NCG030265_COMPLETE FILE - HISTORICAL_20180619

PERMIT NO.
DOC TYPE
STORMWATER DIVISION CODING SHEET
NCG PERMITS
A
I HISTORICAL FILE
7 MONITORING REPORTS
DOC DATE ❑ c� 0 ) q o (i l
YYYYMMDD

ROY COOPER
Governor
Energy, Mineral
and land resources
ENVIRONMENTAL QUALITY
June 19, 2018
Dave Steel Company, Inc.
Attention: Allan Clontz, EHS Director
Post Office Box 2630
Asheville, North Carolina 28802
Subject: Compliance Evaluation Inspection
Permit: NICGO30265
Buncombe County; North Carolina
Dear Mr. Clontz:
MICHAEL S. REGAN
secretary
WILLIAM E. VINSON, JR
Interim Director
Enclosed please find a copy of the Compliance Evaluation Inspection Report for the inspection I conducted at
the subject facility on June 12, 2018.
The report should be self-explanatory; however, should you have any questions concerning this report,
please do not hesitate to contact me at [phone] or by email at [e-mail].
Enclosure: Inspection Report
Sinter y,
Isaiah Ree , CEPSCI
Environmental Specialist
Land Quality Section
State of North Carolina I Environmental Quality I Energy, Mineral and land Resources
2090 Us 70 Highway I Swannanoa, NC 28778-8211
828 296 4500 T

i
Compliance Inspection Report
Permit: NCG030265 Effective: 11116117 Expiration: 10131/18 owner. Dave Steel Company
SOC: Effoctive: Expiration: Facility: Dave Steel Company
county: Buncombe 40 Meadow Rd
Region: Asheville
Asheville NC 28843
Contact Person: Jeffrey E Dave Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 06/12/2018
Primary Inspector: Isaiah L Reed
Secondary Inspector(s):
Certification:
Phone:
Entry Time: 03:OOPM Exit Time: 04:OOPM
Phone: [phone]
Reason for Inspection: Routine L Inspection Type: Compliance Evaluation
Permit Inspection Type: Metal Fabrication Slormwater Discharge COC
Facility Status: ® Compliant ❑ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page: 1

Permit: NCQ030265 Owner - Facility: Dave Steel Company
Inspection Date: 06/12/2018 Inspection Type: Compliance Evaluation Reason for Visit Routine
Inspection Summary,
On June 12, 2018 this site was inspected for compliance. I met with Allan Clontz on site. No issues were observed during
the inspection. An additional outfall was observed near the west entrance to the facility_ Due to the location of the outfall, it
is not concidered representative of the industrial activity on site, and can be excluded from analytical monitoring
requirements.
Page; 2

Permit! NGG030265 Owner - Facility; Dave Steel Company
Inspection Date: 0611212018 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Stormwater Pollution Prevention Plan
Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan?
N ❑ ❑ ❑
# Does the Plan include a General Location (uSGS) map?
0 ❑ ❑ ❑
# Does the Plan include a "Narrative Description of Practices'?
®❑ ❑ ❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
®❑ ❑ ❑
# Does the Plan Include a list of significant spills oocurring during the past 3 years?
® ❑ ❑ ❑
# Has the facility evaluated feasible alternatives to current practices?
N ❑ ❑ ❑
# Does the facility provide all necessary secondary containment?
N ❑ ❑ ❑
# Does the Plan include a BMP summary?
■ ❑ ❑ ❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
®❑ ❑ ❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
! ❑ ❑ ❑
# Does the facility provide and document Employee Training?
® ❑ ❑ ❑
# Does the Plan include a list of Responsible Party($)?
N ❑ ❑ ❑
# Is the Plan reviewed and updated annually?
®❑ ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
®❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
■ ❑ ❑ ❑
Comment:
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ®❑ ❑ ❑
Comment:
Analytical Monitorial Yes No NA NE
Has the facility conducted its Analytical monitoring? E ❑ ❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? 11000
Comment:
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? M ❑ ❑ ❑
# Were all outfalls observed during the inspection? ®❑ ❑ ❑
# if the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ M ❑
# Has the facility evaluated all illicit (non stornrwater) discharges? M ❑ ❑ ❑
Comment:
Page: 3

a
Compliance Inspection Report
Permit: NCG030265 Effective: 11/16/17 Expiration: 10/31/18 Owner: Dave Steel Company
SOC: Effective: Expiration: Facility: Dave Steel Company
County: Buncombe
40 Meadow Rd
Region: Asheville
Asheville NC 28803
Contact Person: Jeffrey E Dave Title: Phone: [phone]
Directions to Facility:
System Classiflcations:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 06/12/2018
Primary Inspector: Isaiah L Reed
Secondary Inspector(s):
Certification:
Phone:
Entry Time: 03,o0PM Exit Time: 04:0OPM
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Metal Fabrication Stormwater Discharge COC
Facility Status: Compliant [] Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page: 1

Permit: NCG030265 Owner - Facility: Dave Steel Company
Inspection Hate_ W1212018 Inspection Type; Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
On June 12, 2018 this site was inspected for compliance. I met with Allan Clontz on site. No issues were observed during
the inspection, An additional outfall was observed near the west entrance to the facility. Due to the location of the outfall, it
is not considered representative of the industrial activity on site, and can be excluded from analytical monitoring
requirements.
Page: 2

of a
Permit: NCG0302e5 Owner - Facility: Dave Steet Company
Inspection Date: 0611212018 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Stormwater Pollution Prevention Plan
Does the site have a Stormwater Pollution Prevention Plan?
# Does the Plan include a General Location (USGS) map?
# Does the Plan include a'Narrative Description of Practices"?
# Does the Plan include a detailed site map including outfall locations and drainage areas?
# Does the Plan include a list of significant spills occurring during the past 3 years?
# Has the facility evaluated feasible alternatives to current practices?
# Does the facility provide all necessary secondary containment?
# Does the Plan include a BMP summary?
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
# Does the facility provide and document Employee Training?
# Does the Plan include a list of Responsible Party(s)?
# Is the Plan reviewed and updated annually?
# Does the Plan include a Stormwater Facility Inspection Program?
Has the Stormwater Pollution Prevention Plan been implemented?
Comment:
Qualitative Monitoring
Has the facility conducted its Qualitative Monitoring semi-annually?
Comment:
Analytical Monitoring
Has the facility conducted its Analytical monitoring?
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
Comment:
Permit and Outfalls
# Is a copy of the Permit and the Certificate of Coverage available at the site?
# Were all outfalls observed during the inspection?
# It the facility has representative outfall status, is it properly documented by the Division?
# Has the facility evaluated all illicit (non starmwater) discharges?
Comment:
Yes No NA NE
® ❑ ❑ ❑
®❑❑❑
0❑❑❑
❑ ❑ ❑
❑ ❑ ❑
m ❑ ❑ ❑
w ❑ ❑ ❑
s❑❑❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• Cl ❑ ❑
® ❑ ❑ ❑
1W ❑ ❑ ❑
Yes No NA NE
O❑❑❑
Yes No NA NE
e❑❑❑
❑❑■❑
Yes No NA NE
®❑❑❑
® ❑ ❑ ❑
❑❑0D
E ❑ ❑ ❑
Page: 3

Facility Nam �'j�
IIG..�e �� k
Permit#:
az fa5
Time in/out!
Date:
Stormwater Pollution Prevention Plan
Poes the site have a SWPPP?
Does the Plan include a General Location (USGS) map?
lDoes the Plan include a "Narrative Description of Practices"?
Does the Plan include a detailed site map including outfall locations and drainage areas?
Does the Alan include a list of significant spills occurring during the past 3 years?
Has the facility evaluated feasible alternatives to current practices?
Does the facility provide all necessary secondary containment?
Does the Plan include a BMP summary?
Does the Plan include a Spill Prevention and Response Plan (SPRP�?
Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
Does the facility provide and document Employee Training? _
Does the Plan include a list of Responsible Party(s)?�
GIs the Plan reviewed and updated annually?
Does the Plan include a Stormwater Facility Inspection Program?
Has the Stormwater Pollution Prevention Plan been implemented?
:omments
,Has the facility conducted its Qualitative monitoring semi-annually?
Energy. Mineral
and Land Resources
6 iYlRnnriq+T.,4 ouni-.
Yes No NA NE
Yes / No NA NE
_21 -- ..-❑• -E]
Analytical Monitoring
Yes No
ESA
NE
Has the facility conducted its Analytical monitoring?
Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
:omments t.1os� t�`ee.yS S t"$ Uvn� ern 7�S
Is a copy of the Permit and the Certificate of Coverage available at this site?
Were all outfalls observed during the inspection?
'If the facility has representative outfall status, is it properly documented by the Division?
Has the facility evaluated all illicit {non stormwater} discharges?
:omments and Others Present:

Dave Steel Company, Inc.
Steel Construction Since 1929
February 27, 2015
Department of Environment and Natural Resources
Division of Energy, Mineral, and Land Resources
2090 U.S. Highway 70
Swannanoa, NC 28778
Attn: Laura Herbert, PE, Regional Supervisor
Re: Dave Steel Company, Inc.
40 Meadows Road
Asheville, NC 28802 _
Certificate of Coverage No. NCG030265
Dear Ms. Herbert:
Tfl Fri
Received
LIAR - 5 2015
Land QuatFty Section
Asheville
Dave Steel Company, Inc. (DSCO) will be collect monthly monitoring samples at their facility as part of a Tier II
response for recent stormwater copper exceedances at SDO 002. Please see below for more information
regarding this situation.
SDO 002 Sampling History
DSCO has two stormwater discharge outfalls (SDOs) labeled SDO 001 and SDO 002 (See Figure 1).
Quantitative Results
Copper levels at SDO 002 have been in exceedance of the benchmark value of 0.007 mg/L for two consecutive
sampling events, as shown in Table 1.
Table 1. Data from SDO 002 Recent Sampling Events
Sampling Date at SDO 002
Copper Level
m IL
Notes
May 15, 2014
<0.005
First SemiAnnual 2014
October 14, 2014
0.0078
Second SemiAnnual
January 23, 2015
0.022
First SemiAnnual 2015
Benchmark
0.007
--
Qualitative Results -
The Qualitative Monitoring Events conducted at SDO 002 during the two sampling events listed in Table 1 did
not warrant further investigation due to the good/moderate clarity, low solids, and no presence of foam or oil
sheen at stormwater outfall SDO 002. No other deficiencies were observed at SDO 002 during the Qualitative
ASHEVILLE, NC CINCINNATI, OH CHESNEE, SC
P.O. Box 2630 Asheville, N.C. 28802 Telephone [phone] Fax [phone]
0ERTIFIED AISC QUALITY CERTIFICATION
aFASR;CnTOR STANDARD FOR STEEL BUILDING STRUCTURES
SOPHISTICATED PAINT ENDORSEMENT - ENCLOSED

VLPEnlIIG
puts ansuh ECCAOU
Im-221?

Dave Steel Company, Inc.
Steel Construction Since 1929
Monitoring Events. The system appeared to be operating as designed and was in good order with no evidence of
pollutant discharges.
Potential Non -Industrial On -Site and Off -Site Copper Sources at DSCO
It is Dave Steel's opinion that at least some of the copper (if not all) is likely coming from non -industrial on -site
sources (e.g., electrical and plumbing) and off -site sources such as Asheville -Buncombe Technical Community
College (A-B Tech) that is located upgradient.
Non -Industrial On -Site Sources
Stormwater could pick up copper from exposed wiring and plumbing. During a February 23 on -site
survey by our environmental contractor and our Maintenance Supervisor no exposed copper or any
copper sources other than electrical wiring was identified. No items were found to be deficient at the facility
during the inspection that would have likely contributed to elevated copper levels. See Attachment 2 for the
inspection checklist.
Off -Site Sources
Stormwater sources at A-B Tech include the Thomas Simpson Building and the Rhododendron Building and two
parking areas that are all controlled by a single detention pond. The pond discharge is piped across Dave Steel
property and combined with our on -site stormwater}ust upstream of SDO 002. The recently repaired walkway
above the detention pond could be partially or wholly re -constructed from Copper/Chromate/Arsenate (CCA)
treated materials; no tags are on the materials to verify this circumstance.
Potential On -Site industrial Copper Sources
Ancillary equipment may have copper components that drain to the stormwater conveyance/discharge system.
These equipment include air pollution control devices, roof mounted air conditioning units, and flashing.
MSDS Review
DSCO staff conducted a review of the facility's Material Safety Data Sheets (MSDSs) to determine whether or
not materials used in industrial processes contain copper. Forty-nine MSDSs were reviewed, and based on the
MSDSs provided by the manufacturers. only two products were found to contain copper. The following table lists
the two products that contain copper:
Table 3. Products Found to Contain Copper during MSDS Review
Product
CAS #
Copper
Concentration
Application
Pathway and Likelihood for
Stormwater Impact
Cambridge Lee
Copper
oxide 1314-
o
< 0.1 /o
Plasma welding
None
Tellurium Copper
13-2
consumable tips
Nucor — Bar
Copper
1
< 0.01 % in base
Steel fabrication
Uncontrolled Dust —Not likely
7440-66-6
metal
ASHEVILLE, NC CINCINNATI, OH CHESNEE, SC
P.O. Box 2630 Asheville, N.C. 28802 Telephone [phone] Fax [phone]
# MCERWIED AISC QUALITY CERTIFICATION
<FABR[CATOR STANDARD FOR STEEL BUILDING STRUCTURES
SOPHISTICATED PAINT ENDORSEMENT - ENCLOSED

N
Dave Steel Company, Inc.
Steel Construction Since 1929
Actions To Be Taken to Identifv Potential Copper Sources
During the next rainfall event DSCO will collect stormwater samples from the six locations identified in Figure 1.
Hopefully these samples will broadly identify whether copper originates off -site or on -site. If on -site, the results
will sharpen our focus for the copper source.
Conclusion
DSCO believes the majority, if not all, of the copper seen in the stormwater samples is coming from off -site
and/or on -site non -industrial sources. We will work to identify the source of copper in our stormwater.
DSCO will operate under a Tier II Response in regards to copper, and monthly monitoring will continue at this
SDO for the time being. In accordance with the permit, all parameters will be monitored at SDO 002 during
sampling events until three consecutive sample results are below the benchmark values and/or within the
benchmark range, and/or your office grants DSCO relief from this monthly monitoring.
Please contact me with questions.
Sincerely,
Dave Steel Company, Inc.
Jeff ave
ent
828-252-2771
Attachments: Figure I — Facility Stormwater Layout
Attachment I — Pace Analytical Laboratories
Attachment 2 — Stormwater Inspection Checklist
cc: Darlene Kucken, NCDENR
ASHEVILLE, NC CINCINNATI, OH CHESNEE, SC
�P.O. Box 2630 Asheville, N.C. 28802 Telephone [phone] Fax [phone]
W
MCERTIFIED AISC QUALITY CERTIFICATION
dFABRICATOR STANDARD FOR STEEL BUILDING STRUCTURES
SOPHISTICATED PAINT ENDORSEMENT - ENCLOSED

I
Dave Steel Company
3t
LF
i i
3
i i -
'q i i
. ..... ......
J.
Dave Steel Company, Inc. PLUM
PIM (05M 40 Meadow Road
Asheville, NC 28802
Figure 1. Facility Stormwater Layout

aceAnalytical
www.pscebbs =n
January 28, 2015
Mr. Dan March
Pisgah Environmental Services
9 Woodvale
Asheville, NC 28804
RE: Project: Dave Steel 1410147 1123
Pace Project No.: 92234712
Dear Mr. March:
Pace Analytical Services, Inc.
2225 Riverside Or.
Asheville, NC 28804
[phone]
Enclosed are the analytical results for sample(s) received by the laboratory on January 23, 2015.
The results relate only to the samples included in this report. Results reported herein conform to the
most current TN standards and the laboratory's Quality Assurance Manual, where applicable, unless
otherwise noted in the body of the report.
Analyses were performed at the Pace Analytical Services location indicated on the sample analyte
page for analysis unless otherwise footnoted.
If you have any questions concerning this report, please feel free to contact me.
Sincerely,
Chris Derouen
[e-mail]
Project Manager
Enclosures
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Page 1 of 12

aceAnalyti+cal e
wwwPaVeWDs.mm
ANALYTICAL RESULTS
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
Project: Dave Steel 1410147 1123
Pace Project No.: 92234712
Sample_ SD-01" Lab ID: 92234712001 Collected: 01/23115 10:32 Received: 01/23115 10:46 Matrix: Water
Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual
HEM, Oil and Grease
Analytical Method: EPA 1664E
Oil and Grease
ND mglL
5.0
1
01126/15 12:49
200.7 MET ICP
Analytical Method: EPA 200.7 Preparation Method: EPA 200.7
Copper
ND ug/L
5.0
1 0112311515:05
01124/1505:40 7440-50-8
Lead
ND ug1L
&0
1 01/23/15 15:05
01/24/15 05:40 7439-92-1
Zinc
72.4 ug1L
10.0
1 0112314515.05
01124/1505:40 7440-66-6
2540D Total Suspended Solids
Analytical Method: SM 2540D
Total Suspended Solids
28.5 mgtL
6.2
1
01/28/15 06:31
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 01/28/2015 06:35 PM without the written consent of Pace Analytical Services, Inc..
Page 4 of 12

e
aceAnalytical
www.p&calabs.com
ANALYTICAL RESULTS
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
Project: Dave Steel 1410147 1123
Pace Project No.: 92234712
,Sample: SD-02: Lab ID: 92234712002 Collected: 01123/15 10:28 Received: 01/23/15 10:48 Matrix: Water
Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qua]
HEM, Oil and Grease
Analytical Method: EPA 1664B
Oil and Grease
ND mg1L
5.0 1
01/26/15 12:50
200.7 MET ICP
Analytical Method: EPA 200.7 Preparation Method: EPA 200.7
Copper`
' 22.0 ug1L�
5.0 1 01/23/15 15:05
01/24/15 05:43 7440-50-8
Lead
ND ug1L
5.0 1 01/23/15 15:05
01/24/15 05:43 7439-92.1
Zinc
56.0 ug1L
10.0 1 01123/15 15:05
01124/15 05:43 7440-66-6
2540D Total Suspended Solids
Analytical Method: SM 2540D
Total Suspended Solids
9.8 mg1L
4.0 1
01/28/15 06:31
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 01/28/2015 06:35 PM without the written consent of Pace Analytical Services, Inc.. Page 5 of 12

- aceAnaVical-
CHAIN-OF-CUSTODY 1 Analytical Request Document
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Semi -Annual Facility Stormwater Inspection Checklist
Instructions: This inspection record will be completed semi-annually, at a minimum, in conjunction
with the analytical sampling events. Place an X in the appropriate box for each item. If any response
requires elaboration, do so in the Description & Comments space provided. Further descriptions or
comments.should be attached on a separate sheet of paper if necessary. Semi-annual inspections
must be kept on file at the facility for 5 years.
Area
Yes No Descriptions $ Comments
Solid waste and cardboard dumpsters show
❑
X]
evidence of stormwater impact
Scrap metal accumulation areas show
❑
evidence of stormwater impact
Scrap wood bin shows evidence of stormwater
❑
impact
Waste oil drum shows evidence of stormwater
❑
X
impact
Evidence of stormwater impacts at
❑
A
loading/unloading areas
Evidence of stormwater impacts in� ❑
fabrication/painting areas of facility �wt � A
Evidence of stormwater impacts in other areas X
of the facility
Evidence of stormwater impacts at outfall Cl
Inventory of spilt response equipment needs ❑
restocking
i S.
Signature_ _ �� Date: Fa 23, 20 zb�
----�

Herbert, Laura C
From:
Herbert, Laura C
Sent:
Thursday, February 05, 2015 1:14 PM
To:
'Lisa Manning'
Cc:
Kucken, Darlene; Daniel March; Jeff Dave; King, Melissa
Subject:
RE: Dave Steel Company Stormwater Sampling Event
Lisa,
The benchmarks in the current permit still trigger the tiered response (until the renewal when the benchmarks will
change). However, we will take the new benchmark levels into account when we are reviewing any requests for Tier II -III
relief.
Thanks,
Laura
Laura Herbert, P.E.
Regional Engineer
Division of Energy, Mineral, and Land Resources - Land Quality Section
NCDENR-Asheville Regional Office
2090 US Highway 70
Swannanoa, NC 28778
Tel:[phone] Fax:[phone]
http://portal.ncdenr.org/web/Ir
Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and therefore may be disclosed to third
parties unless the content is exempt by statute or other regulation.
From: Lisa Manning [mailto:[e-mail]]
Sent: Thursday, February 05, 2015 12:33 PM
To: Herbert, Laura C
Cc: Kucken, Darlene; Daniel March; Jeff Dave; King, Melissa
Subject: Re: Dave Steel Company Stormwater Sampling Event
Thanks, Laura. Also, are we able to compare the copper values to the new benchmark of 0.010 mg/L
from this point forward?
Thank you for your help,
Lisa
From: "Herbert, Laura C" <laura.herbert(o)ncdenr.gov>
To: Lisa Manning <manninglaayahoo.com>
Cc: "Kucken, Darlene" <darlene.kucken(a)-ncdenr.gov>; Daniel March < is ah-air vt.edu>; Jeff Dave
<jdave(c�davesteel.com>; "King, Melissa" <Melissa.King(a-)_ncdenr.gov>
Sent: Tuesday, February 3, 2015 4:54 PM
Subject: RE: Dave Steel Company Stormwater Sampling Event
Lisa,
I

For the monthly samples yes — or' ipper. However, for you semiannuals ­j will still need to sample for all
parameters required in the permit.
Thanks,
Laura
Laura Herbert, P.E.
Regional Engineer
Division of Energy, Mineral, and Land Resources - Land Quality Section
NCDENR-Asheville Regional Office
2090 US Highway 70
Swannanoa, NC 28778
Tel:[phone] Fax:[phone]
http://Dortal.ncdenr.org/web/lr
Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and therefore may be
disclosed to third parties unless the content is exempt by statute or other regulation.
From: Lisa Manning tmailto,manningla(cDyahoo.ccml
Sent: Tuesday, February 03, 2015 4:08 PM
To: Herbert, Laura C
Cc: Kucken, Darlene; Daniel March; Jeff Dave; King, Melissa
Subject: Re: Dave Steel Company Stormwater Sampling Event
Hi Laura,
Just to verify, the permit states that we should sample for all parameters at the outfall needing monthly
monitoring. However, your email below states that we should only sample for copper. I just wanted to
verify that it will be okay to sample only for copper at SDO 002. Please let me know.
Thank you,
Lisa
From: "Herbert, Laura C" <laura.herbegft_ncdenr.gov>
To: Lisa Manning <manninglaayahoo.com>
Cc: "Kucken, Darlene" <dadene.kucken@_ncdenr_goy>; Daniel March <pisgah-air [e-mail]>; Jeff Dave
<jdave-davesteel.com>; "King, Melissa" <[e-mail]>
Sent: Tuesday, February 3, 2015 9:26 AM
Subject: RE: Dave Steel Company Stormwater Sampling Event
Lisa,
A quick review of the file indicates that you all have not previously had issues with the copper benchmark. Please
correct me if this is an incorrect assessment. Please provide us with the results of your Tier I investigation, such
as your review of any potential copper exposure pathways from the process and any housekeeping or process
modification responses. Also have you sampled any of the stormwater coming on to the site from AB Tech for
copper? Dave Steel will need to go through a similar process with respect to copper that you all did with respect to
zinc. We will then review your response and do a site visit to respond to your request for a waiver
from monthly monitoring. In the meantime please initiate the Tier II response and monthly sampling. Were any
other of the benchmarks on SDO 002 exceeded? What was the value of TSS (have you seen a spike from
upstream construction at AB Tech?)? If copper is the only exceeded benchmark from the outfall, you may limit
your monthly sampling to only that for copper. However, if TSS is more than normal (even if not above the
benchmark), you may want to sample this as an indicator.

Herbert, Laura C p
From:
Herbert, Laura C
Sent:
Tuesday, February 03, 2015 9:26 AM
To:
'Lisa Manning' -
Cc:
Kucken, Darlene; Daniel March; Jeff Dave; Melissa King
Subject:
RE: Dave Steel Company Stormwater Sampling Event
Lisa,
A quick review of the file indicates that you all have not previously had issues with the copper benchmark. Please correct
me if this is an incorrect assessment. Please provide us with the results of your Tier t investigation, such as your review of
any potential copper exposure pathways from the process and any housekeeping or process modification responses. Also
have you sampled any of the stormwater coming on to the site from A8 Tech for copper? Dave Steel will need to go through
a similar process with respect to copper that you all did with respect to zinc. We will then review your response and do a
site visit to respond to your request for a waiver from monthly monitoring. In the meantime please initiate the Tier li
response and monthly sampling. Were any other of the benchmarks on SDO 002 exceeded? What was the value of TSS
(have you seen a spike from upstream construction at A8 Tech?)? If copper is the only exceeded benchmark from the
outfall, you may limit your monthly sampling to only that for copper. However, if TSS is more than normal (even if not
above the benchmark), you may want to sample this as an indicator.
Thank you for your notification and your efforts to address any potential process exposures to stormwater.
Thanks,
Laura
Laura Herbert, P.E.
Regional Engineer
Division of Energy, Mineral, and Land Resources - Land Quality Section
NCDENR-Asheville Regional Office
2090 US Highway 70
Swannanoa, NC 28778
Tel- 828-296-4500 Fax: [phone]
http://Portal.ncdenr.org/web/Ir
Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and therefore may be disclosed to third
parties unless the content is exempt by statute or other regulation.
From: Lisa Manning [mailto:[e-mail]]
Sent: Tuesday, February 03, 2015 7:55 AM
To: Herbert, Laura C
Cc: Kucken, Darlene; Daniel March; Jeff Dave
Subject: Dave Steel Company Stormwater Sampling Event
Dear Ms. Herbert,
I spoke to Darlene Kucken yesterday, and she suggested I email you. I am writing to.discuss a recent
sampling event at Dave Steel Company (DSCO) that took place on January 23, 2015. This event was
DSCO's first semi-annual sampling event for 2015. If you recall, they have two stormwater outfalls, SDO
001 and SDO 002. During their second sampling event of 2014 (October 14), both SDO 001 and SDO

002 had slight exceedances of the per benchmark (0.0070 mg/L) at r '105 mg/L and 0.0078 mg/L,
respectively. Therefore, DSCO ini. �d a Tier I response.
During the sampling event that took place on January 23, 2015, there again was an exceedance of the
copper benchmark at SDO 002 of 0.0220 mg/L. [SDO 001 did not have an exceedance this time, as
there was no copper detected in the sample (result = < 0.005 mg/L).] I am writing to ask how you .
recommend that we handle this exceedance at SDO 002. We can begin a Tier 11 response and begin
monthly monitoring at SDO 002 if you require this. However, as you may recall, last spring/summer
DSCO staff met with you and your staff to highlight the changes and improvements they have made to
their facility and best management practices to mitigate any potential for stormwater impacts from their
facility. We believe the copper seen in the stormwater samples is coming from non-industrial/non- .
process sources. One wild card, over which DSCO has no control, is the fact that AB Tech is located
directly upstream of DSCO and has parking lots that drain directly to SDO 002. Also, there has been
quite a bit of construction going on at AB Tech recently, which may be having an impact.
Therefore, is there any way that we could request a condensed/collapsed Tier II response and/or
monitoring relief for monthly monitoring at this outfall? If we were to compare these recent exceedances
at SDO 002 to the new benchmark for copper of 0.010 mg1L, the concentration found in October would
not have been considered an exceedance.
Please advise how you would like us to proceed.
Thank you for your time,
Lisa Manning, PE

Pat McCrory
Governor
NCDENR
North Carolina Department of Environment and Natural Resources
June 2, 2014
Dave Steel Company, Inc.
ATTN: Mr. Rob Clowers, CSP
Environmental Health & Safety Director
PO Box 2630
Asheville, North Carolina 28802
John E. Skvarla, Ill
Secretary
SUBJECT: NPDES Stormwater Permit: Request for Regulatory Relief
Dave Steel Company, Inc.
General Permit No: NCG030000; COC No: NCG030265
Buncombe County
Dear Mr. Clowers:
In response to your request for regulatory relief, NCDENR-Land Quality Section staff
conducted a site inspection on May 29, 2014. The primary goal of this inspection was
to evaluate compliance with the conditions of the NCG030000 General Permit, and to
discuss any actions that have been or could be taken to identify and limit potential
sources of zinc related to process operations. At the time of this inspection the facility
was found to be in compliance with permit NCG030265 and no illicit discharges were
discovered.
Monthly monitoring has been triggered by. two consecutive exceedances of the zinc
benchmarks in Storm Drain Outfall Nos. 01 and 02 at your facility. Please keep in mind
that benchmark exceedances are NOT limit violations or violations of permit conditions;
however, you are obligated to follow the tiered response actions outlined in your permit_
Dave Steel Company, Inc. (DSCO) has been following the tiered response actions and
therefore is in compliance with the permit.
As part of tiered response, DSCO has initiated housekeeping actions that appear to
have addressed the process exposures (reference April 23, 2014 letter from you).
These include cleaning out the storm drains in the Fit -up area (south side of the metal
fabrication building) and placing more permanent covers on the drains to prevent
potential contamination; recommendations from the May 23, 2013 NCDENR inspection.
Awareness training for employees has also been implemented to prevent any illicit
discharges into the drains. In addition, DSCO has identified likely non process sources
of zinc including galvanized building material, guttering, and the AB Tech parking lot
located upstream from the facility. There are potential process sources of zinc, but all
Division of Energy, Mineral, and Land Resources — Land Quality Section
Asheville Regional Office, 2090 US Highway 70, Swannanoa, North Carolina, 28778-8211
Telephone [phone] Fax [phone] ne
http://Portal.ncdenr,orglweb/ir/iand-quality Wo hCarolina
An Equal Opportunity / Affirmative Action Employer Naturally

Mr. Rob Glowers, CSP
June 2, 2014
Page 2 of 2
of these operations are located indoors with limited exposure to stormwater. Note that
the April 2014 sampling results for zinc were below the benchmark value in both
outfalls.
Based on the aforementioned items, we are granting regulatory relief in the form of a
collapsed Tier 2 — Tier 3 response. Upon receipt of this letter, DSCO may resume the
permit specified semi-annual analytical monitoring for the remainder of the current
permit term. Your current permit is set to expire on October 31, 2017. This decision
only applies to the zinc benchmarks. A benchmark exceedance of any other
parameter listed in your permit will trigger tiered response actions as described
in the general permit.
You must notify this office in writing, within five business days, if you become aware of
any significant source of zinc at your facility that has the potential to be exposed to
stormwater. The relief granted in this letter is contingent upon the current industrial
practices at DSCO. If industrial practices change and zinc does become a significant
stormwater exposure risk then this office reserves the right to withdraw this decision
and reinstate the permit specified tiered response or other actions that may be
warranted by the new set of circumstances.
Please refer to the enclosed Compliance Inspection Report for additional comments,
observations, and recommendations made during. the inspection.
Please retain and append this letter to your Stormwater Pollution Prevention Plan
(SPPP) or permit. If you have any questions or comments concerning this letter, please
contact Darlene Kucken or me at [phone].
Sincerely,
Laura Herbert, PE
Regional Engineer
Enclosure
ec: Bethany Georgoulias, RCO
Dan Marks, PE, Pisgah Environmental via email.

Compliance Inspection Report
Permit: NCG030265 Effective: 11/01/12 Expiration: 10/31/17 Owner: Dave Steel Company
SOC: Effective: Expiration: Facility: Dave Steel Company
County: Buncombe 40 Meadow Rd
Region: Asheville
Asheville NC 28803
Contact Person: Jeffrey E Dave Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Certification: Phone:
Inspection Date: 05/29/2014 Entry Time: 10:00 AM Exit Time: 12:00 PM
Primary Inspector: Darlene J Kucken Phone:
Secondary Inspector(s):
Laura C Herbert Phone:
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Metal Fabrication Stormwater Discharge COC
Facility Status: 0 Compliant ❑ Not Compliant
Question Areas:
a Storm water
(See attachment summary)
Page: 1

Permit: NCGO30265 Owner - Facility: Oave Steel Company
Inspection Date: 05/29/2014 Inspection Type: Compliance Evaluation Reason far Visii: Routine
Inspection Summary:
Monthly monitoring was triggered by two consectutive exceeedances of the zinc benchmark at Outfall 01 & 02. Dave
Steel has undertaken housekeeping actions that appear to have addressed the process exposures, including a significant
clean out of the storm drain in the Fit -up area and placing permanent covers on the drains to prevent further
contamination (these actions were recommended in the 2013 NCDENR inspection). In addition, awareness training has
been implemented to prevent any illicit discharges into drains. Dave Steel has identified likely non -process sources of
zinc from the galvanized building, gutters and the AB Tech parking lot runoff. The April 2014 samples for both outfalls
were below the benchmark for zinc. Therefore, regulatory relief is being granted in the form of a collapsed Tier 2-Tier 3
for the zinc benchmark and semi-annual analytical monitoring should be conducted for the remainder of the permit.
Additional recommendations:
1. Clean out the two drains as discussed during the inspection and consider providing inlet protection in the form of coir
logs for these drains.
2. Consider employing a vacuum sweep of the paint room on a regular basis during use, instead of a manual broom
sweeping.
Page: 2

Permit: NCG030265 owner -Facility: Dave Steel Company
Inspection Date, 05/29/2014 Inspection Type: Compliance Evaluation
Reason for Visit.
Routine
Stormwater Pollution Prevention Plan
Yes
No
NA
NE
Does the site have a Stormwater Pollution Prevention Plan?
■
❑
❑
❑
# Does the Plan include a General Location (LISGS) map?
■
❑
❑
0
# Does the Plan include a "Narrative Description of Practices"?
■
D
❑
Cl
# Does the Plan include a detailed site map including outfall locations and drainage areas?
■
❑
❑
Cl
# Does the Plan include a list of significant spills occurring during the past 3 years?
■
❑
❑
❑
# Has the facility evaluated feasible alternatives to current practices?
■
❑
fl
❑
# Does the facility provide all necessary secondary containment?
■
n
❑
n
# Does the Plan include a SMP summary?
■
❑
❑
❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
■
❑
❑
❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
0
❑
❑
❑
# Does the facility provide and document Employee Training?
■
❑
❑
❑
# Does the Plan include a list of Responsible Party(s)?
■
❑
❑
Cl
# Is the Plan reviewed and updated annually?
O
❑
Cl
❑
# Does the Flan include a Stormwater Facility Inspection Program?
■
n
Cl
n
Has the Stormwater Pollution Prevention Plan been implemented?
■
❑
Cl
❑
Comment: The SWPP is well written and additional inspection/implementation forms
and policies have been added to enhance the plan.
Qualitative Monitoring
Yes
No
NA NE
Has the facility conducted its Qualitative Monitoring semi-annually?
■
n
Cl ❑
Comment:
Analytical Monitoring
Yes
No
NA NE
Has the facility conducted its Analytical monitoring?
■
❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
❑
❑
■ ❑
Comment:
Permit and Outfalls
Yes
No
NA NE
# is a copy of the Permit and the Certificate of Coverage available at the site?
■
❑
❑ ❑
# Were all outfalls observed during the inspection?
■
❑
n ❑
# If the facility has representative outfall status, is it properly documented by the Division?
❑
❑
■ ❑
9 Has the facility evaluated all illicit (non stormwater) discharges?
❑
❑
■ ❑
Comment:
Page: 3

N
Dave Steel Company, Inc.
Steel Construction Since 1929
May 27, 2014
Department of Environment and Natural Resources
Division of Water Quality
Central Files
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Dave Steel Company, Inc.
40 Meadows Road
Asheville, NC 28802
Certificate of Coverage No. NCG030265
Dear Sir or Madam:
Attached is the First Sena -Annual Storinwater Discharge Monitoring Report for 2014 for Dave Steel
Company, Inc. (DSCO).
Methods
�s Samples were collected on May 15, 2014, during a "Measureable Storm Event" from the facility
stormwater outfalls labeled SDO 001 and SDO 002 (see Figure 1). SDO 001 and SDO 002 are the
locations where previous samples have been collected. Samples were collected from the approximate
center of the discharge streams and transferred to laboratory -supplied containers. Samples were
collected using good sampling practices in pre -cleaned - and in some cases preserved - containers
supplied by Pace Analytical Laboratories (Pace). The containers were placed in a cooler on ice and
delivered to Pace in Asheville, North Carolina for laboratory analyses. pH was measured in the field by
placing a probe within the flow of the respective outfall, and the pH was recorded following
stabilization. The pH meter was calibrated before testing with two buffer solutions that bracketed the
expected pH range. The pH measurement was taken within 15 minutes of collection as required by the
North Carolina Department of Environment and Natural Resources (NCDENR).
IN
A Dave Steel staff representative also conducted a Stormwater Discharge Outfall (SDO) Qualitative
Monitoring event for SDO 001 and SDO 002 during the stormwater analytical sampling event. These
monitoring reports are attached for reference.
The total precipitation was 1.74 inches during the sampling day, plus 0.47 inches of rain that occurred
after 11:00pm the evening before, for a total of approximately 2.21 inches of rain for the 24-hour storm
event period. Samples were collected by 7:10am on sampling day_ Precipitation amounts are based on
an on -site rain gauge and the National Oceanic Atmosphere Administration records of rainfall at the
ASHEVILLE, NC CINCINNATI, OH CHESNEE, SC
� P.O. Box 2630 Asheville, N.C. 28802 Telephone [phone] Fax [phone] ,
�4CFRTIFIED AISC QUALITY CERTIFICATION
CFABZICATOR STANDARD FOR STEEL BUILDING STRUCTURES
'"` SOPHISTICATED PAINT ENDORSEMENT - ENCLOSED

:. Dave Steel Company, Inc.
Steel Construction Since .1929
Asheville Regional Airport. There was no measureable storm event for at least the preceding 72 hours
before the storm event. Calculations of the maximum total flow through each outfall are attached.
Findings
Analytical Results
The laboratory analytical results are summarized in the Discharge Monitoring Report (attached) and
discussed below:
SDO 001
The results for SDO 001 indicate that the samples contained concentrations less than or within the range
of the specified benchmark value concentrations for all parameters measured on -site and at the
laboratory, including the fallowing: Total Suspended Solids (TSS), pH, copper, lead, zinc, and Non -
Polar Oil & Grease/Total Petroleum Hydrocarbons. The laboratory analytical report and chain -of -
custody form are attached to this document.
SDO 002
The results for SDO 002 indicate that the samples contained concentrations less than or within the range
of the specified benchmark value concentrations for all parameters measured on -site and at the
laboratory, including those listed previously.
DSCO is operating under a Tier 11 response currently in regards to zinc because of three previous
exceedances of the zinc benchmark value at SDO 002 during monthly and semi-annual sampling events
during January 2013, November 2013, and February 2014. Because zinc was not exceeded during this
sampling event, DSCO is on their way to having the Tier H response resolved. Monthly sampling is still
required at DSCO (pending NCDENR's response to a Monitoring Relief Request letter submitted on
April 18, 2014, and an inspection by NCDENR to take place on May 28, 2014), until there are two
additional consecutive sampling events in which zinc is below the benchmark value.
Qualitative Results
The SDO Qualitative Monitoring Reports did not warrant further investigation due to the good/moderate
clarity, low solids, and no presence of foam, oil sheen, or erosion/deposition at either stormwater outfall
SDO 001 or SDO 002- No other deficiencies were observed at SDO 001 or SDO 002 during the
Qualitative Monitoring event. Both systems were operating as designed and were in good order with "no
evidence of pollutant discharges. Please see the attached qualitative reports for more information.
ASHEVILLE, NC CINCINNATI, OH CHESNEE, SC
P.O. Box 2630 Asheville, N.C. 28802 Telephone [phone] Fax [phone]
�;�i`� vCERTIFIED AISC QUALITY CERTIFICATION
aFvsRicnro STANDARD FOR STEEL BUILDING STRUCTURES
SOPHISTICATED PAINT ENDORSEMENT- ENCLOSED

a
--. � NO
Dave Steel Company, Inc•
Steel Construction Since 1929
Conclusions
Based on the compliant zinc stormwater result at SDO 002 during this sampling event, we conclude that
the Tier H response is still necessary at this time until there are two additional consecutive sampling
events with zinc below the benchmark value or NCDENR approves DSCO's Monitoring Relief Request.
DSCO will continue monthly monitoring of all parameters at SDO 002 in accordance with the
stormwater permit until the Tier II response has been resolved or NCDENR approves the Monitoring
Relief Request.
Please contact me with operational or compliance issues.
Sincerely,
Dave Steel Company, Inc.
Rob C owers .
Environmental Health & Safety Director
828-252-2771
Attachments: Figure I
Discharge Monitoring Report for SDO 001 and SDO 002
Qualitative Monitoring Reports for SDO 001 and SDO 002
Stormwater FIow Calculations
Laboratory Analytical Report and Chain -of -Custody
cc: Duplicate, Central Files
ASHEVILLE, NC CINCINNATI, OH CHESNEE, SC
e P.O. Box 2130 Asheville, N.C, 26802 Telephone (828} 252-2771 Fax [phone]
Q
CERTIFIED AISC QUALITY CERTIFICATION
<FABRICATOR STANDARD FOR STEEL BUILDING STRUCTURES
SOPHISTICATED PAINT ENDORSEMENT - ENCLOSED

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Semi-annual Stormwater Discharge Monitoring Report
for North Carolina Division of Water Quality General Permit No. NCG030000
Date submitted T05/27/2014
CERTIFICATE OF COVERAGE No. NCG03 0 2 6 5
FACILITY NAME Dave Steel Compan
COUNTY Buncombe
PERSON COLLECTING SAMPLES Dan March
LABORATORY_ Pace Analytical lab Cert- # 92146300001
Comments on sample collection or analysis:
Part A. Stormwater Benchmarks and Monitoring Results
SAMPLE COLLECTION YEAR 2014
SAMPLE PERIOD Q Jan -June ❑July-oec
or [—]Monthly (month
DISCHARGING TO CLASS ❑ORW ❑HCJW ❑Trout ❑PNA
❑Zero•flow OWater Supply ❑SA
❑X Other Class C
PLEASE REMEMBER TO SIGN ON PAGES 2 AND/OR 3 4
n No discharce this neriod?'
outfal! No.
Date Sample
Collected'
(mo/dd/yrl
24-hour rainfall
amount,
Inches'
Total Suspended Solids
pH,
Standard units
Copper
Lead
Zinc
Non -Polar 0&G/
Total Petroleum
Hydrocarbons
Total Toxic
Organics'
Benchmarks sam>
-
100 mg/L or SO mg/L'
60 — 9.0
0.007 mg/L
0.03 mg/L
0.067 mg/L
a5 mg/L
1 mg/L
001
05/ l 5/2014
2.21
< 3.9
8.3
< 0.005
< 0.005
0.0413
< 5.0
NIA
002
05/15/2014
2.21
7.5
7.8
< 0.005
< 0.005
0.0419
< 5,0
NIA
' Monthly sampling (instead of semi-annual) must begin with the second consecutive benchmark exceedance for the same parameter at the same outfall-
t For sampling periods with no discharge at any single outfali, you must still submit this discharge monitoring report with a checkmark here.
'The total precipitation must be recorded using data from an on -site Fain gauge. Unattended sites may be eligible for a waiver of the rain gauge requirement.
`See General Permit, Table 3 identifying the especially sensitive receiving water classifications where the more protective benchmark applies.
s Total Toxic Organics sampling is applicable only for those facilities which perform metal finishing operations, manufacture semiconductors, manufacture
electronic crystals, or manufacture cathode ray tubes. For purposes of this permit the definition of Total Toxic Organics is that definition contained in the EPA
Effluent Guidelines for the facility subject to the requirement to sample (for metal finishing use the definition as found in 40 CFR 433.11; for semiconductor
manufacture use the definition as found in 40 CFR 469.12; for electronic crystal manufacture use the definition as found in 40 CFR 469,22; and for cathode ray
tube manufacture use the definition found in 40 CFR 469.31).
Permit Date:11/1/2012-10/31/2017
SWU-245, last revised 1o/25/2012
Page 1 of 3

Facilities that incorporate a solvent management plan into the Stormwater Pollution Prevention Plan may so certify, and the requirement for TTO monitoring
may be waived. The solvent management plan shall include a list of the total toxic organic compounds used and the other elements listed in the General
Permit. For those facilities electing to employ the TTO monitoring waiver, the discharger shall sign the following certification statement:
"Based upon my inquiry of the person or persons directly responsible for managing compliance with the permit monitoring requirement for total toxic organics
(TTO), I certify that to the best of my knowledge and belief, no dumping of concentrated toxic organics into the stormwater or areas which are exposed to rainfall or
stormwater runoff has occurred since filing the last discharge monitoring report. I further certify that this facility is implementing the all the provisions of the
solvent management plan included in the Stormwater Pollution Prevention Plan."
Name (Print name)
Title (Print title)
LY _—
(Signature) (Date)
Note: Results must be reported in numerical format. Do not report Below Detection Limit, BDL, <PQL, Non -detect, N D, or other similar non -numerical
format. When results are below the applicable limits, they must be reported in the format, "<XX me/L", where XX is the numerical value of the detection
limit, reporting limit, etc. in mg/L.
Note: If you report a sample value in excess of the benchmark, you must implement Tier 1, Tier S, or Tier 3 responses. See General Permit text.
Part B: Vehicle Maintenance Area Monitoring Results: only for facilities averaging > 55 gal of new oil per month.
No discharge this period:
Outfal! No.
Date Sample
Collected
(mo/dd/yr)
24-hour-rainfall
amount,
Inches'
Non -polar O&G/TPH by
EPA 1664 (SGT-HEM)
Total Suspended Solids
pH
Benchmarks ===>
-
-
15 mg/L• .
100 mg/L or 50 mg/L*
6.0 - 9.0 SU
Footnotes from Part A also apply to this Part B
* See General Permit text, Table 5, identifying the especially sensitive receiving water classifications where the more protective benchmark applies,
Permit Date: 11/1/2012-10/31/2017 SWU-24S, last revised 10/25/2012
Page-2 of 3

r�
Note., if you report a sample value in excess of the benchmark, you must Implement Tier 1, Tier 2, or Trer 3 responses. See General Permit text.
FOR PART AND PART B MONITORING RESULTS:
• A BENCHMARK EXCEEDANCE TRIGGERS TIER 1 REQUIREMENTS. SEE PERMIT PART II SECTION B.
• 2 EXCEfDANCE51N A ROW FOR THE SAME PARAMETER AT THE SAME OUTFALL TRIGGER TIER 2 REQUIREMENTS. SEE PERMIT PART II SECTION B.
• TIER 3: HAS YOUR FACILITY HAD 4 OR MORE BENCHMARK EXCEEDENCES FOR THE SAME PARAMETER ATANY ONE OUTFALL? YES ❑ NO
IF YES, HAVE YOU CONTACTED THE DWQ REGIONAL OFFICE? YES ❑ No ❑
REGIONAL OFFICE CONTACT NAME:
Moil on original and one copy of this AMR, including all "No Oischaree" renoRs. within 30 Clays of receipt of the lob results for of end of monitorina period
in the case o 'No Discharge" reports) to:
Division of Water Quality
Attn: DWQ Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
YOU MUST SIGN THIS CERTIFICATION FOR ANY INFORMATION REPORTED:
" 1 certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to
assure that quallfled personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or
those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete
�am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations."
(S nat e o PermRteej (Date)
Permit Date: 11/1/2012.10/31/2017
r1
SWU-245, last revised 10/75/2012
Page 3 of 3

XLE
NCDENIR
Stormwater Discharge Outfall (SDO)
Qualitative Monitoring Report
For guidance on filling out this form, please visit. http:./�rtal,ncdear.orc,,,/wc-b/wq/ws/sti/ni2dessw#tab-4
Permit No.:{/C/_/_/�/�
Facility Name: Dave Steel Company, Inc.
County: Buncombe
Inspector: Dan March
Date of Inspection: May 15, 2014
Time of Inspection: 07:15
or Certificate of Coverage No.: N/UG/ 0/3/0/2/E/5/
Total Event Precipitation (inches): _2.21
Phone No. 828-252-2771
Was this a "Representative Storm Event" or "Measureable Storm Event" as defined by the permit?
(See information below.)
® Yes ❑ No
Please verify whether Qualitative Monitoring must be performed during a "representative storm
event" or "measureable storm event" (requirements vary, depending on the permit).
E Qualitative monitoring requirements vary. Most permits require qualitative monitoring to be {
performed during a "representative storm event" or during a "measureable storm event." However,
some permits do not have this requirement. Please refer to these definitions, if applicable. t
MI
A "representative storm event" is a storm event that measures greater than 0.1 inches of rainfall
and that is preceded by at least 72 hours (3 days) in which no storm event measuring greater than
0.1 inches has occurred. A single storm event may contain up to 10 consecutive hours of no
precipitation.
A "measurable storm event" is a storm event that results in an actual discharge from the
permitted site outfall. The previous measurable storm event must have been at least 72 hours
prior. The 72-hour storm interval does not apply if the permittee is able to document that a shorter
interval is representative for local storm events during the sampling period, and the permittee
obtains approval from the local DWQ Regional Office.
By this signature, I certify that this report is accurate and complete to the best of my knowledge:
(Signature of Permittee or Designee)
Pagel of 2
SWU-242, Last modified 10/25/2012

1. Outfall Description:
Outfall No. SDO 1 Structure (pipe, ditch, etc.) Pipe
Receiving Stream: Swannanoa
River
Describe the industrial activities that occur within the outfall drainage area: Metal fabrication:
cutting, welding, painting.
2. Color: Describe the color of the discharge using basic colors (red, brown, blue, etc.) and tint
(light, medium, dark) as descriptors: Clear
3. Odor: Describe any distinct odors that the discharge may have (i.e., smells strongly of oil,
weak chlorine odor, etc.): None
4. Clarity: Choose the number which best describes the clarity of the discharge, where 1 is
clear and 5 is very cloudy:
2
5. Floating Solids: Choose the number which best describes the amount of floating solids in
the stormwater discharge, where 1 is no solids and 5 is the surface covered with floating solids:
1
6. Suspended Solids: Choose the number which best describes the amount of suspended
solids in the stormwater discharge, where 1 is no solids and 5 is extremely muddy:
4
7. Is there any foam in the stormwater discharge? No
B. Is there an oil sheen in the stormwater discharge? No
4. Is there evidence of erosion or deposition at the outfall? No
10. Other Obvious indicators of Stormwater Pollution:
List and describe: No indicators of stormwater pollution_
Note: Low clarity, high solids, and/or the presence of foam, oil sheen,'or erosion/deposition
may be indicative of pollutant exposure. These conditions warrant further investigation.
Page 2 of 2
5WU-242, Last modified 10125/2012

1. Outfall Description:
Outfall No. SDO 2 Structure (pipe, ditch, etc.) Pipe
Receiving Stream: Swannanoa
eo"'111 River
Describe the industrial activities that occur within the outfall drainage area: Metal fabrication:
cutting, welding, painting.
2. Color: Describe the color of the discharge using basic colors (red, brown, blue, etc.) and tint .
(light, medium, dark) as descriptors: Clear
3. Odor: Describe any distinct odors that the discharge may have (i.e., smells strongly of oil,
weak chlorine odor, etc.): None
4. Clarity: Choose the number which best describes the clarity of the discharge, where 1 is
clear and 5 is very cloudy:
3
5. Floating Solids: Choose the number which best describes the amount of floating solids in
the stormwater discharge, where 1 is no solids and S is the surface covered with floating solids:
1
6. Suspended Solids: Choose the number which best describes the amount of suspended
solids in the stormwater discharge, where 1 is no solids and 5 is extremely muddy:
n
3
7. Is there any foam in the stormwater discharge? No
B. Is there an oil sheen in the stormwater discharge? No
9. Is there evidence of erosion or deposition at the outfall? No
10. Other Obvious Indicators of Stormwater Pollution:
List and describe: No indicators of stormwater pollution.
Note: Low clarity, high solids, and/or the presence of foam, oil sheen, or erosion/deposition
may he indicative of pollutant exposure. These conditions warrant further investigation.
Page 3 of 2
SWU-242, Last modified 10/25/2012

Stormwater Flow Calculation
Dave Steel Company, Inc.
Asheville, North Carolina
May 15, 2014
Given:
Area contri bud ng to outfall SDO W l= 4.04 acres
Area contributing to ourfall SDO 002= 3.33 acres
Total Event Precipitation = T2.21-" inches
SD© 001
Area contribwing Area contributing to Rainfall Rainfall Volume of Rainfall Runoff Runotr
Runoff m SDO 00 )
to oulfall SDO 001 oulfall SDO 001 for Sample Date
4.04 acres 43,560 ft2 2.21 inches I ft c 32,447.96 N' �7.48 gal l Mgal _
0.243 Mga3
I acre Q inches I ft; 1,000.0000
0002
4rea contributing Area contributing to Rainfall Rainfall Volume of Rainfall Runoff Runoff Runoff to SDO 01
outfall SDO 002 outfall SDO 002 for Sample Date
3.33 acres t 43,560 till i 2.21 inches I ft e 26,737.50 ft' 7,48 gal I Mgal 0,200 tclbal
I acre 12 inches I ft' 1,000,000 ga]
Napes,
square fm
2. R - feel
1. R'- cubic fm
�. gal - gellcm
�. Msai -mi1fm paiims
Page I of I
W

0
aceAnalytical
1 www.pacelabs.cam
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
C'7
C
May 23, 2014
Mr. Dan March
Pisgah Environmental Services
9 Woodvale
Asheville, NC 28804
RE: Project: DAVE STEEL
Pace Project No.: 92201505
Dear Mr. March:
Enclosed are the analytical results for sample(s) received by the laboratory on May 15, 2014. The
results relate only to the samples included in this report. Results reported herein conform to the
most current TN standards and the laboratory's Quality Assurance Manual, where applicable, unless
otherwise noted in the body of the report.
Analyses were performed at the Pace Analytical Services location indicated on the sample analyte
page for analysis unless otherwise footnoted.
If you have any questions concerning this report, please feel free to contact me.
Sincerely,
JW�- @ a---4
Tabitha M Dacal
[e-mail]
Project Manager
Enclosures
REPORT OF LABORATORY ANALYSIS
This report Shell not be reprodured, except in full,
without the written consent of Pace Analytical Services, Inc..
Page 1 of 12

_ ?Wcmnalytical
! www,gaxfabs.0"
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
CERTIFICATIONS
Project: DAVE STEEL
Pace Pr oject No.: 92201505
Charlotte Certification IDs
9800 Kincey Ave. Ste 100, Huntersville, NC 28078
Florida/NELAP Certification #: E87627
North Carolina Drinking Water Certification #: 37706
Kentucky UST Certification #; 84
North Carolina Field Services Certification #: 5342
West Virginia Certification #: 357
North Carolina Wastewater Certification #: 12
VrginiaNELAP Certification #: 460221
South Carolina Certification #; 99006001
Asheville Certification IDs
2225 Riverside Dr., Asheville, NC 28804 North Carolina Wastewater Certification #: 40
Florida/NELAP Certification* E87648 South Carolina Certification #: 99030001
Massachusetts Certification M M-NC030 West Virginia Certification #: 356
North Carolina Drinking Water Certification #: 37712 VirginiaNELAP Certification #: 460222
REPORT OF LABORATORY ANALYSIS
C
C-7 -
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc.. Page 2 of 12

aceAfraly6cal
_r
1 wwH!pacetsbs.ron3
Pace Analytical Services, Inc.
2225 Riverside Dr,
Asheville, NC 20804
[phone]
c
SAMPLE ANALYTE COUNT
Project: DAVE STEEL
Pace Project No_: 92201505
Analytts
Lab ID Sample ID Method
Analysts
Reported
Laboratory
92201505001 SD02 EPA 1664E
CLW
1
PASI-C
EPA200.7
JMW
3
PASI-A
SM 2540D
WRC
1
PASI-A
92201505002 SD01 EPA 1664E
CLW
1
PASI-C
EPA 200.7
JMW
3
PASI-A
SM 2540D
WRC
1
PAS{ -A
REPORT OF LABORATORY ANALYSIS
This report shalt not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Page 3 of 12

17aeeAnalytiba(
l xtNx!pacela6s.com
i
ANALYTICAL RESULTS
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28894
(82B)254-7176
Project: DAVE STEEL
Pace Project No.: 92201505
Sample: SD02 Lab ID: 92201505001 Collected: 05/15/14 07:10 Received: 05/15/14 10:33 Matrix: Water
Parameters Results Units Report Limit OF Prepared Analyzed CAS No. Qual
HEM, Oil and Grease
Analytical Method: EPA 1664E
Oil and Grease
NO mg/L
5.0
1
05/19/14 06A4
200.7 MET 1CP
Analytical Method: EPA200.7 Preparation Method_ EPA200.7
Copper
ND uglL
5.0
1 05/1511411:55
0512011421,15 7440-50-8
Lead
ND ug/L
5.0
1 05/16/14 11:55
05/20/14 21:15 7439-92-1
Zinc
41.9 ug/L
10.0
1 05/16/14 11:55
05/20/14 21:15 7440-66-6
2540D Total Suspended Solids
Analytical Method: SM 2540D
Total Suspended Solids
7.5 mgtL
3.0
1
05/22/14 12:59
all
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full.
Date: 05/23/2014 11:16 AM without the written consent of Pace Analytical Services, Inc., Page 4 of 12

aceAnalytical
www.pacelabs.com
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
ANALYTICAL RESULTS
Project: DAVE STEEL
Pace Project No.: 92201505
Sample: SD01
Lab ID: 92201505002 Collected: 05/15/14 07:05
Received: 05115/14 10:33 Matrix: Water
Parameters
Results Units
Report Limit DF
Prepared
Analyzed
CAS No. Qual
HEM, Oil and Grease
Analytical Method: EPA 1664E
Oil and Grease
ND mg/L
5.0 1
05/19/14 06:44
200.7 MET ICP
Analytical Method: EPA 200.7 Preparation Method: EPA 2003
Copper
ND ug/L
5.0 1
05/16/14 11:55
05/20/14 21:28
7440-50-8
Lead
ND ug/L
5.0 1
05/16/14 11:55
05/20114 2128
7439-92-1
Zinc
41.3 ug/L
10.0 1
05/16114 11:55
05120114 21:28
7440-66-6
2540D Total Suspended Solids
Analytical Method: SM 2540D
Total Suspended Solids
ND mgfL
3.9 1
OW2114 12:59
C- REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
Date: 0512312014 11:16 AM without the written consent of Pace Analytical Services, Inc- Page 5 of 12

Pace Analytical Services, Inc.
1�?(OAnalXicaf- 2225 Or
Riverside
AshNeveville, NC 28130404
! www.pacelaurmm [phone]
1
QUALITY CONTROL DATA
Project: DAVE STEEL
Pace Project No.: 92201505
QC Batch: GCSV117624 Analysis Method: EPA 1664B
QC Batch Method: EPA 16649 Analysis Description: 1664 HEM, Oil and Grease
Associated Lab Samples: 92201505001, 92201505002
METHOD BLANK: 1200904 Matrix: Water
Associated Lab Samples; 92201505001, 92201505002
Blank Reporting
Parameter Units Result Limit Analyzed Qualifiers
Oil and Grease mg/L ND 5.0 05/19/14 06:39
LABORATORY CONTROL SAMPLE: 1200905
Spike LCS LCS % Rec
Parameter Units Cone. Result °% Rec Limits Qualifiers
Oil and Grease m}iL 40 37-2 93 78-114
MATRIX SPIKE SAMPLE: 1200906
92201406001 Spike IVIS MS % Rec
Parameter Units Result Cone. Result °% Rec Limits Qualifiers
Oil and Grease mg/L ND 40 38.1 93 78-114
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced. except in full,
Date: 05/23/2014 11:16 AM without the written Consent of Pace Analytical Services, Inc..
Page 6 of 12
C.

aceAnalytical
xvrw.pacelaAs.arn
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
Project: DAVE STEEL
Pace Project No.: 92201505
QC Batch: MPRP/15969
QC Batch Method: EPA 200.7
Associated Lab Samples: 92201505001, 92201505002
METHOD BLANK: 1200536
Associated Lab Samples: 92201505001, 92201505002
Parameter Units
Copper uglL
Lead uglL
Zinc uglL
QUALITY CONTROL DATA
Analysis Method: EPA 200.7
Analysis Description: 200.7 MET
Matrix: Water
Blank Reporting
Result Limit Analyzed
ND 5.0 05/20/14 19:37
ND 5.0 05/20/1419:37
ND 10.0 05/20/1419:37
Qualifiers
LABORATORY CONTROL SAMPLE:
1200537
Spike
LCS LCS % Rec
Parameter
Units
Conc.
Result % Rec Limits Qualifiers
Copper
uglL
500
472 94 85-115
Lead
uglL
500
475 95 85-115
Zinc
uglL
500
462 92 85-115
MATRIX SPIKE & MATRIX SPIKE DUPLICATE:
120D53B
1200539
MS
MSD
92201265001
Spike
Spike
MS
MSD
MS
MSD
% Rec
Parameter Units
Result
Conc.
Cone.
Result
Result
% Rec
% Rec
Limits
RPD
Copper uglL
0.026
500
500
507
509
96
97
70-130
0
mglL
Lead uglL
ND
500
500
469
465
94
93
70-130
1
Zinc uglL
0.10
500
500
566
566
93
93
70-130
0
mg1L
C
MATRIX SPIKE & MATRIX SPIKE DUPLICATE:
1200540
1200541
MS
MSD
92201505001
Spike
Spike
MS
MSD
MS
MSD
% Rec
Parameter Units
Result
Conc.
Conc.
Result
Result
% Rec
% Rec
Limits
RPD
Copper ug1L
ND
5D0
500
485
478
97
95
70-13D
1
Lead ug1L
ND
500
500
483
476
96
95
70-130
1
Zinc uglL
41.9
500
500
508
497
93
91
70-130
2
Date: 05/23/2014 11:16 AM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Qual
Qual
Page 7 of 12

1!�?Camalxical
vro'w.patelehs.cwn
r
1
QUALITY CONTROL DATA
Project: DAVE STEEL
Pace Project No.: 92201505
Pace Analytical Services, Inc_
2225 Riverside Dr.
Asheville, NC 28804
[phone]
QC Batch: WET131150
Analysis Method:
SM 2540D
QC Batch Method: SM 2540D
Analysis Description:
2540D Total Suspended Solids
Associated Lab Samples; 92201505001. 92201505002
METHOD BLANK: 1204746
Matrix: Water
Associated Lab Samples: 92201505C01, 922015050D2
Blank Reporting
Parameter
Units
Result Limit
Analyzed Qualifiers
Total Suspended Solids
mg1L
ND
2.5 05/22/14 12:48
LABORATORY CONTROL SAMPLE:
1204747
Spike LCS
LCS % Rec
Parameter
Units
Conc. Result
% Rec Limits Qualifiers
Total Suspended Solids
mgIL
250 258
107 80-120
SAMPLE DUPLICATE: 1204748
92201543001 Dup
Parameter
Units
Result Result
RPD Qualifiers
Total Suspended Solids
mg/L
100 98.5 2
SAMPLE DUPLICATE: 12D4749
92201459004 Dup
Parameter
Units
Result Result
RPD Qualifiers
Total Suspended Solids
mg[L
ND
NO
REPORT OF LABORATORY ANALYSIS
This report small not be reproduced. except in full,
Date: 05/23/2014 11:16 AM without the written consent of Pace Analytical Services, Inc,.
C
Page 8 of 12
C.
C

Pace Analytical Services, Inc.
�ceAnalyiical ® 2225 Riverside Dr.
Ashevi3le, NC 2a804
/ ww,vpatalahs.corn [phone]
1
QUALIFIERS
Project: DAVE STEEL
Pace Project No.' 922D1505
DEFINITIONS
Di= - Dilution Factor, if reported, represents the factor applied to the reported data due to changes in sample preparation, dilution of
the sample aliquot, or moisture content.
Nib - Not Detected at or above adjusted reporting limit.
MDL -Adjusted Method Detection Limit.
PRL- Pace Reporting Limit.
RL - Reporting Limit.
S - Surrogate
i.2-Diphenythydrazine (8270 listed analyte) decomposes to Azobenzene-
Consistent with EPA guidelines, unrounded data are displayed and have been used to calculate % recovery and RPD values.
LCS(D) - Laboratory Control Sample (Duplicate)
MS(D) - Matrix Spike (Duplicate)
DUP - Sample Duplicate
RPD - Relative Percent Difference
NC - Not Calculable.
SG - Silica Gel - Clean -Up
U - Indicates the compound was analyzed for, but not detected.
N-Nitrosodiphenylamine decomposes and cannot be separated from Diphenylamine using Method 8270. The result reported for
each analyte is a combined concentration.
Acid preservation may not be appropriate for 2-Chloroethylvinyl ether, Styrene, and Vinyl chloride.
Pace Analytical is TNI accredited. Contact your Pace PM for the current list of accredited analytes.
C_ TNI - The NELAC Institute.
LABORATORIES
PASI-A Pace Analytical Services -Asheville
PASI-C Pace Analytical Services - Charlotte
L
REPORT OF LABORATORY ANALYSIS
This report shall not toe reproduced, except in full,
Date: 05/23/2014 11:16 AM without the written consent of Pace Analytical Services, Inc.. Page 9 of 12

acemalXics
i _ KwWPecelabs.corn
i
QUALITY CONTROL DATA CROSS REFERENCE TABLE
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
Project: PAVE STEEL
Pace Project No.: 92201505
Analytical
Lab ID Sample ID QC Batch Method QC Batch Analytical Method Batch
92201505001
SD02
EPA 16546
GCSV117624
92201505002
SD01
EPA1564B
GCSV/17624
92201505001
SD02
EPA 200.7
MPRP115959 EPA 200.7 ICP114447
92201505002
SD01
EPA200.7
MPRP115969 EPA200.7 ICP114447
92201505001
SD02
SM 2540D
WET131150
92201505002
SD01
SM 2540D
VVET131150
Date: 05123/2014 11:16 AM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
c
Page 10of12
C

uoctrment Name: Sample Condition Upon Document Revised: April 9, 2014
/ � ccAn�ly7ica! Receipt Page 1 of 2
Document No.: Issuing Authorities:
F-ASV-CS-003-revA 3 Pace Asheville Qualit .Office
Client Name-
Courier (Circle): Fed Ex UPS LISPS CClie® Commercial Pace Other
Custody Seat on Cooler/Box Prosont: ❑ yes 07no SlEals intact: n yes [] no
Packing Material: ❑ Bubbie _ , E ubble Hags G Nan Other
Theraiometer Usod:(Gun#3-1302659e�e Type of Ice: 1Net Blue None - Samples on ice, cooling process has begun
f7ll
Temr) Correction Factor: Add ! Subtract 6 • , C
j {
Corrected Cooler Temp.: � C
Biological Tissue is Frozen: Yes Na run
Date and InIY Is o erxaml I;t
1}�4 rson � � i
' Temp slrnuld tie above freezing to S'G
Comments:
contents:
Chain of Custody Present:
2Ye• ONO
Ot4fA
1.
Chain of Custody Filled Out:
EYes, ONo
❑N/A
2.
Chain of Custody Relinquished:
Ye -ONo
❑NIA
3.
Sampler Name & Signature on COC:-
es,ONo
❑NIA
4.
Samples Arrived within Hold Time:
es ©No
ON/A
5,
Short Hold Time Analysis (<72hr1:
Oyes A
❑WA
6.
Rush Turn Around Time Requested:
Oyes ZNo
❑N/A
7.
Sufficient Volume:
a No
❑NIA
8.
Correct Containers used:
i Ye ❑No
❑NIA
9:
-mace Containers Used:
CJYes E]No
❑WA
Containers Intact:
©as ❑No
❑NIA
40.
Filtered volume received for Dissolved tests
❑Ye No
iA
11.
Sample Labels match COG:
Yc ON.
❑NIA
12.
-Includes date/time/IDIAnaI sis Matrix:
it
Ail containers needing FNeservalion hava been checked.
/
©Yes No
❑NIA
13,
All containers needing preservation are found to be in
Yes LINDNIA
compliance with EPA recommendation.
exceptions VOA, coliform, TOG O LPI J-SRO (•:fater)
`
Samples checked for dechlorination:
Yes ❑No
ON/J
14,
Headspace in VOA Vials ( >6mm):
❑Yob ONo
NIA
15.
Trip Blank Present:
Oyes. ONO
NI
15.
Trip Blank Custody Seals Present
iaYes ONO
NIA
Pace Trip Blank Lot # (if purchased):
Client Notification! Resolution:
Person Contacted:
Comments/ Resolution:
DateMm©:
SCURF Review: !j '? j) Date: c-1
SRF Review: I TW\ ) Date:
Nola: Whenever there is a discrepancy affecting North Carolina
compliance samples, a copy of this form will be sent to the North
Carolina DEHNR Certification Office ( i.e out of hold, incorrect
preservative, out of temp, incorrect containers)
C
Field Data Required? Y / N
Place label here
OR
Handwrite project number
(if no label available)
Page 11 of 12

PacMnalAcal `
.- �n:rie-lyrtla6tc�rn
Section A
RagSjired Ctien; Inlonn000n;
Section B
Requlmd Project
CHAIN -OF -CUSTODY 1 Analytical Request Document
The Chain-of-Cuslody Is a LEGAL DOCUMENT. AIJ reievanl fields must be coMpleled acouralf0y.
Section C Page, of
Invoice Infor.'"mo '.
'••": •:7.
1�
I
Repent To- J
. . 1
AlrenEOn:
t
Adds
Copy Tu:
V 14
Company Name:
REGULATORY AGENCY
J. jf k
L�
4ddr„ss',
NPDES GROUNDWATER GRlfriCING WATER
Tai To
Purrhnxe Or;:er No .
Fa;.r. Ounrn
UST RC'tA OTHER
Phor D'
/�
,
PrtNecl Name:
Puce ?ro. .I
Requested pue'ClalnlFAT:
_
U•1
Mnntger:
Site Location
Prarcl4umL•r�:'
� �
Pace Pnor�a=
o o
srarE:
Requested
Analysts Filtered (YIPS)
$°UIO a , reatim Cosa:
RrqurrtdCi�nt kdornas9kp ar -R SL
o'sx,+u'ate r
f
$
COLLECTED
VjwVyT
- Blir YYT
Y4IISl@ :Yeller vW.,
cCL=$ag
Ci.YAOlIr=_
PrnrSrlCi P
*'NiT
i',Nlira,:a
y
So[i,'SoOd SL
SAMPLE ID o;l aL
' fA-4 0.S / -J 'Nip• AR
Ar AR
Samde ILic MUST BE E:NIWi: Tissue TS
O
qq
4
Clit,er or
11
r
F
Z
#
x
DATE
TIME
DATE
T16'.E
_AUDETIo4AL COMMENTS ( RELNJ LiISI;Ep SY{RF"]LtATION
I BATE T.wF
t � I
rr �.
� e
m
H �
H
U Q tY Mace Proiedt�Na.l Lab
S Z 0 2 O
ACCEPTEn BY! AFPILIATIO4 # DATE TPUE SAMPLE CONDITIONS
SAMPLER NAME AND SIGNATURE
d
PRINT Nale cf SA;.fFLER: ` .l
47,
SIGNATURE Pf SAmPLER`�^"'
_..`..: rn: S..':]'y3': Sy: r .. ;C: -4ib lL.': li;. ., .,:LS:-_1 ... '�. . ..: J:;_�...n...'.'....__.-..__.._�-�ti_J•--•�4r1..-.,��
o-....:.�«.y-.we.:........"_._....:..,.:.....tea .a,...,,,.- ,.. ..
SATE S'icned
N
0
N

w�w ®aRe Steel Company, Inc.
Steel Construction Since 1929
April 18, 2014
Department of Environment and Natural Resources
Division of Energy, Mineral, and Land Resources
2090 U.S. Highway 70
Swannanoa, NC 28778
Attn: Laura Herbert, PE
Re: Dave Steel Company, Inc.
40 Meadows Road
Asheville, NC 28802
Certificate of Coverage No. NCG030265
Dear Ms. Herbert:
APR 2 3 2014
Dave Steel Company, Inc. (DSCO) is currently collecting monthly monitoring samples at their facility as part of a
Tier I1 Response for past stormwater zinc exceedances. DSCO would like to request relief from monthly
monitoring at this time. Please see below for more information regarding this request.
SDO 002 Sampling History
DSCO has two stormwater discharge outfalls (SDOs) labeled SDO 001 and SDO 002 (See Figure 1).
Quantitative Results
Zinc levels at SDO 002 have been in exceedance of the benchmark value of 0.067 mg/L for three consecutive
sampling events, as shown in Table l:
Table 1. Data from SDO 002 Recent Sampling Ei,elms
Sampling Date at SDO 002Tx
Zinc Level (m ) �
.- Notes
Janua 30, 2013
0.071
1" Semiannual Event of 2013n
November 26, 2013
0.160
2 Semiannual Event of 2013
Januar� 2014
No Discharge
Tier II Monthly Sarnpiling
February 19, 2014
0.096
Tier 11 Monthly Sampling
March 2014
No Discharge
Tier 11 Monthly Sampling
Qualitative Results
The Qualitative Monitoring Events conducted at SDO 002 during the aforementioned sampling events did not
warrant further investigation due to the good/moderate clarity, low solids, and no presence of foam or oil sheen at
stormwater outfall SDO 002. No other deficiencies were observed at SDO 002 during the Qualitative Monitoring
Events. The system appeared to be operating as designed and was in good order with no evidence of pollutant
discharges.
ASHEVILLE, NC CINCINNATI, OH CHESNEE, SC
P.O. Box 2630 Asheville, N.C. 28802 Telephone [phone] Fax [phone]
�CERTIFiED AISC QUALITY CERTIFICATION
4FABRICAiOR STANDARD FOR STEEL BUILDING STRUCTURES
'"` SOPHISTICATED PAINT ENDORSEMENT - ENCLOSED

Date Steel Company, Inc.
Steel Construction Since 1929
Potential Non -Industrial On -Site and Off -Site Zinc Sources at DSCO
It is Dave Steel's opinion that at least some of the zinc (if not all) is likely coming from non -industrial on -site
sources (e.g. the roof and stormwater pipes) and off -site sources such as Asheville Buncombe Technical
Community College (AB Tech) that is located upstream.
Non -Industrial On -Site Sources
Stormwater picks up zinc from galvanized roofing materials that constitute most of the 78,218 square foot main
metal fabrication building. Most of the roofs drain to galvanized gutters and downspouts and are piped directly to
the stormwater conveyance/discharge system (much of which is also galvanized). Galvanized fencing may also
contribute zinc to stormwater discharaes. Most fencing is on property boundaries and is situated in grassy areas
that should limit zinc transport to impervious surfaces and ultimately to the stormwater conveyance/discharge
system. See Table 2 for an example of a measureable level of non -industrial zinc coming from DSCO's roof.
Off -Site Sources
The sources of stormwater from AB Tech include parking areas below the Rhododendron Building that are
controlled by a detention pond. The pond discharge is piped across Dave Steel property and combined with on -
site stormwater just upstream of SDO 002. Table 2 shows a stormwater zinc concentration that came from an off -
site source.
Table 2. Samples Collected. from Non -Industrial On -Site and Off -Site Locations
Sampling Locatian
''
''`
'' Comparison to ZincBenchmark
and Date
hnc.Level (mg/.L)
Dotes
.:
Z. Value of 0.007, m
Main Roof Drain
0.01 14
On -Site, Front of
17% of benchmark
Nov 26, 2013
building
AB Tech Discharge
0.0246
Off -Site. At DSCO/AB
37% of benchmark
Nov 26, 2013
Tech ro erty line
Potential On -Site Industrial Zinc Sources
Some of the iron used in the metal fabrication shop is galvanized and/or contains zinc (Nucor brand); however,
this only makes up approximately <5% of the total steel we fabricate. We also have a small paint room at the
facility; however, zinc is only contained in one of the products we use (Bright Zinc Galvanizing Spray) at a
concentration of 10-15 % by weight (see Table 3). We only use approximately 1.5 gallons of this product per
year, and painting is conducted indoors. Any overspray is collected indoors as well.
Ancillary equipment has zinc components that drain to the stormwater conveyance/discharge system. These
equipment include air pollution control devices, roof mounted air conditioning units, and flashing. In addition,
truck tires contain about one percent zinc. All of the steel beams delivered to or transported from the site are
trucked. The relatively small property requires that trucks maneuver with tight turning radii. The constant
moving and wheel turning likely produces some zinc -containing residual. Forklifts also have tires that contain
zinc and use hydraulic oil that contains up to 0.1 percent zinc. However, most outside areas have relatively few
of I spots.
ASHEVILLE, NC CINCINNATI, OH CHESNEE, SC
P.O. Box 2630 Asheville, N.C. 28802 Telephone [phone] Fax [phone]
CERTIFIED AISC DUALITY CERTIFICATION
CFABRICA70R STANDARD FOR STEEL BUILDING STRUCTURES
'""` SOPHISTICATED PAINT ENDORSEMENT - ENCLOSED

Date Steel Company, Inc.
� y�
Steel Construction Since 1929
Actions Taken to Remedy Potential On -Site Zinc Sources
Based on an inspection by NCDENR staff in May 2013 after the first zinc exceedance, DSCO made many
improvements to the facility. See Attachment I for details.
Inspection Conducted
DSCO staff conducted a stormwater inspection of the facility in January 2014 in accordance with the Tier II
requirements. No items were found to be deficient at the facility during the inspection that would have likely
contributed to elevated zinc levels. The only item in question was an indoor storm drain cover that had been
moved out of place. After the inspection, it was returned to its proper location. See Attachment 2 for more
information about the inspection.
M!4)C Review
DSCO staff conducted a review of the facility's Material Safety Data Sheets (MSDSs) to determine whether or
not materials used in industrial processes contain zinc. Forty-nine MSDSs were reviewed, and based on the
MSDSs provided by the manufacturers, only eight products were found to contain zinc. The following table
contains the only products that were found to contain zinc:
Table .3. Products Found to Contain Zinc during MSDS Review
Pathway and
Zinc Type
Zme
Usage
Apphcatton
N� Llkellhood f©r
Product
Concentration
r ear
1� y
; 4. ..
m
ormWAter x
-�
by Werght
,o�Iiel°act _.o.xo
Bright Zinc
Zinc powder
Overspray outside of
10-15%
1.5 gal
Touch Up
Galvanizing Spray
7440-66-6
building — Not likely
Cambridge Lee
Zinc oxide
Plasma welding
< 0.1 %
< 100 #
None
Tellurium Copper
1314-13-2
consumable tips
Zinc
< 0.01 % in base
Uncontrolled Dust —
Nucor —Bar
30,013 #
Steel Fabrication
7440-66-6
metal
Not likely
Nucor — Joists,
Zinc
< 0.04 in base
Ships to job
Uncontrolled Dust —
Supply Customer
Bridging
7440-66-6
metal
site only
Not likely
Zinc
< 0.01 in base
1,544,067
Uncontrolled Dust —
Nucor —Plate
7440-66-6
metal
#
Steel fabrication
Not likely
< 0.01 % in base
Zinc
Uncontrolled Dust —
Nucor — Sheet
metal and < 10%
10,833 #
Steel fabrication
7440-66-6
Not likely
in coating
< 0.04% in basemetal
Vulcraft —Nucor —
Zinc
Ships to job
Uncontrolled Dust —
and < 10%
Supply Customer
Decking
7440-66-6
site only
Not likely
in coating
ASHEVILLE, NC CINCINNATI, OH CHESNEE, SC
P.O. Box 2630 Asheville, N.C. 28802 Telephone [phone] Fax [phone]
CERTIFIED AISC QUALITY CERTIFICATION
QFA3RICATOR STANDARD FOR STEEL BUILDING STRUCTURES
''°` SOPHISTICATED PAINT ENDORSEMENT - ENCLOSED

'd
DaNe Steel Company, Inc.
Steel Construction Since 1929
Conclusion
Based on the information provided above, DSCO believes the majority, if not all, of the zinc seen in the
stormwater samples is coming from off -site and/or on -site non -industrial sources. Our roof and AB Tech
discharge samples from November 2013 support this assertion, as they contained zinc concentrations of 17% and
37% of the benchmark value, respectively. Even though DSCO believes these sources are the causes of the
exceedances seen at the site, per NCDENR recommendations, DSCO has made many improvements to the facility
to mitigate any potential on -site industrial sources of zinc.
DSCO respectfully requests that you consider granting relief from the monthly monitoring at this site in regards to
the zinc stormwater exceedances and Tier 11 Response.
DSCO is still operating under a Tier II Response in regards to zinc, and monthly monitoring will continue at this
SDO for the time being. In accordance with the permit, all parameters will be monitored at SDO 002 during
sampling events until three consecutive sample results are below the benchmark values and/or within the
benchmark range, and/or your office grants DSCO relief from this monthly monitoring. Please advise if DSCO
may be relieved from this monthly monitoring. We look forward to hearing your decision and/or discussing this
issue in greater detail.
Please contact me with questions.
Sincerely,
Dave Steel Company, Inc.
Rob owers
Environmental Health & Safety Director
828-252-2771
Attachments: Figure I — Facility Stormwater Layout
Attachment 1 — Email from Rob Clowers to Jonathan Stepp in August 2013
Attachment 2 — Stormwater Inspection in January 2014
cc: Darlene Kucken, NCDENR
ASHEVILLE, NC CINCINNATI. OH CHESNEE, SC
P.O. Box 2530 Asheville, N.C. 28802 Telephone [phone] Fax [phone]
`� CERTIFIED RISC QUALITY CERTIFICATION
QFA9RICATOR STANDARD FOR STEEL BUILDING STRUCTURES
SOPHISTICATED PAINT ENDORSEMENT - ENCLOSED

Dave Steel Company
Monitoring Relief Request Letter
Figure 1. Facility Stormwater Layout
Dave steel Company, Inc. PUG -AM
40 Meadow Road
C tp;!
Ashe%ille, NC 29802

Dave Steel Company
Monitoring Relief Request Letter
1 of 2
Attachment 1. Email from Rob Clowers to DWQ on August 30, 2013
Subject:
_........ .. .... .- ....w...............
Dave Steel Co. NCGO30265
From:
Rob Clowers (rclowers@DavesteeIcom)
.. .. ..
To:
jonathon.stepw?p�...�... .........
cdanr.gov;
Ce:
jclarkADavesteel corn. sbeemanADavesteelcom:
-._........................
Data:
. - .-.., .............. .. ._............ ..................... _.......... ........... ........ .......... ..................- ....... .......... ......... -............... ................ ... . ............. _.....
Friday, August 3t). 2013 9:39 AM
Jonathon.
We appreciate your call this week. This note is to provide follow up on our progress. our Management.
Production and Maintenance Departments have worked well to complete the following objectives:
8 Storm drain hasins have been cleaned out inside the shop.
8 New storm drain covers have been fabricated and fit tightly without water inlets. .
2 Downspout drainage areas have been covered
Active management of dust collection and proper disposal of solid, oil and grease wastes.
Mgt. and Employee Storniwater Pollution Prevention Training. (attached)
In regard to •Pier I status let this note verify we have:
Inspected; identified and continue to evaluate the possible causes of the benchmark value exceedance.
We identified specific. source controls. operational controls and physical improvements to reduce
concoitrations of zinc and all discharge characteristics noted in the SW31"s Plan's 1\ Facility Inspection
section.
The selected actions have been implemented.
We will be closely monitoring the outcome of the Semi Annual qualitative and quantitative stormwater
samples. In the event we continue to exceed benchmarks we will adhere to the Tiered responses and
follow-up activity. This includes checking for possible background sources found in roofing and siding
malerials.
(lave a good Labor Day weekend.
Best_
1018r_013 12:32

Dave Steel Company
Monitoring Relief Request Letter
prini 1 jNdibdA!mm
Rob (IoN►'e►s. C`it'
Ehi� Tiircctrar
Darr Steel C;ompa►►y, like.
Ashivilke, NC rCimimmtt 01f ' Clte.nee. ✓'i Yi
Ph: S«5-252-2771
Fax: [phone]'4
C JI: 828-337-1906
of 10;9^_713 1 ^_:32 P\

Dave Steel Company
Monitoring Relief Request Letter
Please check and return to safety after re, im
CS Upper End
SC Fit tip
SB Maintenance
IG shipping
TOOLBOX TALK IRAIN WATER DRAINS AND WASTE
Septemher a013
We are having a problem with rain water getting blocked and not draining.
The storm water drains in the Shop are collecting solids. Fab Shops generate
trash such as metal dust. cutting fluids, turnings. paper c� plastic trash, clothing
and other wastes. When all of this mixes %vith din - blockage occurs ...
then water gets backed up and stays in the Shop.
Do not place anything in the floor drains. It is important not to use the floor drains as a trash can.
You may have noticed the drains are getting cleaned and new corers installed to bloek trash.
Always use caution to prevent chemicals, paints..oils and cutting fluids from entering the
rainwater drains. Use absorlicnts to catch oils and chemicals and dispose of this in
trash cans or the dumpster.
Remember "We all live downstream"

Dave Steel Company
Monitoring Relief Request Letter
Attachment 2. Stormwater Inspection on January 21, 2014
Sava Siee! Company -- W a_,fiJw Road Facility Stcr mwaiar PWIL;N +s Prevention ?ran
Semi -Annual Facility Stormwater Inspection Checklist
Instructions: This inspection record will be completed semi-annually: at a minimum, in
conjunction with the analytical sampling events. Place an X in the appropriate box for
each item. If any response requires elaboration, do so in the Description & Comments
space provided_ Further descriptions or comments should be attached on a separate
sheet of paper if necessary. Semi-annual inspections must be kept or, file at the facility
for 5 years.
Area Yes No Descriptions & Comments
Solid waste and cardboard dimpsters show o
evidence of stormwater impact
Scrap metal accumulation areas show
L3
evidence of storm -water impact
Scrap wood bill shows evidence of stormwater
0
impact
r n
Waste oil drum shows evidence of stormwater
f t • u!wTtiJe« Lam. ix !v.C��{iv <'tt�J
impact
Evidence of stormwater impacts at
C3
loadinglunloading areas
Evidence of stormwater impacts in
fabrication/painting areas of facility yard
Evidence of stormwater impacts in other areas
r
19 _
of the facility
L.A.
Lt
Evidence of stormwater impacts at outfail;;
© fi
Inventory of split response equipment needs
© Ni, — =jj.: 1
restocking
Lila�✓�r 1?(?�ij aid t EEE r }�:..tj•'_ .G
f2en7artCS:t2iL.i •^—.
-'�' SY�-e4Si� illj' K�1e �iS'CF"1 iel� .7 rm
.
6u4�:..t:'; 'r _;c•...'v+ cf..'ts.t `.... v,n,,,b :.k hG:_
.... !x.-e.i,...
."�'�t�= arc C�,�. �c.;�.�'i:.u°3 a,'_.n t�.•c•,'ti: r•wi�{r�':.��^!�; .'i{7a�-i
,�. r -�Y i� :Cam,-e. . , in..�z::, • o�:,�+ rc:.. • ' i
.tip= "=' :r••`C Rri� 7 11':,4
���1 �. i'�::✓ :. ^� j�'A�-•. t'a.� � C.�.i:-rr, i �w.{^' '%r r., nT��y
F` .. ,x �Yi
..► s,�1 ..°.� ;�.; �:e:..�,.;n _ ;,•r r ..y;�. 1'�...� .i Vie; ���• �r•�.:+t- F� +r;� . —4 � y!,t-�:. r:�• �s�.
;t
Signature: ;�:�°�:i r,� � ;•�t},�; '::,€�^•� _
Date: 11 ;.;
GQNNks'hbA. = 3� . rCXsi

Dave Steel Company, Inc.
Steel Construction Since 1929
April 18, 2014
Department of Environment and Natural Resources
Division of Energy, Mineral, and Land Resources
2090 U.S. Highway 70
Swannanoa, NC 28778
Attn: Laura Herbert, PE
Re: Dave Steel Company, Inc.
40 Meadows Road
Asheville, NC 28802
Certificate of Coverage No. NCG030265
Dear Ms. Herbert:
APR 2 3 2014
'- n Qiality Section
Dave Steel Company, Inc. (DSCO) is currently collecting monthly monitoring samples at their facility as part of a
Tier II Response for past stormwater zinc exceedances. DSCO would like to request relief from monthly
monitoring at this time. Please see below for more information regarding this request.
SDO 002 Sampling History
DSCO has two stormwater discharge outfalls (SDOs) labeled SDO 001 and SDO 002 (See Figure 1).
Ouantitative Results
Zinc levels at SDO 002 have been in exceedance of the benchmark value of 0.067 mg/L for three consecutive
sampling events, as shown in Table 1:
Table 1. Data from SDO 002 Recent Sampling Events
Satholing Date at SDO' 002
" Zinc Uve (ri i ) '
Notes 7
January 30, 2013
0.071
1" Semiannual Event of 2013
November 26, 2013
0.160
2 Semiannual Event of 2013
January 2014
No Discharge
Tier II Monthly Sampling
February 19, 2014
0.096
Tier II Monthly_Sampling
March 2014
No Discharge
Tier II Monthly Sam ling
Qualitative Results
The Qualitative Monitoring Events conducted at SDO 002 during the aforementioned sampling events did not
warrant further investigation due to the good/moderate clarity, low solids, and no presence of foam or oil sheen at
stormwater outfall SDO 002. No other deficiencies were observed at SDO 002 during the Qualitative Monitoring
Events. The system appeared to be operating as designed and was in good order with no evidence of pollutant
discharges.
ASHEVILLE, NC CINCINNATI, OH CHESNEE, SC
P.O_ Box 2530 Asheville, N.C. 28802 Telephone [phone] Fax [phone]
WCERTIFIED AISC QUALITY CERTIFICATION
FASRICATOR STANDARD FOR STEEL BUILDING STRUCTURES
SOPHISTICATED PAINT ENDORSEMENT - ENCLOSED

DaS Steel Company, inc.
Steel Construction Since 1929
Potential Non -Industrial On -Site and Off -Site Zinc Sources at DSCO
It is Dave Steel's opinion that at least some of the zinc (if not all) is likely coming from non -industrial on -site
sources (e.g. the roof and stormwater pipes) and off -site sources such as Asheville Buncombe Technical
Community College (AB Tech) that is located upstream.
Non -Industrial On -Site Sources
Stormwater picks up zinc from galvanized roofing materials that constitute most of the 78,218 square foot main
metal fabrication building. Most of the roofs drain to galvanized gutters and downspouts and are piped directly to
the stormwater conveyance/discharge system (much of which is also galvanized). Galvanized fencing may also
contribute zinc to stormwater discharges. Most fencing is on property boundaries and is situated in grassy areas
that should limit zinc transport to impervious surfaces and ultimately to the stormwater conveyance/discharge
system. See Table 2 for an example of a measureable level of non -industrial zinc coming from DSCO's roof.
Off -Site Sources
The sources of stormwater from AB Tech include parking areas below the Rhododendron Building that are
controlled by a detention pond. The pond discharge is piped across Dave Steel property and combined with on -
site stormwater just upstream of SDO 002. Table 2 shows a stormwater zinc concentration that carve from an off -
site source.
Table 2. Samples Collected from Non -Industrial On -Site and Off -Site Locations
Sampling Location
°Comparison to: Zinc Benchmark
. and Date
Zinc.Level (mg/L)
-.
Notes
=
Value of.0.067. m
Main Roof Drain
0.01 14
On -Site, Front of
17% of benchmark
Nov 26, 2013
building
AB Tech Discharge
~
0.0246
Off -Site, At DSCO/AB
37% of benchmark
Nov 26, 2013
Tech property line
Potential On -Site Industrial Zinc Sources
Some of the iron used in the metal fabrication shop is galvanized and/or contains zinc (Nucor brand); however,
this only makes up approximately <5% of the total steel we fabricate. We also have a small paint room at the
facility; however, zinc is only contained in one of the products we use (Bright Zinc Galvanizing Spray) at a
concentration of 10-15 % by weight (see Table 3). We only use approximately 1.5 gallons of this product per
year, and painting is conducted indoors. Any overspray is collected indoors as well.
Ancillary equipment has zinc components that drain to the stormwater conveyance/discharge system. These
equipment include air pollution control devices, roof mounted air conditioning units, and flashing. In addition,
truck tires contain about one percent zinc. All of the steel beams delivered to or transported from the site are
trucked. The relatively small property requires that trucks maneuver with tight tuming radii. The constant
moving and wheel turning likely produces some zinc -containing residual. Forklifts also have tires that contain
zinc and use hydraulic oil that contains up to 0.1 percent zinc. However, most outside areas have relatively few
oil spots.
ASHEVILLE, NC CINCINNATI, OH CHESNEE, SC
P.O. Box 2630 Asheville, N.C. 28802 Telephone [phone] Fax [phone]
CERTIFIED AISC QUALITY CERTIFICATION
�1�kJ dFfL9RICA30R STANDARD FOR STEEL BUILDING STRUCTURES
"`"� SOPHISTICATED PAINT ENDORSEMENT- ENCLOSED

Dawl Steel Company, Inc.
Steel Construction Since 1929
Actions Taken to Remedy Potential On -Site Zinc Sources
Based on an inspection by NCDENR staff in May 2013 after the first zinc exceedance, DSCO made many
improvements to the facility. See Attachment I for details.
Inspection Conducted
DSCO staff conducted a stormwater inspection of the facility in January 2014 in accordance with the Tier 11
requirements. No items were found to be deficient at the facility during the inspection that would have likely
contributed to elevated zinc levels. The only item in question was an indoor storm drain cover that had been
moved out of place. After the inspection, it was returned to its proper location. See Attachment 2 for more
information about the inspection.
MSDS Review
DSCO staff conducted a review of the facility's Material Safety Data Sheets (MSDSs) to determine whether or
not materials used in industrial processes contain zinc. Forty-nine MSDSs were reviewed, and based on the
MSDSs provided by the manufacturers, only eight products were found to contain zinc. The following table
contains the only products that were found to contain zinc:
Table 3. Products Found to Contain Zinc during MSDS Review
a wa an
P th y d
Zinc Type
Zinc
Usage
Likelihood for
Product
Prod
and CAS*
Concentration
per year
Application
3
Stormwater
by Weight
Impact:�
Bright Zinc
Zinc powder
10-15%
1.5 gal
Touch Up
Overspray outside of
Galvanizing Spray
7440-66-6
building — Not likely
Cambridge Lee
Zinc oxide
< 0.1 %
< 100 #
plasma welding
None
Tellurium Copper
1314-13-2
consumable ti s
XNucor---Bare
Zinc
< 0.01 % in base
30"10-0- '
Steel Fabrication
Uncontrolled Dust —
7440-66-6
metal
Not likely
Nucor — Joists,
Zinc
< 0.04 in base
Ships to job
Supply Customer
Uncontrolled Dust —
Bridging
7440-66-6
metal
site only
Not like]
ucor=Plate
Zinc
< 0.01 in base
[544;067/
Steel fabrication
Uncontrolled Dust —
7440-66-6
metal
#
Not likely
Zinc
< 0.01 % in base
Uncontrolled Dust —
Nucor— Sheet
40
74-66-6
meta] and < 10%
10,833 #
Steel fabrication
Not likely
in coating
Vulcraft —Nucor —
Zinc
< 0,04% in base
Ships to job
Uncontrolled Dust —
Decking
7440-66-6
met al and < 10%
site only
SulCustomer
ppy
Not likely
in coating
ASHEVILLE, NC CINCINNATI, OH CHESNEE, SC
P.O. Box 2630 Asheville, N.C. 28802 Telephone [phone] Fax [phone]
-CERTIFIED AISC QUALITY CERTIFICATION
<FABRICATOR STANDARD FOR STEEL_ BUILDING STRUCTURES
SOPHISTICATED PAINT ENDORSEMENT - ENCLOSED

d
Da%% Steel Company, Inc,
Steel Construction Since 1929
Conclusion
Based on the information provided above, DSCO believes the majority, if not all, of the zinc seen in the
stormwater samples is coming from off -site and/or on -site non -industrial sources. Our roof and AB Tech
discharge samples from November 2013 support this assertion, as they contained zinc concentrations of 17% and
37% of the benchmark value, respectively. Even though DSCO believes these sources are the causes of the
exceedances seen at the site, per NCDENR recommendations, DSCO has made many improvements to the facility
to mitigate any potential on -site industrial sources of zinc.
DSCO respectfully requests that you consider granting relief from the m—o—nthly'monitoring'at,this-site-iti'regards,to--?
thee zi stormwater eezce'edances-and Tier1I,Response.
DSCO is still operating under a Tier I1 Response in regards to zinc, and monthly monitoring will continue at this
SDO for the time being. In accordance with the permit, all parameters will be monitored at SDO 002 during
sampling events until three consecutive sample results are below the benchmark values and/or within the
benchmark range, and/or your office grants DSCO relief frorn this monthly monitoring. Please advise if DSCO
may be relieved from this monthly monitoring. We look forward to hearing your decision and/or discussing this
issue in greater detail.
Please contact me with questions.
Sincerely,
Dave Steel Company, Inc.
Rob Clowers
Environmental Health & Safety Director
828-252-2771
►'
Gc
�d
�do�
Attachments: Figure I — Facility Stormwater Layout
Attachment I — Email from Rob Clowers to Jonathan Stepp in August 2013
Attachment 2 — Stormwater Inspection in January 2014
cc: Darlene Kucken, NCDENR
ASHEVILLE, NC CINCINNATI, OH CHESNEE, SC
day P.O. Box 2630 Asheville, N.C. 28802 Telephone [phone] Fax [phone]
CERTIFIED AISC QUALITY CERTIFICATION
QFP92ICnTOR STANDARD FOR STEEL BUILDING STRUCTURES
'"` SOPHISTICATED PAINT ENDORSEMENT - ENCLOSED

Dave Steel Company
Monitoring Relief Request Letter
C�
Figure 1. Facility Stormwater Layout
%
...... . . ...........
Dave Steel Company, Inc. PUQ5H
ENWW&a& SMOW LLB
Phm 40 Meadow Road
...................
Asheville, NC 28802

Dave Steel Company
Monitoring Relief Request Letter
1 of
Attachment 1. Email from Rob Clowers to DWQ on August 30, 2013
Subject:
......... ........ ......... ........... ....._..._ .... .. .: _...,...._..... ........ .._.......... _._..............
Dave Steel Co. l40G030265
From:
............_.........
Rob Clowers (rclowers#Davesteel.com)
--...... ._.......... ........ ._.._..,_........ ......... ._...._......... ..... ....... .._.._-_._...... _........... .................................. .,.__......,..............
TO:
..... ........
jonathon.stepp@ncdenr-gov;
-- __._-...... _._.-, ...... .. .. _____
Cc:
......................,..,..,...... ,..... ,............ ,., -...,......,..,.....,..,......... .,...... .,..... ,......... ,......... ,., ..,..,........... . ..
jclark @Davesteel.com; sbeemangDavesteetcom;
..... ............ ............___......... _,........ ......,
.............................._._...._.......
Date:
...... .................. ...... .... .._..._........ ....... .......... ........ .._............... ............ ................ _..._.... ..... _.._............. ...........
Friday. August 30, 2013 9;39 AM
Jonathon.
We appreciate your call this week. This note is to provide follow up on our progress. Our Managerrlent.
Production and Maintenance Departments have worked well to complete the following objectives:
8 Storm drain basins have been cleaned out inside the shop.
8 New storm drain covers have been fabricated and fit tightly without water inlets. .
2 Downspout drainage areas have been covered
Active management of dust collection and proper disposal of solid, oil and grease wastes.
Algt. and.Employee Stortuwater Pollution Prevention Training. (attached)
In regard to Tier I status let this note verify we have:
Inspected, identified and continue to evaluate the possible causes of the benchmark value esceedance.
We identified specific source controls. operational controls and physical improvements to reduce
concentrations of zinc and all discharge characteristics noted in the Sw'3P's Plan's R Facility Inspection
section.
The selected actions have been implemented.
We will be closely monitoring the outcome ofthe Semi Annual qualitative and quantitative stotmwater
samples, in the event we continue to exceed benchmarks we will adhere to the Tiered responses and
follow-up acti,,7ty. This ineludes checking forpossible background sources found in roofing and siding
materials.
Have a good Labor Flay weekend.
Best.
10,'812013

Dave Steel Company
Monitoring Relief Request Letter
'rml
Rub Clowe1-S,
I.i[iS Dircclor
]lace Steel C(Impany, Inc.
ashcr iac, NC a C0.,1 * Chonce. ZrC
Ph: 52.277I
Fav 928-2 -5t'_4
Cell: 828-33 7-1906

Dave Steel Comt)anv
Monitoring Relief Reauest Letter
[toolbox Talk: RAIN WATER DRAINS AND WASTE
Month Se tzmbcr2013
cove ,- . 't eS'f V�v:: � SYTf'�w'�aitt vl:we Yl:cF ; :'F6R'! o.l.�S'1] �i . F�YTii M.`. ClC1f�T1iAT
TOOLBOX TALK IRAIN WATER DRAINS AND WASTE
September 2013
We are having a problem with rain water getting blocked and not draining.
The storm water drains in the Shop arc eollecting solids. Fab Shops generate
trash such as metal dust, cutting fluids, turnings, paper& plastic trash, clothing
and other wastes. When all of this mixes with dirt - blockage occurs ...
then water gets backed up and stays in the Shop.
Do not place anything in the floor drains. It is important not to use the floor drains as a trash can.
You mac have noticed the drains are eettine cleaned and new covers installed to block trash.
Always use caution to prevent chemicals, paints. oils and cutting fluids from entering the
rainwater drains. Use absorbents to catch oils and chemicals and dispose of this in
trash cans or the dumpster.
Remember "We all live do%cnstream"

Dave Steel Company
Monitoring Relief Request Letter
Attachment 2. Stormwater Inspection on January 21, 2014
Dave S!"t company - 'Usadow Road Facility Stormwater PaquVon Prevention Plan
Semi -Annual Facility Stormwater Inspection Checklist
Instructions: This inspection record will be completed semi-annually, at a minimum, in
conjunction with the analytical sampling events. Place an X in the appropriate box for
each item. If any response requires elaboration, do so in the Description & Comments
space provided. Further descriptions or comments should be attached or, a separate
sheet of paper if necessary. Semi-annual inspections must be kept or; file at the facility
for b years.
Area
Solid waste and cardboard dumpsters show
evidence of stormwater impact
Scrap metal accumulation areas show
evidence of stormwater impact
Scrap wood bin shows evidence of stormwater
impact
Waste oil drum shows evidence of stormwater
impact
Evidence of stormwate. impacts at
loading/unloading areas
Evidence of stormwater impacts in
fabricationlpaintng areas of facility yard
Evidence of stormwater irnpacts in other areas
or the Facility
Evidence of stormwater impacts at ou?Tallt;
Yes No Descriptions & Comments
I�
L
L�
LYCA [a U ^ht =rc 34=
Inventory of spill response equipment needs ©
restocking;
"����RL'.��ti C.:-:,C#•FC ':a� G� e��..�' �'i�.r_ tip;;-3-,�� � �e._ ,.,... .
a Remarks.
-} <,V,, f7uC�:r".f r�.i:': ;si"�ra. ti, r�;.; +.,... •r9 hrt; k. {,•3i:>..... Oria .
.��te..ctt'1 C,.,ei,., l•�:�.+r.�, F.t.n t:{,^ti: �-�,:,�{.��'ic�v:�; s^Arr�
..p, Y. 'i:.;: i? `�,f- ; �ra�i '"• tte: stti _l `.i�* `G=•.. i3 i Gt !%E.:
.►�.iKA1c:r ,..t'jt4 t,,1 t :c°'4`.:n.�, w,N-',,,,4,th :" wri . +5�•
ti ,� M r •n ;t.Y€. CC
Signature: Date: Ii r.€ f " ,i rz ,ui.
S-Oc r,r�

I spoke with Laura Herbert and Jonathan Stepp(828-296-4500) of DENR Division of Land Resources
today. DLR just recently assumed responsibility for stormwater and Jonathan Stepp, whom we met at
your facility, will be one of her lead stormwater people.
Ms. Herbert tells me the DENR GentFal Offiee sta# (Bethany r-.-.er-goulias 919 907-6372 and KeR Yield.
919 997 &"&' staff are eentemplating preparing to present adjusted al ;iRG and eoppe+
beRc ems- benchmark values for zinc and copper at the next Triannual Review meeting. The values
that are currently being discussed for zinc and copper will raise the benchmark value from 67 and 7
micrograms per liter (mg/L) respectively to 126 and 10.5 mg/L. The attached table lists the "Calculated
Revised Stormwater Benchmark" values for several metals. Note that the table was published June 8,
2010. Bethany Georgoulias (919-807-6372) and Ken Pickle (919-807-6376) are the Raleigh, Central
Office, contacts that have the most up to date information regarding upcoming reviews/ updates to
benchmark values.
Ms. Herbert and Mr. Stepp stated that they were hopeful that the benchmark would be adjusted in the
near future but could not give a definite timeline. tentatively PiFejected that Dregs „ia Feyi5e metal
�enGhrna;k values by the end of the yeaf. The regularly scheduled Triannual Review for benchmark
concentrations is due this year but has been delayed due to the departmental re -organization as well
other conflicting circumstances_ This will be the forum to make these changes. Some public review may
be necessary and could delay implementation. More on that as the situation develops.
The Central office staff did review our proposed sampling and analysis plan. They may accept a fewer
le�,el of pi:ge€ less burdensome sampling plan to demonstrate that zinc and copper enter water from
sources other than industrial products. One option being discussed is to allow facilities to certify that no
raw materials contain zinc or copper (backed up with MSDSs and a letter describing individual activities
in the facility) and Minor testing_ of-- For fe+ example - roof runoff that proved provides evidence that
zinc and/or copper is eeetiributed contributing to stormwater from non -industrial sources could be
enough to F^l,W the hP_AGh., aF show that the subject facility has reasonably evaluated a benchmark
exceedance and will provide the regional office with the regulatory authority to relieve the facility from
the tiered resoponce as it relates to the benchmark in question,
For now, Ms. Herbert tells me that any facility that passes into the Tier II or Tier III permit stipulated
response pregFam and continues with the prescribed sampling/analyses and reporting requirements will
be considered in compliance with their stormwater permit.

Herbert, Laura C
From:
Fox, Tim
Sent:
Tuesday, August 27, 2013 4:11 PM
To:
Lisa Manning ([e-mail])
Cc:
Herbert, Laura C; Stepp, Jonathan
Subject:
Industrial Stormwater/Dave Steel.
Lisa,
r
As we discussed effective August 1" The Division of Energy, Mineral, and Land Resources (DEMLR) administers the
industrial
stormwater program.
We have discussed Dave Steel during this transition period. I wanted to give you contact information for future
correspondence.
Laura Herbert's contact info below. Also Jonathan Stepps contact is below who was at the site inspection with me. I
know that Jonathan called and spoke with Mr. Clovers regarding permit conditions.
DEMLR is communicating with our central office regarding,facilities exceeding zinc and copper benchmarks. The
additional data that has begin sent is in the file.
As long as facilities are Following the tiered response action in the permit they are not in violation.
If I can be of any help during this transition period let me know thanks for your understanding.
Tim
Laura Herbert, P.E
Regional Engineer
Division of Energy, Mineral, and Land Resources - Land Quality Section
NCDENR-Asheville Regional Office
2090 US Highway 70
Swannanoa, NC 28778
Tel:[phone] Fax:[phone]
htto://r)or-tal.ncdenr.ore/web/Ir
Jonathan Stepp—Jonathan.Stepp@ncdenr.,gnv .
North Carolina Dept. of Environment and Natur•6rR"rJ0tc6�-,-;; '
Asheville Regional Office = I— "` "
Division of Energy, Mineral, and Land Resources - Land Quality Section
2090 U.S. 70 Highway r
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Tire Fox - [e-mail]
North Carolina Dept. of Environment and Natural Resources
1

Asheville Regional Office
Division of Water Resources — Water Quality Programs
2090 U.S. 70 Highway
T-
Swannanoa, NC 28778
Tel: [phone] -'
Fax: [phone]
Notice: Email correspondence to and from this address may be subject to the NC Public Records Law and may be
disclosed to third parties.
i;
y
' rr
2

Dave Steel Co. 8/26/2013 Phone conversation with Rob Clowers
I spoke with Mr. Rob Clowers of Dave`s Steel about their ongoing efforts to address a benchmark
exceedance for zinc at the facility. Mr. Clowers stated that they are in the process of lining up
contractors to clean a drain that is located inside of one of their manufacturing areas. The drain has
several poor fitting covers that allow metal shavings and other debris inside this are to enter the drain.
The drain covers are going to be replaced by tighter fitting covers to prevent contamination in the
future. Additionally, Mr. Clowers is organizing employee training so that staff do not use the drains as a
waste disposal area while sweeping the floor. I encouraged Mr. Clowers to include these actions in his
SPPP as part of their tier 1 response.
Pisgah Environmental prepared a sampling plan for Dave Steel Company and has submitted the plan to
the North Carolina Department of Environment And Natural Resources Asheville Regional Office. The
plan has been reviewed by me and other department staff, including central office staff, and we are in
agreement that the plan is well crafted; however, the zinc benchmark exceedance that it addresses does
not warrant a study of this magnitude. I advised Mr. Clowers that Dave Steel Company should continue
through the tiered response as described in the general permit. I also told Mr. Clowers that Dave Steel
Company would remain in compliance as long as they followed the permit.

! NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Pat McCrory Thomas A. Reeder
Governor Acting Director
June 13, 2013
Dave Steel Company, Inc.
Attn: Rob Clowers, CSP
Environmental Health & Safety Director
P.O. Box 2630
40 Meadow Road
Asheville, NC
SUBJECT: NPDES Stormwater Permit Compliance Inspection
Dave Steel Company, Inc.
Permit No: NCG030265
Buncombe County
Dear Mr. Clowers:
John E. Skvaria, III
Secretary
This letter is in follow-up to the NPDES Stormwater Permit Compliance Inspection conducted on
May 23, 2013. The facility was found not to be in compliance with permit NCG030265.
Noncompliance is due to a benchmark exceedance for zinc that occurred during the 2013
semiannual stormwater sampling event.
Enclosed is a copy of the Compliance Inspection Report, which contains additional observations
and comments for your reference -
Please contact me at [phone] or Tim.Fox nncdenr.gov, if I can be of any further assistance.
Sincerely,
Tim Fox
Environmental Specialist
Surface Water Protection
Enclosure
cc: Lisa Manning, PE, LEED AP BD+C (e-copy)
Dan March — Pisgah Environmental Services, LLC (e-copy)
Central Files
Asheville Files
S:\.SWP\Buncombe\Stormw•aterlNCG03 Metal Fabrication0ave Sleel\CELgave Sleel.06-13-13.doc
t.oCation: 2090 U.S, Highway 70, 5wannanoa, North Carolina 28778 One
Phone: [phone] FAX: [phone] NorthCarofina
Internet: www.ncwaterquality.org An Equal Qpporlunity l Affirmative rmative Action Employer Li

The Dave Steel Company, Inc
June 13, 2013
Page 2 of 2
Picture # t 5/23/20t3 View of storm grate cover.
Picture #2 5I2M2013 V iew of SDO #2
Picture #3 5/23/2013 View of Storm System.

IT —
Dave Steel Company, Inc.
Steel Construction Since 1929
June 3, 2013
North Carolina Department of Environment and Natural Resou
Division of Water Quality
Mr. Chuck Cranford
2090 US Highway 70
Swannanoa, NC 28778
Re: Dave Steel Company, Inc.
40 Meadow Road
Asheville, NC 28802
Certificate of Coverage No. NCG030265
Zinc Sampling and Analysis Plan
Dear Mr. Cranford:
RECEIVED
J U N 5 2013
WWW
Bodke
Dave Steel Company, Inc. exceeded its zinc benchmark for outfalls SDOI and SD02 during
the first 2013 semiannual stormwater sampling event. At that time we initiated a Tier I
Response that included an examination of our activities to find potential sources of zinc at the
site. In addition, we contacted the NC DENR Division of Water Quality (DWQ) staff to
discuss our options. Our initial response is that zinc enters stormwater either from off -site
upstream source(s) or from non -industrial sources on our site. None of the iron used in our
metal fabrication shop is galvanized; nor do we apply zinc to our products either through
painting or galvanizing.
Conversations with Tim Fox and Susan Wilson of DWQ identified a strategy to come into
compliance with the zinc benchmark. We propose to quantify non -industrial zinc sources and
subtract those contribution(s) from our respective outfall reporting. Non -industrial zinc
sources include contributions from off -site sources and from infrastructure sources (roofs,
downspouts, siding, and fences). The following document presents a Zinc Sampling and
Analysis Plan to implement our zinc control strategy
BACKGROUND
First 2013 Semiannual Stormwater Results
Samples were collected on January 30, 2013, during a 'Representative Storm Event' from the
two facility outfalls.
Outfall I (SDO1) had a zinc discharge concentration of 0.133 milligrams per liter [mg/L],
which is above the benchmark concentration of 0.067 mg/L. Outfall 2 (SD02) had a zinc
discharge concentration 0.071 mg/L, which is also above the benchmark concentration.

tiffg5%''aLC,cu CV;.T-L bw$t4wVq=
1)(91, - 2 5013
HECGIA-eD

Off Site Zinc Sources
Stormwater enters the Dave Steel site from Asheville -Buncombe Technical Community
College. The sources of stormwater include parking areas below the Rhododendron Building
that are controlled by a detention pond. The pond discharge is piped across Dave Steel
property and combined with on -site stormwater just upstream of SD02.
On -Site Zinc Sources
Stormwater picks up zinc from galvanized roofing materials that constitute most of the 78,218
square foot main metal fabrication building. Most of the roofs drain to galvanized gutters and
downspouts and are piped directly to the stormwater conveyance/discharge system (much of
which is also galvanized).
Galvanized fencing may also contribute zinc to stormwater discharges. Most fencing is on
property boundaries and is situated in grassy areas that should limit zinc transport to
impervious surfaces and ultimately to the stormwater conveyance/discharge system.
Ancillary equipment has zinc components that drain to the stormwater conveyance/discharge
system. These equipment include air pollution control devices, roof mounted air conditioning
units, and flashin .
Truck tires contain about one (1) percent zinc. Ali of the steel beams delivered to or
transported from the site are trucked. The relatively small property requires that trucks
maneuver with tight turning radii. The constant moving and wheel turning produces zinc -
containing residual.
Forklifts have tires that contain zinc and also use hydraulic oil that contains up to 0.1 percent
zinc. Most outside areas have relatively few of spots.
Proposed Zinc Sampling and Analysis Strategy
We plan to evaluate whether our elevated zinc stormwater discharges are due to off -site
sources. We also plan to evaluate whether non -industrial sources not under our operational
control on our site contributed to the elevated zinc stormwater discharges. In particular, we
will evaluate galvanized building materials and drain pipes. Table 1 lists sampling locations.
Figure I shows sampling locations.
Ultimately, we plan to make a case to DWQ staff that off -site zinc and on -site zinc from non-
industrial sources should be subtracted from our stormwater zinc discharge totals.
Dave Steel Company — Zinc Sampling and Analysis Plan 2

Calculations
Off -site zinc mass and on -site zinc mass from non -industrial sources (when measureable) will
be subtracted from the stormwater outfall concentration by the following mass balance
calculation. This equation assumes the volume of stormwater (Q, liters) times the
concentration of zinc in the stormwater (C, milligrams per liter) yields the mass of zinc for
each of several sources.
Q5C5 = QOCO + QICI + Q2C2 + Q3C3+ Q4C4
Where: QOCO = Off -site Zinc Contribution
QICI = Roof Zinc Contribution
Q2C2 = Tires
Q3C3 = Hydraulic fluid
Q4C4 = Other Zinc Sources
Q5C5 = Stormwater Discharge Outlet 1 or 2
Re -arranging the equation yields the corrected zinc stormwater discharge outfali
concentration. The example below only addresses a correction for off -site and roof zinc
contributions. The sampling strategy may be able to parse zinc concentration from tire,
hydraulic fluid, and other sources from the site.
Q5C5 - QOCO - QICI = Q2C2 + Q3C3 + Q4C4
The zinc amounts from each of the above sources may not be discernable due to uncertainty
within the stormwater collection system's orientation and connections. However, every effort
will be made to identify specific sources when possible. We expect this sampling and
analysis activity to yield information that will substantiate that the zinc benchmark
exceedances seen at our facility are not due to any of our industrial activities. We will send
DWQ a letter report upon completion of our Zinc Sampling and Analysis study.
Please review this Zinc Sampling and Analysis Plan and provide comments on the location
and number of sampling points, the analytical methods, and the calculation of zinc mass
discharged in stormwater from our facility. Please contact me with comments or questions.
Sincerely,
Dave Steel Company, Inc.
Rob Mowers
Environmental Health & Safety Director
828-252-2771
Dave Steel Company —.Zinc Sampling and Analysis Plan 3

Table 1. Dave Steel Zinc Sampling and Analysis Matrix
Location
Type
Description
Sampling
Preservative
Analysis
1
Stormwater Pipe
7472 — From 7420
Grab
HNO3
Zinc by ICP2
2
7472 — From Bay 4 Roof
3
7472 — From Admin Building Roof
4
7472 — From Other Pipe
5
7472 — Discharge to Swannanoa River — A
6
7470 — Discharge to Swannanoa River — B
7
7510 — From 7501
8
7510 — From 7502
9
7510 — From Admin Building Roof
10
7510 — From Bay 4 Roof
11
7501 — From En 1/Sales Building Roof
12
7502 — From Sheetflow into Drop Inlet
13
7483 — Discharge to Swannanoa River — A
14
13983 — Discharge to Swannanoa River —13
15
12566 — From AB -Tech
16
Roof Downspout
From Bay 6 Roof
17
From Bay 4 Roof
18
From Bay 4 Roof
19
From Bay 6 Roof
20
From Bay 2 Roof
21
From Bay I Roof
22
From Bay 1 Roof
23
From Bay 3 Roof
24
From Bay 3 Roof
25
From Bay 2 Roof
rThe two `B' locations represent stormwater access points directly on the property line rather than inside the active yard.
Z EPA Method 200.7 —"Determination of Metals and Trace Elements in Water and Wastes by Inductively Coupled Plasma -Atomic Emissions Spectroscopy"
Dave Steel Company — Zinc Sampling and Analysis Plan 4

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Permit: NCG030265
SOC:
County: Buncombe
Region: Asheville
Compliance Inspection Report
Effective: 11/01/12 Expiration: 10/31/17 owner: Dave Steel Company
Effective: Expiration: Facility: Dave Steel Company
40 Meadow Rd
Contact Person: Jeffrey E Dave
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Asheville NC 28803
Title: Phone: [phone]
Certification: Phone:
Inspection Date: 05/23/2013 Entry Time: 01:00 PM Exit Time: 03:00 PM
Primary Inspector: Timothy R Fox Phone: [phone]
Secondary Inspector(s):
Jonathan Stepp Phone:
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Metal Fabrication Stormwater Discharge COC
Facility Status: 0 Compliant ■ Not Compliant
Question Areas:
■ Storm Water
(See attachment summary)
Page: 1

Permit: NCGO30265 Owner -Facility: Dave Steel Company
Inspection Date: 0512312013 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Tim Fox and Jonathan Stepp with The Asheville Regional Office, Division of Water Quality, toured the facility. Rob
Clowers, CSP Environmental Health and Safety Director, with Dave Steel Company, Lisa Manning, PE (Consultant) and
Dan March with Pisgah Environmental Services, were present at the time of inspection.
The Dave Steel Company contacted our office to start a conversation regarding evaluating a strategy to address
compliance concerning the zinc benchmark limits in the new permit. Dave Steel Company has been proactive in
evaluating possible sources of zinc concentrations at the facility.
Dave Steel exceeded its zinc benchmark for outfalls SDO1 and SD02 during the first 2013 semiannual stormwater
sampling event.
Record keeping was in order and provided during the inspection.
The facility intiated a Tier 1 response and has evaluated potential zinc sources at the site.
Off -site sources of zinc include the Asheville -Buncombe Technical Community College. Parking areas above the facility
drain onto Dave Steel property_
The on -site zinc sources at the facility include; galvanized roofing, fencing, gutters and drain pipes.
There is also fork lift and truck transport activity at the facility. This activity was minimal and there were no major signs of
hydralic oil residue deposits.
Dave Steel is doing a good job evaluating the possible causes of zinc exceedances.
The one area that needs correction that was discovered during the inspection included the stormwater grates inside the
south side of the metal fabrication building. These covers need to be evaluated and corrected for any possible source of
contamination, One other improvement discussed was an improved condition or method to access S002.
The inspection ended with a discussion regarding zinc evaluation, tiered responses, and future correspondence. Dave
Steel plans to implement a zinc strategy which will include additional sampling which will be shared with our regional office
for evaluation and feedback.
Page: 2

Permit: NCG030265 Owner -Facility: Dave Steel Company
Inspection Date: 05/23/2013 Inspection Type: Compliance Evaluation
Stormwater Pollution Prevention Plan
Reason for Visit: Routine
Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan?
■
Q
n
0
# Does the Plan include a General Location (USGS) map?
■
n
Q
n
# Does the Plan include a "Narrative Description of Practices"?
■
Cl
0
0
# Does the Plan include a detailed site map including outfall locations and drainage areas?
■
Q
❑
D
# Does the Plan include a list of significant spills occurring during the past 3 years?
e
n
D
D
# Has the facility evaluated feasible alternatives to current practices?
■
n
0
n
# Does the facility provide all necessary secondary containment?
■
n
n
n
# Does the Plan include a BMP summary?
■
# Does the Plan include a Spill Prevention and Response Plan (Si
■
0
El
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
■
rl
Q
# Does the facility provide and document Employee Training?
■
❑
0
n
# Does the Plan include a list of Responsible Party(s)?
■
c
-
o
# Is the Plan reviewed and updated annually?
■
❑
0
0
# Does the Plan include a Stormwater Facility Inspection Program?
■
0
0
Has the Stormwater Pollution Prevention Plan been implemented?
■
0
0
Q
Comment: Continue appropriate stormwater yearly training and documentation.
Qualitative Monitoring
Yes No
NA
NE
Has the facility conducted its Qualitative Monitoring semi-annually?
o
0
0
n
Comment:
Analytical Monitoring]
Yes No
NA
NE
Has the facility conducted its Analytical monitoring?
■
❑
0
❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
[1
0
■
0
Comment: The facility exceeded Zinc benchmarks for Outfalls SD01 and SD02
during the first 2013 semiannual stormwater sampling event.
Tier 1 response has been intiated.
Permit and Outfalls
Yes No
NA
NE
# Is a copy of the Permit and the Certificate of Coverage available at the site?
■
0
❑
# Were all outfalls observed during the inspection?
■
0
0
Q
# If the facility has representative outfall status, is it properly documented by the Division?
f_1
0
■
❑
# Has the facility evaluated all illicit (non stormwater) discharges?
■
n
Cl
n
Page: 3

Permit: NCG030265 Owner - facility: Dave Steel Company
Inspection Date: 0512312013 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Comment: Please correct storm drain grates inside the south side of the building
within 90 days of receiving this inspection report.
Page: 4

Fox, Tim
From: Lisa Manning <[e-mail]>
Sent: Monday, June 03, 2013 4:41 PM
To: Fox, Tim
Cc: Daniel March
Subject: Follow up from inspection/meeting on May 23, 2013
Hi Tim,
Thank you for the meeting we had at Dave Steel on May 23, 2013, We look forward to receiving your inspection report.
wanted to touch base with you about a couple of items...
• We are in the process of working on a zinc sampling and analysis plan for the facility, and we hope to have it to
you this week.
• Were you able to confirm what we would happen with any data collected? For example, if we collect additional
samples, must they be submitted to DENR? Also, if we have any exceedances, will we be automatically kicked
into Tier 2? Or, if we have no exceedances, will we be considered out of Tier 1 ?
• You mentioned an interoffice memo regarding "No Exposure" certification. Can you please pass that along to me
when you have a chance?
• 1 mentioned the CRONOS database to you (in addition to Weather Underground) as a potential source for rainfall
data. Can you let me know what you think about it? With Weather Underground, you can get hourly totals;
however, it collects data from the airport. With CRONOS, there are stations closer to Dave Steel, but there are
only daily totals recorded. Here is a link to the :^rebsite... http://www.nc-climate.ncsu.edu/cronos/index.php and
we could possibly use site # NC-BC-5 (http://nc-climate.ncsu.edu/cronos?station=NC-BC-5&temporal=daily)
which is 2 miles from Dave Steel. Please let me know what you think about these sites.
I look forward to hearing back from you.
Thank you,
Lisa Manning, PE, LEED AP BD+C

pF`WAfF,q Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
ft "Asheville'RegionalOffice
SURFACE WATER PROTECTION
CERTIFIED MAIL January 29, 2007
RETURN RECEIPT REQUESTED
7006 2150 0005 2459 6769
Mr. Jeffrey Dave
Dave Steel Company
P.O. Box 2630
Asheville, NC 28802
SUBJECT: NOTICE OF VIOLATION
NOV-2007-PC-0053
Compliance Evaluation Inspection
Dave Steel Company - 40 Meadow Rd.
Permit Number NCG030265
Buncombe County
Dear Mr. Dave:
Enclosed please find a copy of the Compliance Evaluation Inspection report from the inspection
conducted on January 24, 2007 by Ms. Laurie Moorhead of the Asheville Regional Office. Mr. Claude
Greene and Ms. Ellen Steele pleasantly greeted Ms. Moorhead and reviewed permit documents, and Mr.
Greene led Ms. Moorhead through a site visit. Several permit conditions are being met at the Meadow
Road location; however, deficiencies noted result in violations of permit NCG030265.
Permit NCG030265 requires that a stormwater management plan be prepared and maintained by
the permittee. While a consultant did prepare a plan several years ago, it is in need of review and
update. The site map needs revision to illustrate the correct location of all stormwater outfalls. The
permit also requires visual and analytical monitoring of the stormwater that exits the site. A description
of the monitoring requirements as well as the stormwater management plan contents is contained in Part
II pages 1 through 7 of the permit.
Please refer to the enclosed inspection report for additional findings and recommendations. A
follow up inspection may be scheduled to review your stormwater management plan and monitoring data
in about 6 months. In the meantime, if you or Mr. Greene have any questions related to this inspection
or to interpretation of permit NCG030265 requirements, please call Ms. Moorhead at [phone].
Sincerely, (i ,
Lai �r�Cr2icC�
Roger C. Edwards, Regional Supervisor
Enclosure Surface Water Protection
Asheville Regional Office
cc- Claude Greene, Dave Steel Company
Danny Smith — NPS ACO Unit One
ARO Files
NorthCarolina Central Fifes lUttzrally
2090 US Hwy 70, Swannanoa, NC 28778 828-296-4500 Fax [phone] Customer Service 877-623-6748

■ Complete items 1, 2, and 3. Also complete A. Signature_
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JEFFREY DAVE
DAVE STEEL COMPANY
POST OFFICE BOX 2630
ASHEVILLE NC 28802
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Compliance Inspection Report
Permit: NCG030265 Effective: 09/01/02 Expiration: 08/31/07
SOC: Effective: Expiration:
County: Buncombe
Region: Asheville
Contact Person: Jeffrey E Dave
Directions to Facility:
Primary ORC: Certification:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Owner: Dave Steel Company
Facility: Dave Steel Company
40 Meadow Rd
Asheville NC 28803
Phone: [phone]
Phone:
Inspection Date: 01/2412007 Entry Time: 08:30 AM Exit Time: 09:30 AM
f
Primary Inspector: Laurie L Moorhead, /}�� /l Phone: [phone]
Secondary Inspector(s): , J rX �c�O�e7 "% Exi.4664
Reason for Inspection: Routine Inspection Type: Stormwater
Permit Inspection Type: Metal Fabrication Stormwater Discharge COC
Facility Status: ❑ Compliant ■ Not Compliant
Question Areas:
■ Storm Water
(See attachment summary)
Page: 1

Permit: NCG430265 . Owner - Facility: Dave Steel Cornpany
Inspection Date: 01/24/2007 Inspection Type: Stormwater Reason forVlsit: Routine
Inspection Summary:
The inspector met Claude Greene, Safety Director and employee responsible for implementation of the stormwater
permit, and Ellen Steele, Human Resources Director, to review the stormwater management plan and all accompanying
documentation. Review of said documents revealed a properly prepared plan that contains all elements specified in the
permit. However, a site inspection indicated the following deficiencies;
1) No visual or analytical sampling has been conducted since 2002. Poor communication between exiting staff has
resulted in a failure to conduct required activities. Mr. Green and Ms. Steele were both directed to read the permit and the
current stormwater management plan to become familiar with responsibilities of the permit, Mr. Greene was directed to
initiate both visual sampling during a rain event and analytical sampling during a representative rainfall event as described
in the permit.
2) While the current stormwater management plan is complete in that it addresses all components of the permit, the site
map is inaccurate. For example, the site map indicates 3 outfalls on site, when a walk-through of the property revealed
13 outfalls. Mr. Green was directed to update the site map as well as the stormwater management plan as needed.
3) No annual training as required by the permit has been conducted since 2002. Mr. Greene and Ms. Steele were both
instructed as to the necessity of training, training contents and required documentation of such.
4)During the inspection, the stormdrain located at the west end of the bolt room had sand bags, one of which was split
open, directly adjacent to the drain such that during a rainfall event, sand can enter the drain, Mr. Greene was directed to
remove the sand bags from proximity of the stormdrain.
5)During the inspection, another stormdrain located by the maintenance trailer in back of the bolt room was in need of
some type of filtering structure. Mr. Greene was directed to install either a gravel envelope underlain by filter fabric or a
silt fence to protect the stormdrain from sediment entering the drain during a storm event.
The Meadows Drive location has a very good start at coming into compliance in that the stormwater management plan
has already been prepared. Review and update of the plan and site map should occur as soon as the 2 stormdrains
mentioned in 4) and 5) are attended. Additionally, visual and analytical monitoring of all outfalls should be initiated in the
spring of this year so that data will be available for permit renewal.
Page: 2

Permit: NGG030265 Owner -Facility: Dave Steel Company
Inspection Hate: 01/24/2007 Inspection Type: Stormwater Reason for Visit: Routine
Stonnwater Pollution Prevention Plan Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan? ® ❑ ❑ ❑
# Does the Plan include a General Location (USGS) map?
■
❑
❑
11
# Does the Plan include a "Narrative Description of Practices"?
■
n
D
D
# Does the Plan include a detailed site map including outfall locations and drainage areas?
®
D
D
D
# Does the Plan include a list of significant spills occurring during the past 3 years?
■
D
# Has the facility evaluated feasible alternatives to current practices?
❑
®
El
Q
# Does the facility provide all necessary secondary containment?
D
D
D
# Does the Plan include a BMP summary?
®❑
❑
D
# Does the Plan include a Spili Prevention and Response Plan (SPRP)?
■
D
0
Cl
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
■
D
D
# Does the facility provide and document Employee Training?
D
®
Cl
0
# floes the Plan include a list of Responsible Party(s)?
a
0
❑
D
# Is the Plan reviewed and updated annually?
❑
0
0
# Does the Plan include a Stormwater Facility Inspection Program?
®
D
n
Q
Has the Stormwater Pollution Prevention Plan been implemented?
Q
®
❑
D
Comment: The facility has a good plan, but it has not been implemented since 2002
due to staff turnover of responsible person in charge. Monitoring and training has not
been implemented since 2002.
Qualitative Monitoring
Yes
No
NA
NE
Has the facility conducted its Qualitative Monitoring semi-annually?
®0
D
Comment: Visual monitoring has not been conducted since 2002 due to turnover of
responsible party.
Analytical Monitoring
Yes
No
NA
NE
Has the facility conducted its Analytical monitoring?
■
D
# Has tine facility conducted its Analytical monitoring from Vehicle Maintenance areas?
D
❑
m
D
Comment: No vehicle maintenance is conducted on -site. Analytical samples have not
been collected since 2002.
Permit and Outfalls
Yes
No
NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site?
W
0
0
D
# Were ail outfalls observed during the inspection?
■
D
D
Q
# If the facility has representative outfall status, is it properly documented by the Division?
❑
Q
■
D
Page: 3

Permit: NCG030265 Owner - Facility: Dave Steel Company
Inspection !late: 0112412007 Inspection Type: Stormwater Reason for Visit: Routine
# Has the facility evaluated all illicit (non stormwater) discharges? ❑ ■ 0
Comment: The site map is inaccurate, indicating that there are 3 outfalls when 13
were observed. Recommendations were made to address potential pollution at outfall
at west end of bolt room and at maintenance trailer in back of bolt room.
Recommended that site map be updated and that visual and analytical monitoring be
conducted at all outfalls.
Page: 4

SwSGStormwater Services Group, LLC
_ 8916 Oregon Inlet Court
Raleigh, North Carolina 27603
February 15, 2007 ?
Mr. Roger C. Edwards
NC Division of Water Quality (ARO)
2000 US Hwy 70
Swannanoa NC 28773
D u
FEB 2 0 2007 01
WATER QUALITY SECTION
ASHEVILLE REGiON.AL OFFICE
L
Phone: [phone]
Fax: [phone]
RE: Dave Steel Co (Meadow Rd facility) — NPDES General Permit NCG030265
NOV-2007-PC-0053
Mr. Edwards:
Dave Steel Company has contracted with my firm to provide a portion of the necessary services
to satisfy the compliance issues described in your NOV dated January 29, 2007. Specifically, we
are contracted to provide an employee training class and to perform analytical monitoring at the
representative stormwater discharge outfalls.
Per the numbered items in your Inspection Summary:
1. We performed analytical monitoring in 2002. The sample collected on January 19, 2002 was
the sample required during the fifth year of the 1997-2002 Permit. The sample collected
November 11, 2002 was the sample required for the first year of the 2002-2007 Permit.
Since all parameters in the November 2002 event were under the cut-off limits, no additional
analytical monitoring is required until this year. Please remove this item as a violation.
We also performed visual observations in January and November 2002. If you need copies
of these reports, please let us know. We were not contracted to perform outfall monitoring in
subsequent years.
A petition letter requesting representative outfall status for SDO-001 was sent to Bradley
Bennett on March 27, 2002. Since no response was received, we assume the petition is
approved.
We are under contract to perform analytical outfall monitoring this Spring. We anticipate
that the samples will be collected no later than March 31, 2007. Reports will be submitted as
required by the Permit. Analytical monitoring performed this Spring will satisfy the Permit
requirement for fifth year monitoring.
2. We disagree that the site map is inaccurate as to the number of outfalls. There 'ire three
industrial outfalls (see Map 2) at this facility, not 13 as indicated by Laurie Moorhead. For
purposes of the Permit, an outfall is defined as the point where the facility zsr runoff
discharges AS A POINT SOURCE into waters of the State or leaves the facility's prgperty.

NCDWQ, Page 2
February 15, 2007
sWit SG
Internal catch basins that are part of a network of pipes are not considered outfalls unless the
catch basin drops into a culvert that is carrying waters of the State (i.e., a stream). We
designated two catch basins as outfalls FOR MONITORING PURPOSES only because the
catch basins are the most -downstream accessible point in the internal pipe network.
For example, the SDO-001 monitoring point is the pipe that exits C13410. SDO-001 consists
of CB#10 through C13414, MH#3, M14#4, and the connecting pipes. Manholes with solid
lids are not considered outfall points because surface runoff does not flow through solid lids
and enter the manhole. CB#9 and CB#8 are in the public right-of-way, but could be
considered as alternate monitoring points for SDO-001 if CB#10 is inaccessible.
The SDO-003 monitoring point is the pipe that exits CB930 and enters the culvert that is
carrying a "waters of the State" stream. Since the downstream end of the SDO-003 pipe is
inaccessible, the monitoring is performed inside CB#30.
If you believe there are 13 outfalls, please indicate their locations on the enclosed Map 2 and
call to discuss.
3. We provided a Permit & SViWPPP Compliance Workshop to facility staff on March 25, 2002.
We were not contracted to provide training in subsequent years. We are providing another
workshop on February 19, 2007. In this workshop, we will train the staff to perform the
semi-annual inspections and ' the semi-annual wet weather qualitative outfall monitoring.
After the workshop, the Permittee may decide to contract with us to provide semi-annual site
inspections and semi-annual qualitative monitoring. Regardless, these tasks will be done.
4. We were not aware of a storm drain located in the west end of the bolt room. We will
inspect this drain on February 19 and modify Map 2 as necessary.
5. We were not aware of a storm drain located by the maintenance trailer. We will inspect this
drain on February 19 and modify Map 2 as necessary.
We have recommended to the Permittee that the SWPPP should be updated later this Fall after
the General Permit NCG030000 is re -issued. We will also look at the two drains indicated in
Items 4 and 5 above to determine if there is a better or alternate BMP that can be implemented.
If you should have any questions, please do not hesitate to call us.
Sincerely,
S M ATER ERVICEs GROUP, LLC
es D. Frei
Senior Project Manager
cc: Claude Green (Dave Steel Co)

.1
Michael F. Easley, Governor
William G. Ross Jr., secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
March 31, 2006
Dave Steel Company
40 Meadow Rd
Asheville, NG 28803
Subject: - General Stormwater Permit Inspections
Dave Steel Company
Permit No. NCG030265
Buncombe County
Dear Sir or Madam:
Your facility holds a general permit from the North Carolina Division of Water Quality to
discharge stormwater associated with industrial activities performed at your facility. Please be
advised that the Asheville Regional, Office will be performing NPDES stormwater inspections
sometime in the hear future.
If this office has not previously inspected your facility, you should be prepared to demonstrate
compliance with all terms and conditions included in the permit. Specifically, we will be
evaluating the following: your stormwater pollution prevention plan, stormwater outfall
locations, qualitative and analytical monitoring data and any other activities required by your
permit. Please note that any data reported to the State must be analyzed by a facility that has a
North Carolina laboratory certification, either as a full laboratory or as a facility certified to
perform on -site field testing. If you have any questions regarding the generation of your
facility's data, please feel free to call Gary Francies at [phone],
Copies of the general permits and accompanying documents can be accessed from the following
webpage: http://iviviv.ncit,atergzsality.org/sat/Forms_Documents.htni#stormtvaterGP.
If you have any questions, please contact me in the Asheville Regional Office at [phone].
cc: NPS Compliance & Assistance Oversight Unit
SWP-Central Files
ARO Files
Sincerely,
Qj�1 0_\_�
Roy Davis
Environmental Engineer
NP-hCarolina
laturally
North Carolina Division of Water Quality 2090 US, Hwy 70
Internet: http:llwww.ntwaterquality.orgl
An Equal OpportunitylAffirmative Action Employer
Swannanoa, NC 28778 Phone [phone] Fax [phone]

i
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Imp = 70% Alternate SDO-N
Monitoring Point /I
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Map 2 - Facility Site Map
Dave Steel Company
40 Meadow Rd.
NPDES Permit NCG030265
SWSG Stormwater Services Group, LLC
8916 Oregon Inlet Ct Raleigh, NC (919) 661a"54