WQ0005603_Site Assessment Acknowledgement_20100122

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NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water quality
Beverly Eaves Perdue Coleen H.Sullins Dee Freeman
• Governor Director Secretary
Aquifer Protection Section
January 22, 2009
•
Jerry Sisk, Facilities Engineer
Coats American Inc.
P.O. Box 368
Marion,NC 28752
Subject: Response to Nov-2009-LV-3069 and Phase 1 Site
Assessment Report for Coats American Sevier Plant
• Permit No. WQ0005603
Wastewater Recycle System (Ash Basin)
McDowell County
Dear Mr. Sisk,
The Asheville Regional Office (ARO) acknowledges the submittal of a site assessment
report from ERM NC concerning a Notice of Violation (Nov-2009-LV-3069) issued on August 25,
2009. The NOV was issued in response to violations of 15A NCAC 2L (Groundwater Quality
Standards) at four monitoring wells (MW-10, MW-11, MW-12, and MW-14) located outside of
the review boundary for the Coats American -Sevier Plant coal ash basin.
A limited site assessment of select monitoring wells was required to determine the
nature of the water quality violations. Analysis of the coal ash material was also required to
ascertain any additional toxicity characteristics. A work plan was submitted on September 29,
2009 and a final report issued on December 9, 2009. A post project meeting was held at the
Division of Water Quality's Asheville Regional Office on December 11, 2009.
Analysis of a composite sample of coal ash indicates the presence of several metals and
anions of interest including arsenic, chloride, iron, manganese, mercury, nitrite, and sulfate. Iron
and mercury were the only parameters to exceed Protection of Groundwater Soil Remediation
Goals established by the NCDENR Inactive Hazardous Sites Branch (IHSB). The ERM NC
report contends that concentrations for arsenic, iron, manganese, mercury and chloride are
within the typical ranges for natural soils and are not expected to impact groundwater above
background levels. Naturally occurring levels of sulfate and nitrite in soils are not available and
are likely indicators of impact by coal ash operations if detected in groundwater at elevated
N°ehCauotina
Natural'
North Carolina Division of Water Quality—Asheville Regional Office 2090 U.S.Highway 70 Swannanoa,NC 23778 Phone[phone]
Aquifer Protection Section FAX [phone]
Customer Service 1-877.623-6748
Internet h2o.enr.statenc.us

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Coats American
January 22, 2010
Page 2 of 3
concentrations. Results from the TCLP test indicate the coal ash does not exhibit the toxicity
characteristics of hazardous wastes.
Groundwater quality results show elevated iron and manganese concentrations above
15A NCAC 2L (Groundwater Quality Standards) at all four monitoring wells. Metal
concentrations were lowest in the background well (MW-2) and highest in the furthest down
gradient well (MW-12). Chloride, sulfate, barium, boron, copper, nickel, and zinc were also
present at one or more wells but none exceeded groundwater quality standards. Arsenic,
mercury, lead, and nitrite were not detected above practical quantitation limits. The ERM NC
report concludes that elevated iron and manganese concentrations are attributable to natural
conditions based on the levels-detected in the background well (MW-2).
After a review of the ERM NC Phase 1 Site Assessment Report, the Division feels that
continued assessment and review of the groundwater quality data for iron and manganese is
necessary. Listed below are comments and supporting data for your review:
• Results from the analysis of the coal ash indicate a leaching potential for iron and
possibly manganese based upon the NCDENR IHSB Protection of Groundwater Soil
Remediation Goals.
• Analytical results for the background well (MW-2) may not be representative of natural
background groundwater conditions given the difference in construction of this well
(transition zone) compared to down gradient monitoring wells (saprolite). Matrix
interference (suspended sediment) at this well resulted in abnormally high levels of
metals and anions during sampling (October 2009). Until this issue can be fully
evaluated, data collected from the background well (MW-2) should be considered
suspect.
• A review of groundwater data available for McDowell and surrounding counties was
conducted by the North Carolina Department of Water Resources (1). According to the
report, 85% of all groundwater wells sampled contained less than 0.3 mg/1 of iron.
Similarly, 81% of all samples analyzed for manganese had a concentration less than 0.2
mg/I. Most of this data was obtained from drilled bedrock water supply wells of varying
age.
• The North Carolina State Laboratory for Public Health website (2) provided additional
groundwater quality data for McDowell County. Approximately half of the 449 water
supply wells analyzed for iron fell below a detection limit of 0.1 mg/I. The median iron
concentration in the remaining wells is 0.27 mg/I. Of the 447 water supply wells analyzed
for manganese, approximately 76% fell below a detection limit of 0.03 mg/I. The median
manganese concentration in the remaining wells is 0.07 mg/I.
(1) Sumsion, C.T. and Laney, R:L., 1967, Geology and Ground-water Resources of the Morganton
Area, North Carolina, Groundwater Bulletin 12: North Carolina Department of Water Resources,
140 p.
(2) North Carolina State Laboratory Public Health Environmental Sciences-
http://204.211.171.13/EnvironmentalSciences/inorganic/frmMainSearch.aspx

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• Cots American
January 22, 2010
Page 3 of 3
The Division is requiring the following additional assessment activities:
• Evaluate sampling methods used by Coats American personnel to conduct ground water
monitoring. The main focus should be on determining whether suspended sediments are
causing elevated metal and anion concentrations. Determine a corrective strategy to
address identified issues (e.g., removal of pumps, low purge sampling, corresponding
filtered samples, additional training, replacement wells, etc.).
• ARO will be submitting a permit modification for the addition of iron as a monitoring
parameter. The Division's Central Office will notify you when this modification becomes
final.
• ARO personnel will be on hand in April 2010 to collect or split groundwater samples with
Coats American personnel. Please notify the APS staff a week in advance to the next
• monitoring event.
• ARO requests information on the emergency pond located north of coal ash pond.
Specifically, we would like to know whether coal ash has ever been disposed of at this
locale or, if applicable, how much material is being stored in the pond presently.
• An updated site map was submitted on June 28, 2009. We request that a legend be
added to this map and resubmit to the Asheville Regional Office.
The Division appreciates your attention and prompt response in this matter. If you have
• questions, please do not hesitate to contact me at [phone] or [e-mail].
Sincerely,
Brett Laverty
Hydrogeologist
Cc: ERM NC