WQ0005603_CORR_20121008

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NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P. E. Dee Freeman
Governor Director Secretary
Aquifer Protection Section
July 31, 2012
Jerry Sisk, Engineering Director
Coats North America
Post Office Box 368
Marion, NC 28752
SUBJECT:Ash Storage Pond & Permit Status Update
Coats American—Sevier Plant
Wastewater Recycle System
Permit No.WQ0005603
McDowell County
Dear Mr.Sisk:
The intent of this letter is to provide clarification on several site-related topics recently
discussed with Mr. Mike Bell of your Toccoa, Georgia office. Having reviewed the site history and
groundwater monitoring data, we feel we are at a point to where we can outline a proposed path for
the coal ash basin and associated groundwater monitoring requirements.
Ash pond closure
At this time, closure in place of a coal ash pond is allowed in North Carolina. However, there
exists very limited guidance in place that prescribes a proper ash pond closure. Currently, there is a
DWQ technical workgroup devoted to this effort and drafting of the guidelines is underway. There are
also coal ash pond closures occurring at several electric utility companies in the state. Closure guidelines
are necessary to provide you with the items you need for a legal and environmentally safe closure.The
anticipated completion of these guidelines is within the year. Groundwater monitoring, deed
recordation, impoundment stability survey, etc. are parts of ash pond closure. We should be able to
provide you with more details within the year. The alternate option is to distribute the ashlunder a'
separate DWQ permit (Ash Distribution). Since the pond is no longer in operation, you need to
determine a closure path.
One
AQUIFER PROTECTION SECTION—Asheville Regional Office(ARO) NorthCarolina
2090 U.S.70 Highway,Swannanoa,NC 28778-8211 'aturaII
Phone:[phone] FAX:[phone]
Internet www.ncwateroualitv.orq
An Equal Opportunity l Affirmative Action Employer

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Non-discharge permit ti
Although the ash pond is no longer in operation, we recommend that you retain your current
non-discharge permit as it allows a buffer (i.e., compliance boundary) around the ash pond to monitor
groundwater; if the permit is rescinded prior to closure, there would be no compliance boundary,
groundwater standards would apply immediately adjacent to the ash.
Groundwater monitoring
As previously recognized, the groundwater monitoring network at the site has not given a clear
or accurate representation of the groundwater quality. Limiting well yields, turbidity, influence from the
dewatering system (i.e., French drain) and incorrectly placed wells have not allowed us to verify the
conditions of the groundwater at the site. Prior to rescinding the permit or moving toward ash pond
closure,the groundwater quality of the site must be thoroughly evaluated. DWQ staff from the Asheville
Regional Office will be responsible for evaluating groundwater quality and monitoring well performance
at the site.
DWQ sampling and evaluation
In an effort to address the previously mentioned groundwater assessment issues, DWQ would
like to perform the site evaluation work in late August 2012. This evaluation will consist of sampling
monitoring wells and the dewatering system, verifying locations of the monitoring wells in reference to
the review/compliance boundary and possibly determining the location of any future monitoring wells
needed for ash pond closure. All results of the sampling will be shared and recommendations made
following interpretation of the results. We will also evaluate whether monitoring wells can be removed
from the sampling schedule to reduce sampling costs. If additional monitoring wells are warranted and
based on the need or justification for the well, DWQ may install the well(s) at no cost to you.Any change
in groundwater monitoring will attempt to reduce monitoring to those wells and constituents that are
needed for the site's closure. Post-closure monitoring, as previously mentioned, is a typical requirement
when closing a wastewater unit in place.
Please contact me if you have any additional questions or concerns. I can be reached at(828)
296-4500 or at [e-mail].
Sincerely,
Brett Lavert'
Hydrogeologist
Aquifer Protection Section
Asheville Regional Office
Cc: Mike Bell,Director Environmental&Safety Engineering Coats North America

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P. E. Dee Freeman
Governor Director Secretary
Aquifer Protection Section
October 8, 2012
Jerry Sisk—Engineering Director
Coats American Inc.—Sevier Plant
P.O. Box 368
Marion;NC 28752
Subject: Well abandonment and permit modification
WQ0005603—Wastewater Recycle
Coats American Inc.—Sevier Plant
McDowell County
Dear Mr.Sisk,
On September 26, 2012, personnel from the Asheville Regional Office's Aquifer Protection Section
(APS) were at the Sevier Plant evaluating groundwater monitoring wells surrounding the coal ash basin.
During the site visit, staff noted extensive damage to monitoring well MW-11 (see attached map). The
cement pad and well casing now extend approximately a foot above the ground. It is apparent that the
cement grout has been compromised and the well bore may be acting as a conduit for surface runoff.
According to 15A NCAC 02C .0112 (a), every well shall be maintained by the owner in a condition
whereby it will conserve and protect the groundwater resources, and whereby it will not be a source or
channel of contamination or pollution to the water supply or any aquifer, or the well shall be
permanently abandoned in accordance with the requirements of 15A NCAC 02C.0113(d).
Monitoring well MW11 will need to be immediately and properly abandoned by a licensed driller
with a minimum level C certification. All casing and screen material will need to be removed. According
to 15A NCAC 02C .0113(d), monitoring wells greater than 20 feet in depth or that penetrate the water
table shall be abandoned by completely filling with a bentonite or cement type grout.
You will be required to work closely with the Asheville Regional Office to locate and construct a
replacement monitoring well. We are scrutinizing this portion of the site because an active French drain
is believed to be altering hydrologic conditions in the vicinity of monitoring wells MW-11 and MW-15.
AQUIFER PROTECTION SECTION—Asheville Regional Office(ARO) NorthCarohn a
2090 U.S.70 Highway,Swannanoa,NC 28778-8211 Phone:[phone] FAX:[phone] Naturally
lla't1/N�//Naturally
Internet www.ncwateroualiN.orq
An Equal Opportunity\Affirmative Action Employer

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Page 2 of 3
APS staff will need to be on site during well construction. Please be aware that we may require static
water level monitoring(up to 24 hours) and development within the transition zone bedrock. Our goal is
to ensure the replacement monitoring well is appropriately constructed given the unique site
conditions.
Once well abandonment and replacement are complete, you will need to submit a permit
modification to finalize the change. You can download the appropriate application from the following
website: http://portal.ncdenr.org/web/wq/aps/lau/applications. Once on the application website,
choose Closed Loop Recycle Systems and select form CLRS 08-11.
I would appreciate your prompt attention to this matter. Please contact me if you have any
additional questions or concerns. I can be reached at(828) 296-4500 or at [e-mail].
Sincerely,
/ , i
raalt----
Brett Lav-
Hydrogeologist
Aquifer Protection Section
Asheville Regional Office

Page 3 of 3
Attachment: Location of monitoring well MW-11.
TBM ON TOP OF l�„+' �eadwall
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CONCRETE REAM/ALL f \ 20
ELEV. = 1300.983 ;.e;<�` _,,,,A �'�PelDrive , - (
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MONITOR WELL B11 �`
TOP OF PIPE' ELEV. a 130921' ,""- ��+. A WWI --
CONCRETE BASED ELEV• = 1393.159' Fr ' ' T,ny
Conn . 6'O
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fl W _._. Wall.
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— ' Owe
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Q _ . a" N' , '(o`sc NEV MONITOR WELL NI5 ,z, Pod
r- , to TOP OF PIPE ELEV = 1381.91
`GPA led �° a J06-.0"a CONCRETE BASSI ELL.V. = 13ULfV
�•r 4�•ew
p� j / , ' Remammg property a
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Price, Bev
From: Price, Bev
Sent: Tuesday, October 15, 2013 3:35 PM
To: 'Mike BELL
Subject: RE: Ash Basin Closure Guidelines-Coats American Sevier Plant
Ok, thanks Mike.
Bev Price- [e-mail]
North Carolina Dept.of Environment and Natural Resources
Division of Water Resources
Water Quality Section
Asheville Regional Office
2090 U.S.70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax:[phone]
Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and
may be disclosed to third parties.
From: Mike BELL [mailto:[e-mail]]
Sent: Friday, October 11, 2013 4:16 PM
To: Price, Bev
Cc: Jerry Sisk
Subject: RE: Ash Basin Closure Guidelines -Coats American Sevier Plant
Bev,
Thanks for getting back to us so quickly. This is helpful,albeit not as certain as we would like.
Jerry and I will huddle up with the relevant Coats management team and discuss what next for us.
Mike
From: Price, Bev[mailto:[e-mail]]
Sent: Friday,October 11,2013 3:40 PM
To: Mike BELL
Cc:Jerry Sisk
Subject: RE:Ash Basin Closure Guidelines-Coats American Sevier Plant
Mike,
We addressed each of your questions below; responses are in blue. I know this is still not what you are looking for but
unfortunately,at the present time this is all we have. Please call me if you want to discuss further.
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Bev
Bev Price- [e-mail]
North Carolina Dept.of Environment and Natural Resources
Division of Water Resources
Water Quality Section
Asheville Regional Office
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax:[phone]
Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and
may be disclosed to third parties.
From: Mike BELL [mailto:Mike.BELL(Tcoats.com]
Sent: Wednesday, October 09, 2013 12:04 PM
To: Price, Bev
Cc: Jerry Sisk
Subject: Ash Basin Closure Guidelines - Coats American Sevier Plant
Bev,
In follow-up to our phone conversation this morning regarding your inspection report letter of September 30 and the
December 4, 2012 Draft Guidelines for Closure of Ash Ponds, we have a couple of questions regarding this information:
1. You state that, "the ash basin may be closed out as the facility is no longer using a coal fired boiler." Could you
be more definitive about the requirement to close this basin? It is difficult to get funding for such a large project
from our UK parent company if the requirement is not certain.
DWR is not currently requiring the closure of the subject ash pond. However, in its current state or condition,
the ash pond may represent a potential threat to groundwater. If groundwater impacts are observed at any
point in the future resulting from the ash basin, removal or control of the primary source would be a
requirement along with additional secondary source treatment and soil/groundwater assessment.The current
intent of the DWR is to provide you with information you can use to begin evaluation of options for the ash
pond that include not only closure in-place but also distribution of coal ash under NCAC 2T.1200.
2. On the guidelines,we note they are draft guidelines. Considering the complexity and high cost implications of
these guidelines, we would be reluctant to proceed with engaging an engineering firm to develop plans or even
give us cost estimates when the guidelines have not been finalized. How certain is DENR these will be the final
guidelines? At what point in the issuing of these guidelines is DENR and when will they be finalized?
We are currently uncertain as to the finalization of the draft closure guidelines.As you may know, EPA is
currently reviewing coal ash regulations that may or may not apply to this particular site. EPA's decision on the
regulation of coal ash could have an impact on the continued development of these guidelines. Currently, some
coal ash ponds in N.C. are being closed using these draft guidelines.
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Thanks,
Mike
Mike Bell
Director Environmental &Safety Engineering
Coats North America
T: [phone] Ext. 2248
M: [phone]
[e-mail]
374 Coats Drive, Toccoa, GA, 30577 USA
www.coats.com
The information contained in this communication(including any attachments transmitted with it) is confidential
and may be privileged and the views, conclusions and other information expressed herein are not necessarily the
views of or endorsed by Coats plc unless such information is transmitted in the normal course of its business. It
is for the exclusive use of the intended recipient(s). If you have received this message in error and you are not
the intended recipient(s),please notify us by email ([e-mail]) or telephone our technical
support helpdesk at Coats plc. [phone] (available 24 hours a day, 7 days a week) and then delete the
email and any copies of it including any attachments thereto. Any distribution, copying or use of this
communication or the information contained herein if received in error is strictly prohibited. Coats plc will not
be liable for direct, special, indirect or consequential damages arising from the alteration of the contents of this
message by a third party or as a result of any virus being passed on. All reference to "Coats plc" includes all of
its subsidiaries and associated companies. Coats plc is registered in England and Wales under company
registration number 04620973 having its registered office at 1 The Square, Stockley Park, Uxbridge UB11 ITD
The information contained in this communication (including any attachments transmitted with it) is confidential
and may be privileged and the views, conclusions and other information expressed herein are not necessarily the
views of or endorsed by Coats plc unless such information is transmitted in the normal course of its business. It
is for the exclusive use of the intended recipient(s). If you have received this message in error and you are not
the intended recipient(s),please notify us by email (Apps.Supporu2i coats.com) or telephone our technical
support helpdesk at Coats plc. [phone] (available 24 hours a day, 7 days a week) and then delete the
email and any copies of it including any attachments thereto. Any distribution, copying or use of this
communication or the information contained herein if received in error is strictly prohibited. Coats plc will not
be liable for direct, special, indirect or consequential damages arising from the alteration of the contents of this
message by a third party or as a result of any virus being passed on. All reference to "Coats plc" includes all of
its subsidiaries and associated companies. Coats plc is registered in England and Wales under company
registration number 04620973 having its registered office at 1 The Square, Stockley Park, Uxbridge UB11 ITD
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