NCS000304_Staff Report_20081115

NCS000304
�OF W A %Q Michael F. Easley, Governor
William G. Ross Jr., Secretary
\Q G North Carolina Department of Environment and Natural Resources
(_ Coleen H. Sullins Director
` 1 Division of Water Quality
© , C
STAFF REVIEW AND EVALUATION
NPDES Stormwater Permit
Facility Name:
Gerdau Ameristeel US Inc.
NPDES Permit Number:
NCS000304
Facility Location:
Charlotte, NC (Mecklenburg County)
Type of Activity:
STEEL MANUFACTURING
SIC Code
3312
Receiving Streams:
See Figure 1
River Basin:
Catawba .River Basin, Sub -basin 03-08-36
Stream Classification:
C
Proposed Permit Requirements:
See attached draft permit.
Monitoring Data:
See Table 1
Facility Location:
See Figure 1
Response Requested by (Date):
11/15/08
Central Office Staff Contact:
Brian Lowther, [phone]
Special Issues:
Issue
Rating Scale: 1 eas to 10 hard
Compliance history
3
Benchmark exceedance
6
Location (TMDL, T&E
species, etc)
3
Other Challenges:
• Contacting
Company
8
Difficult Rating:
20/40
Special Issues Explanation:
• Representative outfall status applied for with application. The regional currently handles this type
of application; therefore, the information is included with the staff report from them to handle.
• Timothy L. Keesling was the contact for the representative outfall status but no longer works for
Gerdau Ameristeel. The current contacts he provided were:
Corporate contact is Sunny Crews 813-505-2864
Plant Manager is Casimro Lidorio 704-596-0361
Page 1 of 10

NCS000304
Description of Onsite Activities:
• Outfall 1 — employee parking lot, drainage from roadway areas (right-of-ways not owned by Gerdau
Ameristeel)
• Outfall 2 — Right-of-way along Lakeview Road and drainage along the truck roadway and rail spurs.
Truck and rail traffic to storage areas.
• Outfall 3 — Significant materials are stored in the drainage area. This area also includes equipment
storage, co -product storage, oil storage, steel billet, and drainage from production areas. It has a large
amount of undeveloped area.
• Outfall 4 - Materials stored in this area are finished steel product, scrap metal raw material, co -
product storage areas. Area includes rail yard, production area, and fuel oil storage area.
Documents Reviewed:
• SPU File
• 2008 draft 303(d) list
• 2004 Catawba Basinwide Plan
• Central File
• EPA 2008 Sector -Specific permit, Sector F "Primary Metals"
History:
• 05/1/1995: Pennit first issued to Florida Steel Corporation
• 05/21/1996: Permit issued with named changed to Ameristeel Corporation. Analytical monitoring in the
pen -nit includes TSS, COD, BOD, Zinc, Cadmium, Lead, Phenols, Nickel, Copper, Total Rainfall, Event
Duration, and Total Flow. Monitoring was required annually.
• 08/01/2000: Permit renewed. Analytical monitoring in the permit includes BODS, Cadmium, COD, Copper,
Lead, Nickel, Phenols, TSS, Zinc, Total Rainfall, Event Duration, and Total Flow. Monitoring was
required quarterly during the 4`" year.
• 01/24/2005: Pennittee submitted renewal application.
Page 2 of 10

NCS000304
Figure 1: Map of Facility
Page 3 of 10
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NCS000304
Gerdau Ameristeel
P't
Latitude; 350 21' 20" N
Longitude; 800 49' 35" W
-
���1
County; Vk�ddenburg
Receiving Stream; UT to Long Creek
ti
Stream Class; C
Sub -basin: 03-08-34 (Catawba River Baan)
Map Scale 1:24,000
Facility Location
Page 3 of 10

NCS000304
Central Office Review Summary:
1. Owner's Other Permits:
• NCG030284 Metal Fabrication Stormwater Discharge, Charlotte Rebar Division
• NCG030290 Metal Fabrication Stormwater Discharge, Ameristeel Corporation — Raleigh Rebar
Division
• WQ0006060 Wastewater Recycling, Gerdau Ameristeel US, Inc, Charlotte Steel Mill
2. General Observations:
3312 - Steel Works, Blast Furnaces (Including Coke Ovens), and Rolling Mills
Materials of Concern Location and BMP
Electric Arc Furnace Dust contains Cadmium, Chromium and Lead (NW) Ongoing inspections and cleanup. Loading and
unloading inside building.
Lime (Calcium Hydroxide) contains Calchun IYydroxide (NW) Ongoing inspections and cleanup. Loading and unloading
inside building.
Caster Mold Lubrication Oil, Hydraulic fluids, and lubrication oils and greases contain Petroleum based organic compounds
(NE, W, and SW) secondary containment or sealed unused drums, under roofed area with secondary containment.
Petroleum fuel products — Benzene, toluene, xylene and ethylbenzene (N) Tanks have secondary containment.
Carbon (between crane buildings) Ongoing inspections and cleanup. Loading and unloading inside building.
Scrap metal containing metals and Oil & grease (E) No direct access, overland run-off to west pond.
Slag & Mill Scale piles containing metals and Oil & grease (W) No direct access, overland run-off to ditch.
Soil Erosion from exposed earth banks. Fuel drips along banks. Oil & grease and TSS (E) No direct access, overland run-off to
ditch.
Impairment: Not on 303(d) list. The Basinwide Plan states approximately 11.3 miles of Long Creek (from a
point 0.6 mile downstream of Mecklenburg County SR 2074 to a point 0.4 mile upstream of Mecklenburg
County SR 1606) are rated Impaired due to turbidity and exceedances of the manganese water quality standard.
Ambient data from the current assessment period indicate that the turbidity readings remain in violation of the
state standard. Fecal coliform concentrations are also above the state standard, but Long Creek is not used for
primary recreation. There are no NPDES discharges to this stream, suggesting that impairment is likely a result
of urban runoff, construction and agriculture in the watershed. Many general recommendations were provided
in Section A, Chapter 4, Part 4.13. Part 4.13 focuses on habitat degradation.
http://h2o.enr.state.ne.us/basinwide/documents/CTBA-4.pdf
4. Threatened and Endangered: On the National Heritage map there is one species (Villosa vaughaniana or
Carolina Creekshell) that is state regulated (E).
5. Location: This discharges to a UT to a classified C stream.
6. Industrial Changes Since Previous Permit: Replaced existing baghouse with a new enclosed baghouse to
control particulates. Upgraded glycol -water recycle cooling system. System is installed in secondary
containment tanks to prevent stormwater contamination. Installation of new co -product hauling road.
7. Analytical Monitoring Notes: Samples were taken at four outfalls during the fourth year of the permit. The
benchmarks were exceeded for BOD, Cd, COD, Cu, Pb, TSS and Zn. The values were the highest for outfall
002.
From the 2008 EPA Multi -Sector General permit, Sector F for Primary Metals recommends adding Al and Zn
based on the SIC code of 3312. There is scrap yard onsite that can have 30,000 tons of scrap metal.
Therefore, monitoring for Cd, Cu, Pb, TSS and Zn was maintained for the permit and Al was added. Phenol
was removed from the permit because the monitoring results were under the current benchmarks. Removing
Page 4 of 10

NCS000304
Nickel was considered, but Ni was maintained because of the scrap metal yard onsite and having only 4 data
points. BOD and COD remained in the monitoring because of values over the current benchmarks. Chromium
was also added based on it being in the Electric Arc Furnace Dust onsite. pH is important to include because of
the lime storage.
The representative outfall letter asked for Outfall 004 to represent Outfall 002 and for Outfall 001 to not be
monitored because it has no industrial activity. Outfall 002 has a drainage area that is primarily a road however
the monitoring data is higher for 002 than for 004. The drainage area for Outfall 001 does look to only include
the employee parking lot and no industrial activity. A site visit will probably be necessary to determine
representative outfall status.
Be sure to verify roads and parking area draining to 001 do not include industrial -related traffic (hauling,
loading, etc.).
8. Qualitative Monitoring Notes: The qualitative monitoring was recorded 11 times from 9/19/00 to 9/27/04.
Outfall 001 —Some dirt coming from roadway (Lakeview and HW 115). Event on 3/16/04 had 9s for clarity,
floating solids, and suspended solids. Blue/black color recorded on event.
Outfall 002 — Dirt from road in many event comments. Red/Black color on 7/25/02 which was from heavily
travelled road for trucks.
Outfall 003 — Light grey color in two events supposedly from slag haul road. The application stated there was a
new slag road created for co -product hauling road.
Outfall 004 — 12/13/01 muddy water from construction operation. Reddish Brown Color.
Page 5 of 10

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NCS000304
Revised Permit Recommendations: Analytical Monitoring:
1. Maintaining BOD, Cd, COD, Cu, Pb, Ni, TSS and Zn. Removing Phenol. Al and Cr are added to the
monitoring.
2. pH has been added to the analytical monitoring requirements.
3. All analytical monitoring has been set to semi-annually during a representative storm event as defined in Part II
Section B. The permittee must also document the total precipitation for each event. If no discharge occurs
during the sampling period, the permittee must submit a monitoring report indicating "No Flow" within 30 days
of the end of the six-month sampling period. Additionally, samples must be taken a minimum of 60 days apart,
as specified in Table 2.
4. Benchmarks for analytical monitoring have been added to this draft permit. Exceedances of benchmark values
require the permittee to increase monitoring, increase management actions, increase record keeping, and/or
install stormwater Best Management Practices (BMPs) in a tiered program. If the sampling results are above a
benchmark value, or outside of the benchmark range, for any parameter at any outfall then the facility shall
follow the Tier 1 guidelines which require a facility inspection within two weeks and implementation of a
mitigation plan within two months. If during the term of this permit, the sampling results are above the
benchmark values, or outside of the benchmark range, for any specific parameter at a specific discharge outfall
two times in a row (consecutive), then the facility shall follow the Tier 2 guidelines which require a repetition
of the steps listed for Tier 1 and also immediately institute monthly monitoring for all parameters at every
outfall where a sampling result exceeded the benchmark value for two consecutive samples.
5. The permittee is required to collect all of the analytical and qualitative monitoring samples during
representative storm events as defined in Part 11 Section B Qualitative monitoring is required regardless of
representative outfall status.
6. The permittee is responsible for all monitoring until the renewal permit is issued. See Footnote 1 of Tables 1,
4, and 5.
7. The flow reporting requirement has been removed per DWQ revised strategy. (The total rainfall parameter is in
this permit, however.)
8. Vehicle maintenance monitoring has been revised to semi-annually in order to coincide with analytical and
qualitative monitoring.
Other Proposed Changes to the Previous Permit:
1. Additional guidance is provided about the Site Plan requirements. The site map must now identify if the
receiving stream is impaired and if it has a TMDL established. It must also describe potential pollutants in each
outfall. The map requirements are stated more explicitly. And, the site plan must contain a list of significant
spills that have occurred in the past three years and also must certify that the outfalls have been inspected to
ensure that they do not contain non-stormwater discharges. Additional information is provided in Part II
Section A.
2. Additional requirements for the Stormwater Management Plan have been specified in Part II Section A. More
details regarding secondary containment are provided.
3. Additional requirements for the Stormwater Pollution Prevention Plan have been specified in Part II Section A.
The plan must also be updated annually to include a list of significant spills and to certify that the outfalls do
not contain non-stormwater discharges.
4. The facility must now implement a semi-annual Facility Inspection Program of the site's stormwater
management controls as specified in Part II Section A.
5. Information regarding the No Exposure Exclusion has been added to this draft permit. If industrial materials
and activities are not exposed to precipitation or runoff as described in 40 CFR § 122.26(g), the facility may
qualify for a No Exposure Exclusion from NPDES stormwater discharge permit requirements. Additional
information is provided in Part I Section A.
Page 7 of 10

NCS000304
Discussions with permittee: Permit Contact Timothy L. Keesling 704-596-0361 x 3048
Renewal Application and Request for Representative outfall:
Timothy Keesling left the company in the spring but is still helping out with questions as they look for a new
environmental manager. Talked with Timothy Keesling on 09/29/08.
Corporate contact is Sunny Crews 813-505-2864
Plant Manager is Casimro Lidorio 704-596-0361
1. Have there been any changes since the application was submitted? No
2. What type of steel plant is it? They use 100% recycled scrap. Melted and alloys are added. They make billets
and then store them. Billets are sold or made into rebar, channels, etc. Biggest stormwater issue onsite would
be the scrap yard that can have 30, 000 tons of scrap metal.
3. Is there any discharge from any of the three ponds? Some discharges in very wet weather.
4. It looks like there are some high values in your analytical monitoring, especially at Outfall 2. Any reason for that?
The drainage area is primarily road and there used to be sediment and materials on the road. Since the
monitoring, they have increased their maintenance of the road.
5. What materials are stored outside? What is the co-product? Scrap metal and carbon and lime in bags. The co-
products are steel slag and mill scale (rust). The mill scale is sold to the cement industry.
6. Asked for representative outfall for outfall 002. The analytical monitoring shows outfall 002 as the worst outfall.
Why would that be? They had poor maintenance that has supposedly changed.
7. Vehicle Maintenance? Yes. It is contracted out but the contractor comes to the vehicle.
8. What is your SIC code? 3312
Page 8 of 10

NC 5000304
Site Visit 11/6/08
Mike Parker, Brian Lowther, Ken Pickle, and Cory Larsen met with Charlie Blubaugh of Gerdau Arneristeel
The main purpose of the site visit was to examine the stormwater outfalls. Currently, the permittee was using two
streams to collect their samples for outfalls 003 and 004.
Issues that was raised at the site visit:
Outfall 001 and 002 were evaluated. Outfall 001 was employee parking that was elevated from other industrial
activates and will not require analytical sampling. Outfall 002 was primarily a haul road. The analytical
monitoring was high for this area. This is probably because of the trucks dropping off loads of scrap metal and then
leaving on the haul road. Outfall 002 will need to be sampling in the renewal permit.
Water is pumped from the West pond to the South pond and then to the North pond. The water from the North
pond is being used in a couple different ways. One is to be pumped to the slag staging area where it is used as a
contact coolant. The water sprayed on the slag then drains into the west pond. West pond is also added CO, in
order to treat the water. Therefore, there is some comingling of process water and stormwater.
Where should the samples locations be for drainage areas 3 and 4? Sample the outlet of the North pond for
drainage area 3 and sample the outlet near the capped landfill for drainage area 4.
The capped landfill has water draining from it into a stream in drainage area 3
Oil & Grease was added to the analytical monitoring.
Special Issues Explanation:
This permit will be renewed as an individual NPDES stormwater permit. The west pond onsite collects slag
quench water which is combined with the stormwater and pH adjusted. The water from the west pond
eventually ends up in the North Pond. The discharge of the North Pond will be monitored in this permit. Also,
the facility operates near zero discharge operation. During a site visit on November 11, 2008 there was a
discharge coming from the North Pond but this event was atypical because the plant was not running.
Page 9 of 10

NCS000304
Recommendations: Based on the documents reviewed, the application information submitted on January 20, 2005
sufficient to issue an Individual Stormwater Permit.
Prepared by (Signature)
Stormwater Permitting Unit Supervisor
for Bradley Bennett
Date
Concurrence by Regional Office Date
Water Quality Supervisor
Regional Office Staff Comments
Page 10 of 10
Date

NGS000304
0\4O�
0
Facility Name:
NPDES Permit Number:
Facility Location:
Type of Activity:
SIC Code
Receiving Streams:
River Basin:
Stream Classification:
Proposed Permit Requirements:
Monitoring Data:
Facility Location:
Response Requested by (Date):
Central Office Staff Contact:
Special Issues:
J4
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins Director
Division of Water Quality
STAFF REVIEW AND EVALUATION
NPDES Stormwater Permit
Gerdau Ameristeel US Inc.
NCS000304
Charlotte, NC (Mecklenburg County)
STEEL MANUFACTURING
3312
See Figure 1 , ?�
}
Catawba River Basin, Sub -basin 03-08-36
C
See attached draft permit.
See Table 1
See Figure 1
11/15/08
Brian Lowther, [phone]
Issue
Rating Scale: 1(easy) to 10(hard)
Compliance history
3
Benchmark exceedance
6
Location (TMDL, T&E
Spec . es, etc)
3
Other Challenges:
• Contacting
Company
8
Difficulty Rating:
20/40
Y�L
,y 2
�O
Special Issues Explanation:
• Representative outfall status applied for with application. The regional currently handles this type
of application; therefore, the information is included with the staff report from them to handle.
• Timothy L. Keesling was the contact for the representative outfall status but no longer works for
Gerdau Ameristeel. The current contacts he provided were:
Corporate contact is Sunny Crews 813-505-2864
Plant Manager is Casimro Lidorio 704-596-0361
Page 1 of 9

NCS00030411
-
Recommendations: Based on the documents reviewed, the application information submitted on Jamiary 20, 2005
sufficient to issue an Individual Stormwater Permit.
Prepared by (Signature) �� ���� Date (u 66 %OS
Stormwater Permitting Unit SupervisorDate 1 1 f
for Bradley Be ett
"'PIP
Concurrence by Regional Office 1Date
�e
Water Quality Supervisor. �� �'� Date /,g
E
Regional Office Staff Comments
Page 9 of 9
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Page 9 of 9