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HomeMy WebLinkAboutNC0004243_NOV-2019-LV-404 and 405 Response_20190701Coats • North America June 28, 2019 North Carolina Department of Environmental Quality Water Resources 2090 U.S. Highway 70 Swannanoa, NC. 28778 JUL20 0 i 1019 � Water QUality i,egional operations Asheville Regional pace Reference: Coats American, Inc. Notice of Violation and Intent to Assess Civil Penalty Permit No. NC0004243 Sevier Plant WWTP McDowell County Issuance Date: May 25, 2017 Mr. G. Landon Davidson, This letter is in response to the Notice of Violation and Intent to Assess Civil Penalty letters dated June 14, 2019. The notices were received by the Coats American, Inc. facility on June 27, 2019. The two notices, NOV-2019-LV-0404 and NOV-2019-LV-0405, are in reference to permit exceedances of total recoverable phenolics based on data submitted on the Discharge Monitoring Reports (DMRs) submitted to the Division of Water Quality (DAQ) for the months of January 2019 and April 2019. A written (email) communication was delivered to Mr. Tim Heim of the DAQ on May 20, 2019 informing the DAQ of the permit exceedance. The exceedance was identified while preparing the DMR for the month of April. An acknowledgment from Mr. Heim was received on May 21, 2019 via email. In addition to notifying the DAQ, an internal investigation was initiated to determine the source of the phenols resulting in the permit exceedance. The investigation included a cause analysis, root cause determination, and the creation of an action plan aimed at preventing recurrence of the event. The chemical usage throughout the plant, including the dye house, bonding operations, and housekeeping and maintenance, was reviewed and no abnormal usage, spills, or releases to the wastewater treatment facility were identified. The site's ozonation system was determined to be in good operating condition at the time of the April exceedance. Earlier in the year, the site approved the acceptance of residential septic tank waste as a low -risk activity to help add biological matter to the treatment ponds. This practice was stopped as a result of the incident investigation but was not determined as a primary cause of the phenols exceedance. The natural decomposition of organic matter within the treatment plant was listed as a potential source of the phenols exceedance. No other changes or upsets to the operation of the wastewater treatment facility were noted during the investigation prior to the April exceedance. The permit exceedance for the month of January 2019 was identified during the incident investigation process and was investigated concurrently with the April exceedance. 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 phenols limits. A review of the May effluent data indicates all samples were below the permit limits for daily and monthly maximum levels. Coats will continue to investigate and monitor the chemical usage and operation of the wastewater treatment facility. Please feel free to contact me directly if you have any questions or need any further documentation to address the noted violations. Sincerely, Signature: 'Up� �(�XW6V-� Michael Cothran Manufacturing Director Coats American, Inc.- Sevier m ichael. cothran(a)coats. com 828-756-4111 extension 3272 Date: CP /d p / a o cc: John Moss, Facilities Maintenance Manger- Coats North America Todd Wegenast, Regional Environmental Manager- Coats North America Paul Prendergast- Global Environmental Manager- Coats, PLC.