NC0004243_Report Review_20150807

NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory Donald R. van der Vaart
Governor Secretary
August 7, 2015
Mr. John J. Moss
Coats American Inc. RECEIVEDIDENRIDWR
Sevier Plant SEP - 3 2015
P.O. Box 368
Marion, North Carolina 28752 Water Quality
Permitting Section
Subject: Environmental Response and
Recommendations Report Review
Sevier Plant/Coats American WWTP
NPDES Permit No. NC0004243
McDowell County, N.C.
Dear Mr. Moss:
The North Carolina Department of Environment and Natural Resources (NCDENR) received the
Environmental Response and Recommendations Report (Report) produced for Coats American,
Inc. (Coats) by its consultant, ERM, Inc. (ERM) on July 20, 2015. The Report describes the
emergency response, follow-up actions, source analysis and planned future actions relevant to
Coats American, Inc. and the July 2015 fish kill event on the North Fork of the Catawba River.
The Asheville staff of the NCDENR Division of Water Resources (DWR) has completed its review
of the Report and offers the-following comments:
1. Page 2, Paragraph 1, Line 4: Clarification — DENR field staff observed no dead fish, but
did observe dead amphibians upstream of the confluence of the UT with Limekiln Creek.
2. Page 2, Paragraph 1, Lines 9 & 10: Clarification — indicated that the substance had no
dissolved oxygen and a high pH (11.4).
3. Page 2, Paragraph 1, Line 10: DENR field staff did not observe elevated pH and low
dissolved oxygen in Limekiln Creek and the North Fork River, otherwise known as the
"fish kill" area. The only anomalous readings were within the water impounded
immediately above the beaver dam.
4. Page 6, Paragraph 3, Lines 3 & 4: Clarification — DENR field staff observed dead frogs
(not fish) upstream of the beaver dam.
North Carolina Division of Water Resources—Asheville Regional Office
2090 U.S.Highway 70,Swannanoa,N.C. 28778
Phone[phone]
FAX [phone]
Intemet: hftp://portal.ncdenr,org/weblwq/
An Equal Opportunity/Affirmative Action Employer

Mr. John J. Moss
August 7, 2015
Page 2of5
5. Page 6, paragraph 5, Line 1: Seepage was observed on the west and south sides of the
aeration basin and equalization basin. What assessment activities and corrective action
are being proposed for the seepage associated with the wastewater treatment lagoons?
6. Page 7, Paragraph 2, Line 1: Verify the status and origin of the abandoned pipes on the
footbridge and include this information in the forthcoming report from-ERM.
7. Page 7, Paragraph 5, Line 8: Make reducing the potential for confusion amongst facility
personnel regarding floor and other potentially applicable drains a focus in future
updates to the Storm Water Pollution Prevention Plan (SWPPP). During the emergency
response, DENR field staff questioned plant personnel about the number of storm water
drains connected to outfall SW-007. Plant personnel erroneously indicated only two
storm drains in the east parking lot were connected to SW-007. Figure 5 of the ERM
report indicates 13 external storm drains connected to Outfall SW-007. Identify
opportunities to improve facility personnel's knowledge and understanding of the drain
system and applicable components.
8. Page 8, Paragraph 2, Line 2: Include any additional findings on the use of water
-treatment chemicals (biocides, etc.) in the water storage pond area in the forthcoming
reportfrom ERM.
9. Page 8, Paragraph 3, Line 2: The ash pond retains storm water and water filtration
backwash water. The discharge of water filtration backwash into the coal ash basin is
not authorized under the current permit,(closed-loop recycle system). The practice of
discharging backwash water to the coal ash basin must be eliminated immediately.
10. Page 9, Paragraph 2, Line 1: How was it determined that,the grass "burns" were not
chemical in nature? Can photos be provided? How will ERM confirm that the area was
not impacted by a "spill"?
11. Page 9, Paragraph 3, Line 3: Chiller blow-down and cooling water should be routed to
the WWTP -or permitted under wastewater discharge pursuant to the NOV/NRE. All
cooling water (cooling tower, chiller room, boiler room, etc.) shall be directed to the
wastewater treatment plant or permitted under NCG500000. All water treatment water
(plant filtration, water storage pond, backwash, etc.) shall go to WWTP or be permitted
under NCG590000.
12. Page 10, Paragraph 4, Line1: Provide further detail on what chemicals are being stored
in the external chemical storage area. Are there any containment measures currently in-

Mr. John J. Moss
August 7, 2015
Page 3 of 5
place for the external chemical storage area? Does natural site topography in the
external chemical storage area allow water to drain towards a nearby storm water
discharge?
13. Page 10, Paragraph 5, Line 1: describe what chemicals (and quantity) are being stored in
the internal chemical storage area.
14. Page 10, Paragraph 5, Line 10: Include additional detail on the vertical caustic storage
tank, caustic transfer station, and associated piping in the forthcoming report from
ERM. Has the integrity of the caustic piping been verified?
15. Page 10, Paragraph 6, Line 1: Please explain the location and function of the water
settling basins. What chemicals are used for this process? How are these basins cleaned
and maintained?
16. Page 10, Paragraph 7, Line1: Is there potential for an internal plant spill to migrate
underneath the external walls and be conveyed through the roof drains (at ground level)
to the storm-drainage system?
17. Page 11, Paragraph 3, Bullet 3: What approximate quantities of the listed chemicals are
stored in the water filtration plant? Provide a narrative describing in detail the chemicals
and processes used in the filtration plant. Include the measured or estimated quantities
of water being used for processing and that being sent to the storage ponds? What is
the estimated yield of the supply well?
18. Page 11, Paragraph 5, Bullet 1: What cleaning chemicals are stored/used in this area?
Describe in detail the process used for cleaning the bird droppings. Your description is to
include, but not be limited to, names of staff involved in cleaning, chemicals used,
amounts of chemicals used, time of the event, duration of the event, amount of water
used, etc.
19. Page 12, Paragraph 2, Line 7: What is the status of the floor drain connection project?
Do any additional areas of the facility have floor drains with the potential for
connections to areas other than the WWTP? Confirm that an updated floor drain plan
will be produced as part of the SWPPP.
20. General Comment: How are caustic chemicals introduced and used in production? For
example, how are the caustic chemicals delivered to the plant (including quantities);
how and where are they off-loaded; and how are they (chemicals) introduced into the

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Mr.John J. Moss ,
August 7, 2015
Page 4of5
various production processes (i.e. piping or by hand)? In addition, what is the estimated
daily use (volume) of caustic chemicals in the production process?
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21. General Comment: In the forthcoming ERM report, you are to include an estimate of the
amount of caustic that would have potentially caused an event of this magnitude?
22. General Comment: Provide a schedule for the Inventory Loss Evaluation and s
forthcoming report from ERM.
23. Page 13, Paragraph 4, Line 4: Report states that potential for berm failure is low
(wastewater treatment), yet numerous large tree roots are assumed to penetrate the
berm and could compromise structural integrity if they die/rot etc. Has this been
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considered as a failure mechanism? Remove all woody vegetation from the slopes of the
berm. Visually inspect the entire impoundment daily.
24. General Comment: Has the former sludge drying bed area been assessed as a potential I
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contributing factor for this event? Please provide a narrative of the historical use of this
area including dates of active use, and an estimate of remaining sludge material.
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25. General Comment: Provide a timeline for proposed future assessments and reports.
26. Page 15, Bullet 6: Evaluate ponds to verify if the discharge complies with both storm
water and wastewater regulations.
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27. Page 15, Bullet 7: How will inspections be performed, and what is the proposed n
mechanism for triggering less frequent inspections?
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28. General Comment: According to Figure 5, Outfall SW-007 runs underneath the plant at
two locations. Is there any evidence of spills in these areas? Are there any operations s
involving caustic chemicals present in these two locations? Is there any evidence of a
potential connections between these two internal locations and Outfall SW-007? Is a
camera evaluation of the pipe leading to Outfall SW-007 where it runs under the facility
being considered? ;
29. General Comment: In the forthcoming report, you are to summarize all existing
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analytical data (e.g., PAHs, metals, etc.) collected since the fish kill event initiation,
provide maps as needed to represent data locations, and provide a narrative evaluating
the results. The narrative is to include an evaluation of the source of constituents
detected, a comparison to applicable regulatory cleanup levels, an evaluation of the
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Mr. John J. Moss
r August 7, 2015
Page 5 of 5
potential for impact to groundwater and/or surface water and.recommendations with
regard to additional sampling or corrective measure.
30. General Comment: Provide a narrative as an addendum
If you have questions concerning this matter, please do not hesitate to contact me at 828-296- ,
4500.
Sincerely,
s
Timothy Heim, P.E. Environmental Engineer
Water Quality Regional Operations, DWR
Asheville Regional Office
cc: WQ Asheville Files
DEMLR ARO Stormwater
MSC 1617-Central Files-Basement
WQ Enforcement)NPDES Point Source Branch
G:\WR\WQ\McDowell\Wastewater\Industrial\Coats 04243\ERM ER3 Report Review Response Letter 2015GLDw
edits.doc