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HomeMy WebLinkAboutNC0001643_Issuance of Permit_20021219 Michael F. Easley,Governor • �C' r State of North Carolina William G. Ross,Jr.,Secretary 0) Department of Environment and Natural Resources 7 O .0 Alan W.Klimek, P.E.,Director Division of Water Quality December 19, 2002 Mr.M. S.Abba Fieldcrest Cannon,Inc. One Lake Circle Drive Kannapolis,North Carolina 28081 Subject: Issuance of NPDES Permit NC0001643 New Street Mill WWTP Rockingham County Dear Mr.Abba: Division staff have reviewed and approved your renewal application for an NPDES discharge permit. Accordingly, the Division is forwarding the subject NPDES permit. This permit is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S. Environmental Protection Agency dated May 9,1994(or as subsequently amended). In response to Fieldcrest Cannon's letter dated September 11,2002 we offer the following comments: • Fecal Coliform—All facilities with discharges of domestic wastewater are required to monitor (or have limits for) fecal coliform as per Division policy. • Total Residual Chlorine—A footnote was added to the effluent page for total residual chlorine. Since chlorine is not being used at the facility now,monitoring will only be required if chlorine is used. • Metals —The data submitted for the metals were evaluated to determine if monitoring was required. The only parameter that was present above the action level standard was total copper. Monitoring for total copper on a weekly basis is included in the permit. • Temperature — The discharge includes boiler blowdown and non-contact cooling water. The Division has established minimum requirements for this type of discharges including monitoring for temperature. If any parts, measurement frequencies, or sampling requirements contained in this permit are unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty (30) days following receipt of this letter. This request must be in the form of a written petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed with the office of Administrative Hearings, 6714 Mail Service Center, Raleigh, North Carolina 27699-6714. Unless such a demand is made,this permit shall be final and binding. This permit is not transferable except after notice to the Division. The Division may require modification or revocation and reissuance of the permit. This permit does not affect the legal requirements to obtain other permits which may be required by the Division of Water Quality, the Division of Land Resources, the Coastal Area Management Act, or any other federal or local governmental permit. If you have any questions concerning this permit,please contact Teresa Rodriguez at telephone number (919) 733-5083,extension 595. Sincerely, Original Signed By David A. Goodrich Alan W. Klimek,P.E. cc: Central Files U.S.EPA Region IV Winston-Salem Regional Office/Water Quality Section ISPDES Files 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone(919)733-5083 FAX(919)733-0719 An Equal Opportunity Affirmative Action Employer Visit us on the INTERNET @ www.enr.state.nc.us Permit NC0001643 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY 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, Fieldcrest Cannon, Inc. is hereby authorized to discharge wastewater from a facility located at the New Street Mill New Street Eden Rockingham County to receiving waters designated as the Dan River in the Roanoke River basin in accordance with effluent limitations, monitoring requirements,and other conditions set forth in Parts I,II,III and IV hereof. This permit shall become effective February 1,2003. This permit and authorization to discharge shall expire at midnight on April 30,2007. Signed this day December 19,2002. Original Signed By • David A. Goodrich Alan W.Klimek,P.E.,Director Division of Water Quality By Authority of the Environmental Management Commission Permit NC0001643 SUPPLEMENT TO PERMIT COVER SHEET Fieldcrest Cannon, Inc. is hereby authorized to: 1. Continue to operate the existing 0.500 MGD wastewater treatment system consisting of dual influent lift pumps, lint screen, aeration basin, dual clarifiers, chlorine contact chamber, post aeration chamber, and sludge lagoon located in Eden at the New Street Mill in Rockingham County. 2. Discharge from said treatment works at the location specified on the attached map into the Dan River, classified C waters in the Roanoke River Basin. I ' ` l i �. lei } ` `J• _- - .'1 /! •, '% ‘1111! ��. 7 'fii [-' 1 C J I, fes. : G '< .. . • --)1_ ,.,:\ ! .- i ' IA' V `� % ; . _:j~ ter an UVI 4t:-1 -‘k let--. "III ' , • . 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N\.... .„ „ii., , ..,..„. , ,_ c___, _\ y".---) / - -)\ ,.1 ir V\-- t . \e , i n ,..„. \4....../o\tt r....5 ('-' ,, A\\v..\ 11' E __ 1 f� i s*or �A 4 \.:::1Le • . c„.....N A \cr. Fieldcrest Cannon Inc. .r.:4.,. ....t F ac lity Lat don :: ',- StateGrid1Quad Southeast Men Latihadc 36°29'34"Ni not to scale B2ONW Loogthide 79°42"13"W Receiving Strom Dan River Drainage Basun: Roanoke river NPDFS Permit No. NC0001643 saeamc>ass C subBay 03-02-03 North Rockingham County Permit NC0001643 A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS During the period beginning on the effective date of the permit and lasting until expiration,the Permittee is authorized to discharge non-contact cooling water,boiler blowdown and domestic wastewater from outfall 001. Such discharges shall be limited and monitored by the Permittee as specified below: Limits Monitoring Rquirements Monthly Daily Measurement Sample maple Location.' Avsop M..innu(n Frequency _ Type Flow 0.5 MGD Continuous Recording Influent or Effluent BOD,5-day 2020 30.0 mg/L 45.0 mg/L Weekly Composite Effluent Total Suspended Solids2 30.0 mg/L 45.0 mg/L Weekly Composite Effluent Total Nitrogen Quarterly Composite Effluent (NO2+NO3+TKN) Total Phosphorus Quarterly Composite Effluent Dissolved Oxygen Weekly Grab Effluent, Upstream&Downstream Fecal Coliform Weekly Grab Effluent pH2 Weekly Grab Effluent Total Residual Chlorines Weekly Grab Effluent Conductivity Weekly Grab Upstream&Downstream Temperature(°C)4 Weekly Grab Effluent, Upstream&Downstream Total Copper Weekly Composite Effluent Footnotes: 1. Upstream = at least 50 feet upstream from the outfall. Downstream = at Highway 700. Upstream and Downstream samples shall be grab samples. 2. The pH of the effluent shall not be less than 6.0 nor greater than 9.0 (on the standard units scale). 3. Monitoring is required only if chlorine is added to the treatment system. 4. The temperature of the effluent shall not 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 32°C. There shall be no discharge of floating solids or visible foam in other than trace amounts. A. (2.) BIOCIDE CONDITION There shall be no chromium,zinc or copper added to the treatment system except as pre-approved additives to biocidal compounds. The permittee shall obtain approval from the Division's Aquatic Toxicology Unit prior to the use of any biocide (not previously approved by the Division) in the effluent discharged under this permit. Approval for use of any biocide not previously approved should be requested at least 90 days in advance of any planned usage. Contact the Aquatic Toxicology Unit for detailed instructions on requesting approval of biocides: NC DENR/DWQ/Aquatic Toxicology Unit 1621 Mail Service Center Raleigh,North Carolina 27699-1621 ,)'\-1E.0 sr.,rFS UNITED STATES ENVIRONMENTAL PROTECTION AGENCY �P ,-w REGION 4 o Q ATLANTA FEDERAL CENTER ZyFti X02 61 FORSYTH STREET r4,PROS ' ATLANTA,GEORGIA 30303-8960 D rE_Sityxf-17 NOV 2 ] 2002 U 1 November 18, 2002 DENR-;VATER QUALITY POINT SOURCE RR c NCH f Mr. Dave Goodrich, Supervisor "" — -----.. NPDES Unit Division of Water Quality North Carolina Department of Environment and Natural Resources 1617 Mail Service Center Raleigh,North Carolina 27699-1617 SUBJ: NPDES Permit for Fieldcrest Cannon, Inc. Permit No. NC0001643 Dear Mr. Goodrich: In accordance with the EPA/NCDENR Memorandum of Agreement, we have completed our review of the revised draft permit referenced above which was received by EPA on November 1, 2002, and have no objections to the proposed permit conditions. We request that . we be afforded an additional review opportunity only if significant changes are made to the permit prior to issuance, or if significant comments to the permit are received. Otherwise, please send us one copy of the final permit when issued. If you have any questions, please contact me at (404) 562-9334 or at stewart.dee@epa.gov. Sincerely, /a-it .A1044.1-- Dee Stewart NPDES and Biosolids Permits Section Permits. Grants and Technical Assistance Branch Water Management Division Internet Address(URL)• http://www.epa.gov Recycled/Recyclable•Printed with Vegetable Oil Based Inks on Recycled Paper(Minimum 30%Postconsumer) Re:NPDES permit NC0001643-Fieldcrest Cannon Subject: Re: NPDES permit NC0001643-Fieldcrest Cannon Date: Thu, 17 Oct 2002 09:29:57-0400 From: David Russell <David.Russell@ncmail.net> Organization: NC DENR Winston Salem Regional Office To: Teresa Rodriguez <teresa.rodriguez@ncmail.net> Draft permit looks O.K. to me. Fact sheet was sent to you from WSRO on August 22. Recommend issuance. David Teresa Rodriguez wrote: David, The referenced draft permit was sent to the regionon August 7,2002 for review and comments.Did you got this permit for review or do you know if anyone reviewed this permit?I'm getting ready to finalize it but can't find any comments or the signed fact sheet from the region. Thanks, Teresa David Russell NC DENR Winston-Salem Regional Office Division of Water Quality,Water Quality Section 585 Waughtown Street Winston-Salem,NC 27107 Voice: (336)771-4608 ext 260 FAX: (336) 771-4630 Voice: (336) 771-4608 ext 260 I of 1 10/24/2002 8:10 AM piiiowtex COR POR CATION SEP 1 3 ZOOZ Fieldcrest Cannon Division DENR - WATER QUALITY One Lake Circle Drive PUNT SOURCE BRANCH Kannapolis, North Carolina 28081 P.O. Box 107 (Zip 28082) 704/939-2000 September 11, 2002 Ms. Teresa Rodriguez State of North Carolina Department of Environment and Natural Recourses Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 RE: Draft Permit NC0001643 New Street Mill Rockingham County Dear Ms. Rodriguez: I have reviewed the draft permit for the above referenced facility and have the following comments: • Our previous permit did not include monitoring for fecal coliform. My understanding is that testing for this parameter was removed from our permit several years ago due to test results abeing significantly below the limits for testing. We would request if the requirement to monitor is r rkill going to survive in the final permit that after testing for six months if the results are as low as i' they have been in the past that the requirement be removed from the permit at that time. • Our previous permit did not include testing for total residual chlorine. Since we do not treat with chlorine at this plant. This requirement was removed when the fecal coliform testing and -- monitoring was removed. Typically what happens at this plant is that the detention time is so -10'°X great in the plant that chlorination is not required, and it is my understanding that this is why it 0 was removed from previous permits. We request that this testing requirement be removed from the permit as well. Attachment 1 depicts the existing plant operation. Attachment 2 summarizes -9 .d" the plant operation. • In our permit application, we listed several metals being present as "trace" amounts. We feel r k_ the levels of these metals in the effluent are insignificant, and have attached the original test results that we utilized in the application. Attachment 3 details the test results. Please review the attached results, and if you are in agreement, please remove the testing requirement for these metals from the permit. • Our previous permit did not include a temperature monitoring condition. Since the plant is significantly under utilized, the temperature of the effluent is usually ambient. The only heat source in the plant is the boiler, which is only operated during the winter months. We would request if the requirement to monitor is going to survive in the final permit that after testing for six months if the results indicate that the temperature is always ambient that the requirement be removed from the permit at that time. New Street WWTP Permit Memo Page Two September 11, 2002 For your information, Josh Chandler is no longer with the corporation, and Larry Dillon is now handling our environmental matters. Any questions you might have should be referred to Larry or myself. We appreciate the opportunity to review this permit, and trust that favorable consideration will be give to the specific comments presented. If any additional information of further clarification is required, please let me know. I can be reached at (704) 939-2740. Sincerely, 27 M. S. Abba MSA/bs pc: Larry Dillon newstreetwwtpdraftpermit . ATTACHMENT 1 SCREEN (NOT IN USE) INFLUENT � PUMPS ai WASTE AERATION SLUDGE BASIN THICKENING ~' (NOT IN USE) T CLARIFIER _ CLARIFIER #1 #2 1T, CHLORINATION (NOT IN USE) IIIIII TO DAN RIVER "'"'r PILLOWTEX FIELDCREST CANNON MILLS, INC. DRAM JACK BOSTIC 09/10/02 ENGIBY DAIL NEERING EDEN, NORTH CAROLINA PROW MU !AMMO oaN FIELDCREST CANNON, INC. - ROCKINGHAM COUNTY, N.C. FLOW SCHEMATIC ! NEW STREET WASTE TREATMENT PLANT of FIELDCREST CANNON INC. _°"°'"TNC' s`"` NONE ENGINEERING "u"° 60030006 cr wt • KANNAPOUS. NORTH CAROUNA 01 ND' 600-3-0006 Re'' ATTACHMENT 2 NEW STREET WASTEWATER TREATMENT PLANT ROCKINGHAM COUNTY,NORTH CAROLINA SUMMARY OF OPERATION September 11, 2002 The existing wastewater treatment plant was originally designed to treat process wastewater from two manufacturing plants with plans for additional manufacturing in the future. The design flow for this facility was .5 MGD. Treatment units consist of an extended aeration activated sludge basin followed by clarification and chlorination. See Attached Figure 1 for a process flow plan. Since the plant was constructed the dyeing operations have ceased at our manufacturing plants, and the flow rate from this facility is averaging 40,000 GPD. The high detention time minimizes sludge production, and produces a high quality effluent for discharge into the Dan River. The sludge storage basin is not in use as this process no longer produces sludge, and the treatment with chlorine was eliminated sometime in the past. Fecal monitoring in the past has always been below any limits,which is due in our opinion to the long detention time. • ATTACHMENT 3 IFFFM-ITT-ii _s1 INTLRNATIONAI. ()k Date: 06-Sep-02 CLIENT: Fieldcrest Cannon,Inc. Client Sample ID: Effluent Lab Order: B01080757 CollectionBegin Date: 8/29/2001 7:30:00 AM Project: Special Testing Collection Date: 8/30/2001 8:00:00 AM Lab ID: B01080757-01 Matrix: WASTEWATER Tag No: COMPOSITE Analyses Result Limit Qual Units DF Date Analyzed TOTAL ARSENIC IN WASTER WATER BY GF E206.2 Analyst: RTW Arsenic <0.0050 0.0050 mg/L 9/7/2001 1:25:00 PM 9/17/2001 9:00:44 PM TOTAL METALS IN WASTEWATER BY ICP E200.7 Analyst: RTW Aluminum 0.065/ 0.050 mg/L 9/4/2001 9:00:00 AM 9/20/2001 9:20:00 PM Boron <0.10 0.10 mg/L 9/4/2001 9:00:00 AM 9/20/2001 9:20:00 PM Calcium 12 0.10 mg/L 9/4/2001 9:00:00 AM 9/20/2001 9:20:00 PM Iron • 0.44 0.050 mg/L 9/4/2001 9:00:00 AM 9/20/2001 9:20:00 PM Magnesium 2.3 0.10 mg/L 9/4/2001 9:00:00 AM 9/20/2001 9:20:00 PM Potassium 6.5 0.50 mg/L 9/4/2001 9:00:00 AM 9/20/2001 9:20:00 PM Sodium <0.10 0.10 mg/L 9/4/2001 9:00:00 AM 9/20/2001 9:20:00 PM Tin <0.10 0.10 mg/L 9/4/2001 9:00:00 AM 9/20/2001 9:20:00 PM Titanium <0.050 0.050 mg/L 9/4/2001 9:00:00 AM 9/20/2001 9:20:00 PM TOTAL METALS IN WASTEWATER BY ICP-MS E200.8 Analyst: RTW Antimony 0.0017 0.000020 mg/L 9/4/2001 9:00:00 AM 9/6/2001 6:09:00 PM Barium 0.017 0.00020 mg/L 9/4/2001 9:00:00 AM 9/6/2001 6:09:00 PM Beryllium 0.00029 0.000060 mg/L 9/4/2001 9:00:00 AM 9/6/2001 6:09:00 PM Cadmium 0.00051 0.000040 mg/L 9/4/2001 9:00:00 AM 9/6/2001 6:09:00 PM Chromium 0.0012 0.00070 mg/L 9/4/2001 9:00:00 AM 9/6/2001 6:09:00 PM Cobalt 0.00061 0.000040 mg/L 9/4/2001 9:00:00 AM 9/6/2001 6:09:00 PM Al - ?3 Kopper, cif 0.0020 mg/L 9/4/2001 9:00:00 AM 9/6/2001 6:09:00 PM Lead 0.00047 0.00020 mg/L 9/4/2001 9:00:00 AM 9/6/2001 6:09:00 PM Manganese 0.052 0.00050 mg/L 9/4/2001 9:00:00 AM 9/6/2001 6:09:00 PM Molybdenum 0.091 0.00050 mg/L 9/4/2001 9:00:00 AM 9/6/2001 6:09:00 PM Nickel . 0.0048 0.0020 mg/L 9/4/2001 9:00:00 AM 9/6/2001 6:09:00 PM Selenium , 0.00056 0.00030 mg/L 9/4/2001 9:00:00 AM 9/6/2001 6:09:00 PM Silver <0.000010 0.000010 mg/L 9/4/2001 9:00:00 AM 9/6/2001 6:09:00 PM Thallium <0.000010 0.000010 mg/L 9/4/2001 9:00:00 AM 9/6/2001 6:09:00 PM Zinc -' 0.024 0.0050 mg/L 9/4/2001 9:00:00 AM 9/6/2001 6:09:00 PM COLOR,ADMI M2120E Analyst: MSJ Initial pH 6.63 8/31/2001 11:00:00 AM 8/31/2001 11:00:00 AM Certifications: Simalabs-Burlington EP Chemistry Lab ID:NC00137,Bioassay Lab ID:NC2721500 NC Chemistry:#85,Biomonitoring:#002,Drinking Water:#37743,#37738,Radiation License:#001-904-0G SC Laboratory ID:#99042 VA SWCB ID:#000061,Drinking Water:#00018 / Burlington Eden 1 302 Belmont Street • Burlington, NC 27215-6935 370 W. Meadow Road • Eden, NC 27288 Phone (336) 570.4661 • FAX (336) 570-4698 Phone (336) 623-8921 • FAX (336) 623-5878 Phone (888) 274-5227 i NCWRC ,HCP ,FALLS LAKE TEL :919-528-9839 Sep 06 '02 15 :01 No .004 P .02 i , • u r/ ` or3 � + ' , xt , 4n �4 pi 44, n s ' tA'.‘1 54..rr ` ti North Carolina Wildlife Resources Commission i MEMORANDUM Charles R.Fullwood,Executive Director TO: Teresa Rodriguez, NPDES Unit ision terV-FROM: anielle R. Pender, Pim exit egion Coordinator Habi tat Conservation Program DATE: 6 September 2002 SUBJECT: Proposed Permit Renewal for Fieldcrest Cannon,Inc.,New Street Mill WWTP, Rockingham County,NPDES Permit No.NC0001643 Biologists with the North Carolina Wildlife Resources Commission(NCWRC)have reviewed the subject application for impacts to fish and wildlife, and we are familiar with the habitat values of the area. Our comments are provided in accordance with provisions of the Clean Water Act of 1977(as amended), the Fish and Wildlife Coordination Act(48 Stat. 401, as amended; 16 U.S.C. 661-667d),North Carolina General Statutes (G.S. 113-131 et seq.), and the North Carolina Administrative Code 15A NCAC 10I.0102. The applicant has submitted a request for a permit renewal for the Fieldcrest Cannon, Inc.,New Street Mill Wastewater Treatment Plant to discharge treated wastewater into the Dan River in the Roanoke River basin. It is our understanding that this plant utilizes chlorine in their treatment system. Chlorine is acutely toxic to aquatic organisms and forms secondary compounds that are also detrimental to aquatic life. In addition,the dechlorination agent, hydrogen disulfide, is also very toxic to aquatic life. We are especially concerned with impacts of this project on the many sensitive species that are found in this system. The Dan River and its tributaries support a high diversity of aquatic organisms, including largemouth bass (Micropterus salmoides),sunfishes, catfishes,minnows,darters,and mussels and other invertebrates. The Dan , River aquatic habitat is considered by the Natural Heritage Program to be a State significant natural heritage area, and the Non-Game Section of the NCWRC has identified this river as one of six high priority areas for long term conservation. There are records for the existence of the federal and state endangered James River spiny mussel(Pleurobema collina), the federal species of concern and state endangered green floater(Lasmigona subviridis), state species of special concern riverweed darter(Etheostoma podostemone)and bigeye jurnprock(Scarlomyzon ariommus), and the state significantly rare Roanoke hogsucker(Hypenteli'um roanokense) and notched rainbow (Villosa constricta)in the Dan River system. We recommend that the following conditions be incorporated into the permit to reduce impacts to fish and wildlife resources and in particular to listed species. Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center•Raleigh,NC 27699-1721 Telephone: (919) 733-3633 ext.281 • Fax: (919) 715-7643 1 NCWRC ,HCP 'FALLS LAKE TEL :919-528-9839 Sep 06 '02 15 :02 No .004 P .03 Page 2 • 6 September 2002 New Street Mill WWTP NPDES No.NC0001643 €'. 1. We request that ozone or ultraviolet light systems replace the chlorine systems. These disinfectants also provide an additional benefit of removing a hazardous material from the workplace. 2. If not already in place,we suggest the installation of a stand-by power system. Thank you for the opportunity to provide input on this project. If we can be of further assistance,please contact our office at(919)528-9886, cc: Garland Pardue,USFWS •• • • • • • r • .. 4-- FY -L ___ .0,11i is ..... b 411 lig -41. 1921 VANCE STREET P.O. BOX 2157 REIDSVILLE, NC 27320 336-349-4331 PUBLIC NOTICE STATE OF NORTH CAROLINA AFFIDAVIT OF PUBLICATION ENVIRONMENTAL MANAGEMENT 161171 MAILS ER/NPDES UNIT VICECENTER NORTH CAROLINA RALEIGH,NC 27699-1617 NOTIFICATION OF INTENT TO ISSUE A ROCKINGHAM COUNTY NPDES WASTEWATER PERMIT On the basis of thorough staff review and application of NC General Statute 143.21 Public law 92-500 and other lawful stan- dards and regulations the North Carolina Before the undersigned, a Notary Public of Said Environmental Management Commission proposes to issue a National Pollutant Dis- County and State, duly commissioned, qualified, and charge Elimination System (NPDES) was- tewater discharge permit to the person(s) authorized by law to administer oaths, personally listed below effective 45 days from the publish date of this notice. appeared David Clevenger, who being first duly sworn, Written comments regarding the proposed permit will be accepted until 30 days after deposes and says. That she is an official of Media the publish date of this notice. All com- ments received prior to that date are con- General of Reidsville, Inc. engaged in the publication of sidered in the final determinations regard- ing ing the proposed permit. The Director of a newspaper known as The Reidsville Review pub- the NC Division of Water Quality may de- cide cide to hold a public meeting for the pro- lished, issued and entered as second class mail in the posed permit should the Division receive a significant degree of public interest. City Reidsville,Reidille, in said County and State; that she is Copies of the draft permit and other sup- porting information on file used to deter- mine conditioned present in the draft per- authorized to make this affidavit and sworn statement, mit are available upon request and pay- ment of the costs of reproduction. Mail that the notice or other legal advertisement, a true copy comments and/or requests for information to the NC Division of Water Quality at the . of which is attached hereto, was published in The • above address or call Ms. Christi Jackson at 919-733-5083. extension 538. Please in- Reidsville Review on the following dates: cludes the NPDES permit number attached in any communication. Interested persons may also visits the Division of Water Quali- ty at 512 N. Salisbury Street. Raleigh. NC __9\40SUl�8 27604-1148 between the hours of 8:00 a.m. and 5:00 p.m.to review information on file. NPD ES Permit Number NC00018643. Field- crest Cannon, Inc. (New Street Mill WWTP). One Lake Circle 29081 has applied for ae permit o elnewal for and that the said newspaper in which such notice, paper a facility located in Rockingham County ' p I1 discharging treated wastewater into the document, or legal advertisement was published was, at Dan River in the Roanoke River Basin. Cur- ti rentlyy no parameters are water quality li- mited. This discharge may affect future al- the time of each and every such publication, a newspa- locations in this portion of the receiving stream. per meeting all of the requirements and qualifications August 13,2002 of Section I-597 of the General Statutes of North Carolina and was qualified newspaper within the mean- ing of Section I-597 of the General Statutes of North Carolina. This day of0\kkjinkLi c�4 Jai ( ,i,1 / _ollb, ..4110P PF('PIrr- Sworn to andsubscribed before me, this C—P:b OCT 1 0 2002 day of (T�^ t ,r- -hiva bUuuc► urFICE r /. -� ,-k l Notary Public C /Ci:: �` .--- / `yx, " / - l DENR/DWQ FACT SHEET FOR NPDES PERMIT DEVELOPMENT NPDES Permit NC0001643 Facility Information Applicant/Facility Name: Fieldcrest Cannon, Inc. / New Street Mill Applicant Address: One Lake Circle Drive, Kannapolis,NC 28081 Facility Address: New Street Mill, Eden,NC Permitted Flow 0.5 MGD Type of Waste: 30% domestic, 5%boiler blowdown, 65% non-contact cooling water Facility/Permit Status: Renewal County: Rockingham Miscellaneous Receiving Stream: Dan River Regional Office: Winston-Salem Stream Classification: C Quad B2ONW 303(d) Listed?: No Date August 7, 2002 Subbasin: 030203 Permit Writers: Dee Stewart, EPA Teresa Rodriguez,DWQ Drainage Area (mi2): 1740 Summer 7Q10 (cfs) 370 Winter 7Q10 (cfs): 610 Average Flow (cfs): 1653 IWC (%): 0.21 SUMMARY Fieldcrest Cannon,Inc.,has requested a renewal of NPDES discharge point NC0001643 for the disposal of non- contact cooling water, sanitary wastewater,and boiler blow-down to waters of the state. The previous NPDES permit for Fieldcrest Cannon, Inc.,expired on February 28,2002 and the facility NPDES Permit Application was received on October 1,2001. The Division of Water Quality's NPDES Unit issues the permits for individually permitted facilities,and determines the conditions that must be achieved prior to discharging wastewater. This fact sheet summarizes the rationale used to determine permit limits and conditions. This facility generates non-contact cooling water,sanitary wastewater,and boiler blow-down,which are treated by the New Street Wastewater Treatment Plant (WWTP). The system is an extended aeration activated sludge treatment system with a design flow of 0.5 MGD;however,the actual flow to the WWTP is approximately 0.04 MGD. The effluent discharges to the Dan River. Current Stream Conditions The receiving water is the Dan River in the Roanoke River basin. The most current wasteload allocation for the receiving water with respect to this facility was competed in 1996. Instream Monitoring The Instream monitoring conditions are retained from the previous permit for temperature,pH,conductivity,and dissolved oxygen,as recommended by the 1996 wasteload allocation. Compliance Summary The compliance records for January 2000 through December 2001 show two exceedances of total suspended solids monthly average: 42.5 mg/L and 34.0 mg/L in March and April 2000,respectively. The facility has been in compliance with all other parameters during this time period. Page 1 of 3 DENR/DWQ FACT SHEET FOR NPDES PERMIT DEVELOPMENT Permit Limit Development The flow limit,BODS limit,total suspended solids limit,dissolved oxygen monitoring,conductivity monitoring,total phosphorus monitoring,total nitrogen monitoring,and pH limit have been included in the permit per 40 C.F.R. 122.44(1)which requires that permits be issued with conditions as stringent as the pervious permit unless circumstances on which the pervious permit have materially and substantially changed. The conditions upon which the pervious permit,i.e.,nature and quality of wastewater,have not substantially changed since previous permit issuance and therefore the permit conditions will remain. Fecal coliform monitoring has been added to the permit based on best professional judgment and the 30% contribution of sanitary wastewater to the total discharge flow. Monitoring for total residual chlorine has been added recognizing the facility disinfects using a chlorine contact chamber and based on best professional judgment. A temperature limit has been added due to a reasonable potential for non-contact cooling water to contribute to temperature increases of the discharge flow and impact the receiving water,per 40 C.F.R. 122.44(d)and protective of North Carolina water quality standard 15A NCAC 02B.0211(j). Several metals were listed in the application as believed present,but no data was provided to determine reasonable potential for inclusion of a limit. Quarterly monitoring for two years will be required and the information evaluated by the Division and the permit re-opened to include a limit if necessary based on best professional judgment. The monitored parameters include: total zinc,total selenium,total nickel,total molybdenum,total magnesium,total cadmium,total lead,total antimony,total beryllium,total cobalt,total barium,total chromium,total aluminum,total cadmium,and total copper. Data may be submitted for these parameters during the public notice period. If data is received and indicates no reasonable potential for a permit limit for a parameter,all monitoring will be deleted for the parameter from the permit prior to issuance. If data is received and indicates reasonable potential for inclusion of a limit,than the final permit will be issued with the appropriate limit for the parameter. Proposed Changes from Previous Permit D A fecal coliform limit,due to the 30%contribution of sanitary wastewater to the total discharge flow,has been added to the permit. ➢ Monitoring for total residual chlorine has been added recognizing the 30%contribution of sanitary wastewater to the total discharge flow. D A limit for temperature has been added protective of North Carolina water quality standards. D Several metals were listed in the application as believed absent,but no data was provided to determine reasonable potential for inclusion of a limit. Quarterly monitoring for two years will be required and the Division will evaluate the information and the permit re-opened to include a limit if necessary. The monitored parameters include: total zinc,total selenium,total nickel,total molybdenum,total magnesium,total cadmium,total lead, total antimony,total beryllium,total cobalt,total barium,total chromium,total aluminum,total cadmium,and total copper. PROPOSED SCHEDULE FOR PERMIT ISSUANCE: Draft Permit to Public Notice: August 12,2002 (est.) Permit Scheduled to Issue: September 30,2002(est.) STATE CONTACT: If you have any questions on any of the above information or on the attached permit, please contact Teresa Rodriguez at (919) 733-5038 extension 595. Page 2 of 3 DENR/DWQ FACT SHEET FOR NPDES PERMIT DEVELOPMENT DRAFT PREPARED BY: Dee Stewart U.S. EPA Region W DRAFT REVIEWED BY: ) Thr/7 0 Teresa Rodriguez NC DENR/DWQ/NPDES Unit REGIONAL OFFICE COMMENT: NAME: DATE: Page 3 of 3 DENR/DWQ • FACT SHEET FOR NPDES PERMIT DEVELOPMENT DRAj;T•PREPARED BY: Dee Stewart U.S. EPA Region IV DRAFT REVIEWED BY: /3') Th 1/7/6 Teresa Rodriguez NC DENR/ DWQ /NPDES Unit REGIONAL OFFICE COMMENT: 4 l � isieri Nty..4):j 9 DATE: 0 Z 0 8 2-'1- Page 3 of 3 Jatev sti% UNITED STATES ENVIRONMENTAL PROTECTION AGENCY �� YW REGION 4 ��� ATLANTA FEDERAL CENTER F nor 61 FORSYTH STREET 47.q<PRO1 ATLANTA, GEORGIA 30303-8960 E � � od � August 26, 2002 ai AUG 3 0 2002 Mr. Dave Goodrich, Supervisor AR - WATER QUALITY NPDES Unit POINT SOURCE BRA NcN Division of Water Quality North Carolina Department of Environment and Natural Resources 1617 Mail Service Center Raleigh, North Carolina 27699-1617 SUBJ: NPDES Permit for Fieldcrest Cannon, Inc. Permit No. NC0001643 Dear Mr. Goodrich: In accordance with the EPA/NCDENR Memorandum of Agreement, we have completed our review of the draft permit referenced above which was received by EPA on August 14, 2002, and have no objections to the proposed permit conditions. We request that we be afforded an additional review opportunity only if significant changes are made to the permit prior to issuance, or if significant comments to the permit are received. Otherwise, please send us one copy of the final permit when issued. If you have any questions, please contact me at (404) 562-9334 or at stewart.dee@epa.gov. Sincerely, AJwa%- Dee Stewart NPDES and Biosolids Permits Section Permits, Grants and Technical Assistance Branch Water Management Division Internet Address(URL)• http://www.epa.gov Recycled/Recyclable•Printed with Vegetable Oil Based Inks on Recyded Paper(Minimum 30%Postconsumer) Re:[Fwd►[Fwd:Draft Fieldcrest Permit-NC0001643]] Subject:Re: [Fwd: [Fwd:Draft Fieldcrest Permit-NC0001643]] Date:Tue,09 Jul 2002 16:08:43-0400 From:Matt Matthews <matt.matthews@ncmail.net> To:Natalie Sierra<Natalie.Sierra@ncmail.net> CC: Charles Weaver<Charles.Weaver@ncmail.net>,teresa.rodriguez@ncmail.net I put in a call to Dee and left voice mail at about 3:45. At 03:20 PM 7/9/02-0400,Natalie Sierra wrote: I think it might be best if Matt spoke with Dee(a she) directly. Besides being the best person for the job,if she has any additional questions,they can be answered immediately. What do you guys think? -Natalie Matt Matthews wrote: Charles and Natalie, Our records indicate the facility failed six of nine tests during the period May 1989 through June of 1990.There were no subsequent failures through the last WET monitoring event of May 1997.That would include 28 straight compliant monitoring events. Our records do not include any indication as to what caused the failures. Given that EPA's own infamous application 2A does not require any WET monitoring for domestic discharges under 1 MGD,the facility had seven straight years of compliance when the discharge included process wastewater, and the discharge now is 100%domestic,I'm a little puzzled as to why Dee would think the monitoring is needed. Does she(he?)understand that there is no process wastewater in the discharge? I'll be happy to talk with her(him?)directly to get the justification for this(and to ask about the 91 and 92 failures that we don't have any record of). Let me know what you want to do. Matt At 02:14 PM 7/9/02-0400,you wrote: Matt-this is the draft Natalie mentioned. Dee Stewart submitted the draft permit and fact sheet as one big document. I don't believe these folks need a tox test,but any comments you have (for or against)will be greatly appreciated. CHW Return-Path: <dave.goodrich®ncmail.net> Original-Recipient:rfc822;Charles.Weaver@ncmail.net Received: from scc067.its.state.nc.us (149.168.194.129) by nplexl.ncmail.net(5.5.060) id 3D21649D0001D79D for Charles.Weaver@dwq.denr.ncmail.net;Wed,3 Jul 2002 13:38:29-0400 Received: from ncmail.net(149.168.194.132) by scc067.its.state.nc.us (5.5.060) id 3D0382B3001387A4 for Charles.Weaver@dwq.denr.ncmail.net;Wed,3 Jul 2002 13:38:29-0400 Received: from ncmail.net(localhost[127.0.0.1]) by ncmail.net(8.11.5/8.11.5)with ESMTP id g63HcQD15289 for<Charles.Weaver@ncmail.net>;Wed,3 Jul 2002 13:38:26-0400(EDT) Received:from ncmail.net obasnight.ehnr.state.nc.us [149.168.123.19]) by ncmail.net(8.11.5/8.11.5)with ESMTP id g63HcQ315282 1 of 4 7/10/2002 6:05 AM Re:[Fwd:[Fwd:Draft Fieldcrest Permit-NC00016431] • for<Charles.Weaver@ncmail.net>;Wed,3 Jul 2002 13:38:26-0400 (EDT) Message-ID: <3D2336AC.9C53401C@ncmail.net> Date:Wed,03 Jul 2002 13:38:52-0400 From:Dave Goodrich <dave.goodrich@ncmail.net> X-Mailer:Mozilla 4.7 [en] (WinNT;I) X-Accept-Language:en MIME-Version: 1.0 To: Charles Weaver<Charles.Weaver@ncmail.net> Subject: [Fwd:Draft Fieldcrest Permit-NC0001643] Content-Type:multipart/mixed; boundary="----------CC74F6BB3A1 DC4511394D64E" Charles- The first Region N-drafted permit!? -Dave Return-Path:<Stewart.Dee@epamail.epa.gov> Original-Recipient:rfc822;dave.goodrich@ncmail.net Received: from scc067.its.state.nc.us (149.168.194.129)by nplexl.ncmail.net(5.5.060) id 3D21649D00016FE9 for Dave.Goodrich@dwq.denr.ncmail.net;Wed,3 Ju1 200209:24:00-0400 Received:from scc074.its.state.nc.us (149.168.194.133)by scc067.its.state.nc.us (5.5.060) id 3D0382B300132897 for Dave.Goodrich@dwq.denr.ncmail.net;Wed,3 Jul 2002 09:24:00-0400 Received: from scc074.its.state.nc.us (localhost[127.0.0.1]) by scc074.its.state.nc.us(8.11.5/8.11.5)with ESMTP id g63DNuw14804 for<dave.goodrich@ncmail.net>;Wed,3 Jul 2002 09:23:56-0400(EDT) Received: from scc073.its.state.nc.us (maildmz.state.nc.us [207.4.219.13]) by scc074.its.state.nc.us(8.11.5/8.11.5)with ESMTP id g63DNt614791 for<dave.goodrich@ncmail.net>;Wed,3 Jul 2002 09:23:55-0400(EDT) Received: from myrtle.rtpnc.epa.gov(myrtle.rtpnc.epa.gov[134.67.208.33]) by scc073.its.state.nc.us(8.11.4/8.11.4/DFR)with ESMTP id g63DMV215759 for<dave.goodrich@ncmail.net>;Wed,3 Jul 2002 09:22:31 -0400(EDT) Received: from epahubll.rtp.epa.gov(epahubll.rtp.epa.gov[134.67.213.52]) by epamail.epa.gov(PMDF V5.2-32#42055) with ESMTP id <OGYO00AUAD70QO@epamail.epa.gov> for dave.goodrich@ncmail.net; Wed, 3 Jul 2002 09:23:27-0400(EDT) Content-return:prohibited Date:Wed,03 Jul 2002 09:23:39-0400 From:Stewart.Dee@epamail.epa.gov Subject:Draft Fieldcrest Permit-NC0001643 To:dave.goodrich@ncmail.net Message-id: <OF9863524E.F9F19F21-ON85256BEB.0049493B@rtp.epa.gov> MIME-version: 1.0 X-Mailer:Lotus Notes Release 5.0.1a August 17, 1999 • Content-type:multipart/mixed; Boundary="0_=0ABBE178DFDACFAB8f9e8a93df938690918c0ABBE178DFDACFAB" Content-disposition:inline X-MIMETrack:Serialize by Router on EPAHUBI I/USEPA/US(Release 5.0.9a January 7,2002) at 07/03/2002 09:23:47 AM X-Filter-Version: 1.7(maildmz) Dave, I must have something wrong with Charles E-mail address-this message keeps corning back to me. Would you please do me a favor and forward it • to him. It is the draft of the Fieldcrest permit that we have been working on. Thanks, Have a nice July 4th!! 2 of 4 7/10/2002 6:05 AM Re:[Fwdr[Fwd:Draft Fieldcrest Permit-NC0001643]] Dee Forwarded by Dee Stewart/R4/USEPA/US on 07/03/2002 09:14 AM Dee Stewart To: weaver.charles@ncmail.net 07/02/2002 03:31 cc: Roosevelt Childress/R4/USEPA/US@EPA PM Subject: Draft Fieldcrest Permit-NC0001643 Charles, I have pulled together a draft of the Fieldcrest Permit,with a draft cover letter. As discussed earlier this morning,this is still a work in progress and reflects a conservative permit based only on the permit files received, but I wanted to let you know where I was heading and give you an opportunity to check on toxicity language. You asked for the application information: Josh W.Chandler,P.E. Corporate Environmental Engineering Coordinator One Lake Circle Drive Kannapolis,NC 28081 704/939-2654 fax: 704/939-2714 josh_chandler@pillowtex.com I have summarized the proposed changes in the cover letter. It may not be necessary to require all of the metals monitoring that was missing from the application in the permit if the permittee samples prior to permit issuance and that information is evaluated for RP for a limit. I understand that you are writing the pemittee requesting this information prior to public notice of this permit. I have also included a fecal limit due to the 30%sanitary waste contribution,TRC monitoring,and I year of quarterly chronic toxicity monitoring(I found buried in the file where some WET failures had occurred in the early'90's.). DO and Temperature limits were included based on NC WQS,but may not be necessary after review of the compliance data. The fact sheet needs a compliance evaluation(I do not have the compliance files and have not done a PCS pull for this facility. I was hoping that you would have easy access to this information). I have not finished the permit justification,but will get to this next week. Hopefully this is a good starting point. Looking forward to working with you. Have a nice 4th of July!! Dee Stewart 3 of 4 7/10/2002 6:05 AM Re:[Fwd:[Fwd:Draft Fieldcrest Permit-NC0001643]] • 404/562-9334 (See attached file: 1643fieldcrest cannon.doc) Matt Matthews NC DENR/Division of Water Quality Aquatic Toxicology Unit 1621 Mail Service Center Raleigh,North Carolina 27699-1621 v-(919) 733-2136 f-(919)733-9959 MailTo:Matt.Matthews@ncmail.net A few observations and much reasoning lead to error, many observations and a little masoning to truth. --Alexis Carrel Matt Matthews NC DENR/Division of Water Quality Aquatic Toxicology Unit 1621 Mail Service Center Raleigh,North Carolina 27699-1621 v-(919)733-2136 f-(919)733-9959 MailTo:Matt.Matthews(a,ncmail.net A few observations and much reasoning lead to cans; many observations and a little reasoning to tnrtb. —Alexis Carrel • 4 of 4 7/10/2002 6:05 AM Re:[Fw.Priority Pollutant Analysis-Fieldcrest Cannon,Inc.NC0001643] Subject:Re: [Fwd:Priority Pollutant Analysis-Fieldcrest Cannon,Inc.NC0001643] Date:Wed,03 Jul 2002 09:10:39-0400 From:Teresa Rodriguez <teresa.rodriguez@ncmail.net> Organization:NC DENR DWQ To:Charles Weaver<Charles.Weaver@ncmail.net> CC:Natalie Sierra<Natalie.Sierra@ncmail.net> Charles, It is correct that they don't have to do a PPA.The section that applies to them is 40 CFR 12221(h) manufacturing facilities discharging only non-process wastewater. They do have to test for BOD,TSS,TRC,oil&grease,COD,TOC Ammonia,pH and temp. Charles Weaver wrote: Dee says the facility discharges non-contact cooling water and domestic-no process waste. Based on that statement,I don't think they need to do a PPA. However,we have the facility is rated as a Major. Despite this,they have no tox test. Dee wants to add a fecal limit,TRC limit and a tox test to the draft. Teresa: Can you tell me-based on your review of the EPA application requirements-where in 40 CFR 122 it says that industrial facilities do a PPA ONLY when the discharge process wastewater? Basically,I'd like to confirm that no PPA should be necessary for this facility. If one is necessary,I'll send National Spinning an add-info letter requesting the additional analyses. Dee is sending a draft to us soon. I'd like you both to peer-review it. Thanks, CHW Subject: Priority Pollutant Analysis-Fieldcrest Cannon,Inc.NC0001643 Date:Tue,02 Jul 2002 10:24:27-0400 From:Stewart.Dee@epamail.epa.gov To:charles.weaver@ncmail.net Charles, I looked at the file for Fieldcrest, Cannon, Inc. They did submit a priority pollutant analysis dated December 20, 2001. The analysis was for VOC's and did not include any metal, fecal coliform, oil and grease, chloride, sulfate, phosphorus, nitrate, ect. analysis. I have listed the wastewater characteristics that were deemed present in the wastewater but no actual analytical data was included. Information needs to be collected from the facility and evaluated for reasonable potential for a limit in the permit. All metals should be for total. Thanks, Dee Ammonia Organic Nitrogen Nitrate Nitrite Phosphorus 1 of 2 7/5/2002 8:47 AM Rc:(Fwd:Priority Pollutant Analysis-Fieldcrest Cannon,Inc.NC00016431 • • Sulfate Chloride Fluoride Aluminum Antimony Beryllium Barium Cadmium Cobalt Chromium Fecal Coliform Copper Lead Magnesium Molybdenum Nickel Selenium Zinc Oil and Grease • :i 2 of 2 7/5/2002 8:47 AM IWC Calculations Owner: Fieldcrest Cannon Permit No. NC0001643 Prepared By: Enter Design Flow(MGD): 0.5 Enter s7Q10(cfs): 370 Enter w7Q10 (cfs): 610 Residual Chlorine Ammonia(NH3 as N) (summer) 7010 (CFS) 370 7Q10(CFS) 370 DESIGN FLOW (MGD) 0.5 DESIGN FLOW (MGD) 0.5 DESIGN FLOW (CFS) 0.775 DESIGN FLOW (CFS) 0.775 STREAM STD (UG/L) 17.0 STREAM STD (MG/L) 1.0 UPS BACKGROUND LEVEL(I 0 UPS BACKGROUND LEVEL 0.22 IWC (%) 0.21 IWC (%) 0.21 Allowable Conc. (ug/I) 8133 Allowable Conc. (mg/I) 373.4 Ammonia(NH3 as N) (winter) 7Q10 (CFS) 610 Fecal Limit Not Required DESIGN FLOW (MGD) 0.5 (If DF>331; Monitor) DESIGN FLOW (CFS) 0.775 (If DF<331; Limit) STREAM STD(MG/L) 1.8 Dilution Factor(DF) 478.42 UPS BACKGROUND LEVEL 0.22 IWC (%) 0.13 Allowable Conc.(mg/I) 1245.4 NPDES Servor/Current Versions/IWC 7/8/02 Dee Stewart To: charles.weaver®ncmail.net 07/02/02 10:24 AM cc: Subject: Priority Pollutant Analysis-Fieldcrest Cannon, Inc. NC0001643 Charles, I looked at the file for Fieldcrest, Cannon, Inc. They did submit a priority pollutant analysis dated December 20, 2001. The analysis was for VOC's and did not include any metal, fecal coliform, oil and grease, chloride, sulfate, phosphorus, nitrate, ect. analysis. I have listed the wastewater characteristics that were deemed present in the wastewater but no actual analytical data was included. Information needs to be collected from the facility and evaluated for reasonable potential for a limit in the permit. All metals should be for total. Thanks, Dee Ammonia Organic Nitrogen Nitrate Nitrite Phosphorus Sulfate Chloride Fluoride.. Alu.� - ium -► ,:. '. ✓✓ Ccs ✓ obalt�i Chromium -- Fecal Coliform Copper Lead Magnesium,... Molybdenumv Nickel -' Seleniu v Zinc Oil and Grease V 4 ! 1 blith4;t1 Teresa Rodriguez To: Dee Stewart/R4/USEPA/US@EPA ��` 111 4 0deresa.rodriguez�nc cc: /�(�� mail.net> Subject: Fieldcrest cannon draft permit V 07/15/02 11:49 AM Dee, Natalie Sierra and I reviewed the draft permit and have the following comments: Cover Letter: 1. In the cover letter the County should be listed as Rockingham County • instead of Cabarrus. On the cc list the Regional Office is the Winston-Salem Regional Office. Point Source Compl. , Tech Assistance & Cert. and Central Files don't have to be cc'd with the draft permit. 2. Cadmium is misspelled in the last sentence of the first page. Permit: 1. Fecal Coliform - With only 30 % of domestic wastewater the dilution is higher than the minimum dilution factor (331:1) required by North --���,4•'`rd1;^3 Carolina policy for the implementation of a fecal coliform limit. A p limit is not required, monitoring only should be adequate. V._ 2. Dissolved Oxygen - A dissolved oxygen limit is not required by Northlir Pr?5 Carolina policy, unless modeling shows need for the limit or their ---�(,p v" 4 compliance history requires it. 3. Metals - The cover letter mentions that several parameters were listed as believe bsentt but there was no information to establish limns Tne f ootnote for the metals in the effluent page of the permit Ci7says the parameters were listed as believed present therefore monitoring was included to collect data. If some metals are believed absefit why would data collection be required, this facility is discharging non process wastewater only and the application requirements do not require testing for metals. For the ones that are believed present, as an alternative, they could submit data during the notice period, then we can determine if a limit is necessary. Fact Sheet: 1. Current Stream Conditions - There is no other WLA in the file, the 1996 was the last one done. The Dan River is fully supporting at the discharge location. 2. Compliance Summary - The compliance records for January 2000 through December 2001 show two exceedances of Total Suspended Solids, 42 .5 mg/1 and 34 mg/1 on March and April 2000. Matt Matthews from the Aquatic Toxicology Unit is reviewing the toxicity requirements, he may have further comments. If you have any questions, you can call me at 919-733-5083, ext 595. Teresa Re:Fieldcrest Cannon Permit NC0001643 • Subject: Re: Fieldcrest Cannon Permit NC0001643 Date: Mon, 15 Jul 2002 14:01:05 -0400 From: Matt Matthews<matt.matthews@ncmail.net> Organization: NC DENR DWQ To: Teresa Rodriguez<teresa.rodriguez@ncmail.net> CC: Natalie Sierra<Natalie.Sierra@ncmail.net> Teresa and Natalie, I talked directly with Dee about this last week and followed up with Charles afterwards. Dee indicated to me that EPA considers non-contact cooling water as "process wastewater, " which, along with the previous failures is why she suggested a year's worth of monitoring. I explained to her that non-contact cooling water was among our list of process water types that was exempted from WET testing and also described our biocide review process. It turns out that she also was confusing Fieldcrest plants which is why she thought there were WET failures in 91 and 92 and maybe why she got the county wrong. My advice to Charles was that we continue to do business as we have in the past; in this case we would not require WET monitoring but would include the biocide review condition in the permit. Matt Teresa Rodriguez wrote: >Dee, >Natalie Sierra and I reviewed the draft permit and have the following >comments: >Cover Letter: >1. In the cover letter the County should be listed as Rockingham County >instead of Cabarrus. On the cc list the Regional Office is the >Winston-Salem Regional Office. Point Source Compl., Tech Assistance & >Cert. and Central Files don't have to be cc'd with the draft permit. >2. Cadmium is misspelled in the last sentence of the first page. >Permit: >1. Fecal Coliform - With only 30 % of domestic wastewater the dilution >is higher than the minimum dilution factor (331:1) required by North >Carolina policy for the implementation of a fecal coliform limit. A >limit is not required, monitoring only should be adequate. >2. Dissolved Oxygen - A dissolved oxygen limit is not required by North >Carolina policy, unless modeling shows need for the limit or their >compliance history requires it. >3. Metals - The cover letter mentions that several parameters were >listed as believed absent but there was no information to establish >limits. The footnote for the metals in the effluent page of the permit >says the parameters were listed as believed present therefore monitoring >was included to collect data. If some metals are believed absent why >would data collection be required, this facility is discharging non >process wastewater only and the application requirements do not require >testing for metals. For the ones that are believed present, as an >alternative, they could submit data during the notice period, then we >can determine if a limit is necessary. >Fact Sheet: >1. Current Stream Conditions - There is no other WLA in the file, the 1 of 2 7/16/2002 8:27 AM Re:Fieldcrest Cannon Permit NC0001643 • >1996 was the last one done. The Dan River is fully supporting at the >discharge location. >2. Compliance Summary - The compliance records for January 2000 through >December 2001 show two exceedances of Total Suspended Solids, 42.5 mg/I >and 34 mg/1 on March and April 2000. >Matt Matthews from the Aquatic Toxicology Unit is reviewing the toxicity >requirements, he may have further comments. If you have any questions, >you can call me at 919-733-5083, ext 595. >Teresa > Matt Matthews NC DENR/Division of Water Quality Aquatic Toxicology Unit 1621 Mail Service Center Raleigh, North Carolina 27699-1621 v-(919) 733-2136 f-(919) 733-9959 MailTo:Matt.Matthews@ncmail.net A few observations and much reasoning lead to error; many observations and a little reasoning to truth. --Alexis Carrel 2 of 2 7/16/2002 8:27 AM J�,�t£o sr, , UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4 gi% 1 ATLANTA FEDERAL CENTER ra 61 FORSYTH STREET ATLANTA,GEORGIA 30303 44 pRoIt-nVIA CERTIFIED MAIL May 20, 2002 Mr. Dave Goodrich, Supervisor NPDES Unit Division of Water Quality North Carolina Department of Environment and Natural Resources 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Dear Mr. Goodrich: We have received the North Carolina National Pollutant Discharge Elimination System (NPDES)permit file for Fieldcrest Cannon,Inc. in Cabarrus County,North Carolina to develop draft permit renewal limits. Enclosed in this permit file, along with the permit application, was a check, dated August 1, 2001, from the Pillowtex Management Services Corporation, in the amount of$250.00, to the North Carolina Department of Environment and Natural Resources. We are returning the check with this letter to you. Please contact me or Caroline Ejimofor, if you have any questions. Sincerely, oosevelt Childress, Chief NPDES and Biosolid Permits Section Permits, Grants &Technical Assistance Branch Water Management Division Enclosure FIELDCREST CANNON- NEW STREET WWTP NPDES PERMIT NO. NC0001643 EDEN,NC 36 Month Effluent Discharge Summary Parameter Daily Average Max Value Min Value Fequency of Number of Sample &Code Observed Obseved Analysis Analysis Type Flow(GPD) 0.040 0.193 0.010 Daily 780 C 50050 pH (units) N/A 7.4 6.8 Daily 780 G 00400 Temp. Cc) 16.8 28.0 1.0 Daily 780 G 00010 BODS(mg/i) 8.4 41.0 1.7 Weekly 156 C 00310 TSS(mg/I) 17.8 50.5 4.0 Weekly 156 C 00530 * Values are based on July 1998-June 2001 Effluent Discharge Reports pqwtec R A T / O N arrfAGELLPAIIILWAr 41010 CANNON CORPORATE ENGINEERING DEPARTMENT PO Box 1208 Kannapolis,NC 28082 cam- -: September 10, 2001 a E3, li: ^ a Lu NC Department of Environment and Natural Resources ' ii o Permits and Engineering Unit ' In cr oz. Division of Water Quality/NPDES Unit caD oa 1617 Mail Service Center Raleigh, NC 27699-1617 '= ``� RE: Fieldcrest Cannon, Inc. NPDES Permit No. NC0001643 Renewal Application Dear Sir or Madam: Please find enclosed the NPDES permit renewal application for Fieldcrest Cannon's New Street WWTP located in Eden, NC. Submitted with this letter are the following items, which are required for permit renewal: i 1. NPDES Application Form(in triplicate) 2. Permit Renewal Fee-$250.00 (Check#663128) 3. Plant Description (Present Operating Status &Potential Facility Changes) 4. Engineering Alternative Analysis 5. Sludge Management Plan 6. Schematic of Wastewater Flow 7. Location Map 8. Production Data A Priority Pollutant Analysis is forthcoming and will be submitted as soon as possible. If you have any questions or need additional information, please call me at 704-939-2654. Sincerely, 1 ).---to..a.... ti), e ,....,41,141.___ osh W. Chandler, P.E. Environmental Engineering Coordinator Attachments FIELDCREST CANNON, INC.—NEW STREET WWTP NPDES PERMIT NO. NC0001643 EDEN,NC Plant Description The New Street Wastewater Treatment Plant(WWTP) is an extended aeration activated sludge system comprising of an influent pump station, a 72" Bauer Hydrosieve lint removal screen, a concrete lined aeration basin, two circular secondary clarifiers, a sludge holding lagoon, and a post aeration basin. Approximately 0.04 MGD of wastewater is received for treatment from Fieldcrest Cannon's Decorative Bedding Plant and Warehouse. The wastewater is comprised entirely of non-contact cooling water, boiler blowdown, and domestic wastewater. Settled sludge from the secondary clarifier is pumped back to a diversion box,just prior to the aeration basin. Wasted sludge is pumped to a sludge holding lagoon for temporary storage. Treated wastewater is discharged continuously from this system to the Dan River at 36 deg., 30 min., 0 sec. Latitude and 79 deg., 42 min., 32 sec. Longitude. The WWTP was originally designed to treat wastewater from two existing Fieldcrest Cannon manufacturing plants plus the addition of another manufacturing operation that was to be constructed in the future. However, since that time, one of the two existing plants ceased manufacturing operations and was converted into a warehouse, and plans for the future addition were abandoned. As a result, the actual hydraulic and organic load to the WWTP is much less than what was originally designed. Due to the considerably high detention time of the system, sludge production is minimized, and a high quality effluent is produced. No potential facility upgrades/expansions/repairs are planned in the future. Only routine operation and maintenance activities are scheduled to occur. Plant Specifications: Hydraulic Design Capacity=0.5 MGD Aeration Basin Volume= 1,000,000 gal. Secondary Clarifier Volume(each) =68,000 gal. Sludge Holding Lagoon Volume=57,600 ft3 (2,133 yd3) FIELDCREST CANNON,INC. -NEW STREET WWTP NPDES PERMIT NO.NC0001643 EDEN,NC Sludge Plan The New Street Wastewater Treatment Plant(WWTP)is an extended aeration activated sludge system that inherently generates minimal amounts of sludge. Approximately 0.04 MGD of wastewater is received for treatment from Fieldcrest Cannon's Decorative Bedding Plant and Warehouse. The wastewater is comprised entirely of non-contact cooling water, boiler blowdown, and domestic wastewater. Settled sludge from the secondary clarifiers is pumped back to a diversion box,just prior to the aeration basin. When there is a need to waste sludge, wasted sludge is pumped to a 57,600 ft3 (2,133 yd3) holding lagoon for temporary storage. However, since the organic load entering the plant is very low, there is a rarely a need to waste sludge. Prior to 1995, the manufacturing process included a dying operation, which produced much more wastewater than is currently being generated. That was the last time that sludge was wasted to the holding lagoon. Currently, all settled sludge is returned to the aeration basin in order to optimize treatment efficiency. Schematic of Water Flow 45,000 GPD 5,000 GPD CITY WATER DECORATIVE BEDDING DECORATIVE BEDDING PLANT WAREH❑USE V❑N-C❑NTACT SANITARY SANITARY - BOILER - COOLING USE USE WATER 2,000 GPD 26,00C GPD 7,000 GPD EVAP❑RATION/STEAM EVAP❑RATION 8,000 GPD 2,000 GPD 35,000 GPD 5,000 GPD NEW STREET WWTP 30:16 f-f_fout. 1510 60-' c ,- DAN RIVER (❑❑1 OUTFALL) 40,000 GPD • FIELDCREST CANNON, INC. -NEW STREET WWTP NPDES PERMIT NO. NC0001643 EDEN,NC Engineering Alternatives Analysis The New Street Wastewater Treatment Plant(WWTP) treats wastewater generated by Fieldcrest Cannon, Inc.'s Decorative Bedding Plant and Decorative Bedding Warehouse. The system is an extended aeration activated sludge treatment system with a design flow of 0.5 MGD; however, the actual average flow to the WWTP is approximately 0.04 MGD. The wastewater is comprised entirely of non-contact cooling water, boiler blowdown, and domestic wastewater. The effluent discharges to the Dan River. There are two non-discharge alternatives that have been considered for this location. The first option is to land apply the treated effluent. The second is to discharge the pretreated effluent to the local POTW. Both of these methods will be discussed below. OPTION 1 -Land Application of Treated Effluent_ Based on the average effluent flow of 40,000 GPD, it is calculated that 10.3 acres of land is needed to accommodate this amount of flow for land application purposes (details are shown on calculation page 1). First of all, there are significant capital costs associated with the design and installation of a spray irrigation system for land applying the treated effluent. Installation of piping networks, pumps, monitoring wells, and tertiary filters will be required. The initial capital cost for this system is estimated to be$570,000 (see calculation page 2 for details). Because of the extensive capital cost incurred, this option is obviously not cost effective. Furthermore, there are additional operation and maintenance expenses associated with a land application system, as well as soil testing and permitting expenses. The reoccurring annual expenses are expected to equal approximately$20,000/year. Below is the present value analysis of the cost to install and operate a land application system versus the cost to continue discharging effluent to the Dan River(calculations are provided in the following pages). PV to land apply treated effluent=$682,562 PV to discharge effluent to Dan River=$56,285 From the figures above, it is evident that the cost to pursue a land application program is much higher as compared to the current mode of operation. Fieldcrest Cannon would retain its present operational and maintenance costs of the WWTP in addition to the extra costs associated with land applying the effluent. While land application is a feasible alternative, it is not economically justifiable. Engineering Alternative Analysis—New Street WWTP OPTION 2 -Local POTW Sewer Connection: The Fieldcrest Cannon Plant New Street WWTP is located outside of the city limits and is approximately 3000 LF from the nearest Eden City sewer main. The cost to design, construct, meter, and permit this sewer connection is estimated to be$275,000. Additionally, the costs associated with operating our WWTP will still be intact, since there will need to be some type of pretreatment and wastewater monitoring to eliminate surcharges. Also, the city sewage rates, as well as the annual administration fee,must be taken into account. According to the City of Eden, our sewage rate would equal$1.40 per 1000 gallons of wastewater. A letter from Mr. Steven Branz, P.E. specifying the applicable City sewage rate is attached for your review. This is in contrast to the$0.40 per 1000 gallons that it costs us to treat our own wastewater. A present value analysis of the cost to connect to the city sewer system versus that to continue the current mode of operation yields the following results: PV w connect to Porrw sewer system=$471,999 PV to discharge effluent to van River=$56,285 (Calculations for the present value analysis and a description of the sewer facilities required to connect to the city sewer system are provided on calculation pages 2 &3). From these results, it is apparent that connecting to the City's sewer system is not a reasonable option. Our current method of operation has proven to be the most equitable alternative. In summary, Fieldcrest Cannon would like to continue to operate its own WWTP. Our current system is efficiently operated and maintained, and it consistently complies with effluent standards. By utilizing our own resources, we can better control the treatment of our waste, and do so in the most economically feasible manner. 2 1 ENGINEERING ALTERNATIVE ANALYSIS CALCULATIONS Land Application Analysis: Criteria: 1) Effluent Design Flow Rate=40,000 gpd 2) Land Application Rate= 1 in/wk/acre (Per Scott Berg, Land Application Consultant for S&ME, Inc. in Greensboro, NC) 3) Soil Loading Rate is Based on the Typical Soil Classification for the Piedmont Area's Subsoils. Soils in this Particular Area Are in the Felsic Crystalline/Mixed Felsic and Mafic Regions. (clay, silty clay-low permeability) 4) Fieldcrest Cannon's Cost to Treat WW=$0.80/1000gal (Includes the Additional Operation and Maintenance of a Spray Irrigation System and Tertiary Filters in Addition to the Current WWTP's Costs, as well as Sampling of Groundwater Monitoring Wells and Annual Reporting of Analysis). Volume Of WW To Be Applied Per Acre: 1 in/wk/acre x 1 ft/12in=0.0.0833 ft/wk/acre 1 acre=43,560 ft2 0.833 ft/wk/acre x 43,560 ft2= 3630 ft3/wk/acre x 7.481 gal/ft3 = 27,156 Ral/wk/acre Area Needed To Accomodate A Flow Of 40,000 gpd: 40,000 gpd x 7 day/wk= 280,000 gal/wk 280,000 gal/wk = 10.3 acres 27,156 galwk/acre 2 Present Value Analysis Calculation Of Land Auolication of Treated Effluent: PV=Co+C(1/(1+r)) x (1-1/(1+r)11) (1-1/(1+r)) PV=Present Value of Cost Co =$570,000 (Start-up Costs for the Addition of a Spray Irrigation System and Tertiary Filters) C =Treatment Costs for a 20 Year Period w/Avg. Daily Flows of 40,000 gpd r =0.0825 n = 20 C=40,000 gal/day x$0.80/1000gal x 365 days/yr=$11,680/yr PV=$570,000+$11,680 x 1/1.0825 x 1-(1/(1.0825)20) =$682,562 1-(1/1.0825) PV = 082,562, Description of Requirements for Land Application of Treated Effluent: 1) Tree Removal/Soil Cut and Fill of Irrigation Area $150,000 2) Finish Grading of Irrigation Area $ 25,000 3) Approximately 100 Yards of Piping to Irrigation Area $ 5,000 4) Irrigation System to Cover 10.3 Acres $300,000 5) Pumps to Pump from WWTP to Irrigation Area $ 10,000 6) Installation of Monitoring Wells $ 10,000 7) Engineering Services $ 20,000 8) Tertiary filters for WWTP $ 50,000 $570,000 I 3 Present Value Analysis Calculation Of City Of Salisbury Sewer System Connection: Criteria: 1) Annual Average Effluent Flow=40,000 gpd 2) City of Eden's Cost to Treat WW=$1.40/1000 (Per Mr. Steve Branz, City Engineer) PV=Co+C(1/(1+r)) x.(1-1/(1+r)") (1-1/(1+r)) PV= Present Value of Cost Co =$275,000 (Start-up Costs) C = Sewer Rates for a 20 Year Period w/Average Daily Flows of 40,000 gpd r =0.0825 n = 20 C =40,000 gal/day x$1.40/1000gal x 365 days/yr=$20,440/yr PV=$275,000+$20,440 x 1/1.0825 x 141/(1.0825)20) =$471,999 1-(1/1.0825) PV = $471,999 Description Of Sewer Facilities Required: 1) New Pump Station 2) New Force Main, Valving, Pipe Fabrication 3) New Metering Equipment&Vault 4) Engineering&Construction Services 4 Present Value Analysis Calculation Of Current WWTP Operation: Criteria: 1) Annual Average Flow =40,000 gpd 2) Fieldcrest Cannon's Cost to Treat WW=$0.40/1000gal (Includes All Associated Costs Including Power, Labor, Chemical, Maintenance,and Regulatory Costs) PV=Co+C(1/(1+r)) x(1-1/(1+r)n) (1-1/(1+r)) PV=Present Value of Cost Co =$0 C = Sewer Rates for a 20 Year Period w/Avg. Daily Flows of 40,000 gpd r =0.0825 n =20 C =40,000 gal/day x$0.40/1000gal x 365 days/yr=$5,840/yr PV=$5,840 x 1/1.0825 x 141/(1.0825)20) =$56,285 1-(1/1.0825) PV = $56.285 1 G\�Y OF • 20 .t r CAR°� "p City of Eden Mr. Battle Moore Fieldcrest Cannon, Inc. PO Box 107 Kannapolis, NC 28082 RE: City Sewer Services Dear Mr. Moore: The city has a sewer main located approximately 3000' from your WWTP that your system could be tied into. Tying into this system would require a pump station and force main. The applicable sewage rate would be $1.40 per 1000 gallons of wastewater, with additional charges if color removal is necessary. The rate is 1.75 the normal city rate as your business is located outside of the city limits. Your estimate of$275,000 to tie your system into our system appears to be a reasonable estimate. If you require additional information please let me know. I may be reached at (910) 623-2110. Sincerely, even Branz, P.E. City Engineer 308 East Stadium Drive • Eden, NC 27288-3523 • (910) 623-2110 • Fax (910)623-4041 THE EFFORT ALWAYS MATTERS printed on recycled paper