NC0004243_LM20150011_20150720

— 11;4
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
Certified Mail # 7014 0510 0000 4466 6440
Return Receipt Requested
July 20, 2015
Jerry Sisk, Director Engineering
Coats American Inc
PO Box 368
Marion, NC 28752
Donald R. van der Vaart
Secretary
RECEIVEDIDENRIDWR
SUBJECT: Notice of Violation and Assessment of Civil Penalty
for Violations of North Carolina General Statute (G.S.) 143-215.l(a)(6)
and NPDES Permit No. NC0004243
Coats American Inc
Sevier Plant
Case No. LM -2015-0011
McDowell County
Dear Permittee:
JUL 2 4 2015
Water Quality
Permitting Sed«'
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of $1,159.26 ($1,000.00 civil
penalty + $159.26 enforcement costs) against Coats American Inc.
This assessment is based upon the following facts: a review has been conducted of the discharge monitoring report
(DMR) submitted by Coats American Inc for the month of April 2015. This review has shown the subject facility to be
in violation of the discharge limitations and/or monitoring requirements found in NPDES Permit No. NC0004243. The
violations, which occurred in April 2015, are summarized in Attachment A to this letter.
Based upon the above facts, I conclude as a matter of law that Coats American Inc violated the terms, conditions or
requirements of NPDES Permit No. NC0004243 and G.S. 143-215.1(a)(6) in the manner and extent shown in
Attachment A. In accordance with the maximums established by G.S. 143-215.6A(a)(2), a civil penalty may be
assessed against any person who violates the terms, conditions or requirements of a permit required by G.S.
143-215.1(a).
Based upon the above findings of fact and conclusions of law, and in accordance with authority provided by the
Secretary of the Department of Environment and Natural Resources and the Director of the Division of Water
Resources, I, G. Landon Davidson, Regional Supervisor, Asheville Regional Office hereby make the following civil
penalty assessment against Coats American Inc:
2090 U.S. 70 Highway. Swannanoa, NC 28778
Phone: [phone] \ Intemet "-.v%v.ncdenr.gov <http:i/www ncdenr.sov>
An Equal Oppornmity' Affirmative .Action Employer- Made in part by recycled paper

Option 3 File a petition for an administrative hearing with the Office of Administrative Hearings:
If you wish to contest any statement in the attached assessment document you must file a petition for an
administrative hearing. You may obtain the petition form from the Office of Administrative Hearings. You must file
the petition with the Office of Administrative Hearings within thirty (30) days of receipt of this notice. A petition is
considered filed when it is received in the Office of Administrative Hearings during normal office hours. The Office of
Administrative Hearings accepts filings Monday through Friday between the hours of 8:00 a.m. and 5:00 p.m.,
except for official state holidays. The petition may be filed by facsimile (fax) or electronic mail by an attached file
(with restrictions) - provided the signed original, one (1) copy and a filing fee (if a filing fee is required by NCGS
§150B-23.2) is received in the Office of Administrative Hearings within seven (7) business days following the faxed
or electronic transmission. You should contact the Office of Administrative Hearings with all Questions regarding the
filing fee and/or the details of the filing process.
The mailing address and telephone and fax numbers for the Office of Administrative Hearings are as follows:
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, NC 27699-6714
Tel: [phone]
Fax: [phone]
One (1) copy of the petition must also be served on DENR as follows:
Mr. Sam M. Hayes, General Counsel
Department of Environment and Natural Resources
1601 Mail Service Center
Raleigh, North Carolina 27699-1601
Please indicate the case number (as found on page one of this letter) on the petition.
Failure to exercise one of the options above within thirty (30) days of receipt of this letter, as evidenced by an internal
date/time received stamp (not a postmark), will result in this matter being referred to the Attorney General's Office for
collection of the penalty through a civil action. Please be advised that additional penalties may be assessed for violations
that occur after the review period of this assessment.
4

If you have any questions, please contact Janet Cantwell with the Division of Water Resources staff of the Asheville
Regional Office at [phone] or via email atjanet-cantwell@,ncdenr.gov.
Sincerely,
for S. Jay Zimmerman, P.G.
Director, Division of Water Resources, NCDENR
By G. Landon Davidson, Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDENR
ATTACHMENTS
Cc: WQS Asheville Regional Office - Enforcement File (w/attachments)
NPDES Compliance/Enforcement Unit - Enforcement File (w/attachments)
Central Files, Water Quality Section (w/attachments)
5

JUSTIFICATION FOR REMISSION REQUEST
Case Number: LM -2015-0011 County: McDowell
Assessed Party: Coats American Inc
Permit No.: NC0004243 Amount Assessed: $1,159.26
Please use this form when requesting remission of this civil penalty. You must also complete the "Request For
Remission, Waiver of Right to an Administrative Hearing, and Stipulation of Facts" form to request remission of
this civil penalty. You should attach any documents that you believe support your request and are necessary for the
Director to consider in evaluating your request for remission. Please be aware that a request for remission is limited to
consideration of the five factors listed below as they may relate to the reasonableness of the amount of the civil penalty
assessed. Requesting remission is not the proper procedure for contesting whether the violation(s) occurred or the
accuracy of any of the factual statements contained in the civil penalty assessment document. Pursuant to N.C.G.S. §
143B -282.1(c), remission of a civil penalty may be granted only when one or more of the following five factors apply.
Please check each factor that you believe applies to your case and provide a detailed explanation, including copies of
supporting documents, as to why the factor applies (attach additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C.G.S. 143B -282.1(b) were wrongfully applied to
the detriment of the petitioner (the assessment factors are listed in the civil penalty assessment document);
(b) the violator promptly abated continuing environmental damage resulting from the violation (i.e., explain the
steps that you took to correct the violation and prevent future occurrences);
(c) the violation was inadvertent or a result of an accident (Le., explain why the violation was unavoidable or
something you could not prevent or prepare for);
(d) the violator had not been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary remedial actions (i.e., explain
how payment of the civil penalty will prevent you from performing the activities necessary to achieve
compliance).
EXPLANATION:

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
COUNTY OF MCDOWELL
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
Coats American Inc )
Sevier Plant 1
PERMIT NO. NC0004243 ) CASE NO. LM -2015-0011
Having been assessed civil penalties totaling $1,159.26 for violation(s) as set forth in the assessment document of the
Division of Water Resources dated July 20. 2015, the undersigned, desiring to seek remission of the civil penalty, does
hereby waive the right to an administrative hearing in the above -stated matter and does stipulate that the facts are as
alleged in the assessment document. The undersigned further understands that all evidence presented in support of
remission of this civil penalty must be submitted to the Director of the Division of Water Resources within thirty (30) days
of receipt of the notice of assessment. No new evidence in support of a remission request will be allowed after (30) days
from the receipt of the notice of assessment.
This the
day of 24
ADDRESS
TELEPHONE
SIGNATURE

ATTACHMENT A
Coats American Inc
CASE NUMBER: LM -2015-0011
PERMIT: NC0004243 FACILITY: Sevier Plant COUNTY: McDowell REGION: Asheville
Limit Violations
MONITORING OUTFALL/
VIOLATION
UNIT OF
CALCULATED
%. OVER
PENALTY REPORT PPI LOCATION PARAMETER
DATE
FREQUENCY
MEASURE
LIMIT VALUE
LIMIT VIOLATION TYPE
$1.000.00 4-2015 001 Effluent FEC COLI
4/30/15
Weekly
#/100ml
200 297.80
48.9 Monthly Geometric Mean Exceeded
Monitoring Violations
MONITORING OUTFALL I VIOLATION UNIT OF CALCULATED %. OVER
PENALTY REPORT PPI LOCATION PARAMETER DATE FREQUENCY MEASURE LIMIT VALUE LIMIT VIOLATION TYPE
$0.00 4-2015 001 Effluent NH3-N - Cone 414/15 Weekly mg/l Frequency Violation
j

DIVISION OF WATER RESOURCES - CIVIL PENALTY ASSESSMENT (FILE)
Violator: Coats Sevier Plant/ NC0004243
(April 2015 DMR)
County: McDowell
Case Number: LV -2015-0011
8 ASSESSMENT FACTORS
As required by G.S. 143-214.6A(c), in determining the amount of the penalty I considered the factors
set out in G.S. 143B -282.1(b), which are:
1) The degree and extent of harm to the natural resources of the State, to the public health, or to
private property resulting from the violation;
All effluent violations may be detrimental to the receiving stream but may not
be immediately quantified.
2) The duration and gravity of the violation;
One Monthly Geometric Mean Fecal exceeded the permit limit by 48.88%.
One Weekly Ammonia Nitrogen was inadvertently left off the DMR ending 04/04/15.
3) The effect on ground or surface water quantity or quality or on air quality,
All effluent violations may be detrimental to the receiving stream but may not
be immediately quantified.
4) The cost of rectifying the damage;
The cost is unknown.
5) The amount of money saved by noncompliance;
The amount of money saved would include the cost of excess solids
removal and additional aeration.
6) Whether the violation was committed willfully or intentionally;
It does not appear to be either.
7) The prior record of the violator in complying or failing to comply with programs over which
the Environmental Management Commission has regulatory authority; and
There have been no civil penalty enforcements in the twelve months prior to
this violation.
8) The cost to the State of the enforcement procedures.
$159.26.
&I • 2' - Lam( -T--
Date
07/20/2015
G. Landon Davidson, Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office, NCDENR

May 2
0.4
EFFLUENT
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NPDES PERMIT NO,
NC0004243 DISCHARGE NO. 001
MONTH
APRIL
18
Monthly Limit
YEAR 2015
FACILITY NAME COATS
AMERICAN
CLASS III
COUNTY
McDOWELL
_1
OPERATOR IN RESPONSIBLE CHARGE (ORC) PHILLIP PITTMAN
GRADE
111
PHONE
828 756_41 1
CERTIFIED LABORATORIES
III COATS AMERICAN (21
WATER TECH
CHECK BOX IF ORC HAS CHANGED
FEERSON(S) COLL ING SAMPLES Phillip
Pittman
_
Mail ORIGINAL and ONE COPY ;o
Y 6 201 x
MAY
ATTN: CENTRAL FILES
1
(SIGNATURE OF OPERATOR IN RE SPflSIBLE
CHARGE)
DATE
DIVISION OF WATER QUALITY
Cu3aT�>�� FILE E � THIS SIGNATURE, I CERTIFY THAT THIS REPORT IS
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June 15, 2015
Coats North America
Mr. Landon Davidson
North Carolina Department of Environment & Natural Resources
Division of Water Resources
Water Quality Regional Operations
2090 U.S. Highway 70
Swannanoa, NC 28778
SUBJECT: Coats American, Inc.
Sevier Plant
PO Box 368
Marion, NC 28752
NPDES Permit No. NC0004243
NOV-2015-L-0026
Dear Mr. Davidson,
In regards to the NOV letter dated June 9th, 2015.....
Coats North America
630 American Thread Road
Marion, NC 28752
Telephone: [phone]
Fax: [phone]
E -Mail: [e-mail]
We were non-compliant on Fecal Coliform for the month of April. It was overlooked on the DMR
and marked as compliant when it was actually non-compliant. The DMR sheet shows the limit to be
400 but our permit clearly shows that 400 is the daily maximum and 200 is the monthly average that
we must meet. Fecal coliform is back in compliance for the month of May. Our average for May was
95.
An Ammonia Nitrogen sample was taken on March 31st but omitted from the DMR. Samples were
also taken on April Th, April 14th, April 21st and April 28th. An amended copy of the April DMR is
being submitted.
Sincerely,
J . o
cc: Phillip Pittman - Coats American
RECEIVED
OMslon of water Resources
JUN 18 2015
Water Quality Regional Ooerations
Asheviiie P.:' lona! �rfice