NC0004243_NOV-2019-PC-0575 and 0576 Response_20190913

D Coats North America
Coats Box 368 63merit
North America ���LLLLLL VVV American Thread Road
Mar
� Marion, NC 28752
TEL [phone]
AUG 2 9 2019 FAX [phone]
Water quality R6910nal Operations
August 28, 2019 Asheville Regional 0
North Carolina Department of Environmental Quality ffiCe
Water Resources
2090 U.S. Highway 70
Swannanoa, NC. 28778
Reference: Coats American, Inc.
Notice of Violation and Intent to Assess Civil Penalty
Permit No. NC0004243
Sevier Plant WWTP
McDowell County
Issuance Date: August 12, 2019
Mr. G. Landon Davidson,
This letter is in response to the Notice of Violation (NOV) and Intent to Assess Civil Penalty
letter dated August 12, 2019. The letter received on August 19, 2019 references NOV-2019-
PC-0575 and NOV-2019-PC-0576. The reporting violations include a failure to report quarterly
instream monitoring results for the parameters as specified in permit condition A. (2) on three
(3) separate occurrences in 2019, including March, May, and July.
Upon review of the site records, the last quarterly instream monitoring results were submitted
to the North Carolina Department of Environmental Quality (NC DEQ) on the November 2018
discharge monitoring report (DMR) via the electronic reporting portal.
As discussed verbally on August 7, 2019 with Linda W iggs and yourself, the Sevier facility
indicated it did not conduct the required instream monitoring results for the first and second
quarter of 2019. The site believed that these reporting requirements were solely related to the
monitoring for total polycyclic aromatic hydrocarbons, or PAHs, which were discontinued under
the approval of the NC DEQ in a letter dated February 5, 2019.
Coats would like to request an amendment to the NOV to delete the violation as noted for July
as we are currently in the third quarter of 2019. Instream monitoring for all parameters was
completed in August 2019 and the results will be reported on the August DMR to meet the
requirements for quarterly reporting (Q3).
The Coats American Sevier facility takes every effort to ensure compliance with all permit
limits, monitoring, and reporting requirements and believes the appropriate actions have been
taken to maintain compliance with the instream monitoring requirements.
Please feel free to contact me directly if you have any questions or need any further
information.

Sincerely,
Signature: w"� V
Michael Cothran
Manufacturing Director
Coats American, Inc.- Sevier
michael. coth ran(a)coats.com
828-756-4111 extension 3272
Date: v / ) g Igo
cc: Tim Heim, North Carolina Department of Environmental Quality, Division of Water Quality
John Moss, Facilities Maintenance Manger- Coats North America
Todd Wegenast, Environmental Compliance Manager- Coats North and Central America