WQ0005603_Correspondence_20100421

NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
David Goodrich
Division of Water Quality
Aquifer Protection Section
1636 Mail Service Center
Raleigh, NC 27699-1636
Subject: Permit Modification Request
Division of Water Quality
Coleen H. Sullins
Director
April 21, 2010
Coats American, Incorporated
Wastewater Recycle System (Ash Basin)
Permit No. WQ0005603
McDowell County
)ear Mr. Goodrich,
Dee Freeman
Secretary
The Asheville Regional Office (ARO) would like to request modification to the subject permit. The
modification is to add the parameter of Iron (Fe) to the current monitoring requirements. Therefore, we are
requesting monitoring wells #10, 411, #12 and #14 be monitored every April, August and December for Fe.
The reason for the request is as follows: The ARO issued a Notice of Violation (NOV-2009-LV-3609) on
August 25, 2009 for violations of Groundwater Quality Standards at four monitoring wells located outside of
the review boundary for the Coats American -- Sevier Plant coal ash basin. As a result, a limited site assessment
was performed by ERM NC of select monitoring wells to determine the nature of the water quality violations.
Analyses of the coal ash were also required. The results of the composite sample of coal ash indicated the
presence of several metals and ions of interest including arsenic, chloride, iron, manganese, mercury, nitrite and
sulfate. Iron and mercury were the only parameters to exceed Protection of Groundwater Soil Remediation
Goals established by the NCDENR Inactive Hazardous Sites Branch (IHSB). The ERM NC report contends
that concentrations for arsenic, iron, manganese, mercury and chloride are within the typical ranges for natural
soils and are not expected to impact groundwater above background levels. Groundwater quality results from
the assessment showed elevated iron and manganese concentrations above 15A NCAC 2L (Groundwater
Quality Standards) at all four monitoring wells. The ERM NC report concluded that elevated iron and
manganese concentrations were attributable to natural conditions based on the levels detected in the background
well.
AQUIFER PROTECTION SECTION —Asheville Regional Oftice (ARO)
2690 U.S, 76 Highway, Swannanoa, NC 28778-8211
Phone: [phone] FAX : [phone]
Customer Service: 1-877-623-6748
Internet: www.nuvaterqualityorg
An Equal Opportunity ! Affirmative Action Employer
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Mr. Goodrich
April 20, 2010
Page 2
Based upon the review of the ERM NC Phase I Site Assessment Report, the ARO feels that continued
assessment of the groundwater data for iron is necessary, thus the permit modification request. Please feel free
to contact me at 828-296-4685 if you have any further questions.
Sincerely,
Beverly Price
Environmental Specialist
Cc: Jerry Sisk, Coats American, Inc.