NC0004243_NOV2022LV0360_RESP_20220607

Coats
North America
7 June 2022
North Carolina Department of Environmental Quality
Division of Water Resources
2090 U.S. Highway 70
Swannanoa, NC. 28778
Reference: Coats American, Inc.
Notice of Violation (NOV) — NOV-2022-LV-0360
Permit No. NC0004243
Sevier Plant WWTP
McDowell County
Issuance Date: 31 May 2022
Attn: Ms. Lauren Armeni
Ms. Armeni,
This letter is in response to the Notice of Violation (NOV) dated 31 May 2022 regarding'a daily
maximum exceedance for the BOD parameter. The BOD daily maximum value reported on 21
April 2022 was 214.34 lbs./day, while the permitted daily maximum limit is 188.5 lbs./day.
An internal investigation has been initiated to determine the source of the elevated BOD levels
resulting in the permit exceedance. The investigation includes a cause analysis 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. All mechanical systems at the treatment facility are reported
in good operating condition and the sampling protocol was followed.
No other changes or upsets to the operation of the wastewater treatment facility were noted
during the investigation prior to the April exceedance.
Following the high BOD levels on 21 April, subsequent BOD levels for the remainder of the
month of April and May are well below the daily maximum permit limits.
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 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 this NOV.
Sincerely,
Signature: Date:
Emrah Bilgin
Manufacturing Director
Coats American, Inc.- Sevier
emrah.bil in coats.com
828- 559- 7698
b (412o22_
cc: John Moss, Facilities Engineering Manager- Coats North America
Todd Wegenast, Environmental Compliance Manager- Coats North America