NC0004243_Concurrence Letter_20180614

Water Resources
ENVIRONMENTAL QUALITY
June 14, 2018
Mr. John Moss
Facilities Engineering Manager
Coats America Sevier Plant
630 American Thread Road
Marion, North Carolina 28752
Dear Mr. Moss:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Interim Director
The Division has reviewed the May 31, 2018 request from Bruce D. Reilly, PE with Civil &
Environmental Consultant, Inc., on behalf of Coats America for concurrence from the Division on the
non -applicability of the floodplain requirement stated in 15A NCAC 18A .1950(i) for proposed
maintenance activities in Coats America's Sevier Plant WWTP in McDowell County. Specifically,
North Carolina Administrative Code states that wastewater treatment plants shall not be located in
areas subject to frequent flooding, and mechanical or electrical components of treatment systems shall
be above the 100 -year flood level. Mr. Bruce D. Reilly, PE with Civil & Environmental Consultant,
Inc. wrote DEQ in May and stated that the Coats America Sevier Plant WWTP was constructed in the
100 -year floodplain prior to the effective date of the requirement stated in 15A NCAC 18A .1950(i),
and the maintenance activities, namely the removal of sludge from the equalization and aeration
lagoons and the replacement/upgrade of selected mechanical components are critical for the Sevier
Plant WWTP to continue to operate in compliance with their NPDES permit.
Based on this information, the Division agreed to issue this letter acknowledging the non -applicability
of the floodplain requirement for the above maintenance activities in the equalization and aeration
lagoons; however, the Division would also like to recognize that good engineering practices would be
to upgrade treatment at the facility in order to protect for a 100 -year flood event and for Coats America
to take steps necessary to prevent flooding and equipment damage that could result in permit violations
if unprotected. Please be aware, the maintenance activities and rehabilitation of the equalization and
aeration lagoons shall follow the design criteria requirements specified in 15A NCAC 02T. 0505 (d)
through (h). In addition, good engineering practices suggest raw water filtration solids be settled and
disposed of on a routine basis.
If you have any questions, or require any additional information, please contact me at [phone]
or by email at [e-mail].
Sincerely,
Bing BEngineer
NPDES Complex Permitting Unit
CC: Landon Davidson (Asheville Regional Office)
Bruce D. Reilly, PE (Senior Project Manager, CEC)
Todd Wegenast (Coats Regional Environmental Manager)
Troy Doby, PE (DWR/Non-discharge Permitting)
State of North Carolina I Environmental Quality I Water Resources
1617 Mail Service Center I Raleigh North Carolina 27699-1617
919 807 6300