NC0004243_PC-2019-0049 Response_20190701

Coats
• North America
NI I
Water Quality Regional Operations
Asheville Regional Office
December 5, 2019
North Carolina Department of Environmental Quality
Water Resources
2090 U.S. Highway 70
Swannanoa, NC. 28778
Reference: Coats American, Inc.
Division of Water Resources- Civil
Case Number PC-2019-0049
Permit No. NC0004243
Sevier Plant WWTP
McDowell County
Received Date: December 5, 2019
Mr. G. Landon Davidson,
Penalty Assessment
Coats North America
PO Box 368
630 American Thread Road
Marion, NC 28752
TEL [phone]
FAX [phone]
This letter is in response to the Division of Water Resources Civil Penalty Assessment letter
dated September 13, 2019 and received at the Coats American (Coats) facility on December
5, 2019. The letter references reporting violations for failure to report quarterly instream
monitoring results for the parameters as specified in permit condition A. (2) for the first two (2)
quarterly reporting periods of 2019.
In accordance with Option 2 as stated in the letter, Coats is submitting a request for remission
or mitigation of the civil penalties as assessed.
The site ceased the quarterly instream monitoring for all parameters following receipt of a letter
(enclosed) from the North Carolina Department of Environmental Quality dated February 5,
2019 that authorized the site to discontinue the quarterly instream monitoring for total
polycyclic aromatic hydrocarbons, or PAHs, per permit condition A. (4). Prior to this, the
quarterly instream monitoring for all parameters had been conducted as required by the permit.
Upon receipt of the Notice of Violation (NOV) dated August 12, 2019, and in consultation with
Mr. Tim Heim of the Asheville Regional Office, the site immediately resumed the quarterly
instream monitoring for the parameters as required in permit condition A. (2) and has
completed the monitoring for the third and fourth quarters of 2019.
Further, Coats has invested in a compliance assurance digital platform that identifies legal
requirements regarding environmental permits and licenses and allows the creation of
compliance related tasks, such as the quarterly monitoring. The Coats compliance system
identifies the task based on the required frequency, such as quarterly for the instream
monitoring, and assigns it to the responsible person. The responsible person is required to
complete the task by the due date and enter evidence of the completion before closing the

task in the system. Once completed, the compliance system automatically generates a new
task based on the established frequency and assigns it to the responsible person. Enclosed is
a copy of the compliance task as an example.
Additionally, in support of Coats request for remission or mitigation of the civil penalties, the
noted violations were not committed intentionally or willfully and there was no documented
damage to the surface waters or is there any currently known to exist.
Coats takes every effort maintain compliance with all environmental permit limits and
operational requirements and is committed to compliance assurance as a key performance
indicator for the company.
Please feel free to contact me directly if you have any questions or need any further
information.
Sincerely,
Signature: .*AA6Vj 06�—
Michael Cothran
Manufacturing Director
Coats American, Inc.- Sevier
michael.cothran(a)coats.com
828-756-4111 extension 3272
Date: 1) 119 p01
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

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
Mr. John Moss
Facilities Maintenance Manager
Coats American Sevier Plant
630 American Thread Road
Marion, North Carolina 28752
Dear Mr. Moss:
NORTH CAROLINA
Environmental Quality
February 5, 2019
The Division has received your summary of 12 Total PAHS samples (including 4 effluent samples
and 8 instream samples) on January 29, 2019, with all 12 Total PAHS samples reported less than
the detection level of 0.5 µg/L. In accordance with the Special Condition A. (4) Total PAHS
(Polycyclic Aromatic Hydrocarbons) Monitoring in your NPDES permit (Permit number
NC0004243), effective on March 1, 2019, quarterly monitoring for Total PAHS can be
discontinued.
If you have any questions, or require any additional information, please contact me at (919) 707-
3610 or via email at [e-mail].
Sincerely,
I�
Bing Bai, Engineer
NPDES Complex Pennitting Unit
cc: NPDES Files
Central Files
DWR/Asheville Regional Office / Water Quality
Coats North America/Todd Wegenast
North Carolina Department of Environmental Quality 1 Division of Water Resources
512 North Salisbury Street 116nMail SoMce Center I Raleigh North Carolina 27699 lot?
9197rn uit

Quarterly sample instream at locations in Limekiln Creek (U1/ D1) and tl
River (U2) for dissolved oxygen, TRC, total hardness, and total copper. Nc
monitored at D1 and U2 locations/ grab sample. Report to NC DEQ via e[
that monitoring occurred. Sampling is conducted February/May/Auguste
Task Definition
Location Sevier
Record No. 9
Action Required Quarterly sample instream at locations in Limekiln Creek (U1/ D1) and the N'
dissolved oxygen, TRC, total hardness, and total copper. Note: Only total har
U2 locations/ grab sample. Report to NC DEQ via eDMR application for mont
Sampling is conducted February/May/August/November
Current Task Due Tuesday, December 31, 2019
Date
Next Task Due Date Tuesday, March 31, 2020
Frequency Every 3 months
End Date
Person Responsible John Moss

Tasks
Record ... Action Required Person Respons
9 Quarterly sample instream at locations in Limekiln Creek (U1/ D1) and the North Fork Catawba
River (U2) for di...
Requirements
Requirement C... Requirement Summary
USQ00021 The facility follows the requirements stipulated in its NPDES
permit including requirements with respect to sa...
Domain Jurisdi
Wastewater Discharge Feder
Permit / License