WQ0005603_STFRPT_20200915

State of North Carolina
Department of Environmental Quality
Division of Water Resources

Water Quality Permitting
Regional Staff Report

FORM: APSRSR 04-10 Page 1 of 4
September 15, 2020

To: DWR Water Quality Permitting Section Central Office Application No.: WQ0005603
Attn: Poonam Giri Regional Login No.:

From: Mikal Willmer
Asheville Regional Office
I. GENERAL SITE VISIT INFORMATION
1. Was a site visit conducted? Yes or No
a. Date of site visit: 01/15/2020 (Inspection in LF).
b. Site visit conducted by: Mikal Willmer & Brett Laverty
c. Inspection report attached? Yes or No
d. Person contacted: and their contact information: John Moss, Facilities Engineering Manager (828)756-
4111 ext.3258
e. Driving directions: Hwy. 221 N. from Marion. Turn right on American Thread Road (SR 1556). Facility
is located approximately 1 mile on the right.
II. PROPOSED FACILITIES FOR NEW AND MODIFICATION APPLICATIONS
1. Facility Classification: (Please attach completed rating sheet to be attached to issued permit)
2. Are the new treatment facilities adequate for the type of waste and disposal system? Yes or No
If no, explain:
3. Are site conditions (soils, depth to water table, etc) consistent with the submitted reports? Yes No N/A
If no, please explain:
4. Do the plans and site map represent the actual site (property lines, wells, etc.)? Yes No N/A
If no, please explain:
5. Is the proposed residuals management plan adequate? Yes No N/A
If no, please explain:
6. Are the proposed application rates (e.g., hydraulic, nutrient) acceptable? Yes No N/A
If no, please explain:
7. Are there any setback conflicts for proposed treatment, storage and disposal sites? Yes or No
If yes, attach a map showing conflict areas.
8. Is the proposed or existing groundwater monitoring program adequate? Yes No N/A
If no, explain and recommend any changes to the groundwater monitoring program:
9. For residuals, will seasonal or other restrictions be required? Yes No N/A
If yes, attach list of sites with restrictions (Certification B)

DocuSign Envelope ID: 01908517-0ED9-46C3-89E6-D20FC6EFF35B
FORM: APSRSR 04-10 Page 2 of 4
III. EXISTING FACILITIES FOR MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? Yes No N/A
ORC: Certificate #: Backup ORC: Certificate #:
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? Yes or No N/A
If no, please explain: Coats converted to gas fired boilers in 2009 and no longer uses coal as a fuel source.
Ash has not been deposited in the basin since December 2009. The Notice of violation issued after the site
inspection in 2015 has been closed out and issues were addressed.
3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? Yes or No N/A
If no, please explain:
4. Has the site changed in any way that may affect the permit (e.g., drainage added, new wells inside the
compliance boundary, new development, etc.)? Yes or
If yes, please explain: In July 2015, Coats American was responsible for the accidental release of sodium
hydroxide, which resulted in a large fish kill in Limekiln Creek and the North Fork of the Catawba River. The
resulting site investigation identified approximately 640 cubic yards of coal ash or coal combustion residuals
(CCR) outside of the CCR basin. It was determined that a portion of the berm on the southeast side of
the basin had failed at some point in the past resulting in CCR migrating towards an unnamed
tributary bordering the site. The ARO issued a Notice of Violation to Coats American on December 29,
2015. Approximately, 643 cubic yards of CCR was removed from the flood plain and placed back in the
basin on June 8, 2016. Approximately, 712 cubic yards of clean fill were used to repair the berm.
5. Is the residuals management plan adequate? Yes or No N/A
If no, please explain:
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? Yes or No
If no, please explain: N/A
7. Is the existing groundwater monitoring program adequate? Yes No N/A
If no, explain and recommend any changes to the groundwater monitoring program: The earthen berms
surrounding the approximately 4.5-acre storage basin (basin) are constructed from coal ash or coal
combustion residuals (CCR). An unnamed tributary to Limekiln Creek is located on the south-side of the
CCR basin. The CCR berm on the south-side of the basin borders this unnamed tributary for
approximately 350 feet. There is a distinct possibility that CCR leachate may be discharging directly to the
unnamed tributary on the south-side of the basin. Because the near vertical berm extends directly into
surface waters, there is no opportunity to construct an appropriate groundwater monitoring well.
Therefore, the ARO is recommending an additional surface water monitoring site immediately
downstream of the CRR basin. There is no corresponding upstream or background location as the
manufacturing plant has eliminated all traces of the headwaters. The coordinates for this proposed surface
water sampling site is 35.789659, -82.023580. Surface water monitoring will coincide with the schedule and
parameters required for monitoring wells MW10, MW16, and MW17.
8. Are there any setback conflicts for existing treatment, storage and disposal sites? Yes or No
If yes, attach a map showing conflict areas.
9. Is the description of the facilities as written in the existing permit correct? Yes or No
If no, please explain: The facility has never constructed or operated a closed-loop wastewater recycle system
associated with the CCR Basin. Historically, the non-discharge permit has been used to monitor
groundwater surrounding the CCR basin. In 2015, the ARO and the Central Office (Ja Zimmerman)
discussed the appropriateness of the closed-loop recycle permit. A settlement agreement has been reached
regarding monitoring and preventative measures moving forward.
10. Were monitoring wells properly constructed and located? Yes No N/A
If no, please explain: New monitoring wells 16 & 17 were added and wells 2, 11R, 12, 13, 14 & 15 were
abandoned.
DocuSign Envelope ID: 01908517-0ED9-46C3-89E6-D20FC6EFF35B
FORM: APSRSR 04-10 Page 3 of 4
11. Are the monitoring well coordinates correct in BIMS? Yes No N/A
If no, please complete the following (expand table if necessary):
Monitoring Well Latitude Longitude

○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
12. Has a review of all self-monitoring data been conducted (e.g., NDMR, NDAR, GW)? Yes or No
Please summarize any findings resulting from this review: A review of the monitoring well data indicates
there have been no permit exceedances since the last permit renewal. The ARO hydrogeologist observed
the collection of groundwater samples and split samples with the permittee in April 2017 and December
2019.
13. Are there any permit changes needed in order to address ongoing BIMS violations? Yes or No
If yes, please explain:
14. Check all that apply:
No compliance issues Current enforcement action(s) Currently under JOC
Notice(s) of violation Currently under SOC Currently under moratorium
Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.)
15. Have all compliance dates/conditions in the existing permit been satisfied? Yes No N/A
If no, please explain:
16. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
Yes No N/A
If yes, please explain:
IV. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? Yes or No
If yes, please explain:
2. List any items that you would like Non-Discharge Central Office to obtain through an additional information
request:
Item Reason

3. List specific permit conditions recommended to be removed from the permit when issued:
Condition Reason

4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition Reason

See Section V Requirements outlined in settlement agreement dated August 3, 2020.
5. Recommendation: Hold, pending receipt and review of additional information by regional office
Hold, pending review of draft permit by regional office
DocuSign Envelope ID: 01908517-0ED9-46C3-89E6-D20FC6EFF35B
FORM: APSRSR 04-10 Page 4 of 4
Issue upon receipt of needed additional information
Issue
Deny (Please state reasons: )

6. Signature of report preparer:

Signature of WQS regional supervisor:

Date:
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
This facility consists of an inactive coal ash basin with groundwater monitoring. The ARO is recommending
the addition of a surface water sampling site in the UT on the southside of the ash basins.
Additional requirements are listed within the signed settlement agreement between Coats and NC DEQ DWR.
DocuSign Envelope ID: 01908517-0ED9-46C3-89E6-D20FC6EFF35B
9/15/2020