WQ0006060_Staff Report_20191219

State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
To: ❑ NPDES Unit ® Non -Discharge Unit Application No.: WQ0006060
Attn: [e-mail] Facility name: Gerdau Ameristeel US —Charlotte Steel Mill CLRS
County: Mecklenburg
From: [e-mail]
Mooresville Regional Office
Note: This form has been adapted from the non -discharge fg acili , staff report to document the review of both non -
discharge and NPDES permit applications and/or renewals. Please complete all sections as they are applicable.
I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No
a. Date of site visit: 12-09-2019
b. Site visit conducted by: Maria Schutte
c. Inspection report attached? ❑ Yes or ® No BIMS is updated.
d. Person contacted: Bob Churchill and their contact information: [phone] (cell) or
bob.churchill a,gerdau.com.
e. Driving directions: From the MRO travel to I-77 South
onto Lakeside Rd. Facility is on the left.
2. Discharge Point(s): NA
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters: NA
Classification:
River Basin and Sub -basin No.
Take the W.T. Harris Blvd Exit & turn left: Turn left
Describe receiving stream features and pertinent downstream uses:
11. PROPOSED FACILITIES: NEW APPLICATIONS
1. Facility Classification: (Please attach completed rating sheet to be attached to issued permit)
Proposed flow:
Current permitted flow:
2. Are the new treatment facilities adequate for the type of waste and disposal system? ❑ Yes or ❑ No
If no, explain:
3. Are site conditions (soils, depth to water table, etc.) consistent with the submitted reports? ❑ Yes ❑ No ❑ N/A
If no, please explain:
4. Do the plans and site map represent the actual site (property lines, wells, etc.)? ❑ Yes ❑ No ❑ N/A
If no, please explain:
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5. Is the proposed residuals management plan adequate? ❑ Yes ❑ No ❑ N/A
If no, please explain:
6. Are the proposed application rates (e.g., hydraulic, nutrient) acceptable? ❑ Yes ❑ No ❑ N/A
If no, please explain:
7. Are there any setback conflicts for proposed treatment, storage and disposal sites? ❑ Yes or ❑ No
If yes, attach a map showing conflict areas.
8. Is the proposed or existing groundwater monitoring program adequate? ❑ Yes ❑ No ❑ N/A
If no, explain and recommend any changes to the groundwater monitoring program:
9. For residuals, will seasonal or other restrictions be required? ❑ Yes ❑ No ❑ N/A
If yes, attach list of sites with restrictions (Certification B)
Describe the residuals handling and utilization scheme:
10. Possible toxic impacts to surface waters:
11. Pretreatment Program (POTWs only):
III. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ❑ Yes ❑ No ® N/A
ORC: Certificate #: Backup ORC: Certificate #:
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes or ❑ No
If no, please explain:
Description of existing facilities: There are two recycled water systems for process cooling water. The facility
collects all water possible for use in the cooling loops. This includes storm water, an on -site irrigation well, the
leachate water from their closed landfill & formerly the remediated water from a SVE system related to an above
ground storage tank incident. The SVE system is no longer required by DWM-UST and planned for well
abandonment, per discussion with Mr. Churchill and letter from DWM-UST.
Proposed flow:
Current permitted flow:
Explain anything observed during the site visit that needs to be addressed by the permit, or that may be important
for the permit writer to know (i.e., equipment condition, function, maintenance, a change in facility ownership,
etc.)
3. Are the site conditions (e.g., soils, topography, depth to water table, etc.) maintained appropriately and adequately
assimilating the waste? ❑ Yes or ❑ No NA- There is no application associated with this closed loop
recycle system.
If no, please explain:
4. Has the site changed in any way that may affect the permit (e.g., drainage added, new wells inside the compliance
boundary, new development, etc.)? ❑ Yes or ® No ; MRO staff recommends keening the Remediated water
from the SVE system in the permit language, until the permittee can prove it is disconnected via the proposed
system well abandonments.
If yes, please explain:
5. Is the residuals management plan adequate? ® Yes or ❑ No
If no, please explain: Oil from the oil water separators is contained in site oil drums until collected b, Safe
Kleen for proper disposal. And the Mill Scale is collected and managed by TMS (Tube City and International
Mill Services) an on -site contactor who markets product for reuse.
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ❑ Yes or ❑ No ® N/A
If no, please explain:
7. Is the existing groundwater monitoring program adequate? ❑ Yes ❑ No ® N/A There is no
groundwater monitoring required because of this Kermit. The AST-SVE system was only connected because the
FORM: WQROSSR 04-14 Page 2 of 4

permittee could utilize the remediated water for cooling
If no, explain and recommend any changes to the groundwater monitoring program:
8. Are there any setback conflicts for existing treatment, storage and disposal sites? ❑ Yes or ® No
If yes, attach a map showing conflict areas.
9. Is the description of the facilities as written in the existing permit correct? ® Yes or ❑ No
If no, please explain:
10. Were monitoring wells properly constructed and located? ❑ Yes ❑ No ® N/A
If no, please explain:
I t . Are the monitoring well coordinates correct in BIMS? ❑ Yes ❑ No ❑ N/A
If no, please complete the following (expand table if necessary):
Monitoring Well
Latitude
Longitude
O l 11
O / 11
O l 11
O / 11
O l 11
O / //
O / //
O / //
O / //
O / //
12. Has a review of all self -monitoring data been conducted (e.g., DMR, NDMR, NDAR, GW)? ❑ Yes or ❑ No
Please summarize any findings resulting from this review: NA — there are no analytical requirements for this
permit.
Provide input to help the permit writer evaluate any requests for reduced monitoring, if applicable.
13. Are there any permit changes needed in order to address ongoing BIMS violations? ❑ Yes or ® No
If yes, please explain:
14. Check all that apply:
® No compliance issues ❑ Current enforcement action(s) ❑ Currently under JOC
❑ Notice(s) of violation ❑ Currently under SOC ❑ Currently under moratorium
Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.)
If the facility has had compliance problems during the permit cycle, please explain the status. Has the RO been
working with the Permittee? Is a solution underway or in place?
Have all compliance dates/conditions in the existing permit been satisfied? ® Yes ❑ No ❑ N/A
If no, please explain:
Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes ®No❑N/A
If yes, please explain:
15. Possible toxic impacts to surface waters: Unlikely. but possible via overflow to storm water ponds.
16. Pretreatment Program (POTWs only):
IV. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ® No
If yes, please explain:
2. List any items that you would like the NPDES Unit or Non -Discharge Unit Central Office to obtain through an
additional information request:
Item Reason
FORM: WQROSSR 04-14 Page 3 of 4

3. List specific permit conditions recommended to be removed from the permit when issued:
Condition Reason
4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition
Reason
Highlight freeboard
documentation and water
level gauge requirements
for both recycle ponds in
Assume this language will be added to the permit as it was with a recent MRO
the cover letter, with 6
Recycle permit renewal.
month (?) window to install
gauges.
5. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office
❑ Hold, pending review of draft permit by regional office
❑ Issue upon receipt of needed additional information
® Issue
❑ Deny (Please state reasons: )
6. Signature of report preparer:
Signature of regional supervisor:
Date: 12.19.19
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
None.
—DocuSigned by:
F161 FB69A2D84A3...
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