04.02.2012 map and emails

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Pickle, Ken
From: Pickle, Ken
Sent: Monday, February 22, 2016 5:50 PM
To: Bennett, Bradley
Subject: FW: Description of Ponds, Horsehead, NCS000562
Bradley,
It looks to me like there are two open items recently raised requiring our review and comment. The first is the spill. The
second is the basin designated as the "Storm Pond", one of four ponds on the west side of the facility. As you suggest,
I'll look again at the permit text, and at the application materials. NCS000562, effective 4/1/2013.
Summary:
• For the spill into the energy dissipater, and whether there is a permit violation:
o Part I Section B authorizes the discharge of stormwater that has been "adequately treated" With
respect to any zinc residuals in the energy dissipater or the rest of Basin #1, until the benchmark testing
is accomplished, we won't have a basis to assess whether or not any zinc residuals from the spill are a
possible cause of violation of the 'adequately treated' requirement.
o Part II Section A requires secondary containment to prevent runoff pollution. Leaking secondary
containment is no secondary containment. The permittee has violated this requirement of the
permit. But, presumably he fixed it right away.
o Part III Section C requires the permittee to properly operate and maintain the systems put in place to
achieve compliance with the permit. We would apply this requirement to the requirement for
secondary containment, and note that he has failed to properly operate and maintain the system. But
again, presumably he fixed it right away.
o Summary: Yes, there's a permit violation as a result of a water line breaking and ineffective
secondary containment. Environmental impact is not yet established.
• For the "Storm Pond" and whether discharges from it are permitted under our permit
o Not mentioned by name in the text of the permit.
o Not mentioned by name in the application narrative, although the submitted site drawing indicates that
the pond in question is part of the 10 -acre Area 200 part of the facility. The whole Area 200 is noted on
the drawing as having recycle back to the process for contaminated stormwater, or controlled release
for tested and confirmed clean stormwater, as are several other areas of the site. The level of detail of
the drawing does not indicate the nature of any effluent structure or piping configurations, either in the
individual containment structures, or in the Storm Pond. As I think I recall from the on-site meeting
previously, site personnel reported that there was a piping connection at the pond, but that it had never
been used, and that it never would be used to discharge stormwater. I conclude that the purpose of this
basin is a manufacturing process purpose, not an environmental or stormwater purpose, despite the HH
name. Note that HH correspondence reports that the facility captures rainfall to reduce reliance on city
water.
o We have an inspection report indicating sediment accumulation in the pond, with the assumed potential
for zinc concentrations.
o Summary: Our permit provides that fluids from secondary containment can be released if found
uncontaminated. I would not consider this Storm Pond a secondary containment. To me, secondary
containment implies limiting the environmental exposure to an area immediately around the tankage
involved. That is not the case here. I think the pond is functioning more for rainfall capture for process
purposes, process fluid volume capacitor, spill reclaim, and recycle basin. I think there is a very basic

distinction to be made between normally passive, infrequently used, secondary containment for
environmental protection and a process fluid capacitor.
Ken
BACKGROUND DISCUSSION SUPPORTING THE SUMMARY ABOVE
On the first issue of the spill. I've gone over the Horsehead permit, NCS000562, and see these potential elements of the
permit that might be relevant. The circumstances are: a water line break that filled a containment structure to a point
where a portion of the contents of the containment leaked out through a failed seam between materials, and then got
into the stormwater-only collection system.
• No help: our permit authorizes stormwater discharges associated with industrial activity, and it does not appear
that the circumstances have resulted in a discharge. (Jeff reports that HH reports that the material was
completely contained in the concrete -lined energy dissipater basin.)
• No help: As to any zinc residuals, the material was pumped out. We would rely on the zinc benchmark in the
permit to control zinc content in any stormwater discharges due to any (presumably?) small amount of
residuals remaining in the energy dissipater structure.
• No help: Part I Section B: "Any other point source discharge to surface waters of the state is prohibited unless
it is an allowable non-stormwater discharge or is covered by another permit, authorization, or approval. The
stormwater discharges allowed by this permit shall not cause or contribute to violations of Water Quality
Standards." Again, in the first sentence, there was no discharge. In the second sentence no evidence of a wqs
violation from the non -discharge.
• No help: Part IV Definitions: "Allowable Non-stormwater Discharges This permit regulates stormwater
discharges. Non-stormwater discharges which shall be allowed in the stormwater conveyance system are:
a. All other discharges that are authorized by a non-stormwater NPDES permit.
b. Uncontaminated groundwater, foundation drains, air -conditioner condensate without added chemicals,
springs, discharges of uncontaminated potable water, waterline and fire hydrant flushings, water from
footing drains, flows from riparian habitats and wetlands.
c. Discharges resulting from fire -fighting or fire -fighting training, or emergency shower or eyewash as a result
of use in the event of an emergency."
But, again, without a resulting discharge. I question whether this part of the permit is triggered.
No help: With respect to any portion of the original application submittal, there are portions that speak in a
limited way to provisions for spills. Form 2F in four places reports that, "Material exposed to stormwater will be
minimized, and when necessary will be managed to avoid potential impact to stormwater discharged from the
facility." (2F, IV B). "This scheme for managing stormwater in the production area of the facility and other areas
of the property will minimize the potential for pollutants to enter stormwater that is discharged from the site."
(21F, IV Q. "Materials will be managed to prevent the potential for entry in stormwater that is discharged from
the facility." (2F, VII E). "The facility is designed and will be constructed and operated in a manner to minimize
the potential for materials to enter stormwater that is discharged." (2F, VII C). So, the application states that
HH will manage the materials and stormwater, and will also design and construct the facility, to prevent the
discharge of polluted stormwater. Those statements might together be construed to say that spilled
materials would not be transported off site in a stormwater discharge. But again, without a resulting
discharge, the reasonable interpretation might be that the facility indeed managed the spill to prevent the
discharge of site stormwater containing the spilled materials.
Some help: Part I Section B: "Until this permit expires or is modified or revoked, the permittee is authorized to
discharge stormwater to the surface waters of North Carolina that has been adequately treated and managed in
accordance with the terms and conditions of this permit." Vague "adequately treated and managed" offers some
direction, but would be hard to definitively pin a violation on HH, imo. I think the probable measure of

"adequately treated" is the discharge concentration of Zn. if the zinc concentration is over benchmarks, and if
the exceedance might be attributable to the spill from the WOX containment, then the spill might be the basis
for asserting that the permittee did not adequately treat and manage his stormwater discharge.
• Some help: Part II Section A SPPP: "Secondary Containment Requirements and Records. Secondary
containment is required for: bulk storage of liquid materials including petroleum products; storage in any
amount of Section 313 of Title III of the Superfund Amendments and Reauthorization Act (SARA) water
priority chemicals; and storage in any amount of hazardous substances, in order to prevent leaks and spills
from contaminating stormwater runoff. A table or summary of all such tanks and stored materials and their
associated secondary containment areas shall be maintained. If the secondary containment devices are
connected to stormwater conveyance systems, the connection shall be controlled by manually activated
valves or other similar devices, which shall be secured closed with a locking mechanism. Prior to release into
the stormwaters conveyance system, any stormwater that accumulates in containment areas shall be at a
minimum visually observed for color, foam, outfall staining, visible sheens, and dry weather
flow. Accumulated stormwater may be released if found to be uncontaminated by any material." The leaking
secondary containment system has failed this part of the permit requirements, since leaking secondary
containment is no secondary containment. Failure to provide secondary containment would be a permit
violation.
• Some help: Part III Section C Boilerpate: " Proper Operation and Maintenance The permittee shall at all times
properly operate and maintain all facilities and systems of treatment and control (and related appurtenances)
which are installed or used by the permittee to achieve compliance with the conditions of this
permit." Possibly we could propose that the permittee has not complied with this permit requirement since
leaking secondary containment is not proper operation and control of the systems installed to achieve
compliance with the permit.
With respect to the basin designated as the "Storm Pond" and any discharge from it:
• The text of the permit does not speak to such a pond by name. Nor by any indirect reference.
However, note that the face of the permit references GS 143-215.1 which establishes the requirement for a
permit, and from which 15A NCAC 2H .0126 springs which incorporates by references 40 CFR 122.26, which
authorizes "discharges composed entirely of storm water", which is the basis for us casually characterizing our
permits as "stormwater-only' permits. All to say that if this pond has any process fluid flowing into it, it can't
be discharged under our permit. But, we do have a confusing circumstance with area drainage from the sloppy
areas of the facility. If that material produced by operations sloppiness is transported by runoff into the Storm
Pond, can it be discharged under our permit, assuming it would be found to be uncontaminated? Even so, it is d
not clear that the Storm Pond is equipped with a discharge line to our Basin #1 along the Broad River.
The HH application materials describe four categories of flows that mi ht be generated at the site. b¢
o HH uses the term 'discretionary storm water" for r in some process as will be colletedy
and tested and potentially used in the process. or rested prior to dischar e r released as stormwater.
o HH further intends to collect rainfall from certainther process areas and always use the water as part
of the process. �
o Additionally, HH uses the term "non -discretionary storm w rrSintall originating on the perimeter
roadways, commercial areas, and roof tops of the site, but without contact with the industrial
processes. Such flows will be discharged directly to the stormwater outfall.
o Rainfall originating from undeveloped areas (fill and vegetated areas not affected by plant activities) will
be essentially treated as not qualifying as regulated stormwater, and will be discharged unmanaged as
the terrain dictates.
o None of the HH categorizations above specifically identifies the "Storm Pond."
o While these are HH classifications, they mean nothing to us except insofar as the containment structure
liquids are stormwater-only liquids, testing clean. Our permit only authorizes stormwater-only
discharges, free of any contamination
0 The HH 2013 Integrated Contingency Plan covers the SPPP requirements in Chapter 4.0.

o Paragraph 4.2.2 reports that, 'Tbffpare no secondarycontainment areas that are connected to storm
water conveyance systems. A portable hose will be used to transfer water from the secondary containment
to the storm water system, if needed. Storm water that accumulates in the containment areas will be
visually observed and tested to ensure contaminants are below permit limits before being released to the
storm water conveyance system." This entrywould be consistent with our permit requirements for
secondary containment.
Ken Pickle
Stormwater Program Specialist
DEMLR Stormwater Permitting Program
Department of Environmental Quality
919 807 6376 office
ken. [e-mail]
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury St, Raleigh, NC 27604
f C&
—/'Nothing Compares �.
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Pickle, Ken
Sent: Friday, February 19, 2016 1:47 PM
To: Davidson, Landon <[e-mail]>; Menzel, Jeff <[e-mail]>; Burch, Brent
<[e-mail]>; Heim, Tim <[e-mail]>
Cc: Bennett, Bradley <[e-mail]>; Aiken, Stan E <[e-mail]>
Subject: FW: Description of Ponds
Hi guys,
Thanks for bringing us up to speed. I'll talk with Bradley a little more about this over the next few days to see what/if
this may mean under our permit coverage of Horsehead.
Ken
Ken Pickle
Stormwater Program Specialist
DEMLR Stormwater Permitting Program
Department of Environmental Quality

919 807 6376 office
ken. pickle ()ncdenr.gov
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury St, Raleigh, NC 27604
-/'Nothing Compares,..
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Davidson, Landon
Sent: Friday, February 19, 20161:26 PM
To: Menzel, Jeff <[e-mail]>; Burch, Brent <[e-mail]>; Aiken, Stan E
<[e-mail]>; Pickle, Ken <[e-mail]>
Cc: Heim, Tim <[e-mail]>
Subject: RE: Description of Ponds
To all,
Thanks Jeff. This is a good revision or correction to my email from yesterday. This sentence regarding the stormwater
pond: Most likely there is zinc and other constituents within this sediment the concentrations are not known at this time.
could suggest a potential violation of the stormwater permit? Does there need to be more investigation into how the
ponds, or at least the SW capture pond, is being used and its connection to stormwater outlets? I just don't have the
background on the SW side for this type of facility where SW is captured in ponds that are bled into a process and if
recycling occurs in that same pond.
G. Landon Davidson, P.G.
Regional Supervisor – Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ – Division of Water Resources
828 296 4680 office
828 230 4057 mobile
Landon. DavidsonCrDncdenr.00v
2090 U.S. Hwy. 70
Swannanoa, N.C. 28711
-/'Nothing Compares
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Menzel, Jeff
Sent: Friday, February 19, 2016 11:39 AM
To: Burch, Brent <[e-mail]>
Cc: Davidson, Landon <[e-mail]>; Aiken, Stan E <[e-mail]>
Subject: Description of Ponds

On the West side of the HH property there is a series of 4 lined ponds. Starting south and going north the ponds are
called the following names; Storm pond, West Maintenance Pond, Raffinate Pond, and Depleted Solution Pond.
1. Storm Pond. Collects storm water from the road ways on the western half of the property. Collected storm
water than can be introduced into the process as needed or if there is a surplus after a storm event the water is
routed through bleed treatment and discharged as wastewater. There is approximately 3 to 4 feet of material in
the bottom of this pond consisting of sediment introduced during construction and process materials
introduced through spills, tracked materials washing off roadways, etc. Most likely there is zinc and other
constituents within this sediment the concentrations are not known at this time.
2. West Maintenance Pond. This pond was designed to collect storm water and process materials
within secondary containment units on the west side of the property. This water can be introduced back into
the process to recover process materials.
I am unsure the extent of sedimentation within this pond.
3. Raffinate Pond. Collects water from the 200 Area Raffinate secondary containment. Can be introduced back into
process.
4. Depleted Solution Pond. Spent electrolyte solution can be introduced back into process to be combined with
organic solvent to hold the purified zinc in solution or can be routed through bleed treatment to remove built
up impurities or contaminants.
During this idling period the facility will have to continue to process storm water on the west side of the property. They
will do this by collecting the water from west roadways and containment units, routing storm water to the Storm and
West maintenance ponds, and then processing in the bleed treatment process to be discharged from their 001
wastewater outfall. Other parts of facility which will also have to remain active during this time included units which
process the organic solvent solution and the zinc furnace.
There was a release this week to storm water Basin 1. The spill was contained in the energy dispersion unit. A 2" city
water line broke around 5 am this water flowed into the WOX silos containment. A leaked then occurred in the WOX
silo containment wall seam and the water made its way into the storm water system on the east side of the property.
The concrete energy dispersion unit collected the water and they were able to pump and haul from this unit so there
was no discharge to the other parts of the storm water basin.
Jeff Menzel
Western Region Environmental Specialist
Hazardous Waste Section
Division of Waste Management
828 419 5034 office
919 270 1967 cell
[e-mail]
PO Box 1568
Black Mountain. NC 28711
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ompares,-
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Pickle, Ken
From:
Pickle, Ken
Sent:
Friday, February 26, 2016 10:46 AM
To:
Aiken, Stan E
Cc:
Bennett, Bradley; Walker, Fred
Subject:
Horsehead spill and Stormwater Permitting Program wrap up for now
Hi Stan,
It's Friday, and I'm trying to wrap-up/nail-down a few issues that crossed my desk over the last couple of weeks,
including our comments on the February spill at Horsehead and the suspension of start-up and manufacturing
activities. I've spoken with Bradley (programmatic concerns) and with Mike Lawyer (experienced in
enforcement/implementation of our permits from a Regional Office perspective.) Most of this we have already covered,
but just in case it comes up again in ARO, here's where I think we should be (based on what I think we know about the
site and spill):
• They have not applied for rescission of the stormwater permit yet, but if they do it would not be automatic for
us. I think there's a reasonable case to be made that we would require them to clean up the site (remove
potential stormwater exposure to our satisfaction) before we would rescind the permit. We have the authority
in federal rule to require continuing permit coverage and compliance even if the plant shuts down. Continuing
on this idea, ARO or RCO should advise HH that the permit is still in effect until we officially rescind it. Do you
guys want to do that, or would you prefer me to?
• The "Storm Pond" should never discharge directly to surface waters based on our understanding of its use and
contents. Discharge of the fluids in that basin is not authorized under the our stormwater permit, NCS000562.
• With respect to the February 2016 spill:
o The text of the permit requires HH to provide secondary containment. Arguably leaking secondary
containment is no secondary containment, and results in a violation of permit conditions. So, yes there
has been a permit violation. However, I have the impression that their response was pretty good, and
that no zinc solution reached the receiving waters. ARO can decide if issuing an NOV/NOD is
appropriate.
o On the same topic, the text of the permit requires the permittee to properly operate and maintain all
systems for pollution control at all times. Again, leaking secondary containment is evidence of the
permittee's failure to properly operate and maintain that control system. Again, again —your call on
how much to make out of this.
o Summary: Yes, the circumstances of the spill amount to a permit violation. The appropriate level of our
response to the violation deserves careful consideration.
• I know you all have been out to the site several times during construction and start up, but I don't see a BIMS
entry for a permit compliance inspection. If HH is high on your radar, consider if it's time for a compliance
inspection. The fact that they are shutting down operations might ease our concerns a little, but imo reduced
staff and management attention to the physical plant along with atypical operations (shut down procedures)
would increase our concerns to an even greater degree.
o It might be worthwhile to get copies and review all their stormwater monitoring results as part of the
inspection. (I'd like to see those, too.)
o After the big spill in 2015 HH promised to go around to all the containments and
inspect/repair/revise/address the failure mechanism (seam between tank wall and containment wall)
identified in that spill. Can they provide work orders/logs/ physical evidence that indeed they did that
to a substantial extent?
o Do they intend to do the same thing for the failure mechanism in this second spill (I mean both the
water line break and the containment failure.)

Ken
Ken Pickle
Stormwater Program Specialist
DEMLR Stormwater Permitting Program
Department of Environmental Quality
919 807 6376 office
ken. [e-mail]
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury St, Raleigh, NC 27604
�Nothing Compares..
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

Pickle, Ken
From: Pickle, Ken
Sent: Tuesday, February 23, 2016 12:37 PM
To: Bennett, Bradley
Subject: FW: Interpretations of site conditions vs permit requirements, Horsehead Corp, ARO
Hi Bradley,
I spoke with Mike Lawyer about Horsehead. His comments included:
• We shouldn't rescind their permit, even though they are shutting down. I advised that they hadn't requested
rescission, and that my expectation is that significant exposed materials would remain.
• Did they make timely notification of the spills? I advised Yes.
• Sounds like they did just what we would hope they would do in response to a spill. Based on my description of
their response actions on the first spill.
• Note that permit provides they still can't contravene WQS. DWR should pursue this if they're interested, but
not DEMLR.
• Mike concurs that leaking secondary containment is inadequate, and does not meet the permit
requirements. He has encountered this before and required permittees to beef up the secondary
containment to the point of adequacy. I explained the mechanism of the first leak, and that although I don't
know the exact mechanism in the second leak, it was again a containment failure.
• Mike suggested review of the permittee's Spill Prevention and Response Plans to see if they're adequate. I
reported that the spill responses have been good, so for. And that after the first spill HH reported that they
would institute an inspection and repair program specifically targeting the failure mechanism for sPW
prevention. Whether they have followed through with the spill prevention portion or not I don't know. He
suggested we confirm the follow through on the first spill prevention actions.
• Mike suggested review of the permittee's secondary containment design basis. I failed to report to Mike that
HH asserted that the containment has been designed for the 100 -yr rainfall – I probably need to check that early
comment to be sure it's still valid_ I did confirm that the failure mechanism was not overtopping, afaik.
• Mike would consider a CEI. I advised that ARO had been on sited�riag nction, i— n Apri12�1 , in
response to the first spill, but not to conduct a CEI.
• Mike would be interested in whether the sampling shows that the facility was meeting the benchmarks
before/after the spills.
KBP Summary Conclusions and proposed Actions:
(Based on review of permit text 2F and application materials, SPPP chapter in the Integrated Contingency Plan,
discussion with Mike Lawyer)
• Inadequate secondary containment is a permit violation. Response actions have been very good. KBP
opinion: No further action by DEMLR.
• We/ARO should notify HH that the stormwater permit remains in effect nnril wQ res_cind it: and we likely won't
based on our understanding of site conditions.
• We/ARO should review any monitoring results in relation toCefore and after the spills.• We/ARO should confirm that HH subsequently acted to prev tcontainment ;he
he mechanism in the
first spill, and that the mechanism in the second spill will likewise re reventative measures at other \
co ments. �—
• RO may want to consider a stormv✓ater CEI.
• The "Storm Pond" should never discharge directly to surface waters based on our understanding of its use an�
contents.

• KBP to advise Stan of these conclusions. Bradley, any cautions, comments, or corrections?
KBP
Ken Pickle
Stormwater Program Specialist
DEMLR Stormwater Permitting Program
Department of Environmental Quality
919 807 6376 office
ken oickleCd)ncdenr.gov
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury St, Raleigh, NC 27604
--::' Nothing Compares
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Lawyer, Mike
Sent: Tuesday, February 23, 2016 9:32 AM
To: Pickle, Ken <[e-mail]>
Cc: Bennett, Bradley <[e-mail]>
Subject: RE: Interpretations of site conditions vs permit requirements, Horsehead Corp, ARO
Hey Ken. I should be in the office today and likely tomorrow as well.
Michael Lawyer, CPSWQ
Environmental Program Consultant
Division of Energy, Mineral and Land Resources I Land Quality Section
North Carolina Department of Environmental Quality
910 433-3394 office
mike. lawver cDncdenr.gov
225 Green Street, Suite 714
Fayetteville, NC 28301
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Erhail correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Pickle, Ken
Sent: Tuesday, February 23, 2016 9:08 AM

To: Lawyer, Mike <[e-mail]>
Cc: Bennett, Bradley <[e-mail]>
Subject: Interpretations of site conditions vs permit requirements, Horsehead Corp, ARO
Hi Mike,
I'd like to chat with you about the circumstances around a permitted facility in ARO. Are you available over the next
couple of days to speak with me on two issues at the subject facility in ARO?
Background:
o Horsehead Corporation holds our individual stormwater permit NCS000562, issued for the first time April 1,
2013. The facility is sited above the flood plain, on the high banks of the Broad River, just west and south of
Mooresboro, NC. The Broad River is class C at that point.
o They take zinc by-products from manufacturing processes and further refine it into ultra-high purity zinc, for
which there is a very profitable specialty market.
o The construction and start-up have been plagued with problems both wrt production and 1romm�G o enta
plant was moth -balled earlier this month, never having reached full scale production. T�shake-out period jus
stretched on and on.
o We have a report that a portion of the management and engineering staff will remain on site farthe #i
being. They are not going down to just security staff.
o First issue: There have been at least two spills of zinc -enriched solutions, one earlier this month, and one last
year.
o DEMLR ARO and SPP are interested because both spills made it to our site stprTw
AtsH7aV—nffft#Rthe
hill oaloround immediately adjacent to the Broad River. A portion of t66 -first spill passed into e
;Broad River,•- the second spill was contained in the 'energy dissipater, theconcretelined first c amber
i-ofthe stormwater basin (Energy dissipater because: 60" stormwater pipe, 80`drolT.)�
o DWR ARO surface water and ground water are interested because of the potential for zinc to reach both
the Broad River and ground water.
o DWR ARO Haz Waste folks are interested because the spilled zinc solution might be, ed haz
waste now that it has been released to the environment.y
o DWR NPDES has issued a wastewater discharge permit for the fa ' ity ut the spill incidents don't S��V
appear to trigger any concern under the wastewate ' . A portion of t first spill reached the
Broad River, and might be considered discharging wastewater without a perm .
production area. The basin's primary purpose is to�a'pture-stormwaterand spills for introduction back into the
process (they need rainwater to augment city water in the process.) Discussion has arisen on whether that
stormwater could ever be discharged if it tested clean, given the sloppy operation and presence of process fluids
leaking onto the pavement draining to the pond.
So, my questions have to do with whether you have had opportunity to apply the stormwater permit conditions or
boilerplate to similar spill circumstances. The other ARO Divisions seem to expect DEMLR to act under the
stormwater permit, but it's not clear to Bradley and me where the text might be used to either require action or to be
the basis of an enforcement/NOV/NOD. What portions of the permit text have you used to encourage better
behavior from our permittees?
Please let me know when you can make time to chat.
Thanks,
Ken
Ken Pickle
Stormwater Program Specialist

DEMLR Stormwater Permitting Program
Department of Environmental Quality
919 807 6376 office
ken. oickleCa)ncdenr.aov
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury St, Raleigh, NC 27604
=.I. Nothing Compares�
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

v
HORSEHEAD METAL PRODUCTS, INC.
484 HICKS GROVE. ROAD
MOORESBORO, NORTH CAROLINA 28114
October 9, 2015
Via Electronic Mail Oandon.davidson Amcdenr.eov) and U.S. Mail
Mr. G. Landon Davidson
North Carolina Department of Environment and Natural Resources
Water Quality Regional Operations
Asheville Regional Office
2090 U.S. Highway 70
Swannanoa, NC 28778
Re: Notice of Violation/Notice of Intent to Enforce
NOV-2015-DV-0188 (SIMS Inc. #201501151)
Rutherford County
Dear Mr. Davidson:
On September 24, 2015, Horsehead Metal Products, LLC (Horsehead) received the above -
referenced Notice of Violation/Notice of Intent to Enforce (NOV) related to a release of low pH
solution at the Mooresboro facility. As requested, this letter provides a report assessing the
cause, significance, and extent of the release and a plan listing all actions to prevent future
releases.
With respect to the allegation of discharge in violation of G.S. 143-215.83, the release of the
solution from the cellhouse containment was mitigated such that any discharge to the Broad
River would not have resulted in a violation of G.S. 143-215.83. Specifically, the definition of
"discharge" in Article 21a of Chapter 143 provides in relevant part as follows:
"Discharge" shall mean, but shall not be limited to, any emission, spillage,
leakage, pumping, pouring, emptying, or dumping of oil or other hazardous
substances into waters of the State or into waters outside the territorial limits of
the State which affect lands, waters or uses related thereto within the territorial
limits of the State, or upon land in such proximity to waters that oil or other
hazardous substances is reasonably likely to reach the waters, but shall not
include amounts less than auantities which may be harmful to the uublic health or
welfare as determined pursuant to G.S. 143-215.77A;
G.S. 143-215.77(4). Section 143-215.77a provides that quantities of designated hazardous
substances for purposes of this Article are the quantities of designated hazardous substances as
established by the EPA pursuant to Section 311 of the Clean Water Act. The EPA has
promulgated the quantities for designated hazardous substances at 40 C.F.R. § 117.3. The
regulatory quantity for sulfuric acid is 1,000 pounds. Given the concentration of sulfuric acid in
the released process solution and the subsequent efforts to mitigate any portion of the release

HORSEHEAD METAL PRODUCTS, INC.
484 HICKS GROVE ROAD
MOORESBORO, NORTH CAROLINA 28114
which reached the stormwater system, there is no reasonable potential that the regulatory
quantity for a "discharge" under G.S. 143-215.77a could have been released to the Broad River.
Upon discovery of the lower than typical pH in the energy dissipater on September 5, 2015, plant
personnel closed the main gate valve at the outfall to the Broad River an gate valve on the
energy dissipater at Basin 1. The energy dissipater is the first structure in the Basin I system and
serves to slow stormwater as it enters Basin 1. Since there had been an extended period without
any substantial rainfall prior to September 5, 2015, Basin 1 was emmty and no discharge to the
Broad River occurred to that point in time. The gate valves at the energy dissipate'—ran 3asin 1
remained closed throughout the investieation of the source of the lower than typical pH.
Following a rain event on September 9. 2015, approximately 200,000 gallons of water was
removed by vacuum truck from Basin 1. This water was recycled for use in the plant process.
Additionally, sediment in the energy dissipater and sediment in Basin.1 with any vis—ible impacts
from the solution release were removed and placed in roll -off containers. Although the gate
valve at Basin 1 remained closed, a leak near the gate valve in the discharge sbucture was
discovered which allowed water from the basin to be discharged to the Brad Rivgr.' While the
leak con' until a repair was completed at 7 p.m. on September 11, the remediation of the
stgAUjQ-aaid-sol jV released to the stormwater system was concluded on September 'and
thus mitigated any impacts to the stormwater in Basin 1 such that the quantity of sulfuric acid
discharges would not have reached the regulatory quantity for a "discharge" in violation of G.S.
143-215.83.
G46 e'Z I7
Additionally, despite any elevated concentrations of cadmium, lead and zinc in the water sample
referenced in the NOV, these elevatedsmncentrations do not constitute an unlawful discbarge
pursuant to G.S. 143-215.83. These metals are covered by the benchmarkine
requirements under =Stormwater Permit Na.NC.S000562, and therefore any elevated
levels of these metals would be addressed under the terms of that Permit. As such, any discharge
with these elevated metals would not be a discharge in violation of G.S. 143-215.83. `k�,,)LJ
1. Report on the Release C
On the evening of September 5, 2015, plant personnel identified a potential problem during the
course of routine inspection at Basin I of the facility stormwater system. Using a basic pH
testing strip, testing indicated a pH less than 6.0 Standard Units in the stormwater entering the
energy dissipater which is the first structure in the Basin 1 system.[ Further investigation
indicated that the source of the subject water may have been material inadvertently making its
way into the storm drain system from a malfunctioning pump in the vicinity of the cellhouse
earlier that day. On September 6, 2015, testing of water entering the energy dissipater again
indicated a lower than typical pH. A subsequent investigation was undertaken to identify the
source of water entering the stormwater system. This investigation revealed water entered the
I Basin 1 is a sedimentation basin, and the energy dissipater serves to slow stormwater entering Basin 1.
Business Confidential Information

G - 4
storm drains in the vicinity of the cellhouse, at which time efforts were underway to identify the
source. '
On ,September 7, 2015 an investigation was initiated to identify potential sources of water
entering the stonnwater system in the vicinity of the cellhouse. Two contractors were engaged to
assist in this, effort. One company conducted a CCTV inspection inside the storm line in the
vicinity of the cellhouse to identify the location of water entering the stormwater system. The
other company installed an air"bladder to prohibit water flow from the area into the downstream
stormwater system. While the bladder was effective in stopping any additional flow from the
cellhouse area, the results of the CCTV inspection were inconclusive as to the location of the
water entering the stormwater pipe.
On September 8, 2015, a detailed surface investigation was initiated in the cellhouse area to
identify locations where seepage into the stormwater system may have occurred. A void located
in a joint where a recirculation tank is in contact with the cellhouse secondary containment
structure was discovered. The material escaped, as a consequence of a pump malfunction at the
north sump of the cellhouse containment, when the water/acid solution in the containment area
of the cellhouse rose to an elevation above the joint.
The containment area under the cellhouse is designed to capture water solutions, including rain
water, wash water and cell cleaning solutions from the cellhouse. The composition of the
material in the containment area typically is approximately 93% water, 6.1 % sulfuric acid, 85
ug/l cadmium,17.3 g/1 zinc, 24.4 mg/1 lead, and 203 mg/l chlorides. The solutions are recovered
in the containment area under the cellhouse and pumped to the acid tank and then to the solvent
extraction area for use in the process.
When the low pH water in the stormwater system was discovered on September 5, 2015, the
pump in the North sump that sends the solution to the acid tank had malfunctioned and was
being repaired. While the pump was being repaired, temporary pumps were installed in the
containment area to pump the solution. The liquid levels in these containment structures are
monitored periodically by plant personnel during each operating shift. At the time of the
containment breach, the liquid level in the basement was higher than normal because of the
pump malfunction. Because of this unusually high liquid lever in the basement, the liquid
entered the open joint where the wall of the recirculation tank meets the floor of the containment
area. Once the elevation of liquid in the basin rose to the elevation of the joint, the solution
seeped into the joint and entered the area under the recirculation tank and the underlying gravel
layer. The solution traveled through the backfill and infiltrated the stormwater drainage pipe
backfilling the area. The liquid seeped into the storrawater pipe and traveled in the storm drain to
Basin 1.
Business Confidential Information

HORSEHEAD METAL PRODUCTS, INC.
484 HICKS GROVE ROAD
MOORESBORO, NORTH CAROUNA281 14
Although plant personnel could not determine whether a reportable quantity of sulfuric acid had
been released, Horsehead called the NRC as a precautionary measure on September 9, 2015 at
3:30 pm, to advise the agency of the apparent release of process solution from the base of
secondary containment structure. After the call to the NRC, Horsehead notified the DENR
Regional Office by telephone. We understand that DENR notified the Forest City Fire
Department.
All secondary containment structures in the facility are constructed of reinforced concrete with
containment sizing based on 110% of the largest tank in the containment, Following the
discovery of the unsealed joint in the containment area under the cellhouse, Horsehead engineers
and maintenance personnel confirmed that no other areas in the facility have similar seal
problems.
Based on the available information, any discharge of the solution from the cellhouse containment
area to the Broad River was minimized through mitigation efforts following the initial discovery
of low pH at the energy dissipater. As soon as the low pH condition of water entering the energy
dissipater was detected on September 5, 2015, plant personnel closed the main gate valve at the
r outfall to the Broad River and the gate valve on the energy dissipater at Basin 1. Since there had
at j been an extended period without any substantial rainfall prior to September 5, 2015, Basin 1 was
Se } 5 empty and no discharge to the Broad River occurred to that point in time.
As noted above, on September 9th and 10th, a rain event of approximately 0.7 inches of
k precipitation occurred and stormwater entered Basin 1. At the time, the main gate valve on the
yr �� stormwater discharge outfall was closed and the water was retained in the basin. On September
9, 2015, a leak near the gate valve in the discharge structure was discovered which allowed water
from the basin to be discharged. Water discharged from the discharge structure was tested for
pH and found to be below 6.0 Standard Units. Vacuum trucks were mobilized to remove water
from Basin 1. UrQgyqLw ter was recycled for use in the plant process.
The small leak that allowed water to enter the Broad River resulted from a crack in the concrete
box that serves as the housing for the main gate valve. Hydraulic cement was used to seal the
crack and stop water from leaking through the concrete wall. These repairs were completed on
Friday, September 11, 2015, at approximately 7 p.m.
We determined that water at the concrete discharge structure entered the Broad River from mid-
day on September 9th until 7 p.m. on September 11. The duration of the leak was 55 hours. We
estimated the flow rate from the leak to be 10-15 gallons per minute (GPM). Sample analytical
results showed water discharged to the Broad River contained 3.36 mg/L cadmium, 0.541 mg/L
lead and 685 mg/L of zinc.
Business Confidential Information

1
"4o
HORSEHEAD METAL PRODUCTS, INC. /jf� 1�l j1 17
,J
...... . ...
84.HICKS:�3A3gVE:ROAD............:.::•.......:..........,., ...:
MOORESBORO, NORTH CARO.UNA 28114
2. Plan to Prevent Future Releases in Containment Areas
The following actions have been implemented to prevent a future releases:
As noted above, the defective j oint in the containment area under the cellhouse in Area
200 has been repaired. Inspections will be performed on the containment areas for
cracks and repairs will be made as required,
A high level alarm will be installed on the cellhouse containment to alert personnel if
liquid levels are elevated so action can be taken to draw the level down.
Weekly inspections have been initiated at the inlet and outlet of Basin 1, including
field tests for pH.
Horsehead remains committed to operating in a manner protective of the environment and
appreciates the Department's continued assistance as we continue through the startup phase at
the Mooresboro facility. If additional information is needed in support of this request, please call
me at 828-919-3139.
Since rel ,
Jim Harris
Environmental Manager
Business Confidential Information

j ;; v,,, �616 %
tr698) 919- 31-19
Bennett, Bradley
i8s $) 945-5x83 �c)
From:
Pickle, Ken
Sent:
Thursday, September 17, 2015 6:10 PM
To:
Bennett, Bradley
Subject:
Horsehead leak
Reported sequence:
• Saturday 9:30 pm, 9/5: staff observed flow into the energy dissipater during a dry weather period; staff tested
with pH strips commonly carried; discovered pH low; closed valves out of the energy dissipater and the effluent
valve in the Basin 1 outlet structure. Moved up gradient into the plant and cleaned up the area around an
earlier acid pump spill. Material in the energy dissipater vacuumed up and returned to process.
• Sunday, 9/6: staff observed continuing flow, concluded that the acid pump spill was not the source, but with no
obvious source. Staff pulled manhole covers back up stream until isolated in the Electrowinning area (Area 400)
storm sewer.
• Monday, 9/7: EHS Manager continued to receive reports of flow over the weekend. Installed rubber plug in the
area storm sewer. An attempt to run a camera through the line was inconclusive, but a leakingjoint was
detected.
• Tuesday, 9/8: Normal process operations (?) Monday night pulled down liquid stored in the containment area
under Electrowinning: Staff observed a breach in the containment liner to polypropylene tank seal. Fluid
reported to be 7% H2SO4 laden with Zn. Construction project manager reported lots of gravel backfilled in the
area of this particular storm sewer leg. Working scenario: the breach in the liner allowed containment fluid to
flow through the underlying gravel fill to the concrete sewer pipe (no joint gasket, just concrete to concrete
construction at the joint) and down the collection system to the energy dissipater at the foot of the hill.
• Wednesday, 9/9: Horsehead contacts ARO to report leak/spill into the Broad River. Valve on Basin 1 discharge
does not effectively seal, and a trickle of Basin 1 contents are still discharging.
Jl' Thursday, 9/10: Basin 1 still leaking into the Broad River. Landon reports that he has told Horsehead that
discharge from the Basin is permissible until the current inventory in the stormwater system and Basin 1 is
normal pH and free of elevated metals. BRADLEY: SEEMS LIKE THIS IS THE TEST OF WHEN THEY CAN
DISCHARGE. JIM NEEDS TO CONVEY THESE RESULTS TO LANDON AND US.
• Friday, 9/11: Horsehead reports they have flushed and neutralized the stormwater piping from the cell house
area to the energy dissipater; adjusted the pH levels in Basin 1; maintained water levels below the breach in the
seal at the cellhouse containment; and are obtaining quotes to repair the defective seal.
• Saturday, 9/12: Horsehead reports leak out of Basin 1 stopped on previous Friday night, 9/11. Horsehead
continuing to vacuum truck water out of Basin 1 and back into the process.
Wednesday, 9/16: Horsehead verbal report that Basin 1 cleaned up & requests permission to bring the storm
,+k system back on line. YESTERDAY'S ASSERTION OF CLEAN UP SHOULD BE CORROBORATED BY ANALYTICALS,
WHICH SHOULD BE AVAILABLE ON FRIDAY, IF THEY ACTED AS THEY SHOULD HAVE.
• Thursday, 9/17: DEMLR SPP contacted Mr. Harris and began conversation about site conditions; conversation
interrupted. Weather forecast this afternoon for the plant area indicates potential for rain Monday night,
9/21. Conversation to be continued Friday, 9/18.
• Friday, 9/18: Discuss with Jim Harris:
a�6 o Please provide us with all metals and pH results on discharges or contained volumes in any way related
to this incident.
s>><SoP o Photos show large amounts of sediment in the energy dissipater. Have you cleaned that out? It's a
(} potential reservoir for Zn, Pb, Cd.
n o Has the dry weather flow into the energy dissipater stopped?
o KBP floating an idea: ????? — "Please take pH, Cd, Zn, and Pb analyses daily on every discharge from
�ttJ Basin 1 for one week starting with the first discharge. Send full EPA Method analyses to Pace labs on
�j rush processing: find a Hach Kit for metals, or other rapid field measurement method, if available,

and use it for operational guidance concurrent with the approved EPA Method sampling. Report
results daily to RCO and ARO DWR and DEMLR" -- ???
Ken
Ken Pickle
Stormwater Program Specialist
NCDENR I DEMLR I Stormwater Permitting Program
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: [e-mail]
Website: htto://oortal.ncdenr.org/web/IrZstormwater
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
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