WQ0005603_Regional Office Physical File Scan Up To 11/29/2022

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PERMIT # Uj ® 000" 03 1
FACILITY C c S hM& �t eVV\ i� �M � d ,.fx� Se v I (,v' Fj 4A
COUNTY�bt-j � � ( CLASS
FACILITY ADDRESS 6 3O Amerb CCc h I Nrea4d R oOJ
P,®. SoX, ' Mav on NC, 2-F752
FACILITY
DIRECTIONS: 41,E u . 22 / N :�cm fnarl an . Tyr► ri 0 4 hh 'America-n
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OWNER / PHONF„ ` 1- _ • " n e Yhnre r -=rt�
& ADDRESS
RESPONSIRT,F . �vr, iS
OFFICIAL
FACILITY
REPRESENTATIVE a�� Pk�1� n Pi'44rnan
Phone Fax
Cell
OPERATOR ,VWTV
Phone
Cell
: % GRADE
BACK-UP OPERATOR GRADE
Phone
Cell
,ju„e all 9ar6
PERMIT ISSUED o OTHER PERMIT #
EXPIRATION'DATE 5/51 fao DATE ISSUED
RENEWAL DATE a V3o/,q
STREAM Name j 04k 5, V- of 4L,.P- 6.ocwkg Class
7010
Basin & Sub -basin

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Healthi,y and, Natural Resources

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.11 wells
shalhbe sampled every April, August, and December for the following parameters:
COD IDS
TOC pH
Selenium Chloride
Water Level Total Suspended Solids "
SO4 Magnesium
Calcium
Volatile Organic Compounds.- In December only (by Method 1 or Method 2 below)
Method 1: Method 6230D ( Capillary - Column), "Standard Methods for the
Examination of Water and Wastewater", 17th edition, 1989
-Method 2: Method 502.2 " Methods for the Determination of Organic Compounds in
Drinking Water", United States Environmental Protection Agency - 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/l are detected in any downgradient monitoring
well, additional 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/l, 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 analysis 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. ,
�e The Compliance Bound for the disposal system is
specified by regulations in 15 NCAC 2L, Classifications and Water Quality Standards
applicable to the groundwater of North Carolina. An exceedance of Groundwater Quality
Standards beyond the Compliance Boundary is subject to penalty provisions applicable
under General Statute 143-215.6A. The sale of property,.by the Permittee, which is within
or contiguous to the disposal system 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 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 Division 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 d 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.
( Any groundwater quality monitoring as deemed necessary by the Division of
Environmental Management shall be provided. The Division will attempt to coordinate any
additional requirements with Coats American.
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GROUNDWATER SECTION
DIVISION OF ENVIRONMENTAL MANAGEMENT
RECORD OF WASTE DISPOSAL PERMIT APPLICATION REVIEW
REVIEW BY:
FIELD INVESTIGATION
DATE:
DATE:
FACILITY NAME: �v�ir�oi^ir��1 /,QPQ� SAyler
TOWN: �?ri�n '% COUNTY: �%✓%DirJL'//
LOCATION: _ / t c s�
TYPE OF DI
SYSTEM (LANDFILL, LAGOON, 'ETC) :}/„`�
DESIGNED CAPACITY (GPV) :
WASTE PHYSICAL CHARACTERISTIC:
✓DESCRIPTIONi OF FMLITY:' 6,
,bol%r
CHEMICAL ANALYSES AND OTHER DATA AVAILABLE: (CHECK THOSE APPLICABLE AND ATTACH COPIES):
]AMBIENT GROUNDWATER QUALITY (WATER TABLE) . RAW WASTE [-1 OTHER
j� AMBIENT GROUNDWATER QUALITY (ARTESIAN) Q TREATED WASTE SPECIFY
�
NAME OF NEAREST STREAM: a „Ve..�r�.i v-i 6, �m Lim e- k, {� 0-r. DISTANCE: ,,.__�= r
DISTANCE TO NEAREST WELL: _� j6 0 Q DEPTH: PUMPING RATE:
PROPOSED METHOD FOR PREVENTING GROUNDWATER CONTAMINATION:
STRUCTURE, LITHOLOlGY PAN/D PERM.�E-ABI/LITY OF �S;URFICIAL MATE/RIALS: •5.,� ,,,/r G�%1ac�,aa
A. t a1�kT orr) 2-:!t A °I?
HY RAULIC RELATIONSHIP BETWEEN WATER TABLELAND ARTESIAN `AQUIFERS: The iL;,,7,a,
t 6d io /I'-Fff
7��9.+StB't� Pw.4 F�.�'3l //1 ✓l c�G{f'/7C A
,"DEPTH TO BEDROCK:
DEPTH
TO SEASONAL HIGH
WrATER TABLE:
MONITORING FACILITIES EEDED (ATTACH
SKETCH):
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�h-, rr-
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RECOMMENDED SAMPLING SCHEDULE AND PARAMETER REQUIRED:
REMARKS
10AND RECOMMENDATIONS r-T�Z l ,,J,aN T« r- �)—Jou.)rJ -i- J
GW 48
Revised 7/84

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DIVISION OF ENVIRONMENTAL MANAGEMENT
GROUNDWATER SECTION
October 15, 1986
MEMORANDUM
TO: Don Link
FROM: Len Bramble
SUBJECT: Application for Renewal/Amendment of Existing Permit
X New Permit
Facility Name : American Thread Company
County : McDowell
Type of Project : Ash Sludge Lagoon
Applicable Permit Numbers : APN 008445
GW 86172
We have received a copy of the above referenced application,
which was sent to your regional office for comment on or about
October 10, 1986.
You should review the application package for completeness
and adequacy of relevant information and submit your request
for additional information to me (via telephone or memo) by
October 22, 1986 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
review the application package and submit your comments to me by
November 5, 1986.
If a copy of the application package has not been made
available to your office, PLEASE LET ME KNOW.
cc: Permit Issuance Files
LB/ls/RONOTIF
t'
C E I� E D
1986
Groundwater Section
IP Asheville Regional Office

4 •oy ` / V
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State of North Carolina
Department of Natural Resources and Community Development
Asheville Regional Office
James G. Martin, Governor S. Thomas Rhodes, Secretary
DIVISION OF ENVIRONMENTAL, MANAGEMENT
WATER QUALITY SECTION
September 23, 1986
Mr. F. T. Eslick, General Manager Technical Services
American Thread - Sevier Plant
Post Office Box 368
Marion, North Carolina 28752
Dear Mr. Eslick:
Receipt of the following documents is hereby acknowledged:
X Application Form
Engineering Proposal (for proposed control facilities)
Request for permit renewal
X Permit,,Processing Fee
Other
If any of the items listed below are checked, the application received is
incomplete and the indicated item(s) must be received before review can begin:
_ Application Form (copies enclosed)
X Engineering Proposal (See on attached sheet)
_ Permit Processing Fee
Other
If the application is not made complete within thirty (30) days, it will
be returned to you and may be resubmitted when complete.
This application has been forwarded to the Permits and Engineering Unit in
the Raleigh Office for review and preparation of a draft permit. Once the
permit is drafted, public notice must be issued for forty-five (45) days prior
to final action on the issuance or denial of the permit. You will be advised
of any comments, recommendations, questions, or other information necessary for
the review of the application.
Interchange Building,, 59 Wbodfin Place, P.O. Box 370. Asheville, N.C. 28802-0370 • Telephone 70g-2^3.3341.,
AlF""'i rl., are:...., �,•.,,,. r"" i,.,....

Mr. F. T. Eslick
September 23, 1986
Page Two
A Staff Report and Recommendations regarding this discharge will be
prepared by the Asheville Regional Office. If you have any questions regard-
ing this application, please contact the Permits and Engineering Unit, Water
Quality Section, Post Office Box 27687, Raleigh, North Carolina 27611.
Sincerely,
vj James R. Reid
Environmental Chemist
xc: Roy M. Davis
Permits and Engineering

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SEVIER PLANT f P.O. BOX 368 f MARION. NORTH CAROLINA 28752 f PHONE [phone]n1
a
September 19, 1986
North Carolina Department of Natural Resources
Interchange Building
50 Woodfin Place
PO Box 370
Asheville, NC 28802-0370
v Attn: Mr. James R. Reid, Environmental Chemist
Ref: Non -Discharge Permit, Sevier Plant, Ash Sluice Pond-'
Dear Mr. Reid:
Enclosed please find our application for reference permit and
I 'checked=with Roy Davis -on test data to_•submit and he re-
quested the following:
Parameter Test Results
Alkalinity 45 ppm
TSS 7 ppm
Total Solids 836 ppm
The test samples were composite grab samples from the four
corners of the ash sluice pond. Our Jerry McKinney ran the
tests.
If we can further assist you in this matter, please advise.
FTE/rch
Very truly yours,
AMERICAN THREAD CO.
.� Liuc;
F. T. Eslick,
General Manager Technical Services
-RECEIVED
1{1} -date; C��f+Y CAfo�s�i;
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ENGINEERING DEPARTMENT 1 P. 0. BOX 880 ! OLD FORT, NORTH CAROLINA 287621 PHONE [phone]
m .
•J September 29, 1986
h Carolina Department of Natural Resources'
Interchange Building
North g
59 Woodfin Place
P.O.:-Box 370
Asheville, N.C. 28802-0370
Attn: Mr. James R. Reid, Environmental Chemist
Ref: Non -Discharge Permit, Sevier ',Plant, -Ash Sluice..Pond
Dear 'Mr. Reid: `.
As per your request for an engineering proposal regarding the above
referenced permit we "offer' the' following information:
1. The lagoon varies in depth from two to six feet.
2. The dikes are.tirelve feet wide and vary in depth from five to
eight •feet.
3. Attached is our drawing, SE-145 which shows the basin, -the manu-
facturing facility and other pertinent landmarks such as streams
and roads.
If we can further assist you in this matter, please advise.
�Very truly yours,
U W.
Jerry W. Sisk,
Manager Engineering
cc: Mr. F.T. Eslick - Sevier
JWS/sf
RECEIVED
W*W Quzilty Uvisl.

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to
NPDES STAFF REPORT.AND RECOMMENDATIONS
County McDowell
NPDES Permit NO._Non-Discharge Permit
PART I - GENERAL INFORMATION
N,
1. Facility And Address: American Thread Company - Sevier Plant
P. 0. Box 368
Marion, N. C. 28752
2: Date of Investigation:- September 5, 1986
3. Report Prepared By: James R. Reid
4. Persons Contacted and Telephone Number: Jerry McKinney
704/756-4111 -.
5. Directiond'to Site From Marion, travel North on Highway 221 .
to SR 1556; turn right and travel approximately 3� mile to -,plant.
6. Discharge Point hatituder'. 350 47' 25"
Longitude: 820 O1' 30"-
Attach a USGS Map Extract and indicate treatment plant site and
discharge point on map.
USGS Quad No.
or USGS Quad Name Little Switzerland
7. Size (land available for expansion and upgrading):
Sufficient land is available for replacement or expansion.
8. Topography (relationship to flood plain included): Flat.
9. Location of nearest dwelling: Approximately 1000'
10. Receiving stream or affected surface waters: Non -Discharge.
a. Classification:
b. River Basin and Subbasin No.:
C. Describe receiving stream features and pertinent downstream
uses:
t
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PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
1. Type of wastewater: % Domestic
100% Industrial
a. Volume of Wastewater: MGD
b. Types and quantities of industrial wastewater:
Non -Discharge settling basin for water from a wet scrubber
which is installed on a coal fired boiler.
C. Prevalent toxic constituents in wastewater: None known.
d.`' Pretreatment Progr=am -(POTWs' only) N/A
in development approved
_.should be -required,. not needed
2. Production rates (industrial discharges only) in pounds N/A
a. highest month in the last 12 months
b. highest year in last 5 years
3. Description of industrial process (for industries only) and
applicable CFR Part and Subpart: N/A
4. Type of treatment (specify whether proposed or existing):
Existing.
5. Sludge handling and disposal scheme:
Proposal is to allow basin to fill and then abandon the system
and construct a new one.
6•.. Treatment plant classification:
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State of North Carolina
Department of Natural Resources and Community Development
Asheville Regional Office
James G. Martin, Governor S. Thomas Rhodes, Secretary
DIVISION OF ENVIRONMENTAL MANAGEMENT
GROUNDWATER SECTION
October 31, 1986
Mr. F. T. Eslick, General Manager
Technical Services
American Thread
Post Office Box 368
Marion, North Carolina 28752
SUBJECT: Monitor Wells
American Thread - Sevier Plant
11cDowell County, North Carolina
Dear Mr. Eslick:
On October 28, 1986, Jim Reid and I representing the Division of Environ-
mental Management met with Hubert Johnson and Jerry McKinney of American Thread
to select the locations for the groundwater monitoring wells that will be re-
quired in the permit for the non -discharging ash sludge lagoon. At that time
we selected locations for three monitor wells. One monitor well was located
upgradient from the ash basin and will be used for background data purposes.
Two other monitor wells were located downgradient from the ash basin. One down -
gradient site was located on the northeast side of the basin. The other site,
as per my telephone conversation with Jerry McKinney of October 30, 1986, was
to be located on the northwest side of the ash basin between the unused ash
storage basin and State Road 1556 which is located in front of the plant.
The parameters to be analysed for in the monitor wells during the months
of March, July, and November will be listed in your permit when issued.
During the October 28, 1986, visit we also discussed groundwater monitoring
and located three monitor well sites at the three unlined basins of the waste-
water treatment plant as we are planning to add groundwater monitoring require-
ments to your NPDES permit in the near future. I would recommend you consider
constructing monitor wells around the wastewater treatment plant at the same
time as you construct wells around the ash pit to help minimize expense.
These monitor wells should be constructed to a depth of 30 feet and be
equipped with a ten -foot section of well screen on the bottom. I have enclosed
a diagram of a typical monitor well installation as well as "Applications to
Interchange Building, 59 Woodfin Place, P.O. Box 370, Asheville, N.C. 28802-0370 • Telephone [phone]
An Equal Opportunity Affi. mative Action, Employer

Mr. F. T. Eslick ,
October 31, 1986
Page 2
Construct Monitor Wells". One application should be completed for the ash basin
site and one for the wastewater treatment plant site if you plan to construct
these wells at the same time. These applications shall be submitted to this
office prior to well construction so that well construction permits may be
issued.
If you have any questions regarding this matter, please contact me.
DRL:sb
Enclosure
cc: Bob Cheek
James R. Reid
j-
Sincerely, '{�
r��"n✓ '
Donald R. Link
Hydrogeological Regional Supervisor

Locking Cap
Steel Outer Casing
�( If Plastic Inner Casing)
LAND
Neat Cement Grout
2 or larger diam.
Well Casing
�euamp(� a.'gx�c,le 4D
Pvc-
Pelletized Bentonite
C I ea n Washed
Sand or Gravel
(optional)
Well Screen
required for
unconsolidated
formations
P.Xa�p�e � Sri Sc�v�c �0
PVC_ we l I Sc reejo
4
4-
IQ
}
0
a SURFACE
NOTE :
1_ Borehole to be six inches
larger than outside diameter
of casing.
2. Casing and screen to be
centered in borehole.
3. Top of well screen should
not be above mean high
seasonal water level.
4. Casing and screen material
to be compatible with type
of contaminant being mon-
itored.
5. Well head to be labeled
with highly visible warning
saying Well is for moni-
toring and not considered
safe for drinking ° .
6. Well to be afforded reasc
able protection against
damage after construction.
`d'o+& l T_)CptGA 361
Recommended Construction Details for a Pollution Monitor Well

RE 1VED
WAfrr Quality Divisir
NOV 6 1986
W*sxarn R*glorwl OftIC4
State of North Carolina
Department of Natural Resources and Community Development
Division of Environmental Management
512 North Salisbury Street 0 Raleigh, North Carolina 27611
James G. Martin, Governor
S. Thomas Rhodes, Secretary GROUNDWATER SECTION
November 5, 1986
Mr. Fred T. Eslick
General Manager Technical Services
American Thread Company
P.O. Box 368
Marion, NC 28752
SUBJECT: Non -Discharge Permit Application Review
American Thread Company
Ash Sludge Lagoon
McDowell County
(APN008445/GW86172)
Dear Mr. Eslick:
R. Paul Wilms
Director
As part of the Division of Environmental Management's com-
prehensive approach in addressing the impact of waste treat-
ment, storage, or disposal projects on the environment, your
permit application has been forwarded to us for assessment of
the potential impact of the project on groundwater quality.
Our initial review indicates that the data submitted is
not sufficient to make this assessment.
Before your application can be processed therefore, you
are requested to submit the following information to the
Groundwater Section. This information should be submitted in
full within 60 days of the date of this letter. Failure to com-
ply may result in the returning of this application as incom-
plete.
(1) A general location map, showing orientation of the
facility with reference to at least two (2) geographic
references (numbered roads, named streams/rivers, etc.).
(2) A site -specific map, with topographic contours (contour
interval should not exceed 10 feet or 25 percent of total
site relief, whichever is less), showing all
facility -related structures within the property boundary
and the location of all wells, springs, lakes, ponds, or
other surface drainage features within 500 feet of the
Pollution Prevention Pays
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

principal waste treatment/disposal site(s). Wells should
be labeled as to their primary usage (drinking water, pro-
cess water, monitoring, etc.)
(3) A chemical analysis of the wastewater or sludge, just
prior to disposal, to include the following:
(a) Total Organic Carbon (g) Magnesium
(b) Biological Oxygen Demand (h) Phosphorus
(c) Chlorides (i) Phenol
(d) Nitrates ( j ) pH
(e) Sodium (k) EP Toxicity
(f) Calcium (1) Total Dissolved Solids
(4) Hydrogeologic profile, via hand or powered soil auger
borings, to a depth of 20 feet or auger refusal, whichever
is less. The number should be sufficient to define:
(a) the major types of lithologic strata underlying the
site
(b) the estimated vertical hydraulic conductivity of the
consolidated thickness of total strata encountered
(c) the depth, thickness, hydraulic conductivity and
coefficient of permeability of the major lithologic
units encountered to the total boring depth
(d) depth of the mean seasonal high water table (if
definable from soil morphology or from evaluation of
other applicable available data)
NOTE: In the event the permitted facility will utilize
several separate disposal fields overlying
different major soil types, at least one (1)
hydrogeologic profile should be established for
each of the major soil types.
NOTE: In the event that the surficial (water table)
aquifer is less than 20 feet the hydraulic
relationship (rate and direction of groundwater
flow) between this unit and the underlying
artesian or semi -confined aquifer unit must be
determined.
(5) Detailed plans and specifications of the proposed
facility.
Please feel free to contact the Groundwater Section, at
[phone], if clarification or information is required.
Sincerely,,
IY4 /� ZZ
Bob Cheek, Supervisor
Permits and Compliance Unit
LB/ls/86172B.
cc: 'Don hink 1
Bob Teulings
Central Files
Permit Issuance Files

DIVISION OF ENVIRONMENTAL MANAGEMENT
GROUNDWATER SECTION
January 29, 1987
MEMORANDUM
TO: Arthur Mouberry
FROM: Leland L. Laymon
SUBJECT: Review of Non -Discharge Permit Application
American Thread, Sewer Plant, McDowell County
APN 008445/GW 86172
SERG Review Eng: Bob Teulings
The Groundwater Section has no objections to issuance of
the subject permit given the following recommended conditions:
(1) Within 90 days of permit issuance, install three
monitor wells (one upgradient and two downgradient)
located and constructed as approved by the Asheville
Regional Office.
(2) During the months of March, July and November collect
samples from the wells and analyze for: TDS, TOC,
SO4, Ca, pH, Mg and Se.
If any questions concerning these comments, please call me
at 733-3221.
LLL/ls
cc: Roy Davis/Don Link
Central Files
Groundwater Files
.3
D
FE s ' _ 1987
Groundwater Section
q Asheville Regional Office

tate of North Carolina
Department of Natural Resources and Community Development
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor
S. Thomas Rhodes, Secretary
March 26, 1987
Mr. F. T. Eslick
General Manager Technical Services
American Thread Company
Post Office Box 368
Marion, N. C. 28752
R. Paul Wilms
Director
SUBJECT: Permit No. 14441
American Thread Company
Sevier Finishing Plant
Wastewater Settling Basin (as built)
McDowell County
Dear Mr. Eslick:
Iit accordance with your application received September 25, 1986,
forwarding herewith Permit No. 14441, dated March 2.6, 1987, to American
for the operation of the subject as -built non -discharge settling basin.
we are
Thread Company
This permit shall be effective from the date of issuance until April 1, 1992,
and shall be subject to the conditions and limitations as specified therein. Please
take notice of Condition 7 requiring the installation of groundwater monitoring wells.
If any parts, requirements, or limitations contained in this permit are
unacceptable to you, you have the right to request an adjudicatory hearing upon
written request within 30 days following receipt of this permit. This request must' be
in the form of a written petition, conforming to Chapter 150B of North Carolina
General Statutes, and filed with the Office of Administrative Hearings, Post Office
Drawer 1-1666, Raleigh North Carolina 27604.
If you wish to have the hearing before the Hearing Officer with this
Department, you must indicate in the petition that you waive the right to have the
contested case conducted by a Hearing Officer in the Office of Administrative
Hearings, and wish to have the matter conducted in the Department of Natural Resources
and Community Development. Unless such demands are made this permit shall be final
and binding.-
Continued next page
- VV `er Qualify SeC'ion
A PD o - i-0B7
Pollution Prevention Pays
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] Aslievllle Regional Office
An Equal opportunity Affirmative Action Employer AslleVllle; North Carolina

If you need additional information concerning this matter, please contact Mr.
Robert Teulings, telephone No. 919/733-5083, ext. 177.
Sincerely yours,
R. Paul Wilms
cc: McDowell County P Health Department
Groundwater Section
Asheville Regional Supervisor
Dennis R. Ramsey
jk

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
,.DEPARTMENT OF NATURAL RESOURCES AND COMMUNITY DEVELOPMENT
RALEIGH
P E R M I T
For the discharge of Sewage, Industrial Wastes, or Other Wastes
In accordance with the provisions of Article 21 of Chapter 143, General
Statutes of North Carolina as amended, and other applicable Laws, Rules and
Regulations
PERMISSION IS HEREBY GRANTED TO
American Thread Company
McDowell County
FOR THE
operation of an existing non -discharge settling basin for ash from coal-fired boilers
and wastewater from stack scrubbers at the American Thread Company's Sevier Finishing
Plant,
pursuant to the application received September 25, 1986, and in conformity with the
project plan, specifications, and other supporting data subsequently fi=led and
approved by the Department of Natural Resources and.Community Development and
cons1dered a part of this permit.
This permit shall be effective from the date of issuance until April 1, 1992,
and shall be subject to the following specified conditions and limitations:
1. This permit shall become voidable unless the facilities are constructed in
accordance with the approved plans, specifications and other supporting data. ,
wastewater to the surface waters of the State.
2. This permit is effective only with respect to the nature and volume of wastes
described in the application and other supporting data.
3. The facilities shall be properly maintained and operated at all times.
4. This permit is not transferable.
5. In event the facilities fail to perform satisfactorily including the creation of
nuisance conditions, the Permittee shall take such immediate corrective action as
may be required by this Division, including the construction of additional or
replacement wastewater treatment or disposal facilities.

6. Any monitoring deemed necessary by the Division of Environmental Management to
insure surface and ground water protection will be established and an acceptable
sampling reporting schedule shall be followed.
7. Monitofing wells shall be constructed and sampling schedules arranged as
required by the Division of Environmental Management and constructed in
accordance with 15 NCAC 2c .0100.
a. Within 90 days,of permit issuance, three wells, nt and two
down rant, shall be constructed to monitor groundwater quality. Location
and construction of these 'wells shall be as approved by the Division's
Asheville Regional Office.
b. The wells shall be sampled upon completion and thereafter during the months
of March, July, and November. The samples shall be analyzed for the
following parameters7--
Total Dissolved Solids Mg
Total Organic Carbon Se
SO4 PH
Ca
8. Solids, sludges, or r pollutants removed ng from the wastewater
storage facilities shall be c e -and disposed of in such a manner as to
prevent any contamination of the surface or groundwater of the State.
9. Diversion or bypassing of the untreated wastewater from the treatment and storage
lagoon is prohibited.
10. Freeboard in the lagoon shall not be less than two (2) feet at any time.
11. The issuance of this permit"shall not relieve American Thread Company of the
responsibility for damages to surface or ground waters resulting from the
operation of this facility.
12. The facilities shall be effectively maintained and operated as a non -discharge
system to prevent the discharge of any wastewater resulting from the operation of
this facility.
13. The Permittee, at least six (6) months prior to the expiration of this Permit,
shall request its extension. Upon receipt of the request, the Commission will
review the adequacy of the facilities described therein, and if indicated, will
extend the Permit for such period of time and under such conditions and
limitations as it may deem appropriate.
Permit issued this the 26th day of March, 1987.
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
R. Paul Wilms, Director
0,-^ Division of Environmental Management
By Authority of the Environmental Management Commission
Permit NO. 14441

State of North Carolina
Department of Natural Resources and Community Development
Asheville Regrional Office
James G. !Martin, Governor S. Thomas Rhodes, Secretary
DIVISION OF ENVIRONMENTAL MANAGEMENT
GROUNDWATER SECTION
July 14, 1987
Mr. F. J. Eslick
General Manager Technical Services
American Thread Company
Post Office Box 368
Marion, North Carolina 28752
SUBJECT: Notice of Noncompliance
Groundwater Compliance Monitoring
American Thread Company
Sevier Finishing Plant
Permit No. 14441
McDowell County, North Carolina
Dear Mr. Eslick:
Review of the Compliance Monitoring Report Forms submitted to us for
samples collected on May 28, 1987, indicates a violation of groundwater
quality standards for some of the parameters tested. The concentration of
selenium in monitor well No. 2 was reported as 21 ug/l and monitor well
No. 3 was 32 ug/l. The standard for selenium is 10 ug/l. Monitor well
No. 3 had a concentration of 569 mg/1 of dissolved solids which is a viola-
tion of the 500 mg/1 standard for dissolved solids. Also, high values of
TOC's (range from 14 to 131 mg/1) were reported.
It is my understanding that the samples were improperly collected in
that the monitor wells were not sufficiently bailed (at least six volumes
of water prior to sample collection), and improper sampling equipment was
used. This being the case, the wells shall be resampled properly.
On July 28, 1987 at 10:00 a.m., Ms, Diane Eskenasy from our office,
plans to meet with Jerry McKinney at the subject facility to collect samples
and discuss proper sampling techniques, American Thread may split a sample
with her at this time.
Interchange Building, 59 Woodfin Place, P.O. Box 370, Asheville, N.C. 28802-0370 • Telephone [phone]
An Equal Opportunity Affirmative Action Employer

J Mr. F. J. Eslick
July 14, 1987
Page Two
If you have any questions, please contact me or Don Link at 704/253-3341.
Sincerely,
Laura Kay Dechant
Hydrogeological Technician
LKD:sb
cc: Bob Cheek
Jerry McKinney

DIVISION OF ENVIRONMENTAL MANAGEMENT
GROUNDWATER SECTION t
ASHEVILLE REGIONAL OFFICE
MEMORANDUM
TO: L. P. Benton, Jr., Deputy Director
Division of Environmental Management
THROUGH: Roy M. Davis, Regional Supervisor
Division of Environmental Management
Donald R. Link, Hydrogeological Regional Supervisor Al
Groundwater Section
Ir-
FROM: Diane M. A. Eskenasy, Hydrogeological Technician
Groundwater Section )0111-0.AL
SUBJECT: Notice of Violation, Order and Notice of Proposed Continuing
Penalties Against Barbour's Well Boring, Drilling & Pump
Service, Inc.
Burke County, North Carolina
DATE: August 6, 1987
On July 29', 1987, ,I inspected- six monitor well's constructed by Barbour's '
Well Boring, Drilling & Pump Service, Inc. for American Thread Company in
McDowell County. These wells are in violation of the North Carolina Well
Construction Standards and Well Construction Permit No. 55-0001-WM-0029 in that
the wells were not properly equipped with well screens, gravel pack, bentonite
seal, and locking caps. Attached are my July 29, 1987 inspection reports
and the Notice of Violation, Order and Notice of Proposed Continuing Penalties.
DMAE:sb
Enclosure

State of North Carolina
Department of Natural Resources and Community Development
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor - R. Paul Wilms
S. Thomas Rhodes, Secretary Director
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Michael Barbour
Barbour's Well Boring, Drilling &
Pump Service, Inc.
Route 2, Box 459F
Morganton, North Carolina 28655
Subject: Notice of Violation of North Carolina Well
Construction Standards and Well Construction Permit
No. 55-0001-WM-0029, Order and Notice of Proposed
Continuing Penalties
Dear Mr. Barbour:
This letter transmits a Notice of Violation, Order and a proposed continu-
ing civil penalty to be assessed against Barbour's Well Boring, Drilling &
Pump Service, Inc. This action concerns the six monitor wells you constructed
under Well Construction Permit No. 55-0001-WM-0029 for American Thread Company
located in McDowell County, North Carolina.
Attached is a copy of the Notice, Order and proposed assessment document
explaining this penalty. This action was taken under the authority of North
Carolina General Statutes 87-83, et seg. The Order requires you to take
remedial action in fifteen (15) days from your receipt of the attached Notice.
Copies of the permit and applicable regulations are included with this letter
for your convenience. The Notice of Proposed Continuing Penalties section of
the document advises you as to actions you must take within twenty (20) days of
your receipt of this notice in regards to the continuing penalties. The
continuing penalties may be assessed from the date you receive this notice.
Within thirty (30) days of your receipt of the attached document, you must
submit a written request for an administrative hearing or the order will become
final. Failure to comply with the final Order may result in the assessment of
civil penalties or referral to the Attorney General's office for injunctive
Pollution Prevention Pays
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
A.. Frt,nl 0­.-n ;.., AFF:—,r:....- A,-r;.,- F-1.,111

Mr. Michael Barbour
Page Two
relief. Your request for hearing 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, Post Office Drawer 11666, Raleigh,
North Carolina 27604. A copy of the petition should be filed with this
office.
Sincerely,
R. Paul Wilms
Attachments
cc: Perry Nelson
Asheville Regional Office
Office of Legal Affairs
Mr. Jerry Sisk, American Thread
Company

STATE OF NORTH CAROLINA
COUNTY OF WAKE
IN THE MATTER OF:
Barbour's Well Boring, Drilling)
& Pump Service, Inc. )
Route 2, Box 459F )
Morganton, Burke County, North )
Carolina 28655 )
NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DIVISION OF ENVIRONMENTAL MANAGEMENT
NOTICE OF VIOLATION,
ORDER
AND
NOTICE OF PROPOSED CONTINUING
PENALTIES
GW#
Acting pursuant to the North Carolina Well Construction. Act, North Caroli-
na General Statutes (G.S.) 87-83, et seq., (hereinafter the Act) and North
Carolina Environmental Management Commission (Commission) Regulation Title 15
North Carolina Administrative Code 2J .0003, I, R. Paul -\Wilms, Director of the
Division of Environmental Management, make the following:
I. FINDINGS OF FACT:
A. Barbour's Well Boring, Drilling & Pump Service, Inc. constructed
six monitor wells on the property of American Thread Company on SR 1556
in McDowell County, North Carolina. Well Construction Permit No. 55-0001-
WM-0029 was issued to American Thread Company for said wells. American Thread
Company hired Barbour's Well Boring, Drilling & Pump Service, Inc. to construct
said , monitor 'wells' in --accordance with 'constructi n -'"standards' -get- out,'in"'the
permit. Said wells were not on land which is owned or leased by Barbour's Well
Boring, Drilling & Pump Service, Inc. Said wells were constructed on or after
January 1, 1986.
B. On July 29, 1987, staff of the Asheville Regional Office (ARO) of the
Division of Environmental Management (DEM) inspected said wells. The
inspection and review of ARO and DEM,records revealed that:
(1) The six wells were not equipped with well screens;
(2) The six wells were not equipped with gravel packs;
(3) The six wells did not have a bentonite seal above the gravel
pack;
(4) The six wells were not equipped with locking caps.
Based upon the above Findings of Fact, I make the following:
II. CONCLUSIONS OF LAW AND NOTICE OF VIOLATIONS:
A. Barbour's Well Boring, Drilling & Pump Service, Inc. is a "person"
within the meaning of G.S. 87-85(9).

B. Barbour's Well Boring, Drilling & Pump Service, Inc. violated V
Commission Regulation 15 NCAC 2C .0'107(e)(1) and Well Construction Permit No.
55-0001-WM-0029 on six occasions by not equipping wells constructed in an
unconsolidated rock formation with screens.
C. Barbour's Well Boring, Drilling & Pump Service, Inc. violated Well
Construction Permit No. 55-0001-WM-0029 on six occasions by not emplacing a
gravel pack that extends two feet above the top of the well screen.
D. Barbour's Well Boring, Drilling & Pump Service, Inc. violated
Commission Regulation 15 NCAC 2C .0108(c)(5) and Well Construction Permit No.
55-0001-WM-0029 on six occasions by not installing a bentonite seal above the
gravel pack.
E. Barbour's Well Boring, Drilling & Pump Service, Inc. violated
Commission Regulation 15 NCAC 2C .0108(c)(7) and Well Construction Permit No.
55-0001-WM-0029 on six occasions by not installing locking caps on the wells to
insure against unauthorized access and use.
F. General Statute 87-94 provides that a civil penalty of not more than
one hundred dollars ($100.00) may be assessed against a person who violates, on
or after January 1, 1986, any provision of G.S. 87-83 et seq., or any order
issued pursuant thereto, or any adopted regulation promulgated thereunder.
Each day of a continuing penalty shall be considered a separate offense.
Based upon the above Findings of Fact and Conclusions of Law, I make the
following:
III. ORDER:
Pursuant to G.S. 87-91(b), you are required to take the following remedial
actions, within fifteen (15) days upon your receipt of this Order, which will
effect compliance with the requirements of the Act and the rules and regula-
tions issued thereunder:
A. For violation of Commission Regulation 15 NCAC 2C .0107(e)(1) and
Well Construction Permit No. 55-0001-WM-0029, you must take the following
action: equip the six wells with screens or abandon the wells in accordance
with Commission Regulations 15 NCAC 2C .0113(2) and 15 NCAC 2C .0114(b).
B. For violation of Well Construction Permit No. 55-0001-WM-0029, you
must take the following action: install a gravel pack that extends two feet
above the screen on each of the six wells or abandon the wells in accordance
with Commission Regulations 15 NCAC 2C .0.113(2) and 15 NCAC 2C .0114(b).
C. For violation of Commission Regulation 15 NCAC 2C .0108(c)(5) and
Well Construction Permit No. 55-0001-WM-0029, you must take the following
action: install a bentonite seal above the gravel pack on each of the six
wells or abandon the wells in accordance with Commission Regulations 15 NCAC 2C
.0113(2) and 15 NCAC 2C .0114(b).
D. For violation of Commission Regulation 15 NCAC 2C .0108(c)(7) and
Well Construction Permit No. 55-0001-WM-0029, you must take the following

action: install a locking cap on each of the six wells or abandon the wells in
accordance with Commission Regulations 15 NCAC 2C .0113(2) and 15 NCAC 2C
.0114(b).
If you fail to take the above -described actions and effect compliance with
the Commission Regulations and this Order within fifteen (15) days of your
receipt of this Order, a civil penalty will be assessed as set out below for
failure to comply within the specified time.
This Order will become final unless a request for a hearing is made within
thirty (30) days from the date of your receipt of this Order.
Based upon the above Findings of Fact, Conclusions of Law and Order, I
make the following:
IV. PROPOSED ASSESSMENT AND NOTICE OF CONTINUING PENALTIES:
Pursuant to G.S. 87-94 and 15 NCAC 2J .0006, in determining the amount of
the penalty, I have taken into account the Findings of Fact and Conclusions of
Law and considered the degree and extent of harm caused by the violation, the
cost of rectifying the damage, the amount of money the violator saved by his
noncompliance, whether or not the violation was committed willfully, and the
prior record of the violator in complying or failing to comply with G.S. 87-83,
et seq.
Accordingly, Barbour's Well Boring, Drilling & Pump Service, Inc. shall
be assessed.a civil penalty of:
$ for six (6) violations of Commission Regulation 15 NCAC 2C
.0107(e)(1) and Well Construction Permit No. 55-0001-WM-
0029 by failing to equip each of the six wells with
screen;
$ for six (6) violations of Well Construction Permit No.
55-0001-WM-0029 by failing to install a gravel pack that
extends two feet above the top of the well screen in each
of the six wells;
$ for six (6) violations of Commission Regulation 15 NCAC
2C .0108(c)(5) and Well Construction Permit No. 55-0001-
WM-0029 by failing to emplace a bentonite seal in each of
the six wells;
$ for six (6) violations of Commission Regulation 15 NCAC 2C
.0108(c)(7) and Well Construction Permit No. 55-0001-WM-
0029 by failing to install locking caps on each of the six
wells.
In accordance with 15 NCAC 2J .0007(a), within twenty (20) days from
receipt of this Decision, you must correct the above cited violations and
comply with the above Order or submit reasons in writing why the penalty should
not be assessed. If after twenty (20) days the violations have not been
corrected or no response has been received or if a response is not sufficient
justification to preclude assessment, the penalty will be assessed as a

continuing penalty from the date of your receipt of this Notice of Violation,
Order, and Notice of Proposed Continuing Penalties, with each day in violation
being considered a separate offense, pursuant to G.S. 87-94(a).
The total penalty assessed for continuing violations shall be based upon
the amounts set out above, multiplied by the number of days each violation
continues.
You must notify Roy M. Davis, Regional Supervisor of the Asheville Region-
al Office, Post Office Box 370, Asheville, North Carolina 28802, in writing as
to the date you ceased the violations. You should not assume the wells are in
compliance with the regulations until the wells have been inspected and you
have been notified by this Division in writing.
UNDER THE AUTHORITY OF THE
ENVIRONMENTAL MANAGEMENT COMMISSION
(Date) R. Paul Wilms, Director
Division of Environmental Management

State of North Carolina
Department of Natural Resources and Community Development
Asheville Regional Office
James G. Martin, Governor
S. Thomas Rhodes, Secretary
DIVISION OF ENVIRONMENTAL MANAGEMENT
GROUNDWATER SECTION
Mr. Jerry G. McKinney
American Thread Company
P. 0. Box 368
Marion, North Carolina 28752
Dear Mr. McKinney:
August 12, 1987
Subject: Compliance Monitoring Reports
American Thread Company
Permit No. 14441
McDowell County, North Carolina
In order for the Groundwater Section to review and process compliance
monitoring reports in a consistent manner, please send the report forms
directly to the Groundwater Section in Raleigh at the address at the top
of the form. Submit the blue and green copies to Raleigh and keep the
white copy for your files. If an agent is authorized to submit the forms
in your behalf, notify them of this procedure.
If you have any questions or comments regarding compliance monitoring,
please contact me or Don Link at [phone].
Sincerely,
Kay Dechant
Hydrogeological Technician
KD:ar
cc: Nargis Toma
Interchange Building, 59 Woodfin Place, P.O. Box 370, Asheville, N.C. 28802-0370 • Telephone [phone]
An Equal Opportunity Affirmative Action Employer

DIVISION OF ENVIRONMENTAL MANAGEMENT
ASHEVILLE REGIONAL OFFICE
GROUNDWATER SECTION
September 22, 1987
MEMORANDUM
TO: R. Paul Wilms,, Director
Division of Environmental Management
THROUGH: Perry Nelson, Chief
Groundwater Section
Roy M.,,Davis, Regional Supervisor
Division of Environmental Management
FROM: Donald R. Link, Hydrogeological Regional Supervisor
Groundwater Section
SUBJECT: Correction Deadline Extension
Groundwater Commission Order # 87-49
Barbour's Well Boring, Drilling & Pump Service, Inc.
American Thread -Sevier Plant
McDowell County, North Carolina
I have attached for your signature a letter granting an extension until
October 15, 1987, of the deadline of September 30, 1987, for Groundwater.
Commission Order # 87-49 issued against Barbour's Well Boring, Drilling & Pump
Service, Inc.
DRL:ar
Attachment

IA SZRATE o
Man
.Q auw may.
State of North Carolina
Department of Natural Resources and Community Development
Division of Environmental Management
512 North Salisbury Street 0 Raleigh, North Carolina 27611
James G. Martin, Governor
S. Thomas Rhodes, Secretary
Mr. Michael A. Barbour
Barbour's Well Boring, Drilling & Pump Service, Inc.
Route 2, Box 459F
Morganton, North Carolina 28655
R. Paul Wilms
Director
Subject: Correction Deadline Extension
Groundwater Commission Order # 87-49
Barbour's Well Boring, Drilling & Pump Service, Inc.
American Thread -Sevier Plant
McDowell County, North Carolina
Dear Mr. Barbour:
In response to the request made by you and Mr. Jerry W. Sisk, Manager
Engineering, of American Thread, an extension is granted on Groundwater
Commission Order # 87-49 until October 15, 1987, to make corrections on all
downgradient monitor wells at the American Thread -Sevier Plant.
If you have any questions, contact the Asheville Regional Office at
704-253-3341.
cc: Jerry Sisk
Hubert Johnson
Perry Nelson
Asheville Regional Office
Sincerely,
R. Paul Wilms
Pollution Prevention Pays
P.O. Box 27687, Raleigh, North Carolina 27611-76U Telephone [phone]
An Equal Opportunity Affirmative Action Employer

american
thmild
ENGINEERING DEPARTMENT P.O. BOX 880 OLD FORT, NORTH CAROLINA 28762
1 � / PHONE [phone]
a
September 3, 1987
Mr. Roy M. Davis
Regional Supervisor
Asheville Regional Office
Department of Natural Resources and Community Development
Division of Environmental Management
P.O. Box 370
Asheville, N.C. 28802
Re: Well Construction Permit No. 55-0001-WM-0029
Dear Roy:
As per the agreement at our meeting the morning of September 1, 1987
and subsequent phone conversation with Mr. Don Link that afternoon,
Barbour's Well Boring, Drilling & Pump Service Inc. has made
corrections to the two wells agreed upon to be done now.
As per the requirements of the Notice of Violation, GWCO 87-49,
filed against Barbour's Well Boring, Drilling & Pump Service,
Inc. a letter from him will be forthcoming.
The other wells involved will be corrected by October 15, 1987.
Please find attached two copies of our revised drawing SE-308 show-
ing the final locations of the monitoring wells.
If I can be of further assistance or if more information is needed,
please contact me.
Very truly your;,
Jerry W. Sisk,
Manager Engineering
cc: Mr. Mike Barbour - Barbour's Well Boring
Mr. F.T. Eslick - Old Fort
Mr. H. Byrd - Sevier
Mr. H. Johnson - Sevier
JWS/sf s
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AMERICAN
nueadCompany
J
October 24, 1990
Ms. Kay Dechant
Hydrogeologist
Division of Environmental Management
NC Department of Environment, Health, and Natural Resources
59 Woodfin Place
Asheville, NC 28801
Re: Sevier Plant
Plot Plan
Dear Kay:
Please find attached the drawing you requested showing the
property line and plant layout on the same drawing.
If I can be of further assistance, please advise.
Very truly yours,
W-1 4,4� W
AArry W. Sisk
Manager of Engineering
JWS/cl
cc: Mr. Jerry McKinney - Sevier
Environmental File
P.O. Box 880, Old Fort, North Carolina 28762 •7041668-7609

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AUG i 51991D

I
j e y d ✓ate
r
State of North Carolina
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
September 18, 1991
MR JERRY SISK
COATS AMERICAN
HWY. 221 NORTH
MARION, NORTH CAROLINA 28752
Dear MR SISK:
Sip .� � 1q�
�1e Ro�.too�t O
Subject: Applicat?dhll%..' Q 903
Sevier Plk*ev
Ash
McDowell County
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
2
Lz
Donald Safrit, P.E.
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

lzee lc /io / / IT I
/-y, ,f Down l / e�) yce 14-
DIVISION OF ENVIRONMENTAL, MANAGEMENT
GROUNDWATER SECTION
MEMORANDUM
TO: D ayx Li rL k-
DATE: a 1-991
FROM: Jack Floydf��
SUBJECT: Application for
,-""Renewal/Amendment of Permit No.--q-4
New 7ermit
Facility Name—1e_©A--�,-m2�icGln
County At\ C DOW-0-
Type of Project:, Ira ve
Central Office Contact:f";cct�
Applicable Permit Numbers: W.Q 00C)6l0 03 GW 91
EPA
AC
We have received a copy of the above referenced application,
wh' w s sent to your regional office for comment on or -about
1991
You should review the application package for completeness
and adequacy of relevant information and submit your request for
ad itional informatioo to me (via telephone or memo) by
1 SF/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
rev C then application package and submit your comments to me by
,
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
p Fern 3 0 1991 L�

DH `V SHC OF ENVIRONMENTAL MANY WENT
Groundwater Section
MEMORANDUM D
Date:
OCT I - 1991
Review Engineer Groundwater Section
� Asheville Regional Office
Perrm�its & Engineering Unit
From: i q "� 1f1aar7
Groundwater Section
/
Subject:.' LCr:��S �}-�c�r•,Cc?r� ���"��+r`rli �%�" i7NIf0n 11r�f r".:
Request for Additional Information
WQ000 -5o'0. / Gw G7 /-? 7/
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:
'Item 1
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 fill in blanks: ,
For-- Items=lparameters:
a' ew /&/ /1" e?' � 5111.'� 4;' � r i % / 61CO3 11 c"2
lrlr //S �f1C/el�lr��sf
710
4 F=g_s Z'a�7 -e.*�� li� � l� F f`Fr��r�c"S
j.`
l �
If you have any questions, please advise.
NOTE: See Reverse For Additional Information Items.
cc: e? n' Regional Groundwater Supervisor
White Copy - Water Quality Section Yellow Copy - Groundwater Section Pink Copy - Regional Office

IJt of Additional Infomnation Items
Groundwatier Section
July 15, 1990
item 1. A general location map, showing orientation of the facility with reference to at least two (2) geographic n'$enmces (numbered roads, named straws/rivers,etc.).
Item 2. A site-specitic crap, with topographic contours (contour tnwrval should not exceed 10 foet or 25 percent of total site mile$ whichever is leas), showing all facility - related structures within the
property boundary and the location of all wells, springs, lakes, ponds, or other surface drainage features within 500 feet of the waste treatment/disposal.site(s). Wells shouldbe labeled as to
their primary usage (drinking water, process water, rrnnitoring, etc)
Item 3. A soil evaluation of the appliation site by a soils scientist to verify the accuracy of the SCS soils map regarding the presence or absence of a seasonally high water table or bedrock within
three vertical feet of the deepest point of sludge application, and to determine the cation exchange capacity of the soils.
item 4. A mil evaluation of the disposal site by a soils scientist down to a depth of seven feet or the 'C' horizon, whichever Is less, to develop a soil map through field evaluation of soil tOdUM, color,
the depth, thickness and type of restrictive horizon(s), the presence or absence of a seasonal high water table or bedrock within throe vertical feet of the deepest point of sludge application,
and cation exchange capacity.
item a A soil evaluation of the disposal site conducted by a soils scientist to adequately evaluate the mils to be utilized far treatment and disposal down to a depth of seven feat to include field
descriptions of texture, color, soucb=,stnuture, the depth, thickness and type of restrictive hodzons, the presence or absence and depth of evidence of any seasonal high water table and
recornsimclations concerning application rates of the waste constituents The investigation should also include field estimates or measurements of saturated hydraulic conductivity in the
most restrictive horizon, and cation exchange capacity. Excavation of test pits may be necessary for proper evaluation of the soils at the site.)
IUm a Proposed location and construction details of a groundwater monitoring well network as specified in Rule .0205(d) of the Regulations (15 NCAC 211. 0200)
Item 7. As per the conditions of your current pemrit you were required to install groundwater monitoring wells. These wells were to be sampled and analyzed according to a schedule and for those.
parameters as specified in the permit A search of our records indicates that, as of the date of the letter, no groundwater monitoring data, crave been received. Please submit all results of
groundwater sampling and analysis which have been obtained to date. If no sampling and/or analyses have been conducixul, you are requested to sample the wells and report the results of
the analyses as specified in the current permit
Item 8. information as to the presence or absence of any wells located within 500 feet of the waste trc atraenn/disposai facility. Any such wells should be accurately bested on the site .map, and
labeled as to their primary usage (Ie, drinking water, monitoring, etc.).
Item 9. A hydrogeologle description of the subsurface, to a depth of 20 feet or bedrock, whichever is less, The number of borings shall be svfHtientto define the fallowing for the area underlying each
major soil type at the disposal site:
(Q significant changes in lithology underlying the site;
(it) the vertical pemrah111ty of the unsaturated zone and the hydraulic conductivity of the saturated zone; and
(iu) depth to the mean seasonal high water table (if de(lable from soil morphology or from evaluation of other appliccable available data)
Item 10. A hydrogeologlc description of the subsurface, to a depth of 20 feet or bedrock, whichever is less The number of boringrs shall be sufficient to define the following for the area underlying each
major soil type at the disposal site:
(d significant changes in lithology underlying the sitc;
(9) the vertical permeabiilty of the unsaturated zone and the hydraulic conductivity of the soruratd zone:
(W) depth to the town seasonal high water table (if definable from soil morphology or from evaluation of other applicable available data);. and
(iv) a determination of ti-ansmisscvity and specific yield of the unconfined aquifer based on a withdrawal or recharge test
Item 11. A hydrogeologc description of the subsurface, which should include information on the vertical and horizontal extent and the lithologic character of the unconfined aquifer. The hydraulic
relationship between the unconfined aquifer and the first, confined aquifer beneath the site should be determined, including the thickness, lithologic character, and vertical pearaability of
the confirming bed. The information must also include a determination of the transmisslvity and specific yield of the unconfined aquifer, detrltr ine d by either a withdrawal or recharge test.
Item 12. A hydrologic evaluation in the area of the proposed waste disposal facility waste disposal facility, which should include the depth to water, direction of movement and quality of groundwater
in the shallow groundwater system, as well as an evaluation of the potential impacts the proposed system may have on groundwater levels, movement and quality.
Item la In order to be in compliance with 15 NCAC 2H .0219 (1), any lagoon or pond used for treatment storage or disposal of waste shall have either a liner of natural material at least one tot in
thickness and leaving a hydraulic conductivity of no greater than 1 x 10 -6 centimeters per second when compacted, or a synthetic liner of sufficient thickness to exhibit 1) structural
integrity, and 2) an effective hydraulic conductivity no greater than that of the natural material liner. Please provide a demil description of the materials used for liners
Item 14. 15 NCAC 2H .0219 (e) specifies that waste shall not be applied or discharged onto or below the land surface when the vertical separation betwe m the waste and the seasonal high water table
Is leers than ONE In EaLC. if any of the area to be utilteed has a separation of less than 17-9* : iA THREE. a demonstration must he made using predictive calculations or modeling rnetiods,
acceptable to the Director, that such placerrment will not result in contravention of classified groundwater standards. Please provide information describing the depth to mean seasonal
highwater table and supportive information for sites with depths Iris than THREE Q) F '1' separation -
Item 15. A recent complete chemical analysis of the typical waste to he discharged, which should include the following parameters
(List parameters)
pain 16, Is the waste which is to be discharged comprised solely of domestic waste, or are there other sources which will contribute to the wastLwate& If so, please provide information as to the
type(s) of waste involved, as well as the anticipated quantity.
Item 17. Boring logs and well construction details for all existing monitoring wells. Such information should Include ground surface elevations at each well location and static water level measure-
ments.
Iten 18. please note that in order to be in comnpiiance with 15 NCAC 2H .0219 (d), the bottom of earthen impoundments, trenches or other similar excavations shall be at least bur feet above the
bedrock surface. If the bottom of the excavation is less than four feet above the bedrock surface, a liner of natural or synthetic material having a hydraulic conductivity no grater than 1 x
10-7 centimeters per second will be required. Please provide Inforation confining compliance with this reguiranent
Items 19. The Information submitted indicates that hand auger borings were advanced at the site. Please indicate the locations of these borings on a site mop. In addition, you are requested to subrnit
complete lithologic descriptions of the borings along with any evidence which may indicate the presence or absence of a seasonal high water tabld
Item 20. Flom the mils maps which were submitted, it Is difficult in sonic cams to positively identify what soil type(s) are ibtmd on various belie Yoiu�are requested to submit revised maps which
clearly show the distribution of the various soil types on each propose( land application site.
Item 21. A characterization of groundwater quality In the vicinity of the lagoons. This characta+zation should be accornpllshed by the Installation of monitoring wells for. the purpose of describing the
hwalogy in the area, and for collecting grotmdwatrr quality samples from the water table aquifer. The locations far these wells are shown on the enclosed map. 'Me well construction details
and sampling methods should be by approval of the Regional office, from which a well construction permit must be obmirie t.
Groundwater samples shall be obtained from each monitoring well and analyzed for the following parameters
(List parameters)
The messurarnent of water level should be taken prior to sampling for the other parameters.
Ltholog)c lags, well construction details and the analytical results of the sampling should be submitted to the Groundwater Section, Division of Environmental Management
Item 22 In order to be in compliance with 15 NCAC 2H .0219 (. j ) (5) M (_), a buffer acne of at least — feet rust be maintained between the perimeter of the disposal field and any property boundary.
It is noted from the submitted plans that portions of the proposed facility lie within_ feet of the property boundary, lase submit revtsod plans which demonstrate compliance with buffer
zone requirements.

DIVISION OF ENVIRONMENTAL MANAGEMENT
ASHEVILLE REGIONAL OFFICE
GROUNDWATER SECTION
October 10, 1991
MEMORANDUM
TO: Brian Wootton
Raleigh Central Office
FROM: Fred C. Hankinson
Asheville Regional Officb''
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

s
11
DIVISIOEN®ALEM3ZMR EMENTAL MANAGEMENT
GROUNDWATER SECTION
October 23, 1991
M E M O R A N D U M FOCT
2 519�i'D
T0: Don Safrit
THROUGH: Bob Chee
Groundwater Section
Asheville Re Tonal Office
FROM: Brian Wootton
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)

i
t'
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
Selenium
Calcium
TDS
pH
Chloride
Total Suspended Solids
Volatile Organic Compounds
method 1 or 2 below)
Orthophosphate
so
Magnesium
TOC
Water Level
Fecal Coliforms
- In December Only (by
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
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

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/l, 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

A.
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: Don Link
Central Files
Permit Issuance Files

_
NEL L BRANCH /� • r' =1, .K 7.. E
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D.B. 3,90, Pg. 477
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PRoPosgD HOA l -roA WEa-S

NOV 2 21991
Groendivater Section
State of North Carolina 16 Asheville Re;;icnal Office
Department of Environment, Health, and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27604
James G. Martin, Governor
William W. Cobey, Jr., Secretary
George T Everett, Ph.D..
Director
November 14, 1991 ;
Regional Offices
Asheville
704l251-6208
Coats American
Highway 221 North
Fayetteville
Marion, North Carolina 28752
919/486-1541
Mooresville
Attn : Mr. Jerry W . Sisk
704/663-1699
Raleigh
SUBJECT: Permit No. WQ 0005603
919/733-2314
Sevier Plant
Recycle System Wastewater Settling Basin
Washington
919/946-6481
McDowell County
Wilmington
Dear Mr. Sisk:
919/395-3900
Winston-Salem
In accordance with the policy of the Division
of
919/896-7007
Environmental Management to ensure the good quality of
North Carolina's groundwater, the referenced Permit
requires several activities related to groundwater
monitoring. The following guidelines are presented
to
assist you in complying with those requirements. If
you
have any questions concerning these matters, you should
contact Don Link at the address shown below to discuss
the
requirements relevant to your specific facility:
Asheville Regional Office
59 Woodfin Place
Asheville, NC 28801
[phone]
1. Condition No.16: The installation of monitor
wells as approved by the Department's
Regional Asheville Office.
THE MONITOR WELLS MUST BE DEVELOPED, TO A TOTAL
SUSPENDED SOLIDS LEVEL NOT EXCEEDING 5 mg/L.
Prior to acce_ptinq a new well, you should verif
that the driller has developed the well to an
acceptable level as stated above. Failure to do
so may result in samples containing excessive
amounts of suspended solids, due to improper well
P.O. Box 29535. Raleigh, North Carolina 276260535 Telephone [phone] / Pollution Prevention Pays
An Equal Oppormn tv AHirmame Action Employer

development, which could lead to analysis and
compliance problems. The North Carolina Well
Construction Standards 15A NCAC 2C .0105 require
that a Permit be issued prior to construction
of any monitoring well, and therefore permit
application forms are attached for your
convenience. To facilitate the permitting
process, you should contact the appropriate
Regional Office personnel as described above, to
discuss the location and construction requirements
relevant to your specific facility.
NOTE: Please disregard the above if installation of
approved monitoring wells has already been
completed.
2. Condition No.17: Sampling of the referenced wells
on the schedule and for the constituents listed
below:
SCHEDULE: The monitor wells must be sampled
initially after construction and
'
"thereafter every April, August and December.
CONSTITUENTS•
COD TDS (500.0)
Chloride (250.0) Orthophosphate
SO44 Fecal Coliforms
TOC Water Level
Tbtal Suspended Solids
pH (6.5-8.5 standard units)
Selenium (0.01) Magnesium
Calcium
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
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 measurement of water levels must be made prior
to sampling for the remaining parameters.
The numbers in parentheses represent the maximum
allowable concentrations in groundwater for the
various analytical parameters, as specified in 15A
NCAC 2L [Groundwater Classifications and
Standards]. Unless otherwise specified, the units
for these concentrations are expressed as
milligrams per liter.
If any volatile organic compounds are detected by
method 6230D, or the equivalent Tethod 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.
If TOC concentrations -greater than 10 mg/l are
detected in any downgradient monitoring well,
additional 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/l, 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.
A supply of forms (GW-59) on which the analytical
results must be reported are attached. Instructions are
provided on the reverse of the white copy of each 4-part
form. The analytical results should be sent to the address
shown at the top of the form and are due in our office no
later than the last working day of the month following
sample collection.
Additional forms will be provided upon receipt of
the attached form GW-59 RO.
FOR ANY ADDITIONAL INFORMATION RELATED TO
REQUIREMENTS FOR GROUNDWATER QUALITY PROTECTION,
PLEASE REFER TO YOUR PERMIT.

C
If you have any questions, please do not hesitate to
contact me at [phone].
Sincerely,
C. Brian Wootton
Hydrogeology Technician
Permits and Compliance
Groundwater Section
CBW/sbp/0005603.
Attachments
c c : tnL-2i gal
Central Files
Compliance Monitoring Files
9

Monday, December 16, 1991
MEMORANDUM
To: Ted Bush,
Assistant Chief for Operations
Groundwater Section
From: Donald Safrit, P.E., Super isor
Permits and Engineering Unit
Subject: Coats American -Sevier Plant
Permit No. WQ0005603
McDowell County
DEC IS 199'
In accordance with agreed upon procedures, please review the attached petition filed with
the Office of Administrative Hearings. Please evaluate the objections raised by the
permittee and provide me with your comments within ten (10) working days of your
receipt of this package.
The items under adjudication are:
See attached petition. TNTC
Miscellaneous comments:
If you have any questions, please contact Randy Jones
cc: Office of the Attorney General
Donald Safrit
Randy Jones

A 1 4
Monday, December 16,1991
MEMORANDUM
To: Forrest Westall
Water Quality Regional Supervisor
Asheville Regional Office Re 1 Office
From: Donald Safrit, P.E., Su rvisor
Permits and Engineering nit
Subject: Coats American -Sevier Plant
Permit No. WQ0005603
McDowell County
In accordance with Water Quality Section procedures, please review the attached petition
filed with the Office of Administrative Hearings. Please evaluate the objections raised by
the permittee and provide me with your comments within ten (10) working days of your
receipt of this package.
The items under adjudication are:
See attached petition. TNTC
Miscellaneous comments:
If you have any questions, please contact Randy Jones
cc: Office of the Attorney General
Donald Safrit
Randy Jones

Adjudications

MOORE & VAN ALLEN
ATTORNEYS AT LAW OTHER OFFICES:
3000 NCNB PLAZA DURHAM, N. C.
CHARLOTTE, N. C. 28280 - 8085 RALEIGH, N. C.
PETER J. McGRATH, JR. TELEPHONE [phone] TELEFAX [phone]
DIRECT DIAL: [phone] TELEX 6843042
CABLE MORVAN
December 10, 1991 `0
Mr. John Seymour
State of North Carolina
Department of Environment, Health and Natural Resources
Division of Environmental Management c�
512 North Salisbury Street
Raleigh, North Carolina 27626-0535
Re: Permit No. WQ0005603/Coats American/Sevier Plant
Recycle System Wastewater Settling Basin/ McDowell
County
Dear Mr. Seymour:
In accordance with the provisions of the North Carolina
Administrative Procedure Act, N.C. Gen. Stat. Section 150B-23(a),
on behalf of Coats American, we are enclosing for service on the
Department of Environment, Health and Natural Resources (the
"Department") Coats American's Petition for a Contested Case
Hearing (the "Petition") regarding the above -referenced permit
(the "Permit").
In addition and also in accordance with North Carolina state
policy as explicitly set forth in the Administrative Procedures
Act at Section 150B-22, we hereby request that the Department
attempt to settle the disputes regarding the Permit, as described
in the enclosed Petition, through informal procedures prior to
the occurrence of a formal contested case hearing.
CHAR_2\F:\DOCS\PJM\LETTER\21131 1

n � ,
John Seymour
December 10, 1991
Page 2
Please contact the undersigned at [phone] to commence
negotiations toward an informal settlement of this matter. In
addition, if you have any questions regarding the enclosed
petition, please contact the undersigned.
Very Truly Yours,
MOORE & VAN ALLEN
Peter J. cGrat Jr.
cc: Ms. Kay Dechant
Mr. Ronald Budnick
Mr. Roger Cothran
Mr. Rex Stuckey
Mr. Rick Gaskins
CHAR 2\F:\DOCS\PJM\LETTER\21131 1

.. 1; �
PLEASE PRINT CLEARLY OR TYPE
STATE OF NORTH CAROLINA
COUNTY OF(I)McDowell
IN THE OFFICE OF
ADMINISTRATIVE HEARINGS
(2) Coats American )
Petitioner,
(Your Name)) tl
rn
PETITION
FOR A
(3) Department of Environment, CONTESTED CASE 1[EARI.\G.;�
Health and Natural Resources )
_ Respondent.
(The State Agency or Board about which you are ) p
complaining) )
1 hereby ask for a contested case hearing as provided for by G.S. 15011-23 because the:
(4) Department of Environment, Health and Natural Resources has:
. (name of agency)
(Briefly state facts showing how you believe you have been harmed by the state agency or board.)
Proposed a nondischaree permit for Petitioner's wastewater settling basin.
which includes parts, requirements and limitations which are unacceptnblp
to Petitioner, all as described more specifically on Appendix A hereto,
which Petitioner incorporates her by reference
(if more space is needed, use addidonaf-sheets and attach)
(5) (Check all that apply) Because of these facts, the agency has:
_deprived me of property;
ordered me to pay a fine or civil penalty;
otherwise substantially prejudiced my
rights; and based on these facts the agency
has exceeded its authority or jurisdiction;
X acted erroneously;
failed to use proper procedure;
=acted arbitrarily or capriciously; or
_failed to act as required by law or rule.
(6) Date:DecemberZt7 1991 (7) Print your name: Peter J. McGrath, Jr
(8) Print your address: Moore & Van Allen, 3000 NCNB Plaza, Charlotte, NC 28280
(9) Your telephone number: [phone] (10) Your
When you have completed this form you MUST mail or deliver the ORIGINAL and one COPY to the Ice of Adminis-
trative Hearings, P.O. Drawer 27447, Raleigh, ,NC: 27611-7447.
AND
You must also mail or deliver a COPY to the State Agency named on line (3) of this form. Please indicate below.
CERTIFICATE OF SERVICE
I certify that this Petition has been served on the State Agency named below by depositing a copy of it with the United States
Postal Service with sufficient postage OR by delivering it to the named agency.
Served on:
(11) Mr. John Seymour (12) Department of Environment, Health and Natur
(name) (agency) Resources
(13) 512 North Salisburg Street, Raleigh, NC 27626-0535
(address)
(14) This the 10 day of December 19 91
(15)
11-06 (419/91)

APPENDIX A
Coats American, has filed herewith a written request (the
"Request") for an adjudicatory hearing relating to proposed
Permit No. WQ0005603 (the "Proposed Permit") covering the Coats
American Sevier Plant Recycle System Wastewater Settling Basin.
Coats American has set forth below the specific parts,
requirements and limitations contained in the Proposed Permit
which substantially prejudice the rights of Coats American,
exceed the agency's authority, are erroneous and are arbitrary or
capricious. The objections of Coats American to the Proposed
Permit that are listed below -are numbered to correspond to the
appropriate Proposed Permit limitations.
Coats American objects to the failure of the Division of
Environmental Management to explore informal dispute resolution
mechanisms, such. as the'auhmission-of a- draft permit to Coats
American for comment, prior to issuance of the final permit, and
request that informal dispute mechanisms be explored prior to any
hearing in this matter.
Paragraph 4. Coats American believes Paragraph 4 provides a
grant of authority to the Division of Environmental Management
(the ""Division") which is unreasonably broad, and will allow the
Division to act in an arbitrary or capricious manner with
substantial prejudice to Coats American's rights. Coats American
requests that Paragraph 4 of the Proposed Permit be deleted and
replaced by a new Paragraph 4 to read as follows:
"In the event the Facilities fail to perform to the
reasonable satisfaction of the Division, including the creation
of nuisance conditions, the Permittee shall take such corrective
action as shall be necessary and appropriate, including those as
may be reasonably required by the Division, such as the
construction of additional or replacement wastewater treatment or
disposal facilities."
Paragraph 5. The permitted facility consists mainly of a
settling basin which has been and is operating continuously.
Consequently, this provision makes no sense. Coats American is
unable precisely to determine the meaning of the term "in advance
of operation of the facility," and is therefore unable to
determine a proper method for compliance with the Paragraph 5
pre -operation notification requirements. The terms "in advance
of operation of the installed facilities" in Paragraph 5 are not
defined. Coats American suggests that the term "Facilities" be
defined in the Proposed Permit preamble to include the existing
nondischarge settling basin for ash from coal-fired boilers and
wastewater from stack scrubbers and all associated piping,
valves, controls, activities and appurtenances discharging into
the ash sluice pond. Coats American then suggests that the
capitalized term "Facilities" (as so defined) be substituted for
the undefined term facilities in all instances throughout the
Proposed Permit. Coats American may then comply with Paragraph 5
CHAR_2\F:\DOCS\PJM\ENVIRONM\19991 1

by notifying the Division forty-eight (48) hours prior to the
effective date of the final permit.
Paragraph 6. There is no reason to believe the permitted
facilities will generate any sludge. Thus, Paragraph 6 is
inapplicable and should be deleted in its entirety.
Paragraph 11. The authority granted to the Division in Paragraph
11 is unreasonably broad and will allow the Division to act in an
arbitrary or capricious manner. Coats American suggests,
therefore, that the word "reasonably" be inserted in the first
line of Paragraph 11, immediately following the word "deemed."
In addition, Coats American requests that the Proposed Permit
include a general procedure for appeal by Coats American (either
to the Director of the Department of Environment, Health and
Natural Resources, or through the Office of Administrative
Hearings) ol'any Division decisions, instructions or orders
relating to the final permit which Coats American believes,
unreasonable, prejudicial, unauthorized, erroneous, arbitrary or
capricious, or contrary to law.
Paragraph 13. The Proposed Permit should explicitly state the
frequency with which Coats American must undertake the specified
maintenance inspections. Coats American expects to undertake
such inspections on a monthly basis.
Paragraph 14. There is no reason to believe that there will be
any leachate associated with the permitted facilities, and
believes that the reference to leachate in Paragraph 14 is
inapplicable and should be deleted. The last sentence of
paragraph 14 should be limited to samples of groundwater or
surface water relating to the Ash Sluice Pond.
_Paragraph 15. Paragraph 15 assumes that there is a contaminant
Plume relating to the ash sluice pond. However, there is no
evidence of any contaminant plume associated with the permitted
facilities. It is unreasonable to require Coats American to
model something that is not known to exist. If a contaminant
Plume exists, 180 days is insufficient time to detect, define and
model the plume. If there is no plume, it is impossible for
Coats American to comply with this paragraph. Therefore, that
Paragraph 15 should be deleted in its entirety.
Paragraph 16. Based upon the available information concerning
the hydrogeologic conditions at the Sevier facility, the
locations for monitoring wells specified in the Proposed Permit
are not hydraulically downgradient from the permitted facilities.
Coats American therefore requests that the Division permit Coats
American to install the required monitoring wells downgradient
from the permitted facilities. The precise downgradient
locations can be identified in the construction permit to be
submitted to the Division's Asheville Regional Office following
the issuance of the final permit. In addition, because Coats
American is required to obtain a separate permit before
installing any new monitoring wells, it is appropriate to begin
CHAR_2\F:\DOCS'\PJM\ENVIRONM\19991 1 - 2 -

running the 180 days from the date of issuance of monitoring well
permits rather than 180 days from the date of issuance of the ash
sluice pond permit.
Par_ aph ;17. There i°fecalreason
coliformbelieve
magnesiumwill
associated
orthophosphate, selenium, .
with the permitted facilities, anThe hsampling at 1parameters hshould
substances will be unnecessary• ling for such substances.
be revised to exclude samp
Paragraph 18. The locations of the he°siteedpl npattachedand
to the
Review Boundaries, as11indicated��on do not comply with the
Proposed Permit (the Site Plan"),
requirements of 15theAstream0are not likely toWells
southeast side of detect conditions
relating to the ash sluice pond. Coats American therefore
requeses .t:,:,at the Compliance Boundary be, relocated
t follted on
ow the
stream bed located south of the ash sluice pond,
the Site Plan.
Paragraph 19. Paragraph
landprovides
allow theaDivisiongrant
tofact in
authority to the Division
an arbitrary and capricious Coatser, which is American rejudicial to
rights of Coats American.
bly" be inserted in the first line of Paragraph
the word "reasona""
19, immediately following the word deemed.In addition, Coats
American reiterates its request inin itially set forth under
Paragraph 11 above, for inclusion
AmericanhofProposed Divisionpdecermit of a
decisions
procedure for appeal y
Coats which Coats American believes to be unreasonable, arbitrary or
capricious.
Paragraph .24. Subparagraphs 24(a), (b) and (c), which relate to
operation of treatment facilities, are inapplicable to the
permitted facilities and should be deleted in their entirety.
Paragraph 25. Paragraph 25 is inapplicable and should be deleted
in its entirety.
This App=ndix.A is hereby incorporated by reference into the
Petition.
CHAR 2\F:\DOCS\PJM\ENVIRONM\19991_1
- 3 -

i
State of North Carolina ;
VERIFICATION
Dowell
County of Mc
being first duly sworn, deposes and says that
`T.g. Stuckey, for Coats American, that he is
he is the Director of Engineering
authorized to Verify
this Petition, and that the factual
information therein
is correct to the best of his knowledge.
information and belief .
W.R. Stuckey
Sworn to and subscribed
before me this the
day
of December 1991,
Notary Public
My commission expires:
- 4 -
CHAR 2\F:\DOCS\PJM\ENVIRON14\19991 1

NOr __DES FACILITY AND PERMIT DATA
RETRIEVE OPTION TRXID 6OU KEY WQ0005603
PERSONAL DATA FACILITY APPLYING
FOR PERMIT APP/PERMIT FEE-$ 250.00 REGION
FACILITY NAME> COATS AMERICAN-SEVIER PLANT 4
COUNTY> MCDOWELL O1
ADDRESS:
MAILING (REQUIRED) ENGINEER:
STREET: HIGHWAY
221 NORTH
STREET:
CITY: MARION
ST NC
ZIP 28752 CITY:
ST ZIP 0
TELEPHONE 704 756
4111
TELEPHONE:
STATE CONTACT> SEYMOUR
FACILITY
CONTACT JERRY W. SISK
TYPE OF PROJECT> RECYCLE FACILITY
LAT: 354725 LONG: 820130
DATE APP RCVD
09/17/91
N=NEW,M=MODIFICATION,R=REISSUE>
R
DATE ACKNOWLEDGED
09/18/91
DATE REVIEWED
09/26/91 RETURN DATE
REG COMM REQS
09/19/91
DATE DENIED
/ / NPDES #-
REG COMM RCVD
10/21/91
DATE RETURNED
/ / TRIB Q .0000 MGD
ADD INFO REQS
10/02/91
OT AG COM REQS
09/19/91 TRIB DATE-
ADD INFO RCVD
10/11/91
OT AG COM RCVD
10/25/91
END STAT APP P
O1/09/92
DATE ISSUED
11/06/91 DATE EXPIRE 10/31/96
FEE CODE( 9)1=(>lMGD),2=(>10KGD),3=(>1KGD),4=(<lKGD+SF),5=(S>300A),6=(S<=300A),
7=(SENDEL),8=(SEDEL),9=(CLREC),0=(NO FEE) DISC CODES 68 16 ASN/CHG PRMT
ENG CERT DATE 11/11/11 LAST NOV DATE / / CONBILL( )
COMMENTS: 244,800 GPD RENEWAL OF 14441
MESSAGE:

^ r %
/'ip,4
Monday, December 16,1991
MEMORANDUM
To: Forrest Westall
Water Quality Regional Supervisor
Asheville Regional Office Re ' 1 Office
From: Donald Safrit, P.E., Su rvisor
Permits and Engineering nit
Subject: Coats American -Sevier Plant
Permit No. WQ0005603
McDowell County
RECEFIVED
Water Qi381itY Se-6on
DEC 2 3 1991
,Asheville Regional Off W
,Ashevitle, North CarotiTO
In accordance with Water Quality Section procedures, please review the attached petition
filed with the Office of Administrative Hearings. Please evaluate the objections raised by
the permittee and provide me with your comments within ten (10) working days of your
receipt of this package.
The items under adjudication are:
See attached petition. TNTC
Miscellaneous comments:
If you have any questions, please contact Randy Jones
cc: Office of the Attorney General
Donald Safrit
Randy Jones

Monday, December 16, 1991
MEMORANDUM
To: Ted Bush,
Assistant Chief for Operations
Groundwater Section
From: Donald Safrit, P.E., Supe isor
Permits and Engineering Unit
Subject: Coats American -Sevier Plant
Permit No. WQ0005603
McDowell County
In accordance with agreed upon procedures, please review the attached petition filed with
the Office of Administrative Hearings. Please evaluate the objections raised by the
permittee and provide me with your comments within ten (10) working days of your
receipt of this package.
The items under adjudication are:
See attached petition. TNTC
Miscellaneous comments:
If you have any questions, please contact Randy Jones
cc Office of the Attorney General
Donald Safrit
Randy Jones

Adjudications 1

PETER J. MCGRATH, JR.
DIRECT DIAL: [phone]
MOORE & VAN ALLEN
ATTORNEYS AT LAW
3000 NCNB PLAZA
CHARLOTTE, N. C. 28280-8085
TELEPHONE [phone]
December 10, 1991
OTHER OFFICES:
DURHAM, N. C.
RALEIGH, N. C.
TELEFA% [phone]
TELEX 6843042
CABLE MORVAN
W
Mr. John Seymour
State of North Carolina -_
Department of Environment, Health and Natural Resources
Division of Environmental Management 1�a
512 North Salisbury Street .-
Raleigh, North Carolina 27626-0535
Re: Permit No. WQ0005603/Coats American/Sevier Plant
Recycle System Wastewater Settling Basin/ McDowell
County
Dear Mr. Seymour:
In accordance with the provisions of the North Carolina
Administrative Procedure Act, N.C. Gen. Stat. Section 150B-23(a),
on behalf of Coats American, we are enclosing for service on the
Department of Environment, Health and Natural Resources (the
"Department") Coats American's Petition for a Contested Case
Hearing (the "Petition") regarding the above -referenced permit
(the "Permit").
In addition and also in accordance with North Carolina state
policy as explicitly set forth in the Administrative Procedures
Act at Section 150B-22, we hereby request that the Department
attempt to settle the disputes regarding the Permit, as described
in the enclosed Petition, through informal procedures prior to
the occurrence of a formal contested case hearing.
CHAR 2\F:\DOGS\PJM\LETTER\21131 1

I �0 l
John Seymour
December 10, 1991
Page 2
Please contact the undersigned at [phone] to commence
negotiations toward an informal settlement of this matter. In
addition, if you have any questions regarding the enclosed
-petition, please contact the undersigned.
cc: Ms. Kay Dechant
Mr. Ronald Budnick
Mr. Roger Cothran
Mr. Rex Stuckey
Mr. Rick Gaskins
Very Truly Yours,
MO'ORE & VAN ALLEN
i
i
Peter J. cGrat Jr.
CHAR 2\F:\DOGS\PJM\LETTER\21131 1

PLEASE PRINT CLEARLY OR TYPE
STATE OF NORTII CAROLINA
COUNTY OF (I) McDowe 11
IN THE OFFICE OF
ADMINISTRATIVE HEARINGS
(2) oats American )
( Petitioner,
Your Name �
V. ) PETITION
rn
FOR A
(3) Department of Environment, CONTESTED CASE IIEARI.NG.
Health and Natural Resources )
Respondent.
(The State Agency or Board about which you are )
complaining) )
I hereby ask for a contested case hearing as provided for by G.S. 150I1-23 because the: {
(4)_Department of Environment Health and Natural Resources
(name of agency) has:
(Briefly state facts showing how you believe you have been harmed by the state agency or board.)
Proposed a nondischarge Dermit for Petitioner's wastewater setting ba in.
which includes Parts, requirements and limitations which are unacceRtablp to Petitioner, all as described more s ecifical on A endix A which Petitioner incorporates herein by reference.
(Or more space is needed. use additional sheets and attach)
(5) (Check all that apply) Because of these facts, the agency has.
_deprived me of property;
ordered me to pay a fine or civil penalty;
=otherwise substantially prejudiced my
rights; and based on these facts the agency
has exceeded its authority or jurisdiction;
(6) Date: December Fc�o1991
(8) Print your address: Moore & Van Allen,
X acted erroneously;
failed to use proper procedure;
=acted arbitrarily or capriciously; or
_failed to act as required by law or rule.
(7) Print vour name: Peter J. McGrath, Jr
3000 NCNB Plaza
(9) Your telephone number: [phone] (10) Your
Charlotte, NC 282
When you have completed this form you MUST mail or deliver the ORIGINAL and one COPY to the ice of Adminis-
trative Hearings, P.O. Drawer 27447, Raleigh, NC 27611-7447.
AND
You must also mail or deliver a COPY to the State Agency named on line (3) of this form. Please indicate below.
CERTIFICATE OF SERVICE
I certify that this Petition has been served on the State Agency named below by depositing a copy of it with the United States
Postal Service with sufficient postage OR by delivering it to the named agency.
Served on:
(II) Mr. John Seymour (12) Department of Environment, Health and Na
(name) (agency)
(13) 512 North Salisburg Street, Raleigh, NC 27626-0535 Resour�
(address)
(14) This the 10 dayof December- , 19 91
(15)
11-06 (()9/91)

-/ 1
APPENDIX A
Coats American, has filed herewith a written request (the
"Request") for an adjudicatory hearing relating to proposed
Permit No. WQ0005603 (the "Proposed Permit") covering the Coats
American Sevier Plant Recycle System Wastewater Settling Basin.
Coats American has set forth below the specific parts,
requirements and limitations contained in the Proposed Permit
which substantially prejudice the rights of Coats American,
exceed the agency's authority, are erroneous and are arbitrary or
capricious. The objections of Coats American to the Proposed
Permit that are listed below are numbered to correspond to the
appropriate Proposed Permit limitations.
Coats American objects to the failure of the Division of
Environmental Management to explore informal dispute resolution
mechanisms, such . as the gubmission of a- draft permit to Coats
American for comment, prior to issuance of the final permit, and
request that informal dispute mechanisms be explored prior hearing in this matter. to any
P_gral,h 4. Coats American believes Paragraph 4 provides a
grant of authority to the Division of Environmental Management
(the "Division") which is unreasonably broad, and will allow the
Division to act in an arbitrary or capricious manner with
substantial prejudice to Coats American's rights. Coats American
requests that Paragraph 4 of the Proposed Permit be deleted and
replaced by a new Paragraph 4 to read as follows:
"In the event the Facilities fail to perform to the
'reasonable satisfaction of the Division, including the creation
of nuisance conditions, the Permittee shall take such corrective
action as shall be necessary and appropriate, including those as
may be reasonably required by the Division, such as the
construction of additional or replacement wastewater treatment or
disposal facilities."
c"
Paragraph 5. The permitted facility consists mainly of a
settling basin which has been and is operating continuously.
Consequently, this provision makes no sense. Coats American is
unable precisely to determine the meaning of the term "in advance
of operation of the facility," and is therefore unable to determine a proper method for compliance with the Paragraph 5
pre -operation notification requirements. The terms "in advance
of operation of the installed facilities" in Paragraph 5 are not
defined. Coats American suggests that the term "Facilities" be
defined in the Proposed Permit preamble to include the existing
nondischarge settling basin for ash from coal-fired boilers and
wastewater from stack scrubbers and all associated piping,
valves, controls, activities and appurtenances discharging into
the ash sluice pond. Coats American then suggests that the
capitalized term "Facilities" (as so defined) be substituted for
the undefined term facilities in all instances throughout the
Proposed Permit. Coats American may then comply with Paragraph 5
CHAR 2\F:\DOCS\PJM\ENVIRONM\19991 1

by
effective ldatethe
ofDivision
forty-eight (48) hours prior to the
permit.
j Paragraph 6. There is no reason to believe the permitted
UV facilities will generate any sludge. Thus, Paragraph 6 is
inapplicable and should be deleted in its entirety,
ara ra h 11. The authority granted to the Division in Paragraph
11 is unreasonably broad and will allow the Division to act in an
arbitrary or capricious manner. Coats American suggests,
therefore, that the word "reasonably" be -inserted in the first
line of Paragraph 11, immediately following the word,"deemed."
n addition, Coats American requests that the Proposed Permit
include a general procedure for appeal by Coats American (either
to the Director of the Department of Environment, Health and
Natural Resources, or through the Office of Administrative
Hearings) of any Division decisions, instructions or orders
relating to the final permit which Coats American believes,
unreasonable, prejudicial, unauthorized, erroneous, arbitrary or
capricious, or contrary to law.
Para ra h 13. The Proposed Permit should explicitly state the
41q
frequency with which Coats American must undertake the specified
maintenance inspections. Coats American expects to undertake
such inspections on a monthly basis.
.Paragraph 14. There is no reason to believe that there will be
any leachate associated with the permitted facilities, and
believes that the reference to leachate in Paragraph 14 is
inapplicable and should be deleted. The last sentence of
paragraph 14 should be limited to samples of groundwater o
surface water relating to the Ash Sluice Pond. r
Paragraph 15. Paragraph 15 assumes that there is a contaminant
plume relating to the ash sluice pond. However, there is no
evidence of any contaminant plume associated with the permitted
facilities. It is unreasonable to require Coats American to
model something that is not known to exist. If a contaminant
Plume exists, 180 days is insufficient time to detect, define and
model the plume. If there is no plume, it is impossible for
Coats American to comply with this paragraph. Therefore, that
Paragraph 15 should be deleted in its entirety.
Paragraph 16. Based upon the available information concerning
the hydrogeologic conditions at the Sevier facility, the
locations for monitoring wells specified in the Proposed Permit
are not hydraulically downgradient from the permitted facilities.
Coats American therefore requests that the Division permit Coats
American to install the required monitoring wells downgradient
from the permitted facilities. The precise downgradient
locations can be identified in the construction permit to be
submitted to the Division's Asheville Regional Office following
the issuance of the final permit. In addition, because Coats
American is required to obtain a separate permit before
installing any new monitoring wells, it is appropriate to begin
CHAR Z\F:\DOCS\PJM\ENVIRONM\19991_1 - 2 -

�W
mq
running the 180 days from tSefromethe dateissuance
issuancemonitoring
the ash
permits rather than 180 day
sluice pond permit.
Paragraph 17. There is no reason to believe there will be any
orthophosphate, selenium, fecal
andltha�samplingor eformsuch associated
with the permitted facilities, samplingparameters should
substances will be unnecessarg forsuchsubstances.
be revised to exclude sampling
Paragraph 18. The locations of the proposed Compliance and
Review Boundaries, as indicated on the site plan attached to the
Proposed Permit (the Site Plan"), do not comply with the
requirements of 15 heAstream0107 and are not likely toells on the
detect conditions
southeast side of the pond. coats American therefore
relating to the ash sluice
reques�.:s .t:�.at the Compliance theuashry be sluiceepondLeastindicated on
stream bed located south
the Site Plan.
Paragraph 19. Paragraph 19 provides too broad -a grant of
authority to the Division and wawiliichtis prejudicial toact
the
an arbitrary and capricious manner,
rights of Coats American. Cort�d�nrthenfirsttherefore
line of requests
aragraphthat
the word "reasonably be rose
19, immediately following the word "deemed." In addition, Coats
American reiterates its request initiallyit of set
Paragraph it above, for Coatssion in p�nerican ofProposed
Division decisionsth under
procedure for appeal by
which Coats American believes to be unreasonable, arbitrary or
capricious.
h'ch relate to
raph 25. Paragraph 25 is inapplicable and should be delete
Parag
in its entirety.
This Appendix.A is hereby incorporated by reference into the
Petition.
(b) and (c) , w i
are inapplicable to the
deleted in their entirety.
CHAR 2\F:\DOGS\PJM\ENVIRONM\19991 1 3

State of North Carolina ; VERIFICATION
County of McDowell
being first duly sworn,
deposes and says that
Stuckey, that he is
' is the Director of that
for Coats American,
he
ify this Petition, and that the factual
auth
or"iced to ver
in is correct to the best of his knowle gee
information
tion there
information and belief.
W.R. Stuckey
Sworn to and subscribed
before mo fthis Cher 1991.
day
Notary Public 9 r
My commission expires:
4
CHAR 2\F:\D0CS\PJH\EHVIR0NM\19991 1

.f a
NON NPDES FACILITY AND PERMIT DATA
RETRIEVE OPTION TRXID 6OU KEY WQ0005603
PERSONAL DATA FACILITY APPLYING
FOR PERMIT APP/PERMIT FEE-$ 250.00
REGION
FACILITY NAME> COATS AMERICAN-SEVIER PLANT 4
COUNTY> MCDOWELL
01
ADDRESS:
MAILING (REQUIRED) ENGINEER:
STREET: HIGHWAY
221 NORTH
STREET:
CITY: MARION
ST NC
ZIP 28752 CITY:
ST
ZIP 0
TELEPHONE 704 756
4111
TELEPHONE:
STATE CONTACT> SEYMOUR
FACILITY
CONTACT JERRY W. S'ISK
TYPE OF PROJECT> RECYCLE FACILITY
LAT: 354725 LONG: 820130
DATE APP RCVD
09/17/91
N=NEW,M=MODIFICATION,R=REISSUE>
R
DATE ACKNOWLEDGED
09/18/91
DATE REVIEWED
09/26/91 RETURN DATE
REG COMM;.REQS
09/19/91
DATE DENIED
/ / NPDES #-
REG COMM RCVD
10/21/91
DATE RETURNED
/ / TRIB Q
.0000 MGD
ADD INFO REQS
10/02/91
OT AG COM REQS
09/19/91 TRIB DATE-
ADD INFO RCVD
10/11/91
OT AG COM RCVD
10/25/91
END STAT APP P
01/09/92
DATE ISSUED
11/06/91 DATE EXPIRE
10/31/96
FEE CODE( 9)1-(>lMGD),2=(>10KGD),3=(>lKGD),4=(<lKGD+SF),5-(S>300A),6=(S<-300A),
7=(SENDEL),8=(SEDEL),9=(CLREC),0=(NO FEE) DISC CODES 68 16 ASN/CHG PRMT
ENG CERT DATE 11/11/11 LAST NOV DATE / / CONBILL( )
COMMENTS: 244,800 GPD RENEWAL OF 14441
MESSAGE:

DIVISION OF ENVIRONMENTAL MANAGEMENT
ASHEVILLE REGIONAL OFFICE
GROUNDWATER SECTION
IL
January 10, 1992
MEMORANDUM
TO: Jim Reid
Water Quality Section
FROM: Kay Dechant�( /
Groundwater Section
SUBJECT: Review of Petition for a Contested Case Hearing
Coats American -Sevier Plant
Permit No. WQ0005603
McDowell County, North Carolina
I have reviewed the objections raised by the subject
permittee. Following are my comments regarding the issues
related to groundwater monitoring and compliance:
PARAGRAPH 11.
Recommendation:
Remain unchanged.
Comments: The request for insertion of the work
"reasonably" implies that the permittee is assuming that
we may require unreasonable monitoring. The Division has
a responsibility and commitment to public trust to
insure that reasonable monitoring is established. The
insertion of the work "reasonably" as requested, could
prompt debate, without resolution, as to the definition
of what is reasonable. .
The subject permit is regulated under G.S., Article 21,
Chapter 143, which contains provisions for hearings and
appeals. It would be cumbersome to state those
provisions as a permit condition.

Memo/Jim Reid/Petition-Coats American/1-10-92 Page 2
PARAGRAPH 15.
Recommendation: Remain unchanged.
Comments: Currently, there exist monitor well K8014
located downgradient of the ash sluice pond. There are
exceedences of the groundwater standards in K8014 for
total dissolved solids (i.e., TDS values up to 780 mg/1).
As the upgradient well does not exceed standards for TDS,
and K8014 located 200 feet downgradient of the ash
sluice pond exceeds groundwater standards, there is
evidence that a contaminant plume is associated with the
permitted facility.
The 180 day time frame is very reasonable.
PARAGRAPH 16.
Recommendation: Should be changed as follows, "Within 90
days of permit issuance, two (2) monitor wells must be
installed at the Compliance Boundary. 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 location
and construction details for these wells must be approved
by the Asheville Regional Office from which a well
construction permit must be obtained".
Comments: There was an error on the site map attached to
the permit in that the compliance boundary should be
shown as 250 feet from the waste boundary. The facility
was -'initially permitted on March 26, 1987.
The 180 day time frame should not be associated with
issuance of the well construction permit.
PARAGRAPH 17.
Recommendation: The sampling parameters should be
revised to exclude orthophosphate and fecal coliform.
Comments: I concur with the permittee that
orthophosphate and fecal coliform would not be expected
to be associated with the permitted facility. However,
selenium and magnesium are components of coal and could
feasibly be associated with the ash sluice pond. Levels
of magnesium are substantially higher in the two
downgradient wells as compared to the upgradient well
presently located at the facility.

Memo/Jim Reid/Petition-Coats American/1-10-92 Page 3
PARAGRAPH 18.
Recommendation: Delete reference to the attached site
map.
Comments: Refer to comments for Paragraph 16. Also, the
request that the compliance boundary be relocated should
be denied. The compliance boundary cannot arbitrarily be
changed, for it is determined by rule in NCAC Title 15
Subchapter 2L.
PARAGRAPH 19.
Recommendation: Remain unchanged.
Comments: Same as comments for Paragraph 11.
LKD/gc
cc: Roy Davis

State of North Carolina
Department of Environment, Health, and Natural Resources
Asheville Regional Office
James G. Martin, Governor Ann B. Orr
William W. Cobey, Jr., Secretary Regional Manager
DIVISION OF ENVIRONMENTAL MANAGEMENT
WATER QUALITY SECTION
January 13, 1992
MEMORANDUM
TO: Roy Davis
THROUGH: Forrest Westal
FROM: Jim Reli.d
SUBJECT: Coats Anferican
Non -discharge Permit WQ0005603
Adjudication Comments
McDowell County.
In response to your request for comments concerning subject issue,
statements are offered below. Statements have been numbered to correlate
with Appendix A of Coats American's petition for adjudication. Attached
to this memorandum are the Ground Water Section's comments on those
items for which you requested their response.
Paragraph 4.
Paragraph 4 should remain as it appears in non -discharge permit
number WQ0005603. The permittee proposes changing "satisfactorily"
to "to the reasonable satisfaction of the Division". Compliance
with the permit is the Division's desire. "Satisfactorily" has
historically been and is currently understood to mean "compliance
with the permit". The proposed change unnecessarily adds ambiguity
by suggesting that something other than permit compliance might
reasonably satisfy the Division.
Permittee proposes inserting into paragraph 4 "as shall be necessary
and appropriate" and "as may be reasonably required by the Division"
(emphasis added). No additional protections would be offered the
permittee by the changes requested. Only those actions "necessary
Interchange Building, 59 WoodHn Place, Asheville, N-C. 28801 • Telephone [phone]
:\n 1-MMI thnwrcunity Al III aVIII III I.innl„vcr

and appropriate" to reestablish permit compliance would be sought by
the Division. The permittee could refuse to perform any action
suggested by the Division'which the permittee believed unreasonable.
The Division and its representative(s) would be liable for
negligence should it require Coats American to implement any
unreasonable, unnecessary, or inappropriate actions.
Paragraph 5.
Delete paragraph 5 in accordance with the permittee's request. The
facility is in operation; the "notify prior to operation"
requirement is therefore unnecessary.
No modification of the permit to include the term "Facilities" is
necessary. The permit specifies those items of treatment equipment
which are governed by the permit. No additional explanation is
believed to be required.
Paragraph 6.
Do not change paragraph 6. -The facility will most certainly
generate "sludge" as defined at 15 NCAC 2H..0203 (20). Paragraph 6
is therefore applicable.
Paragraph 13.
Do not change paragraph 13. Coats American, in their petition,
states an intent to undertake inspections monthly. Should some
change in facilities operation necessitate increased or decreased
inspections, Coats American would be able to respond in a
situationally appropriate manner under the permit as written. With
an inspection schedule precisely defined in the permit, permit
modification would be required prior to Coats Americans ability to
change the schedule.
Paragraph 14.
Do not modify paragraph 14. Under certain.conditions, leachate from
unlined earthen lagoons (such as the one operated by Coats American
under permit WQ0005603) could be reasonably expected. There is no
basis for deletion of the word "leachate".
Paragraph 24.
Retain paragraph 24 as written. Unusual situations and system
failures could be envisioned which would necessitate Coats Americans
notifying the Division.
Paragraph 25.
Do not modify or delete paragraph 25. The Division intends to
classify non -discharge type facilities at some point in the future
and intends to require certified operators for such facilities. The
Division would wish that the certification requirement apply to
Coats American at the appropriate time.
Please see me if clarification or additional information is needed.

L
Memo/Jim Reid/Petition-Coats American/1-10-92 Page 2
PARAGRAPH 15.
Recommendation: Remain unchanged.
Comments: Currently, there exist monitor well K8014
located downgradient of the ash sluice pond. There are
exceedences of the groundwater standards in K8014 for
total dissolved solids (i.e., TDS values up to 780 mg/1).
As the upgradient well does not exceed standards for TDS,
and K8014 located 200 feet downgradient of the ash
sluice pond exceeds groundwater standards, there is
evidence that a contaminant plume is associated with the
permitted facility.
The 180 day time frame is very reasonable.
PARAGRAPH 16.
Recommendation: Should be changed as follows, "Within 90
days of permit issuance, two (2) monitor wells must be
installed at the Compliance Boundary. 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 location
and construction details for these wells must be approved
by the Asheville Regional Office from which a well
construction permit must be obtained".
Comments: There was an error on the site map attached to
the permit in that the compliance boundary should be
shown as 250 feet from the waste boundary. The facility
was initially permitted on March 26, 1987.
The 180 day time frame should not be associated with
issuance of the well construction permit.
PARAGRAPH 17.
Recommendation: The sampling parameters should be
revised to exclude orthophosphate and fecal coliform.
Comments: I concur with the permittee that
orthophosphate and fecal coliform would not be expected
to be associated with the permitted facility. However,
selenium and magnesium are components of coal and could
feasibly be associated with the ash sluice pond. Levels
of magnesium are substantially higher in the two
downgradient wells as compared to the upgradient well
presently located at the facility.

DIVISION OF ENVIRONMENTAL MANAGEMENT
ASHEVILLE REGIONAL OFFICE
GROUNDWATER SECTION
January 10, 1992
MEMORANDUM
TO: Jim Reid
Water Quality Section
FROM: Kay Dechant )2
Groundwater Section
SUBJECT: Review of Petition for a Contested Case Hearing
Coats American -Sevier Plant
Permit No. WQ0005603
McDowell County, North Carolina
I have reviewed the objections raised by the subject
permittee. Following are my comments regarding the issues
related to groundwater monitoring and compliance:
PARAGRAPH 11.
Recommendation:
Remain unchanged.
Comments: The request for insertion of the work
"reasonably" implies that the permittee is assuming that
we may require unreasonable monitoring. The Division has
a responsibility and commitment to public trust to
insure that reasonable monitoring is established. The
insertion of the work "reasonably" as requested, could
prompt debate, without resolution, as to the definition
of what is reasonable.
The subject permit is regulated under G.S. Article 21,
Chapter 143, which contains provisions for hearings and
appeals. It would be cumbersome to state those
provisions as a permit condition.

f `
Memo/Jim Reid/Petition-Coats American/1-10-92 Page 3
PARAGRAPH 18.
Recommendation: Delete reference to the attached site
map.
Comments: Refer to comments for Paragraph 16. Also, the
request that the compliance boundary be relocated should
be denied. The compliance boundary cannot arbitrarily be
changed, for it is determined by rule in NCAC Title 15
Subchapter 2L.
PARAGRAPH 19.
Recommendation: Remain unchanged.
Comments: Same as comments for Paragraph 11.
LKD/gc
cc: Roy Davis

' `• d ST Z
State of North Carolina
Department of Environment, Health, and Natural Resources
Asheville Regional Office
James G. Martin, Governor
William W. Cobey, Jr., Secretary
DIVISION OF ENVIRONMENTAL MANAGEMENT
January 15, 1992
10100[e);i`a1lilui
TO: Don Safrit, Supervisor
Permits and Engineering Section
FROM: Roy M. Davis
Regional Supervisor p`
SUBJECT: Petition for Contested Case Hearing
Permit Number WQ0005603
Coats American
Sevier Plant
McDowell County
Ann B. Orr
Regional Manager
In accordance with your memorandum request dated December 16, 1991, we
offer as an attachment our response to issues raised in Coats American
petition for a contested case hearing.
Enclosure
xc: Jon Link,
Forrest R. Westall/
Interchange Building, 59 Woodfin Place, Asheville, N.C. 28801 • Telephone [phone]
An F(iu.d C)igr);unity :\11irmativu A�u,m l.mplu cr

t_
s
Groundwater Section
January 23, 1992
MEMORANDUM
TO: Don Safrit
I ROUGH: 'Ted h
FROM: Bob Cheek
SUB=: Adjudication of Permit
Permit No. WQ0005603
Coats American, Inc - Sevier Plant
McDowell County
The Groundwater Section has reviewed the subject adjudication of
permit No. WQ0005603 issued November 6, 1991. , The following are
comments listed by item:
#4 - This condition is considered standard and should remain in
the permit. It may be prudent to include a statement in the
permit cover letter that states the Division's willingness to
coordinate any additional requirements with the permittee.
#5 - This condition should be deleted.
#6 - The permittee states that no sludge is generated, however,
what will they do with the sludge in the lagoon? This
condition should remain since the permittee may decide to
empty the lagoon sludge and dispose of the material.
#11 - This is a standard condition and should remain. See comments
under #4.
#13 -.We have no problem stating monthly inspections in this
condition.
#14 - The Groundwater Section is concerned with the potential of
leachate contaminating groundwater. However, sampling of
subsurface leachate is next to impossible. The only way to
sample leachate impact would be through groundwater samples.
Furthermorerleachate may result in a surface water problem
from material leaching through the lagoon sidewalls. If this
is the case sampling of this runoff would be appropriate.
Therefore we recommend that the current verbage remain
unchanged, to allow us the opportunity to sample any
leachate resulting in runoff.

#15 - The existing monitoring wells currently show contamination,
contrary to the permittee's assertion. New wells were
requested because the existing wells were not properly
located. We concede this condition may have been premature,
given these facts. Modeling can be required in the future
should the new wells show contamination at the review
boundary. Therefore, we recommend deletion of this
condition.
#16 - The permittee should be required to acquire a well
construction permit and install the wells soon after permit
issuance. The 180 days is too long a period to wait for new
wells. Furthermore, their proposal creates an indefinite
time frame for acquisition of a well construction permit.
Therefore, we do not concur with their request and recommend
that the request be denied.
#17 - We do agree that magnesium, orthophosphate and fecal coliform
are inappropriate. Historically they have been required to
monitor these parameters. As for selenium, this element is
typical of coal ash and should be monitored.
#18 - The well locations referenced on the site map are generally
given. Specific locations are coordinated with the regional
offices. A statement explaining that specific locations can
be determined in coordination with the Asheville Regional
Office and other site specific criteria as appropriate.
#19 - This is a standard condition and should remain. See comments
under #4.
#24 - This is a standard condition and should remain in the permit.
#25 - We concur with the permittee that this condition should be
modified to reflect their current certification status.
If there are any questions, please let me know.
BC/TB/JF:ja/Coasts.
cc:DonxLink
Central Files
Permit Files

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RECEIVED
its t
Water QuNlity Section
o � � � MAR 11 , 0 �"92
Asheville Regional Oi i
State of North Carolina Asheville, North Carolir
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
Director
William W. Cobey, Jr., Secretary March 9, 1992
Mr. W. R. Stuckey
Director of General Engineering
Coats American
Post Office Box 670
Toccoa, Georgia 30577
Dear Mr. Stuckey:
Subject: Draft Permit Transmittal
Permit No. WQ0005603
Coats American
Sevier Plant
Wastewater Recycle System
Settling Basin
McDowell County
On November 6, 1991, the Division of Environmental Management issued Permit No.
WQ0005603 to Coats American for the operation of the subject wastewater recycle facilities. On
December 15, 1991, the Division received a Petition for a Contested Case Hearing from attorneys for the
Petitioner which specified several objections to some of the conditions and limitations expressed in Permit
No. WQ0005603, which was issued on November 6, 1991. On February 19, 1992, a meeting was held
between representatives of Coats American and the Division of Environmental Management to discuss the
issues associated with the contested case. As indicated in the meeting, a draft permit has been developed
for your consideration.
Objection 1: Coats American objects to condition 4, which basically states that if the facilities fail to
perform satisfactorily, the Permittee will be required to take immediate corrective actions,
including the construction of additional or replacement wastewater treatment or disposal
facilities. The Permittee proposes replacing the term "perform satisfactorily" with the term
"perform to the reasonable satisfaction of the Division" and proposes to replace the
requirement for taking'immediate corrective actions with the requirement to take corrective
actions that may be reasonably required by the Division.
Response 1: This condition is a standard condition that is placed in essentially all permits. The intent is
to enable the Division to require the Permittee to take whatever corrective actions are
necessary to ensure compliance with the permit. We feel that the suggested wording
modifications will add ambiguity to the ability of this permit to accomplish its intent;
- therefore, this condition has not been modified.
Regional Offices
Asheville Fayetteville Mooresville Raleigh Washington Wilmington Winston-Salem
704/251-6208 919/486-1541 704/663-1699 919/733-2314 919/946-6481 919/395-3900 919/761-2351
Pollution Prevention Pays
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

Mr. W. R. Stuckey
March 9, 1992
Page 2
Objection 2: Coats American questioned the appropriateness of having condition 5 in the permit.
Response 2: Condition 5 was placed in this permit in error and has been deleted.
Objection 3: Coats American has requested that the term "facilities" be defined.
Response 3: The narrative portion of the permit on page 1 has been modified by inserting the words for
the operation of the existing "wastewater recycle facilities", which consist of...
Objection 4: Coats American objects to condition 6, which deals with sludge disposal, and states that its
facility will not generate any sludge.
Response 4: The residuals in the settling basin are characterized as sludge, as defined in 15A NCAC 2H
.0203, definition number (20). This condition is placed in all permits of this type to inform
the Permittee that there are requirements that must be adhered to should the settling basin be
cleaned out.
Objection 5: Coats American objects to condition 11, which .allows the Division to require any
monitoring that it deems necessary. Coats American has also requested that a general
appeal procedure be incorporated into the permits.
Response 5: Condition 11 has been modified by adding a sentence which indicates the Division's
willingness to coordinate any future additional requirements with Coats American;
however, the Division must maintain its ability to require any additional monitoring that it
finds necessary for the protection of the surface waters and groundwaters.
The attached draft permit contains a statement that indicates that it is final; however, all new
permits or modifications originating from the Division contain provisions for appeal.
Objection 6: Coats American objects to condition 13, which requires that the Permittee inspect the
recycle facilities to prevent malfunctions and deterioration, etc.
Response 6: Condition 13 intentionally places the burden on the Permittee to conduct inspections at the
frequency that is necessary to prevent malfunctions and deterioration, etc. This condition
has not been modified. Coats American can discuss its inspection frequency with the
Asheville Regional Office to obtain advice on its reasonableness.
Objection 7: Coats American objects to the portion of condition 14 which refers to leachate.
Response 7: Since there is the potential for material to leach through the unlined lagoon into the
groundwater or to leach through the lagoon sidewalls and to become a surface water
problem, this condition has not been modified.
Objection 8: Coats American objects to the requirement in condition 15 to model a contaminant plume.
Response$: New properly located wells have been requested. If these wells indicate problems, the
Division will require modeling in the future; therefore, condition 15 has been deleted from
the permit.
Objection 9: 'Coats American states that the specified locations for the monitoring wells required in
condition 16 are not hydraulically downgradient of the permitted facilities and requests that
the time frames specified for installation be extended.
Response 9: A new map has been provided which revises the location of the monitoring wells. The
Division feels that the specified time frames are reasonable; therefore, they have not been
revised.

Mr. W. R. Stuckey
March 9, 1992
Page 3
Objection 10: Coats American objects to some of the sampling parameters that have been specified in
condition 17.
Response 10: Condition 17 has been modified by deleting the requirement for sampling orthophosphate
and fecal coliform. .
Objection 11: Coats American stated that the locations referred to for the Compliance and Review
Boundaries in condition 18 do not comply with the applicable regulations.
Response 11: A revised map has been provided.
Objection 12: Coats American objects to condition 19, which allows the Division to require any
groundwater monitoring that it deems necessary.
Response 12: The requirements of this condition have already been discussed in response 5.
Objection 13: Coats American objects to some of the wording in condition 24.
Response 13: Condition 24 has been modified to make it more specific to the recycle facilities.
Objection 14: Coats American objects to condition 25, which is the requirement for a wastewater
treatment plant operator.
Response 14: According to the current regulations, a wastewater treatment plant operator is not required
for this recycle facility; however, condition 25 is typically placed in all such permits. The
portion of condition 25 which states "upon classification of the facility by the certification
commission" signifies that an operator is not required until the Division notifies Coats
American.
Please review the attached draft permit and submit written comments directly to Mr. Randy Jones,
of my staff, by March 23, 1992, either stating Coats American's acceptance of the draft permit or
describing those conditions with which you still have concerns. If you have concerns with the draft permit
and we can come to no further agreements, the Attorney General's office will be so informed and the
adjudicatory hearing process can continue. If you are willing to accept the draft, please execute the
attached "Notice of Withdrawal."
If you have questions concerning this matter, please contact Mr. Randy Jones at 919/ 733-5083.
Sincerely,
. tc a .
Donald it, P. E., Supervisor
Water Quality Permits and Engineering
Attachments.:-..:.
cc: Asheville Regional Office, Water Quality (with attachments)
roun water Section, ack Floyd (with attachments)
Attorney General's Office, File No. 91 EHR 1392, Betsy Rouse (with attachments)
Peter J. McGrath, Jr. (Moore & Van Allen, 3000 NCNB Plaza, Charlotte, NC 28280) (with attach.)
Randy Jones (with attachments)

p:.. is ...
State of North Carolina
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
� Director
Mr. W. R. Stuckey
Director of General Engineering
Coats American
Post Office Box 670
Toccoa, Georgia 30577
Subject: Permit No. WQ0005603
Coats American
Sevier Plant
Wastewater Recycle System
Settling Basin
McDowell County
Dear Mr. Stuckey:
On November 6, 1991, the Division of Environmental Management issued Permit No.
WQ0005603 to Coats American for the operation of the subject wastewater recycle facilities. On
December 15, 1991, the Division received a Petition for a Contested Case hearing from attorneys for Coats
American which specified several objections to some of the conditions and limitations expressed in Permit
No. WQ0005603, which was issued on November 6, 1991. As a result of the submitted Petition and a
subsequent meeting between representatives of Coats American and the Division, Permit No. W00005603
is being reissued.
This permit shall be final and effective from the date of issuance until October 31, 1996, shall void
Permit No. WQ0005603, which was issued on November 6, 1991, and shall be subject to the conditions
and limitations as specified therein. Please pay particular attention to the monitoring requirements in this
permit. Failure to establish an adequate system for collecting and maintaining the required operational
information will result in future compliance problems.
Regional Offices
Asheville Fayetteville Mooresville Raleigh Washington Wilmington Winston-Salem
704/251-6208 9191486-1541 704/663-1699 919/733-2314 919/946-6481 919/395-3900 919/761-2351
Pollution Prevention Pays
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

Mr. W. R. Stuckey
March 9, 1992
Page 2
If you need additional information concerning this matter, please contact Mr. Randy Jones at 919/
733-5083.
Sincerely,
George T. Everett
cc: McDowell County Health Department
Asheville Regional Office, Water Quality
Asheville Regional Office, Groundwater
Training and Certification (no revised rating)
Facilities Assessment Unit
Groundwater Section, Jack Floyd
Attorney Generals Office, File No. 91 EHR 1392, Betsy Rouse
Peter J. McGrath, Jr. (Moore & Van Allen, 3000 NCNB Plaza, Charlotte, NC 28280)

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
RALEIGH
RECYCLE SYSTEM PERMIT
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina,
as amended, and other applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
Coats American
McDowell County
FOR THE
operation of the a st rlg astewate xecyc aG� ,�;,•�which consists of a settling basin for ash from coal-
fired boilers, wastewater from stack scrubbers, and all associated piping, valves, controls and
appurtenances to serve Coats American Sevier Plant with no discharge of wastes to the surface waters,
pursuant to the adjudication request received on December 15, 1991 and in conformity with the project
Plan, specifications, and other supporting data subsequently filed and approved r the Department of
Environment, Health and Natural Resources and considered a part of this permit.
This permit shall be effective from the date of issuance until October 31, 1996, shall void Permit No.
WQ0005603, which was issued on November 6, 1991, and shall be subject to the following specified
conditions and limitations:
1. This permit is effective only with respect to the nature and volume of wastes described in
the application and other supporting data.
2. The facilities shall be properly maintained and operated at all times.
3. This permit is not transferable. In the event there is a desire for the facilities to change
ownership, or there- is a name change of the Permittee, a formal .permit request must be
submitted to the Division of Environmental Management accompanied by an application
fee, documentation from the parties involved, and other supporting materials as may be
appropriate. The approval of the request will be considered on its merits and may or may
not be approved.
4. - In the event that the facilities fail to perform satisfactorily, including the creation of
nuisance conditions, the Permittee shall take immediate corrective action, including those as
- -" may be required by this Division, such as the construction of additional or replacement
wastewater treatment or disposal facilities.
5. The sludge generated from these treatment facilities must be disposed of in accordance with
General Statute 143-215.1 and in a manner approved by the North Carolina Division of
Environmental Management.
6• The issuance of this permit shall not relieve the Permittee of the responsibility for damages
to surface or ground waters resulting from the operation'of this facility.
1

7. The facilities shall be effectively maintained and operated as a non -discharge system to
prevent the discharge of any wastewater resulting from the operation of this facility.
8. Diversion or bypassing of untreated wastewater from the treatment facilities is prohibited.
9. Freeboard in the ash settling pond shall not be less than two feet at any time.
10. Any monitoring deemed necessary by the Division of Environmental Management to insure
surface and groundwater protection will be established and an acceptable sampling
reporting schedule shall be followedeA>a`sronw,t�lalttem c�cad'lsaate, an
entsith CoaAmerican
11. Adequate inspection, maintenance, and cleaning shall be provided by the Permittee to
insure proper operation of the subject facilities.
12. The Permittee or his designee shall inspect the wastewater recycle facilities to prevent
malfunctions and deterioration, operator errors and discharges which may cause or lead to
the release of wastes to the environment, a threat to human health, or a nuisance. The
Permittee shall keep an inspection log or summary including at least the date and time of
inspection, observations made, and any maintenance, repairs, or corrective actions taken
by the Permittee. This log of inspections shall be maintained by the Permittee for a period
of three years from the date of the inspection and shall be made available upon request to
the Division of Environmental Management or other permitting authority.
13. Any duly authorized officer, employee, or representative of the Division of Environmental
Management may, upon presentation of credentials, enter and inspect any property,
premises or place on or related to the recycle system at any reasonable time for the purpose
of determining compliance with this permit; may inspect or copy any records that must be
kept under the terms and conditions of this permit; or may obtain samples of groundwater,
surface water, or leachate.
14. Within 90 days of permit issuance, two (2) monitor wells must 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 location and construction details for these wells must be approved by
the Asheville Regional Office, from which a well construction permit must be obtained.
15. The two (2) new monitor wells must be sampled initially after construction and all wells
i shall be sampled every April, August, and December for the following parameters:
COD TDS
TOC pH
Selenium Chloride
Water Level Total Suspended Solids
SO4 Magnesium
Calcium
Volatile Organic Compounds - In December only (by Method 1 or Method 2 below)
Method 1: Method 6230D ( Capillary - Column), "Standard Methods for the
Examination of Water and Wastewater", 17th edition, 1989
Method 2: Method 502.2 " Methods for the Determination of Organic Compounds in
Drinking Water", United States Environmental Protection Agency - 600/4-
88/039
2

.4
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
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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 to of the
casing. P
If TOC concentrations greater than 10 mg/l are detected in any downgradient monitoring
well, additional 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/l, 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 analysis 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.
16. The Compliance Boundary delineated on the attached site plan for the disposal system is
specified by regulations in 15 NCAC 2L, Classifications and Water Quality Standards
applicable to the groundwater of North Carolina. An exceedance of Groundwater Quality
Standards beyond the Compliance Boundary is subject to penalty provisions applicable
under General Statute 143-215.6A. The sale of property, by the Permittee, which is within
or contiguous to the disposal system site may alter the location of the Comliance
Boundary. p
For facilities permitted on or after December 30, 1983, the Compliance Boundary is
established at the lesser of 250 feet from 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 Division 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.
17. Any groundwater quality monitoring as deemed necessary -by the Division of
Environmental Management shall be p ovided. MMIKrsosa will attempt t® conrinate atiy
dtion , �r �qua'rea%vaithC ao-Arriecan:
3

8 • The annual administering and compliance fee must be paid by the Permittee within thirty
(30) days after being billed by the Division. Failure to pay the fee accordingly may cause
the Division to initiate action
v (c)(4) to revoke this permit as specified by 15 NCAC 2H .0205
19. Failure to abide by the conditions and limitations contained in this permit may subject the
Permittee to an enforcement action by the Division of Environmental Management in
accordance with North Carolina General Statute 143-215.6A to 143-215.6C.
20. The issuance of this permit does not preclude the Permittee from complying with any and
all statutes, rules, regulations, or ordinances which may be imposed by other government
agencies (local, state, and federal) which have jurisdiction.
21. A set of approved plans and specifications for the subject project must be retained by the
Permittee for the life of this project.
22. Noncompliance Notification:
The Permittee shall report by telephone to the Asheville Regional Office, telephone no. 704/
251-6208, as soon as possible, but in no case more than 24 hours or on the next working
day following the occurrence or first knowledge of the occurrence of any of the following:
a. Any occurrence at h wastewat r ec �c )4which results in the treatment of
significant amounts of wastes which are abnormal in quantity or characteristic, such
as the dumping of the contents of a basin or tank; the known passage of a slug of
hazardous substance through the facility; or any other unusual circumstances.
b. Any process unit failure, due to known or unknown reasons, that render the recycle
facility incapable of adequate wastewater treatment such as mechanical or electrical
failures of pumps, aerators, compressors, etc.
C. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-
pass directly to receiving waters without treatment of all or any portion of the
influent to such station or facility.
d. Any time that self -monitoring information indicates that the recycle facility is not in
compliance with its permit limitations.
Persons reporting such occurrences by telephone shall also file a written report in letter
form within 15 days following first knowledge of the occurrence. This report must outline
the actions taken or proposed to be taken to ensure that the problem does not recur.
23. Upon classification of the facility by the Certification Commission, the Permittee shall
employ a certified wastewater treatment plant operator to be in responsible charge of the
wastewater treatment facilities. The operator must hold a certificate of the type and grade at
least equivalent to the classification assigned to the wastewater treatment facilities by the
Certification Commission.
24. The Permittee, at least six (6) months prior to the expiration of this permit, shall request its
= extension. Upon receipt of the request, the Commission will review the adequacy of the
facilities described therein, and if warranted, will extend the permit for such period of time
and under such conditions and limitations as it may deem appropriate.
4

Permit issued this the V w
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COM USSION
- - _ George T. Everett, Director
Division of Environmental Management
By Authority of the Environmental Management Commission
Permit No. WQ0005603
5

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STATE OF NORTH CAROLINA
COUNTY OF MCDOWELL
FILE No. 91 EHR 1392
_Coats American,
Petitioner,
V.
DEPARTMENT OF ENVIRONMENT,
HEALTH, AND NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL
MANAGEMENT
Respondent.
IN THE OFFICE OF
ADMIlVISTRATIVE HEARINGS
NOTICE OF WITHDRAWAL
OF PETITION
Petitioner hereby withdraws its petition for a contested case hearing. No further proceedings
are needed or required to resolve the contested case captioned above.
This the day of
19_.
Petitioner/Authority for Petitioner
CERTIFICATE OF SERVICE
I hereby certify that I have served a copy of the attached NOTICE OF WITHDRAWAL, by
having same placed in the United States Mail bearing sufficient postage for delivery by first class
mail and addressed as follows:
(Date)
Attorney General's Office
N.C. Department of Justice
P.O. Box 629
Raleigh, North Carolina 27602-0629
Petitioner/Attorney for Petitioner

Coats American
April 2, 1992
Kay Dechant
59 Woodf in P1.
Asheville, N. C. 28808
RE: GROUND WATER MONITORING
Dear Kay:
Coats American
Post Office Box 368
Marion, North Carolina 28752
Telephone [phone]
Fax [phone]
As you know, we sample our monitoring wells quarterly for
various parameters. Recently, both the quality and quantity
of water taken from the wells have dropped to the point that
accurate information can't be obtained from these wells.
Please accept this letter as an official request to postpone
further testing of our monitoring wells until new'wells can,
be constructed. We expect the new wells to be in'operation
within ninty (90) days.
Please feel free to call if you have questions.
Sincerely,
Jerry McKinney
Environmental Manager
APR --1 1992
A m—,bv, :`! the Coate V,yella C.,roup

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State of North Carolina
Department of Environment, Health and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27604
James G. Martin, Governor George T. Everett, Ph.D
William W. Cobey, Jr., Secretary Director
Regional Offices
Asheville
704/251-6208
Fayetteville
919/486-1541
Mooresville
704/663-1699
Raleigh
919/571-4700
Washington
919/946-6481
April 30, 1992
Coats American
Post.Office Box 670
Toccoa, Georgia 30577
Attn: Mr. W. R. Stuckey
SUBJECT: Permit No. WQ0005603
Sevier Plant
Wastewater Recycle System
McDowell County:
Dear Mr. Stuckey:
Wilmington In accordance with the policy of the Division of
919/395-3900 Environmental Management to ensure the g good quality of
North Carolina's groundwater, the referenced Permit.
Winston-Salem requires several activities related to groundwater
9.19/896-7007 monitoring. The following
guidelines are presented to
assist you in complying with those requirements. If you
have any questions concerning these matters, you should
contact Don Link at the address shown below to discuss the
requirements relevant to your specific facility:
Asheville Regional Office
59 Woodfin Place
Asheville, NC 28801
[phone]
Condition No. 14: The installation of monitor wells as
approved by the Department's Asheville Regional
Office.
THE MONITOR WELLS MUST BE DEVELOPED TO A TOTAL
SUSPENDED SOLIDS LEVEL NOT EXCEEDING,5 mg/L.
Pollution Prevention Pays
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]

Prior to accepting a new well, you should verify that
the driller has developed the well to anacceptable
level as stated above. Failure to do so may result in
samples containing excessive amounts of suspended
solids, due to improper well development, which could
lead to analysis and compliance problems. The North
Carolina Well Construction Standards 15A NCAC 2C .0105
require that a Permit be issued prior to construction
of any monitoring well, and therefore permit
application forms are attached for your convenience.
To facilitate the permitting process, you should
contact the appropriate Regional Office personnel as
described above, to discuss the location and
construction requirements relevant to your specific
facility.
NOTE: Please disregard the above if installation of
approved monitoring wells has already been
completed.
Condition No. 15: Sampling of the referenced wells on
the schedule and for the constituents listed
below:
SCHEDULE: The monitor wells must be sampled
initially after construction and
thereafter every April, August and December.
CONSTITUENTS:
Calcium COD
Chloride (250.0) TDS (500.0)
SO (250.0) TOC
Water Level Total Suspended Solids
Selenium (0.01) Magnesium
pH (6.5-8.5 standard units)
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
The measurement of water levels must be made prior to
sampling for the remaining parameters.

The numbers in parentheses represent the maximum
allowable concentrations in groundwater for the
various analytical parameters, as specified in 15A
NCAC 2L [Groundwater Classifications and Standards].
Unless otherwise specified, the units for these
concentrations are expressed as milligrams per liter.
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.
If TOC concentrations greater than 10 mg/1 are
detected in any downgradient monitoring well,
additional 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/l, this concentration will be taken to represent the.
naturally occurring TOC concentration. Any exceedances
of this naturally occuring TOC concentration in the
downgradient wells shall be subject to the additional
sampling and analysis as described above.
A supply of forms (GW-59) on which the analytical
results must be reported are attached. Instructions are
provided on the reverse of the white copy of each 4-part
form. The analytical results should be sent to the address
shown at the top of the form and are due in our office no
later than the last working day of the month following
sample collection.
Additional forms will be provided upon receipt of the
attached form GW-59 RO.
FOR ANY ADDITIONAL INFORMATION RELATED TO REQUIREMENTS
FOR GROUNDWATER QUALITY PROTECTION, PLEASE REFER TO
YOUR PERMIT.

If you have any questions, please do not hesitate to
contact me at [phone].
CBW:hl:Stuckey
Attachments
cc: SPEWRIM
Central Files
Compliance Monitoring Files
Sincerely,
C. Brian Wootton
Hydrogeology Technician
Permits and Compliance
Groundwater Section
MAY —71992 D

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