic, pass/fail at a test concentration of 79% using Ceriodaphnia as
the test organism. Under their current SOC, which addresses toxicity, the facility does
monthly full range chronic toxicity testing. Since June 1994, Cone has conducted 39
WET tests, and with the exception of one conducted February of this year, the tests have
never resulted in a chronic value greater than 50%. Recent communications from our
Aquatic Toxicology Unit (ATU) have indicated that Cone's TIE/TRE progress reports
have consistently referred to dissolved solids (TDS) and surfactants as primary causes of
effluent toxicity. The ATU's comments characterize Cone's efforts to address TDS and
other causative agents of toxicity at the source as unsubstantive. I have attached the ATU
comments on Cone's most recent progress report for your review.

Individual Toxicants
,NA A Reasonable Potential Analysis (RPA) was performed on the most recent available
22 months of effluent data for individual toxicants in order to determine the likelihood of
a� a violation of water quality standards during critical low flow (7Q 10) periods for any
parameter. The toxicant analysis indicated that, with the exception of arsenic and
chlorides, all toxicant limits and monitoring should remain unchanged in Cone's NPDES
\ �the
ermitThe RPA indicated that the predicted maximum level of arsenic was well below
n wable load, and that the current arsenic limit should be dropped in favor of
ly monitoring. It is recommended that the effluent monitoring frequency for
14 chlorides be increased from quarterly to monthly because predicted effluent chloride
levels approach the allowable load and because this parameter is a suspected contributor
to effluent toxicity. It should also be noted that the required quarterly monitoring for
chlorides appears to be somewhat sporadically performed by the permittee. I have also
attached the table summarizing the results of the individual toxicant RPA as Figure 6.
Thank you for the opportunity to provide input into the wasteload allocation process
j r Z for the Cone Mills NPDES permit. Please let me know if you need any further
information or assistance in this matter.
.tr2'
cc: Central Files
Steve Tedder
Steve Mauney - Winston-Salem Regional Office
Matt Mathews - Aquatic Toxicology Unit

Figure 1
Location Map
United Holy Church`
ce0� e�ti
a�O 0-
J°fir Guilford DOC
y Dump
ENEW...
Greensboro
i
o �
L �
Scale In Miles
Quarterstone Farm
Brookview Rd.
SR 2824
F
>y Greensboro
Osborne WWTP —
o
yi
U
m o
C7 �
Cn
Z
G�0
O
�s
�o
US70A
cl-eansville
M e ville School
I

Figure 1 b.
South Buffalo Cr.-Buffalo Cr.-Reedy Fork
Location Map

Cone Discharge
11.0
10.0
9.0
8.0
7.0
6.0
E
0 5.0
4.0
3.0
2.0
1.0
0.0
0 1
2
Figure 2
DO PROFILE
North Buffalo Creek
Summer 1994
3
STREAM MILE
fJun'94 --o—Jul'94 �Aug'94
4
5
F

Cone Discharge
8.0 /
7.0
6.0
5.0
a�
E 4.0
O
3.0
2.0
1.0
0.0
N. Buffalo Discharge
Figure 3
DO PROFILE
North Buffalo Creek
Summer 1995
0 1 2 3 4 5
STREAM MILE
F—F Jun '95 --O-- Jul '95 • - Aug '95
N.

Cone Discharge
10.0
9.0
8.0
7.0
6.0
5.0
O
4.0
3.0
2.0
1.0
0.0
0
Figure 4
DO PROFILE
North Buffalo Creek
Summer 1996
1 2 3 4 5 6 7 8 9
STREAM MILE
—FJun'96 --*--Jul'96—*—Aug'96
10

Figure 5
Dissolved Oxygen vs. Stream Mile
North Buffalo Creek
Comparison of Cone Mills
Allocation Scenarios
7
N. Buffalo Headwater +Cone Reduced to 5/1
—+— Cone Removed
6 - - - - - Current Allocation -
Reedy Fork Confluence
5 - - - - - -
North -South Confluence
4 --
rn
E
O
0 3 -
2
/Cone Mills North Buffalo VVVVTP
0
i
t �' hro �tK ,`rL % �b �� O� ��, ^� �cb �ro fk�` fir, ,, �� ,`b �R ��, rL5 �cb fro ti� ��, tip` �-Z
Stream Mile

1: i;ure 6
TOXICANT ANALYSIS
Facility Name
Cone Mills
NPDES #
NC0000876
Ow WD
1.25
7Q 10s cfs
0.5
lWC a
79.49
'ecVin_q Stream
N. Buffalo Creek
Stream Class
C-NSW
FINAL RESULTS
Chromium
Max. Pred Cw
57
Max. Obs Cw
30
Allowable Cw
62.9
Arsenic
Max. Pred Cw
27.2
Max. Obs Cw
16
Allowable Cw
62.9
Lead
Max. Pred Cw
35
Max. Obs Cw
14
Allowable Cw
31.5
Nickel
Max. Pred Cw
32.5
Max. Obs Cw
13
Allowable Cw
110.7
Chloride
Max. Pred Cw
235.62
Max. Obs Cw
138.6
Allowable Cw
289.4
Fluoride
Max. Obs Cw
2.6
Allowable Cw
2.3
Zinc
Max. Obs Cw
77
Allowable Cw
62.9
Copper
Max. Obs Cw
14
Allowable Cw
8.8

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O(OON 000
Page 1
Note for Jason Doll
From: Kevin Bowden
Date: Mon, Sep 15, 1997 6:56 AM
Subject: Cone Mills
To: Jason Doll
F i i e ( s): Cone Chron. 6/97; Cone Mills 9708
Jason, attached are two files: the latest chronology we have put together on Cone Mills and a
copy of our 9708 progress report review comments. I hope it will help. You may want to
obtain a copy of Ron Linville's SOC amendment staff report which accompanied the
facility's most recent request for and extension under the SOC. If you like, I Can fax to you.
Please let me know.
The bottom line is that Cone has a long-term history of toxicity noncompliance and has been
slow to address toxicity reduction efforts. Cone has placed a majority of emphasis on
connection to Greesboro which' we support; however, we made it clear to Cone during our
initial discussions that solving its toxicity probelm in N. Buffalo Creek and connection to
Greensboro represent independent issues. Ron Linville has a good perspective on
questionable instream data which Cone has submitted. This office does not support an SOC
amendment extension.

DIVISION OF WATER QUALITY
June 24, 1997
MEMORANDUM
To: Ron Linville
Thru: Larry Ausley
Matt Matthews
From: Kevin Bowden
Per your request, please find below a summary of information which has been prepared to assist
you and DWQ staff in evaluating Cone's THE progress. At this time, we feel that a complete chronology
of all correspondence relating to Cone's THE progress is not warranted. However, we have provided
pertinent information on Cone's/DWQ's actions to address toxicity noncompliance. We hope this
information is helpful in supporting our position that Cone has had sufficient time to solve their effluent
toxicity problem. We have also provided you with a complete copy of all our quarterly THE review
comments.
• 1/6/94 Larry Ausley and PPP representatives met with Cone and conducted a
collaborative site visit. Cone representatives were aware that TDS most likely was the primary
cause of effluent toxicity. pH adjustment was discussed along with future options for toxicity
reduction. It was noted during this meeting and at subsequent meetings that Cone switched
from using sulfuric acid to CO2 for neutralization during late 1993 and that effluent toxicity
was significantly reduced.
• 6/17/94 Assessment of $140,847.00 civil penalty by the Director. Of this total, $5,850.00
was assessed for failure to meet the 90% chronic toxicity limit specified by the NPDES Permit
from March 1993 - December 1993 (9 of 9 toxicity failures). The majority of the CPA was
for violating the permit reporting requirements for BOD ($126,100.00). There were concerns
raised concerning dissolved oxygen values in the receiving stream and whether these values
were accurate.
• 7/23/95 NOV from WSRO to Toompas concerning CSI conducted on July 10 and 11,
1995. The equalization basin appeared to be full of solids and the secondary clarifiers
appeared to be short circuiting. During this inspection Cone representatives acknowledged
that polymers and alkalinity were suspect causes for toxicity. Biocides were also entering the
WWTP. Letter confirms receipt of Cone's SOC application.
• 8/30/95 Meeting at Cone with WSRO staff and ASTU staff. Cone acknowledged the TDS
issue and mentioned that they switched back to sulfuric acid after speaking with another textile
manufacturer who was experiencing similar problems with pH adjustment using CO2. Cone
mentioned that it was unable to lower the pH below 8.3 s.u. when using CO2. It was noted
that Cone had done very little to investigate chemical usage. We suggested that Cone
investigate polymer usage, evaluate WWTP efficiency, conduct effluent
characterization/identification testing, evaluate biocide usage, keep a log of WWTP process
modifications, and make toxicity source reduction a priority.
• 10/3/95 Memo from Jason Doll to WSRO transmitting comments concerning Cone's
instream self -monitoring data. The letter requests that a member of the WSRO staff
accompany Cone during an instream monitoring run. DO saturation values of 134% reported
by Cone for a "low flow piedmont stream during the dead of summer" were questionable.
While the City of Greensboro recorded 16 of 38 values less than 5.0 mg/l in North Buffalo
Creek for the period July to August, 1995, Cone did not report any DO values less than 6.0
mg/l.
• 10/13/95 Meeting at WQ lab with ASTU staff, Cone representatives, and staff from WSRO
concerning THE proposals. Cone indicated their decision to hire BRI to conduct THE work.

Page 2
Cone Mills
June 24, 1997
• 12/6/95 Meeting at Cone to discuss THE direction. Cone emphasized their intent to
become a Pretreatment Facility and to solve their toxicity problem, neither of which has
occurred to date. The Ash Pond discharge was also discussed.
• 3/22/96 Memo from ASTU to WSRO providing comments on facility's initial. THE
progress report dated 9602. The report indicated that the primary toxicant is TDS. Our
comments mentioned that Cone should undertake actions to decrease MLSS concentrations.
ASTU comments mentioned that TDS is an issue which was previously discussed.
• 5/30/96 Memo from ASTU to WSRO providing comments on facility's 9605 progress
report. It was noted that the facility was having difficulty in maintaining solids control in the
aeration basin, decreased polymer dosage rates, and repaired a chlorine leak. Cone indicated
their willingness to evaluate a caustic recovery system.
• 7/18/96 Meeting at Cone with ASTU staff, WSRO staff, City of Greensboro
representatives, and BRI. At this meeting, City representatives mentioned a recent law suit
filed by the American Canoe Association against several municipalities in the state including
Greensboro. Cone mentioned that they will not use CO2 since it is not effective in reducing
pH to acceptable levels. 20% Cone/80% Osborne mix resulted in IC25 values of >89% and
P/F test run at 15% Cone/85% Osborne was "Pass."
• 9/4/96 Memo from ASTU to WSRO providing comments on facility's 9608 progress
report. Notable Date Log entries included the removal during 6/14-6/21 of 1,000,000 gallons
of residuals from the system with an additional 250,000 gallons being removed on 7/25-7/31.
Conclusions from TDS characterization studies suggest the dominant toxicant is TDS
(primarily sodium and sulfate).
• 12/10/96 Memo from ASTU to WSRO providing comments on facility's 9611 progress
report. Our comments indicate that we view Cone's connection to Greensboro and Cone's
proposed discharge alternatives as representing independent issues with respect to the City's
discharge status.
• 1/15/97 Letter from the City of Greensboro to Cone indicating the City's requirements for
Cone to connect.
• 3/14/97 Memo from ASTU to WSRO providing comments on facility's 9702 progress
report. A reduction in the use of dry and wet polymers was noted. Almost 40,000-50,000
gallons of residuals were wasted during December 1996. The report notes that Cone
continues to evaluate a replacement polymer for Magnifloc 577C, a polymer previously
scrutinized and found to have a "High Impact" via AQUATOXTM. Phase I TIE testing suggest
that pH 10 adjustment, solid phase extraction at pHi and pH 10, and EDTA chelation at 3.0
mg/1 treatments were "most effective in reducing effluent toxicity." Reductions in toxicity
during the report period were attributed to shutdown of the high caustic production processes.
Results of additional TIE testing suggest that additional refractory toxicants are present in the
effluent.
• 3/26/97 Ltr from ASTU to Tedder indicating that THE activities, (those which have been
conducted and proposed) are occurring late in the THE process.
• 6/9/97 Memo from ASTU to WSRO providing comments on facility's 9705 progress
report. The report mentions that Cone is investigating a potential polymer replacement for
Magnifloc 577C. Toxicity source monitoring suggests that the discharge from the Ash Pond
is acutely toxic with a measured 48-h LC50 of 14% and an IC25 value of 2.5%. Our
comments indicate that investigations of the Ash Pond discharge and polymer toxicity should
already have occurred.

DIVISION OF WATER QUALITY
March 26, 1997
MEMORANDUM
To: Steve Tedder
Through: Jimmie Overto
Larry Ausley
Matt Matthews m
From: Kevin Bowden h-6
Subject: SOC Extension Request
Cone Mills Corporation
SOC EMC WQ No. 95-17
NPDES Permit No. NC0000876
Guilford County
In a letter to the Director dated March 13, 1997, Mr. Art Toompas with Cone Mills requested an
extension of time under the subject SOC to "establish a new termination date concurrent with date the City
can accept our effluent." The letter mentions that Cone has "worked diligently to identify the source of
toxicity during the time frame of the existing SOC" and is "still experiencing some difficulties that we are
committed to solving."
Cone Mills Corporation signed the subject SOC on October 18, 1995. The SOC was
subsequently signed by the Director on January 29, 1996, contains an achieve compliance date of May
31, 1997, contains an expiration date of August 31, 1997, and provides conditional compliance for one
final effluent parameter, chronic toxicity.
The THE activities which have been conducted and the activities which are being proposed (ie,
Phase I TIE testing, surfactant analysis, chemical product optimization, bench scale treatability evaluation,
acute impact assessment) all represent actions that are occurring late in the THE process. Representatives
from this office and the Office of Waste Reduction conducted a site visit in January 1994. It was noted
then that TDS or some component of the effluent directly proportional to TDS was responsible for a
significant amount of toxicity observed in the effluent and that sulfate appeared to be the major ion of
concern. It was suggested that Cone evaluate the potential toxicity of two compounds which contained
alkylphenols. Cone's use of polymers and flocculating agents was also discussed as was its use of
biocidal compounds and cooling tower/airwash treatment chemicals. Since this initial site visit with
Office of Waste Reduction personnel, several additional meetings and site visits with Cone officials have
occurred to discuss THE activities and progress. The work proposed in this extension request should
have been initiated earlier in 1994 when proposed by our staff. This has been highlighted to Cone in
correspondence since that time dated 3 October 1995, 22 March 1996, 4 September 1996, 10 December
1996, and 14 March 1997.
Cone's latest THE Progress Report indicates that total dissolved solids has been identified as the
primary effluent toxicant; however, it does not account for all toxicity present in Cone Mills' discharge.
The Company admits that it has experienced problems with biosolids removal and has been "active in
expanding our permit WQ0003760 for land application of biosolids." Recent TIE testing results suggest
the following treatments to be effective in reducing effluent toxicity: pH10 adjustment, solid phase
extraction at pHi and pH9, and EDTA chelation at 3.0 mg/l treatment. Non -polar organics and cationic
metals may also be contributing to effluent toxicity.
Cone Mills has communicated its intent to become an industrial user and discharge to the City of
Greensboro. Likewise, the City of Greensboro has identified several criteria which have to be met by the
Company prior to accepting Cone Mills' wastestream, one of which is completion of expansion at the
T.Z. Osborne WWTP (projected completion date - October 2, 1998). Data we have reviewed from two
previous mixed effluent toxicity evaluations conducted at a 20/80 (Cone/Osborne) effluent concentration
suggests that effluent from Cone will not have an acute or chronic toxic impact on Osborne's discharge to
the receiving stream. We have clearly stated our past and present position that acceptance of Cone Mills'

Page 2
Cone Mills
March 26, 1997
wastestream by the City of Greensboro and the Company's chosen alternative(s) to achieve compliance
with the current 79% chronic toxicity permit limitation are independent issues. At present it appears
unlikely that Cone will be able to achieve the timetable established by Greensboro for connection to the
City while still under the current SOC.
Based on the long-term history of toxicity noncompliance at Cone and their failure to actively
pursue recommendations made by the office, we do not support any amendment to the SOC which would
extend the date to achieve compliance with final limits past May 31, 1997.
If you should you have any questions or need additional information concerning this issue, please
contact me at 3-2136
cc: Steve Mauney/Winston-Salem Regional Office
Kent Wiggins
Dennis Ramsey
Tom Poe -Pretreatment
Central Files

Clils-t-D.-tvNE
March 13, 1997
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
ARTICLE NUMBER �33�
Mr. A. Preston Howard, Jr., P. E., Director
State of North Carolina Department of
Environment, Health and Natural Resources
Division of Water Quality
P. 0. Box 29535
Raleigh, NC 27626-0535
Subject: Special Order by Consent
EMC SOC WQ 95-17
NPDES Permit NC0000876
Cone Mills Corporation
Guilford County
Dear Mr. Howard:
RECEIVEG
MAR 14 1997
ENVIRON&1ENT4L SCIENCES
We are writing to request that our Special Order by Consent
(SOC) EMC SC WQ 95-17 be amended to allow for an extension of
time. Significant progress has been made since the initiation of
the Toxicity Reduction Evaluation (TRE) in December 1995. The
ongoing activities of monthly effluent toxicity monitoring,
recording of Waste Water Treatment Plant (WWTP) operations, and
review of chemical usage have provided valuable insight into the
source/cause of toxicity. Progress has also been realized in the
areas of toxicant identification and source evaluation, toxicity
source reduction, and impact assessment of discharge delivery to
the City of Greensboro's Osborne wastewater treatment facility.
The quarterly THE Progress Report dated February 13, 1997 issued
last month summarizes these efforts.
We are enclosing a December 27, 1996 letter from Burlington
Research, Inc. (BRI) indicating that the White Oak pretreated
effluent is not expected to adversely impact the Osborne
treatment system.
CONE 'TILLS CORPORATION
P.Q. BOY 26540 3tor NORTH ELM STREET GREENS80R0, NC 21415-6540
FAX: [phone]

The City of Greensboro has issued the enclosed January 15,
1997 letter that outlines its requirements for our connection to
their municipal sewer system. We have met with the City and have
agreed to meet their requirements to become a pretreatment
facility. The City expects completion of the 10 million gallon
per day expansion of the Osborne treatment plant in October 1998.
The City also plans to enter into a SOC which contains a
provision prohibiting the acceptance of any major industrial
discharges for 6 months following completion of the expansion.
Given these factors, we respectfully request that our SOC be
amended to establish a new termination date concurrent with the
date the City can accept our effluent. While we have diligently
worked to identify the source of toxicity during the time frame
of the existing SOC, we are still experiencing some difficulties
that we are commited to solving.
A study was recently made for a six week period during which
we did not run any of our styles requiring heavy caustic. This
test, deemed to be twice as effective in reducing TDS levels as
caustic recovery, did not yield results that met our 79% goal.
We also have had difficulty with biosolids removal and have
been active in expanding our permit WQ0003760 for land
application of biosolids. With the presently requested land for
biosolids application, we should have the ability to maintain
optimum levels of mixed liquor suspended solids. This process
also helps to reduce polymer demand which reduces toxicity caused
by high levels of polymer. Land application has already begun
this year and is helping to reduce our biosolids backlog.
During the proposed extension to the SOC all plans to gain
the City's approval for discharge including construction of
transfer facilities, testing for impacts, modifications to the
White Oak treatment facilities and other requirements stated in
the City of Greensboro's letter of January 15, 1997 would be
completed.
Additionally, while key areas of the THE have been addressed
to date, there are additional activities that are currently
underway and being planned for the future. These activities,
some of which are contingent upon completion of construction of
the expanded Osborne facility, include but are not limited to the
following:
(2)

1. Toxicity Identification EPA Phase I Procedures
To identify agents of toxicity not attributable to TDS
(Total Dissolved Solids), EPA Phase I Toxicant Identification
Evaluation (TIE) procedures were applied to a White Oak composite
effluent collected January 27-28, 1997. In conjunction with the
procedure, a mock effluent prepared to simulate the ion content,
hardness, and alkalinity of the January 27-28 composite effluent
was fractionated. Results of both studies will facilitate
identification of additional refractory toxicants. Pending
results of the tests, additional trials may be conducted.
2. Surfactant Analvses
Preliminary results of the January 28 fractionation indicate
that surfactants may be contributing to effluent toxicity. To
better understand surfactant components, analytical procedures
are being conducted on the effluent, WWTP activated sludge, and
WWTP foam. Additional work will be scheduled pending data
review.
3. Chemical Product Optimization
Identification and evaluation of production process
chemicals containing 5% or more surfactant is currently underway.
4. Bench Scale Treatability Evaluation
It has been demonstrated that the White Oak discharge does
not contribute toxicity to Osborne effluent at concentrations as
high as 20%. To address the City's concern regarding any impact
White Oak discharge may have as a component of the influent waste
stream to the Osborne treatment facility, a bench scale
treatability study is planned. Per the City's request,
definitive evaluations must be conducted with activated sludge
from the new expanded Osborne facility.
5. Acute Impact Assessment
To gauge any impact White Oak discharge has on the viability
of nitrifying bacteria, biomass acute inhibition studies will be
conducted (Test OECD209, Activated Sludge Respiration Inhibition
Test). The initial evaluation will be conducted with nitrifier
(3)

activated sludge from the City of Greensboro's North Buffalo
wastewater treatment facility. This work is scheduled to begin
soon. Repeat trials will be conducted with nitrifier activated
sludge obtained from the expanded Osborne facility. This work
will be done after the on-line status of the single stage
nitrification system is completed at the Osborne facility, which
is currently projected for October 1997.
The studies and other evaluations will continue until we
consistently meet our goal of 79% or become connected to the City
of Greensboro municipal sewer system. In any event the
connection to the City system is the ultimate goal, and we are
anxious for the process to be complete. We are available to meet
with you at your convenience to discuss the status of our THE and
our plans to become an indirect discharger with extensive
pretreatment.
Sincerely,
Arthur J. Toompas
Corporate Environmental Manager
cc: Mr. Paul Braxton Mr. Neil Koonce
Mr. Mather Whitehead lbs. Lindy Bode Aucoin
Mr. Larry Coble ✓Mr. Larry Ausley
(4)

El..,
BURLINGTON
RESEARCH
December 27, 1996
Mr. Arthur Toompas
Cone Mills Corporation
3101 North Elm Street
Greensboro, NC 27415-6540
Re: Summary of THE Activities
Dear Arthur:
Aquatic Bioassay Testing
Aquatic Toxicity Reduction Evaluations
Chemical Product Environment Assessments
NPDES Testing
Reporting & Data Handling Services
In response to your request, I have prepared the following summary of Cone Mills THE activities
since the beginning of the program in December 1995:
ON -GOING
Monthly THE Dare Log
Provides date -specific documentation of production activities and WWTP operations
that may identify cause/effect relationship with effluent toxicity.
Chemical Usage Review
Focus is on review of chemicals that contribute to waste loading at WWTP. Aquatic
toxicitv and biodegradability data is requested for products that may be a source of
effluent refractory toxicity. Recommendations to replace/minimize usage of products
with more environmentally "friendly" alternatives are made as appropriate. The initial
review of Cone Mills chemical usage is close to completion. This activity is
considered on -going in that usage information is reviewed whenever new products are
introduced. Upon completion of the intial review, a formal review will be carried out
on a semi-annual basis.
Monthly WWTP Effluent Toxicity Monitoring
Conducted to gauge short and long-term fluctuations in effluent toxicity and
correlation with changes in production activities, chemical usage, WWTP operations,
and/or calendar season/weather.
1302 Belmont Street - Burlington, NC 27215-6935 - Tel. [phone] - Fax [phone]
I

Mr. Arthur Toompas
December 27, 1996
Page 2
Conductivity Source Evaluation
In April, caustic and sufuric acid usage, WWTP effluient flow, and conductivity data
for the months of January, February, and March were reviewed. Information indicated
that a reductions in caustic discharge with concurrent redutions in sulfuric acid can
provide proportional reductions in the generation of sodium sulfate and associated
conductivity.
White Oak W ITP/Osbourne POTW Mixed Effluent Toxicity Evaluation
An objective of the THE is to determine whether White Oak discharge contributes to
the toxicity of effluent from the City of Greensboro's Osbourne treatment plant. To
that end, focus has been directed towards measuring the toxicity of proportioned
mixes of final effluent from both facilities, including baseline toxicity testing of
individual whole effluents. Currently White Oak discharge is being evaluated at both
15% and 20% concentrations. To date, two studies have been conducted with facility
effluents collected the weeks of June 10 and September 16. Toxicity test results in
both trials indicate that White Oak WWTP effluent does not contribute chronic or
acute toxicity to Osbourne POTW effluent when mixed at 15% or 20% proportions.
Toxicity Characterization Procedures
TDS (Total Dissolved Solids)
The contribution of total dissolved solids (TDS) to White Oak effluent toxicity has
evaluated by two characterization methods, both of which involve the preparation of
a synthetic effluent formulated to closely simulate the major ion (i.e. salt) content of
White Oak discharge. The first procedure involves toxicity testing of mixed
proportions of synthetic and whole effluent; a trial was conducted with effluent
collected April 29-30, and another trial with effluent collected June 13-14. A single
trial of the second procedure, involving toxicity testing of a synthetic effluent only,
was initiated July 11. Study results have confirmed TDS, in particular sulfate and
sodium ions, as the primary agent of toxicity in White Oak final effluent.

Mr. Arthur Toompas
December 27, 1996
Page 3
Stress Gene Assav
An aliquot of effluent collected April 30 - May 1 was submitted to Xenometrix, Inc.
for assay by Pro-Tox, an assay which facilitates examination of the genotoxicity and
cytotoxicity of a chemical compound as well as an indication of the compounds mode
of action. The assay did not identify significant impact for any particular chemical
though there were marginal responses characteristic of surfactants and surfactant
metabolites.
PROPOSED
TDS Source Reduction (Currently underway.)
Investigation of effluent TDS/conductivity reduction resulting from reduction in high -
caustic processes was initiated the week of November 25 and is expected to continue
through January 3. WWTP effluent toxicity, conductivity, and ion analyses are being
conducted.
Bench -scale Trearability Evaluation
It has been demonstrated that White Oak discharge does not contribute toxicity to
Osboume effluent at concentrations as high as 20%. To gauge any impact White Oak
discharge may have as a component of the influent wastestrearn to the Osboume treatment
facility, a bench -scale treatability study is suggested. The evaluation will include design
features of the new Osbourne facility currently under construction. Execution of the study
is pending communication of criteria by the City of Greensboro.
White Oak WWTP/Osbourne POTW Mixed Effluent Toxicity Evaluation
Repeat trials are suggested pending clarification of criteria established by the City of
Greensboro.
In summary, chemical and biological studies clearly indicate that total dissolved solids,
ZP
specifically sodium and sulfate ions, are the primary source of the toxicity present in White Oak
effluent. It is apparent, also, that the elevated level of salts in White Oak effluent does not
contribute to the toxicity of Osboume effluent; and it is expected that this elevated concentration
will not adversely impact the Osboume treatment system.

Mr. Arthur Toompas
December 27, 1996
Page 4
I trust that this summary provides the necessary elaboration on THE activities but please let me
know if additional detail is needed.
Sincerely,
13-URLINGTON RESEARCH, INC.
Richard A. Diehl
Executive Vice President
Vice President, Toxicological & Biological Services
Copy: Allan Williams, City of Greensboro

CITY OF GREENSBORO
�. 'NORTH CAROLIN'A
CI
Paul Braxton
Vice President - Engineering
Cone Mills Corporation
3101 North Elm Street
P.O. Box 26540
Greensboro, NC 27415-6540
Dear Paul;
UTILITIES DEPARTMENT
P.O. BOX 3136
GREENSBORO, NC 27402-3136
TELEPHONE: [phone]
FAX NO: [phone]
January 15, 1997
Martie Groome and I appreciated the opportunity to meet with you, Arthur Toompas,
Mather Whitehead, and Rick Diehl of Burlington Research last week. We fully
understand the difficult position that Cone Mills is in with their current SOC and the
difficulty you have in achieving limits that would allow you to discharge to the City of
Greensboro's wastewater system. We also appreciate that you do understand the similar
compliance issues we face if your effluent is accepted for treatment by the City. Current
compliance issues that the City faces force us into a position of requiring as close to "fail
safe" requirements as is practical. For us to do less places the overall City operation at
tremendous risk.
We agree with Burlington Research that salinity or total dissolved solids (TDS) appears to
be the primary cause of your effluent toxicity. However, the data indicate that there is
clearly another toxicant or group of toxicants that is causing failures that cannot be
explained by total dissolved solids alone. Until such time as all such causes are
determined, our ability to fully assess the impact of Cone effluent on our treatment plant is
clouded considerably. We therefore encourage you to continue your Toxicity Reduction
Evaluation to more fully characterize and eliminate those compounds. Also, as we
discussed, it would appear that process changes or additions (such as caustic recovery)
would have to be implemented to reduce toxicity to acceptable levels.
One of the advantages of better toxicity characterization (and more specifically elimination
of toxicants other than TDS) is that once consistent data is developed linking TDS with
toxicity, TDS could be used as a substitute for monitoring Cone's discharge to the City in
the event that is permitted. At this point, with unknowns causing high variations, there is
no substitute for continuous monitoring of toxicity other that bioassay with its attendant
expense.
�n

We understand your desire for firm goals for you to achieve that would allow your
discharge to the City system. In the past we have not quantified toxicity for this purpose
other than require its elimination. Assuming you can better characterize the unknown
toxicant(s) and reduce the TDS that appears to be the primary factor (and no doubt this
will have to be done to achieve the following), the following are conditions that the City of
Greensboro will require for connection to our system:
1. The discharge from Cone Mills will have to be made to the transfer pumping station at
the North Buffalo Treatment Plant. The plant has no capacity available and there are
no plans to expand it nor is there room to do so on the site. In fact, the State may even
consider reducing its capacity at the time of permit renewal. Furthermore, the influent
at this plant is less "industrial" than at T. Z. Osborne and the City does not wish to add
high TDS to this plant should any type of reuse ever be considered from the plant.
Cone Mills would of course have to construct whatever facilities would be required to
this point and may be required to modify the pumps at this station in order to provide
sufficient capacity.
2. The transfer system (from North Buffalo to T.Z. Osborne) is incapable of handling any
additional flows during wet weather. For that reason, Cone Mills will need to provide
the capability of holding up to 10 days of discharge. As we have discussed, this should
be no problem with some modification to the current polishing ponds. Systems would
have to be installed to allow monitoring of discharged flows by the City at the
treatment plant. -
3. Discharge to the City must await completion of the expansion of the T. Z. Osborne
Wastewater Treatment Plant. This is currently scheduled for October 2, 1998 but
weather delays could play significantly in actual completion time (the contractor has
already been granted 14 days for this reason). Any agreement would be contingent on
the completion, startup, and satisfactory operation of the plant.
4. Cone Mills must continue their Toxicity Reduction Evaluation, identifying all factors ---- -
affecting toxicity. We understand your desire for a target toxicity, and have been
reluctant to offer one until all factors have been identified. As we discussed, we will
require a minimum passing toxicity concentration of 20%; that is, a test sample of 20%
Cone Mills effluent must pass. Cone Mills must demonstrate consistent compliance
with this requirement. In an attempt to define that, we would consider six months of
no toxicity shown at 20% to be compliant. Periods longer than that could exhibit a
single failure at 20% as long as it passed at 10% concentration. In order to achieve
this kind of consistency, we feel that Cone Mills will have to be fully knowledgeable of
the factors that cause the toxicity and be able to control those factors. The end result
is that we would expect to see a control strategy that Cone Mills would be using to
control toxicity in order to meet this requirement. During the time that compliance
was demonstrated, Greensboro personnel would participate in the strategy
development and testing so as to better understand factors that might affect the City's
treatment plant.

5. Cone Mills would of course be required to continue operation of their existing
treatment processes, including but not limited to color removal.
6. The requirement of passing toxicity is made in light of the City's concern of being able
to pass its own effluent toxicity requirements, which are even more stringent than
Cone Mills current limit. This is a concern of the ability of toxicants to pass through
the City processes, just as they currently do the Cone Mills process. Furthermore, we
are concerned about the effect of the Cone Mills toxicants upon the City's biological
processes. The City operates nitrification activated sludge, currently two -stage at the
T. Z. Osborne Plant. It will be converted to single stage as a part of the construction,
hence any testing of the effects of Cone Mills effluent on these highly sensitive cultures
cannot take place until the construction of the plant is complete. While Cone Mills
may wish to test the effects of their effluent on pilot scale tests conducted with the
North Buffalo single stage nitrification cultures, the observance of no effect would not
be considered by the City to demonstrate no effect on T. Z. Osborne plant. Such tests
may, however, give a level of comfort to Cone Mills that when T. Z. Osborne is
running with single stage, tests would be more likely to give satisfactory results. This
may give Cone Mills more confidence and allow them to demonstrate more likely
connection to the City when dealing with regulatory agencies. However, the City
would require pilot testing by independent laboratory consultants of the Cone Mills
effluent using T. Z. Osborne single stage nitrification cultures before the effluent
would be allowed to be discharged to the plant. At this time we are not prepared to_;
describe in detail what those tests would entail, but they would clearly have to
demonstrate no observable deleterious effect on the process. -
7. A new Significant Industrial User Permit application would be required and subject to
the approval of the State of North Carolina. Negotiations concerning local pollutant
allocations and permit limits will also be conducted between the City Industrial Waste
Section and Cone Mills prior to issuance of a draft permit.
It should be noted that all of these requirements are predicated on our current NPDES
permit. Should the State of EPA substantially modify our permit, it could require
adjustment of Cone Mills discharge conditions just as it could any of our current Industrial
Users.
3

Again, we encourage your pursuit of identification of all factors affecting toxicity in your
effluent as well as means to reduce the TDS levels so that the 20% requirement can be
met. We look forward to continuing our discussions so as to assist Cone Mills in solving
this difficult problem. Cone Mills is one of Greensboro's most outstanding corporate
citizens. We greatly appreciate your presence in our community and will everything we
can to assist you to remain one of our leading businesses.
Sincerely,
-4� f
Allan E. Williams
Director of Utilities
cc: Arthur Toompas, Cone Mills
Ed Kitchen, City Manager
Arthur White, Chief; Wastewater
Martie Groome, Industrial Waste Manager
4

cc: Permits and Engineering
Technical Support Branch
County Health Dept.
Central Files
WSRO
SOC PRIORITY PROJECT: Yes X No
If Yes, SOC No. 95-17
To: Permits and Engineering Unit
Water Quality Section
Attention: Jeffrey T. Myhra (Review Engineer)
Date: 970717
NPDES STAFF REPORT AND RECOMMENDATION
County Guilford
Permit No. NC 0000876
PART I - GENERAL INFORMATION
1. Facility and Address: Arthur J. Toompas
Cone Mills Corporation
3101 North Elm St.
Greensboro, NC 27415-6540
2. Date of Investigation: 961021
3. Report Prepared by: Ron Linville
4. Persons Contacted and Telephone Number:
Arthur Toompas and John Hodges of Cone Mills @ 910/379-6226.
5. Directions to Site: Go Hwy 29N from I-40/85, exit and turn
left on 16th St. Turn Lt. on Fairview past corporate
offices then left on Textile Drive and then left on Upland
Dr. WWTP is at the end of Upland Dr.
6. Discharge Points(s), List for all discharge points:
Outfall 001:
Latitude:
36o06115"
Longitude:
79o46115"
Outfall 005:
(reported as
once thru cooling
& cooling tower)
Latitude:
36006'20"
Longitude:
79o46112"
Outfall 006:
(reported as
cooling tower
only)
Latitude:
36o06'02"
Longitude:
79o46102"
U.S.G.S. Quad
No. Greensboro U.S.G.S.
Quad Name C19SE

7. Site size and expansion area consistent with application ?
X Yes No If No, explain:
8. Topography (relationship to flood plain included):
WWTP in floodplain. Serious flooding of site unknown
although operational concerns do exist.
9. Location of nearest dwelling: None known within 1000'
10. Receiving stream or affected surface waters:
North Buffalo Creek
a. Classification: C-NSW
b. River Basin and Subbasin No.: CPF030602
C. Describe receiving stream features and pertinent
downstream uses: Suburban/rural mix. More rural
outside of city limits.
Part II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
1. a. Volume of Wastewater to be permitted: 1.25 MGD
(Ultimate Design Capacity)
b. What is the current permitted capacity of the Waste
Water Treatment facility? 1.25 MGD
C. Actual treatment capacity of the current facility
(current design capacity)? Reportedly 3.5 MGD
d. Date(s) and construction activities allowed by previous
Authorizations to Construct issued in the previous two
years. None known.
e. Please provide a description of existing or
substantially constructed wastewater treatment
facilities: Some dye reclamation occurs at the
manufacturing plant, leftover dyes are sent via
collection system with domestic waste to the WWTP.
The treatment facility consist of pre-treatment
screening, equalization basin, CO2* and Acid
neutralization, additional screening. Additional
biological treatment usingextended aeration activated
sludge process includes 2 primary clarifiers, chemical
coagulation/flocculation and polymer addition, 4.0 MG
surface aeration basin, 3 secondary clarifiers with
chemical addition capabilities, flow meter,
chlorination, polishing pond, effluent reaeration and
automatic sampler. Residuals handling includes
thickener, aerobic digester and truck transfer station.
* CO2 unit removed after explosion
NPDES Permit Staff Report
Version 10/92
Page 2

f. Please provide a description of proposed wastewater
treatment facilities. Connection to POTW.
g. Possible toxic impacts to surface waters: Toxicity
issues are significant and potentially numerous.
h. Pretreatment Program (POTWs only):
in development approved
should be required X* not needed
*when connected to POTW
2. Residuals handling and utilization/disposal scheme:
a. If residuals are being land applied, please specify DWQ
Permit No. W00003760
Residuals Contractor: Cone Mills
Telephone No. 910/379-6226
b. Residuals stabilization: PSRP X PFRP
Other (100 day digester storage)
C. Landfill: None, except for solids removed in
screenings.
d. Other disposal/utilization scheme (Specify):
3. Treatment plant classification (attach completed rating
sheet) . IV
4. SIC Code(s): 2211 & 2261
Primary 02 Secondary 55
Main Treatment Unit Code: 012 3
PART III - OTHER PERTINENT INFORMATION
1. Is this facility being constructed with Construction Grant
Funds or are any public monies involved. (municipals only)?
2. Special monitoring or limitations (including toxicity)
requests: SOC has been issued to address WET. To date, no
resolution of WET has occurred.
NPDES Permit Staff Report
Version 10/92
Page 3

3. Important SOC, JOC or Compliance Schedule dates: (Please
indicate)
na�A
Submission of Plans and Specifications To be determined
Begin Construction in upcoming SOC
Complete Construction amendment.
The SOC should include language for constructing a
connection to the POTW as well as some language detailing
TIE and THE actions to reduce WET.
4. Alternative Analysis Evaluation: Has the facility evaluated
all of the non -discharge options available. Please provide
regional perspective for each option evaluated.
Spray Irrigation: Existing for residuals.
Connection to Regional Sewer System: Should occur within
the near future if City of Greensboro will accept.
Subsurface: Not enough room.
Other disposal options: Unknown.
5. Other Special Items: The Corporation has been working
under an SOC to resolve WET and has indicated that they
desire to connect to the City of Greensboro WWTP. This will
likely occur after an upgrade at the T Z Osborn WWTP.
During the last Lab inspection at this facility it was
discovered that BOD values provided for the Corporation are
"all questionable". This is extremely unsettling as the
creek has been considerably stressed for Oxygen on several
occasions. Cones discharge is suspected to be the main
culprit causing oxygen depletion in this stream by the WSRO.
Due to the reported partially supporting/poor-fair quality
of this stream segment, the Division should scrutinize and
consider tightening the limits currently in place for this
NPDES Permit. Correlation to other NPDES Permit limits for
North Buffalo Creek, South Buffalo Creek and Buffalo Creek
should also occur. Special concern should be focused on the
pounds limits currently allowed for Cone Mills. Cone's pH,
TDS, salt, conductivity, BOD, and COD (other parameters
as appropriate) should be specifically reviewed and
evaluated. This facility needs to be encouraged to connect
to the available POTW collection system. The Aquatic
Toxicology Unit should also be requested to comment on
proposed Permit limits.
NPDES Permit Staff Report
Version 10/92
Page 4

Page 1
Note for Jason Doll
From: Ruth Swanek
Date: Mon, Jul 15, 1996 10:15 AM
Subject: FW: Cone Mills Saga
To: Carla Sanderson; Jason Doll; Steve Bevington
FYI.
From: Dave Goodrich on Mon, Jul 15, 1996 10:02 AM
Subject: Cone Mills Saga
To: Coleen Sullins; Don Safrit; Larry Ausley; Ruth Swanek; Steve Tedder; Susan Wilson
I had a discussion with Arthur Toompas this morning. He requested that we extend the
expiration date of the recently issued permit. I told him no. I told him our intention was to
see that Cone got their toxicity under control by the end of the SOC.
He proceeded to ramble on about everything other than progress in reducing toxicity. He
talked about trying to do treatability studies with G'boro (they won't agree to it until Cone
gets their act together), about whether or not ceriodaphnia was the correct toxicity species to
use, about the fact that he ate lunch with Linda Rimer recently, etc.
Bottom line: Tedder was right. He's shifty. However, we have a real opportunity to have
them connect to G'boro once and for all IF we continue to pressure them into making
significant progress towards toxicity reduction. Coble isn't sure they can meet toxicity test
limits but attributes toxicity to polymer addition (???? Someone explain that one to me.).
Therefore, I think the pressure will have to come from somewhere other than the region.
Ray Shaw will be out of the picture next month (he's retiring at the end of this month) which
places another unknown on the situation. There's a meeting between Cone and G'boro and
DWQ this Thursday to discuss THE results.

NORTH CAROLINA DEPARTMENT OF ENVIRONMENT
HEALTH AND NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL MANAGEMENT
M E M O R A N D U M
TO: Martha Groome, City of Greensboro
Mike Burleson, Cone Mills
THROUGH: Steve Mauney
FROM: Ron Linville I-.
DATE: 960216
SUBJECT: Joint Stream Monitoring January 24, 1996
Guilford County
CdG
The following results were obtained during our monitoring
session:
Site: NB WWTP
Sampler Temperature pH DO Conductivity
GBO 8.4 7.47 11.52 -
CONE 8.6 - 11.8 592
DEM 8.5 7.35 10.8 550
Site: Summit
Sampler Temperature pH DO Conductivity
GBO 9.1 7.39 11.45 -
CONE 9.2 - 12.0 253
DEM 9.0 7.3 10.4* 222
Site: Church
Sampler Temperature pH DO Conductivity
GBO 9.8 7.41 11.23 -
CONE 9.8 - 11.6 108
DEM 9.7 7.34 10.4* 88
Site: Pond
Sampler Temperature pH DO Conductivity
GBO 10.9 7.56 3.5(bkt) -
CONE 10.9 - 3.6(bkt) 4000
DEM 11.0 7.76 2 .4 (pond) * 3800
*DO measurements were determined later in the DEM regional
office to be approximately 1.0 mg/1 lower than actual due to
a problem with the DO Meter membrane.
Thank you for your cooperation and contribution with this
exercise.
cc: Technical Services
Central Files
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CAL2COMP.XLC
Comparison of Calibration Scenarios, North Buffalo Creek from Cone Mills
Through Reedy Fork
Cone Mills Discharge
7 -r
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North South Buffalo Confluence
= IN North Side WWTP
State DO Standard
Basic Calibration
- Proposed Limits
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0 5 10 15
Stream mile (Cone discharge point is mile one)
Page 1
0
25

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ALLOCOMP.XLC
Comparison of Allocation Scenarios, North Buffalo Creek from Cone Mills Through
Reedy Fork
Cone Mills Discharge
Northside WWTP
North South Buffalo Confluence
- - - - - - State DO Standard
Basic Allocation
Proposed Limits
Cone Tied to Northside
0 5 10 15
Stream mile (Cone Discharge point is mile one)
Page 1
20
25
h

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ALLOCOMP.XLC
Comparison of Allocation Scenarios, North Buffalo Creek from Cone Mills Through
Reedy Fork
0 5 10 15 20 25
Stream mile (Cone Discharge point is mile one)
Page 1

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date
UPSTR. CONE
25 yds. above outfall
temp DO % sat tom p
DOWNSTR. EFF
Summit Ave. SODS
DO % "t IbsJday
GREENSBORO UPST
at Influent Conduit
temp SODS DO %ag
5/3/94
114.6
8.7
85.6
15.0
8.8
87.3
30
17.0
2.8
49.7
5/10/94119.4
7.4
80.4
20.0
7.8
85.8
47
18.0
3.8
F,,4.*,-.....-i.-.V..�..-,
49.7
5/17/94
21.0
6.0
67.3
20.8
6.8
76.0
55
20.0
5.7
39.6
5/26/94
22.0
7.4
84.7
23.0
7.9
92.1
17
122.0
2.3
28.6
5/31/94
25.0
6.6
79.9
24.0
7.5
89.1
46
122.0
7.1
24.0
6/7/94
24.0
5.8
68.9
24.0
5.8
68.9
40
124.0
4.3
20.2
6/9/94
23.0
5.3
61.8
23.0
5.3
61.8
30
123.0
5.5
30.3
6/10/94
23.0
5.4
63.0
23.0
5.6
65.3
48
22.0
3.2
29.7
6/13/94
25.0
5.9
71.4
25.0
6.4
77.5
30
23.0
2.5
29.2
6/14/94
26.0
5.3
65.3
26.0
6.0
74.0
28
24.0
4.1
w
F-..'
27.3
6/16/94
28.0
5.8
74.1
28.0
5.0
63.9
105
26.0
7.0
Q
24.7
6/21/94
29.0
8.0
104.0
27.0
5.9
74.1
79
26.0
6.9
32.1
623/94
26.0
5.3
65.3
26.0
6.0
74.0
109
126.0
3.9
30.8
6124/94
25.0
5.6
67.8
26.0
6.0
74.0
114
124.0
4.8
57.0
6/28/94
23.0
5.6
65.3
23.0
5.4
63.0
86
23.0
4.9
38.5
6/30/94
24.0
6.2
73.7
24.0
5.4
64.2
75
22.0
4.6
48.1
7/1/94
124.0
6.6
78.4
24.0
5.6
66.5
115
23.0
5.3
5.0
58.3
7/,gW94
24.4
6.0
71.8
25.0
6.3
76.3
175
25.0
5.7
......
....
33.9
717/94
24.0
7.2
85.6
24.6
6.9
82.9
111
26.0
5.1
<2 E>i
25.9
7/8/94
26.4
6.3
78.2
26.8
6.9
86.3
125
27.0
6.1
26.4
7/12/94
25.1
6.2
75.2
25.4
7.0
85.4
106
125.0
4.0
29.1
7/14/94
25.2
6.7
81.4
25.4
7.8
95.1
64
26.0
6.4
7/15/94
25.8
6.3
77.4
25.9
7.9
97.2
76
26.0
5.8
30.8
7/19/94
27.0
7.8
97.9
27.2
9.0
113.4
71
26.0
4.3
30.8
7/21194
27.0
7.7
96.7
26.0
8.7
107.3
107
24.0
3.1
48.7
7/22/94
26.3
8.0
99.2
26.3
8.7
107.8
133
26.0
3.9
39.5
7/26/94
26.6
10.3
128.4
26.5
9.6
119.4
82
26.0
2.4
5.6
69.0
7/28/94
23.8
11.1
131.4
25.2
10.6
128.8
88
24.0
3.1
7.8
92.7
7/29/94
23.0
10.3
120.1
23.0
10.3
120.1
91
23.0
4.9
8.5
99.1
8/2/94
25.0
9.6
116.2
25.0
9.9
119.8
107
25.0
2.9
6.9
83.5
8/4/94
26.0
10.0 123.3
26.0
10.0
123.3
98
25.0
2.4
6.5
78.7
8/5/94
26.0
10.9
134.4
26.0
10.1
124.5
79
25.0
2.7
5.2
62.9
8/9/94
23.0
12.2
142.3
23.5
10.2
120.1
102
22.0
8.9
18.3
8/11194
26.0
10.6
130.7
26.0
10.7
131.9
78
24.0
4.9
39.2
8/12/94
26.0
9.7
119.6
26.0
10.2
125.8
90
24.0
3.0
32.1
8116/94
24.0
10.0
118.8
24.0
9.8
116.5
105
23.0
2.7
47.8
8/18/94
24.0
10.4
123.6
25.0
11.2
135.6
105
23.0
5.4
-43:'...:
52.5
8/19/94
24.5
10.0
119.9
25.0
10.9
132.0
122
25.0
2.29
---- ------
47.2
8/23/94
24.0
12.0
142.6
24.0
11.4
135.5
63
23.0
1.8
5.6
65.3
8/25/94
24.0
7.6
90.3
24.0
6.9
82.0
120
23.0
2.8
5.9
68.8
8/26/94,
24.0
7.9
93.9
24.0
7.7
91.5
97
23.0
3.9
<42
49.0
8/30/94
24.0
8.2
97.4
24.0
8.3
98.6
107
24.0
3.0
7.4
87.9
9/1/94
24.0
7.3
86.7
25.0
7.3
88.4
134
24.5
2.2
6.2
74.4
9/2/94
23.0
7.6
88.6
24.0
7.6
90.3
98
22.3
3.3
6.7
77.1
9/6/94
24.0
7.0
83.2
24.0
7.6
90.3
95
20.3
1.0
6.4
70.8
9/8/94
23.0
7.7
89.8
24.0
7.0
83.2
112
21.2
2.0
7.4
83.4
9/9/94
23.0
7.6
88.6
24.0
6.6
78.4
88
21.0
1.9
5.7
64.0
9/13/94
24.0
7.0
83.2
25.0
6.6
79.9
123
20.7
1.2
5.4
60.2
9/15/94
24.0
7.2
85.6
25.0
6.7
81.1
83
21.3
1.8
6.0
67.7
9/16/94
24.0
7.6
90.3
25.0
7.3
88.4
85
22.0
1.9
5.6
64.1
9/20/94
22.0
10.9
124.7
23.0
8.6
100.3
92
18.0
1.1
7.5
79.2
9/22/94
23.0
7.9
92.1
23.0
7.5
87.5
95
18.7
4.3
A.
49.3
9/23/94
23.5
7.7
90.6
23.5
6.8
80.0
63
17.9
2.8
X
49.6
9/27/94
24.0
7.3
86.7
24.0
6.9
82.0
119
20.1
1.9
5.1
56.2
9/29/94
22.0
8.6
98.4 122.0
7.8
89.2
77
18.7
3.6
5.5
59.0
19/30/94121.5
9.6
108.8121.5
8.8
99.7
43
17.5
1.9
5.7
59.6

ATTACHMENT 1. DISSOLVED OXYGEN DATA FROM NORTH BUFFALO CREEK
s. of Cone Summit
9.0
Ave. U
8.8
s. of G-boro
Ds. of Gboro Rankin
Mill Rd
Date U
4/1193
8.8
9.2
4/2193
9.5
9.6
8.8
9.2
4/5193
4/6193
9.0
10.2
8.8
8.4
7.1
7.0
6.8
417/93
4/8193
7.4
9.7
9.9
7.2
7.2
7.2
3.6
6.5
7.8
419/93
4/12/93
4/13193
4/14193
9.3
7.7
7.3
7.8
4/15/93
4/16193
9.2
8.2
7.4
6.0
5.4
4/19/93
4/20/93
4/21193
8.3
7.0
4/22193
7.9
6.8
8.2
8.6
8.3
8.6
6.5
6.2
6.9
>>..... 3.5
5.3
6.3
A.2
5.8
4.9
4/23/93
4/26/93
4/27/93
4/28/93
4/29/93
4/30/93
5/3/93
5/4/93
5/5193
11.0
5.6
7.5
7.9
7.0
7.3
9.2
9.2
8.8
8.6
8.0
6.2
7.2
6
6.7
5.7
5.8
6.0
5.9
3.7
4.0
- 4.2
4.1
5.6
13
--0.6
5.2
4.9'
'4
5/6/93
517/93
5/10/93
5/11193
5/12193
5/13/93
5/14/93
5/17/93
5/18/93
32
5.3
5.8
5/19/93
6.3
7.0
5.9
6.2
5/20/93
5/21/93
6.6
4.6
5/24/93
5/25/93
7.0
8.0
5.3
4.4
6.4
6.4
8.2
5/26/93
6.9
6.4
5/27/93
7.9
5.7
5/28193
7.3
5.9
5/31 /93
S EP ` ? 1993
`VIOLATIONS OF THE D.O. STANDARD ARE SHADED AND SHOWN IN BOLD PRINT.
C�•�••;l��i. riLES

OXYGEN DATA FROM NORTH BUFFALO CREEK
ATTACHMENT 1. DISSOLVED
•e .f
611/93
7.2
7.0
6.2
4.9
1�
6/2/93
6.4
5.2
7.0
?9
5.9
6/3/93
7.0
7.0
6.8
23
6.3
4.4
6/4193
6/7/93
7.6
7.2
< 2.2
5.3
5.0
5.0
6/8/93
6.9
6.6
18
6.2
6/9193
6.7
7.2
6/10193
8.5
5 8
4.7
6/11/93
8.0
60.3�
2:1<
6.0r
5.3
6/14/93
7.9
6 2
8.3
8.2
6/15193
'
6/16/93
7.9
5.9
'.0.9,8.2
5.8
6/17193
7.2
5.3
6/18193
7.2
5.5
22
6/21 /93
7.8
1.4
Q.d
6/22/93
7.2
6/23/93
7.0
5.3
0.3
:.
26
6/24/93
7.3
4.9
,;3'
6/25/93
7.1
5.7
6.3
2.0
4 9
31
6/28/93
7.2
6.6
�6
5.8 ;,
6/29/93
7.2
6/30/93
7.0
6.0
7/l/93
6.3
6.0
5.3
7/2/93
6.6
7/5/93
4.9
44:
5.7
36
7/6/93
6.3
717/93
6.0
4.9
7/8/93
5.3
5.032'
4.5
<1.0
4.8
7/9/93
4.8
d.3
2.
6.1
4.6i
7/12/93
7.7
3.2
2:0:
-
7/13/93
4.2
7/14/93
3.3
3.1
7/15/93
3.8
3.5
3.3
5.2
4
7/ 16193
3.5
3.8
4.0
7/19/93
4 $
3.7
2.6
5.2
4 Q
7/20/93
5.0
4 .4
-
7/21 /93
3.9
3.0
4.2
7/22193
5.0
7/23/93
5.9
5.0
7/26193
6.23.
5.3
1,1
4.49.
7/27/93
6.4
7/28/93
6.0
1.4
1.4
1.1.
7/29/93 '>
4 4
:...
7/30193
4.6
1.6
# of measurments
84
84
35
3522
7
22
#c5mg/I
9
33
lA.
_ww-
S EP h 1 1993
-VIOLATIONS OF THE D.O. STANDARD ARE SHADED AND SHOWN IN BOLD PRINTUNTPh;s FILES
w

January 17, 1996
Mr. David A. Goodrich, Supervisor
NPDES Group
NCDEHNR
P. 0. Box 29535
Raleigh, NC 27626-0535
RE: NPDES Permit Renewal Dratt
NC0000876
Cone Mills White Oak Wastewater Treatment Plant
Dear Mr. Goodrich:
We have reviewed the draft of a renewal permit for the Cone
Mills White Oak Wastewater Plant. After calling Ms. Susan Wilson
to express our concerns, we :agreed that I should write to you.
We would like to request a meeting to discuss the draft permit.
Our concerns are mainly related to the BOD issue. We would like
to have an opportunity to review the EPA QUAL 2E model
information and to discuss the feasibility of technology meeting
the proposed limits.
Our goal continues to be to become a pretreatment facility
and to discharge into the City of Greensboro sewer system. We
have worked toward that goal for one and a half years and have
not received approval.
Thank you for yours and Ms. :ti'ilson's consideration. Please
suggest a few potential meeting dates so that we can arrange to
have the proper personnel available.
Sincerely,
Arthur J. Toompas
Corporate Environmental Mgr.
cc: Mr. Mather Whitehead
Ms. Lindy Bode Aucoin
Mr. John Hodges
Mr. Mike Burleson
Mr. Larry Coble
CONE MILLS CORPORATION, 1201 MAPLE STREET, GREENSBORO, NC 27405

COUNTY OF GUILFORD
IN THE MATTER OF
NORTH CAROLINA
NPDES PERMIT
NO. NC0000876
HELD BY CONE MILLS
CORPORATION
NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
SPECIAL ORDER BY CONSENT
EMC WQ NO. 95-17 AD I
Pursuant to provisions of North Carolina General Statute (G.S.) 143-215.2,
this Special Order by Consent is entered into by the Cone Mills Corporation,
hereinafter referred to as the Corporation, and the North Carolina
Environmental Management Commission, an agency of the State of North Carolina
created by G.S. 143B-282, and hereinafter referred to as the Commission:
1. The Corporation and the Commission hereby stipulate the following:
(a) That the Corporation holds North Carolina NPDES Permit No.
NC0000876 for operation of an existing wastewater treatment works and
for making an outlet therefrom for treated wastewater to North Buffalo
Creek, Class C-NSW waters of this State in the Cape Fear River Basin,
but is unable to consistently comply with the final effluent limitations
for Chronic Toxicity set forth in the Permit. Compliance may require
preparation of plans and specifications for construction and operation
of additional treatment works.
(b) The Commission has concluded that noncompliance with final effluent
limitations constitutes causing and contributing to pollution of the
waters of this State named above, and the Corporation is within the
jurisdiction of the Commission as set forth in G.S. Chapter 143, Article
21.
(c) Since this Special order is by Consent, neither party will file a
petition for a contested case or for judicial review concerning its
terms.
2. The Corporation agrees to pay the North Carolina Department of
Environment and Natural Resources the sum of $50,000 as full settlement
of all past toxicity violations of permit number NC0000876 occurring
from failure to achieve compliance with final effluent limits required
by the previous SOC's final compliance deadline of May 31,1997. Payment
shall be submitted to the Director, Division of Water Quality, P.O. Box
29535, Raleigh, NC 27626-0535, within thirty (30) days of the signature
of this Order. The Corporation agrees to waive the Corporation's
right to an administrative hearing or remission of civil penalties for
the above settlement amount. Failure to pay this amount will result in
the Division assessing the Corporation a civil penalty through formal
notification.
3. The Corporation, desiring to comply with the permit identified in
paragraph l(a) above, hereby agrees to do the following:

2) Comply with a > 19 % value on or before January 1, 1998.**
3) Comply with a > 39 % value on or before June 1, 1998.**
4) Comply with a > 59 % value on or before November 1, 1998.**
5) Comply with all NPDES permit limitations or cease discharge from
outfall 001 to North Buffalo Creek on or before May 1, 1999.**
(d) Stipulated penalties for failing to meet the performance schedule
dates listed in
Section (c)
above
shall be as follows:
Failure
to
meet
the
1/01/98
date ..................$
50,000
Failure
to
meet
the
6/01/98
date ..................$
75,000
Failure
to
meet
the
11/01/98
date
.................$100,000
Failure
to
meet
the
5/01/99
date..................$250,000
Noncompliance with this section shall be defined as the result of any
toxicity test (performed by The Corporation or the Division) which
does not meet or exceed the applicable interim limit. Interim
limitations shall be effective during the calendar month which
includes the compliance schedule date and any subsequent months until
the next compliance date is encountered. The first instance of
noncompliance of an interim limit will cause the applicable
stipulated penalty to come due. Should there be any additional
instances of noncompliance for any interim limit, stipulated
penalties will be due in the amount of $5,000 per violation until the
next compliance date is encountered.
**These compliance dates shall become void upon presentation to the
Division of a binding agreement between The Corporation and the City
of Greensboro indicating Greensboro's acceptance of The Corporation's
wastewater. Such agreement must include a firm date for the
connection and flow acceptance of the wastewater into the City's
collection system or POTW.
(e) During the time in which this Special Order by Consent is effective,
comply with the interim effluent limitations contained in Attachments A, B
and C. The following reflects only the limitations that have been modified
from NPDES requirements by this Order:
Permit Limits Modified Limits (SOC)
Parameters Unit Monthly Avg. Monthly Avg.
Toxicity Pass/Fail 79% Monitor Monthly*
*As prescribed above. Results should also be reported if any
additional testing occurs.
(f) No later than 14 calendar days after any date identified for
accomplishment of any activity listed in 3(b)l), 2) and 5) above, submit to
the Director of the North Carolina Division of Water Quality (DWQ) written
notice of compliance or noncompliance therewith. In the case of
noncompliance, the notice shall include a statement of the reason(s) for
noncompliance, remedial action(s) taken, and a statement identifying the
extent to which subsequent dates or times for accomplishment of listed
activities may be affected.
4. The Corporation agrees that upon notice by Division of Water Quality and
unless excused under paragraph 5, the Corporation will pay the Director of
Division of Water Quality, by check payable to the North Carolina

(a) Comply with all terms and conditions of the permit except those
effluent limitations identified in paragraph l(a) above. See
attachments A, B, and C for all current monitoring requirements and
effluent limitations. The permittee may also be required to monitor
for other parameters as deemed necessary by the Director in future
permits or administrative letters.
(b) Undertake the following activities in accordance with the indicated
time schedule:
1) Submit quarterly THE progress reports to the Winston-Salem
Regional Office. The reports are to be submitted in triplicate no
later than the 15th day of each February, May, August, and November.
2) Undertake efforts to reduce end of pipe effluent toxicity.
Effluent toxicant characterization, identification, and confirmation
activities should be considered within the THE to accomplish this
task. Potential effluent toxicants for consideration include but are
not limited to: total dissolved solids, surfactants and/or
surfactant containing compounds, metals, dyes, oils, organic
compounds, dredged materials, process chemicals, maintenance
chemicals, and polymers/flocculation agents used at the White Oak
facility.
3) Provide an assessment of settled solids and pore waters for the
final polishing pond, the raw wastewater basin, the ash pond and the
aerated sludge basin on or before January 3, 1998.
4) Provide an independent wastewater treatment engineering and
operational analysis of the White Oak wastewater treatment facilities
on or before February 1, 1998. This analysis will include a review
of the White Oak WWTP's efficiency, suggestions to improve WWTP
efficiency, verification of treatment basin capacities and potential
flow augmentation regimes for improving stream conditions for North
Buffalo Creek.
5) Provide documentation including an economic analysis as to why a
caustic recovery system was not/could not be implemented at the White
Oak facility. This document is due on or before February 1, 1998.
6) Provide a complete chemical usage and optimization study for all
significant chemicals and compounds used at the White Oak facility
which have the potential to be discharged to the White Oak WWTP on or
before April 1, 1998.
7) Evaluate the feasibility of removing all non -contact cooling
water discharges to North Buffalo Creek and report these findings to
the Division on or before April 1, 1998.
8) Complete dredging of basins (see item 3 above) plus all other
basins or tanks which have historical accumulations of bottom solids
on or before October 1, 1998 in order to provide optimal capacity in
the WWTP. This activity must be conducted in a manner that will
minimize odors.
(c) The Corporation must meet the following compliance performance
schedule and provisions:
1) Collect on a daily basis a sufficient volume of composite sample
such that the Division may procure approximately one (1) gallon of
said sample on demand whenever said samples are routinely removed by
the Corporation from the sampling refrigerator.

Department of Environment and Natural Resources, according to the following
schedule for failure to meet the deadlines set out in paragraph 3(b) or
failure to attain compliance with the effluent toxicity limitations/
monitoring requirements contained in Attachments A and B.
Failure to meet a schedule date $1000/day for the
first 7 days;
$5000/day thereafter
Failure to achieve compliance with $250,000
final effluent limits at final compliance
deadline
Monitoring frequency violations $1000 per omitted
value per parameter
Failure to submit progress reports $1000/day for the
first 7 days;
$5000/day thereafter
5. The Corporation and the Commission agree that the stipulated penalties are
not due if the Corporation satisfies the DWQ that noncompliance was caused
solely by:
a. An act of God;
b. An act of war;
c. An intentional act or omission of a third party but this defense shall
not be available if the act or omission is that of an employee or agent of
the defendant or if the act or omission occurs in connection with a
contractual relationship with the permittee;
d. An extraordinary event beyond the permittees control. Contractor delays
or failure to obtain funding will not be considered as events beyond the
permittee's control; or
e. Any combination of the above causes.
Failure within 30 days of receipt of written demand to pay the penalties,
or challenge them by a contested case petition pursuant to G.S. 150B-23,
will be grounds for a collection action, which the Attorney General is
hereby authorized to initiate. The only issue in such an action will be
whether the 30 days has elapsed.
6. Noncompliance with the terms of this Special Order by Consent is subject to
enforcement action in addition to the above stipulations, including
injunctive relief pursuant to G.S. 143-215.6.C.
7. This Special Order by Consent and any terms, conditions and interim
effluent limitations contained herein, hereby supersede any and all
previous Special Orders, Enforcement Compliance Schedule Letters, terms,
conditions, and limitations contained therein issued in connection with
NPDES Permit No. NC0000876.
8. The permittee, upon signature of the Special Order by Consent, will be
expected to comply with all schedule dates, terms, and conditions of this
document.

9. This Special Order by Consent shall expire on August 1, 1999.
For Cone Mills Corporation:
Print Name
Title
Signature
Date
For the North Carolina Environmental Management Commission:
Chairman of the Commission Date
coneadm 1. soc

ATTACHMENT A
Part I
Page 2 of 4
Permit No. NC0000876
A (1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS SUMMER (April - October 31) (Continued)
*** Quarterly average based upon weekly samples
**** Chronic Toxicity (Ceriodaphnia) See Attachment B.
***** See Attachment C
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall
be monitored daily at the effluent by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

ATTACHMENT A
Part I
Page 1 of 4
Permit No. NC0000876
A (1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS SUMMER (April - October 31)
During the period beginning on the effective date of this Special Order and lasting until April 30, 1999, the
permittee is authorized to discharge from outfall serial number 001. Such discharge shall be limited and
monitored by the permittee as specified below.
Effluent Characteristics
Discharge Limitations
Monitoring
Requirements
Lbs/day
Units specify
Measurement
Sample
Sample
Mon Avg
Daily Max
Mon Avg Daily Max
Frequency
Type
Location*
Flow
1.25 MGD
Continuous
Recorder
I
or E
BOD, 5 Day, 200 C
100.0
200.0
10.0 mg/1 20.0 mg/l
Daily
Composite
E
TSS
292.0
500.0
Daily
Composite
E
NH3 as N
18.3
36.6
2.0 mg/1 4.0 mg/1
Daily
Composite
E
Dissolved Oxygen**
Daily
Grab
E,
U, D
Fecal Coliform (geometric mean)
200.0/100 ml 400.0/100 ml
4/Week
Grab
E,
U, D
COD
14805.0
29610.0
Weekly
Composite
E
Sulfides
42.0
84.0
Weekly
Grab
E
Phenols
21.0
42.0
Weekly
Grab
E
Total Chromium
0.66
63.0 ug/l
Weekly
Composite
E
Temperature
Daily
Grab
E,
U, D
Conductivity
Daily
Grab
E,
U, D
Total Nitrogen (NO2+NO3+TKN)
Quarterly
Composite
E
Total Phosphorus
2.0 mg/1***
Weekly
Composite
E
Chronic Toxicity****
Quarterly
Composite
E
Pollutant Analysis*****
Annually
E
Chloride
Quarterly
Composite
E
Lead
Quarterly
Composite
E
Fluoride
Quarterly
Composite
E
Arsenic
Quarterly
Composite
E
Copper
Quarterly
Composite
E
Nickel
Quarterly
Composite
E
Zinc
Quarterly
Composite
E
Total Residual Chlorine
21.0 ug/l
Daily
Grab
E
* Sample locations E - Effluent, I - Influent, U - Upstream 25 yards above the outfall, D - Downstream at (1)
Summit Avenue.
Upstream and downstream samples shall be grab samples. Stream samples shall be collected three times per week
during June, July, August, and September, and once per week during the remaining months of the year.
** The daily average Dissolved Oxygen effluent concentrations shall not be less than 6.0 mg/l.

ATTACHMENT A
Part I
Page 3 of 4
Permit No. NC0000876
A (1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS WINTER (November 1 - March 31)
During the period beginning on the effective date of this Special order and lasting until April 30, 1999, the
permittee is authorized to discharge from outfall serial number 001. Such discharge shall be limited and
monitored by the permittee as specified below.
Effluent Characteristics Discharge Limitations Monitoring Recruirements
Lbs/day
Units specify
Measurement
Sample
Sample
Flow
Mon Avg.
Daily Max
Mon Avg Daily Max
Frequency
Type
Location*
BOD, 5 Day, 200 C
200.0
400.0
1.25 MGD
20.0 mg/1 40.0 mg/l
Continuous
Daily
Recorder
Composite
I or E
E
TSS
292.0
500.0
Daily
Composite
E
NH3 as N
36.6
73.2
4.0 mg/1 8.0 mg/l
Daily
Composite
E
Dissolved Oxygen**
Daily
Grab
E, U, D
Fecal Coliform (geometric mean)
200.0/100 ml 400.0/100 ml
Daily
Grab
E, U, D
COD
14805.0
29610.0
Weekly
Composite
E
Sulfides
42.0
84.0
Weekly
Grab
E
Phenols
21.0
42.0
Weekly
Grab
E
Total Chromium
0.66
63.0 ug/1
Weekly
Composite
E
Temperature
Daily
Grab
E, U, D
Conductivity
Daily
Grab
U, D
Total Nitrogen (NO2+NO3+TKN)
Quarterly
Composite
E
Total Phosphorus
2.0 mg/l***
Weekly
Composite
E
Chronic Toxicity****
Quarterly
Composite
E
Pollutant Analysis*****
Annually
E
Chloride
Quarterly
Composite
E
Lead
Fluoride
Quarterly
Composite
E
Arsenic
Quarterly
Composite
E
Copper
Quarterly
Composite
E
Nickel
Quarterly
Composite
E
Zinc
Quarterly
Composite
E
Total Residual Chlorine
21.0 ug/l
Quarterly
Daily
Composite
Grab
E
E
* Sample locations E - Effluent, I - Influent, U - Upstream 25 yards above the outfall, D - Downstream at (1)
Summit Avenue.
Upstream and downstream samples shall be grab samples. Stream samples shall be collected three times per week
during June, July, August, and September, and once per week during the remaining months of the year.
** The daily average Dissolved Oxygen effluent concentrations shall not be less than 6.0 mg/l.

ATTACHMENT A
Part I
Page 4 of 4
Permit No. NC0000876
A (1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS WINTER (November 1 - March 31) (Continued)
*** Quarterly average based upon weekly samples
**** Chronic Toxicity (Ceriodaphnia) See Attachment B.
***** See Attachment C
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall
be monitored daily at the effluent by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

NPDES Permit No. NC00008766
Cone Mills - Greensboro
ATTACHMENT B
CHRONIC TOXICITY MONITORING (MONTHLY)
The permittee shall conduct chronic toxicity tests using test procedures outlined in:
The North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure (Revised
November 1995) or subsequent versions.
The effluent concentration defined as the Instream Waste Concentration (IWC) shall be 79%.
Recommended effluent serial dilutions for the full range test are 79 %, 59 %, 39.5 %, 20 % and
10% (these concentrations may be modified only upon prior approval from the Environmental
Sciences Branch and provided that Phase II test methodology is adhered to). The chronic value
for this analysis will be determined using the geometric mean of the highest concentration having
no statistically detectable impairment of reproduction or survival and the lowest concentration
that does have a statistically detectable impairment of reproduction or survival. The presence
of 48 hour acute toxicity will be determined using Fisher's Exact Test at 48 hours from test
initiation. Collection methods, exposure regimes, and further statistical methods are described
by the document referenced above.
The permit holder shall perform at a minimum monthly monitoring using these procedures to
establish compliance with the Order condition. Full range toxicity testing is to be performed
during the months of January, April, July and October. Effluent sampling for this testing shall
be performed at the NPDES permitted final effluent discharge below all treatment processes.
All toxicity testing results required as part of this Order condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the months in which tests were performed, using the
parameter code THP3B for the Chronic Value and TGA313 for the 48 hour Acute Toxicity
measure (Pass/Fail). Additionally, DWQ Form AT-3 (original) is to be sent to the following
address:
Attention: Environmental Sciences Branch
North Carolina Division of
Water Quality
4401 Reedy Creek Road
Raleigh, NC 27607
Test data shall be complete and accurate and include all supporting chemical/physical
measurements performed in association with the toxicity tests, as well as all dose/response data.
Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine
is employed for disinfection of the waste stream.
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, the NPDES 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 and appropriate environmental controls, shall constitute an invalid test
and will require immediate retesting (within 30 days of initial monitoring event). Failure to
submit suitable test results will constitute noncompliance with monitoring requirements.

NPDES WASTE LOAD ALLOCATION
PERMIT NO.: NC0000876
PERMITTEE NAME: Cone Mills Corporation
FACILITY NAME: Cone Mills -Greensboro Facility
Facility Status: Existing
Permit Status: Renewal
Major
Pipe No.: 001
Minor
Design Capacity: 1.25 MGD
Domestic (% of Flow):
Industrial (% of Flow):
10%
Modeler
Date Rec.
#
d
9/11/15 '1
IF-3 �11
Drainage Area (mil) 'IV, 7 Avg. Streamflow (cfs):- (3, _*�
7Q10 (cfs) D. S Winter 7Q10 (cfs) /, y 30Q2 (cfs)��
Toxicity Limits: IWC 2q % Acut hroni
Instream Monitoring: Loaol4", rse4« 54-1d be- mo►+,4r,,-4
aN Vps�m And d0,.1,16b e-4,V A�-/ Si i�S
Parameters '7~_ay. , %-�c1i, Gerid. , Lcc►d., ,4rsen�-C
Upstream ve-A Location z5 vds above- aAi 41�
,t 4%Z-Downstream a Slid Location ,moo
xni/.A.�t cC,411f
ummer
Winter
Comments:
Mnthly Av Daily Max
Mnthly Av Daily Max
Flow (MGD):
1.25
1.25
BOD5 (lbs/day):
100 200
200
400
BOD5 (mg/1):
10 20
20
40
TSS (lbs/day):
292 500
292
500
DO (mg/1):
6.0 6.0
6.0
6.0
PH (SU):
6.0-9.0 6.0-9.0
6.0-9.0
6.0-9.0
RECEIVING STREAM: North Buffalo Creek
COD (lbs/day):
12,690 25,380
12,690
25,380
NH3-N (lbs/day):
18.3 36.6
36.6
73.2
Class: C-NSW
NH3-N (mg/1):
2.0 4.0
4.0
8.0
Sub -Basin: 03-06-02
TN (mg/1):
monitor montior
monitor
monitor
TP (mg/1):
2.0*
2.0*
Reference USGS Quad: C 19 SE (please attach)
Fecal Coliform (/100ml):
200 400
200
400
Residual Chlorine (ug/1):
21
21
County: Guilford
Sulfides (lbs/day):
36 72
36
72
Phenols (lbs/day):
18 36
18
36
Regional Office: Winston-Salem Regional Office
Chromium (lbs/day):
0.66
0.66
Ex Date: 1/31/96 Treatment Plant Class:
p•
(ug/1):
ChrPrevious
Lead
Lead (ug/1):
63
32
63
32
Arsenic(ug/1):
63
63
Classification changes within three miles:
Copper (ug/1):
monitor**
monitor**
Nav,, :
Nickel (ug/1):
Zinc (ug/1):
monitor quarterly
monitor**
monitor quarterly
monitor**
Chloride (mg/1):
monitor quarterly
monitor quarterly
r,
Flouride (mg/1);
2.3
2.3
j ► �)
*Limit is quarterly average
based on weekly samples
Requested by: Susan Wilson `��Date: 9/5/95
**Parameters for which no
monitoring frequency is specified should be monitored at
standard frequencies determined by the treatment plant class.
Prepared by: Date: Comments:
Reviewed by: ' Date: °
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Page 5

Frtm: Jim Eakzr ChemTreat at: Cone Mills Corporation Jlm's office .Mocksvllle Page 6 of 6 Monday, July 24, 1995 1:MPM To: John Hodges
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_ Additional
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Page 5

North Carolina
Cooperative Extension Service
NORTH CAROLINA STATE UNIVERSITY
COLLEGE OF AGRICULTURE & LIFE SCIENCES
Department of Biological and Agricultural Engineering . Box 7625 • Raleigh, NC 27695-7625 • Tel: [phone] • FAX: [phone]
E-mail: [e-mail]
Office: 919/515-6791
FAX: [phone]
Mr. Arthur Toompas
Cone Mills Corporaton
1425 Maple Street
Greensboro, NC 27405
Dear Mr. Toompas:
Re: Comprehensive Nutrient Management Plan for Land Application Activities at the
Guilford County Prison Farm
The by-product streams serving as nutrient sources at the Guilford County Prison facility
include the domestic wastewater generated at the prison, the animal waste and manure
generated by animal operation at the Guilford County Prison Farm, and the treated biosolids
generated at the Cone Mills facility, in Greensboro, North Carolina. These materials must be
managed in accordance with guidelines promulgated by both federal and state regulatory
agencies.
The development of a comprehensive nutrient management plan must be based upon the
potential nutrient removal capacity or assimilative capacity of the crops grown on the site. The
existing cropping system consists of a mix of row crops and pasture crops. Corn and small
grain, soybeans, fescue and Coastal Bermudagrass pasture all serve as receiver crops at the
Guilford County Prison Farm. The potential for nutrient removal must be based upon realistic
crop yield or goals. The corn and small grain crop can remove up to 2001bs of nitrogen per acre
per year per bushel anticipated yield while soybeans can utilize 3 to 5 lbs of nitrogen per bushel
per acre per year. Soybeans also fix nitrogen and return nitrogen to the soil so this nitrogen
requirement must be discounted.
The land area required to assimilate nutrients must be based upon both the quality or
characteristics of the material to be land applied and the volume of material to be land applied.
These waste generation characteristics are superimposed over crop and soil characteristics to
determine land area requirements necessary for assimilation. In support of this project, samples
of the liquid waste from the two storage lagoons holding by-product from the Cone Mills facility
were collected and analyzed. The report which follows attempts to balance the nutrient sources
with the nutrient assimilative capacity on the Guilford County Prison facility.
Employment and program opportunities are offered to all people regardless of race, color, national origin, sex, age or handicap.
North Carolina State University, North Carolina A&T State University, U.S. Department of Agriculture, and local governments cooperating.

Page 2
It has been a pleasure to work with you and your staff in preparation of this report and
I look forward to working with you in the future.
Sincerely,
6) � /14� 2-- - C �
A.R. Rubin, Extension Specialist
Associate Professor
Biological & Agricultural Engineering
rubin\letters\toompas

Nutrient Management
Cone Mills Biosolids Program
Guilford County, NC
The Cone Mills Facility in Greensboro, North Carolina utilizes a portion of the land at
the Guilford County Prison Farm for a nondischarge treatment program to managed the
biosolids generated at the Greensboro Facility. The Cone Mills Facility in Greensboro transports
their treated stabilized biosolids to the Guilford County Prison Farm for utilization as a nutrient
source for crop production. These nutrient sources are stored in lagoons at the Guilford County
Prison Facility where they may be combined with a small portion of farm waste and these
materials are then applied to agricultural land.
The Guilford County Prison Farm contains approximately 800 acres of agricultural land.
The site contains both pasture crops and row crop areas. There are some questions regarding:
a) the nutrient assimilative capacity of the Guilford County Prison Farm; and b) its ability to
assimilate the nutrients generated by Cone Mills and farm waste generated on site. The purpose
of this brief report is to assess the various nutrient sources available from Cone Mills, Inc., and
to determine the land area requirements necessary for their assimilation. In determining these
requirements, the volume of animal waste and human waste from the Guilford County Prison
Farm is not included. The land area required to assimilate those nutrient sources are the subject
of a second report.
The volume of material transported to the Guilford County Prison Farm from the Cone
Mills Facility is 9 million gallons per year. This volume of liquid is determined by the
nondischarge permit issued in accordance with the provisions contained in 15A NCAC .0200.
Waste Characterization
Samples of the liquid waste from the "farm pond" and the "pasture pond" were collected
and analyzed to determine their nutrient and metal levels. These ponds contain primarily the
residuals from the Cone Mills Processing Facility in Greensboro, North Carolina. The volume
of material is 9 million gallons per year. The waste was found to be dilute and to contain low
concentrations of nutrients and regulated metals. Table 1 attached summarizes the nutrient
concentrations in these lagoons. For purposes of these calculations, the 9 million gallons per year
volume of material transported to the Guilford County Prison Farm was divided into equal
portions. One volume is transported to the pasture pond and the other to the "farm pond."
Nutrient content is based upon 4.5 million gallons transported to each pond. Table 1 then
summarizes the nutrient sources from the Cone Mills Facility in Greensboro, North Carolina.
The materials to be land applied are not toxic and not hazardous are well suited for application
to agricultural land. In addition to the nutrient testing, samples of these materials were
examined to determine the levels of potentially pathogenic microorganisms. Samples were
analyzed to determine levels of Coliform bacteria, Salmonella, and Helminth ova. No Helminth
ova were found. Salmonella levels were measured at 330 per gram and coliform levels were
13,000 per gram. The Class B pathogen reduction levels established by the United States
Environmental Protection Agency indicate that Class B pathogen reduction level are achieved
with Coliform levels below 2 million. These materials do meet pathogen reduction requirements
established by the U.S. Environmental Protection Agency for Class B biosolids. Metal content
is low and these materials may qualify as "clean" biosolids.

Site Assimilative Capacity
The assimilative capacity of the receiver sites is determined based upon the nutrient
uptake of the various crops grown on the site. The approximately 450 acres of farm land at the
prison Facility is made up of both row crops and pasture crops. Pasture crops cover
approximately 300 acres of the site. Row crops cover the remaining 150 acres. The pasture sites
are capable of producing up to 5 tons of forage per acre per year. These forage yields are based
upon measured crop response to waste application events. The combination of irrigation and
nutrient application does render these sites very productive agriculturally. The forage crops are
capable of removing 40 to 50 lbs of nitrogen per acre per year per ton yield. The 5 tons of fescue
grass harvested are capable of removing between 200 and 250 lbs of nitrogen per acre per year.
For purposes of these calculations, a median 225 lbs of nitrogen per acre per year crop
assimilative capacity is used. The land area required to assimilate the nitrogen contained 9
million gallons of treated biosolids from the Cone Mills Facility are :
Pasture: 4.5 MGY x 8.34 [.5 (1384 mg/1 TKN-23.4 mg/1 - NH3) + .5 (23.4) + 67.8 mg/l NO31
Farm: 4.5 MGY x 8.34 [.5(1214-14.9) -.5 (14.9) + 51.5] = 24717.3 lb-PAN/Y
Total: 28515.3 lb - PAN + 24717.3 lb - PAN
225 lb - PAN/AC/YR = 236.6
Similarly, the 9 million of material will contain approximately 67,000 lbs of phosphorus.
Phosphorus too must be assimilated at agronomic rates. Phosphorus is both utilized by plants
and stored in soil. Phosphorus assimilative capacity can be as high as between 200 to 400 lbs
per acre per year. If conservative phosphorus loadings are utilized, then the land area required
to assimilate the phosphorus from these ponds is calculated as:
Farm: 31833 lb-P/yr
200 lb-P/ac/yr = 159.2 ac.
Pasture: 36048.8 lb-P /yr
200 lb-P/ac/yr = 180.2 ac.
Total = 339.4 ac. (say 350 ac.)
The most limiting of the constituents does appear to be phosphorus. The land area
required to assimilate the approximately 70,000 lbs of phosphorus generated at this Cone Facility
is approximately 350 acres. This land mass is the largest of the land area requirement necessary
to assimilate the waste constituents.
The metal loadings contained in the material are low. The most restrictive of the
regulated metals contained in this material is copper. The copper level detected is below the
pollutant level established by the U.S. Environmental Protection Agency as critical. If these
were municipal biosolids, these materials would "qualify" as exceptional quality product because
of these low metal levels. Nonetheless, metal loadings should be restricted to the maximum
cumulative pollutant loading as listed in the EPA 503 regulation. These maximum levels are
included as an attachment to this report.

The land area required for assimilated the 9 million gallons of liquid based on the
phosphorus concentration is approximately 350 acres per year. The 9 million gallon load applied
to 350 acres suggests that the annual load should not exceed 26,500 gallons per acre per year.
This is equivalent to approximately 1 inch per acre per year.
The nutrient concentrations must be monitored closely. If the nutrient values are less
than those reported in this text, then loadings could be higher. Similarly, if the nutrient values
are higher than those reported herein, then loadings should be reduced to insure that this land
application program remains agronomically sound.
The EPA regulations also mandates monitoring frequencies for municipal biosolids
program. Although this material is not a municipal biosolids, the same criteria for testing should
followed. The 9 million gallons of product generated per year constituents approximately 750
dry tons at 2% solids.
9 MGY x 8.34 lb/g x .02 = 750.6 (say 750 tons)
2000 lb/t
The EPA monitoring frequency for municipalities generating from 360 to 1500 dry tons of
product per year is 2 sampling events per year. Clearly, this is a minimum and quarterly
sampling should be accomplished to insure that the quality of these biosolids remain reasonably
constant and to insure that this program remains agronomically sound.
The biosolids analysis also indicates that the potassium is low in this material. Agricultural
crops do require significant quantities of potassium to support the development of root and
stem. The approximately 26,000 pounds of potassium contained in this 9 million gallon per year
biosolids load will supply approximately 75 lbs of potassium per acre. Optimum load of
potassium for the cropping system proposed is 100 lbs per acre per year. The site should be
supplemented with approximately 25 lbs of potassium per year per acre.
Waste Application Operation
The approximately 9 million gallons of liquid applied is generated throughout all seasons of the
year. Cropping systems onsite do not require nutrients during fallow seasons. Consequently,
the operator must store material for short periods of time when nutrient requirements are
minimum. Row crops generally require nutrient application approximately 30 to 60 days prior
to planting and immediately after germination. Pasture crops can tolerate nutrient application
during most seasons of the year, but during cold winter months most pastures go dormant and
nutrient requirements are minimal. Consequently, nutrients should be applied to pasture lands
during the spring, summer, and early fall. These nutrients should be applied agronomically to
row crop lands prior to planting in the spring immediately after harvest in the fall. These fall
application events on row crop land should be followed by seeding the receiver sites with small
grains such as wheat, barley, oats, or other small grains suitable for growth.
The material to be land applied can be applied directly to the land surface or can be applied
3

directly to the land surface and likely disked. This method of waste application promotes the
mineralization of the nitrogen, but facilitates the loss of ammonium. The direct incorporation
of these materials insures that all nutrients applied to the site remain on the site. If these sites
were nitrogen limited, then surface application would be the method of choice. Because the site
is phosphorus limited, light disking onto row crop lands and surface application on pasture sites
are the methods of application of choice to insure that phosphorus is incorporated into the soil
and does not exit through sediment loss. A no till operation which minimizes any site
disturbance will help to insure that phosphorus remains on -site and is not lost through erosion.
Conclusion
The industrial biosolids transported from the Cone Facility in Greensboro, North
Carolina Guilford County Prison Farm can be assimilated on approximately 340 acres of land.
The ideal combination of lands contains a mix of row crops and pasture crops. Material should
be applied to the ground surface on the pasture crops and may be either surface applied or
lightly incorporated on row crop sites. The material is dilute but can be a valuable nutrient
source supporting the agricultural operation on the Guilford County Prison Farm.
rubin/reports.dir/ conemills
4

Biosolids Quality and Nutrient or Metal Content
in Farm Pond' and Pasture Pond2, Cone Mills, and
Guilford County Prison Farm Facility
Constituent
Concentration
Mass/4.5 mg (1)
Concentration
Mass/4.5 mg (2)
TKN (mg/1)
1214
N/A
1384
N/A
NH3-N (mg/1)
14.9
N/A
23.4
N/A
NO3-N (mg/1)
51.5
N/A
67.8
N/A
PAN (mg/1)
658.6
24717.3
759.8
28515.3
TP (mg/1)
848.2
31833.0
961.3
36048.8
K (mg/1)
334.2
12532.5
369.6
13747.5
Ca (mg/1)
236.4
8865
271.3
10173.8
Mg (mg/1)
32.1
1203.8
35.2
1320
Na (mg/1)
618.2
23182.5
556.3
208613
SAR
Pb (mg/kg)
8.3
311.3
11.4
427.5
Zn (mg/kg)
7.4
2715.0
101.2
3795
Cu (mg/kg)
63
2362.5
33.2
1245
Ni (mg/kg)
3.2
120
5.7
213.8
Cd (mg/kg)
<.5
18.8
<.5
18.8
Cr (mg/kg)
<.5
18.8
<.5
18.8

II.
ENGINEERING ECONOMICS ALTERNATIVES ANALYSIS
A. Cone Mills - Greensboro Facility
Guilford County
Upland Drive Extension
Arthur J. Toompas - Manager of Water &
Ai
Cone Mills Corporationr Resources
1201 Maple Street
Greensboro, NC 27405
[phone]
B. The facility is not proposed, it is existing.
It consist of screening, equalization, pi;
neutralization, extended aeration activated
sludge, clarification, polymer coagulation and
flocculation, clarification, chlorination,
Polishing pond, and reaeration prior to
discharge to North Buffalo Creek.
C. The White Oak Plant of Cone Mills Corporation is
served by this wastewater treatment facility.
D. The plant has a flow limitation of 1.1 MGD at
Present and proposes to go to 1.25 MGD. This
small increase is expected to have minimal affect
on the treatment system and the receiving stream.
A. 1. City of Greensboro sewer system has a line running
through the waste treatment plant property.
Capacity of the City treatment plant does not
allow for connection of this discharge. Pilot
tests were conducted and City and their
consultants concluded that this was not possible.
2. Textile processing, dyeing and finishing
wastewaters are not suitable for subsurface
disposal and should not be permitted for this type
system.

a.
Engineering Economics Alternatives Analysis
.Page 2
3. Spray irrigation land is not available. The
treatment plant lies within the City of Greensboro
in an area bounded by North Buffalo Creek,
streets, and a residentialAevelopment. Currently
the digested sludge is land applied very
successfully, however, the;ttansportation of
biosolids is reasonable but transportation of
effluent is not possible.
B• None of the three alternatives are feasible.
C. 1. Discharge is presently to North Buffalo Creek and
it is proposed to continue at the same point
through the same discharge system.
2. Land is presently owned on both sides of the
stream by the Permittee.
A. N/A
B. 1. Already existing
2. N/A
3. Based upon the last year of operation the costs
were $1,183,000 for an average cost of $3.21 per
1000 gallons. We expect these costs to average
at approximately the increase found in CPI.
C. N/A
D. N/A

DIVISION OF ENVIRONMENTAL MANAGEMENT
December 5, 1995
MEMORANDUM
TO: Dave Goodrich
Steve Mauney
FROM: Jason Doll GoJ
THROUGH: Carla Sanderson(
SUBJECT: Revised Limits for Permit Renewal
Cone Mills Discharge (NPDES #NC0000876)
Guilford County
As per our December 5 meeting with Steve Tedder and the recommendations of the
Winston-Salem Regional Office, the Cone Mills NPDES permit should contain a second
effluent limits page with the following revised limits for BOD5:
Summer Winte
Monthly Avg. Daily Max. Monthly Avg. Daily Max.
BOD5 (lbs/day): 50 100 100 200
BOD5 (mg/1): 5 10 10 20
The revised limits should be scheduled to take effect 3 years after issuance, with limits for
all other permit parameters remaining unchanged.
The required decrease in BOD5 load, is based on documented. water quality
problems in North Buffalo Creek. Evaluation of instream self -monitoring data from Cone
Mills and the Greensboro - N. Buffalo Creek WWTP has shown frequent and ongoing
violations of the 5.0 mg/l water quality standard for instream DO, with reported DO levels
occasionally less than 2.0 mg/l. Furthermore, the instream DO profile depicted by the self -
monitoring data (attached), although somewhat rougher, closely resembles the DO profile
predicted by the QUAL2E model developed for Buffalo Creek as part of the Cape Fear
Basinwide Management Plan (refer to separate report).
As we have pirviousiy Uis(:usscii, dic i cid t dbjidiv 1 QLjA.LGi. 11-it-MiCl PIC-L-1l.LJ C
dramatic over -allocation of assimilative capacity for oxygen demanding wastes in the
Buffalo Creek system. The instream data reaffirms the model's prediction and emphasizes
Cone Mill's significant contribution to the over -allocation and subsequent degradation of
North Buffalo Creek. The two factors combine to create a compelling rationale for
reduction of Cone's allocation. It should be mentioned that the most beneficial scenario, in
terms of water quality, would be the elimination of Cone's discharge through connection to
the City of Greensboro's sewer system. It is my understanding that the City has expressed
willingness to accept Cone's waste stream if Cone can achieve a significant and consistent
reduction in effluent toxicity. If you have any questions or require any further information
in this matter, please do not hesitate to contact me.
cc: Ron Linville - Winston-Salem Regional Office
Steve Bevington - Instream Assessment
Larry Ausley - Aquatic Toxicology
Central Files

Cone Discharge
10
9
8
7
6
co
E 5
O
4
3
2
1
0
c
L
1
Ischarge
DO PROFILE
North Buffalo Creek
2 3 4
STREAM MILE
Jun '94 —0 Jul '94 A Aug '94
5
19
11

NORTH CAROLINA DEPARTMENT OF ENVIRONMENT
HEALTH AND NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL MANAGEMENT
M E M O R A N D U M
951102
TO:Jason Doll
THROUGH:Steve Mauney
FROM: Ron Linville
DATE:951102
SUBJECT:Cone Mills Permit Renewal
Wasteload Allocation Comments
NPDES Permit NC0000876 Guilford County
The WSRO recommends that Part III-G be utilized in the current
Permit during the renewal in order to reduce known impacts to
North Buffalo Creek. The following scenario is presented for
your consideration:
1. Renew Cone's Permit with 2 sets of limits pages. The
first set should continue existing limits for a period of roughly
3 years. The second set of limits would begin 2 years prior to
Permit renewal and would contain stricter limits. This should
provide a reduction of impacts to the stream down the road and
provide the corporation time to plan the necessary improvements.
This process may also provide an additional incentive for the
corporation to connect to the POTW as a pretreatment facility.
2. The second set of limits should reduce Cone's Permit
limits by 50% or provide for 5/2 limits in order to address "the
onset of problem conditions in the receiving waters".
3. As an incentive to the City of Greensboro, the WSRO
recommends that the North Buffalo WWTP (NB WWTP)be provided with
an additional limits page which would give Cone's flow (with
restrictions that it can only be utilized for Cone) to the City
POTW. It should be stipulated in the City's Permit that no limit
changes will occur at this time; however, stream conditions will
continue to be monitored after Cone ceases to discharge. The
City's Permit should stipulate that the next renewal period may
activate the appropriate Permit condition reopener if problems
persist in North Buffalo Creek.
If stream conditions improve during the new Permit period,
we will have accomplished our goal of preserving (and possibly
improving) water quality in the basin. The City will also have
an incentive to provide the best treatment possible during the
next 5 years. Thank you for your consideration and assistance on
this matter.

: S D .
Facility Name:
NPDES No.:
Type of Waste:
Facility Status:
Permit Status:
Receiving Stream:
Stream Classification
Subbasin:
County:
Regional Office:
Requestor:
Date of Request:
Topo Quad:
FACT SHEET FOR WASTELOAD ALLOCATION
Cone Mills - White Oak Plant
NC0000876
90% Industrial, 10% Domestic
Existing
Renewal
North Buffalo Creek
C-NSW
03-06-02
Guilford
Winston-Salem
Susan Wilson
9/5/95
C19SE
Wasteload Allocation Summary
(approach taken, correspondence with region, EPA, etc.)
Request #
C C' T 2 6 19M
'_ M
8349
_.. '
!VED
ristic: estimated from
USGS #
0209518100
Date:
3/93
Drainage Area (mi2):
14.7
Summer 7Q10 (cfs):
0.5
Winter 7Q10 (cfs):
1.4
Average Flow (cfs):
13.2
30Q2 (cfs):
1.5
IWC (%):
79
A field calibrated QUAL2E model of North and South Buffalo Creek developed for the Cape Fear
Basin Plan has indicated an over -allocation of assimilative capacity in this system. Available
instream data supports the model predictions. Upstream data from the Greensboro - N. Buffalo
WWTP shows frequent and ongoing violations of the 5.0 mg/l instream DO std. which can be
directly attributed to the Cone discharge (see attached memo). The Division should continue to
aggressively pursue all ongoing efforts to eliminate the discharge via connection to the Greensboro
sewer system. If the connection does not occur, any future expansion of the Cone discharge, if
permitted, will be very likely to receive more stringent treatment limits, as deemed necessary to
prevent water quality violations. Please note changes in limits and monitoring for toxicants and
additional instream monitoring requirements in this renewal. Please see Special Instructions or
Conditions section of this fact sheet.
Special Schedule Req
Reviewers:
­2 e- 7Z' S -� L ink 7'EgK ` Led �N %-- oC� /z��� 9
Recommended by: � Date: a 1
Reviewed by
Instream Assessment: Date: /o z 3 S S
Regional Supervisor: =� �� Date: -2 X�
Permits & Engineering: `� Cam" Date: / I �S
RETURN TO TECHNICAL SUPPORT BY: ''��

Recommended Limi
mm r
Winter
Monthly Avg.
Daily Max.
Monthly Avg.
Daily Max.
Flow (MGD):
1.2 ,
1.25
BODS (lbs/day):
100
200
200
400
BODS (mg/1):
10
20
20
40
TSS (lbs/day):
292
500
292
500
DO (mg/1):
6.0
6.0
6.0
6.0
pH (SU):
6.0-9.0
6.0-9.0
6.0-9.0
6.0-9.0
COD (lbs/day):
12,690
25,380
12,690
25,380
N1-13-N (lbs/day):
18.3
36.6
36.6
73.2
NH3-N (mg/1):
2.0
4.0
4.0
8.0
TN (mg/1):
monitor
montior
monitor
monitor
TP (mg/1):
2.0*
2.0*
Fecal Coliform (/100ml):
200
400
200
400
Residual Chlorine (ug/1):
21
21
Sulfides (lbs/day):
36
72
36
72
Phenols (lbs/day):
18
36
18
36
Chromium (lbs/day):
0.66
0.66
Chromium (ug/1):
63
63
Lead (ug/1):
32
32
Arsenic(ug/1):
63
63
Copper (ug/1):
monitor**
monitor"
Nickel (ug/1):
monitor quarterly
monitor quarterly
Zinc (ug/1):
monitor**
monitor"
Chloride (mg/1):
monitor quarterly
monitor quarterly
Flouride (mg/1);
2.3
2.3
*Limit is quarterly average based on weekly samples
**Parameters for which no monitoring frequency is specified should be monitored at standard
frequencies determined by the treatment plant class.
X Parameter(s) are water quality limited. For some parameters, the available load capacity of
the immediate receiving water will be consumed. This may affect future water quality based
effluent limitations for additional dischargers within this portion of the watershed.
No parameters are water quality limited, but this discharge may affect future allocations.
INSTREAM MONITORING REQUIREMENTS
Upstream Location: N.Buffalo Cr. 25 yds. above outfall
Downstream Location:N. Buffalo Cr. at #1) Summit Ave. #2) N. Buffalo WWTP Influent Conduit
Parameters: Temp., DO, Fecal Coliform, Cond., Lead, Arsenic
Special instream monitoring locations or monitoring frequencies:
1. Instream monitoring for lead and arsenic need only be performed monthly at upstream and
downstream #1 locations.
2. Downstream #2 site is contingent upon obtaining permission for access from the City of
Greensboro.

IP
TOXICS/METALS/CONVENTIONAL PARAMETERS
Whole Effluent Toxicity Test
Existing Limit:
Chronic (Ceriodanhnia), Quarterly P/F @ 79%
Recommended Limit:
Renew with existing limit
Monitoring Schedule:
Mar., Jun., Sept.,
Dec.
Existing Limits
Summer
Monthly Avg.
Daily Max.
Winter
Monthly Avg.
Daily Max.
Flow (MGD):
1.25
1.25
BOD5 (lbs/day):
100
200
200
400
BOD5 (mg/1):
10
20
20
40
TSS (lbs/day):
292
500
292
500
DO (mg/1):
6.0
6.0
6.0
6.0
pH (SU):
6.0-9.0
6.0-9.0
6.0-9.0
6.0-9.0
COD (lbs/day):
14,805
29,610
14,805
29,610
NH3-N (lbs/day):
18.3
36.6
36.6
73.2
NH3-N (mg/1):
2.0
4.0
4.0
8.0
TN (mg/1):
monitor
montior
monitor
monitor
TP (mg/1):
2.0*
2.0*
Fecal Coliform (/100ml):
200
400
200
400
Residual Chlorine (ug/1):
21
21
Sulfides (lbs/day):
42
84
42
84
Phenols (lbs/day):
21
42
21
42
Chromium (lbs/day):
0.66
0.66
Chromium (ug/1):
63
63
Lead (ug/1):
monitor quarterly
monitor quarterly
Arsenic(ug/1):
monitor quarterly
monitor quarterly
Copper (ug/1):
monitor quarterly
monitor quarterly
Nickel (ug/1):
monitor quarterly
monitor quarterly
Zinc (ug/1):
monitor quarterly
monitor quarterly
Chloride (mg/1):
monitor quarterly
monitor quarterly
Flouride (mg/1);
monitor quarterly
monitor quarterly
*Limit is quarterly average based on weekly samples
Limits Changes Due To: Parameter(s) Affected
Change in 7Q10 data
Updated application of fed. effluent guidelines X COD, Phenols, Sulfides
Relocation of discharge
Change in wasteflow
Updated toxicant analysis of effluent data X Pb, As, Cu, Zn, Flouride
Other (onsite toxicity study, interaction, etc.)

4
MISCELLANEOUS INFORMATION & SPECIAL CONDITIONS
Has the facility demg_strated the ability to meet the proposed new limits with existing treatment
facilities? Yes ✓ No
If no, which parameters cannot be met? iRQ-s e 7
Would a "phasing in" of the new limits be appropriate? Yes No
If yes, please provide a schedule (and basis for that schedule) with the regional
office recommendations:
If no, why not?
Special Instructions or Conditions
Since APAM requirement will be removed permit, due to regularly detected significant levels of
carcinogenic organo-bromide compounds (bromodichloromethane, dibromochloromethane,
bromoform and chloroform) in recent APAM sampling results, facility should be required to
perform annual EPA Method 624 sampling for volatile organics.
Wasteload sent to EPA? (Major) (Y or N)
(If yes, then attach updated evaluation of facility, including toxics analysis, modeling analysis if
modeled at renewal, and descriptio77or
fits into basinwide plan)
Additional Information attached? N) If yes, explain with attachments.
1. Memo regarding instream data and receiving stream impacts from Cone discharge.
2. Map of Buffalo Creek watershed with discharge points and monitoring sites indicated.
3. Graph of instream DO levels for Summer 1994.
4. Toxicity test fact sheet.

Facility Name (-,6.4e- A llS- LA I �c_ c W4 1jilf Permit # oo4>871., Pipe # �L
CHRONIC TOXICITY PASSIFAIL PERMIT LIMIT (QRTRLY)
The effluent discharge shall at no time exhibit chronic toxicity using test procedures outlined in:
1.) The North Carolina Ceriodaphnia chronic effluent bioassay procedure (North Carolina Chronic Bioassay
Procedure - Revised *September 1989) or subsequent versions.
The effluent concentration at which there may be no observable inhibition of reproduction or significant mortality
is -7cl 9b (defined as treatment two in the North Carolina procedure document). The permit holder shall perform
Quarterly monitoring using this procedure to establish compliance with the permit condition. The first test will be
performed after thirty days from the effective date of this permit during the months of
Effluent sampling for this testing shall be performed at the NPDES
permed final�effl�'discharge below all treatment processes.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form (MR-1) for the month in which it was performed, using the parameter code TGP3B.
Additionally, DEM Form AT-1 (original) is to be sent to the following address:
Attention: Environmental Sciences Branch
North Carolina Division of
Environmental Management
4401 Reedy Creek Road
Raleigh, N.C. 27607
Test data shall be complete and accurate and include all supporting chemical/physical measurements performed in
association with the toxicity tests, as well as all dose/response data. Total residual chlorine of the effluent toxicity
sample must be measured and reported if chlorine is employed for disinfection of the waste stream.
Should any single quarterly monitoring indicate a failure to meet specified limits, then monthly monitoring will
begin immediately until such time that a single test is passed. Upon passing, this monthly test requirement will
revert to quarterly in the months specified above.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of
Environmental Management 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 and appropriate environmental controls, shall constitute an invalid test and will require immediate
retesting(within 30 days of initial monitoring event). Failure to submit suitable test results will constitute
noncompliance with monitoring requirements.
7Q10 j) S cfs
Permitted Flow J. 25 MGD
IWC 71 %
Basin & Sub -basin -OCo- o�
Receiving Stream d
Lr-
County
•nRt • Me M,
Date o 1 C
AN-
QCL P/F Version 9191

i
DIVISION OF ENVIRONMENTAL MANAGEMENT
October 23, 1995
MEMORANDUM
TO: Susan Wilson
Steve Mauney
FROM: Jason Doll ?O
THROUGH: Carla Sanderson/
SUBJECT: Evaluation of Instream Self -Monitoring Data
& Adverse Impacts on the Receiving Stream
Cone Mills Discharge (NPDES #NC0000876)
Guilford County
As -part of the' wasteload allocation process or the renewal of the Cone Mills NPDES
permit, a thorough evaluation of available self -monitoring was conducted to quantify the
adverse impacts of the predicted over' -allocation of the North and South Buffalo Creek
system. Data from the Greensboro - N. Buffalo WWTP was included in the evaluation
since the facility's upstream monitoring site is about 1.5 miles downstream of the Cone
discharge (see attached map). The data showed regular and persistent violations of the
water quality standard for instream dissolved oxygen which could be directly attributed to
Cone.
On the attached graph of instream DO levels from summer of 1994, the Upstream and
Downstream i lines represent data from Cone's monitoring sites and the Downstream 2
line is actually from the N. Buffalo WWTP upstream monitoring site at their influent
conduit pier. Note that there is very;little variation in DO levels between the first two sites,
which may be explained by the fact that they are only 0.3 mi. apart, and with the
downstream site so close to the outfall, the temporary effects of effluent DO may still
persist. By the time it reaches the Downstream 2 site, 1.2 miles below Downstream 1, the
oxygen demanding component of the waste stream has had time to be more substantially
exerted, and the result is readily evident. Of 56 instream DO samples taken by Greensboro
from May - Sept., 1994, 34, showed DO levels less than 5.0 mg/1. In the same period
Cone reported no violations of the standard at their downstream monitoring site.
Particular notice should be given to'Cone's data from late July to late August. During
that period Cone reported DO levels from both sites consistently in the 9-12 mg/1 range,
with temperatures of 24-26' C. Such values, yielding DO saturation levels as high as
134%, are extremely unlikely for a low flow piedmont stream in the dead of summer and
are highly suspect. It should be noted that the available data from 1995 monitoring reports
appears to be more typical, but Cone reports no instream DO levels less than 6.0 mg/l,
while Greensboro has recorded 16 of 38 values less than 5.0 mg/1 just downstream.
In order to better address the disparity of values between these sites, I recommend
that, if possible, a member of the regional office staff accompany the Cone and City of
Greensboro sampling personnel during an instream monitoring run. This would give the
Division the opportunity to more effectively judge the validity of data by evaluating such
factors as the calibration of meters and sampling protocols utilized. It would also allow us
to determine first hand if stagnant conditions exist in the stream at any of the sampling

locations. Stagnant, pooling conditions, if they exist, could be an explanation for the
unusually high instream DO values reported, due to temporary super saturation resulting
from algal activity. In addition, Cone should be informed, in the permit renewal process
and/or by the regional office, that instream data from the City of Greensboro has
documented ongoing degradation of the receiving stream that can be attributed directly to
the Cone discharge, and that data from upstream monitoring at the N.Buffalo WWTP will
continue to be utilized to evaluate the impact of their discharge.
Allocation runs of the field calibrated QUALM model developed for the Buffalo Creek
system, have shown that the best scenario for improving the degraded water quality
involves elimination of the Cone discharge by connection to the Greensboro sewer system
interceptor running through Cone's property. All possible efforts should be pursued to
mitigate Cone's effluent toxicity problems which pose the largest current barrier to
connection. Please let me know if there are any measures we can take in terms of the
wasteload allocation / permit renewal process to facilitate elimination of this discharge. In
light of the condition of the receiving stream, if no connection occurs, no future expansion
of the Cony; discharge should be permitted unless Cone's treatment system can be upgraded
to achieve a reduction in the currently allocated 100 lb/day monthly average load of BOD5.
If you need any further information, or have any questions or additional concerns in
this matter, please'do not hesitate to 'contact me.
cc: Dave Goodrich - NPDES Group
Larry Ausley - Aquatic Toxicology
Ron Linville'- Winston-Salem Regional Office
Central Files
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5/3/94
5/17/94
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6/16/94
6/23/94
6/28/94
7/1 /94
7/7/94
7/12/94
7/15/94
7/21 /94
7/26/94
7/29/94
8/4/94
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8/23/94
8/26/94
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10/2/95
Cone Mills, NC0000876
efflmts.876.cone
CONE MILLS, NC0000876
Effluent Guideline Limitations - 40 CFR 410.70 (Subpart G)
1Tvpe of Product Produced 11000 lbs/day prod. mon. av
Stock and Yarn Finishing 300
Summary
Effluent Parameter
EPA Limitations in 40 CFR
Ibs/1000 Ibs ofproduct)
Effluent Limits
Ibs/da
Comments
Daily Maxi
30 day avg.
Daily Maxj
30 day avg.
BOD5
6.8
3.40
2,040
1,020
BAT
COD
84.6
42.30
25,380
12,690
BAT
TSS
17.4
8.70
5,220
2,610
BAT
Sulfide
0.24
0.12
72
36.0
BAT
Phenols
1 0.12
0.061
36
18.0
BAT
Total Chromium
1 0.121
0.061
361
18.0
BAT
H
1 6.0-9.0
6.0-9.0
6.0-9.0
6.0 - 9. 01
BPWTT
Permit application states 250,000 - 300,000 #/day produced.
Production numbers indicate 269,671 #/day (1993) and 265,129 #/day (1994)
These values are within 10% of 300,000 #/day.

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DTVISION OF ENVIRONMENTAL MANAGEMENT
September. 7, 1.988
u
TO: Steve Mauney
THRU: Trevor Clements'k
FROM: David Vogt? (V
SUBJECT: Instream Assessment for Proposed SOC: WQ # 88-33
Cone Mill Corporation, NC0000876, Guilford Co.
As a result of our meeting on 8-9-88 with representatives of the Cone
Mills Corporation, I believe that no instream assessment is required for
this SOC. This is because Cone has agreed to not pursue any additional flow
beyond their design capacity of 1.1 MGD.
As far as the question of the appropriate SOC limit for chromium, I
talked with Arthur Toompas recently and he stated that Cone no longer has
chromium in their effluent as a by-product. of their manufacturing process:
Thus, I feel that the permit limit of 0.56 l.bs/day and 61 ug/1 should be
more than adequate for this constituent.
If you desire further clarification of this matter, please call me at
(91.9) 733-5083, ext. 507.
DV/gh

cl _
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_

NORTH CAROLINA DEPARTMENT OF NATURAL RESOURCES AND
COMMUNITY DEVELOPMENT
DIVISION OF ENVIRONMENTAL MANAGEMENT
Winston-Salem Regional Office
July 22, 1988
M E M O R A N D U M
TO: Trevor Clements, Supervisor
Technical Services Group
THROUGH: M. Steven Mauney
Water Quality Supervisor,WSRO
FROM: A.R. Hagstrom I�,/(�.'o wa
Environmental Engineer
SUBJECT: In -Stream Assessment for the Discharge from the
Cone Mills Corporation's WWTP (Dye Plant), NPDES
Permit No. NC0000876 and proposed SOC, EMC WQ, No.
88-33
Please conduct an in -stream assessment for the subject
facility as part of the SOC evaluation. Provide a copy of
your results to Steve Reid, Compliance Group, and the WSRO.
ARH/pyp

rl _l C Uj Q 9 8 -33
Request Form for In -stream Assessment for 67B
(� Y'
NAME OF FACILITY l-0 � f- I' S �r�orh i b}'i SUBBASIN `A(�E C »
COUNTY Cj11,,, 1-6r d REGION LUS i2Q DESIGN FLOW 3.
RECEIVING STREAM 004-r44 5VrF, L-0 ci?6 ' K
�It� Prsc P r ein a 4. S -Fe-r rn i}. e r m I+ lak � n� C J V.d i c a ,E 4
BACKGROUND DATA :
A. Why is SOC needed? (Facility is out of compliance with which
effluent limits? Ther haoOxenh"irg4rokblt mee+� rj-k{,eir o14 Parmlt L;rmiltS
an*dl Miley wild baL)t mar—-}rowble ►ree����� -+ke. yt&W l im�+S • Som�c erpblems a efeoh +v
ba Slecsohr-1,am-& cr a s hctu4, bwn rocess waS-}e r0a+�•�Tht ?I"+- ►s old a�„%A haS
r,14,y uiA-crS - Pro blemE Qx� s+ wi tt-, 44D,S�TV ►J > aA TaXr c� �- y
B. History of SOC requests: NeMe +b 4x4 a,. Vie.y hawt uccess� � oe-
WniQ#}e,�ts-b�'ne��mr+1►rn'rfs sinm'Fa6um- 79j,-'ht14ij� 14Ab5 hn,.ea►jdc- {
e 1. Monthly Average waste flow / p1�a.+ •
prior to any SOC i� 2,2 (� ��z
mgd
p2. SOC flow added: Date: N01LIL.
f m- owe PetM4+V16W Date
40 mo
Date:
Pew FIa0AAj�+'cAa.�Q t�'onm«� i.IO (A6i)
total of previously approved SOC
3. Flows lost from plant
4. This SOC request
flow:
mgd
flow: mgd
f low: mgd
flow: (JDYl e
mgd
flow: Q o'YU mgd
f l ow: 1.1 C-yw mgd
S. Total plant flow post-SOC
(sum of original flow and
SOC flow minus losses) flow: ten ' mgd
* NP-") Qom; -�-- (. I mGJ) ) I -S m P6 s�oua aI(ow �Dr excrosj-"S.
,�} r 6. Is this an accurate flow balance for plant? Why/why not?
�nC Jlot,� �11ax'imlwY►1 ���^Q P2s } 12 Y -OIiAS � w
4. VA�x(, ,-S 4GA
�bo Ue 1. i O YY Ga b C�l 44— vy o omy-a-uerc s C'ItA we,1\ w k tR % n -t 4 Q
�raba�l� I;rn,r1aC� Swim S. Flow Sly, WW tak cam, \.5 Yv1�D�arSO�,
C. Please attdch DMR summary for past year for all permitted parame-
__ __tars.. If_possible, include reports from previous years if
facility has been under SOC for more than a year.
13o
l � �J" �c.Y►'1 .

C"L, 01,' Qo oca -�4&A(
THIS SOC s EMC—uJQ) M.- 3 3
A- Request is for domestic or industrial waste? if it is a combin-
ation, please specify percentages. Corvtb"Aa-* eil\
iaP"x. k 5 % 3a,—mi4 , $S% S'►1ALxs4r- a-Q- by "'o- .
B. What type of industry? Please attach any pertinent data.
aX-}" le , 61 ��,,�r�;h� , a�� ��hi51-�ir1 oL� n� +ex+ile oath �deMjM)
SOC° 's 22 III 2.z.g ►� 22.�� 22(� I
C. The region q proposes the followin30C limits:
m
low sons t$0966 3aa (oo0 16s� �^►Yn
S- NH31 �sx 1cr AWs icr Wet G vkA
I bs /cf c►� q�,,.�9� S�1�i4 a.Q
Cone G�oe,sn'� � no %,Om�rr• L _ . Ms/Q
b����,►�
—6 T s s �,92 3'DD 35a 700 t 6s
dal
fecal coliform I m00�2p0 /
O #/100m1
PH Cs +0 SU
Ch ro►►�1 •+n ' 47/.94- _
CorwP ovrt eAL m t%r-+
r
lc) d /a �. `r� �� os bares. w w07 —�
y
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40l
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bo

CONE MILLS CORPORATION
GREENSBORO, N. C. 27405
June 2, 1988
Mr. Paul Wilms
Department of Natural Resources and
Community Development
State of North Carolina
Division of Environmental Management
512 North Salisbury Street
Raleigh, NC 27611
Re: Special Order By Consent
Dear Mr. Wilms:
Pursuant to our last meeting, Cone Mills proposes the
attached Special Order By Consent with Interim Permit. With the
exception noted below, I believe that this Consent Order
formalizes our previous conversations on this matter.
We have, however, provided in paragraph 5 only that the
acceptance of the Special Order By Consent does not waive our
rights to appeal the new permit. It is our contemplation that if
you issue the new permit at the time of the issuance of the
Special Order By Consent with the interim permit, Cone Mills will
have to protest the same and request an adjudicatory hearing in
order to reserve our rights. However, we will would be willing
after such request was made, to agree to hold the matter in
abeyance until the term of the Special Order By Consent expired.
matter.
Please advise if you have any questions concerning this
Very truly yours,
a .
r'e�' 4 � /— —
Tom Alspaug
Manager, Air & Water Resources

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
COUNTY OF GUILFORD
IN THE MATTER OF )
NORTH CAROLINA )
NPDES PERMIT )
NO. NC0000876, )
HELD BY )
CONE MILLS CORPORATION )
GREENSBORO, NC )
SPECIAL ORDER BY CONSENT
Pursuant to the provisions of North Carolina General Statute
143-215.2, this Special Order of Consent is made and entered into
by Cone Mills Corporation, hereinafter referred to as the Company
and the North Carolina Environmental Management Commission, an
agency of the State of North Carolina created by NCGS 143B-282,
and hereafter referred to as the Commission:
1) The Company and the Commission hereby stipulate the
following:
a) The Company holds North Carolina NPDES Permit No.
NC0000876 for operation of an existing wastewater
treatment plant discharging into the waters of North
Carolina.
b) The Commission has offered to the Company a revised
Permit to be effective
c) The Company seeks a period of time to explore other
possible arrangements for discharge of its effluent
to the stream while maintaining appropriate water
quality standards, together with an interim permit
for such period of time.
2) The Company, in order to comply with the stipulations of
the Commission, agrees to the following:
a) The Company will negotiate in good faith with the City
of Greensboro, NC to discharge its wastewater into the
Municipal Wastewater Treatment Plant operated by the
City. The Company will as part of this negotiation
carry out all reasonable studies and investigations
required by the City to meet its standards for
discharging into the Municipal Plant.
b) If the Company is unable to enter into a satisfactory
contract with the City of Greensboro, the Company shall
explore flow augmentation and/or piping its effluent
down the river to a location where additional dilution
or reaeration is available.
c) The Company shall complete all studies and negotiations
necessary for resolution of its discharge conditions

within 1 year of the issuance of this Order.
3) The Company shall report to the Commission every two months
on the progress that has been made in resolving the
question of its discharge.
4) During the effective period of this Order the Company shall
be in compliance with the effluent limitations and
monitoring requirements contained in the interim permit
attached, hereto, as Attachment 1.
5) Acceptance of this Special Order of Consent by the Company
shall not constitute a waiver of any of its rights to
appeal or protest the issuance of the proposed new
permit.
6) This Special Order of Consent shall expire 1 year after the
date of issuance of the proposed Interim Permit.
Entered into this day of , 19
CONE MILLS CORPORATION, INC. N.C. ENVIRONMENTAL
MANAGEMENT COMMISSION
By: By:

MEMO.
Wiz
DATE: -
SUBJECT:
Cr, M, L L 1,44
��n = 4, q
1-1• 37 ,,E A)80D q,,?7 =
le 0
C"OD r3o
„a STATF4„
North Carolina Department of Natural
N
e.
Resources &Community Development

NORTH CAROLINA DIVISION OF ENVIRONMENTAL MANAGEMENT
WATER QUALITY SECTION / TECHNICAL SERVICES BRANCH
INTENSIVE SURVEY UNIT
3 MAY 1988
MEMORANDUM
TO: TREVOR CLEM
THRU: JAY SAUBER
FROM: HOWARD BRYANT (4 M 13
SUBJECT: CONE MILLS BOD (COMPOSITE UNINHIBITED) NC0000876 GUILFORD CO.
RECEIVING STREAM: NORTH BUFFALO CREEK SUB -BASIN: CPF02
DAY
BOD
NH3-N
TKN-N
NOX-N
TOT N
REPS
---
mg/L
----
mg/L
mg/L
mg/L
mg/L
#
0
------
0.64
------
5.8
------
0.03
5.8
----
1
13
8
4
37
8
5
43
2.4
6.8
0.02
6.8
7
10
69
2.3
6.0
0.05
6.0
7
15
93
6
17
100
0.11
3.9
2.3
6.2
6
20
108
5
25
117
0.05
3.1
3.9
7.0
5
30
123
4
33
127
4
39
132
0.19
3.9
4.4
8.3
4
45
138
3
52
145
3
56
149
3
60
152
3
65
156
3
70
160
3
75
163
3
80
171
3
Date Collected: 10/11 February 1988 (1030-1035) 24 hour composite
Collected By: Hagstrom/Mickey
Setup: 12 February 1988 (1440)
Cary Lab BOD-5: sample lost
ph: 8.1 5 drops sulfite/100 ml
100 o sample Seeded
20 % sample-BOD-5: 40 mg/L BOD-80: 158 mg/L (3 replicates)
100 % sample Unseeded BOD-5: 41 mg/L BOD-80: 170 mg/L (3 replicates)

NORTH CAROLINA DIVISION OF ENVIRONMENTAL MANAGEMENT
WATER QUALITY SECTION / TECHNICAL SERVICES BRANCH
INTENSIVE SURVEY UNIT
3 MAY 1988
MEMORANDUM
TO: TREVOR CLEMENTS
THRU: JAY SAUBER
FROM: HOWARD BRYANT %Jz. /2
SUBJECT: CONE MILLS
BOD (COMPOSITE
INHIBITED)
NC0000876
GUILFORD
CO.
RECEIVING
STREAM:
NORTH BUFFALO CREEK
SUB -BASIN:
CPF02
DAY
BOD
NH3-N
TKN-N
NOX-N
TOT N
REPS
mg/L
mg/L
------
mg/L
------
mg/L
------
mg/L
------
#
---
0
0.68
6.3
0.02
6.3
1
11
8
5
40
2.4
7.4
0.01
7.4
8
10
63
2.5
6.9
0.01
6.9
7
14
77
6
17
85
3.3
5.3
0.01
5.3
6
20
91
5
25
104
1.8
4.4
0.88
5.3
5
27
113
4
30
120
4
33
124
4
39
130
0.10
3.0
4.6
7.6
4
45
135
3
52
140
3
56
143
3
60
146
3
65
150
3
70
156
3
75
159
3
80
164
3
Date Collected: 10/11 February 1988 (1030-1035) 24 hour composite
Collected By: Hagstrom/Mickey
Setup: 12 February 1988 (1520)
Cary Lab BOD-5: 36 mg/L
pH: 8.1 Sulfite: 5 drops/100 ml
100 o sample Seeded

NORTH CAROLINA DIVISION OF ENVIRONMENTAL MANAGEMENT
WATER QUALITY SECTION / TECHNICAL SERVICES BRANCH
INTENSIVE SURVEY UNIT
3 MAY 1988
MEMORANDUM
TO: TREVOR CLEN�E�I�T�TS '
THRU: JAY SAUBE
FROM: HOWARD BRYANT
SUBJECT: CONE MILLS BOD (GRAB INHIBITED) NCOOOO876 GUILFORD CO.
RECEIVING STREAM: NORTH BUFFALO CREEK SUB -BASIN CPF02
DAY
BOD
NH3-N
TKN-N
NOX-N
TOT N
REPS
mg/L
mg/L
-----
mg/L
-----
mg/L
-----
mg/L
-----
#
----
---
0
----
0.64
6.6
0.02
6.6
5
38
2.0
7.4
0.01
7.4
8
10
59
2.4
6.5
0.01
6.5
7
14
73
6
17
80
3.6
6.3
0.01
6.3
6
20
86
5
25
94
3.7
6.9
0.01
6.9
5
30
100
4
33
103
4
39
ill
3.1
6.1
0.90
7.0
4
45
117
3
52
123
3
56
126
3
60
131
3
65
139
3
70
146
3
75
149
3
80
153
3
Date Collected: 11 February 1988 (1040) Collected By: Hagstrom/Mickey
Setup: 12 February 1988 (1610)
pH: 7.9 5 drops sulfite
Cary Lab BOD-5: 33 mg/L
100 o sample Seeded
20 % sample--BOD-5: 34 mg/L BOD-80: 127 mg/L (3 replicates)

NORTH CAROLINA DIVISION OF ENVIRONMENTAL MANAGEMENT
WATER QUALITY SECTION / TECHNICAL SERVICES BRANCH
INTENSIVE SURVEY UNIT
3 MAY 1988
MEMORANDUM
TO: TREVOR CLEM N
THRU: JAY SAUBER
FROM: HOWARD BRY
/d__A
SUBJECT: CONE MILLS
BOD (GRAB
SAMPLE UNINHIBITED)
NC0000876
GUILFORD
CO.
RECEIVING
STREAM: NORTH BUFFALO
CREEK
SUB -BASIN:
CPF02
DAY
BOD
NH3-N
TKN-N
NOX-N
TOT N
REPS
---
mg/L
mg/L
mg/L
mg/L
mg/L
#
0
----
-----
0.64
-----
6.4
-----
0.01
-----
6.4
----
5
41
2.40
6.9
0.01
6.9
8
10
62
2.30
6.4
0.02
6.4
7
14
77
6
17
91
0.55
4.2
1.4
5.6
6
20
100
5
25
ill
0.04
3.9
3.6
7.5
5
30
118
4
39
127
0.13
3.4
4.4
7.8
4
45
132
3
52
139
3
56
144
3
60
147
3
65
150
3
70
153
3
75
158
3
80
165
3
Date Collected: 11 February 1988 (1040) Collected By: Hagstrom/Mickey
Setup: 12 February 1988 (1525)
pH: 7.9 Sulfite: 5 drops/100 ml
Cary Lab BOD-5: test unsatisfactory
100 o sample Seeded
20 o sample-BOD-5: 40 mg/L BOD-80: 156 mg/L (3 replicates)
10 o sample-BOD-5: 42 mg/L BOD-80: 168 mg/L (3 replicates)

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PERMIT NO.: NCOOOU �76
NPDES WASTE LOAD ALLOCATION
Modeler Date Rec. #
FACILITY NAME: V1 LL,LLS 1 r 01)1�
Facility Status: PROPOSED
(circle one)
Permit Status: , MODERCATION UNPERNMED NEW
(circle one
Major Minor
Pipe No: Gd (
Design Capacity (MGD):
Domestic N of Flow):
Industrial (9r of Flow): /GO L
Comments: PC✓rsic"A Of
Z 4j�
RECEIVING STREAM: < �7* 6 C re
A)o i
Class: G
Sub -Basin: & 3
Reference USGS Quad: G _/�.SE (please attach)
County: �� -Q, j
Regional Office: As Fa Mo Ila Wa W1 WS
labels owe)
Requested By: ` = Ve'rUI� Date:
Prepared By:
Date:
Reviewed By: Vj "�'�'� L 9ate: �� 3—SR
Ov 2( t.^e cN'" &, 2-IF
(�. J t `^� 6 r:z( , _,6 U Lvw"
60 Q
�L �_ RL!�
Drainage Area (ml2 / ,7 Avg. Streamflow (cfs): ! R
7Q10 (cfs) 0 '&Winter 7Q10 (cfs) 7 30Q2 (cfs)
Toxicity Limits: IWC % (circle one) Acute / hA on
Instream Monitoring:
Parameters Le•�e��✓��
Upstream v Location .2-
Downstream �ocations
,-,� oell. J60 �1)j
S Q.vv e o
,Savr�yj .e/��se�e�
si
(a-fC. St- c x-fc-.t s i ds �
MY% 71 ,4 OQ('(4�-Je •
Effluent
Characteristics
Summer
Winter
BOD
lb
NH3"N
D.O. (mg/0
if s�Lt
67-9
•_
a,7 Quera
Cop
z9&lo
���✓1 �IA iC�NI tr i�.
� I .�W� Y' �� .
* ttax 7 c +C,st / ,Llj( 0_Cr7t a .¢,1V

r
ti 4
FOR APPROPRIATE DISCHARGERS, LIST COMPLETE GUIDELINE LIMITATIONS BELOW
Effluent Characteristics
Monthly rams
Average
Daily
Maximum
Comments
C�q
wo�
--�
3 aq S'
o
LI
Z
Type of Product Produced
Lbs/Day Produced
Effluent Guideline Reference
3 Sv oov
, 7 z /v,

gp
Rif
POR
ems■ ���...�.,'�� �'� �i�i-;.''� � - = v �1aw

T
Facility Name
1115
fTll11 # /(JG U 00(D E- 7(,
CHRONIC TOXICIT'y TESTING REQUIREMENT (QRTRLY)
The effluent discharge shall at no time exhibit chronic toxicity using test procedures outlined in:
I -) The North Carolina �ariodVbnia chronic effluent bioassay Bioassay Procedure - Revised *February 1987) or subsequent procedure�o (North
Carolina Chronic
The effluent concentration at which there may be no observable inhibition of reproduction or
significant mortality is �% (defined as treatment two in the North Carolina procedure
document). The permit holder shall perform r r
compliance with the permit condition. The firstIIt s�ll�benp�terrfform using
rer' � - ty from establish
issuance of this permit during the months of �. days
sampling for this testinEffluent
g shall be performed at the DES rm tted final effluent discharge below
all treatment processes.
All toxicity testing results required as pan of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the month in which it was performed, using the parameter
code TGP3B. Additionally, DEM Form AT-1 (original) is to be sent to the following address:
Attention: Technical Services Branch
North Carolina Division of
Environmental Management
P.O. Box 27687
Raleigh, N.C. 27611
Test data shall be complete and accurate and include all supporting chemicaUphysical measurements
Performed in association with the toxicity tests, as well as all dose/response data. Total residual
chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for
disinfection of the waste stream.
Should any test data from this monitoring requirement or tests performed by the North Carolina
Division of Environmental Management 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 and appropriate environmental controls, shall constitute an invalid test
and will require immediate retesting(within 30 days of initial monitoring event). Failure to submit
suitable test results will constitute" a failure of permit condition.
7Q 10 cfs
Pcrmited Flow !• / MGD
.Iwc%
Basin & Sub -basin
Receiving Stream -O - o z_
o
County
r�
Recommended by:
Date
**Chronic Toxicity (Ceriodaphnia) P/l= at /y1 a dw , --
— —, U lr-_ Scc l art J , Condition G-'
Sep , ---

i
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Ca„L be. Us Oj
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b� T hcrrasli 4c,en Uf73 /'hG.D /•J ✓�%C�D
clA
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IP S+r e avv� yw A ilo r j A
r -
5 �vcvt f t, b L � IOA r e"-( O[o e.5 40t t i z t 4'or p,7 iGC
IS Ivc I ncC, L.One 3
� a S 0. ✓1 I u e v.. C I t e / e, L vice 5 I e
C%�c W t 6LA, S (.!� s l,�u� e. G- t 5 I v c Q •�n rr� e M 14
1
01- �4 5e� 0V,, StS l.d►1� �/ ��s
H - cL S
vr: c� Su41MB /' Sece saw .
L,Lav2 1 �,� 5 4fcte,sl� ss- I�S��
o -F et en wo.2 / CL
II 11
1�owe e�'� e t S�' I- /r%2 Oy 1 G �ttifct.
S ln.rhi/ to if cS •�►� in C� Uvt 1:c
A v e ,-a i (I 6-vt, G ..3 � � S /� 2 0,D, .
vV

i.e.
14 V
Ca�J' � .296io
P%e�o .21 IfZ
Use �O-Ac- LIve1'ce, s h s reco.-►i.ne,7�
C
Nc. W Cad��-
,� P
Sew, nner Cc _ 50 305,
(7c,)fb = o.b cis 1-70
LS/d
C7glo = 1.7 cfg !. 70S'
V

r �
r�
�r
�' ..
r�
�r
�' ..

,
SUMMER
CONE MILLS/GREENSBORO
ALLOC RUN/LBDATA 21, CM_ALLOC
---------- MODEL RESULTS
Discharger : CONE MILLS CORPORATION
Receiving Stream : NORTH BUFFALO CREEK
______________________________________________________________________
The End D.O. is 5.09 mg/l.
The End CBOD is 12.17 mg/l.
The End NBOD is 5.45 mg/l.
______________________________________________________________________
WLA
WLA
WLA
DO Min
CBOD
NBOD
DO
Waste Flow
(mg/l) Milepoint Reach #
______ _________ _______
(mg/1)
____
(mg/1)
____
(mg/1)
__
(mgd)
------------
Segment 1
5.05 1.50 1
Reach 1
18.00
9.00
6.00
1.10000
Reach 2
18.00
9.00
6.00
16.00000
Reach 3
0.00
0.00
0.00
0.00000
Reach 4
0.00
0.00
0.00
0.00000

z•.g. MODEL SI.JC'11"IARY' DATA
Discharger a CONE" MILLS CORPORATION St_tt]basin : 030602
Receiving Stream : NOit_I_H BUFFALO 1_;RE_=E=K Stream C.::I.ass: C::--NSW
Summer- 7010 . 0.6 Winter 701.0 . 1..7
Design Temperature: 26.
1LEN6TH1 SLOPE! VELOCITY 1 DEPTH: Kd 1 Kd 1 Ka 1 Ka 1 KN 1 KN 1 KNR ! KNR I
: mile 1 ft/mil fps 1 ft !design: 120' !design: 320' !design! 320' :design! 120' :
Segment 1 1 1.70: 5.881 0.141 : 1.08 1 0.24 1 012 1 1.71 1 1.50: 0.48 1 000 1 OAS 1 0.00 1
Reach 1 1 : : 1 1 ! 1 1 1
-----------------------------------------------------------------------------------------------------
, i i i I ,
Segment 1 1 0.50! 2.861 0.651 1 1.68 1 0.32 ! 0.24 1 1.87 1 1.64: 0.48 ! 0.30 1 0.48 ! 0.00 1
Reach 2: 1 1 ! 1 1 I 1 I
-----------------------------------------------------------------------------------------------------
+
Segment 1 1 1.401 2.86! 0.616 1 112 1 0.31 1 014 1 107 1 1.551 OAS 1 0.30 1 OAS 1 0.00 1
Reach 3 1 I 1 1 1 1 I 1 1 1 ! : :
-----------------------------------------------------------------------------------------------------
Segment 1 : 1.601 2.86! 0.603 1 107 1 0Al 1 013 1 1.73 1 1.521 0.40 1 0.30 1 0.48 1 0.00 1
Reach 4 1 1 : 1 1 I 1 1 1 1 1 1 :
-----------------------------------------------------------------------------------------------------
1 Flow 1 C:; I=C OD 1
1 t_:'fi' S 1 t"i g/ 1 1
Segment 1. Reach .L
Waste 1 1.705 1 18.000 1
Segment 1. Reach 2
mg/1 1 mg/l 1
1..1:30 1 6.000
1.130 1 6.000
Tributary
1 0.000 1
0..000
1
0.000 1
0.000
* Runoff
+ 0.880
3.200
0.570 1
6.000
Segment 1
Reach :3
Tributary
1 0.900 1
3.200
1
0.570 1
6.00C)
* Runoff
1 2.460 1
3.200
1
0.570 1
6.000
Segment .L
Reach Li.
Waste
1 0.000 '
0.000
1
0.000 1
0.00C)
Tributary
1 0.730 1
3.200
1
0.570 1
6.00C)
* F:t_tnoff
1 2.820 1
:3.200
1
0..5:0 1
6.00
i
* Runoff flow is in cfs/mile

SUMMER
CONE MILLS/GREENSBORO
ALLOCATION/LBDATA 21, CM_ALLOC
---------- MODEL RESULTS ----------
Discharger : CONE MILLS CORPORATION
Receiving Stream : NORTH BUFFALO CREEK
______________________________________________________________________
The End D.O. is 5.09 mg/l.
The End CBOD is 12.17 mg/l.
The End NBOD is 5.45 mg/l.
______________________________________________________________________
WLA
WLA
WLA
DO Min
CBOD
NBOD
DO
Waste Flow
(mg/l) Milepoint Reach #
______ _________ _______
(mg/l)
____
(mg/l)
____
(mg/l)
__
(mgd)
__________
Segment
1
5.05 1.50 1
Reach
1
18.00
9.00
6.00
1.10000
Reach
2
18.00
9.00
6.00
16.00000
Reach
3
0.00
0.00
0.00
0.00000
Reach
4
0.00
0.00
0.00
0.00000

MODEL SUMMARY DATA
D i sch arcge-c : (:_C:iNE MILLS CORPORATION Sut: bas i n 030602
Receiving Stream . NORTH BUFFALO CREEK Stream Class: C--N W
Summer 7010 „ 0.6 Winter_ 7010 . 1.7
Design Temperature: 26.
;LENGTH; SLOPE; VELOCITY : DEPTH; Kd ; Kd ; Ka ; Ka ; KN ; KN ; KNR ; KNR
mile ; ft/mi; fps ; ft ;design; Z201 ;design; Z201 ;design; 1201 ;design; @201
i { 1 i { 1 1 , iI i {
1 1 i i 1 i i i 1
Segment 1 ; 1.70: 5.88; 0.141 ; 1.08 ; 019 ; 012 ; 1.71 ; 1.50; 0.48 ; 0.30 ; OAS ; 020
Reach 1 ; ; ; ; ; ; ; ; ; ; ;
i i i ,
-----------------------------------------------------------------------------------------------------
;
i i 1 i i i 1 1 i 1 i , 1 i , i
Segment 1 ; 0.50; 2.86: 0.651 ; 108 ; 0.32 ; 014 ; 1.87 ; Lai OAS ; 010 ; OAS ; 0.00
1 { 1 i 1 i I 1 I ! 1 1
Reach 2 , , i i i , i , , , i . 1
-----------------------------------------------------------------------------------------------------
i i i i 1 , , i I i 11
, i i i ,
Segment 1 ; 1.40: 2.861 0.616 : 132 ; 0.31 ; 0.24 ; 1.77 ; 1.551 0.48 ; 010 ; OAS ; 0.00 ;
Reach 3 ; ; ; ; ; ; ; ; ; ; ; ;
-----------------------------------------------------------------------------------------------------
1
Segment 1 ; 1.60; 2.86; 0.603 ; 117 ; 0.31 ; 013 103 ; L 2; OAS ; 0.30 ; OAS ; 0.00
Reach 4 ; ; ; ; ; ; ; ; ; ; ; ;
-----------------------------------------------------------------------------------------------------
F"Iow ; CttOD
cfs ; mg/I
Segment I Reach I
Waste ; 1..705 ; 19.000
Headwaters! 0.600 ; 3.200
Tributary ; ii„iit}r•'_? ; 0.000 ;
* Runoff ; 0.180 ; 3.200 ;
Segment I Reach 2
NBOD ; l.i . 0
m i-_1 / 1 ; m cg / 1.
1.130 ; 6.00C.)
0.000 ; 0.000
Waste
; 24. 800 ;
19.000 ;
9.000 ;
6.000
ribt_ttary
Tributary
; 0.000 ;
0.000 ;
0.000 1
0.000
* F?t..l'i7i-..Iff
; 0.880 ;
3.200 ;
0.570 ;
6.00(..)
Segment i
F•.i-.?ac.h 3
Waste
; 0.000 ;
0.000 ;
i}.rii}ii ;
0.000
Tributary
{ 9.....
, i_ ,. , i_, i_a
1
3.200
1
0.570
5 .:�}
s
C} i_.
* Runoff
; 2.460 ;
3.200 ;
0.570 ;
6.000
Segment 1
Reach 4
Waste
1 0.000 ;
0.000 ;
0.000 ;
0.00C)
Tributary
; 0.730 ;
3.200 ;
[a„;',=i70 ;
6.000
w ' Runoff
; 2.820 ;
3.200 ;
0.570 ;
6.00C)
iF Runoff flow is in cfs/mile

DIVISION OF ENVIRONMENTAL MANAGEMENT
October 30, 1987
MFMnP A MnT TM
TO: Arthur Mouberry
THRU: Trevor Clements P
Steve Tedder
FROM: David Vogt
SUBJECT: Comments on Cone Mill's Letter of October 8, 1987
I have reviewed the letter that Cone Mills wrote to the Director
concerning items that they disagreed with in the latest draft permit.
Trevor has asked me to address items 3, 4, and 5 and send my comments
to you for inclusion in their permit file. These are as follows:
Item 3: Interacting permittees were given equivalent wasteloads.
Although Cone Mills is ambiguous about who "all permits" is, I believe
they are referring to the 16 MGD Greensboro WWTP that is located
approximately one mile downstream from their outfall. We have not
yet implemented Greensboro's new limits because their permit comes up
for renewal in November, 1988. However, a memorandum was placed in
their file concerning the interaction between the two facilities and
suggested limits based on equal assimilative capacity (a complete
summary of applicable effluent limits is provided in the model output
summary that responds to item 5).
For oxygen -consuming waste, effluent statistics for the two
facilities are:
Model
Input
Corresponding
Limits
CBOD
NBOD
BODS
NH3 N DO
Greensboro (mg/1)
18
9
12
2� 6
Cone Mills (mg/1)
18
9
6
2 6
Cone Mills (#/day)
165
82.5
55
18.3 -
Since we model in CBOD and NBOD, you can see that Cone Mills and
Greensboro were assigned identical wasteloads. The difference
in the BODS limits is due to the CBOD/BODS ratio used to estimate
the conversion of BODS to ultimate CBOD. Because they have textile
waste that is fairly resistant to instream breakdown, Cone Mills
was assigned a CBOD/BODS ratio of 3 (see attached letter that was
copied to Dale or, 2-5-87), whereas Greensboro is a POTW and was
assigned the domestic waste CBOD/BODS ratio of 1.5.
Item 4: As per our Water Quality Regulations (NCAC 2B.0404 (c) ),
"summer" shall be April 1st through October 31st and "winter" shall
be November 1st through March 31st.
Item 5: See attached.

An important consideration in assigning Cone Mills the new, lower
limits was the fact that their downstream self -monitoring data document
instances of repeated DO violations in 1987. For instance, from July
20th through July 31st, all DO samples taken at the Highway 29 station
were below 5 mg/l. On 5 of these days, Cone Mills' effluent load was
at or below what we are proposing in their new draft permit.
If you need further assistance, please feel free to contact me.

CONE MILLS CORPORATION
GREENSBORO, N. C. 27405
October 8, 1987
Mr. R. Paul Wilms, Director
Division of Environmental Management
P. O. Box 27687
Raleigh, North Carolina 27611
Re: Comments on DRAFT NPDES Permit
Cone Mills Corporation
242U Fairview Street
Greensboro, NC 274U5
Guilford County
NPDES No. 0000876
Dear Mr. Wilms:
Following a detailed technical review of the
above -referenced permit for the Greensboro operation of Cone Mills
Corporation, we are of the opinion that we cannot accept it in its
present form because:
(1•) The permit does not contain an upset provision and
should provide such a provision;
(2) The permit should provide for weekly averages in
pounds and monthly averages in pounds for all
parameters in place of daily averages in pounds and
daily maximums in pounds;
✓ (3) All permits should have the same standards, for the
same stretch of stream, in a water quality stream.
Therefore, we suggest that limits as set forth on
the attached sheet entitled "Exhibit A";
✓ (4) Please note that in Exhibit A we request that
"summer" be defined as May through September and
"winter" be defined as October through April; and
'�(5) We request a copy of all modeling information for
our review.
As an alternative, we suggest that you extend the
present permit as an interim permit and leave the
199U.section alone .for the present. In the

Mr. R. Paul Wilms
October 8, 1987
Page 1
meantime, Cone Mills Corporation and your office
will carry out a joint study to determine if the
199U proposed permit numbers are rational and
justifiable.
If we cannot agree upon these permit provisions, we will
have no choice but to request a hearing before an administrative law
judge.
Yours very truly,
T. A. Alspau
Manager, Water & Air Resources
CBA:ms
cc: -Mr. Arthur Mouberry, DEM Raleigh
Mr. Larry Coble, Winston-Salem Regional Office
Mr. Ed Barnhart, Hydroscience, Inc.
Enclosure

BOD
TSS
NH3asN
Total Cr
COD
Su if ide
Phenol
BOD
TSS
NH3asN
Total Cr
COD
Sulf ide
Phenol
EXHIBIT A
Summer - May through September
Weekly Average lbs.
13/.6
500.0
55.0
1.12
29610
84.0
42.0
Monthly Average lbs.
91.7
292.0
3 6 . "1
U.56
14,8U5
42.0
21.0
Winter - October through April
Weekly Average lbs. Monthly Average lbs.
275.2 183.5
5UU 292
11U.0 73.4
1.12 0.56
2961U 14,8U5
84.0 42.0
42.0 21.0

P
lJor .1�)j 4J o C�ct ire
03
w t, 3 o r L 21-gl "7
C..onc M;I (s
qw= o Mc�D
M&P
# iton
fko�.o [S',?.70tZ 6/t7
TDV
1.7 c{S _G�oco U-),— 1 P
i�q = lip r{S = Ib M6 i)
i�oi•6Yr3. 35-"
3A = .2,2.
Q
57410 = o.ti c �S
W7410 = .2.1.c45
.2 cf v
it
�J q
k,.
IC z
f 3
S 7Q to Ad ���
0.1'� _
6.8t
.2.4(.
oaio f.o.� ,
-O-S-3
1.04
2.51,
c�
A �.o. Cam;)
5.2q
2.f-S-
7.q1
Trl S7QIo(c4)
-
-
0. 40
_. T- 6 Jv 7910--(t4S)
—
'-
1. 27
'-ir-6-Q^ (r-�i� -----
-
_-
.S510
late
-
2-iv4r
3.31
'r-47
0.73
1.03
a,
US crS
�N
.Q L
•1
-#62.6iys-. o aa�
ZV*4 = 37. 10 M; 1-
S7lrI•
W7(� to = 12. so eft SIQ,ZT3 Z
cfs

NPDES WASTE LOAD ALLOCATION
PERMIT NO.: NCOO Op giro
FACILITY NAME: Caaw mjuC."OtAlya.�
Facility Status: " PROPOSED
(circle one)
Permit Status: C� MODIFICATION UNPERhl=D NEW
(circle one)
Minor ✓ Minor
Pipe No:60 1
Design Capacity (MGD):
Domestic (% of Flow):
Industrial (% of Flow): 06'%
Comments: Ae j�s:e,, v{ woi 4 3611
__ iACPe-aSe ��o�
RECEIVING STREAM: Cd'«k
Class: C
Sub -Basin:
03-o(p-oi
Reference USGS Quad: C (`1 S� (please attach)
County: __ &IL&O
Regional Office: As Fa Mo Ra Wa Wi
(circle owe)
Requested By: Aye, +� Date: 6l2/87
Prepa
Revie
(f 1,01
_,D t ,
,"�U v U
sp
W
Modeler
Date Rec.
#
�bJ
1 b 3 -f7
1o� 1r
�/
Drainage Area (mi2 ) %T• Avg. Streamflow (cfs): /(
7Q10 (cfs) Winter 7Q10 (cfs) J'7 30Q2 (cfs)
Toxicity Limits: IWC 74 % (circle one) Acute <Chronic
Instream Monitoring:
Parameters _ eCrWl v"t-
_ �o _ 1r3oD5
Upstream '� Locations r A buvc ow'ft+�Gi'
Downstream t�Location(l) SUMMIT aye,7ve—
© 15r roJ C-Possi/3c
/b fk SL • ex flint ✓/
Effluent
Characteristics
Summer
Winter
B O D 5 (90-f, I S
Ss
/ 1 O
NHj N (04M WS
( T. 3
3(..(.
D.O. (mg/1) Q
G
S
T S S (TL" �
a I2
F. Col. (/100m1)
pH (SU)
(o _
%
AJ
a.11u cal.
J

/ .
' FOR APPROPRIATE DISCHARGERS, LIST COMPLETE GUIDELINE LIMITATIONS BELOW
Effluent Characteristics
Monthly Daily
Average Maximum V
Comments
i 14
So
-13SO
C„u fiAs Q s /Oo A. z,e A/J.
TO
vYs-
:ffs z z .A. Sbo Am.
�KAs
Zf
�f L
1L
stk
6-1 stA
Type of Product Produced
Lbs/Day Produced
Effluent Guideline Reference
�k at f ;
301 doe
/o z /o- -3

Request No. :4086
--------------------- WASTELOAD ALLOCATION APPROVAL FORM --
Permit Number
: NC0000876
Facility Name
: CONE MILLS CORPORATION
Type of Waste
: INDUSTRIAL
Status
: EXISTING
Receiving Stream
: NORTH BUFFALO
CREEK
Stream Class
: C-NSW
Subbasin
: 030602
County
: GUILFORD
Drainage Area
Regional Office
: WINSTON-SALEM
Average Flow
Requestor
: D. OVERCASH
Summer 7010
Date of Request
: 6-3-87
Winter 7Q10
Quad
: C 19 SE
30Q2
RECEIVED
N.C. Dept. NRCD
JUL 9 19@7
/ision:_t
Envr'n nnta|Mono8annen%
Winston-Salem Reg. Office
(sq mi) : 14.7
(cfs) : 16
(cfs>
((--fs) : 1.7
(cfs) :
------------------------- RECOMMENDED EFFLUENT LIMITS -..... .... ----------..... .... ..... ... ..... ..... -... ... ..... ...
-
:
Wasteflow (mgd):
5-Day BOD (#/day>:
Ammonia Nitrogen (#/day>:
Dissolved Oxygen (mg/l>:
TSS (#/day>:
Total Chromium (#/day):
pH (SU>:
*Other Limits Attached :
:
:
t
�—�
._
18.3
36'6
6
292
5
Sea zqz.
0.56
f)��'
6-9
6-9
PERMITS & ENGINEERING
--------------------------------- MONITORING ---------------
Upstrea(p (Y/N): Y Location HERN RR BRIDGE
/rl�
Downstream (Y/N): Y��vocat.on��)AVENUE /�tL J1� e^�~~"'
uu '~^ ,�°=^« C,~~--_( "^L '``---`rc
---------------------------------- COMMENTS ---------
TOXICITY TESTING REQUIREMENT ATTACHED.
RECOMMEND FACILITY MONITOR
)6 �
^�* ^=m&,tt � �� (~~' ����� `� ~��w��D
�V44 ����w��x °
, ��m�& ��� -`�, �-
Vm~., LL Col*v- ecb1plemri wj4A '\�ScviarA m1&ukok �� ��ww�m�)^ ~�
~�'�_
Recommended by
Reviewed by:
Tech. Gupport Supervisor
-��
n v Regional
Supervisor
Permits & Engineerinc�__��
/-
RETURN TO TECHNI
/
Date _��- I 7_:in
� __ Date _ _
Date
�*�C�=__ ___ Date __
��U� �� �00� -� ^
nn«�� ~= o�«»«

44 0 ghp
Cone Mills Corporation - Permit# NC0000876 - WLA#
BPT Limitations Under Federal Guideline #410.72(a)
Constituent
COD
Sulfide
Phenol
Monthly Average
14805 Ibs/day (2399 mg/I)
42 Ibs/day (6~8 mg/l)
21 %bs/day (3'4 mg/I)
Toxicity testing Tequirement attached.
Recommend facility monitor for zinc.
Maximum Daily Average
29610 lbs/day (4798 mg/l)
84 lbs/day (13'6 mg/l)
42 lbs/day ( 6.8 mg/l)

Facility Name �J'"L±Lo
Permit N /UG0000 p7—
TOXICITY TESTING REQUIRE:ME:NT
The effluent discharge shall at no time exhibit chronic toxicity using
test procedures outlined in:
1.) The North Carolina Ceriodaphnia chronic effluent bioassay proce-
dure (North Carolina Chronic Bioassay Procedure - Revised 'February 1987) or
subsequent versions.
The effluent concentration at which there may he no observable inhibi-
tion of reproduction or significant mortality is �e (defined as treatment
two in the North Carolina procedure document). The permit holder shall
perform monitoring using this procedure to establish compliance
with the permit ndition. The first rest will be performed within thirty
days from issua of this permit. Effluent sampling for this testing shall
be performed at the NPDF.S permitted final effluent discharge below all
treatment processes.
All toxicity testing results required as part of this permit condition
will be entered on the Effluent Discharge Monitoring Form (MR-1) for the
month in which it was performed, using the appropriate parameter code.
Additionally, DEM Form AT-] (original) is to be sent to the following
address:
Attention: Technical Services Branch
North Carolina Division of
Environmental Management
P.O. Box 27687
Raleigh, N.C. 27611
Test data shall be complete and accurate and include all supporting chemi-
cal/physical measurements performed in association with the toxicity tests,
as well as all dose/response data. Total residual chlorine must be measured
and reported if chlorine is employed for disinfection of the waste stream.
Should any test data from this monitoring requirement or tests per-
formed by the North Carolina Division of Environmental Management 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 docu-
ment, such as minimum control organism survival and appropriate environmen-
tal controls, shall constitute an invalid test and will require immediate
retesting. Failure to submit suitable test results will constitute a fail-
ure of permit condition.
7Q10 0.L cfs
Permited Flow L 1 MGD Recommended by:
Basin & Sub -basin/ -
Receiving Stream a feel(
County r --Date

DIVISION OF ENVIRONMENTAL MANAGEMENT
April 29, 1988
MEMORANDUM (1:nter.1cj)
TO: Steve Tedder
THRU: Trevor Clements
FROM: David Vogt V
SUBJECT: Joint Meeting to Discuss the Incorporation of Cone Mill's
Waste into the Greensboro Treatment System
Per your request, I attended a meeting held on 4-26-88 at the Osborne
Wastewater Treatment Plant to discuss the possibility of Cone Mill's tying
into the Greensboro treatment system. In attendance were representatives
from the City of Greensboro, their engineers: Hazen & Sawyer, and several
executives from Cone Mills. Representing DEM were Larry Coble and Steve
Mauney from the Winston-Salem Regional Office, Suzanne Hoover from
Pre-treatment, and myself (copy of attendance list is attached).
Numerous topics were discussed, but in this memo I will only address
those items that I feel are related in some way to Technical Services.
First, Greensboro is distressed by our toxicity testing program. They
feel that the chronic test is unreliable and can potentially penalize the
dischargers that are required to use it. Arthur White (City of Greensboro)
was especially vocal in registering his belief that the test is unreliable
and cannot produce similar results for split samples (i.e., when splitting
one sample into two, one test will fail, one will pass). Martie Groome
said that she will be sending a letter to you in the near future outlining
Greensboro's concerns about the test and also about using an unreliable
methodology to meet the toxicity limits that are going to be in their
renewed permit.
Regarding Cone Mills, Greensboro has numerous concerns about allowing
Cone into their treatment system, either at the North Buffalo facility
or the Osborne facility. Bob DiFiore (Hazen & Sawyer), said he did not
think that it was feasible to bring Cone into the North Buffalo plant
because that facility is nearing capacity. All of the Greensboro people
were quite concerned about the color in Cone's effluent. They said that
the local residents have historically been "riled up" about the black
color in the creek (from Cone's dye batch processes), and Greensboro does
not want that public resentment switched to them. Dals Chaudhary (Hazen &
Sawyer's New York office) said that he was quite familiar with textile
operations and that because the color is not sorbed onto particulate there
would be no effective way to treat it. Discussion then focused on the
Champion/Pigeon River color standard, with Greensboro being quite concerned
that a statewide color standard might be adopted by North Carolina sometime
in the future. Greensboro then asked Larry if he could get Paul to put in
writing that they would never have a color standard (someone broke into

the discussion and Larry did not give them an answer).
Regarding their upcoming permit renewal (11-88), Greensboro asked me
how the incorporation of Cone's oxygen -consuming waste would affect their
new limits. I told them that I could not give them a de facto answer, but
that two things would affect their limits. First, the removal of Cone's
discharge would eliminate the interaction of Greensboro's waste with an
upstream discharger, and, in my estimation, would thus give Greensboro an
increased wasteload allocation. However, this could be offset by the fact
that Cone's BOD waste is highly resilient, and therefore, if Cone did not
pretreat to a significant degree, a portion of that resiliency would be
introduced into Greensboro's effluent. This would subsequently increase
Greensboro's CBOD/BOD5 ratio, and hence, lower their BOD5 limits.
Cone pressed Greensboro throughout the meeting for an answer regarding
whether or not Greensboro would indeed accept them into the city's treatment
system. Greensboro's reply was that they could not make that decision
until after they had worked out phosphorus removal with Hazen & Sawyer.
Greensboro feels that, because of the new NSW regulations, redesigning
and/or retrofitting their treatment plants for phosphorus removal is their
first priority and they do not want to engage their consultant in other
engineering questions until that work has been completed. Hazen & Sawyer
replied that the phosphorus removal work would take a minimum of three
months.
From this joint discussion, and from private conversations afterward,
it is my opinion that Greensboro is going to be reluctant to allow Cone
into their system. Therefore, I suggest we issue the draft permit (copy
attached) and have Cone apply for an SOC if they cannot meet the new
limits. This would be in concert with what the Director told them about
having one year to get their problems resolved. Since they already have a
consultant working on this matter, a one year SOC should enable them to
either adopt more efficient production methods or upgrade their treatment.
Until 1988, their self -monitoring data showed that they could meet the new
limits. As Trevor discussed with you previously, Cone has maintained that
their effluent loading has recently gone up several magnitudes, and hence,
there is no way that they can meet the new limits. However, it is my
understanding that Cone has been laying off production workers at the
Greensboro facility; this hardly coincides with a large increase in plant
production.
In addition, I strongly recommend that the appropriate parameters in
the permit be in concentration -based limits as well as mass -based limits.
I have attached a copy of a previous memorandum on this subject.
Please contact me if you need further clarification on this matter.
JDV/jdv

a •
APk il- 2&, / 968
MQenE dP. mme Ci7y
J l ,A Cl� M Ee NA Zt--4 4W.D JA-W yE2
gar
C•*� o� C-rQensbo+-O
CAI-
R477-Ha Cs
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-71 7
47
CeL
L

DIVISION OF ENVIRONMENTAL MANAGEMENT
February 29, 1988
MEMORANDUM
TO: Trevor Clements
FROM: David Vogt
SUBJECT: Limits for Cone Mills Corporation - Greensboro (NC0000876)
Based upon the proposed Division procedure for determining whether
limits for industrial dischargers should be mass or concentration based,
the current proposed limits for the renewal of Cone Mill's permit should
be revised as follows:
Parameter Monthly Average Daily Maximum
Summer Winter -
BOD5 (mg/1) 6 12 -
NH3-N (mg/l) 2 4 -
Total Chromium (ug/1) - - 61
Dissolved oxygen, pH, TSS, COD, sulfide, and phenol do not require
revision.
JDV/jdv
Attachment
cc: Dale Overcash
Steve Mauney
Cone Mills WLA File
Central Files

� Y
North Carolina Division of Environmental Management
Water Quality Section / Intensive Survey Group
�i71 MM"
To: Ruth Swanek
Through: Jay Sauber
From: Howard Bryant
Subject: Long-term BOD Analysis forCone Mills (grab -inhibited)
County: Guilford
NPDES #NC0000876
Receiving Stream: North Buffalo Creek
Sub -basin: 030602
DAY
BOD
NH3-N
TKN-N
NOX-N TN-N
0
0.64
6.6
0.02 6.6
5
38.22
2.00
7.4
0.01 7.4
10
59.16
2.40
6.5
0.01 6.5
14
73.03
17
80.08
3.60
6.3
0.01 6.3
20
86.24
25
93.68
3.70
6.9
0.01 6.9
30
99.92
33
103.35
39
110.77
52
123.30
60
130.85
70
145.97
80
152.66
92
167.68
101
171.44
ill
174.83
126
178.40
Date Collected:
February 11, 1988
1035
NBOD:
3.10 6.1 0.90 7.0
0.07 2.8 6.20 9.0
cc: Central Files
Regional Water Quality Supervisor
Collected by: Mickey Test evaluation:
pH: Seeded: seeded
CBOD: ' 7 CBOD/BOD-5: q, C, 7

North Carolina Division of Environmental Management
Water Quality Section / Intensive Survey Group
MEMORANDUM
To: Ruth Swanek
Through: Jay Sauber
From: Howard Bryant
Subject: Long-term BOD Analysis forCone Mills (composite -inhibited)
County: Guilford
NPDES #NC0000876
Receiving Stream: North Buffalo Creek
Sub -basin: 030602
PAY
BOD
NH3-N
TKN-N
NOX-N TN-N
0
0.68
6.3
0.02 6.3
5
40.23
2.40
7.4
0.01 7.4
10
62.73
2.50
6.9
0.01 6.9
17
84.56
3.30
5.3
0.01 5.3
20
91.19
25
103.90
1.80
30
120.33
39
130.24
0.10
52
140.21
60
145.79
70
155.72
80
163.56
0.08
92
175.47
101
178.97
111
181.45
126
185.05
V
Date Collected:
February 11, 1988
1030-1035
NBOD: 0
cc: Central Files
Regional Water Quality Supervisor
4.4 0.88 5.3
3.0 4.60 7.6
3.6 5.70 9.30
Collected by: Mickey Test evaluation:
pH:8.1 Seeded: seeded
CBOD: j if CBOD/BOD-5: & 6Q

e r
North Carolina Division of Environmental Management
Water Quality Section / Intensive Survey Group
MEMORANDUM
To: Ruth Swanek
Through: Jay Sauber
From: Howard Bryant
Subject: Long-term BOD Analysis forCone Mills (grab -uninhibited)
County: Guilford
NPDES # NC0000876
Receiving Stream: North Buffalo Creek
Sub -basin: 030602
DAY
BOD
NH3-N
TKO► -►N
NOX-N LN
0
0.64
6.4
0.01 6.4
5
40.51
2.40
6.9
0.01 6.9
10
61.39
2.30
6.4
0.02 6.4
14
76.76
17
90.95
0.55
4.2
1.40 5.6
20
99.80
25
111.07
0.04
3.9
3.60 7.5
30
117.83
33
121.21
39
127.07
0.13
3.4
4.40 7.8
45
132.40
52
139.69
60
147.38
70
152.85
80
165.37
0.08
2.9
6.70 9.6
92
170.62
101
173.25
126
179.89
Date Collected: February 11, 1988
Collected by: Mickey Test evaluation:
1035
pH:
Seeded: seeded
NBOD:
CBOD:
CBOD/BOD-5:
cc: Central Files
Regional Water Quality Supervisor

North Carolina Division of Environmental Management
Water Quality Section / Intensive Survey Group
MEMORANDUM
To: Ruth Swanek
Through: Jay Sauber
From: Howard Bryant
Subject: Long-term BOD Analysis forCone Mills (composite-unseeded)
County: Guilford
NPDES #NC0000876
Receiving Stream: North Buffalo Creek
Sub -basin: 030602
DAY
BOD NH3-N
TKN-N N X-N TN-N
0
5
41.23
10
63.33
14
80.09
17
92.10
20
101.54
25
112.37
30
119.30
33
123.16
39
128.92
52
142.95
60
149.85
70
157.56
80
169.99
92
174.72
101
177.91
111
181.64
126
185.19
Date Collected: February 11, 1988
Collected by: Mickey Test evaluation:
1030-1035
pH: Seeded: unseeded
NBOD:
CBOD: CBOD/BOD-5:
cc: Central Files
Regional Water Quality Supervisor

f
North Carolina Division of Environmental Management
Water Quality Section / Intensive Survey Group
MEMORANDUM
To: Ruth Swanek
Through: Jay Sauber
From: Howard Bryant
Subject: Long-term BOD Analysis forCone Mills (composite -uninhibited)
County: Guilford
NPDES # NC0000876
Receiving Stream: North Buffalo Creek
Sub -basin: 030602
DAY
BOD
NH3-N
TKN-N
NOX-N TN-N
0
0.64
5.8
0.03 5.8
5
42.75
2.40
6.8
0.02 6.8
10
68.65
2.30
6.0
0.05 6.0
17
99.54
0.11
3.9
2.30 6.2
20
108.44
25
117.13
0.05
3.1
3.90 7.0
30
123.51
33
126.72
39
131.91
0.19
3.9
4.40 8.3
52
144.80
60
152.09
70
159.73
80
170.65
0.09
3.1
7.00 10.1
92
178.51
101
181.10
ill
183.38
126
186.92
Date Collected:
February 11, 1988
Collected by:
Mickey Test evaluation:
1030-1035
pH:
Seeded: seeded
NBOD:
CBOD:
CBOD/BOD-5:
cc: Central Files
Regional Water Quality Supervisor

CONE MILLS CORPORATION
GREENSBORO, N. C. 27405
June 3, 1987
Mr. Arthur Mouberry
N.C. Dept. of Natural Resources
and Community Development U
512 North Salisbury Street
Raleigh, N.C. 27611 JUN 5 1,987
Re: Draft Permit
NPDES NC0000876
Dear Mr. Mouberry:
PERMITS & ENGINEERING
Confirming our meeting concerning the Draft Permit for the Cone
Mills Corporation Dye Waste Disposal Plant in Greensboro, there are
several points that you agreed to look at again. The flow value
should be changed to 1.1 MGD which is a realistic estimate of the
flow value for this plant.
The change in flow will necessitate the rerunning of the BOD
allocation model. It is our belief that the modelling should recognize
the very stable nature of the effluent caused by in excess of 20 days
detention time in the treatment system. This will result in a very
low initial reaction rate of the waste in stream. We also believe
that reaeration in the stream is quite significant at low flow. We
trust that rerunning the model will result in a loading allocation
that can be met.
A review of the suspended solids indicate that an inappropriate
value was used and we request that the existing value be used for the
new permit.
The Company will examine the phosphorus discharge limits based
on a quarterly analysis period and we request that the State determine
if a compliance schedule for achieving the 2 mg/1 limit can be allowed.
We appreciate your cooperation and look forward to working with
the Staff to resolve these issues.
cc: Mr. Ed Barnhart
Mr. T. A. Alspaugh
Mr. Dale Overcash
Sincerely,
_.._
Arthur J. Too pas
Cone •

u

41
NPDES Limits
Present Permit
Proposed Limits
Cone Requested based on
performance
BOD SUSPENDED SOLIDS FLOW
770 1085
cIr
146 �9'2�Se ��•`�1 3.5
30.8 185.1 0.74
100 250 1.0
i G uV"-
1

Facility Name:
NPDES WASTE LOAD
CDne- Mi 115 &roo l
Engineer Datp Rec. ,
�-
'
Existing
Proposed O Permit IV, /t/�oo
ocg
Pipe No.:
O O County: C�•[,c� l��
Design Capacity (MGD): Industrial (% of
Flow):
/ O C
Domestic (% of Flow): O
Receiving Stream: %V pc'-
U k`J o `Class : C- —
%V'S i4J Sub -Basin: 030(o O 2
19 SF—
G,
CARS Regional Office �) s/� O
Reference USGS Quad: G
( Please attach)
Requestor
: S
o_ -GA _
Q_a0-*►S 0 r" c
-
(Guideline limitations, if applicable, are
to be
listed on
the back of this form.)
Design cZ S
gn imp
VU �A it ���
3/9/fry
��• %
Avg. Streamflow (cfs) :
7Q10 (cfs) 10.(0
h�t►1�s
I' 7
30Q2 (cfs )
Location of D.O. minimum (miles below
Slope (fpm)
Velocity (fps) : 6. 1(7 K
1.1 wlbD kNdc�
w p # �D
K2 (base e , ter day) : J.3
•
r
S u wl rn t �` l� c v►1 C I S
Effluent
Characteristics
Nbnthly
Average
Comments
S o
30 . S s d
S" M �.
)UH
►,s
z ,,"J
30
��-c.�c �
l o 0o too •+tom.
WI Jr.,L 1
Effluent
Characteristics
:'Dnthly
Lveraae
Comments
,Sr D t)
1. 7 Ns/dAt
N6
ti tj
Z+.7 1Ls
p
G. o
"^ S
r s.1 1
ium'#L-
O 444 fQ
o1
(000 Itoo
H
ry ^ S
C �roM iv wt 0.47 s o • �J �o'(g�jl Gl,.ro."tum
Ori i Allocation O �mments: CJ
Ropv s _18cation O S�
�b rmation O
Prepared BY: Reviewed By:
ls"Z,
1�51-t V2'fAll�)
Date:

4�^
For Appropriate DisdarAers, list Complete Guideline limitations Below
Effluent
Characteristics
Monthly
Average AW4
Maximum Daily
Average Ib
Cbmments
oos
�lQo
2380
Coo
rY8o5
Zg b✓b
65
3o'(S
to ago
s 14A-
gY
Z1
Y Z
c
a r-VM 4A ON
7-1
q z
6-S.I.
• K
11 0 oao
MAI65a
vov �Qqp D
Z
Type of Product Produced
Lbs/Day Produced
Effluent Cuideline Reference
Eck / ar-r. Rs' % '
SD 0 00

Cone Mills Corporation - Permit# NCO000876 - WLA# 3012
HPT Limitations Under Federal Guideline #410.72(a)
Constituent
COD
Sulfide
Phenol
Monthly Average
14805 lbs/day (2399 mg/1)
42 lbs/day (6.8 mg/1)
21 lbs/day (3.4 mg/1)
Toxicity testing requirement attached.
Maximum Daily Average
29610 lbs/day (4798 mg/1)
84 lbs/day (13.6 mg/1)
42 lbs/day ( 6.8 mg/1)
Recommend facility monitor for zinc.
Recommend reopener clauses for Total Phosphorus (basinwide total
phosphorus limits may be forthcoming) and zinc (if monitoring data
demonstrates elevated zinc levels in Eastside High Point's effluent).

'
Request No. :3012
--------------------- WASTELOAD ALLOCATION APPROVAL FORM ---------------------
Facility Name
: CONE MILLS CORPORATION
Type of Waste
: INDUSTRIAL
Status
: EXISTING
Receiving Stream
: NORTH BUFFALO
CREEK
Stream Class
: C-NSW
Subbasin
: 030602
Cuuoty
: GUILFORD
Drainage Area
(sq mi)
: 14.7
Regional Office
: WINSTON-SALEM
Summer 7010
(cfs)
: 0.6
Requestor
: D. OVERCASH
Winter 7010
(cfs)
: 1.7
Date of Request
: 3-25-86
Average Flow
(cfs)
: 16
Quad
: C 19 SE
3002
(cfs)
:
------------------------- RECOMMENDED EFFLUENT LIMITS -------------------------
Summer Winter
Wasteflow
(mgd):
0.74
0'74
5-Day BOD
(mg/1):
5
10
Ammonia Nitrogen
(mg/1):
2
4
Dissolved Oxygen
(mg/1):
6
6
TSS
(mg/1):
30
30
Fecal Coliform (#/100ml):
1000
1000
PH
(SU):
6-9
6-9
Total Chromium
(ug/l):
76
124
Other Limits Attached
:
--------------------------------- MONITORING ---------------------------------
Upstream (Y/N): Y Location: 100 FT UPSTREAM OF OUTFALL.
Downstream (Y/N): Y Location: SUMMIT AVENUE.
COMMENTS
TOXICITY TESTING REQUIREMENT ATTACHED. AA_k2� ee>yje. J;mi+s am Azs;reJ
RECOMMEND FACILITY MONITOR FOR ZINC.
RECOMMEND REOPENER CLAUSE FOR NUTRIENTS (BASINWIDE STRATEGY FOR NUTRIENTS IS
PRESENTLY BEING CONSIDERED AND LIMITS WILL BE FORTHCOMING).
Recommended by Date _�������`�.....
�
Reviewed by: op
|
U
Tech' Su000rt Supervisor U '�8��` \ L~~��� Date
-_ --,-- -�.� _
Regional Superviso�� _ Date
Permits & Engineer
Water Quality Section Chief
Date
Date

Facility Name CBac 1"/ 11S r IO I Permit # )VC 00C)0 r?%
,p,Pe oo r
TOXICITY TESTING REQUIREMENT 11
The effluent discharge shall at no time exhibit chronic toxicity using
test procedures outlined in:
1.) The North Carolina Ceriodaphnia chronic effluent bioassay proce-
dure (North Carolina Chronic Bioassay Procedure - Revised *February 1987) or
subsequent versions.
The effluent concentration at which there may be no observable inhibi-
tion of reproduction or significant mortality is _�A$ (defined as treatment
two in the N�o�jth Carolina procedure document). The permit holder shall
perform `0`r k monitoring using this procedure to establish compliance
with the perm' condition. The first test will be performed within thirty
days from issuance of this permit. Effluent sampling for this testing shall
be performed at the NPDES permitted final effluent discharge below all
treatment processes, including chlorination. There may be no dechlorination
of the effluent sample prior to testing.
All toxicity testing results required as part of this permit condition
will be entered on the Effluent Discharge Monitoring Form (MR-1) for the
month in which it was performed, using the appropriate parameter code.
Additionally, DEM Form AT-1 (original) is to be sent to the following
address:
Attention: Technical Services Branch
North Carolina Division of
Environmental Management
P.O. Box 27687
Raleigh, N.C. 27611
Test data shall be complete and accurate and include all supporting chemi-
cal/physical measurements performed in association with the toxicity tests,
as well as all dose/response data. Total residual chlorine must be measured
and reported if employed for disinfection of the waste stream.
Should any test data from this monitoring requirement or tests per-
formed by the North Carolina Division of Environmental Management 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 docu-
ment, such as minimum control organism survival and appropriate environmen-
tal controls, shall constitute an invalid test and will require immediate
retesting. Failure to submit suitable test results will constitute a fail-
ure of permit condition.
7Q10 6.(0 cfs
Permited Flow 6. 4g MGD
Basin & Sub -basin 0 1- 0& -02--
Receiving Stream Ark. R.3O CPCtK
Recommended B

Co n e- ✓A 3 CorPUfLA., vK
,
/Joret- t)
T*-" o C(ce K
U 3 -0(0 -oZ
wj. pq-il-- 30 i L .2141E 7
Sb V
q w = o• 74- m UL
i� 7izZ'16
S74) o = 0.6 As
R
w7Q��
( � = 1b c4 s
4f01.61s3.3
R L
34 = 22. 8 M�
S7Q to o. 9 c f_S
w70o = a-:cf.s
q
C� � s�c,.;tic e, C,n� ��
1.7
0 . �
1 • �
I � �
WCJ4(&w Cm&t))
0.74
K,
—
S7R.o
6.8t
a.4(o
�. 2
WOO C•0 (—C.",)
6,E3
1,,,,4
a,9z
3.3�
�oJ
-7. l I
•.T I
T'rib S7410(cl)
—
Q, JL)
0.73
If,b w 74 10 (CfS)
"'
�. 77
1.03
Tr (.cis,
—
—
S• S�
y, t
�o e wit)
P
5.19
,2. �t,
2.4
us CrS
IP
,ff62.09S-S . O 0ap
S7¢lo = f.Of cfs
W76 )Q = 17.io cfs
Q,.: 58,16 cfs

cevt4e"'t
KcJ
Irvtf+S 470✓ co1) ) PIeI-oI ) �u�tt�e 4
§ 410.72 Effluent limitations representing
the degree of effluent reduction attain-
able by the application of the best
practicable control technology current-
ly available (BPT).
(a) Except as provided in 40 CPR
125.30 through 125.32, any existing
point source subject to this subpart
must achieve the following effluent
limitations representing the degree of
effluent reduction attainable by the
application of the best practicable con-
trol technology currently available
(BPT):
—
----
BPT limitations
Average of
Pollutant or pollutant property
Maximum for
es
�1«
any 1 day
30
consecutive
days
Kg/kkg (or pounds per
1,000 lb) of product
B005............................................
6.8
3.4
COD..............................................
84.6
42.3
TSS.......... ............._.....................
17.4
8.7
Sulfide ............................................
0.24
0.12
Phenol...........................................
0.12
0.06
Total chromium ............................
0.12
0.06
PH......... ......__...
..............
C )
V )
r Within the range 6.0 to 9.0 at all tlmea
Imo r6i
+Z 3 -9 3So = a 34 4 Y
06.34'*0.7y V
8.3`i 'K 0,74
TAJ C��t0M%UW,-
Q P I S C.S O_W� e a S
t� wGr uc�.Q`,"�
C-21
vJ
CLilom U"L
I rojuAt m = 3S'0) o00 I Ls /Az�s
3�7 0) 006
1000 1 bS
V
8`f.6)K 3so _ 4778 n1y/L
9.34 * a . ? + `vi
o , 2 4 # 3 So = )3. 6 z/t�(.3,-I A 0.7µ
53�� o•Tµ
1— L (., I — b w 1 w e.

SolQ /L
�f
s u vv, eA 0.
(o + CO.7 4 * I
--- �CU . 7 "
a,74
use A.)(- u.)c� f

_ .. �� ..
Ilf
. ....
...
..
_
... _
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Stre4,m : _ fJori-�- -Bu��alo Ccee.,,V
mOl'tgstetm ✓ Be&ACh
�Pe C4IC-u I4-to n s
C,Mc wt , I l s f
S lope = 10
error �
�Io��
- 10 ��C Crrc�wS�or� Wwl
Goo
3.s
w►�
fe UsGS CTaq•e
o v C.r
. = s. 6� � t d,� ko t-
e"
c�e
`
`
a l �� • t s
LfP^
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dlsto,ncc

f.
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A I � v

DIVISION OF ENVIRONMENTAL MANAGEMENT
February 5, 1987
MEMORANDUM
TO: Larry Cable
THROUGH: Steve Tedder �-
Trevor Clemei s
4��
FROM: David Vogt V
SUBJECT: Wasteload Allocation For Cone Mills Corporation
As you are aware, renewal of Cone Mill's permit was delayed due to
the complexity of the previous WLA done by Randy Williams. The 1983 WLA
accounted for benth i c processes by the use of zero -order kinetics in the
optional nitrogen subroutine of the Level-B model. The 1983 WLA also
utilized a design flaw of 4.0 MGD and a USGS 7010 of 1.17 cfs.
Cane Mills has since retrofitted its plant for wastewater recycling
and has submitted a revised design flow of 0.74 MGD. In addition, the
current USGS 7010 at the discharge site is 0.6 cfs. Since velocity is
primarily a function of flaw, the reduction in wasteflow and 7010 in
turn reduce the stream velocity that the model uses in calculating the
reaction rates, k1 and k2. The net effect is that the model allocates
less BOD in the effluent.
In order to test the accuracy of the "regular" Level-B model in
simulating the fate of Cone Mill's oxygen -consuming wasteflow, I used
actual data from June 1986 when North Buffalo Creek: was at low -flaw
conditions. Model input was taken from Cane Mill's self -monitoring
data and USGS flaw records. The downstream station at Summit Avenue
was used as a reference point for comparing the predicted dissolved
oxygen (DO) from the model with monitored DO. Several runs of the
model predicted DO concentrations that were within plus or minus 5%
of the recorded data. Therefore, I feel that a Level-B analysis is
appropriate for Cone Mill's wastewater.
Using the benthic nitrogen subroutine, the previous analysis gave
limits of 10 mg/l BOD5 and 4 mg/1 NH3. However, due to the change in
wasteflow and 7010, the present analysis predicts that an ultimate BOD
of 25 mg/l cannot be exceeded if the stream is to maintain 5 mg/l DO at
the sag point. Because the Cary Laboratory has shown that Cane Mill's
effluent has a high CBOD to BOD5 ratio (see attached), I have used the
industrial CBOD/BOD5 of 3 in calculating BOD5 and NH3 limits for this
facility. Hence, I have recommended the limits of 5 mg/l BOD5 and 2
mg / l NH3 (6 trig / l BOD5 and 1.5 mg / l NH3 could also be used if Caine Mills
desires higher BOD5 and lower- NH3 limits).
cc: Dale Overcash
Cane Mills WLA Fills

A REVIEW OF THE RATIO OF ULTIMATE
CARBONACEOUS 600 TO BOO,
DEPARTMENT OF NATURAL RESOURCES AND COMMUNITY DEVELOPMENT
DIVISION OF ENVIRONMENTAL MANAGEMENT
WATER OUALITY SECTION

FAC: The facility at which the sample was collected.
SAS: The code for the river basin
BOD*H: The five-day B00 determined by the Technical Services Unit (mg/1)
80D*C: The five-day 800 determined at the Cary laboratory (mg/I)
N8001: The nitrogenous 800, as determined by the equation
NBOD = 4.57 - NH*-N (mg/1)
CBOD1: The carbonaceous 600, BODLT - NBOD1 (mg/1)
CBOD2: The carbonaceous SODI BODLT - NBOD2 (mg/1)
BODLT: The ultimate BOD, determined by the Technical Services Unit (mg/1)
DUR: The duration of the ultimate ODD test (days)
Ci_B00*H: CBOD1/BOD.H
C2_800*H: CBOD2/BOD*H
C1_BODaC: CBOD1/BOD*C
C2 BOD*C: CBOD2/800*C
CAT: HOS = Hospital
IND = Industrial
MUN = Municipal
SCH = School
Table 2 summarizes the results of the analysis.
In reviewing the data, it Is apparent that the assumption that CBOD = 8004
is not appropriate for municipal wastewater. This can probably be attributed to
1) all carbonaceous oxygen demand in pure domestic wastewater is not exerted in
five days. (EPA Region IV assumes the CBOD/BOO* ratio is 1.5 for domestic
wastewater.)i 2) many municipal facilities In North Carolina receive Industrial
waste which degrades less rapidly then domestic waste.
The CB00/BOD* data are graphically depicted in Figure 1 for municipal
facilities and schools. The four separate boxplots for each category represents
the four dllferent Aeana of determining the ratio, given ?Te data. For this

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m�-
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/�f l NPDES WASTE LOAD ALLOCATION �� —08- 8Z
Facility Name: ��4e ' f r//s "' GQe�.✓sioxo*1 din
Date.
Existing Permit No.: A)C O000o Ca 9:7 _
Pipe No.: COI County: V�
Proposed Q
Design Capacity (MGD):_ a 0 Industrial (% of Flow): /670 7o Domestic (% of Flow):
Receiving Stream: ti'PA..p&Jjai. U44-k Class: C Sub -Basin: 03-0�-40Z
Reference USGS Quad: oUU (Please attach) Requestor: �9Ve r-rakiPiS Ra"6emweir Office
(Guideline limitations, if applicable, are to be listed on the back of this form.)
Design Temp.: ✓ G Drainage Area: �� 5 S 4�"7r' Avg. Streamflow: C 5
7Q10: �' 0 C�S Winter 7Q10: ���� 5 30Q2: �� aCd--s
as
", Location of D.O.minimrumm (miles below outfall): S'� Slope:. s a p M
Velocity (fps) : e)/ '��/�� Kl (base e, per day, 200C) : �• K (base e o 5,'72 '%SZ-t
2 per day, 20 C):
0
7rimtn0✓ //),,Ahgr
Effluent
Characteristics
Monthly
Average
M
A-v
Comments
/
/
w
IT
Original Allocation a
evised Allocation 1z
�M
Effluent
Characteristics
Monthly
Average
eri/�/
Mety,
Comments
TS
# d
w-4'�/d
6K�#�
a�
Date(s) of Revision(s)
(Please attach previous allocation)
�. Prepared By: ���.,�,< �i�l�ff. f-l+ - Reviewed By: Date

For Appropriate Dischargers, list Complete Guideline limitations Below
Effluent
Characteristics
Monthly
Average
Maximum Daily
-AmQA@Se
Comments
Co
14,90
Z'%/o 16
(090e
�ZAI
l�
Type
of Product Produced
Lbs/Day Produced
Effluent Guideline
Reference

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5/3/94
5/17/94
5/31 /94
6/9/94
6/13/94
6/16/94
6/23/94
6/28/94
7/1 /94
7/7/94
7/12/94
7/15/94
7/21 /94
7/26/94
7/29/94
8/4/94
8/9/94
8/12/94
8/18/94
8/23/94
8/26/94
9/1 /94
9/6/94
9/9/94
9/15/94
9/20/94
9/23/94
9129/94
Sbbl —h$dl
INSTREAM DO (mg/1)
N A O OD O N A
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�LSDOPO�✓'/

DIVISION OF WATER QUALITY
June 20, 1997
MEMORANDUM
TO: Tom Fransen
THROUGH: Steve Bevington
FROM: Jason Doll
SUBJECT: DWQ Comments
Cooperative Stream Gage Agreement
I have circulated the list of gage sites and associated studies to be funded by the
cooperative agreement through the modelers, our regional offices and our Environmental
Sciences Branch. I have attached the comments received to date. Most of them are in the
form of e-mail messages.
I also have some comments and questions pertaining to the specific river basins I
work with and the structure and content of the agreement. In keeping with some of the
other comments, I would like to list them by river basin and individual gage site.
TAR/PAMLICO RIVER BASIN
The gages that are listed in the agreement are all fine, but I know of several other
gages that exist in the Tar/Pamlico basin and are not listed on the agreement. They are as
follows:
02081747
Tar River at US 401 at Louisburg, NC
02082506
Tar River below Tar River Reservoir near Rocky Mount, NC
02082585
Tar River at NC 97 at Rocky Mount, NC
02082731
Devils Cradle Creek near Alert, NC
02082770
Swift Creek at Hilliardston, NC
02083000
Fishing Creek near Enfield, NC
02083800
Conetoe Creek near Bethel, NC
* * * * * * * *
Tar River near Greenville (I don't know the number for this gage
because it is brand new, but I wondered why it wasn't on the list.)
02083833
Pete Mitchell Swamp at SR 1409 near Penny Hill, NC
I would speculate that these gages are funded by means other than the agreement, but
I wanted to list them in the interest of making sure they weren't being left out. If it is not
difficult to assemble, a list of the funding sources for each of these gages might be helpful
in enhancing my understanding of the overall gage network in terms of how it is
supported.
PASQUOTANK RIVER BASIN
♦ 4

c
v
cD
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v
0
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w
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m
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6/20/95
6/22/95
6/26/95
6/27/95
6/29/95
7/5/95
7/6/95
7/7/95
7/10/95
7/1 1 /95
7/13/95
7/17/95
7/18/95
7/20/95
7/24/95
7/25/95
7/27/95
7/31 /95
8/1 /95
8/3/95
8/7/95
8/8/95
8/9/95
8/14/95
8/15/95
8/17/95
8/21 /95
8/22/95
8/24/95
8/29/95
8/30/95
8/31 /95
INSTREAM DO (mg/1)
O -+ N W (n O V OD
O O O O O O O O O

Donnelly, Patrick T.
DEM Chemist Lab 11
733-3908
Dorne y, John R.
Water Quality
733-1786
Dorrity, Floyd
Air Quality
715-0891
Dudne , Nancy N.
Construction Grants
733-7015, Ext. 633
Dunn, Felicia
Air Quaili
733-7015, Ext. 337
Durrett, Patricia C.
Wilmington Regional Office
[phone]
Dutcher, Deborah D.
Air Quality
733-7015, Ext. 324
Dutton, Arthur W.
Mooresville Regional Office
[phone]
Eagleson, Kenneth W.
Water Quality
733-9960
Eaton, Lawrence E.
Water Quality
733-6946
Edwards, Betsy M.
Construction Grants
733-7015, Ext. 605
Edwards, Keith R.
Raleigh Regional Office j
5714700
Edwards, Lisa D.
Asheville Regional Office
[phone]
Edwards, Roger
Winston-Salem Regional Office
[phone]
Edwards, Roger C.
Asheville Regional Office
[phone]
Edwards, Ronald E.
Wilmington Regional Office
[phone]
Edwards, William B.
DEM Chemistry Lab
733-3908
Elder, Sabra
Winston Salem Regional Office
[phone]
Ellington, Cindy R.
Administration _JF733-7015,
Ext. 226
Elmore, William D.
Groundwater - Kinston
523-3620
Eskenasy, DianeM
Asheville Regional Office
[phone]
Eud , David D.
Groundwater
733-7015, Ext. 421
Evans, Antonio V.
Water Quality
733-5083, Ext. 579
Evans, Cathem
Administration
733-7015, Ext. 214
Evans, Donald H. Jr.
Construction Grants
733-7015, Ext. 619
Evans, John C. IF
Air Quality
733-7015, Ext. 328
Evans, Stephen L.
Asheville Regional Office
[phone]
Everett, Alta L.
Washington Regional Office
946-6481
Fahnestock, Thomas V. Jr.
Construction Grants
733-7015, Ext. 631
Farmer, Robert C.
Water Quality
733-7015, Ext. 531
Faulcon, James C.I
DEM Chemistry Lab
733-3908
Ferrell, Ronald E.
Water Quality
733-1786
Ferrell, Ter L.
Water Quality
733-2136
Finan, Cynthia M.
Water Quality
733-0026
Fisher, James T.
Water Quality
733-6510
Fisher, Robert P.
Fayetteville Regional Office
[phone]
Fitzgerald, John M.
Washington Regional Office T777946-6481

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Roderick, Linda B.
Administration
733-7015, Ext. 229
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Winston-Salem onal Office
[phone]
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Fa etteville RegRegonal Office
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Washington R 'onal Office
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CAPE FEAR RIVER BASIN
SUB
MAP
NAME OF STREAM
BASIN
INDEX NUMBER
NUMBER
CLASS
--------------
REEDY BRANCH
-----
CPF21
------------
18-74-7-1
------
G27SW3
-----
C SW
REEDY BRANCH
CPF22
18-74-19-4
G26SW3
C SW
REEDY BRANCH
CPF22
18-74-27-1
H27SW4
C SW
REEDY CREEK
CPF09
17-25-4
E20SW7
C
REEDY FORK
CPF02
16-11-(1)
C18SE2
WS-III
NSW
REEDY FORK
CPF02
16-11-(3.5)
C19NW6
WS-III
NSW CA
REEDY FORK
CPF02
16-11-(9)
C20NW4
C NSW
REEDY FORK
CPF09
17-23-0.5
D20SE8
C
REEDYS SWAMP
CPF14
18-23-29-2
F22SE9
C
RESOE CREEK #
CPF23
18-74-55-9-1
J27NW1
C SW
RHODES POND
CPF18
18-68-12-1
G24NW3
C SW
RICE CREEK
CPF17
18-81-6
K26NE8
C SW
RICE PATCH BRANCH
CPF14
18-23-29-3
F22SE9
C
RICE SWAMP
CPF19
18-68-1-17-8-(1)
G25SW7
B SW
RICE SWAMP
CPF19
18-68-1-17-8-(2)
G25SW7
C SW
RICHARDSON CREEK
CPF09
17-25-2-1
E20SW5
C
RICHLAND CREEK
CPF02
16-11-7-(1)
C19NE8
WS-III
NSW
RICHLAND CREEK
CPF02
16-11-7-(2)
C19NE8
WS-III
NSW CA
RICHLAND CREEK
CPF08
17-7
D18NE6
C
RICHLAND CREEK
CPF09
17-22
E19NE9
C
RICHLAND CREEK
CPF10
17-30-5-(1)
F20SE2
B
RICHLAND CREEK
CPF10
17-30-5-(2)
F20SE2
C
RICHLAND CREEK, N PR
CPF09
17-22-1
E19NE8
C
RICHLAND CREEK, S PR
CPF09
17-22-2
E19SE3
C
RICHLAND LAKE
CPF02
16-11-7-(1)
C19NE8
WS-III
NSW
RICHLAND LAKE
CPF02
16-11-7-(2)
C19NE8
WS-III
NSW CA
RICKS CREEK
CPF22
18-74-19-2
G26NE7
C SW
RILEYS CREEK
CPF23
18-74-55-9
J27NW4
C SW
RITA BRANCH
CPF10
17-26-5-3-2
F19NE9
WS-III
RITTERS LAKE
CPF09
17-11-2-(1)
D19NE3
WS-III&B
RIZZO CREEK
CPF23
18-74-55-9-1
J27NW1
C SW
ROBERTS CREEK
CPF07
18-4-7-3
E22SW9
WS-IV
ROBESON CREEK
CPF04
16-38-(1)
E22NW2
C NSW
ROBESON CREEK
CPF04
16-38-(3)
E22NW2
WS-IV
NSW
ROBESON CREEK
CPF04
16-38-(5)
E22NE4
WS-IV
NSW CA
ROBINSON MILL BRANCH
CPF19
18-68-2-13
H25SE3
C SW
ROCK BRANCH
CPFO1
16-2
C19NW1
C NSW
ROCK CREEK
CPF03
16-19-3.5-(1)
C20SE1
WS-IV
NSW
ROCK CREEK
CPF03
16-19-3.5-(2)
C20SE4
WS-IV
NSW CA
ROCK CREEK
CPF03
16-19-8-3
D21NW4
C NSW
ROCK CREEK
CPF02
16-20-2
C21SE9
WS-V NSW
ROCK CREEK
CPF02
16-21-1
D21NE1
C NSW
ROCK CREEK
CPF17
18-81-4
K26NW9
C SW
ROCK FISH CREEK
CPF22
18-74-29
H26SE4
C SW
ROCKFISH CREEK
CPF15
18-31-(1)
G21NE7
C
ROCKFISH CREEK
CPF15
18-31-(12)
G22SW7
B
ROCKFISH CREEK
CPF15
18-31-(15)
H22NW2
C
ROCKFISH CREEK
CPF15
18-31-(18)
H22NE1
B
ROCKFISH CREEK
CPF15
18-31-(23)
H23NW2
C
ROCKY BRANCH
CPF02
16-11-12
C20NW6
C NSW
ROCKY BRANCH
CPF10
17-41-1
E22SW1
C
ROCKY BRANCH
CPF11
17-44-(1)
E22NW9
C
ROCKY BRANCH
CPF11
17-44-(2)
E22NW9
WS-IV
ROCKY BRANCH
CPF19
18-68-6-1
I25NE6
C SW
25

TOXICANT ANALYSIS
Facility Name
Cone Mills
NPDES #
NC0000876
Qw MGD
1.25
7010s cfs
0.5
79.49
N. Buffalo Creek
IwC pq
Rec'ving Stream
Stream Class
C-NSW
FINAL RESULTS
Chromium
Max. Pred Cw
7.7
Allowable Cw
62.9
Arsenic
Max. Pred Cw
50.4
Allowable Cw
62.9
Copper
Max. Pred Cw
23.8
Allowable Cw
8.8
Lead
Max. Pred Cw
9
Allowable Cw
31.5
Nickel
Max. Pred Cw
33.8
Allowable Cw
110.7
Chloride
Max. Pred Cw
175.5
Allowable Cw
289.4
Flouride
Max. Pred Cw
10.062
Allowable Cw
2.3
Zinc
Max. Pred Cw
160
Allowable Cw
62.9
0
Max. Pred Cw
0
Allowable Cw
0.0
0
Max. Pred Cw
0
Allowable Cw
0.0
0
Max. Pred Cw
0
Allowable Cw
0.0
0
Max. Pred Cw
0
Allowable Cwl
0.0
10/12/95 PAGE "

State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor
William W. Cobey, Jr., Secretary
INVOICE
July 1, 1990
TO: Requestors of Information
Concerning Point Source Dischargers
THRU: J. Trevor Clements�11� i
FROM: Marcia Toler-McCullen tA-"
SUBJECT: Miniature Subbasin Maps and Facility Listings
George T. Everett, Ph.D.
Director
Effective July 1, 1990, there will be a minimum charge of 1�1 per zerox copy for information
pertaining to the subbasin maps/facility listings acquired from the Technical Support Branch of
the Division of Environmental Management.
Due to the departmental budget/funding status, it has become necessary to request a charge for all
information. We can no longer provide this information to the private/public sector free of charge.
If obtaining this information through the mail, you will be billed along with the information.
Payment should be made by check only (NO CASH), and mailed promptly after receiving the
requested information.
If obtaining this information personally, payment is expected upon receipt of information, and
should be paid also by check. If payment is by cash, a receipt of payment will be issued
immediately by budget personnel.
If there are any questions concerning this procedure, please feel free to contact me at 919-733-
5083, ext. 521.
MLT:mIt
Attachment
cc: Cathy Cottle
Linda Roderick
Carrie Grant
Frances Cotton
Pollution Prevention Pays
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

TOXICANT ANALYSIS
Parameter =
Chromium I
Parameter =
Arsenic
Standard =
50 ••
/1
Standard =
50
/I
n
BDL=1/2DL
Actual Data
RESULTS
n
BDL=1/2DL
Actual Data
RESULTS
1
2.5
<5
Std Dev.
0.649329819
1
6
6
Std Dev.
5.654
2
2.5
<5
Mean
2.616666667
2
10
10
Mean
13.18
3
2.5
<5
C.V.
0.248151523
3
10
10
C.V.
0.429
4
2.5
<5
4
8
8
5
2.5
<5
5
16
16
_.._.._..
:.::
6
2.5
<5
Mult Factor = I
..................
1.1
6
19
19
Mult Factor =
2.1
7
2.5
<5
Max. Value
7
/1
7
16
16
Max. Value
24
/1
8
2.5
<5
Max. Pred C
7.7
/l
8
24
24
Max. Pred Cw
50.4
/1
9
2.5
<5
Allowable Cw
62.9
/I
9
7
7
Allowable Cw
62.9
/1
10
2.5
<5
101
12
12
11
2.5
<5
11
110
U
12
2.5
<5
12
17
17
r
13
2.5
<5
13
01
><>
14
2.5
<5
14
15
2.5
<5
15
16
2.5
<5
16
17
2.5
<5
17
18
2.5
<5
18
19
2.5
<5
19
20
2.5
<5
20
21
2.5
<5
21
22
2.5
<5
22
23
2.5
<5
23
24
2.5
<5
24
25
2.5
<5
25
10/12/95 PAGE'

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CAPE FEAR RIVER BASIN
SUB
MAP
'NAME OF STREAM
BASIN
INDEX NUMBER
NUMBER
CLASS
--------------
WILKINSON CREEK
-----
CPF04
------------
16-35
------
D22SW3
-----
WS-IV NSW
WILLET BRANCH
CPF17
18-81-6-1-3
K26SE1
C SW
WILLIAMS CREEK
CPF10
17-26-3
F19NE6
WS-III
WILLIAMS LAKE
CPF07
18-4-5-1
F22NE1
WS-IV
WILLIAMS LAKE
CPF19
18-68-1-17-4-(1)
G24NE8
B SW
WILLIAMS MILLPOND
CPF21
18-74-3
G27NW4
C SW
WILLIAMS OLD MILL BR
CPF19
18-68-1-10
G25SE7
C SW
WILLIAMS POND
CPF04
16-37-2
D22SE7
WS-IV NSW
WILLIAMS POND
CPF19
18-68-1-17-9
H25NW1
C SW
WILLIAMS SWAMP
CPF14
18-23-33-1
F23SE9
C
WILLIAMSON SWAMP
CPF18
18-68-12-3
G24NE4
C SW
WILLIS CREEK
CPF16
18-37
H23SE1
C
WILSON CREEK
CPF06
16-41-2-6
D22SE2
WS-IV NSW
WINDFALL BRANCH
CPF05
16-41-9-(1)
E22NE2
WS-IV NSW
WINDFALL BRANCH
CPF05
16-41-9-(2)
E22NE2
WS-IV&B NSW CA
WOLF CREEK
CPF10
17-26-4
F19NE6
WS-III
WOLF PIT BRANCH
CPF19
18-68-2-12-2-1
H25NE8
C SW
WOLF PIT CREEK
CPF15
18-31-3
G21SE1
C
WOLFSCRAPE BRANCH
CPF21
18-74-5-2
G27NW7
C SW
WOMBLES CREEK
CPF07
18-2
E22SE1
WS-IV
wvUllir,D LAKE
CPF15
18-24-3-(2)
G23NW9
WS-IV&B
WORTH CANAL
CPF20
18-68-22-1-1-1
J25NE1
C SW
WRIGHTSVILLE RECREA AREA
CPF24
18-87-24
K27NE2
SB #
YOUNG LAKE
CPF14
18-23-27-1
G23NW4
C
YOUNG SWAMP
CPF22
18-74-19-1
G26NW8
C SW
YOUNGS BRANCH
CPF13
18-20-26
F23NE7
WS-IV
YOUNGS POND
CPF14
18-23-32-1-1
F23SW5
C
YOUNGS POND
CPF18
18-68-12-1-1
F24NW2
C SW
32

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CAPE FEAR RIVER BASIN
SUB
MAP
NAME OF STREAM
BASIN
INDEX NUMBER
NUMBER
CLASS
--------------
WALDEN CREEK
-----
CPF17
------------
18-88-1
------
L26NE3
-----
SC SW
HQW
WALKERS CREEK
CPF13
18-20-23
F23SW3
C
WALLACE BRANCH
CPF07
18-4-4
E22SW9
WS-IV
WARD BRANCH
CPF04
16-37-1
D22SE7
WS-IV
NSW
WARD SWAMP
CPF19
18-68-1-4
G25NE5
C SW
WARREN MILL POND
CPF19
18-68-1-17-0.5
G25NW7
C SW
WARRIOR LAKE
CPF14
18-23-11-(2)
G21NW3
WS-III&B
WASHINGTON CREEK
CPF22
18-74-30
127NW5
C SW
WATERMELLON RUN
CPF23
18-74-37
127SE5
C SW
WATERMELON RUN
CPF23
18-74-32.5
127SW3
C SW
WATERS BRANCH
CPF17
18-66-2
J26SW9
C SW
WATERY FORK
CPF04
16-27-4-(0.5)
D22NW2
WS-II
NSW
WATERY FORK
CPF04
16-27-4-(2)
D22NW2
WS-II
NSW CA
WATSON BRANCH
CPF16
18-50-5-2-1
I24SE9
C
WATSONS LAKE
CPF07
18-10-(1)
F22NE5
B
WEAVER CREEK
CPF05
16-41-9-3-(1)
E23NW7
WS-IV
NSW
WEAVER CREEK
CPF05
16-41-9-3-(2)
E22NE6
WS-IV
NSW CA
WELCH BRANCH
CPF12
17-43-13-1
E21NW5
C
WELCH BRANCH
CPF22
18-74-20.5
G27SW9
C SW
WELLS CREEK
CPF04
16-28-1
D21NW8
C NSW
WEST BRANCH BEAR CREEK
CPF10
17-26-2
F19NE3
WS-III
WEST BUIES CREEK
CPF07
18-18-2-(1)
F23NE6
C
WEST BUIES CREEK
CPF07
18-18-2-(2)
F23NE1
WS-IV
WET CREEK
CPF10
17-26-5-5
F20SW3
WS-III
WEYMAN CREEK
CPF16
18-61
J25SE1
WS-IV
SW
WHISKEY CREEK
CPF24
18-87-28
K27NE7
SA
WHISPERING PINES LAKE
CPF14
18-23-11-3
G21NE1
WS-III&B
WHITE LAKE
CPF16
18-46-8-1
124NE9
B
WHITE LAKE DRAIN
CPF16
18-46-8
I24NE5
C
WHITE MEADOW BRANCH
CPF13
18-20-27
F23SE1
WS-IV
WHITE OAK BRANCH
CPF20
18-68-18-5
126SW2
C SW
WHITE OAK BRANCH
CPF22
18-74-18-1
G27SE5
C SW
WHITE OAK CANAL
CPF16
18-60-2
J25NE5
WS-IV
SW
WHITE OAK CANAL
CPF20
18-68-22-1-2-2
J26NW7
C SW
WHITE OAK CREEK
CPF05
16-41-6-(0.3)
D23SE7
C NSW
WHITE OAK CREEK
CPF05
16-41-6-(0.7)
D23SW9
WS-IV
NSW
WHITE OAK CREEK
CPF05
16-41-6-(3.5)
D23SW8
WS-IV
NSW CA
WHITE OAK CREEK #
CPF14
18-23-16-4
F21SE3
WS-III
WHITE OAK LAKE
CPF02
16-11-14-1-2
C19SE3
C NSW
WHITE SPRING CREEK
CPF17
18-88-1-1
L26NE3
SC SW
HQW
WHITEHEAT CREEK
CPF02
16-24
D21NE1
C NSW
WHITEHORSE BRANCH
CPF13
18-20-2
F22NW5
B
WHITEOAK BRANCH
CPF22
18-74-19-6
G26NE8
C SW
WHITEOAK BRANCH
CPF22
18-74-23-0.5-1
H28NW1
C SW
WHITEOAK CREEK
CPF07
18-7-6
E23NW9
C
WHITEOAK SWAMP
CPF19
18-68-1-11
G25SW9
C SW
WHITES CREEK
CPF16
18-50-5
125SW4
C
WHITFIELD POND
CPF21
18-74-5-1
G27NW8
C SW
WHITTIE CREEK
CPF02
16-14-5-3
C21NW5
WS-II
NSW
WILD CAT CREEK
CPF19
18-68-8
126NW4
C SW
WILDCAT BRANCH
CPF04
16-30-1
D22NW7
C NSW
WILDCAT BRANCH
CPF14
18-23-16-8-1
F22SW5
WS-III
WILDCAT BRANCH
CPF14
18-23-18-1-1
F22SE7
WS-III
WILDCAT BRANCH
CPF22
18-75-19-10
G26SE2
C SW
31

TOXICANT ANALYSIS
arameter=
Flouride
i„:Parameter=
Zinc
Standard =
1.8
m /I
Standard =
50
/I
n
BDL=1/2DL
Actual Data
RESULTS
n
BDL=1/2DL
Actual Data
RESULTS
1
ND
Std Dev.
0.93242
1
30
30
Std Dev.
17.36
2
<1
<1
Mean
1.10667
2
40
40
Mean
38.47
3
1.75
1.75
C.V.
0.84254
3
20
20
C.V.
0.451
4
1.8
1.8
4
30
30
5
1.75
1.75
5
30
30
6
2.58
2.58
Mult Factor = ;
._.._.._.._..
3.9
X.X.6
30
30
Mult Factor =
...........
21
7
1.35
1.35
Max. Value
2.58
m /I< 7
40
50
40
50
Max. Value
Max. Pred Cw
80
160
/I
/I
8
0.18
0.18
Max. Pred Cw
10.062
m /Is;; 8
9
0.2
0.2
Allowable Cw
2.3
m /I' 9
60
80
60
80
Allowable Cw
62.9
/I
10
0.18
0.18
10
11
0.17
0.17
11
ND
20
30
ND
20
30
12
12
13
13
14
14
20
20
20
20
15
15
16
16
28
30
28
30
17
17
18
18
50
50
19
19
62
61
62
61
20
20
21
21
22
22
23
23
24
24
25
25
10/12/95 PAGE e

CAPE FEAR RIVER BASIN
SUB
MAP
NAME OF STREAM
BASIN
INDEX NUMBER
NUMBER
CLASS
--------------
TURKEY HILL CREEK
-----
CPF04
------------
16-27-3-(2)
------
D22NW1
-----
WS-II NSW CA
TURKEYPEN BRANCH
CPF16
18-61-2
J25NE8
WS-IV SW
TURLINGTON MILLPOND #
CPF19
18-68-1-17-10
G25SW8
C SW
TURNBULL CREEK
CPF16
18-46
H24SW3
C
TURNER BRANCH
CPF16
18-61-3
J25SE3
WS-IV SW
TURTLE BRANCH
CPF19
18-68-1-19
H25SW6
C SW
TWO MILE BRANCH #
CPF08
17-7-3
D19NW5
C
TWOMILE SWAMP
CPF19
18-68-1-17-4-3
G24NE8
C SW
TYSONS CREEK
CPF10
17-29
E21SW8
WS-IV
UNIVERSITY LAKE
CPF06
16-41-2-(1.5)
D22NE7
WS-II NSW CA
UPCHURCHES POND
CPF15
18-31-(18)
H22NE6
B
UPPER LITTLE RIVER
CPF13
18-20-(1)
F22NW8
B
UPPER LITTLE RIVER
CPF13
18-20-(8)
F22NE4
C
UPPER LITTLE RIVER
CPF13
18-20-(23.5)
F23SW3
WS-IV
UPPER RUN
CPF13
18-20-13-3-4-1
F22SW6
C
UPTON CREEK
CPF16
18-50-3
I24SE5
C
UT AT BROOKS LAKE
CPFO1
16-4-1-(1)
C20NW1
B NSW
UT AT BROOKS LAKE
CPFO1
16-4-1-(2)
C20NW1
C NSW
UT AT CAMP DOUGLAS LONG
CPF08
17-8-3-1-(1)
D19NE1
B
UT AT CAMP DOUGLAS LONG
CPF08
17-8-3-1-(2)
D19NE1
C
u`r AT CAMP HERMAN
CPF02
16-11-10-(1)
C20NW4
B NSW
UT AT CAMP HERMAN
CPF02
16-11-10-(2)
C20NW4
C NSW
UT AT CAMP NEW HOPE
CPF05
16-41-1-6
C22SE8
B NSW
UT AT CONE MILLS CLUB
CPF09
17-11-2-(1)
D19NE2
WS-III&B
UT AT CONE MILLS CLUB
CPF09
17-11-2-(2)
D19NE2
WS-III
UT AT GUILFORD COLLEGE
CPF02
16-11-5-1-(1)
C19SW3
WS-III&B NSW
UT AT GUILFORD COLLEGE
CPF02
16-11-5-1-(2)
C19SW3
WS-III NSW
UT AT LAKEWOOD LAKE
CPF15
18-31-24-3.5
H22NE3
B
UT AT MAGNOLIA
CPF19
18-68-1-10-3-1
H26NE8
C SW
UT AT SANFORD W S
CPF07
18-4-3
F22NW3
WS-IV
UT AT WILLIS CREEK CHURCH
CPF16
18-37-3-(1)
H23SE1
B
UT AT WILLIS CREEK CHURCH
CPF16
18-37-3-(2)
H23SE1
C
UT AT WRIGHT MOB HOMES
CPF06
16-41-1-15-2-3-1
D22NE6
B NSW
UT NEAR HOPE MILLS
CPF15
18-31-22-(1)
H23NW1
B
UT NEAR HOPE MILLS
CPF15
18-31-22-(2)
H23NW1
C
UT NEAR LIBERTY
CPF12
17-43-2
D20SE5
WS-III
UT NEAR ROSEHILL ROAD
CPF15
18-27-2-(1)
G23SW3
WS-IV&B
UT NEAR ROSEHILL ROAD
CPF15
18-27-2-(2)
G23SW3
WS-IV
UT NW MT CARMEL CHURCH
CPF10
17-30-5-3-(1)
F20SE2
B
UT NW MT CARMEN CHURCH
CPF10
17-30-5-3-(2)
F20SE2
C
UT TO LITTLE LICK CR
CPF07
18-4-5-1
F22NE1
WS-IV
UT TO MILL CREEK
CPF02
16-18-3-2-(1)
C21SE3
WS-II NSW
UT TO MILL CREEK
CPF02
16-18-3-2-(2)
C21SE3
WS-II NSW CA
UT TO TROUBLESOME CR
CPFO1
16-6-2-(1)
B20SW1
WS-III&B NSW
UT TO TROUBLESOME CR
CPFO1
16-6-2-(2)
B20SW4
WS-III NSW
UT TO TROUBLESOME CR
CPFO1
16-6-2-(4)
B20SW4
WS-III CA NSW
UTLEY CREEK
CPF07
18-7-5.5
E23NE7
C
VARNALS CREEK
CPF02
16-21
D21NW2
C NSW
VARNELL CREEK
CPF12
17-43-11
D21SW9
C
VESTAL CREEK
CPF09
17-22-4
E19NE5
C
VINSON POND
CPF18
18-68-12-7
H24NE1
C SW
VIRGINIA CREEK
CPF24
18-87-9
J28NE4
SA
VON CANON LAKE
CPF14
18-23-3
G20NE2
WS-III
WADS CREEK
CPF14
18-23-2
F21SW8
WS-III
30

Chemical Monitoring Summary Report
1 of
NORTH BUFFALO CREEK AT SR 2832 NEAR GREENSB+-)RO, NC
Station Number: 02095500 Drainage Area (sq mi): 37.1 ® Stream
STORET Number. B0540000 Average Flow (cfs): 53.6 Estuary
Water Quality Class: C NSW Summer 7Q10 (cfs): 8.69 FILake,
Regional Office: Winston-Salem Winter 7Q10 (cfs): 12.2
Topographic Map: C20SW 30Q2 (cfs): 18.6 ❑ Fish Tissue
County: Guilford Fish Community
Subbasin: 030602 Gage: Gage Site
Benthic
STORET NC State Beginning Ending
Parameter Name Units Code Critenon Min Med Max n > Det > Crit Date Date
Disso:ved Oxygen
mg/l
00300
4
3.8
6.8
11.4
65
65
1
1/14/88
7/15/93
pH
SU
00400
6 - 9
6.5
7
7.6
65
65
0
1/14/88
7/15/93
Conductivity
µMho
00094
N/C
98
441
816
65
65
0
1/14/88
7/15/93
Chlorophyll a (Corr)
µg/1
32209
N/C
N/S
Fecal Coliform, MF
r/100 ml
31616
200
40
323.8
4200
17
17
1 12
3/23/92
7/15/93
Total Phosphorus
mg/I
00665
N/C
0.35
1
1.6
17
17
0
3/23/92
7/15/93
Ammonia -Nitrogen
mg/l
00610
N/C
0.17
0.59
6.5
17
17
0
3/23/92
7/15/93
Nitrate/Nithte-N
mg/1
00630
N/C
0.72
5.4
11
17
17
0
3/23/92
1 7/15/93
Total Nitrogen
mg/l
00600
N/C
N/S
Turbidity
NTU
00076
50
2.1
6.5
220
34
34
1 2
1/14/88
7/15/93
Hardness
mg/1
00900
N/C
31
69
93
33
33
0
1/14/88
7/15/93
Total Residue
mg/1
00500
N/C
210
310
700
48
48
0
1/14/88
2/25/92
Total Suspended Res
mg/l
00530
N/C
1
6
540
65
63
0
1 1/14/88
7/15/93
f_',iminum
µg/l
01105
N/C
50
160
1900
17
15
0
3/23/92
7/15/93
Arsenic
µg/1
01002
50
10
10
32
35
11
0
1114/88
7/15/93
Cadmium
µg/1
01027
2
2
2
3
49
5
2
1/14/88
7/15/93
Chromium
40
01034
50
25
25
50
49
1 1
0
1/14/88
1 7/15/93
Copper (AL)
ug/l
01042
7
3
10
89
49
45
33
1/14/88
7/15/93
Iron (AL)
4g/1
01045
1000
160
650
2100
17
17
3
3/23/92
7/15/93
Lead
4g/1
01051
25
10
10
240
48
10
4
1/14/88
7/15/93
Mercury
µg/l
71900
0.012
0.2
34
0
1/14/88
7/15/93
Manganese
µg/I
01055
N/C
35
130 1
420
12
12 1
0
4/15/92 1
7/15/93
Nickel
4g/1
01067
88
10
16
56
49
21 1
0
1/14/88 1
7/15/93
Zinc (AL) I
µg/l
01092
50
16
68
360
49
49 1
36
1/14/88
7/15/93
Abbreviations: n=number of observations; > Det=number of observations greater than the detection limit; > Crit=number of
observations greater than the criterion; N/S=No sample; N/C=No Criteria; AL --Action Level
Notes: Median values are calculated using the detection level for samples classified as below detection. The Median value for
Fecal Coliform is actually the Geometric Mean value. Data includes only surface samples. Samples recorded at less than
detection are considered at the detection level for this summary.
Station Comments:

Tedder, Steve W. 7
Water Quality
733-7015, Ext. SW
Testerman,
Raleigh Regional Office
5714700
Teulings, Catherine I.
Administration
733-7015, Ext. 206
Teulings, Robert P.
Construction Grants
I733 7015, Ext. 610
Thomas, Scot H.
Water Quality
733-7015, Ext. 563
Thompson, Susan G.
Raleigh Regional Office
1 5714700
Thomson, Grace W.
DEM Chemistry Lab
733-3908
Thorpe, Gregory J.F
Water Quality
733-7015, Ext. 557
Thorpe, Roger K.
Washington Regional Office
946-6481
Timin, Brian S.
IF Air Quality
733-7015, Ext. 317
Toler-McCullen, Marcia L.
IF Water Quality
733-7015, Ext. 504
Toma, N.S.
Groundwater
733-1320
Towe, Gene W. 71
Fayetteville Regional Office
[phone]
Tripp, James R.
Washington Regional Office
946-6481
Trivedi, Aparna K.I
Groundwater
733-1310
Trumbower, Kurt S.
Water Quality733-6510
Turner, Priscilla W.
Air Quality
733-7015, Ext. 303
Twisdale, Jefferson T.
Air Quality
733-7015, Ext. 322
Tynan, Mike A.
Mooresville Regional Office
[phone]
Tyndall, Cathy R. IF
Water Quality
733-6510
Ulmer, Stephen H. 7F
Water Quality
733-7015, Ext. 545
VanderVaart, Donald R.
Air Quality
733-7015, Ext. 302
Varner, Harvey N. III
Winston-Salem Regional Office
[phone]
Vaught, Michael L.
Groundwater
733-7015, Ext. 430
Vogel, Shannon M.
Air Quality733-1472
Vozzo, Steven F.
Raleigh Regional Office _jr5714700
Wagner, Brian A.
Groundwater
733-7015, Ext. 406
Wahab, Thomas A.
Construction Grants
733-7015, Ext. 616
Walker, Karen D.
Mooresville Regional Office
[phone]
Walker, Melanie H.
DEM Chemistry Lab
733-3908
Walton, Robert O.
Raleigh Regional Office JF
5714700
Wang, Kai -Ping
Groundwater
1 733-7015, Ext. 411
Wang, Shuyinh 7F
Winston Salem Regional Office
[phone]
Warburton, Thomas R.
Groundwater
733-1326
Warren, Garland E.j
Washington Regional Office
946-6481
Watters, William W.
Winston-Salem Re ional Office
[phone]
Weldon, Kaye A.
Groundwater
733-1316
M7

NORTH BUFFALO CREEK AT SR 2832 NEAR GREENSBORO, NC
Page 2 of 2
Summer Summary (April -October):
Observations Observs > Det Median Maximum Minimum
Dissolved Oxygen (mg/1):
pH (SU):
Total Phosphorus (mg/l):
Ammonia -Nitrogen (mg/l):
Nitrate/Nitrite-Nitrogen (mg/l):
Conductivity (1tMho):
Chlorophyll a (Corr) (µg/1):
Total Suspended Residue (mg/l):
39
39
6.4
7.6
3.8
39
39
7
7.4
6.5
11
11
1.1
1.6
0.5
11
11
0.59
5.1
0.17
11
11
6
11
2.2
39
39
445
816
98
NIS
39
38
5
540
1
Summer Summary (June -September):
Observations Observs > Det Median Maximum Minimum
Dissolved Oxygen (mg/1):
pH (SU):
Total Phosphorus (mg/l):
Ammonia -Nitrogen (m-gA):
Nitrate/Nitrite-Nitrogen (rnm):
Conductivity (1tMhc'
Chlorophyll a (Corr) (}.ugh;
Total Suspended Residue (mg/1).
Yearly Summary:
Dissolved Oxygen
22
22
6.2
7.6
5.2
22
22
7
7.4
6.5
6
6
1.25
1.6
0.5
6
6
0.47
5.1
0.17
6
6
7.2
11
2.2
22
22
436
816
102
NIS
22
21
5
260
1
Year Obs Obs>Det Median Max Min
1988
11
12
6.45
9.7
5.2
19 ]
12
12
7.3
10.4
6.2
19y0
12
12
7.2
9.4
5.8
1991
10
10
7.2
9.6
6
1992
121
1 12
1 6.6
9 1
5.4
1993
7
1 7
1 5.6
11.4 1
3.8
Conductivity
1988
12
12
398.5
609
98
1989
12
12
380
476
110
1990
12
12
395.5
605
234
1991
10
10
424
567
102
1992
12
12
502
693
276
1993
7
7
581
816
211
Total Suspended Residue
1988
12
11
6
540
1
1989
12
12
7
260
2
1990
12
12
5.5
37
2
1991
10
10
6
140
2
1992
1 12
11
1 4
1 22
1 1
1993
1 7 J.
7
1 9
18
1 5
]Z
Year Obs Obs>Det Median Max Min
1988
12
12
6.92
7.G
6.6
1989
12
12
7.1
7.3
6.6
1990
12
12
7.05
7.4
6.5
1991
10
10
7
7.4
6.5
1992 1
12
1 12
1 7.15
1 7.6
1 6.8
1993 1
7
1 7
1 6.7
1 7 1
6.5
19191-.
.,. .
1988
NIS
1989
NIS
1990
NIS
1991
NIS
1992
1 10
10
1.15
1.5
0.5
1993
1 7
7
0.61
1.6
0.35
Ammonia -Nitrogen

Mr. Ben Shiver
Proposed Chatham County WWTP
September 22, 1995
Page 2
BODS (Sum/Win)
NH3N (Sum/Win)
DO (minimum)
TSS
pH
Fecal Coliform
Residual Chlorine
Total Phosphorus
Chronic Toxicity*
Limits (30
day avg.)
nila
Pokeh= Creek
Haw River
mg/1
5/10
30
mg/1
2/4
mg/1
6.0
mg/1
30
30
SU
6.0-9.0
6.0-9.0
/100 nil
200
200
ug/1
17 (daily max)
28 (daily max)
mg/l
2.0
2.0
P/F @ %
2.1
*Toxicity Testing: Chronic / Ceriodaphnia - no observable inhibition of
reproduction or significant mortality at the percentage indicated, Quarterly Test.
Under current DEM procedure, dechlorination and chlorine limits are now required for
all new or expanding dischargers proposing the use of chlorine for disinfection. Levels of
residual chlorine in your effluent necessary to ensure against chronic toxicity in Pokeberry
Creek and in the Haw River are given above. The process of chlorination/dechlorination or
an alternate form of disinfection, such as ultraviolet radiation, should allow the facility to
comply with the total residual chlorine limits.
As you may know, DEM has adopted a whole river basin approach to water quality
management and protection, and the current Cape Fear Basin Plan has been drafted and
completed a public review period The draft plan indicates that DEM is planning to develop
a field calibrated water quality model for the Haw River from Reedy Fork to Jordan Lake.
The model will address the cummulative impacts of oxygen demanding wastewater
discharges in the Haw River system. Therefore, more stringent limits may be required for
the Haw River discharge in order to maintain water quality standards for dissolved oxygen
levels instream, as opposed to the limits given herein, which are based on a localized
modelling approach. Chatham County may want to consider the future implementation of
this basinwide strategy in planning its WWTP design.
Please be advised that response to this request does not guarantee that the Division will
issue an NPDES permit to discharge treated wastewater into these receiving waters. It
should be noted that a new facility involving an expenditure of public funds or use of
public (state) lands and having a design capacity of 0.5 MGD or greater (or a facility
proposing an expansion of 0.5 MGD or greater), or exceeding one-third of the 7Q10 of the
receiving stream will require the preparation of an environmental assessment (EA) by the
applicant. DEM will not accept a permit application for a project requiring an EA until the
document has been approved by the Department of Environment, Health and Natural
Resources and a Finding of No Significant Impact (FONSI) has been sent to the state
Clearinghouse for review and comment. The EA should contain a clear justification for the
proposed facility and an analysis of potential alternatives which should include a thorough
evaluation of non -discharge alternatives. In addition, an EA should show how water
reuse, conservation and inflow/infiltration reductions have been considered. Nondischarge
alternatives, such as spray irrigation, water conservation, inflow and infiltration reduction
or connection to a regional treatment and disposal system, are considered to be
environmentally preferable to a surface water discharge. In accordance with the North
Carolina General Statutes, the practicable waste treatment and disposal alternative with the
least adverse impact on the environment is required to be implemented. If the EA
demonstrates that the project may result in a significant adverse affect on the quality of the
T doA.-V

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O

West, Brian S.
Westall, Forest R.
White, Paul R.
Whiting, Chester E.
Whitley, Myron G.
Whitley, Pamela
Wicker, Michael
Wiggins, Kent
Wiggins, Mack K. Jr.
Wiggs, Linda S.
Wilburn, Diane
Wilcox, Bettv C.
Willets, William D.
Williams, Carla L.
Williams, Edward M.
Williams, Harold M.
Williams, Michael F.
Williams, Stephen B.
Williford, Nancy H.
Wilson, Michelle
Wilson, Stephanie
Wilson, Susan A.
Wix, Jennifer
Wood, Barbara 1.
Woosley, Julie S.
Wooten, Robert E. Jr.
Wootton, Charles B.
Yirka, Charles F.
Yirka, Mark J.
Young, Cheryl G.
Yount, Michael D
Zeigler, Kay K.
Zimmerman, Stanle,
Zoufaly, Stephen
Wilmington Regional Office
Asheville Regional Office
Asheville Regional Office
DEM Chemistry Lab
Winston-Salem Regional Office
Water Quality
Fayetteville Regional Office
Water Quality
Water Quality
Asheville Regional Office
Water Quality
Groundwater
Air Quality
Water Quality
Water Quality
DEM Chemistry Lab
Wilmington Regional Office
Winston-Salem Regional Office
Construction Grants
Water Quality
Water Quality
Water Quality
Mooresville Regional Office
Air Quality
DEM Chemistry Lab
Air Quality
Groundwater
Air Quality
Air Quality
DEM Chemistry Lab
Washington Regional Office
11 Groundwater
i Raleigh Regional Office
Water Quality
[phone]
[phone]
[phone]
733-3908
[phone]
733-7015, Ext. 558
[phone]
733-7015
733-7015, Ext. 542
[phone]
733-7015, Ext. 233
733-7015, Ext. 409
733-7015, Ext. 330
733-7015, Ext. 524
733-6510
733-3908
[phone]
[phone]
733-7015, Ext. 601
733-7015, Ext. 513
733-0026
733-7015, Ext. 555
[phone]
733-7015, Ext. 326
733-3908
733-1815
733-7015, Ext. 432
733-7015, Ext. 325
733-7015, Ext. 337
733-3908
946-6481
733-1302
571-4700
733-7015, Ext. 566

5/3/94
5/17/94
5/31 /94
6/9/94
6/13/94
6/16/94
6/23/94
6/28/94
7/1 /94
7/7/94
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8/26/94
9/1 /94
9/6/94
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9/20/94
9/23/94
9/29/94
EFFLUENT BOD5 (#/d)
N -Al O O O N A a) co
O O O O O O O O O O
O N A O co j
O O O O O O N A
O O Co
INSTRI=AM DO (mg/1)
O
m
ic
r
r
c
a
n
—1

McGee, Elizabeth A.
Water Quality
733-7015, Ext. 575
571-4700
McKemie, Babette K.
Raleigh Regional Office
McKinney, Edythe
Small Business Ombudsman
571-4840
McKinney, Tom H.
Air Quality
733-7015, Ext. 334
McLamb, Ricky W.
F Fayetteville Regional Office
[phone]
McLaurin, Lisa B.
Air Quality
733-7015, Ext. 305
McManus, Thomas L. III
Mooresville Regional Office
[phone]
McPherson ,Frances W.
Administration
733-7015, Ext. 210
Meares, Marjorie L.
Washington Regional Office
946-6481
Medlin, Kenneth N.
IF Water Quali
733-6946
Mesiano, Jeanne M.
Air Quality
715-4207
Metz, Carol D.
Water Quality
733-7015, Ext. 562
Mew, H.E. Jr.
Groundwater
733-7015, Ext. 423
Meyer, James W. JF
DEM Chemistry Lab
IF 733-3908
Mickey, Michael M.
Winston-Salem Regional Office JF
[phone]
Middleton, Francis J.
Construction Grants
733-7015, Ext. 609
Mileson, Beth E.
Air Quality
733-1475
Miller, Corey G.
Air Quality
733-1484
Miller, Kevin H.
Washington Regional Office
946-6481
Miller, Lelon
Air Quality 733-5235
Mills, William C.
Water Quality
733-7015, Ext. 548
Minnick, Harold E.
Asheville Regional Office
[phone]
Mitchell, Steven R.
Raleigh Regional Office_JL
571-4700
Moody, Michael D.
Fayetteville Regional Office
[phone]
Moore, Jerry
Washinton Regional Office j
946-6481
Moore, Sandra H.
DEM Chemist Lab
733-3908
Moore, William J.
Washington Regional Office
946-6481
Moras, Richard M.
Administration
733-7015, Ext. 224
Morey, A. Elizabeth
Groundwater
733-7015, Ext. 407
Morgan,
I DEM Chemistry Lab
733-3908
Morgan, Rodney A.
Raleigh Regional Office
571-4700
Morrison, Ilona T.
Construction Grants
733-7015, Ext. 632
Moser, Ste lien M.
Winston-Salem Regional Office
[phone]
Mouberry, Arthur
Groundwater
733-7015, Ext. 400
Muldrow, Cynthia D.
Air Quality
715-3510
Muller, Paul K.
Asheville Regional Office
[phone]
Mulligan, James H.
Washington Regional Office
946-6481

North Carolina Division of Environmental Management
Water Quality Section / Intensive Survey Group
August 26, 1993
MEMORANDUM
To: Ruth Swanek
Through: Jay Sauber
From: Howard Bryant
Subject: Long-term BOD Analysis forCone Mills
County: Guilford
NPDES # NC0000876
Receiving Stream: North Buffalo Creek
Sub -basin: 030602
DAY
BOD
NH3-N
TKN-N
NOX-N ILLU
0
0.30
2.5
0.02 2.5
5
35.8
0.27
1.9
0.01 1.9
10
52.2
0.34
2.7
0.01 2.7
15
67.4
0.60
4.0
0.01 4.0
20
76.6
0.65
2.8
0.15 3.0
25
85.4
30
90.3
0.05
1.5
1.10 2.6
35
95.2
40
99.9
50
115.2
0.05
3.3
3.00 6.3
60
128.4
70
135.1
80
139.3
90
142.0
100
144.1
110
145.5
120
146.6
0.06
2.9
4.60 7.5
160
150.5
Date Collected: January 14, 1993 Collected by: Hagstrom Test evaluation: excellent
1115-1120 pH:8.9 Seeded: seeded
NBOD: 21.02 CBOD: 129.48 CBOD/BOD-5: 3.62
qg. ' k.; O. 03 y
cc: Central Files
Regional Water Quality Supervisor G�� = J'{, j ' �� !JBo� ` `1• S y, G ` Cc�
C M: & 5 " IP7.5135• 7' 3. (o

3/6/95
SUBBASIN : 30608
MQ
Facility
NPDES #
Receiving Stream
County
Latitude
Longitude
fJD
15
Sharon Barker Residence
UT Deep River
36005'55"
80002'34"
Y
NC0048526
(Forsyth)
16
Crown MHP
UT Hickory Creek
35057'18"
79052'26"
NC0055255
(Guilford)
17
Martin Marietta Aggregates / Pamona Quarry
Long Branch
36003'20"
79055'30"
NCG020060
(Guilford)
18
Star Enterprise
UT Long Branch
36004'25"
79055'02"
NC0022209
(Guilford)
19
Carolina Steel Corporation / Colfax Plant
UT West Fork Deep River
36005'55"
80000'26"
NCG500238
(Guilford)
20
Plantation Pipeline Company
UT East Fork Deep River
36004'23"
79055'28"
NC0051161 - 001
(Guilford)
20
Plantation Pipeline Company
UT East Fork Deep River
36004'24"
79055'32"
NC0051161 - 002
(Guilford)
20
Ashland Petroleum Company
UT East Fork Deep River
36004'20"
79055'33"
NC0065803
(Guilford)
20
Louis Dreyfus Energy Corporation
UT East Fork Deep River
36004'27"
79055'23"
Y
NC0068063
(Guilford)
20
Amerada Hess / Greensboro Terminal
UT East Fork Deep River
36004'27"
7905546"
NC0069256
(Guilford)
20
GNC Energy Corporation
UT East Fork Deep River
36004'28"
79055'17"
NC0074241
(Guilford)
20
Louis Dreyfus Energy Corporation
UT East Fork Deep River
36004'29"
79055'24"
NC0026247
(Guilford)
20
Exxon Company, USA
UT East Fork Deep River
36004'34"
7905545"
NC0000795
(Guilford)
20
Shell Oil Company
UT East Fork Deep River
36004'37"
7905536"
Y
NC0073938 - 001
(Guilford)
20
Shell Oil Company
UT East Fork Deep River
36004'31"
79055'37"
Y
NC0073938 - 002
(Guilford)

F,FFLUENT TOXICITY TESTING 0[SELF-MONITORING SUMMARY) Fri, Sep 15, 1995
(:*.turd aocay cover rr yr r r rem r-c etv um: r3tla
s e. r...
lass
--
---
Pass
--
---
less
---
---
Pass
--
NC0036269/001 Degin:7/1/95 Frequency: Q Aug Nov Feb May
NonComp:ChrAvg
02 -
81.1
---
--
94.4
---
--
Pass
---
--
Pass
--
County:C.harrus Region: MRO Subbasin: YAD12
93 -
Pass
--
---
Pass
---
---
Pass
---
---
Fail
>99
1111:24.0 Special
94 01.5
Fail
L.to
>00,>90
>00
---
---
>99
--
--
61.06
.--
7Q10:1.1.0 IWC(1X-):73.0 Oakr:
05 --
>00
---
---
66, IS
01.1
Cone Mills - Cliffdde PERM CIIR i.IMA.2%
01 pass
-
--
14tae
---
•-
I+n..
---
---
Pall
---
Pass
NCUW4405=1 Degin:4/1/94 lImplency: Q 11/1, A Jan Apr Jul Oct
NonConiluSIN01,11.
02 rasa
Pan"
...
_.
Pn.a
...
...
Luto
Pan"
County:Rudrerfnnl Region: ARO Subbsin: BRD02
93 Fail
Pass
-
Page
-
Pass
---
---
Pass
-•
--
PF:1.75 Special
94 pass
-
-
Pass
/-
-
Pass
--
•--
Pass
•--
-
7Q10: 62.10 IWC(%): 4.19 Order:
95 Late
Pass
-
Pass
.E -
Pass
Pass
Cone Mills Grecnahoro401 PERM CIIR IAM:79%
Y 91 Fail
-
bt
Late
Pass(
Fell
Pass
--
Pass
--
---
Fall
NC0000876/001 9cgin: 10/i/93 Flue ry: Q P/F a Mar Jun Sep Ikc
NonConrp:SING1 J'-
92 Fall
---
Pas.
-
FAR
---
Pa..
---
Fall
---
--
NFl/Pa99
('aunty:Cmilfrnd Region:WSRO Subba.in:('1'F02
93 --
---
Fall
Fall
Fall
19
10
---
to
63
63
63
1111:1.25 Special
04 70.3
01.04
M
••-
81.05
66.0
27.03
27.03
27.00
Foll,27.03
<10.75
<10.76
7QI0:0.46 IWC(%):79 Order:
95 <19.75
27.95
<15
<15
<15
<15
12.25
Conoco, Inc. Grerashoro T nuul ITRM:4M 1111 AC MONfr 1(PIS
01 >00>00'
---
---
---
---
---
---
--.
---
---
--.
_-
N0007457MAX)1 rfrgin:6/I/'/0 11-jorocy:50WIVA
Non(bmp;
02 ...
---
---
---
---
---
---
...
...
---
...
...
Coanly:Guilroal Rrgiuv WSRO Suhbnsin:('111
03 >00'
---
---
...
IT .lM1n7 xprAnl
04 DO
...
...
.._
...
...
7Q10:0.00 IWC(96):1a).W
05 ...
>00
...
---
--•
---
---
Conoco, Inc.. Charlotte Prod, PERM:24 IIR AC MONrr 1 P1S I'r1ID (GRAD)
91 ---
•-
---
---
•--
---
--•
---
---
_--
_._
---
NC'0074705/001 Degin:9/l/93 Fnquency:5OWD/A
NonComp:
92 •-
--
---
•-•
--
--
-•
---
•--
-_
_-.
._
County: Mecklenburg Region: MRO Subbasin:CB34
93 -
--
.--
---
--
-
-
...
>1001
---
>1001,>1001 >1001,>100f
PF:0 Special
94 -
-
-
-_
-
-
-
.-
-
7Q10:0 lWC(%): IM.0 Oat-
05 ...
...
.--
---
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Conorn/Selma Pcoducl. Trrmina1/001 PERM: 2411R LC50 AC MONrr IlP1S
I -Till) (GRAD)
01 ---
...
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---
---
---
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._
-_
.-.
...
N00052311/001 Dcgin:2/28/94 Fnxrycncy: 5OWD/A
NonComp:
92 •-
--
...
--•
•--
--
...
--•
---
...
••.
---
County: Johnston Region: RRO Subbnsin: NEI702
93 - -
-
--
••-
-
-
...
--•
---
---
...
-
PF:- Special
94 -
-
-
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>1001,>1001
>1001.>100f >1001
'JQ 10: 0.0 IWC(%): 100.0 On1cr:
95 ._
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.-.
...
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---
,.
Conover NR W W Il PERM CIIR LIM:32%
Y 91 ---
-
Page
---
---
Pass
_•
---
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---
---
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NCO024252/001 Dcgin:2/In)3 I°aqucncy: Q P/V A Mar Jun Scp Ikc
NonComp:SINGI.E
92 ...
---
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•--
---
Fait
pass
---
pas,
---
--•
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County: Catawba Region: MRO Subbasin: CI1332
93 -
-
Pass
-
-
Pass
-
-•
Pass
-
--
Pass
PF: 1.5 Special
94 -
-
Pass
-
-
Pass
-
-•
Pass
---
-
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7Q10:5.0 IWC(%):32.0 Order
05 -
-
Pass
--
-
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-
Consolidated Melco, Inc. Perm chrlim:90%(permrcquircmentnot erfectivuntil 6/I/96)
91
NCO0587001001 Begin:6/1/95 14ccp+cncy: Q p/F A Fell May Aug Nov
NonComp:Singic
92
County: Union Region: MRO Subbasin: YAD
93
PF: special
94
7Qi0: IWC(%): Ogler:
95
Container Corporation Of America PERM CIIR IAM:11%
91 -
•-
--
---
--
--
---
---
...
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NC00050611001 Begin:5/I/94 Frequency: Q P/P A Jan Apr Jul Oct
NonComp:SINGLE
92 --
-
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---
--
-
_--
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_--
--.
Counly:Clcvclmd Region: MRO Subbasin: DRD04
93 -
-
-
--
--
--
---
--
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___
.._
-
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94 Pass
-
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Fall
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Fall
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---
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7Q10:0.12 IWC(9r•): 11.0 Ord-
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---
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NC0032077/001 Begin: 5/I/94 Frequency: Q P/F A Jan Apr Jul Oct
NonComp:SINGIX
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0 2 consecutive failums = significant noncompliance Y Pm 1991 Data Available
I J iGl-NI ):
I'1'.RM = Permit Requirement I.1- I' = Adnrinislmlive l.cucr - Target Frequency = Monitoring rn queucy: Q- Quan.dy; M- Momhly; BM. BimnnUdy; SA- Semiannually; A- Annually; OWD- Only wl+en disehm Bing; 1)- 1)rsrunlioucd monitoring n,qui-acnt; IS. ('on lusting Indc)x-ndnn study
Dcein = First month required 7QI O = Receiving stmam low Dow criterion (cfs) a = quarterly monitoring increases to monthly upon single failure Months that testing must occur - ex. JAN,APR,JUI.,0C71' NonComp = Cumnit Compliance Requirement
PF = Permitted Bow (MGD) JWC% = Instream waste concentration P/F = Pass/Fail chronic test AC = Acute CIIR = Chronic
Data Notation: f - Fathead Minnow; • - Ceriodaohnia sn.: my - Mvsid shrimp: ChV - Chronic value: P - Mortality of stated oereentaee at hiehest concentration; at - Performed by DEM Tox Eval Grouo: bt - Bad test
Reporting Notation: --- = Data not required; NR - Not reported; ( ) - Beginning of Quarto Facility Activity Status: I - Inactive, N - Newly lssued(ro construct); H - Active but not discharging; f-More data available for month in question f = ORC signature needed

14
A

Mr. Ben Shiver
Proposed Chatham County WWTP
September 22, 1995
Page 3
environment, an Environmental Impact Statement would be required. Monica Swihart of
the Water Quality Planning Branch can provide further information regarding the
requirements of the N.C. Environmental Policy Act.
If you have any questions please contact Jason Doll at [phone].
� 1
Sincerely
Donald Safrit, P.E.
Assistant Chief for Technical Support
Water Quality Section
Gc
c,v- h �RegionalOffice
David Goodrich - NPDES Permits Group
Monica Swihart - Planning Branch
Central Files

Page 1
Note for Jason Doll
From: Larry Ausley
Date: Mon, Oct 9, 1995 7:05 AM
Subject: RE: Cone Mills
To: Jason Doll
I don't think they'd ever do anything under a permit. The currently proposed SOC and show
cause with EPA is the only thing I've seen so far that would get them moving. I still don't
know if Greensboro is going to take them, particularly as long as they are toxic. Our SOC
has been prepared so far under the assumption that they will have to solve their problem
where they are.
From: Jason Doll on Fri, Oct 6, 1995 5:24 PM
Subject: Cone Mills
To: Larry Ausley
I am currently in the process of doing the wasteload for their NPDES permit, which we will
notice in a month or two. I know we've discussed this before, so I'll save you the
explanation of the their history. Obviously, the main goal is still to tie them on to
Greensboro. I wanted to see if you (or Kevin Bowden) had any recommendations on
anything we could do via NPDES permit to better motivate their TIEWRE work and/or
facilitate connection. Let me know if you have any good ideas.
Thanks, Jason

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cc: Permits and Engineering
Technical Support Branch
County Health Dept.
Central Files
WSRO
SOC PRIORITY PROJECT: Yes X No
If Yes, SOC No. 95-17
To: Permits and Engineering Unit
Water Quality Section
Attention: Susan Wilson (Review Engineer)
Date: 950908
NPDES STAFF REPORT AND RECOMMENDATION
County Guilford
Permit No. NC 0000876
PART I - GENERAL INFORMATION
1. Facility and Address: Arthur J. Toompas
Cone Mills Corporation
1201 Maple St.
Greensboro, NC 27405
2. Date of Investigation: 950830
3. Report Prepared by: Ron Linville
4. Persons Contacted and Telephone Number:
Arthur Toompas and John Hodges of Cone Mills @ 910/379-6226.
5. Directions to Site: Go Hwy 29N from I-40/85, exit and turn
left on 16th St. Turn Lt. on Fairview past corporate
offices then left on Textile Drive and then left on Upland
Dr. WWTP is at the end of Upland Dr.
6. Discharge Points(s), List for all discharge points:
Outfall 001:
Latitude:
36o06115"
Longitude:
79o46115"
Outfall 005:
(reported as
once thru cooling
& cooling tower)
Latitude:
36o06120"
Longitude:
79o46112"
Outfall 006:
(reported as
cooling tower
only)
Latitude:
36o06102"
Longitude:
79o46102"
U.S.G.S. Quad
No. Greensboro U.S.G.S.
Quad Name C19SE

7. Site size and expansion area consistent with application ?
X Yes No If No, explain:
8. Topography (relationship to flood plain included):
WWTP in floodplain. Serious flooding of site unknown
although operational concerns may exist.
9. Location of nearest dwelling: None known within 1000'
10. Receiving stream or affected surface waters:
North Buffalo Creek
a. Classification: C-NSW
b. River Basin and Subbasin No.: CPF030602
C. Describe receiving stream features and pertinent
downstream uses: Suburban/rural mix. More rural
outside of city limits.
Part II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
1. a. Volume of Wastewater to be permitted: 1.25 MGD
(Ultimate Design Capacity)
b. What is the current permitted capacity of the Waste
Water Treatment facility? 1.25 MGD
C. Actual treatment capacity of the current facility
(current design capacity)? Reportedly 3.5 MGD
d. Date(s) and construction activities allowed by previous
Authorizations to Construct issued in the previous two
years. None known.
e. Please provide a description of existing or
substantially constructed wastewater treatment
facilities: Some dye reclamation occurs at the
manufacturing plant, leftover dyes are sent via
collection system with domestic waste to the WWTP.
The treatment facility consist of pre-treatment
screening, equalization basin, CO2 and Acid
neutralization, additional screening. Additional
biological treatment using activated sludge process
includes 2 primary clarifiers, chemical
coagulation/flocculation and polymer addition, 4.0 MG
surface aeration basin, 3 secondary clarifiers with
chemical addition capabilities, flow meter,
chlorination, polishing pond, effluent reaeration and
automatic sampler. Residuals handling includes
thickener, aerobic digester and truck transfer station.
NPDES Permit Staff Report
Version 10/92
Page 2

f. Please provide a description of proposed wastewater
treatment facilities. Connection to POTW.
g. Possible toxic impacts to surface waters: Toxicity
issues are significant and potentially numerous.
h. Pretreatment Program (POTWs only):
in development approved
should be required X* not needed
*when connected to POTW
2. Resid-L.-:ls handling and utilization/disposal scheme:
a. Ik residuals are being land applied, please specify DEM
Permit No. W00003760
Residuals Contractor: Cone Mills
Telephone No. 910/379-6226
b. Residuals stabilization: PSRP X PFRP
Other (100 day digester storage)
C. Landfill: None, except for solids removed in
screenings.
d. Other disposal/utilization scheme (Specify):
3. Treatment plant classification (attach completed rating
sheet) . IV
4. SIC Code(s): 2211 & 2261
Primary 02 Secondary 55
Main Treatment Unit Code: 012 3
PART III - OTHER PERTINENT INFORMATION
1. Is this facility being constructed with Construction Grant
Funds or are any public monies involved. (municipals only)?
2. Special monitoring or limitations (including toxicity)
requests: SOC has been requested and connection to POTW is
likely if chronic values improve consistently.
3. Important SOC, JOC or Compliance Schedule dates: (Please
NPDES Permit Staff Report
Version 10/92
Page 3

indicate)
Date
Submission of Plans and Specifications To be determined
Begin Construction in upcoming SOC
Complete Construction document.
4. Alternative Analysis Evaluation: Has the facility evaluated
all of the non -discharge options available. Please provide
regional perspective for each option evaluated.
Spray Irrigation: Existing for residuals.
Connection to Regional Sewer System: Should occur within
the near futui if City of Greensboro will accept.
Subsurface: Not enough room.
Other disposal options: Unknown.
5. Other Special Items: The Corporation is currently
working with DEM and the City to move towards resolving
toxicity issue:• so that this discharge may be diverted to
the North Buffalo WWTP and the Osborne WWTP via pumping.
Long-term BODq may need further review by DEM.
Due to the reported partially supporting/poor-fair quality
of this stream segment, the Division should scrutinize and
consider tightening the limits currently in place for this
NPDES Permit. Correlation to other NPDES Permit limits for
North Buffalo Creek, South Buffalo Creek and Buffalo Creek
should also occur. Special concern should be focused on the
pounds limits currently allowed for Cone Mills. Cone's
salt, conductivity, long-term BOD and COD (other parameters
as appropriate) should be specifically reviewed and
evaluated. This facility needs to be encouraged to connect
to the available POTW collection system which passes through
the manufacturing plant.
The Aquatic Toxicology Unit may be able to provide
additional insights as to any proposed Permit limits.
PART IV - EVALUATION AND RECOMMENDATIONS
The WSRO recommends that the new NPDES Permit be issued for
a short term of 2 years (until after the proposed SOC
expires and/or the corporation connects to the POTW). The
connection date is likely to occur when the City completes
proposed upgrades (anticipated for October 1998). Cone
intends to rectify Toxicity issues and become a pretreatment
program prior to this time. If connection occurs, the NPDES
Permit should be voided without delay.
NPDES Permit Staff Report
Version 10/92
Page 4

The flow allotted to this facility should be allocated to
Greensboro. It is recommended that consideration of a flow
increase at the Osborne WWTP (NC0047384) be reviewed for
appropriate action as deemed appropriate and necessary by
the Division.
S'gnature of report preparer
Water Quallcy Reg' nal Supervisor
i
Date
NPDES Permit Staff Report
Version 10/92
Page 5

State of North Carolina
Department of Environment,
Health and Natural Resources
Winston-Salem Regional Office
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
Leesha Fuller, Regional Manager
1:3F=HNFZ
DIVISION OF ENVIRONMENTAL, MANAGEMENT
September 7, 1995
Mr. Arthur Toompas
Cone Mills Corp.
1201 Maple St.
Greensboro, NC 27405
SUBJECT: Compliance Sampling Inspection
Cone Mills White Oak WWTP
NPDES No. NC0000876
Guilford County
Dear Mr. Toompas:
The referenced sampling performed on July 10 and 11, 1995 by
Mr. David Russell and Mr. Ron Linville of this office provided
the following sampling results:
Parameter Lab Value x 8.34 x 1.094 MGD= Lbs Da
BOD
3.4 mg/1
31.02
COD
120 mg/1
1094.88
Fecal coliform'
20/100 ml
TSS
12 mg/1
109.49
pH
8.7 SUs
Hardness
30 mg/1
Spec. Cond.
4300 uMhos/cm2
MBAS
0.3 mg/1
Phenols
4 ug/1
0.0365
Sulfate
610 mg/1
Sulfide
<0.1 mg/1
0.912
NH3-N
0.37 mg/1
3.376
TKN-N
4.1 mg/l
NO2+NO3-N
0.04 mg/1
Total P
1.9 mg/1
Cd
<2.0 ug/1
Cr
<25 ug/1
Cu
<2.0 ug/1
Ni
<10 ug/1
Pb
<10 ug/l
Zn
63 ug/1
Ag
<5.0 ug/1
Al
170 ug/l
Ca
9.6 mg/1
Fe
360 ug/1
Li
<25 ug/l
585 Wauphtown Street, Winston-Salem, North Carolina 27107-2241 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 60% recycled/ 10% post -consumer paper

Arthur Toompas
Cone Mills Data
950907
Mg
Mn
Na
Arsenic
Hg
Should you
related matters,
Mauney or me at
MSM:rl
Continued
3.6 mg/l
62 ug/l
1000 mg/l
<10 ug/l
<0.2 ug/l
have questions regarding these figures or other
please contact Mr. Ron Linville, Mr. Steve
[phone].
CC: Guilford County
Central Files
WSRO
ncerely,
M. Steve auney
Water Quality Supervisor
Health Department
Arthur White, City of Greensboro
a:\conedata.ltr

Page 1
Note for Jason Doll
From: Larry Ausley
Date: Wed, Sep 6, 1995 7:25 AM
Subject: RE: TIE%rRE Evaluations
To: Jason Doll
Star has made some good improvements and has a good consultant on line (BRI). It is
reasonable (if not mandatory) that we consider anyone to have the ability to meet whatever
limit they end up with if we issue them a permit to discharge. There are a lot of municipals
meeting the 90% limit, as did Staar in May, 1995. I give them a thumbs up at this point.
The region and we met with Cone last week to discuss their plans. After sitting there for six
hours, I remain unconvinced whether their plans will get them where they need to go. They
are accepting bids for a THE but if past history holds true, they will try to piecemeal the
whole thing and wind up a lot poorer and as or more toxic. Until I see positive results, their
activities are window dressing in my mind, awaiting their tie on to Greensboro. I'm not sure
THAT is a given without solution of the tox problem. WSRO gives me the impression
Greensboro doesn't really want them.
From: Jason Doll on Tue, Sep 5, 1995 4:52 PM
Subject: TIE/rRE Evaluations
To: Larry Ausley; Matt Mathews
I'm currently working on a request for speculative limits for the Town of Star WWTP and
the wasteload for Cone Mills (Greensboro Plant). I wanted to take a minute at this somewhat
pivotal point in the NPDES process for these facilities and get the word from you guys on
their efforts thus far. My particular questions might be: 1) Do you think they are making a
legitimate good faith effort at this point, and if so is it producing significant improvements?
2) If not, is there anything we can do on this end to make them move faster or more
diligently? 3) Is there still significant room for improvment at the respective facilities?
Basically, I want the scoop on where they are and where they should go from here.
Let me tell you what they are up to from my end, in case you don't already know.
Star is looking into relocating their 0.6 MGD outfall further downstream in Cotton Cr. solely
to increase dilution and get a lower tox limit (sound familiar?), but due to the hydrology in
that area, little additional (7Q10) flow is gained as you move downstream. They gain
nothing from the prospective site they inquired about, since it has only a minimal positive
flow (0.08 cfs). I'm about to send them a letter saying that in order to achieve their stated
goal in terms of IWC, 75%, at which they feel they could achieve consistent compliance,
they would have to move a considerable distance further downstream and lower the flow
limit in the permit to 0.5 MGD. The consultant (Ron Huff, Hobbs & Upchurch) says he
doen't think its realistic for them to go any further than the site he gave me, and they will
likely stay where they are now (7Q10=0.0). Can we realistically expect Star to pass at 90%?
Results show thay have made some improvement in the last year, but can they do
substantially better? In fact, test results at this point don't support the notion that they could
pass at 75%, and I said so in the letter.
I'm sure you know we've been trying to get Greensboro to tie on Cone Mills, but G'boro
will not take them until they show consistently improved tox results. So Cone's TIE[MW
work is particularly important in the long run in terms of water quality in Buffalo Creek (i.e.

Page 2
it would be a big improvement to get them out of that stream). I wanted to see if you got
anything substantive out of the meeting with them last week, and get your read on where they
are at now. Note than when I framed my questions in terms of "good faith effort" I had
Cone in mind.
If you have any questions or need any more info. give me a call.
Thanks, Jason

July 21, 1995
Mr. Arthur
Cone Mills
1201 Maple
Greensboro,
Dear Art:
CITY OF GREENSBORO-
P.O. BOX 3136
NORTH CAROLINA 13 E BORO, NC 27402-3136
� R
JUL 31 1995
Toompas
Corporation
Street
NC 27405
This letter will confirm our conversation of July 21, 1995,
concerning Cone Mills desire to connect to the City of Greensboro
sanitary sewer system. The City is in receipt of a Significant
Industrial User Wastewater Discharge Permit Application from Cone
dated November 4, 1994.
Our major concern is, of course, the toxicity of the Cone Mills
waste. You have indicated that efforts are ongoing through a
Toxicity Reduction Evaluation process to locate and reduce the
toxic elements. Prior to approving any application to connect to
the sanitary sewer system, Cone must permanently reduce the
toxicity level in the waste so that after dilution with the
municipal wastewater the City will be able to continue to
consistently pass the toxicity requirements included in the
Greensboro NPDES permits.
Please keep us informed of your progress and let us know if we
can be of assistance to you.
Very truly yours,
Ray E. Shaw, Jr.
Public Utilities Director
cc: Preston Howard
Steve Tedder
Larry Coble
Martie Groome
3/16918-1656
640

NORTH CAROLINA DEPARTMENT OF ENVIRONMENT
HEALTH AND NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL MANAGEMENT
September 27, 1994
MEMORANDUM
TO: Jay Sauber
FROM: Mike Mickey lam`
THROUGH: Steve Mauney /11�
SUBJECT: Water Quality Standard Violations
Cone Mills White Oak WWTP
NPDES Permit No. NC0000876
Guilford County
At the recent Inspectors Training Course you recommended that the Regions advise the
Environmental Sciences Branch of any water quality problems below permitted facilities. In
response to your request, please be advised that violations of the dissolved oxygen water quality
standard are occurring in North Buffalo Creek below the Cone Mills White Oak WWTP.
During the summer of 1993, self monitoring data submitted by Cone Mills showed sixteen
violations of the 4.0 mg/l dissolved oxygen water quality standard in North Buffalo Creek (See
�h A�" data in Table 1). During this time period the facility was also in noncompliance with effluent
0 ' limits and reporting requirements and was assessed a civil penalty. of $140,847 on June 17, 1994.
To further substantiate the dissolved oxygen problem in North Buffalo Creek below the White
Oak facility, WSRO also compared Cone Mills upstream dissolved oxygen data with dissolved
oxygen data from the City of Greensboro's upstream sampling point at their North Buffalo
`Wks POTW. Greensboro's upstream point is located further downstream from Cone Mills outfall.
An evaluation of Greensboro's data for the summer of 1993 shows 40 days where their upstream
dissolved oxygen measurements were below the 4.0 mg/1 water quality standard.
A review of the 1994 self monitoring data received to date from Cone Mills shows their
White Oak facility to be in compliance with the oxygen demanding parameters of their permit.
The only effluent limit violations reported involved flow in February and July and toxicity
failures in June and July. However, even while in substantial compliance, stream monitoring data
from North Buffalo Creek in 1994 continues to show violations of the dissolved oxygen water
quality standard (See data in Table 2). Obviously, the existing limits in Cone Mills permit are
not protecting water quality in North Buffalo Creek. In addition, the downstream sampling point
specified in Cone Mills permit is well above the D.O. sag point.
Please give me a call if you have any questions.
cc: Dave Goodrich
Central Files
WSRO

D.O. WATER QUALITY STANDARD VIOLATIONS
BELOW THE CONE MILLS WHITE OAK WWTP
IN NORTH BUFFALO CREEK
Table 1
Cone Mills Stream Data
1993 Self Monitoring Reports
Upstream
Downstream
Upstream
Downstream
Date
D.O.
D.O.
Date
D.O.
D.O.
4-28-93
8.6
3.5
8-02-93
4.7
3.8
5-12-93
9.2
3.7
8-03-93
5.1
2.4
6-21-93
7.8
1.4
8-04-93
4.8
3.6
7-13-93
4.2
3.2
8-06-93
5.5
3.0
7-19-93
4.8
3.7
8-09-93
5.8
3.0
7-28-93
6.0
1.4
8-10-93
6.3
2.9
7-29-93
4.4
1.4
8-11-93
5.8
3.3
7-30-93
4.6
1.6
8-16-93
5.2
3.9
Table 2
1994 Stream Data
Cone Mills and Greensboro's Monitoring Reports
Upstream*
Downstream"
Upstream
Downstream
Date
D.O.
D.O.
Date
D.O.
D.O.
5-17-94
6.0
3.6
7-05-94
6.0
2.8
5-26-94
7.4
2.5
7-07-94
7.2
2.1
5-31-94
6.6
2.1
7-08-94
6.3
2.1
6-07-94
5.8
1.7
7-12-94
6.2
2.4
6-09-94
5.3
2.6
7-14-94
6.7
2.1
6-10-94
5.4
2.6
7-15-94
6.3
2.5
6-13-94
5.9
2.5
7-19-94
7.8
2.5
6-14-94
5.3
2.3
7-22-94
8.0
3.2
6-16-94
5.8
2.0
8-09-84
+
1.6
6-21-94
8.0
2.6
8-11-94
+
3.3
6-23-94
5.3
2.5
8-12-94
+
2.7
6-28-94
5.6
3.3
8-19-94
+
3.9
`Data from Cone Mills DMR's.
"Data from Greensboro's North Buffalo DMR's.
+Data not yet submitted.

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CONE MILLS RECENT HISTORY
Fi-C 444 MT c
December 31, 1992 - Cone Mills submitted an NDPES application for a permit
modification and renewal. The only permit modification requested at this
time was for a wasteflow increase from 1.1 MGD to 1.25 MGD. This flow
increase was granted at existing loading (100 lbs/day in summertime). Cone
also has a concentration limit of 10 mg/1.
July 20, 1993 - After reviewing the draft permit (noticed June 25, 1993), Cone
set up a meeting with DEM to request a five -pound increase in the proposed
BOD5 limit. Cone also expressed a desire to augment instream flow by
manipulation of an upstream impoundment which is controlled by Cone (see
attached memo re: meeting).
Summer 1993 - Cone did not report the required daily BOD5 measurements
for three or four months. They indicated on their DMR's that there was
sample interference. According to Jim Johnston, they claimed that there was
a problem with the Winkler method of calibration which made their sample
results invalid. (Air calibration is the preferred method of calibration. Jim
also said that he has some "inside information" that the data may have been
purposely surpressed because results during this period were not within
permitted limits.)
September 10, 1993 - Permit was issued WITHOUT requested increase in
limit. The decision not to increase the BOD5 limit was based on the fact that
instream DO downstream from Cone was found to be routinely well below
the water quality standard (see attached cover letter to permit and instream
data). It was noted in the cover letter that BOD5 results were not being
reported and Cone was told to rectify this situation as soon as possible.
January 1994 - Enforcement action for non -reporting of BOD5 data...
NOTE: I never did finish the letter regarding the flow augmentation issue.
I'm still planning to do so.
Winston-Salem Regional staff is also concerned about the solids coming from
Cone's discharge. Although the plant is less than 1.5 miles from the
Greensboro North Buffalo Creek WWTP, the POTW does not have capacity at
this time to take Cone's discharge. There have been no recent negotiations
between Cone and Greensboro regarding tie-in and there is not likely to be
any in the near future.
- Goodrich (2/14/94)

NORTH CAROLINA DEPARTMENT OF ENVIRONMENT
HEALTH AND NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL MANAGEMENT
August 12, 1993
_ sir
Irk �� .. ...:'..
M E M 0 R A N D U M 91,
TO: David Goodrich
Rapid Assessment Group �ECH�I�RLUPPtiRT g�p�_CM $
Technical Support Branch
Through: Steve Mauney, Supervisor '-2-1-
WSRO, WQ
From: Art Hagstrom
Environmental Engin er,RO, WQ
Subject: Permit Limits based upon stream augmentation for
Cone MIlls WWTP, NPDES Permit No.NC0000876, 1993 Renewal
NPDES Permit No. Guilford County 03-06-02
The use of stream augmentation as offered by Cone to allow
an increase in BOD5 from 100 lbs./day to 105 lbs./day
at the new increased flow rate of 1.25 MGD appears to be a
reasonable trade-off when only BOD5 is concerned.
During this summer North and South Buffalo Creeks and
Buffalo Creek appear to be in stress. Low DO and high
conductivity between Cone's discharge and North Buffalo WWTP
suggest the need for more strict limits not less for Cone.
It would appear appropriate to require that Cone, as part of
its Permit, further evaluate its dye processes, the dyes it
uses, more in plant pretreatment, solids removal systems,
and the upgrading of its WWPT to determine how they will
further improve effluent quality. Cone should also provide a
schedule to make the improvements.
However, in order to get on with this permit, the augmented
flow proposal and 105 lbs./day BOD5 appear to be the correct
way for DEM to go. -The Permit limits may not be controlling
the right effluent constituents, since they generally meet
all of the limits, but have trouble meeting toxics.
msm/arh
cc: Coleen Sullins
In -stream Assessment Unit
Central Files
WSRO

DIVISION OF ENVIkONMENTAL MANAGEMENT
Water Quality Section/Rapid Assessment Group
JL4 ty 2,71 t `79
MEMORANDUM
TO: Don Safrit
Ruth Swanek
Mike Scoville
Carla Sanderson
FROM: Dave Goodrich
SUBJECT: Cone Mills - Greensboro Facility 1993 Permit Renewal
NC0000876
Guilford County
030602
NCT-&5
F)�vM -71a A40P NCT
On July 20, 1993, Cone Mills met with DEM staff to discuss their draft permit.
Attending the meeting were: Arthur Toompas (Manager of Water and Air Resources at
Cone Mills), Ed Barnhart (President of Hydroscience, Inc.), John Hodges (Environmental
Engineer at Cone Mills), Raymond Fuquay (Vice President at Cone Mills), Coleen Sullins
(P & E), Larry Coble (WSRO), Steve Mauney (WSRO), and Art Hagstrom (WSRO).
Cone Mills had two concerns:
1. They requested an additional five lbs/day of BOD5 be added to their monthly
average mass limit.
2. They proposed to augment flow through manipulation of an upstream lake
owned by Cone Mills.
Background
Cone Mills discharges 1.0 MGD of process wastewater from their textile plant to
North Buffalo Creek, just upstream of Greensboro's North Buffalo Creek WWTP. Cone
Mills requested a modification from 1.0 MGD to 1.25 MGD in 1993. This expanded
hydraulic flow was allowed, but loadings were kept the same. Their existing permit has
expired (6/30/93) and the new permit has been drafted by Alvarez.
Buffalo Lake is a 94-acre impoundment situated just upstream of Cone Mills' 005
outfall on an unnamed tributary to North Buffalo Creek. It is owned by Cone Mills and is
connected to Lake Jeanette (also known as Richland Lake) by a pipeline which can be used
to augment flow to the lake. Lake Jeanette is a 260-acre lake located upstream of Lake
Townsend (Greensboro's primary water supply) on Richland Creek.
Request to Increase BOD5 Mass Limit
Ed Barnhart pointed out that the limits for BOD5 (below) were somewhat
inconsistent since the concentration -based limit was less stringent at high wasteflows than
the mass limit. I explained that the mass limit was meant as a "cap" for BOD. Also, given
the high IWC, it is reasonable to expect water quality impacts even at low wasteflows
hence the concentration limit.

page -2- `
Cone Mills Memo re: Flow Augmentation and Request for an Increase in BOD5 Limit
+Z,,� �,,-_._laly 27 1993
-----------------------------------------------------------------------------------------------------------
Cone Mills BOD5 Limits
EXISTING PROPOSED (DEM) PROPOSED (Cone Mills)
BOD5 (lbs/day)* 100 100 105
BOD5 (mg/1)* 10.0 10.0 10.0
*Represents summertime limits.
------------------------------------------------------------------------------------------------------------
According to Cone Mills, the additional five lbs/day is not within the error of the model and
would help them comply more consistently. Also, changing the BOD5 mass limit to 105
lbs/day would be consistent with the concentration limit. (Actually, a mass limit of 104
lbs/day would be the correct conversion number.)
I explained to Cone Mills staff and Ed Barnhart that we would have to look into
this. I also informed them that as we talked, members of our ESB were collecting data in
North Buffalo Creek as part of our T-O-T study to be used in a QUAL2E model. I also
said that a thorough review of existing water quality data would be necessary to make a
decision on this request.
I agree with Barnhart that it may be beyond the accuracy of the model to
differentiate between the instream effect that an additional five lbs/day of BOD may have. Pj/Cme -
However, according to data collected by ESB and the City of Greensboro (see attached.C/
summary), the DO standard is contravened on a regular basis. As a result, I do not believe
any additional loading should be permitted at this time.
Flow Augmentation
(Please see attached map which is referenced in this discussion.) Cone Mills has an
IWC of 79% and has been passing WET tests approximately 50% of the time. Cone Mills
is proposing to increase the S7Q10 from 0.46 cfs to approximately 3.7 cfs (guaranteed
minimum release).
Philosophically, adding dilution to improve water quality is less than an ideal
situation. However, minimum releases have routinely been permitted throughout the state.
These discharges often increase 7Q10 by a significant amount. Flow augmentation may
actually help improve the quality of water downstream of the release. I spoke with Jim
Mead (DWR) who said that his division has no philosophical disagreement with flow
augmentation as long as certain factors are considered. Members of the meeting agreed
with this viewpoint, and through conversations with Mead, Sullins, Coble, Mauney, and
Hagstrom, I offer the following concerns which were brought to the attention of Cone
Mills at the 7/20/93 meeting:
Technical Considerations
Is such a flow augmentation feasible? Cone Mills was told they should provide a
detailed technical analysis of this proposal to the Division of Land Resources, DEM, and
the City of Greensboro (since this could affect Lake Townsend). I suggested that Cone
Mills may want to reopen their dam safety permits for Richland and Buffalo Lakes. These
permits could be used as a mechanism to demonstrate the technical feasibility of this
proposal.
Water Quality Concerns
Will flow augmentatation significantly alter fish and wildlife habitat in the two lakes
and in the downstream channel? I told Toompas that the questions regarding habitat
changes should be directed to Sherry Bryant, District Fisheries Biologist for the Wildlife
Resources Commission.

page -3- `
Cone Mills Memo re: Flow. Augmentation and Request for an Increase in BOD5 Limit
Fcbruary43-,4994-J u Y Z7 I ql c43
Furthermore, what is the water quality of the augmentation sources? Does Buffalo
Lake stratify? From what part of the water column will the outflow structure draw water to
discharge?
Relocation of the 001 Outfall
If flow augmentation is allowed, the 001 pipe should be relocated below the UT
which conveys the release from Buffalo Lake. This was discussed at the meeting.
Monitoring
Cone Mills has offered to install a gage downstream of the dam, but upstream of
their discharge. Instream monitoring of water quality could also be changed to address
water quality in Buffalo Lake and North Buffalo Creek.
Cone Mills adjudicated their last permit for several years, and everyone at the
meeting expressed an interest in getting this draft permit issued quickly. This permit would
expire in 1996, so the flow augmentation issue should be resolved separately from the
BODS issue (i.e., let's resolve the BOD issue, get the permit out, and take our time with
the flow augmentation). Please let me know if you'd like to discuss these matters. I have
provided separate copies of this memorandum to all those addressed. Sullins volunteered
me to send a letter to Cone Mills which I will do after receiving everyone's comments.
cc: Coleen Sullins
Steve Mauney

City of Greensboro North Buffalo Creek WWTP - Instream Data
Upstream -at Influent Conduit
Temperature
Dissolved Oxygen
DATE
°C)
(mg/1)
Nov-92
14
3.7
Oct-92
22
4.4
Aug-92
23
4.6
Jul-92
24
4.3
Jun-92
20
4.7
May-92
18
5.7
Apr-92
14
6.5
Mar-92
8
9.1
Feb-92
8
9.7
Jan-92
7
10.4
VALUES GIVEN ARE MONTHLY AVERAGES
Downstream at Sampling Pier
Temperature I Dissolved Oxygen
20
6.8
24
7.1
25
6.7
25
6.3
21
6.8
18
7.1
16
7.4
12
9.1
13
9.3
13
9.4
7/27/93

ATTACHMENT 1. DISSOLVED OXYGEN DATA FROM NORTH BUFFALO CREEK
(,fF s TJ�eAM
u fnl S 6A I
- Date
Ups. of Cone
turnmit Ave.
Ups. of G'boro
Ds. of.G'boro
Rankin Mill Rd
- 4/1/93
9.0
8.8
4/2/93
8.8
92
-_ --_ -- 4/5/93
9.5
8.8
4/6/93
9.6
92
_ 4/7/93
9.0
8.8
4/8/93
10.2
8.4
7.1
7.0
6.8
- 419/93
4112/93
7.4
72
4/13/93
9.7
72
6.5
7.8
4/14/93
9.9
72
4/15/93
4/16/93
4/19/93
9.3
7.3
_ t x,' 5.2 5.3
42 5.8 4.9
1.3 5.2 2.4
.,, 0.6 4.9 4.0
- -
- -
3.2 5.3 5.8
7.7
7.8
9.2
6.0
4/20/93
8.2
6.5
4/21 /93
7.4
5.4
4/22/93
4/23/93
4/26/93
4/27/93
4/28193
4/29/93
4/30/93
8.3
7.0
7.9
6.5
6.8
6.2
8.2
6.9
8.6
5
8.3
5.3
8.6
11.0
6.3
7.2
5/3/93
5/4/93
--- 5/5/93
5/6/93
5/7/93
5.6
�:
7.5
6.7
7.9
5.7
7.0
5.8
5/10/93
7.3
6.0
5/1 1/93
9.2
5.9
5/12/93
5113/93
5/14/93
9.2
37
8.8
4,0
8.6
4.2
5/17/93
8.0
4.1
5/18/93
6.2
5.6
5.9
5/19/93
6.3
5/20/93
7.0
6.2
5/21/93
6.6
5/24/93
7.0
5.3
5/25/93
8.0
,.
6.4
6.4
8.2
5/26/93
- 5/27/93
- -
6.9
6.4
7.9
5.7
- -
5/28/93
5/31 /93
7.3
5.9
*VIOLATIONS OF THE D.O. STANDARD ARE SHADED AND SHOWN IN BOLD PRINT.

ATTACHMENT 1. DISSOLVED
OXYGEN
D� cost
DATA FROM NORTH BUFFALO CREEK
�uAmm� 01-5. OF 7g. of
c I�r0 -1 I �
q J, CJ►./
ML- lcP.
6/1/93
- 6/2/93
6/3/93
6/4/93
6/7/93
6/8/93
6/9/93
6/10/93
6/11/93
6/14/93
- 6/15/93
- 6/16/93
- - 6/17/93
7.2
7.G 4.2
5.2
6.2
4.9
4.9
.. 4.4
6.4
7.0
7.0 2,9
- 5.9
7.0
6.8
7.2
6.6
2.3'!
6 3
7.6
2.2
5.3
5.0
6.9
1.8
6.2
5.0
6.7
7.2
5.8
8.5
8.0
6.0
1.3
4.8
4.7
7.9
6.2
; 2.1
6.0
5.3
8.2
7.3
6.6
2.0
8.3
7.9
5.9
5.3 _ {f.$
7.2
8.2
5.8
_ 2.2
4.3
2.6
V 3.0
3.7
6/18/93
7.2
5.5 - -
1.4 {t ..; 4.9
4.41 4 4.9
5.3
4.9 0.3 4.3
5.7
6.3 2.0 4.9
6.6 " 1.6 5.8
6.0
5.0
5.31 176 5.
6/21 /93
- - 7.8
7.2
6/22/93
6/23/93
- 6/24/93
6/25/93
- 6/28/93
6/29/93
6/30/93
7/1/93
7/2/93
7.0
7.3
7.1
7.2
7.2
7.0
�- -
6.3
-- 6.6
7/5/93
7/6/93 6.3 4.9-
7/7/93 6.0 4.9 _
7/8/931 5.3 5.0 .. -1 0
7/9/93 4.6 4.5 0.0 4.8 3.2
7/12/93 7.7 _.4_3j .._ _..-_.;__ 2.3 6.1 4.6
7/13/93 4.2 3.2 2.0 - 5.2 3
7/14193 3.3
_..__ -. --
7/15/93 - 3.8 3.51 _
7/16/93 35 3.8 3.3 5.2 M4
7/19/93 481 _ 3.7
7{ - _ 4.0 5.0
7/20/93 5.G! 5.2 4.4 2.6 l
- -
7/21/93
3.9
3.0
7/22/93
5.0
_ 4.2
1, 5
7/23/93
7/26/93
7/27/93
-
5.9
5.0'
5.2
5.3
4.4
6.2
6.4
1.1
7/28/93
6.0
1.4
7/29/93
--
4.4
7/30/93
4.6
# of measurments 84 84 35
# < 5 mg/I F9 - - 22 --- 33
*VIOLATIONS OF THE D.O. STANDARD ARE SHADED AND SHOWN IN BOLD PRINT.

Si -Pd->-VO

North Carolina Division of Environmental Management
Water Quality Section / Intensive Survey Group
August 26, 1993
MEMORANDUM
To: Ruth Swanek
Through: Jay Sauber
From: Howard Bryant
Subject: Long-term BOD Analysis forCone Mills
W-A-:OR
0
5
35.8
10
52.2
15
67.4
20
76.6
25
85.4
30
90.3
35
95.2
40
99.9
50
115.2
60
128.4
70
135.1
80
139.3
90
142.0
100
144.1
110
145.5
120
146.6
160
150.5
Date Collected: January 14, 1993
1115-1120
0.30
0.27
0.34
0.60
0.65
MIX1161
0.05
cc: Central Files
Regional Water Quality Supervisor
County: Guilford
NPDES # NC0000876
Receiving Stream:
North Buffalo Creek
Sub -basin: 030602
TKN_N
NOX-N
TN-N
2.5
0.02
2.5
1.9
0.01
1.9
2.7
0.01
2.7
4.0
0.01
4.0
2.8
0.15
3.0
1.5
1.10
2.6
3.3 3.00 6.3
2.9 4.60 7.5
Collected by: Hagstrom Test evaluation: excellent
pH: 8.9 Seeded: seeded
k=.039
c3ot�k = t4!
W130z> �2n i

4110
All
Irv,
--,4
lv�#'
VO
"12 6 IM/ h Oj
417i'l
a vq1v
7/)7
1_41_0, j 0 ;341 "V7 /_M/ %�1WW
-,qY/
wey z
7 whl yl�_,4�
N V J'717iZIN
-31*1` J`P7

07/19/93 14:30 CONE MILLS GR,EENSBORO
DFOINNINOOUR RECOND Ci NTUKY OF ►X(:61.I.FMCK
Mr. Steve Mauney
NCl)EHNR
OEM
8025 North Point Boulevard
Suite 100
Winston Salem, NC 27106
RE: Permit No. NC0000876
Dear Mr. Mauney:
July 13, 1993
,•,
Post-V brand fax transmittal memo 7671 61pasaa ►
E
Fr.Pr !CJ�
xj
toa
Dept.
Phon N
Fax ki y?
tol
I am Writing to provide the issues that we would like to discuss
in our meeting scheduled for. July 20, 1993 at 10:30 am ill Raleigh.
Our permit for the White Oak Wastewater Treatment Facility in
Greensboro is being renewed and wc- have Some items that heed further
discussion.
The concentration of DOD should predominate especially at thca
liiyhur flows and the pounds should be the predominate factor at lower
flows. This is due to the higher flows actually helping the receiving
stream in orderassimilate and increase velocity and surface
aeration. ,
It is also proposed that the 7Q10 be change from 0.60 CFS to 3.7
CFS. This would be a(;ucampli.stied via a stream gauging steti,on and
ugmentation during very low flows. This change shQul.d significantly
improve conditions in this section of north atiffalo Creek.
Thank you for the opportunity to meet and discuss our concerns.
95 Sincerely,
✓'�+.�� � '���`' . � tea`'
AJT/am
cc;
Mr.
fir.
Mr.
M�
Larry Coble
Ed Barnhart
John Hodges
Mike Burleson
�jk(V
c/rthur J. Toompas
Corporate Environmental Mgr..
Cone Mills Corporation.,
Grcetlsl�oro, N.C. 27416-654Q _
SINCE 1891 7i1 �t t1�'h �.�,�� �;:•',t�a l�x�;

NPDES WASTE LOAD ALLOCATION
PERMIT NO.: NC0000876
PERMITTEE NAME: Cone Mills Corporation
FACILITY NAME: Cone Mills -Greensboro Facility
Facility Status: _Existing
Permit Status: Modification
Major -1 Minor
Pipe No.: 001
Design Capacity: -4-JO-vlOD- 1. 2
Domestic (% of Flow):
Industrial (% of Flow):
Comments:
9%
91%
requesting modification from 1.1 MGD to 1.25 MGD
RECEIVING STREAM: North Buffalo Creek
Class: C-NSW
Sub -Basin: 03-06-02
Reference USGS Quad: C 19 SE (please attach)
County. Guilford
Regional Office: Winston-Salem Regional Office
Previous Exp. Date: 6/30/93 Treatment Plant Class: 2
Classification changes within three miles:
Requested by: Charles Alvarez
Prepared by: G, 447A&
Reviewed by: !
W -i�ot>L —� 6 h t�QPu
Date: 1/28/93
Date: /7 3
Date: Las
1-2
L.
Modeler
Date Rec.
#
1
13ZS
Drainage Area (mi 2 ) � Avg. Streamflow (cfs): 1_5
7Q10 (cfs) 6 6 Winter 7Q10 (cfs) /. � 30Q2 (cfs)
Toxicity Limits: TWC % Acute Chronic
Instream Monitoring:
Parameters %era-f rX. i cal, �MAe' ✓' D.
Upstream fZ Location
Downstream/ n r,C Location
r, rn
Recommended Limits: Summer Winter
Mon. A,
Wasteflow (MGD):
1.25
BODS Obs/day):
100
BODS (mg/1):
10.0
NH3N (lbs/day):
18.3
NH3N (mg/1):
2.0
DO (mg/1):
6.0
TSS (lbs/day):
292
Fecal Col. 000 ml):
200.0
pH (SU):
6.0-9.0
Temperature (°C):
monitor
TP (mg/1):
2.0**
TN (mg/1):
monitor
Residual Chlorine (µg/1):
Pollutant Analysis:
monitor
Total Chromium (lbs/day):
Total Chromium (µg/1):
COD � � . OS
� Sulfidee
Phenols (lbs/day): 21
Daily Max]Mon. Avg Daily Max
1.25
200
200
400
20.0
20
40
36.6
36.6
73.2
4.0
4.0
8.0
6.0
6.0
6.0
500
292
500
400.0
200.0
400.0
6.0-9.0
monitor
2.0**
21
monitc
0.66
63.0
29610
P+
14805
ri
42
21
0.66
63.0
29610
. gar . _

RECEIVE[
N.C. Dept. of EHNF
APR 1 4 togl
FACT SHEET FOR WASTELOAD ALLOCATION
Winston-Salem
Request # 7325
Regional Office
Facility Name:
Cone Mills Corporation/Cone Mills - Greensboro Facility
NPDES No.:
NC0000876
Type of Waste:
Domestic - 9%/Industrial
- 91%
Facility Status:
Existing
Permit Status:
Modification
Receiving Stream:
North Buffalo Creek
Stream Classification:
C-NSW
Subbasin:
030602
County:
Guilford
Stream Characteristic:
estimated from
Regional Office:
Winston-Salem
USGS #
02.0951.8100
Requestor:
Alvarez
Date:
Period of Record
Date of Request:
1/28/93
Drainage Area (mi2):
14.7
Topo Quad:
C19SE
Summer 7Q10 (cfs):
0.46
Winter 7Q10 (cfs):
1.4
Average Flow (cfs):
13.2
IWC M:
79
Wasteload Allocation Summary
(approach taken, correspondence with region, EPA, etc.)
Facility is requesting modification from 1.1 to 1.25 MGD. A field study of North Buffalo Creek
is scheduled to be performed in the summer of 1993, but this would hold the permit for a long
time, so it was decided by Tech. Support (Clements, Scoville, and Goodrich) to give existing
concentrations and mass limits for oxygen -consuming wastes.
Toxicity testing should continue at a limit of 79%. It should be noted that Cone Mills has had a
difficult time maintaining compliance with their existing pass/fail limit of 74%. Other toxicants
which should be monitored upon renewal include: chloride, lead silve fluoride, cyani e,
arsenic, copper, nickel, and zinc. This is based on four years of data and the at the
small dilution of the receiving stream at 7Q10 conditions does not allow for high levels of any
pollutant in the effluent. Two limits for existing parameters will be changed. Chromium will be
slightly higher than the last permitted limit because an upstream concentration of 0 µg/1 was
assumed this time (as opposed to 12 µg/1 in 1987). Based on criteria for toxicants given to DEM
by EPA in 1993, sulfide should not be greater than 2 µg/1 in the receiving water. Therefore,
sulfide should be limited at 2.5 µg/l after allowing for dilution. TRC limit should be 21 µg/l.
Special Schedule Requirements and additional comments from Reviewers:
Recommended by:4I(� Date: 93
Reviewed by
Instream Assessment: &Z��Date: `� g
Regional Supervisor: X Date:
1�1�3 Permits & Engineering: Date: Z3
MAY 1
RETURN TO TECHNICAL SERVICES BY: 1 1993

2
Existing Limits:
Wasteflow (MGD):
BODS (lbs/day):
BODS (mg/1):
N113N (lbs/day):
N113N (mg/1):
DO (mg/1):
TSS (lbs/day):
Fecal Col. (/100 ml):
pH (SU):
Temperature (°C):
TP (mg/1):
TN (mg/1):
Residual Chlorine (µg/1):
Pollutant Analysis:
Chronic Toxicity:
Total Chromium (lbs/day):
Total Chromium (µg/l):
COD (lbs/day):
Sulfide (lbs/day):
Phenols (lbs/day):
PARAMETERS
Summer Winter
Mon. Avg Daily Max. Mon. Avg. Daily Max.
1.1
1.1
100
200
200
400
10.0
20.0
20
40
18.3
36.6
36.6
73.2
2.0
4.0
4.0
8.0
6.0
6.0
6.0
6.0
292
500
292
500
200.0
400.0
200.0
400.0
6.0-9.0
6.0-9.0
monitor
monitor
2.0**
2.0**
monitor
monitor
monitor
monitor
P/F @74%
P/F @74%
0.56
0.56
61.0
61.0
14805
29610
14805
29610
42
84
42
84
21
42
21
42
*NOTE LIMITS FOR BOD5,NH3, & CHROMIUM ARE GIVEN AS BOTH MASS LIMITS AND
CONCENTRATIONS.
**Quarterly average of weekly samples.
RECOMMENDED LIMITS ARE ON THE FOLLOWING PAGE.

Recommended Limits:
Mon. Av
Wasteflow (MGD):
1.25
BODS (lbs/day):
100
BODS (mg/1):
10.0
NH3N (lbs/day):
18.3
NH3N (mg/1):
2.0
DO (mg/1):
6.0
TSS (lbs/day):
292
Fecal Col. (/100 ml):
200.0
pH (SU):
6.0-9.0
Temperature (°C):
monitor
TP (mg/1):
2.0**
TN (mg/1):
monitor
Residual Chlorine (µg/l):
Pollutant Analysis:
monitor
Total Chromium (lbs/day):
Total Chromium (µg/1):
COD (lbs/day): 14805
Sulfide
Phenols (lbs/day):
21
PARAMETERS
200
20.0
36.6
4.0
6.0
500
400.0
21
Winter
Mon. Avg
Oaily Max
WQ/EL
1.25
1
200
1400
WQ
20
40
IWQ
36.6
73.2
WQ
4.0
8.0
EL
6.0
6.0
WQ
292
I500
I WQ
200.0
400.0
6.0-9.0
WQ
monitor
2.0**
WQ
monitor
21
WQ
mnnitnr
0.66
0.66 WQ
29610
14805
29610I.
42
21
42
*NOTE LIMITS FOR BOD5,NH3, & CHROMIUM ARE GIVEN AS BOTH MASS LIMITS AND
CONCENTRATIONS.
**Quarterly average of weekly samples.
Limits Changes Due To: Parameter(s) Affected
Change in 7Q10 data
Change in wasteflow x tox. test, TRC
Other (onsite toxicity study, interaction, etc.)
New regulations/standards/procedures x sulfide
New facility information (effluent data) RpAM x various toxicants
x Parameter(s) are water quality limited. For some parameters, the available load capacity of
the immediate receiving water will be consumed. This may affect future water quality based
effluent limitations for additional dischargers within this portion of the watershed.

4
INSTREAM MONITORING REQUIREMENTS
Upstream Location: North Buffalo Creek 25 yards upstream of the outfall
Downstream Location: North Buffalo Creek at Summit Ave. bridge
Parameters: Temperature, Fecal, Conductivity, Dissolved Oxygen
Special instream monitoring locations or monitoring frequencies:
MISCELLANEOUS INFORMATION & SPECIAL CONDITIONS
Adequacy of Existing Treatment
Has the facility demonstrated tl ability to meet the proposed new limits with existing treatment
facilities? Yes No V
If no, which parameters cannot be met?-7 9 ^L'
Would a "phasing in" of the new limits be appropriate? Yes V No
If yes, please provide a schedule (and basis for that schedule) with the regional
office recommendations:
a , . cis w►G 0 Ck;�1
If no by not?
d Qom- a CAce�
13DD OAS -N
Special Instructions or Conditions
m.�s -"�Q"Pz-) why
Wasteload sent to EPA? (Major) (Y or N)
(If yes, then attach schematic, toxics spreadsheet, copy of model, or, if not modeled, then old
assumptions that were made, and description of how it fits into basinwide plan)
Additional Information attached? (Y or N) If yes, explain with attachments.
/Dx. �s� �1 rr! � �G�' .-�ofe.Sj CQ/�u/4�otiJ� �iXi�c•�/'�'•'fs� �s��a/Gl►h-i•w

Facility Name t�N�/ "!/!. &�&- (�
%' ' Permit #�� Pipe # 'F
CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QRTRLY)
The effluent discharge shall at no time exhibit chronic toxicity using test procedures outlined in:
1.) The North Carolina Ceriodaphnia chronic effluent bioassay procedure (North Carolina Chronic Bioassay
Procedure - Revised *September 1989) or subsequent versions.
The effluent concentration at which there may be no observable inhibition of reproduction or significant mortality
is '7% (defined as treatment two in the North Carolina procedure document). The permit holder shall perform
quarterquarteru monitoring using this procedure to establish compliance with the permit condition. The first test will be
performed after thirty days from the effective date of this permit during the months of
/ tw' , %u `=* L�e C Effluent sampling for this testing shall be performed at the NPDES
perniitted final effluent discharge below all treatment processes.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form (MR-1) for the month in which it was performed, using the parameter code TGP3B.
Additionally, DEM Form AT-1 (original) is to be sent to the following address:
Attention: Environmental Sciences Branch
North Carolina Division of
Environmental Management
4401 Reedy Creek Road
Raleigh, N.C. 27607
Test data shall be complete and accurate and include all supporting chemical/physical measurements performed in
association with the toxicity tests, as well as all dose/response data. Total residual chlorine of the effluent toxicity
sample must be measured and reported if chlorine is employed for disinfection of the waste stream.
Should any single quarterly monitoring indicate a failure to meet specified limits, then monthly monitoring will
begin immediately until such time that a single test is passed. Upon passing, this monthly test requirement will
revert to quarterly in the months specified above.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of
Environmental Management 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 and appropriate environmental controls, shall constitute an invalid test and will require immediate
retesting(within 30 days of initial monitoring event). Failure to submit suitable test results will constitute
noncompliance with monitoring requirements.
7010 D. f4 cfs
Permitted Flow -'"� MGD Recommended by: ,
Basin & Sub -basin — CMG �' 1�wzja 1 'f
Receiving Stream or>`h 7?:� k
County / Dam 9
QCL P/F Version 9191

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DMSION OF ENVIRONMENTAL MANAGEMENT
Water Quality Section/Rapid Assessment Group
May 14, 1993
MEMORANDUM
TO: WLA FILES
FROM: Dave Goodrich
SUBJECT: Cone Mills - Greensboro Facility 1993 Permit Renewal
ff • 1O1111: 0
Guilford County
Although the fact sheet was finalized in April, questions regarding the application of
the federal criteria for sulfide were unanswered. To my knowledge, a limit based on the
federal criteria of 2 µg/1 had never been given to a facility. Furthermore, there was an
unusually large discrepancy between the effluent guidelines for sulfide and the federal
criteria. After several discussions with various members of the EPA, including Ron Jordan
and Steve Geil (EPA in Washington D.C.) as well as staff at the Region IV headquarters in
Atlanta (Darryl Williams and Lydia Dow), it became clear that hydrogen sulfide is the toxic
form of sulfide which was meant to be limited in the federal criteria document. After
further discussions within DEM and with the EPA, it was decided that hydrogen sulfide
production in a wastewater treatment plant effluent should be minimal if existant at all, so
the appropriate limit would be one based on the effluent guidelines not the federal criteria.
Darryl Williams of the EPA also sent information which indicated that the EPA would not
require the states to use the sulfide limit calculated using the federal criteria unless WET
testing was not being done at the facility.
Before finalizing the WLA, I also noted that I inadvertently left out several
parameters from the limits pages although they were referenced under the summary on page
1. Those parameters were: chloride, lead, silver, fluoride, cyanide, arsenic, copper,
nickel, and zinc. There has been some questions of late as to whether or not to require
monitoring or limits based on APAM results. After discussing this with Ruth Swanek, it
was decided that quarterly monitoring of the above -mentioned toxicants was not
unreasonable, especially since WET tests are only being passed about half the time. Silver
and cyanide were only documented in one of the four APAM's reviewed, so they will be
dropped from the monitoring requirements.
I contacted Art Hagstrom of the Winston-Salem Regional Office on 5/13/93 to tell
him of the changes I outlined above. He was in agreement with the change in the limit for
sulfide and recognized I had omitted some monitoring for toxicants on the limits pages of
the fact sheet.

L.
/ f' r' x���-/
�G -- LA
Z- -Q1
7Y?
YV -:3*?)

CONE MILLS - Allowable Waste Concentrations for Toxicants
7Q10=
0.5
Qa=
13.2
Ow in cfs =
1.9375
PARAMETER
FEDERAL/STATE STANDARD
ALLOWABLE EFF. CONC.
ACTUAL EFF. CONC.
ACTION
(Ag/1)/I
/I
Chloride*
230000
289354.84
69700
monitor
Di-n-butyl phthalate
12000
93754.84
131
none
Chromium
50
62.90)
-& "'. .,-
Lead
25
31.45
37.9
monitor
Silver*
0.06
0.08
5
monitor
Bromodichloromethane
22
171.88
2
none
Bromoform
360
2812.65
3
none
Chloroform
470
3672.06
2
none
Dibromochloromethane
34
265.64
3
none
Antimony
4300
33595.48
19
none
Bis 2-eth Ihex I hthalate
5.9
46.10
24.6
4TH)n#er- Jim
Fluoride
1800
2264.52
240
monitor
Cyanide
5
6.29
20
monitor
Arsenic
50
62.90
180
monitor
Copper*
7
8.81
51
monitor
Nickel
88
110.71
44.1
monitor
Zinc"
1 50
62.90
70
monitor
"Standards" are actually action levels.
%�ilra fro,tf T Af',�U s ��9� 9a) .
4/6/93
pC.1M I
P-g-'Er, nnl
M;Z p4*4 .
ewLyFrvd!> AvCJE,

CONE MILLS - Allowable Waste Concentrations
-SUMMER
Residual Chlorine
................Ammonia as NH3
7010 (CFS)
0.46*7QI0 (CFS)
0.461
DESIGN FLOW (MGD)
1.25DESIGN FLOW (MGD)
1.25
DESIGN FLOW (CFS)
1.9375 DESIGN FLOW (CFS)
1.9375
STREAM STD (UG/L)
17.0 STREAM STD (MG/L)
1.0
UPS BACKGROUND LEVEL (UG/L)
0UPS BACKGROUND LEVEL (MG/L)
0.22
IWC
80.813347 IWC
80.81335
Allowable Concentration (ug/11)
21.036129.............,., Allowable Concentration (Mg/1)
1.185187
..:;WINTER
as NH3
7Q10 (CFS) 1.4
DESIGN FLOW (MGD) 1.25
DESIGN FLOW (CFS) 1.9375
STREAM STD (MG/L) 1.8
UPS BACKGROUND LEVEL (MG/L) 0.22
IWC (%) 1 58.05243
Allowable Concentration (mg/1) 1 2.941677
VX/r,/7r/ SO MC -At,
NC0000876 DAG 4/6/93

PERMITNO.: NC0000876
FACILITY NAME: Cone W115 cocp r,7,on
Facility Status: Ex;S+ina
Permit Status:
Major X
Pipe No.: 00 1
Design Capacity:
Domestic (% of Flow):
Industrial (% of Flow):
Minor
ME
(00
Comments: per,nn;'i Shoo (d
i�xt.se I+m Js bast
NPDES WASTE LOAD ALLOCATION ,(,�N[sr 4�086 oQ, 5. 6,... E 6�31a•T
on vU.W intelMti���^-
RECEIVING STREAM: NOf+h BJo(o C,reA
Class: G - Ow
Sub -Basin: - 03060Z
Reference USGS Quad: C195E (please attach)
County: Gui Ford
Regional Office: Wt As+on - Sale rn
Requested by: Date:
Prepared by: y� Sco Date: q (0 40
Reviewed by: C. Y? .Auk Date: &0190
/o q
be -co u., 114 Q,rsrov w. rtc�,�.s-b �1.�.�5. we . 0,
u l� r+eo�... St. �a,,,..,1� �.r w a� Use, Ga,.�,�� errors �„�, d...s-�r•�.b�; •....
b logc��.ti5 s�si+.� lob
Modeler I Date Rec. I #
nW r,> S -
2 a7"Sv
Drainage Area (mi ) Iy .70 Avg. Streamflow (cfs): 16.6
7Q10 (cfs) 0.6 Winter 7Q10 (cfs) 1,70 30Q2 (cfs) 2.qo
Toxicity Limits: IWC 711 % Acute hroni
Ghro�it, �Cer�odaPyn�a
Instream Monitoring: Qr{r(y
Parameters_Te^et(aAu.� , DO co JucEV:: y , I call (m
Upstream Y Location 25 vacds o.bove ou4sll
Downstream Y Location 1) Swnmi'+ Ave.Aat
S� 5-M#V4( , LT-i10b (W ��• � 2) Is' roa.9 CrOSsinq
Effluent
Characteristics
Summer
Winter
gO Ds
to "'9
Io0
"
20 ^y 1 a� 200
Do
TSS
15 d
2 9Z
HonW
AU .
S00 wly
Niax.
Fecal Col��of1A "In,
200
zoo
su
G-q
6-q
T'
(milt
Z
2
cop
l6 do.
14.805
Hc.,A
.
29610 DA;(
Max.
5 ,&
Ibr
4
Mon+�(
AV .
Sq 4; (
Mix
heal
161
ZI
don (
did .
4 Z Da,(
To+al
roM;aM
61 "9/1
And
o.56
"/. Ual
Comments:
Ckaoxgs r r %are 4.11
aDD�
op SfWC MA.A^A-Y / WS 1Z0 .
J�nas.:a, 7�oy e
rm Rr r

RECETVED
N.C. Dept. NRCD ,
APR 4 t99D
Winston-Salem
Regional Office
------------------- WASTELO ALLOCATION
6-66 7
Request No.:
APPROVAL FORM -------------------
Facility Name: Cone Mills Corporation
NPDES No.: NC0000876
Type of Waste: Industrial
Status: Existing/Renewal k
Receiving Stream: North Buffalo Creek
Classification: C-NSWP; i., f 1990
Subbasin: 030602 Drainage area: 14.�700 sq mi
County: Guilford Summer 7Q10:,, 0.60. Cfs
Regional Office: Winston-Salem Winter 7Q10! 1.70 cfs
Requestor: Average ;flow: 16 cfs
Date of Request: �30Q2: 2.40 cfs
Quad: C19SE
-------------------- RECOMMENDED EFFLUENT LIMITS -------------------------
Summer Winter
Wasteflow (mgd) : 1.1 1.1
BOD5 (mg/1): 10 mg/l and 100 #/day 20 mg/1 and 200 lb/day
NH3N (mg/1): 2 mg/l and 18.3 #/day 4 mg/1 and 36.6 lb/day
DO (mg/1) : 6 6 G� at -
pH (su) : 6-9 6-9 rw F°
TSS (lb/day) : 292 Mo. Avg., 500 Daily Max. ?�4� 16 �"A
COD (lb/day): 14805 Mo. Avg., 29610 Daily Max. M;�kZ
Sulfide (lb/day): 42 Mo. Avg., 84 Daily Max. ��'%y
qo
Phenol (lb/day): 21 Mo. Avg., 42 Daily Max.
Total Chromium: 61 ug/l and 0.56 #/day, Daily Max. 7 Jj M-jj`
r
Toxicity Testing Req.: Chronic/Ceriodaphnia/Qrtrly
--- - PL
--------- MONITORING ------------------------------
Upstream (Y/N): Y Location: 25 yards above outfall
Downstream (Y/N): Y Location: 1) Summit Avenue
2) first road crossing on 16th Street
----------------------------- COMMENTS -----------------------------------
Previous WLA for Cone Mills was completed in June 1988, but the company
did not accept the permit. Since then the company has modified their
treatment facility and performed water quality studies. Permit should
be opened and modified to include the above limits, which represent a
compromise based on the water quality data submitted (see attached memo).
BOD5 and winter DO are the only limits changed. Bo➢s : 6 ­�( (s�M �) `4 12 Ny(j
An updated toxicity form is attached. w1i\4cr W = 5 ,,jlt
-------------------- ------------------------/------------------------------
Recommended by: SCD M Date: 3 27 0
Reviewed by ,,
Instream Assessment: �(4& C. S�jir' 4 Date: .2 )
Regional Supervisor: I). G,-t.� Date: I- .S— S n
"fl Permits & Engineering: LL'L�Date: 40
RETURN TO TECHNICAL SUPPORT BY: MAY 02 1990

10/89
Facility Name C.or)G (v�� (5 (-or Dora.�i0Permit # dG0000676
CHRONIC TOXICITY TESTING REQUIREMENT (QR'FRLY)
The effluent discharge shall at no time exhibit chronic toxicity in any two consecutive toxicity tests,
using test procedures outlined in:
1.) The North Carolina Ceriodaphnia chronic effluent bioassay procedure (North Carolina Chronic
Bioassay Procedure - Revised *September 1989) or subsequent versions.
The effluent concentration at which there may be no observable inhibition of reproduction or
significant mortality is N % (defined as treatment two in the North Carolina procedure
document). The permit holder shall perform quarterly monitoring using this procedure to establish
compliance with the permit condition. The first test will be performed after thirty days from
issuance of this permit during the months of Mar ', Jura Se, , Dec . Effluent
sampling for this testing shall be performed at the NPDES pe itted final effluent discharge below
all treatment processes.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (NIR-1) for the month in which it was performed, using the parameter
code TGP3B. Additionally, DEM Form AT-1 (original) is to be sent to the following address:
Attention: Environmental Sciences Branch
North Carolina Division of
Environmental Management
P.O. Box 27687
Raleigh, N.C. 27611
Test data shall be complete and accurate and include all supporting chemical/physical measurements
performed in association with the toxicity tests, as well as all dose/response data. Total residual
chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for
disinfection of the waste stream.
Should any single quarterly monitoring indicate a failure to meet specified limits, then monthly
monitoring will begin immediately until such time that a single test is passed. Upon passing, this
monthly test requirement will revert to quarterly in the months specified above.
Should any test data from this monitoring requirement or tests performed by the North Carolina
Division of Environmental Management 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 and appropriate environmental controls, shall constitute an invalid test
and will require immediate retesting(within 30 days of initial monitoring event). Failure to submit
suitable test results will constitute noncompliance with monitoring requirements.
7Q10 0.6 cfs
Permited Flow 1. I MGD
IWC% 79
Basin & Sub -basin olo6oZ
;Receiving Stream NorA Ru-F Io (.mek
County (u; i;t)f d
Recommended by:
"�' i. o...JU. -
Date:4-27(10
"Chronic Toxicity (Ceriodaphnia) P/F at _L�_%o, 10.r.) JAn Sep Dec, See Part 3 , Condition G .

EXTENDED MONITORING CONDITIONS FOR LONG TERM BOD
Cone Mills Corporation shall collect a long-term BOD at the effluent
and at all three designated instream sampling sites one time per year
in July,August,or September. Samples should be taken at a time when
the receiving stream is at baseflow conditions.
The laboratory selected to run the long-term tests shall be made aware
by Cone Mills of the following guidelines:
1. No Nitrogen inhibitors shall be used.
2. In addition to ultimate BOD, intermediate nitrogen series
measurements should be made upon set-up and on days 5, 15, 30,
and on the last day of the test.
3. Long-term'BOD tests should be run for at least 60 days
for instream samples and 90 days for effluent samples.

DIVISION OF ENVIRONMENTAL MANAGEMENT
April 2, 1990
MEMORANDUM
TO: Dennis Ramsey
THRU: Ruth Swanek '20
Trevor Clements9L
FROM: Mike Scoville Q5
SUBJECT: Cone Mills Corporation NPDES Permit Reopener
NPDES No. NC0000876, Guilford County
An NPDES permit was issued for Cone Mills Corporation in 1988, but was
not accepted by the company at that time. The revised BODS limits contained
in that permit were more stringent than Cone Mills felt was necessary to
adequately protect the water quality of the receiving water, North Buffalo
Creek.
Since the previous wasteload allocation was performed, new data have
been continually gathered. Improvements of the wastewater treatment
processes have also been implemented. The facility constructed a flow,
equalization basin, added a polymer chemical feed system, and added a pure
oxygen feed system to the outlet of their polishing pond. In the past,
water quality problems caused by the Cone Mills discharge were largely due
to upsets in the treatment system. The Cone Mills effluent is of signifi-
cantly higher quality now than it was at that time, and current treatment
efficiency exceeds that of many textile manufacturing facilities. Also, the
renovated treatment works appear to have reduced the probability of plant
upset, yet when they do occur, the ability to capture the upset within the
polishing pond should reduce the impact on the receiving stream.
North Buffalo Creek is a small urban stream with flow largely comprised
of urban runoff. The quality of urban streams is usually poorer than the
quality of similar rural streams. Urban streams are more prone to litter
and debris build-up, especially near bridges and othevconstructions, which
tend to constrict the channel. Since the time of the last analysis, North
Buffalo Creek has been cleared of debris and kept clear (according to Cone
Mills), leaving the channel unobstructed and increasing the flow -through
velocity of the system. Instream data collected before these changes (and
used in the previous analysis) are probably not representative of current
instream conditions, especially considering the improved wastewater treat-
ment by the facility.
Two intensive water quality surveys were performed in September, 1989,
by Hydroscience, Inc., a consulting firm contracted by Cone Mills. Based on
the recently submitted final report of this study (which also discusses
several 1977 studies), Technical Support recommends that the Cone Mills

NPDES permit be reopened and amended to reflect the attached effluent lim-
its. In light of the newest data, it is felt that the water quality of
North Buffalo Creek will be adequately protected in accordance with State
regulations if Cone Mills consistently discharges at or below these limits.
The only effluent limit changes being recommended are the BODS summer
(winter) limit from 6 (12) mg/l to 10 (20) mg/1 and the DO winter DO limit
from 5 mg/l to 6 mg/l. The BODS limits are monthly averages, while the DO
limit is a daily minimum. The other effluent limits contained in the permit
should remain unchanged, although a new toxicity testing requirement is
attached to provide the most recent language for that requirement to be
included in the revised permit. Ammonia toxicity will be addressed by the
toxicity test. The company is currently within it's 2.0 mg/l summertime
NH3-N limit and frequently discharges less than 1 mg/l. Therefore, a reduc-
tion of the ammonia limits is not warranted at this time.
If you have any questions or comments regarding this matter, or wish to
review the North Buffalo Creek water quality report, please contact me.
cc: Central Files
Dale Overcash

CONE MILLS CORPORATION
GREENSBORO, N. C.
January 3, 1990
Mr. Chuck Wakild, Acting Director
Division of Environmental Management
Environment, Health and Natural Resources
512 North Salisbury Street
Raleigh, NC 27611
Re: Special Order by Consent
EMC WQ No. 88-33
NPDES NC0000876
Dear Mr. Wakild:
27405
/';a�mj
YNI 6 WM
DIV. OF ENWRONMENTAL MANAGEMENT
Raleigh, NC
The year of 1989 has been very active for the above -listed
waste treatment plant. We have undertaken a number of programs to
develop upgrading alternatives. This report will summarize the
progress that we have made and status of our situation.
1. Negotiations with the City of Greensboro - Testa
were made pumping to the City. In meetings we were
told that their plant was close to its limits, both
hydraulically and organically. We do not view this
as a proper alternative at this time.
2. Stream Quality Improvement - We have investigated
flow augmentation and piping effluent downstream
without proper improvement to the stream as review-
ed by our consultant. We have installed a system
to allow oxygenation of the effluent. This system,
in addition to our existing effluent reaeration, has
been very successful.
Studies of decolorization of effluent have been made.
A part of this program was done at the plant with
considerable work done in upgrading the polymer systems.
3. Stream Study - Our consultant, Hydroscience, has also
completed the investigation of the water quality criteria
in the stream. We are now approaching a position where-
by a meeting with your staff to review all of the data
and discuss this final permit is imminent.
Coneiw

Mr. Chuck Wakild
January 3, 1990
Page -2-
We feel that the programs have been successful and look forward
to finally completing this permit process.
Sincerely,
Arthur J. Toompas
Manager, Water & Air Resources
AJT/n
cc: Mr. Larry Coble
Mr. Mather Whitehead
Mrs. Gayle Younger
Mr. Ed Barnhart

CONE MILLS CORPORATION
GREENSBORO, N.C. 27405
September 29, 1989
Mr. Paul Wilms
Environmental Management
Environment, Health & Natural Resources
512 North Salisbury Street
Raleigh, N.C. 27611
Re: Special Order by Consent
EMC WQ No. 88-33
NPDES NC0000876
Dear Mr. Wilms:
This r`e� is submitted as required by the above -listed Consent
Order for the October 1, 1989 report. During the week of September 19-22,
1989 Hydroscience performed the study of North Buffalo Creek. The study
included samples over the creek from above our discharge down to the City
of Greensboro's North Buffalo Treatment Facility. Samples were also taken
of the tributaries to the creek. When the analysis is completed and the
model has been run, we would like to meet with your staff to discuss the
results of this study.
This has been a very wet year and we have had significant rain
nearly every week causing a great deal of difficulty in trying to schedule
a creek survey. Luckily we got the survey done just before the arrival
of Hugo.
Polymer trials are being conducted by a variety of suppliers to
provide the best products for control of this plant. We have found some
products that appear to provide better clarity. The most effective
polymers are a combination of two catonic products.
AJT/n
cc: Mr. Larry Coble
Mr. T.A. Alspaugh
Mr. Mather Whitehead
Mrs. Gayle Younger
Mr. Ed Barnhart
Sincerely,
OAI�ilzs�_.
Arthur J. Toompas
10 196
Coneaw

State of North Carolina
Department of Natural Resources and Community Development
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor R. Paul Wilms
William W. Cobey, Jr., Secretary August 25, 1989 Director
Edwin Barnhart, President
Hydroscience, Inc.
Route 4, Box 659-B
Harbor Island, SC 29920
Subject: North Buffalo Creek Study Plan
Cone Mills Corp., NPDES No. NC0000876, Guilford County
Dear Mr. Barnhart,
I have reviewed the North Buffalo Creek study plan submitted to the
Division of Environmental Management (DEM) by Hydroscience. As you are
aware, Cone Mills Corporation entered into a Special Order of Consent
agreement (SOC) to provide them time explore alternative arrangements for
discharge of its effluent (see Part 1, c). During this time, the SOC
requires the company to "complete all studies and negotiations necessary
for compliance with final permit limits on or before the expiration" of
this Order, which is on January 31, 1990. DEM believes that final effluent
limits contained in the NPDES permit are technically sound, and the burden
is on Cone Mills to prove otherwise. I infer that this is the purpose of
the proposed water quality study. In that light, my concerns and comments
regarding the submitted study plan are listed below:
1) The instream water quality impact of the Cone Mills discharge does
not end at the Greensboro outfall. The resiliency of the Cone Mills BOD
allows for its transport downstream and interaction with the Greensboro
discharge. Therefore, it would be more insightful to continue the instream
study past the Greensboro North Buffalo Creek discharge.
2) I am concerned about the validity of the data obtained when the
Cone Mills discharge is eliminated. In this scenario, care must be taken
to ensure that all effluent previously discharged is completely flushed
from the study area. Even in that case, the residual BOD in the settled
solids associated with the Cone Mills discharge will continue to act as a
source of DO depletion (as sediment oxygen demand). With less flow and a
slower velocity the DO concentration could sag further and/or more rapidly,
making it appear as though the discharge actually improves the water
quality in North Buffalo Creek. More accurately, the stream has reached an
equilibrium which includes the Cone Mills effluent loadings. The results
of this study will gladly be examined by DEM, but any final decisions will
be made based primarily on the results of a modeling analysis and not on
the stream data itself. Pollution Prevention Pays
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

3) It is important that an accurate flow balance for the study area be
obtained at the times of study. Tributary flows and/or main stem baseflow
increases should be measured in relation to the headwater flow.
4) I recommend replicate runs be performed of the long-term BOD and
field parameters, especially when surveying the stream under normal exist-
ing discharge conditions. The replicates could be performed on two sepa-
rate days or on the same day 4-6 hours apart.
5) We expect sediment oxygen demand (SOD) to play a major role in the
dissolved oxygen dynamics of North Buffalo Creek. -Your study plan does not
address SOD.
6) Color is quickly becoming an important issue in water quality. In
the future, Cone Mills may be required to comply with some sort of color
limit due to documented problems of color in North Buffalo Creek. You may
want to consider measuring the color at each of your.sampling stations
to provide data that could be useful to the company if color limits were to
be implemented.
In closing, I would like to request of you a copy of any Hydroscience
reports of your previous involvement in water quality studies of North
Buffalo Creek. I would also like to thank you for informing DEM as to your
plans and intentions and I look forward to seeing the results of this new
study. Please feel free to contact me if you have any questions or com-
ments regarding any of the above.
Sincerelv,
J'T evor Clements, ssistant Chief
In charge of the Technical Support Branch
cc: Cone Mills WLA file
Steve Mauney
Arthur Toompas, Cone Mills Corporation
Central Files

HYDROSCIENCE, INC.
Environmental Engineering and Planning
August 9, 1989
Mr. Trevor Clements
North Carolina Department of Environmental Management
P.O.Box 27687
Raleigh, North Carolina 27611-7687
Re: Cone Mills Corporation
Greensboro, North Carolina
Dear Mr. Clements:
Edwin L. Barnhart, P.E.
Peter Duritzo, P.E.
Robert G. Gross, P.E.
I need to discuss with you our intentions to conduct a water
quality survey in the North Buffalo Creek area adjacent to the
discharge from the Cone Mill White Oak Finishing Plant Treatment
System. The flows in the creek may be sufficiently low to conduct
these meaningful investigations in the late August early September
period. We are making arrangements to have a flow gauge installed
in the creek and hopefully it will be in place prior to the conduct
of these investigations.
Hydroscience has previously conducted a detailed study of the North
Buffalo Creek Area. I believe your group has a copy of these
investigations. In order to avoid confusion we will be using the
same stations and identifications as were presented in that report.
A copy of a map showing the station names and locations is attached
to this letter for your convenience.
The flow gauge will be located just above the study area and should
provide an accurate input flow for the test. The utilities at the
wastewater treatment plant are such that ae can regulate the
discharge of wastewater to the stream. We will therefore be able
to test the stream with and without the wastewater present. We
intend to look at three conditions, these are no discharge from
Cone Mills, a discharge from Cone Mills approaching the present
permit, and a value approaching the permit values suggested by the
State. The exact loadings will not be known until after the
studies are performed, but we should be able to come close to these
three conditions. Operating the system in this way will give us
the best chance of getting a real insight into the stream behavior.
Sampling will be conducted at each of the indicated stations. All
stations will be sampled for BODS, Dissolved Oxygen, Temperature,
pH, Specific Conductance, Ammonia, and Nitrates. Stations N1, N3,
Route 4 Box 659-B Harbor Island • South Carolina 29920 • [phone]

N5A, and N6 will be sampled and longterm BOD's conducted. This
should give us a good indication of the rate of change of ultimate
BOD through the study area.
We would hope to be able to conduct the studies over approximately
a two week period. Assuming that the flows in late August early
September get down low enough to make this possible. As you are
aware this is a very small drainage basin and the flows are highly
erratic when rainfall occurs. It will therefore be necessary to
have a reasonable dry period to get the work done accurately. We
will notify you in advance of the dates on which we intend to
conduct surveys, so that representatives of your organization can
join us if they so choose.
I would appreciate if you would review our program and offer any
comments that you feel are appropriate. We would also welcome your
thoughts regarding the approach to a aly�is. We will keep you
informed of our progress and be "happy to share -the data and our
methods of analysis with you at your convenience. We look forward
to the opportunity of working with you.
Sincerely yours,
Edwin L. Barnhart
President
CC: Arthur Toompas, Cone Mill
ELB/taf

L EC
NO
r
FIGURE 1
SCHEMATIC OF THE NORTH BUFFALO CREEK
STUDY AREA
6)
0.0 )
-T

DIVISION OF ENVIRONMENTAL MANAGEMENT
August 24, 1989
MEMORANDUM
12�vo2 E �1- hPtoc cI S 05S'1 _
TO: Trevor Clements �
-}rykn ��cc55
THRU: Jay SauberJ�� �s5�5-� 00
165oc hould
�vprluo,`tcZJL
FROM: David Vogt }'( rr►c R eOP10A-11°°�
Goic�2 Mf1 A4x-'� 5
0-4� CUo n> G pCo t o2 I
SUBJECT: North Buffalo Creek Study Plan Submitted by 5haela aVa_C
Hydoscience Cohn^ , -to pu 2
2-
RN� ctPts� . �vcry .rc
reo��vJ k u5�
I have reviewed Ed Barnhart's letter of 8-9-89 wherein he
described the proposed intensive surveys to be done this year on cJer�i£,7.
North Buffalo Creek for the purpose of assessing the impact of Cone 6oere��r�e
Mill's discharge. I have the following comments regarding these
studies: Co��� 1e use
-6o r°mPly o2
1) Since North Carolina has been experiencing an unusually wet n.eom
summer this year, the normal buildup of oxygen -consuming 6u? ?reJio� 5
sediment in North Buffalo Creek has probably been greatly Q4cc,
diminished. This buildup has been previously documented by DEM, q S
most notably in the modeling analysis done by Randy Williams. 0.5uftUe,\ -
Thus a study done this year may not predict the true impact of SOD J
on the system. I
2) Also regarding this being a wet flow year, one or all of the
three tributaries on Figure 1 of Ed's letter may need to be sampled.
3) Something I think we need to consider is does Cone Mill's
waste significantly interact with the City of Greensboro's discharge?
The modeling analysis that I performed in 1988 predicted the sag
from Cone Mill's waste to be 0.2 miles upstream of the Greensboro
WWTP. However, the residual CBOD and NBOD interacting with
Greensboro may be significant. If so, then it might be appropriate
for the survey to be extended beyond Greensboro (say out to the
USGS gage at Randkin Mill Road).

4) It seems to me that this is a good time to get some color work
done. As you know, the residents in this area of Greensboro have
been quite vocal about the color problem in North Buffalo Creek. In
fact, during the joint meeting (Cone Mills - City of Greensboro - DEM)
that I attended to discuss the possibility of Cone being an indirect to
Greensboro's North Buffalo Plant, representatives of the City were
very concerned about inheriting color from Cone's textile operations.
Hence, even if DEM does not intend to regulate color levels in the
near future, color samples from the surveys could give us an idea of
the magnitude of the problem.
5) Is Hydroscience going to do time -of -travel and flow work
during the study? It is my opinion that besides installing an
upstream gage, velocities should be ascertained and flow balances
done for each of the surveys.
Please feel free to contact me if I can be of further assistence in
this matter.

MEMO.
DATE: v I v
TO: (U�t\lp SUBJECT:
Pkf� 0-n
t cAk
J
5Z) -(-Ja- call,
uc.,*-9 U--O� 6L4S�-
-Sec JC I� � / G C
North Carolina Department of Natural
Resources &Community Development

HYDROSCIENCE, INC.,
Environmental Engineering and Planning $�._,
AUG1a4
August 9, 1989 Eiil'VlR© pFIVTAL li+ [
Mr. Trevor Clements
North Carolina Department of Environmental Management
P.O.Box 27687
Raleigh, North Carolina 27611-7687
Re: Cone Mills Corporation
Greensboro, North Carolina
Dear Mr. Clements:
Edwin L. Barnhart, P.E.
Peter Duritzo, P.E.
Robert G. Gross, P.E.
I need to discuss with you our intentions to conduct a water
quality survey in the North Buffalo Creek area adjacent to the
discharge from the Cone Mill White Oak Finishing Plant Treatment
System. The flows in the creek may be sufficiently low to conduct
these meaningful investigations in the late August early September
period. We are making arrangements to have a flow gauge installed
in the creek and hopefully it will be in place prior to the conduct
of these investigations.
Hydroscience has previously conducted a detailed study of the North
Buffalo Creek Area. I believe your group has a copy of these
investigations. In order to avoid confusion we will be using the
same stations and identifications as were presented in that report.
A copy of a map showing the station names and locations is attached
to this letter for your convenience.
The flow gauge will be located just above the study area and should
provide an accurate input flow for the test. The utilities at the
wastewater treatment plant are such that we can regulate the
discharge of wastewater to the stream. We will therefore be able
to test the stream with and without the wastewater present. We
intend to look at three conditions, these are no discharge from
Cone Mills, a discharge from Cone Mills approaching the present
permit, and a value approaching the permit values suggested by the
State. The exact loadings will not be known until after the
studies are performed, but we should be able to come close to these
three conditions. Operating the system in this way will give us
the best chance of getting a real insight into the stream behavior.
Sampling will be conducted at each of the indicated stations. All
stations will be sampled for BOD5, Dissolved Oxygen, Temperature,
pH, Specific Conductance, Ammonia, and Nitrates. Stations N1, N3,
Route 4 9 Box 659-B • Harbor Island • South Carolina 29920 • [phone]

N5A, and N6 will be sampled and
should give us a good indication
BOD through the study area.
longterm BOD's conducted. This
of the rate of change of ultimate
We would hope to be able to conduct the studies over approximately
a two week period. Assuming that the flows in late August early
September get down low enough to make this possible. As you are
aware this is a very small drainage basin and the flows are highly
erratic when rainfall occurs. It will therefore be necessary to
have a reasonable dry period to get the work done accurately. We
will notify you in advance of the dates on which we intend to
conduct surveys, so that representatives of your organization can
join us if they so choose.
I would appreciate if you would review our program and offer any
comments that you feel are appropriate. We would also welcome your
thoughts regarding the approach to analysis. We will veep you
informed of our progress and be happy to share the data and our
methods of analysis with you at your convenience. We look forward
to the opportunity of working with you.
Sincerely yours,
Edwin L. Barnhart
President
CC: Arthur Toompas, Cone Mill
ELB/taf

L EG
NO7
n
FIGURE I
SCHEMATIC OF THE NORTH BUFFALO CREEK
6)
STUDY AREA

CONE MILLS CORPORATION
Mir. Paul Wilms, hire
Dept. of Natural Res
and Community Ilev
t;12 north Salisbury
Raleigh, N.C. 27611
F;e: Special Order t
EMC WO No. 88
NPIIES NC0000876
hear Mr. Wilms:
This report is
Consent Order for tl
winter of 1988, see
been made. Since AI:
effluent and has not
winter of 1988.
The treo.tment pia
ment portion of the pl
the addition of a secol
the clarity, reduced tl
sand of higher quali.i
produce more sludge anc
However, production of
GREENSBORO, N. C. 27405
Marc ri 28, 1989
NORTH CAROLINA DEPARTMENT OF NATURAL
RESOURCES AND COMMUNITY DEVELOPMENT o 9 �
Date 4
S� ,Ile
To
Ae:
��1nr� cam. Sl�ca�
k e-, � 8
❑ Note and file
E3 Note and return to me
❑ Note and see me about this
I
❑ Note, initial and forward
Your comments, please
❑ For your information
❑ Prepare reply for my signature
I
r A�C�Ir�
N.C. Dept. NRCD
MAR 3 0 in,3
c;31em
Re�i�rt,.; office
-listed
.ng the
it have
y good
ng the
treat --
iced by
riproved
iniform
ids to
eration.
❑ For your
We tare w o r k :i n g prove ❑Prepare information for me to rep y E, t Il e
ur conversation
question of the d i s� c h a r ❑ Pe ❑ Pleeae answer, with copy to me s t.
er your request To be filed a to _
h ta. s been made with the I Return with more details ) t to
the North Buffalo Waster :losed
with thi report. (Of _..� ,,o the
Sewer 15 also prOpOSE _�. >_Ile clato. :is a I s a enclosed. These
negotiations have progressed although they have been very 'Lengthy.
1.
IL
Conee

r
In order to meet the dissolved oxygen limits in the Consent. Order, we have
designed a stand-by system to provide additional oxygenation. The system was
approved by the Department for construction and all parts have been ordered.
This system will be installed as soon as the parts arrive.
We are also working with our Consultant, Hydrosc:ience, to comply with the
items in dumber 2) of the Consent Order. A pilot plant is on -site awaiting an
upset to evaluate additional. treatment. The absence of an upset has been both
good and bad. It has shown that the modifications have improved treatment;
however, it has delayed the pilot plant evaluations. The Model Qual 2 for the
simulation is now up and running.
cc:J Mr. Larry Coble
Mr. T. A. Alspaugh
Mr. Mather Whitehead
Mrs. Gayle Younger
Mr. Ed Barnhart
Sincerely,
Arthur J. Toompas

CONE M1LLS CORPORATION
GREENSBORO, N. C. 27405
June 26, 1989
Mr. Paul Wilms, Director
Dept. of Natural Resources
and Community Development
512 North Salisbury Street
Raleigh, N.C. 27611
Re: Special Order by Consent
EMC WQ No. 88-33
NPDES NC0000876
Dear Mr. Wilms:
ADMINISTtATIVE SERVICES
RESOtXE MANAGEMENT
This report is submitted in compliance with the above -listed
Consent Order for the July 1, 1989 report. Changes previously made
continue to provide very good control of the plant.
The question of this discharge has been a difficult problem.
After many months of dealing with the City of Greensboro, we made a
trial on effluent. Plans were made to make an influent trial. At
our last meeting with the City of Greensboro on May 30, 1989, we were
told that the influent trial could not be made. They had reviewed
our data with their consultant and decided that they could not take
the hydraulic load or the organic load at the North Buffalo Treatment
Plant. We were told that they were sorry but that they could not
help us at this time.
An oxygen system ordered to meet the dissolved oxygen,require-
ments in the Consent Order has been installed. It is operating and
it is keeping the dissolved oxygen above the 6 milligrams per liter
limit in our Consent Order.
Our Consultant, Hydroscience, was here on June 21, 1989 making
arrangements for the North Buffalo Creek survey. The survey is planned
for July and August. A review will develop an outline of the project
which, of course, will be provided to the Department of Natural Re-
sources. We plan for this to be a joint project and have requested
input from both Raleigh and the Winston-Salem Regional Office.
-J U L1
TECHivrCtii SERVICES
JUL 1989
r y
r
Cone4w

4 ' ,
Mr. Paul Wilms
June 26, 1989
Page -2-
A short-term upset allowed us to run additional lab tests on
polishing. The upset was too short to allow the pilot plant to
evaluate changes. Our tests indicate that some improvement during
upsets can be achieved.
Sincerely, 'F
Arthur J. Toompas
cc: Mr. Larry Coble
Mr. T. A. Alspaugh
Mr. Mather Whitehead
Ms. Gayle Younger
Mr. Ed Barnhart

~~~~
REQUEST
NO.
WASTELOAD ALLOCATION
APPROVAL FORM
RhE
North Pled...
FACILITY
NAME
CONE MILLS - GREENSBDRO'
N~^wom"
�� '^` 28.00
TYPE OF
WASTE
�
STOCK AND YARN DYEING
-~°*
COUNTY
�
GUILFORD
��
-~
''VER QU4LITV�M��
REGIONAL
OFFICE
WINSTON-SALEM
REQUESTOR
DAVE
ADKINS
RECEIVING
STREAM
NORTH BUFFALO CR
SUBBASIN 1
030602
7010 :
1~0 CFS
W7010 : 2^6 CFS
3002
5.2
CFS
DRAINAGE
AREA
22^8 SQ^MI^
STREAM CLASS
:C
************************
RECOMMENDED
EFFLUENT
LIMITS
WASTEFLOW(S)
(MGD)
4.1,D
q,O
MONTHLY AVG
D A�
BOD-5
(MG/L)
�
10
20
�*�&��
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(MG/L)
4
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6O9O
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�
6
6
COD
14805
2961 soff
PH
(SU)
6-9
6-9
SULFIDE
42
8
FECAL COLIFORM
(/100ML):
jmwMr~�� �\
PHENOLS
21
42�
TOTAL CR
(MG/L)
:
0^184 ^
Wq
FACILITY IS : PROPOSED ( ) EXISTING (*/) NEW ( )
LIMITS ARE t REVISION ( w') CONFIRMATION ( ) OF THOSE PREVIOUSLY ISSUElf
REVIEWED AND RECOMMENDED BY:
MODELER -- --- -_-----DATE |--__------
SUPERVISOR,MODELING GROUPK�� ��-DATE
U� »� � � � l� K�
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REGIONAL SUPERVI--�~ - � °�r� ---DATE | ---
PERMITS MANAGER ..�p� � ru° �- *1- ------DATEaw QUALM �- --_---
ON
ERAT
APPROVED BY �

P
NPDES WASTE LOAD ALLOCATION
_,:ility Name:
County:
1,
Permit No.:
Date:
Pipe No.:
- -- /ti rj/. �t� rla
Receiving Stream: l �l�K Class:
Design Capacity (NOD): Design Temp.: _cZj_Z�-Requestor: tiP�D
Sub —basin: Drainage Area: /� :�� �' 7Q10: %- Or
Other Stream Affected: 'ems
Class:
Limits (circle one): Efflu.at or wars Quality Avg. Stream Flow: ! fo�rS DO Sag Pt. (mi. )
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WMKIZA
Prepared by: Reviewed by: IZ_n Date:
IS -3/78

For Industrial rischdrgers List BPT D-)_ow 'r
Effluent
Monthly. e age
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MOM
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