WQ0005603_Staff Report_19910918

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State of North Carolina
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Department of Environment, Health and Natural Resources
Division of Environmental Management
512 North Salisbury Street•Raleigh,North Carolina 27611
James G. Martin, Governor George T.Everett,Ph.D '
William W. Cobey,Jr.,Secretary �tCC-�teL
September 18, 1991 titer Qust'i S°cttvr•
MR JERRY SISK SEP Z �gg1
COATS AMERICAN
HWY. 221 NORTH
MARION, NORTH CAROLINA 28752 Ue ReRwnal 0
Subject: Applica[R1Q �03
Sevier Plt tt
Ash
McDowell County
Dear MR SISK:
The Division's Permits and Engineering Unit acknowledges receipt of your permit application and
supporting materials on September 17, 1991. This application has been assigned the number shown
above. Please refer to this number when making inquiries on this project.
Your project has been assigned to John Seymour for a detailed engineering review. A technical
acknowledgement will be forthcoming. If this acknowledgement is not received within thirty (30)
days,please contact the engineer listed above.
Be aware that the Division's regional office,copied below, must provide recommendations from the
Regional Supervisor or a Procedure Four Evaluation for this project,prior to final action by the
Division.
If you have any questions,please contact John Seymour at [phone].
Sincerely,
C CQJ
Donald
Supervisor,Permits and Engineering Unit
cc: Asheville Regional Office
_ Pollution Prevention Pays
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
-- - An Equal Opportunity Affirmative Action Employer -

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' DIVISION OF ENVIRONMENTAL MANAGEMENT
GROUNDWATER SECTION
MEMORANDUM
TO: t a-n Lr rt\L
DATE: ` p-1- 2. , 199
FROM: Jack Floyd,.e,
SUBJECTS Application for be/Renewal/Amendment of Permit No. ) Lay.¢)
Ne`w hermit
Facility Name Conk Arnne.Cicct s
County IYI e pou.. d(
Type of Project: A-s\ erInCOSIP lacl't n
Central Office Contact: /Br;an lid oo ert
Applicable Permit Numbers: WQ 000S& 03 GW 9/ a91
EPA AC
We have received a copy of the above referenced application,
wl4ch w s sent to your regional office for comment on or- about
- -2jt1 r2- , 1 9 9/
You should review the application package for completeness
and adequacy of relevant information and submit your request for
ad.yitional informatio,p� to me (via telephone or memo) by
c-JC7t 9, , 1 g1/so that all required information ' can be
requested from the applicant at one time. A copy of our formal
request to the applicant for additional information. will be
provided to you.
If you do . not require additional information from the
applicant to complete your evaluation of the project, you should
relaew the applicationi package and submit your comments to me by
e
If a copy of the application package has not been made
available to your office, PLEASE LET ME KNOW IMMEDIATELY so that.
a copy can be forwarded to you as soon as possible .
JF: ja/Appl . shl
@. ff .2NOWN
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SEP 3 01991
- Groundwater Section
Asheville Re:'onal Office

DI IISII2' OF ENVIRONMENTAL MAIN! MENT
/ Groundwater Section
/
MEMORANDUM D t5 d
Date: cc,/ 3°/ /947/ MI D
T� OCT I - 1991 11,
To: /G,4/a 5jtc f r/7ONr
Review Engineer AGrofflRoInc e
Permits & Engineering Unit
From: q I) fc%074, /or)
Groundwater9 Section
Subject:. Coo s �fl r,Cgn ({,•/„F rly /')par/'/Con l/;rrgl>
Request for Additional Information
WQ000 5(03 / Gw 9 /02 7/
file Do ide /1 County
The Groundwater Section has conducted a preliminary review of the subject application
and request that the following items, as indicated in the list of additional information items
dated July 15, 1990 to be included in the request for additional information to the applicant
tin)) Item 7 Item 13 Item 18
Item 2 Item 8 Item 14 Item 19
Item 3 Item 9 Item 15 Item 20
Item 4 Item 10 Item 16 Item 21
Item 5 Item 11 Item 17 Item 23
Item 6 Item 12
Other Items (See attachment)
For Item 22 till in blanks:
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If you have any questions, please advise.
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NOTE: See Reverse For Additional Information Items.
cc: tan Link Regional Groundwater Supervisor
White Copy - Water Quality Section Yellow Copy-Groundwater Section Pink Copy - Regional Office

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List of Additional Information Items
Groundwater Section
July 15. 1991
loon 1. A general baton map ahowmg orientation of the facility with reference to at/east two (2) geographic references (numbered tads, and stmrrs/rwasrmj.
lean 2 A Ste-spec&imp,with topographic commas(contour tetanal should not exceed 10 feed or 25 potent of total ate relict whichever is lost showing all tatty - related shucnrns within the
property boundary and the kmumn of all welly apemgs dales ponda or other sofa a drainage features widen 500 feet of the was=treatment/disposal altr ,wells should be landed as to
thdr Finney usage (drinking ester,process water. mongering, etc.)
teen 3. A soil ealtaion of the application site by a soils scientist, to very the accuracy of the SCS ants imp regandng the presence or absence of a eamta➢y high water table or bedrock within
three venal fist of the deepest point of sludge application, and en detmtnne the eaten exchange capacity of the St
Inn 4. A soil evaluation of the disposal Ste by a mils sdamst down to a depth of seen Gm or the home,whichever Is lei, to develop a soil reap through field evaluation of®➢ Munro color.
the depth, thiclmess and type of restrictive hbmon;s, the preen or absence of a seasonal high water table or bedrock within them vertical feet of the deepest point of Nudge appliatbR
and cation exchange capacity
loon S A soil evalvatbn of the dapoal Ste conducted by a sees scientist to adequately eraluam the sees to be ullitrd ler treatment and disposal down to a depth of seen feet to include field
descriptions of texture. color, structurestructure, the dephh, thickness and type of reactive horizons, the presence or absence and depth of evidence of any ncasenal high water table end
retmrmmdatmu concerning application ate of the waste conatuenta The tmvngadon should aim include field esmata or maarcmenm of saturated hydraulic condtatrvey to the
nest rarMive horizon. and cation exchange capacity. Fkavaeon of test pits may be necessary for proper evaluation of the tots at the ate)
hen S Proposed baton and mnainxtbn darns of a gcmmdwahr monitoring well network as specified in Rule .0205(d) of the Regulations (15 NCAC 2H. 0200)
Ions 7. As pre the conditions of your curet permit you was marled to install gmadwata innNmrtng wells These welts woe to be moped end analyzed according to a schedule al for those
parameters as specified In the carat A®sib of our records Indicates that, as of the date of the letter, no gmtmdwata monitoring data,have bet received. Please submit all rmrle of
groundwater sampling and analysts which have been obtained to data If m..=„.Ming and/or analyse have been conducted you are requested to ample the wells and report the rests of
the an alyss as specified in the current Fart
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Imo& Information as to the presence or absence of any webs bated within 500 feet of the state trabrvnt/desp®l tacitly.Any such wells should be accurately located on the site map. ad
labeled as to thar primary urge Its, drinking water, monitoring, etc.).
Item 9. A lrydnogeobgle dmaiptien of the subsurface. to a depth of 20 feet or bedrock,whither is lea The number of borings shall be sufficient to define the following for the area underlying ach
major me ype at the dtepoal site
(0 significant changes In ethology underlying the eta
(re the vicenal permeability of the snranuatd zone and the hydraulic conductivity of the saturated zone; and
➢l) depth to the mean seasonal high water table(If delable horn soil eserhobgy or horn evaluation of other appbcable eatable data)
loon IG A hydrogeolog:e description of the suhsurfatq to a depth of 20 feet or bedrock,whlehcwr is less.The number of borings shall be sul➢aent to define the following for the am underlying ach
toner soil type at the disposal Ste
(0 significant change; m hthobgy underlying the Ste;
4 the vertical permeability of the unsaturated zone and the hydraulic conduct toy of the saturated zone
14 depth to the man seasonal high water table ➢f definable from soil mrptmbgy or from eeluanon of other applicable available dash and
(n° a determination of tninwnae<viry and epect➢c yield of the unconfined aquifer based on o withdrawal or recharge test
lten 11. A hydmgabec description of the subsurface. which should include tnfmramn on the veinal and horizontal mica and the&hobgte character of the unmated aquifer.The hydraulic
relationship between the unconfined aquifer and the Bet confined seder beneath the site should be demeaned. Including the thickness lithobgie character, and vertical pantvhtkty of
the confining bed. The infonafbn must also include a determination of the tnareatdatvity and speak yield of the unconfined aquifer, detrnmnd by ether a withdrawal or recharge test.
ita,, 12 A hydrologic evaluation to the area of the Imposed waste disposal facility paste disposal facility,which should include the depth to water, demon of mvanrnt and quality of gmurdweter
in the shallow gnrtdeaier system, es well as an ealuatbn of the potential impacts the proposed system nay have on gmmmdwater le ls. movement and quality.
Item la In order to Le in compliance with 15 NCAC 2H.0219(➢,any lagoon or pond used for torment etnmge or dafael of waste shall have either a liner of natural materiel at least one foot in
thickness and having a hydraulic conductivity of no grates than I x 10 s centmlas per second when compacted.or a synthenc liner of sufficient thkle ness to exhibit II structural
mtegrty, and 2) an effective hydraulic conductivity no greater than that of the natural nomad hoer. Pleas poste a detail description of the ratable used for liners
Item 11 15 NCAC 2H .0219 (e)specifies that waste shall not be appeal or dlehargel one,or below the and surface when the tatted separation between the waste and the seasonal high water table
is less than QM ill ZXIL If any of the aim to be exulted has a separation of less than THREE 131 THREE a demonstration must be nab ashy,predictive calculations or modeling methds,
acceptables placement
to the Director, that such placent will not n In contravention It contravention of classified groundwater standards. Rase provide information denoting the depth to resin sasonal
htgilwater table and supportive information for sites with depths lam than totEE l9 FEET emanation.
Item 15. A recent complete chemical analysis of the typed waste to be di charged. which should include the following parameters
flat parameters)
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Item IS is the vase which is to be discharged mmpraed solely of domestic waste or are there other sources which wI l contribute to the wastewsiee?If so, prase provide infomatbn as to the
type(s) of emote mwbd,as well as the anticipated quantity.
loon 17. Boring logs and well construction deaths for all Basting nantrolrig wells Such Inbnatbn should include ground surface elevations at each veil location and state water level measure-
ments.
Item 19. Please troth that In order to be in compliance with 15 NCAC 211.0219(d), the bottom of .When impoundments,trenches or other sinter excavations shall be at least four fat above the
bedrock surface.If the bottom of the atataton is less than four feet above the bedrock surface, a Liner of natural or synthetic material having a hydraulic conductivity no grater than I x
10-7 centimeters per second will he required. Pose pestle information con&nang compliance with this rarytmrent
Item la The information submiteedd indicates that hand auger mraq¢were advanced at the Ste_ Mesa Indicate the locations of these borings on a site Mae In addition,you are requested to submit
complete Bthologlc descriptions of the borings along with any At.,we which nay Indicate the presence or absence of a seasonal high water table
Item 20. From the aids nape which woe subrmm. it is difficult In some mom to positively identify what soil type(s) are bard on various Sea= You are requested to submit eevlsed maps which
clearly show the distribution of the various will types on each.proposed land application site,
kern 21. A rocmmetiaton of groundwater quality in the vicinity of the lagoons This characterization should be acconpished by the Installation of monitoring wells fondle purpose of dacrtoing the
ltmobgy to the area, and for co➢eedng gtamdwater quality samples from the war table aquifer. The batons for these walls are shown on the enclaal nap The well construction details
and sampling methods should be by approval of the Regional office. from which a wee construction permit Rout be obtained.
Groundwater angels shall to obtained from each nnnitortng well and analyzed for the fallowing paarnetes
Rat partners)
The nessnereirt of water km/ should be taken prior to sampling for the other paarretas
tlthobgic bye, well construction details and the enalytk-al results of the sampling shoal be submittal in the Groundwater Section. Division of Envtronnuntal Management.
hen 22 In Oder to be in compllmwe with 15 NCAC T11 .0219 I.f)(51 W)(—),)a�buffer zone of at least ..._fat post be maintained between the painter of the disposal field and any popery thundery.
It is noted fen the submitted phua that pardons of the proposed earthly Ile within_feet of the property boundary. ?Sam submit revisal plans which demonstrate compliance mitt buffer
see requirements.

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DIVISION OF ENVIRONMENTAL MANAGEMENT
ASHEVILLE REGIONAL OFFICE
GROUNDWATER SECTION
October 10, 1991
MEMORANDUM
TO: Brian Wootton
Raleigh Central Office
FROM: Fred C. Hankinson ge
Asheville Regional Office I
SUBJECT: Coats American
Ash Storage Lagoon
Permit No. 14441
WQ0005603, GW91271
The analytical results from groundwater testing of
monitor wells exceeds the State 2L Standards for Chlorides,
COD, dissolved solids, TOX, and VOA' s .
Additional monitor wells must be placed at the review
boundary north of the ash storage lagoon. These wells must be
located at the property boundary because the regulations
require 500 feet from the waste boundary or at the property
boundary, whichever is closer to the source. Also, a monitor
well is recommended to be placed 500 feet east of the
treatment area toward the North Fork Catawba River. These
wells are to be analyzed for purgeable organics to lowest
level of detention limits in addition to normal permit
requirements .
Four ( 4) wells should be sufficient at this time.
Additional wells may be necessary to define the extent of
contaminants.
Isocon maps should be prepared to depict the extent of
each contaminant.
FCH/gc

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DIVISIORNOELENANWORMENTAL MANAGEMENT
GROUNDWATER SECTION
October 23, 1991 -
MEMORANDUM U D
OCT 2 51991 .,
TO: Don Safrit
///J //� Groundwater Section
THROUGH: Bob Cheely�� 4,,QQ 49 i ` — AshevilleRfcaOffice
FROM: Brian Wootton fJ
SUBJECT: Coats American, Inc.
Sludge Land Application
Renewal Permit Application
McDowell County
WQ0005603/GW91271
(John Seymour: DEM Review Engineer)
The Groundwater Section has reviewed the subject permit
renewal request. The facility consist of a unlined 2 .8 acre Ash
Sluice Lagoon that is designed to treat 244, 800 GPD recycled
water containing ash from the coal fire burners and wastewater
from the stack scrubbers.
Two (2) existing monitoring wells are located near the ash
sluice lagoon (monitoring well #2, @ 80 feet south of the lagoon;
monitoring well #3, @ 200 feet north of the lagoon) . The
existing upgradient monitor well #1 is approximately 700 feet
south of the lagoon.
The analytical results from groundwater testing of monitor
wells #2 and #3 have exceeded the state 2L Standards for
Chlorides, COD, Total Dissolved Solids, and TOX.
To determine the extent of the contaminate plume, additional
monitoring wells are being recommended between the Review
Boundary and Compliance Boundary delineated on the attached site
map. Contingent upon the analytical results from these wells,
the permittee may be required to institute a groundwater
remediation program.
1 . Within 180 days of permit issuance, the permittee
shall demonstrate through predictive calculations or
modeling that the contaminant plume will not intersect
the Compliance Boundary. If this fact cannot be
proven, then additional treatment may be proposed as
well as remediation of the affected Groundwater.
2 . Within 90 days of permit issuance, two (2)

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downgradient monitor wells shall be installed between
the Review Boundary and Compliance Boundary delineated
on the attached site map, to monitor groundwater
quality. The wells shall be constructed such that the
water level in the well is never above - or below the
screened (open) portion of the well at any time during
the year. However, the exact location and construction
details for these wells shall be approved by the
Asheville Regional Office, from which a well
construction permit must be obtained.
3 . The two (2) new monitor wells shall be sampled
initially after construction and all wells shall be
sampled every April, August and December for the
following parameters :
COD Orthophosphate
Selenium SO4
Calcium Magnesium
TDS TOC
pH Water Level
Chloride Fecal Coliforms
Total Suspended Solids
Volatile Organic Compounds - In December Only (by
method 1 or 2 below)
Method 1 : Method 6230D (Capillary - Column) , "Standard
Methods For The Examination of Water and
Wastewater", 17th ed. , 1989
Method 2 : Method 502 . 2 "Methods For The Determination
Of Organic Compounds In Drinking Water", U.S .
EPA - 600/4-88/039
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The measurement of water level must be made prior to
sampling for the remaining parameters .
The measuring points (top of well casing) of all
monitoring wells shall be surveyed to provide relative
elevations of the measuring point for each of the
• monitoring wells. The depth of water in each well
shall be measured from the surveyed point on the top of
the casing.
If TOC concentrations greater than 10 mg/1 are detected
in any downgradient monitoring well, additional

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sampling and analysis must be conducted to identify the
individual constituents comprising this TOC
concentration. If the TOC concentration as measured in
the background monitor well exceeds 10 mg/1, this
concentration . will be taken to represent -the naturally
occurring TOC concentration. Any exceedances of this
naturally occurring TOC concentration in the
downgradient wells shall be subject to the additional
sampling and analysis as described above.
If any volatile organic compounds are detected by
method 6230D, or the equivalent method 502.. 2, then EPA
methods 604 and 611 must also be run to detect other
organic compounds which may be present. The results of
all analyses specified in the monitoring requirements,
including 604 and 611 if required, must be submitted
simultaneously.
The results of the sampling and analysis shall be sent
to the N.C. Division of Environmental Management on
Form GW-59 [Compliance Monitoring Report Form] every
May, September and January.
4. The Compliance Boundary delineated on the attached site
map for the disposal system is specified by regulations
in 15 NCAC 2L, Groundwater Classifications and
Standards . An exceedance of Groundwater Quality
Standards beyond the Compliance Boundary is subject to
the penalty provisions applicable under General Statute
143-215 . 6( 1 )a. The sale of property, by the Permittee,
which is within or contiguous to the disposal site, may
alter the location of the Compliance Boundary.
For facilities permitted on or after December 30, 1983,
the Compliance Boundary is established at the lesser of
250 feet from the perimeter of the waste disposal area,
or 50 feet within the property boundary.
If the title to any property which may affect the
location of the Compliance Boundary is changed, the
Permittee shall notify the DEM Director within 14 days .
The Director shall then establish a modified Compliance
Boundary which will be done as a modification to the
Permit.
The REVIEW BOUNDARY delineated on the attached site map
for the disposal system is specified by regulations in
15 NCAC 2L, Groundwater Classifications and Standards .
A REVIEW BOUNDARY is established around disposal
systems midway between the Compliance Boundary and the
perimeter of the waste disposal area. When the
concentration of any substance equals or exceeds the
maximum allowable concentration of that substance at
the REVIEW BOUNDARY, as determined by monitoring, the

permittee shall either (i) demonstrate, through
predictive calculations or modeling, that natural site
conditions, facility design and operational controls
will prevent a violation of standards at the Compliance
Boundary; or, (ii) submit a plan for the _alteration of
existing site conditions, facility design or
operational controls that will prevent a violation of
standards at the Compliance Boundary, and implement
that plan upon its approval by the Director.
5 . Any additional groundwater quality monitoring as deemed
necessary by the Division, shall be provided.
RBC/BW/sbp/91271 .
cc: 4Don Link f
Central Files
Permit Issuance Files

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