NC0000108_Permit (Issuance)_20050928

NPDES DOCUMENT SCANNINS COVER SHEET
NPDES Permit: NC0000108
Document Type: Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Monitoring Report .
Instream Assessment (67B)
Environmental Assessment (EA)
Permit
History
Document Date: September 28, 2005
Tbla doczzumIsat Im pw*Imte�d on X-exx e«paper-i.apmore aay
coImterit oa tdwe wa wex we aiae

O. " '_•" . , . Michael F,Easley,Governor
y William G.Ross Jr.,Secretary
r North Carolina Department of Environment and Natural Resources
w -
C3 ,C
Alan W.Klimek,P.E.Director
Division of Water Quality
September 28, 2005
Mr. Mike Bell
Director of Environmental Engineering =-
Coats North America
P.O. Box 670
Toccoa, Georgia 30577 =
Subject: Issuance of NPDES Permit
NC0000108 Sylvan Plant WWTP
Transylvania County
Dear Mr. Bell:
Division personnel have reviewed and approved your application for renewal of the subject permit. Accordingly,we are
forwarding the attached NPDES discharge permit. This permit is issued pursuant to the requirements of-North,'Carolina
General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S Environmental
Protection Agency dated May 9, 1994 (or as subsequently amended).
This permit includes no major changes from the draft permit sent to you on August 3, 2005. If any:parts;
measurement frequencies or sampling requirements contained in this permit are unacceptable to you; you,have the right
to an adjudicatory hearing upon written request within thirty(30)days following receipt of this letter. This:request 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 (6714 Mail Service Center, Raleigh, North Carolina 27699-6714). Unless sudh"demand
is made, this decision shall be final and binding.
Please note that this permit is not transferable except after notice to the Division. The Division may require modification
or revocation and reissuance of the permit. This permit does not affect the legal requirements to obtain other permits
which may be required by the Division of Water Quality or permits required by the Division of Land Resources, the
Coastal Area Management Act or any other Federal or Local governmental permit that may be required. If you have any
questions concerning this permit, please contact Bob Guerra at telephone number(919)733-5083, extension 539.
Sincerely,
ORIGINAL SIGNED BY
SUSAN A. WILSON
Alan-W. Klimek, P.E.
cc: Central Files
Asheville Regional Office I Surface Water Protection
UNPDES�- U��
N14pStttCar)P;
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North Carolina Division of Water Quality 1617 Mail Service Center . Raleigh,NC 27699-1617 Phone[phone] Customer Service
Intemet h2o,enr.state.nc us 512 N.Salisbury St. Raleigh,NC 27604 FAX [phone] 1-877-623.6748
An Equal OpportunitylAHlrmative Action Employer—50%Recydedl10%Post Consumer Paper

,
Permit NC0000108
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other
lawful standards and regulations promulgated and adopted by the North Carolina
Environmental Management Commission, and the Federal Water Pollution Control Act,
as amended,
Coats American, Inc.
is hereby authorized to discharge wastewater from a facility located at the
Coats American - Sylvan Plant
Old US Hwy 64 East
Northeast of Rosman
Transylvania County
to receiving waters designated as Galloway Creek in the French Broad River Basin
in accordance with effluent limitations, monitoring requirements, and other conditions
set forth in Parts I, 11, III and IV hereof.
This permit shall become effective November 1, 2005.
This permit and authorization to discharge shall expire at midnight on September 30, 2010.
Signed this day September 28, 2005.
ORIGINAL SIGNED BY
SUSAN A. WILSON
Alan W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit NC0000108
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge
are hereby revoked. As of this permit issuance, any previously issued permit bearing
this number is no longer effective. Therefore, the exclusive authority to operate and
discharge from this facility arises under the permit conditions, requirements, .terms,
and provisions included herein.
Coats American, Incorporated is hereby authorized to:
1. Continue to operate an existing 0.015 MGD extended aeration package wastewater
treatment system with effluent disinfection to discharge at outfall 003, located at
Sylvan Plant, on Old US Highway 64 East, Transylvania County, and
2. Discharge from said treatment works at the location specified on the attached map
into Galloway Creek which is classified C waters in the French Broad River Basin.

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NC0000108 - Coats American Facility
Latitude: 35`10'00" Sub-Basin: 04-03-01 Location '
Longitude: 82°48'30"
uad 4: G7NFlRosman,NC
Stream Class: C Coats American,[nc.
j''�
Reccivins Stream: Galloway Creek No! i h
NCOOOO l OB
Permitted Flow: 0.015 MGD Sylvan Plant

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Permit NC0000108
A. (I.) EFFLUENT,LIMITATIONS AND MONITORING REQUIREMENTS — FINAL
During the period beginning on the effective date of this permit and lasting until permit expiration, the Permittee is
authorized to discharge from outfall 003: domestic wastewater. Such discharges shall be limited and monitored
by the Permittee as specified below:
EFFLUENTS "L;JMI TS �'�'� ''` . , fiMONITORIlVG REQUIREMENTSmr TERISTICS 7�. f� �
ofh pally,F, rement1=fiVN4,
Maximum' Feqen ,
Flow 0.015 MGD Weekly Instantaneous Influent or Effluent
BOD5,200C 30.0 m A 45.0 m A Weekly Grab Effluent
Total Suspended Solids 30.0 m A 45.0 m A Weekly Grab Effluent
NH3 as N' 21.0 m A 35.0 m A Weekly Grab Effluent
Fecal Coliform(geometric mean 200l100 ml 400/100 ml Weekly Grab Effluent
Total Residual Chlodne2 28 ugA 21Week Grab Effluent
Temperature,OC Weekly Grab Effluent
H3 211VIonth Grab Effluent
Footnotes:
1. From November 1 through March 31, NH3-N shall not have a limit.
2. The TRC limit shall take effect on May 1, 2007. Until then, the permittee shall monitor TRC
(with no limit).
3. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Permit NC0000108
A. (2.)EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS -
FINAL
During the period beginning on the effective date of this permit and lasting until
permit expiration, the authorization to discharge from outfall 001 is suspended until
this permit is modified pursuant to Condition A. (4).
A. (3.)EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS -
FINAL
During the period beginning on the effective date of this permit and lasting until
permit expiration, the authorization to discharge from outfall 002 is suspended until
this permit is modified pursuant to Condition A. (4).
A. (4.)CHANGE IN OWNERSHIP OR USE OF THE FACILITY- FINAL
Prior to resuming operations at the Sylvan Plant or in the event that the facility
changes ownership, the permittee shall submit a request for permit modification
including the following documentation at least 180 days prior to the start of'
operations:
1. Description of manufacturing processes, products, and expected annual
production.
2. Flow diagram indicating process and wastewater flow volumes.
3. Proposed treatment and characteristics of the wastewater to be discharged.
4. Description of any planned expansions or upgrades to the manufacturing or
treatment facilities.
5. Engineering Alternatives Analysis of wastewater disposal alternatives including
the connection to an existing municipal waste treatment facility and non-
discharge alternatives.
6. If the facility is sold a name ownership change form and required documentation
shall be submitted to the Division.
A. (5.) BIOCIDE CONDITION - FINAL
The permittee shall not use any biocides except those approved in conjunction with
the permit application. The permittee shall notify the Director in writing not later than
ninety (90) days prior to instituting use of any additional biocide used in cooling
systems which may be toxic to aquatic life other than those previously reported to the
Division of Water Quality. Such notification shall include completion of Biocide
Worksheet Form 101 and a map locating the discharge point and receiving stream.

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DENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No.NC0000108
AppltcantlFactltty Name;,31 r,.r..-:i NC0000108=Coats American—Sylvan Plant
Apphcant'Addres's , i i ' Mr. Mike Bell,Director of Environmental Engineering; P.O. Box 670,
Toccoa,Georgia 30577
Facilit ,A'ddres": 'r, , :;'I US Hyj 178 Rosman,NC 28722
;Pernaittcd Flaw'':`; ' '` ,'` „ ` 001+002 are not limited,003 =0.015 MGD
Type of Waste ! th,- I i j Domestic sanitary sewer and intrusive groundwater infiltration only. All
E' sources of process water and cooling water have been shut down and
drained.
Facili /Permit Status ."r' ;'1 Active; Renewal
Transylvania
i f � I' MMISC011an20n5
Recetvin'''iStreatn' , , , -'. i ;`';�' Galloway Creek Reional''O'fficeE ;`';I' Asheville
Stream Classifieahon 'r i`!;;! C State;:Grid ibUSGS., uad : . G7NE
No Writer ,' I "', ,`,' a,: Bob Guerra
04-03-01 ,�'`I `,' 14'%j 9/26/05 .
Diamage"Area�(mt��) �'� ' ' fs`�` 0.69
'Summer`? 10 cfs 01:;l} , "if 0.6
Winter€7,Q10'(cfs) r; t; ` ,: 0.9
v
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C.
30 2� cfs a I 1.
0
Avery 1716 s, cfs :'d ii ;' 2.4
IWC(%} i `!> 3.7% Lat. 35° 10'00"N Long. 82'48'30"W
BACKGROUND
Coats American is/was a producer of greige (non-dyed) cotton and polyester sewing threads.
The permitted wastewater flow contains no actual process flow other than non-contact cooling water.
Sludge generated by the domestic waste at the plant is hauled off-site by DDK Environmental and
treated by the Cranston WWTP. Chlorine is currently used as a biocide,though biocide AQB-008
has been DWQ approved for use at the plant. Due to the biocide use, the sporadic discharges from
001 and 002 are assigned an acute toxicity test.
Outfalls 001 and 002 receive condensate from the air compressor, after cooler, air dryer,
cooling tower blowdown and air washer blowdown and cooling water. Outfall 003 discharges
domestic waste treated at the plant and is required to meet an ammonia limit of 21,0mg/l in addition
to the more standard BOD, TSS and fecal coliform limits.
FACILITY OPERATIONAL CHANGES SINCE LAST RENEWAL
Pursuant to the Permit Renewal Application received on March 24, 2005 the following
changes have impacted the facilities production and wastewater discharges. Manufacturing activities
ceased at the plant on September 30, 2003 with most of the production equipment removed by
December 31, 2003. Coats have no intentions to reopen the plant. Currently the plant is completely
empty except for the plant infrastructure equipment such as air washers, chillers, and various electric
distribution equipment.
Fact Sheet
NPDES NC0U00108 Renewal
Page t

All of the sources of process wastewater have been shutdown and drained. The only
discharge is for very intermittent (1-2 per month) sanitary discharge from Outfall 003, which is
maintained since Coats does not have access to a public sewer system. In reality, most of the sanitary
discharge is groundwater infiltration into the pipe to the treatment plant during heavy rains when the
facility must operate the system to prevent overflow. There are two licensed operators employed on a
part-time basis to operate and maintain the system, sample the effluent and submit monthly DMR's.
There are currently 0 Employees in addition to the two part-time contractors— I
Caretaker/WWTP Operator& I WWTP Operator in Responsible Charge. Coats would like to
maintain the permit and the option for a new owner to benefit and discharge from the current
treatment system, as allowed by Section A.(4.) of the current permit.
FILE REVIEW
The Asheville Regional Office has performed three inspections within this permitting cycle.
The facility has always been in compliance during these inspections.
DMR REVIEW
DMR's dating from May 2002 to present were reviewed with Discharges being sporadic in
recent years. The facility has reported no discharge for 2005. The main concern with effluent from
these outfalls is acute toxicity. Outfall 002 has had two Effluent Aquatic Toxicity failures -August
and November 2004.
REASONABLE POTENTINAL ANALYSIS
Reasonable Potential Analysis was not appropriate for any of the pollutants monitored
through this permit and was not performed during this permit renewal.
PERMITTING STRATEGY
Waste Load Allocation (WLA).
The last waste load allocation was performed in 1991. This WLA established a limit for
ammonia of 21.0 mg/L as well as fecal coliform limits. Chlorine limits were recommended, but after
discussion with the permittee and ARO, acute toxicity testing was given instead.
PERMIT MODIFICATIONS SINCE LAST PERMIT RENEWAL
On January 21, 2004, Coats American requested a permit modification to discontinue
monitoring and reporting requirements, including aquatic toxicity testing, for Outfalls 001 and 002.
The rational for this request was cited as manufacturing operations ceased at this plant on September
30, 2003, with removal of most of the production equipment by December 31, 2003. The facility
provided a Wastewater Flow schematic indicating that all the process wastewater sources have been
shutdown and drained. This was the basis for their reasoning that the potential to contribute
pollutants to the wastewater from these sources has been eliminated.
Correspondence from ARO, Kerry Becker indicated that:
1. Coats America is closed down
2. Outfalls 001 and 002 refer to their cooling towers/stormwater discharges.
3. Outfall 003 is the main wastewater treatment plant for the bathrooms
4. The facility is actively searching for a buyer and
5. The facility wishes to keep the permit for the 003 outfall available for a new
industry.
On June 7, 2004 the Department issued a Modification for this NPDES permit which stated
that this letter authorizes the following permit modification:
L The limitations and monitoring requirements for Outfalls 001 and 002 were suspended.
2. The facility has shut down manufacturing operations at the Sylvan Plant and no longer
discharges non-contact cooling waters.
Fact Sheet
NPDES NCOOOO 108 Renewal
Page 2

3. Outfall 003 has been retained with modifications.
4. A daily maximum limit of 28 gg/L for Total Residual Chlorine was included in the permit.
A TRC policy was adopted by the Division in April 2003. Facilities that didn't have TRC
limits will get limits at renewal or re-issuance of the permit. A compliance schedule of 18
months was added to the permit.
5. Also, a daily maximum limit of 35 mg/1 was added for ammonia. The Division has been
adding daily maximum limits for ammonia to permits with monthly averages since
December 2002 in order to conform to Federal NPDES regulations and
6. A special condition was added to the permit including requirements to be fulfilled in the
event that the facility resumes manufacturing or changes ownership.
SUMMARY OF PROPOSED CHANGES
SUSPENSION OF AQUATIC TOXICITY PERMIT REQUIREMENT
The 6-7-04 Permit Modification issued to Coats American Inc. for discharge from the
Sylvan Plant WWTP suspended ALL Sampling and Monitoring requirements for Outfalls 001
and 002. The facility shut down manufacturing operations and no longer discharges non-contact
cooling waters. Outfall 003 was retained with modifications. Also, a daily maximum limit of 35
mg/l was added for ammonia. This daily maximum limits for ammonia was added to permits
with monthly averages since December 2002 in order to conform to Federal NPDES regulations.
A special condition was added to the permit including requirements to be fulfilled in the event
that the facility resumes manufacturing or changes ownership.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE
Draft Permit to Public Notice: August 03, 2005 (est)
Permit Scheduled to Issue: September 30, 2005 (est)
NPDES DIVISION CONTACT
If you have questions regarding any of the above information or on the attached permit, please
contact Robert Guerra [phone] ext. 539.
NAME: DATE:
Regional Office Comments
NAME: DATE:
SUPERVISOR: DATE:
Fact Sheet
NPDES NCOOOO108 Renewal
Page I

SCHEMATIC OF WASTE WATER FLOW
COATS AMERICAN -- SYLVAN PLANT
TRANSYLVANIA COUNTY
ROSMAN, NORTH CAROLINA
NPDES PERMIT NO. NC0000108
POTABLE WATER PACKAGE
TREATMENT OUTFALL 003
CHLORINATION PLANT (AERATION)
FOR DISINFECTION
THIS OPERATION DISCONTINUED DEC. 2004 DUE TO PLANT CLOSURE _
\ NON-CONTACT
\ \ COOLING WATER /
\ •AIR COMPRESSOR OUTFALL 002
\ AFTERCOOLER /
• AIR DRYER /
CONDENSER
COOLING WATER /
CHLORINATION \ /
AS BIOCIDE \ /
Ca0 UKG
TOWN
/ BLO�D WN
/ \
I / �
/ BLowoowN \
I / / AIR WASHERS \ I
/ BLOWDOWN OUTQALL 001
C3-24-2005

SCHEMATIC OF WASTE WATER FLOW
COATS AMERICAN - SYLVAN PLANT
TRANSYLVANIA COUNTY
ROSMAN, NORTH CAROLINA
NPDES PERMIT NO. NC0000108
POTABLE WATER PACKAGE
TREATMENT OUTFALL 003
CHLORINATION PLANT (AERATION)
FOR DISINFECTION
NON--CONTACT"
COOLING WATER
y . .
-AIR COMPRESSOR OUTFALL 002
AFfERC00LER
• AIR DRYER
CONDENSER
COOLING WATER
CHLORINATION
AS BIOCIDE
COOLING
TOWER
SLOWDOWN
BLOWDOWN
AIR WASHERS SLOWDOWN
OUTFACE 001
,�2;=24-2000�

Whole Effluent Toxicity Testing Self-Monitoring Summary June 16,2005
FACILITY REQUIREMENT YEAR jA-N fEB MAR APR MAY 41N JIVE AUQ SEP OCT NOV OEO
CNA Haldingt,Inc cr lim:5.8% 2%1 Pass - Pm - - Pass - - pm - Pm
NCOOD49521001 Begin 6/U2004 Ftegnmlcy:Q Mar hm Sep Pic + NonComp:Single 20112 - - Pap - - Pm - - Pam -- - Pan
County-Cleveland Region:MRO Subbasin:8RD05 2003 - - Pap - - Pass - - pm -- - Pm
PF:0-8 SP.-W 2OD4 - - Pap - - Peas - - Paso - - Pm
7Q1R 20,0 IWC(%)5.8 am: 2vo5 - - Paw -
Coats Anerdctui4 r Pleat du lion 15% 2001 - Peas - - Pm - - Pans - - Pau -
NCOOD42431001 Begin:1/1/2001 Frequency-0 Feb May Aug Nov + Nmef'.omp:Single 2002 - Pate - - Pan - - Pan - - Pass -
County:McDowell Region:AftO Subbasin:CTB30 2003 - Pass --- -- Pass - - Pass - - P_ -
PF:2.0 Spaial 2004 - Pass - - PM - - Fad Q.5 38.7 Fan 122
7Q10:19.0 rWC(%)14.7 Ord.: 20M 21.2 Pan >50 >50
Cegeatra IaoRoetq Manat chr lim,2 3% 2001 - Pecs - -- Pass - - Pea - ^ Pass .---
4C/Y17­1aY11 94-ri..-711nM5 Fn+,s -n Feb Mery Ana Nnv +-Nn.1`m..n Cinvl. 2002 - Peas - - Pm - - Pass - -- Pass -
County.F.dgecombe Region:RRO Subbasin:TAR02 2003 -- tale Paso - Late Pans - Para - - raw
PF:0.904 smut 21101 - Pan - -- Pass - - Pass -- - PM -
7Qm60.0 RVC(%)2.3 tkd- 2005..- Pass -
Cogentris.ROabord003 dtr lion 90% 2001 c15 Late >90 - NRA90 77.2 s90 >90 >9D >90 -W 5i1•>100t
NCO06SOB I1003 Begin:7112004 Fmquncy:Q Feb May Aug Nov + NonComp:Single 2002 - >100 -- - >100 - - a100 - - 94.9
County:Peum Region:PRO Subbasin:ROA05 2W3 -- >100 - - >100 - _. >100 - - >100 -
PF:VAR speoat 2004 - >100 - - >100 - - '100 - - a100
ruin nn nw('f5n.)IM ado: 2005-- moo - - >100 - - - - -
Coleaial Pipeline-RDUMI 24hr LC50 ac monh cpis fthd 2001 - - >100 - - - - - - - - -
NC0081469=1 Begin:4112004 Frequency:A NolrComp: 2002 NPJ>100 - - - --- - - - - - -
County:Wale Region:RRO Subbasin:NEU02 2003 - - - >100 - - - - - - - -
PF:NA SP-d 2004 » >IOD - - - - - - - - -
7Q10'.NA rwc(%)100 Order: 2W5 --
Clonal Pipdina C arlettc 24hf LC50 be montt epee fthd... ._ .. .. 2001- --
NC0031038/001 Begin:911/2001 Fnquency:A NmCotnp: 2DO2 - - - - Pass mD0 - - - - - -
County.Mecklenburg Region:MRO Subbasen'CTU34 2003 - - - - >1DO - - - - - - -
PF:NA sp--w 20W -
7QIO-0 IWC(%)10D.O Order: 2005 - - - >100
Colonial Pipethse-.Selma 24hr LC50 ac mwut epes fthd 2001 -- -- >100 - - - - - - - - -
NCW3101[MOi BeSM 3J12004 It'MrX ner.A NmComp_ 2002 NRh100 - -- - - - - - - -- - -
County:Johnston Region:RRO Subbasin:NEU02 2003 - - - >100 - - - - - - - -
PF:VAR special 2004 _ >100 •- -• - - - - -
7Qi0:0-0 rWC(%)100-0 ado: 2005 - >100 - - -
Colonial Pipeiind001 - 24hr LC50 ac monit epis Mid 2001 atoo -- - - - - - - - - - -
NCO03104600] Begin'21ifL002 Frequency:A NonComp: 2002 >100>190 - - - - - - - - - -
County-Guilford Region:WSRO Subbasin:CPFOg 2000 -100 - - - - - - - - - - -
PF:NA SP-4 21104 _ -
7Q]O-0.0 lWC(aNa)100 ado: 2006 >100 - -- --
Colonial Pipel;ne/002 24hr LC50 ac moil qu nhd 2001 m00 - - - - - - - - - - -
NC003I046/002 Begin:WI2002 Fnquency:A NolComp: 2002 >100 - - - - - - - - - - -
County:Guilfeud Region:WSRO Subbditi CPF08 20M >1D0 - - - - - - - - -- - -
PF:NA SP. I 2Oo4 a100 - - - - - - - - -
Calmeri PipehadW3 24hr LC50 AC molt epis nhd 2OD1 >700 - - - -- - - - - - - -
NCW31046/W3 Begin:VI/2002 Frequency:A - NonCorrip: 2O=t -Io0 -
CowuyGuilfwd Region:WSRO Subb-in:CPHS 20m -100 - - - - - - - - - - --
PF:NA SP-I 2004 - a100 - - - - - - - -
7QIQ 0.0 IWC(%)1000 arad: 2005 a100 - - - --
Colonial PipdinctM 24hr LC50 ac maul cpis frhd 2"1 >100 - - - - - - -- - - -
e.(.w�.l..:iw. ucgle.'4 iir,+a.1 Frequctwy:n .:peq•Wnp. _.�� -.. - .� - ^• --. -- _. - - .- _ -
County.Guilford Region:WSRO Subbases:CPFO8 2003 a190 - - - - - - - - - - -
PF:NA 2001 - -100 -
7QIR 0.0 IWC(%)100,0 ntder 2D05 >100 - - --
If Pre 2001 Data Available
LEGEND:
PERM-Permh Requirtment LEr a Athllinealraave Letter-Target Frequancy=Monitoring frequency:Q-Quarterly;M-Monthly;BM-Bimonthly;SA-Senom9nually;A.Annually OWO.Only%ben d4durging;D-Discontinued monitoring requirement
Begin-First month i"prod 7Q10=Receiving stream low Bow criterion(ds) +' manetelreng maeasa to mmthly opal failure or NR Months that testing must occur.ea.Jan,Apr,lid,Oca NMCOMP-Current Compliance Requirement
PF-Parmitted flow(MGD) IWC%-lmtreatn w=;te twn=UIilion PT-Pau/Fail cm AC-Acute CHR-Chronic '
Data Notation:f-Fathead Mimcw;•-Ceriodapbrtin sp.;my-Mysid shrimp;ChV-Chronic value;P-Mortality of stated percentage at highest concentration:at-Performed by DWQ Aquatic Tm Unit;bt-Bad test
Reporting Notation:---=Data not required;NR-Not reported Facility Activity Status:I-Inactive,N-Newly Inued(To construct);H•Active but not discharging;t-More data available for month in quation; =ORC degnature needed
10

Coats North America
P.O.Sox 670
Coats Toccoa, Georgia 30577
Telephone: [phone]
• North America FAX: [phone]
Via Certified Mail
March 24, 2005
Ms. Carolyn Bryant
NC Department of Environment& Natural Resources
Department of Water Quality/Point Source Branch
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: NPDES Renewal
Coats American- TransyIvania County
Permit No. NCO000108
Dear Ms. Bryant:
Enclosed is NC-DENR Form 2C - NPDES Permit Application-Short Form for the Coats
American (Coats) facility in Rosman, North Carolina. This Short Form Application is
being submitted in lieu of full EPA Form 2C application originally requested in NC-
DENR's November 29, 2004 renewal notice. Use of the Short Form was authorized by
Mr. Charles Weaver via the attached E-mail dated January 31, 2004 in response to Coats
inquiry concerning the appropriateness of the long form and associated priority
pollutant testing since the facility is closed.
As I indicated in my January 27, 2005 inquiry, manufacturing ceased at this plant on
September 30, 2003 with most of the production equipment removed by December 31,
2003, Coats has no plans to reopen the plant. Currently the plant is completely empty
except for the plant infrastructure equipment such as air washers, chillers, and various
electrical distribution equipment. However, all of those sources of process wastewater
have been shutdown and drained. As such, Outfalls 001 and 002 for those sources
were removed from this facility's permit in NC-DENR's permit modification effective
June 7, 2004.
Thus, the only discharge is for very intermittent (1-2 per month) sanitary discharge
from Outfall 003 which is being maintained since Coats does not have access to a public
sewer system. In reality, most of that sanitary discharge is groundwater infiltration
into the pipe to the treatment plant during heavy rains when we must operate,this
system to prevent overflow. We continue to employ two licensed operators on a part-
time basis to operate and maintain the system, sample our effluent and submit monthly
Discharge Monitoring Reports.

NPDES Renewal
Coats American -Transylvania County
Permit No. NC0000108
March 24, 2005
Page 2
Coats would also like to maintain the permit and the option for a new owner to benefit
and discharge from the current treatment system as is allowed by Section A.(4.) of the
current permit.
Please call, fax or E-mail (mike.bell®coats.com) any questions or comments you may
have about this request.
Sincerely,
COATS NORTH AMERICA
fn ��
Mike Bell
Director Environmental Engineering
Enclosures
cc: Mr. Keith Haynes -- Asheville Regional Office
Mr. Wesley Royal - Royal Water Works, Inc.
Mr. Don Deemer - ERM-SE
Mr. Tom Kitchen
I

Coats American, Inc. - Sylvan Plant
Highway 178, Rosman, North Carolina -Transylvania County
NPDES Permit No. NC0000108
Sludge Management Plan
March 24,2005
Background
This facility is currently closed. Manufacturing ceased on September 30, 2003 with most
of the production equipment removed by December 31, 2003. Coats has no plans to
reopen the plant.
The only discharge is for very intermittent (1-2 times per month) sanitary discharge
plus ground water infiltration from Outfall 003 which is being maintained since the
facility does not have access to a public sewer system.
Sludge Management
The potential for sludge generation and accumulation will be very minimal.
Nevertheless, the operators as part of the daily checks on the proper operation of the
system will monitor any accumulation of solids and the Total Suspended Solids levels
for indications removal is required. As has been the past practice when the
manufacturing processes were ongoing, a licensed septic tank cleaning contractor will
be secured to remove and properly dispose of the accumulated sludge.

Renewal.Notice -NPDES Permit NCO000108
Subject: Renewal Notice - NPDES Permit N00000108
From: [e-mail]
Date: Tdhu;-27zJanf-20.05 1.4:54:27 -0500
To: [e-mail]
CC: [e-mail], [e-mail]
Charles,
Thanks for your prompt reply to my inquiry this morning as to what
monitoring and permit applications are required to renew our Sylvan
Plant ' s
NPDES permit On the plant ' s current and future operating situation,
Coats has no plans to reopen the plant. Manufacturing ceased on
September
30, 2003 with most of the production equipment removed by December 31,
2003 . Currently the plant is completely empty except for the plant
infrastructure equipment such as air washers, chillers, and various
electrical distribution equipment . However, all of those sources of
process wastewater have been shutdown and drained.
Thus, the only discharge is for very intermittent (1-2 per month)
sanitary
discharge from Outfall 003 which is being maintained since we do not
have
access to a public sewer system. In reality, most of that sanitary
discharge is groundwater infiltration into the pipe to the treatment
plant
during heavy rains when we must operate this system to prevent
overflow.
We continue to employ two licensed operators on a part-time basis to
operate and maintain the system, sample our effluent and submit
monthly
DMR' s .
For your convenience, I have attached a copy of the most recent
.submittal
and permit modification suspending monitoring and discharges for
Outfalls
001 and 002 which previously supported the noncontact cooling process
flows
for this facility.
We would appreciate you guidance on the most cost efficient manner to
renew
and maintain this permit under the current extremely limited operating
scenario. We would also like to maintain the option for a new owner
to
benefit and discharge from the current treatment system as is allowed
by
Section A. (4 . ) of the current permit .
Mike Bell
1 of 2 1/31/2005 734 AM

Renewal Notice -NPDES Permit NC0000108
Director, Environmental Engineering
Coats North America
(706) 886-2141 Ext . 2248
(706) 886-9182 Fax
(706) 491-2431 Cell
(See attached file: Coats Sylvan NPDES Permit Mod 060704 .PDF)
cc Via FAX (Email only) :
Wesley Royal
Tom Kitchen
This communication which may be confidential and privileged and the
views expressed herein may be personal and are not necessarily the
views of Coats plc. It is for the exclusive use of the intended
recipients (s) . If you are not the intended recipient (s) , please note
that
any distribution, copying or use of this communication or the
information
in it is strictly prohibited. If you have received this communication
in
error, please notify us by email (Apps . Support@coats .com) or telephone
our technical support helpdesk at Coats plc . +44 (0) 20 8210 5100
(UK 0830h - 1800h, Mon-Fri, GMT) and then delete the e-mail and
any copies of it .
2 of 2 1/31/2005 7:34 AM