NCS000304_Gerdau - Facility Cover Letter and Inspection_20171114

Charlotte -Mecklenburg
STORM
WATER
Services
November 14, 2017
Robert Churchill, Safety & Environmental Manager
Gerdau Long Steel North America Charlotte Mill
6601 Lakeview Road
Charlotte, NC 28269
Subject: Industrial Facility Inspection
Gerdau Ameristeel US, Inc.
Dear Mr. Churchill:
2145 Suttle Avenue
Charlotte, NC 28208-5237
On October 23, 2017, Matthew Storosh, Chad Broadway and Kristen O'Reilly of
Charlotte -Mecklenburg Storm Water Services (CMSWS) conducted an inspection of the above
referenced facility as a requirement of the City of Charlotte's NPDES Permit, NCS000240, Part II
Section H. Inspection authority is granted by Charlotte City Code Chapter 18, Article III, Section
18-82. At the time of inspection, the facility was observed to be in compliance with the City of
Charlotte Storm Water Pollution Control Ordinance.
The inspection was also conducted as part of a cooperative working agreement between
Mecklenburg County and the North Carolina Department of Environmental Quality (NCDEQ) —
Division of Energy, Mineral and Land Resources (DEMLR). NCDEQ — DEMLR has been copied
on this report and made aware of the following observations regarding the facility's NPDES
stormwater permit:
1) Stormwater Pollution Prevention Plan (SPPP)
A Stormwater Pollution Prevention Plan (SPPP) has been developed, recorded, and implemented.
However, several components were missing from the SPPP that are required under NPDES
Individual Permit NCS00034. The facility's SPPP should indicate the year the spill reports are
for, records of annual non-stormwater discharge evaluation of outfalls forms, and secondary
containment discharge log forms that speck the location of the discharge.
2) Qualitative Monitoring
Qualitative monitoring has been conducted and recorded.
3) Analytical Monitoring
Analytical monitoring has been conducted and recorded.
•
To report pollution or drainage problems, call: 311
http://stormwater.charmeck.org
Ct1AR1,(Yr,rr. a.

Robert Churchill
Page 2
November 14, 2017
Thank you for the assistance and cooperation with the site inspection. The attached
report provides details about inspection observations and should be self-explanatory. Please
contact me at [phone] if you have any questions or need additional information. For
questions specifically regarding your NPDES stormwater permit, please contact James Moore
with NCDEQ — DEMLR at [phone].
Sincerely,
Matthew Storosh
Environmental Specialist
Charlotte -Mecklenburg Storm Water Services
cc: Kristen O'Reilly, Charlotte Storm Water Services
James Moore, NCDEQ — DEMLR
Attachment

Cl►arl°Ue Meck/emurg 2 1 4 5 Suttle Avenue
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_ "-NORM Charlotte, NC 28208
WATER Facility Inspection
services --�
Facility Name: Gerdau Ameristeel Inspection #: 33029
Contact: Robert Churchill, Safety & Environmental Manager Permit #: NCS000304
Inspector: MatthewStorosh Receiving Stream: Long Creek
Inspection Date: 10/23/2017 Entry Time: 9:30 am Exit Time: 1:00 pm SIC #:
SUMMAR
Facility Description: Gerdau Ameristeel is located at 6601 Lakeview Road on approximately 106 acres. Gerdau
Ameristeel is a steel manufacturer. This facility mills steel scraps into billets through the addition of alloys, carbon and
lime for off-site sale and conducts on-site bar production for off-site sales.
File Review/History: Gerdau Ameristeel was previously inspected by Charlotte -Mecklenburg Storm Water Services
(CMSWS) on 5/14/2013. During the 2013 inspection, a dry weather flow (DWF) was observed in the stormwater ditch near
the south pond.
Inspection Summary: During the inspection, Gerdau Ameristeel was observed to be in compliance with the City of
Charlotte Storm Water Pollution Control Ordinance. Several recommendations for protecting and improving water quality
are provided in the report. See the report for details.
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CHARLO7"17E_
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To report pollution or drainage problems call: 311
http://stormwater. charm eck. org
Page 1 of 3
Site Inspection Deficiency Comments
Stormwater system (catch basins,
No
The stormwater system consists of drop inlets and ditches
inlets, outfalls, etc.)
that drain to three ponds, and a stormwater ditch located
near the south pond. Collected stormwater is recirculated and
used as process water for the facility. No stormwater system
issues were observed.
Erosion issues
No
No erosion issues were observed during the inspection.
Structural stormwater BMPs
No
Three stormwater ponds were observed during the inspection.
No deficiencies were observed.
Illicit discharges/connections
No
No illicit discharges/connections were observed.
Aboveground storage tank(s) - list
No
Five (5) water glycol tanks and totes ranging from 180 -gallons
tank sizes & contents
to 600 -gallons are located on the site. Five (5) aboveground
storage tanks (ASTs) ranging from 300 to 5000 -gallons of
EcoSafe FR -46, a hydraulic liquid, are located throughout the
site in proper secondary containment. Tank area #1 and #2
contain used oil, diesel fuel, hydraulic oil, transmission fluid
and several other products within secondary containment
dikes. A complete list of all ASTs can be found in the
facility's SPPP.
Underground storage tank(s) - fill port
N/A
area; list tank sizes & contents
Outdoor material storage area(s)
Recommendation
Metal-rebar and other metal products produced by Gerdau
are stored outdoors. Slag from production is stored in an area
where it is sorted by a third party. A rusted drum of unknown
material was observed near Tank Area 1. CMSWS
recommends all drums be properly stored or disposed of to
prevent potential contamination of stormwater.
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http://stormwater. charm eck. org
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http://stormwater.charmeck.org
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Site Inspection Deficiency Comments
Outdoor processing area(s)
Recommendation
Staining on the process water ponds was observed near the
capacity of the containers. CMSWS recommends that facility
personnel confirm the freeboard capacity of the process water
ponds to ensure they meet the freeboard requirements of the
non -discharge permit.
Loading/unloading area(s)
No
Vehicle/equipment area(s) - fueling,
No
The facility services two (2) mobile cranes, loaders, bobcats,
washing, storage, etc.
and several trucks onsite. Per facility personnel, less than
660 gallons of oil is used a year at the site. No stormwater
issues were observed.
Oil/water separator and/or
No
The facility has an oil/water separator near the AST in the
pretreatment
scrap yard. According to facility personnel, the oil/water
separator is not currently in use.
Waste storage/disposal area -
Recommendation
The facility stores scrap metal in several areas throughout the
dumpsters, scrap metal bins, etc.
site. No issues were observed with these areas. The facility
has two (2) 20 -cubic -yard dumpsters for scrap metal and
several 8 -cubic -yard dumpsters for other trash. The rain lid
on one of the 8 -cubic -yard dumpsters near the main entrance
was observed to be broken. CMSWS recommends
contacting Republic Services to have the rain lid replaced.
Food service area(s)
N/A
Indoor material storage area(s)
No
The facility stores scrap metal, manufactured metal products,
totes of hydraulic fluid and other ASTs indoors. No
deficiencies were noted with these areas.
Indoor processing area(s)
Recommendation
Scrap metal is sorted in an indoor building by heavy
machinery. Metal shavings and particulates were observed in
the surrounding outdoor areas. CMSWS recommends
assessing means to reduce exposure of metal particulates to
stormwater from the aforementioned processing area.
Floor drains
No
Spill response equipment
No
Six (6) spill response kits and additional oil dry in storage
areas are located throughout the site.
tormwater Pollution Plan Observed Comments
Does the facility have a stormwater
Yes
pollution prevention plan?
General location (USGS) map
Yes
Narrative description of practices
Yes
Detailed site map
Yes
List of significant spills (past 3 years)
Recommendation
Forms for significant spills were included in the SPPP, but
did not refer to a specific time frame. CMSWS recommends
updating forms to indicate the time frame the forms
correspond to.
Non-stormwater discharge evaluation
No
The most recent non-stormwater discharge evaluation of
of outfall(s)
outfall form was signed by Rodrigo Conon on 4/27/17. The
inspection form was not filled out beyond the signature. No
previous records were available. Facility personnel should
conduct non -storm water discharge evaluations annually and
fill out the corresponding inspection form.
Feasibility study
Yes
All necessary secondary
Yes
Gas ASTs are double walled, all other ASTs are diked and/or
containment provided
under cover. All collected stormwater with a sheen is
collected and disposed of by Safety-Kleen.
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To report pollution or drainage problems call: 311
http://stormwater.charmeck.org
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INSPECTION DETAILS
Stormwater Pollution Plan Observed Comments
Collected water evaluated and
Recommendation
Several of the discharge log forms did not specify the location
documented prior to release
of discharge. CMSWS recommends updating forms to
specify location from which the discharge occurs.
BMP Summary
Yes
Spill prevention and response plan
Yes
Preventative maintenance and good
Yes
housekeeping plan
Facility provides and documents
Yes
Employee training was conducted on several dates in August
employee training
of 2017.
List of responsible parties
Yes
Reviewed and updated annually
Yes
The plan was last updated on 4/27/17.
Stormwater facility inspection
Yes
Stormwater facility inspections are conducted monthly.
program conducted semi-annually
Qualitative/Analytical Monitoring Observed Comments
Qualitative monitoring conducted
Yes
Qualitative monitoring was last recorded on 8/7/17.
semi-annually
Analytical monitoring conducted
Recommendation
Analytical monitoring has been conducted and recorded. The
semi-annually
facility should conduct monitoring as per tier two analytical
monitoring requirements of the permit. CMSWS recommends
facility personnel follow up with the permitting office on the
use of "ND" for reporting analytical results versus numerical
values that represent the lowest threshold detectable.
Analytical monitoring from vehicle
N/A
maintenance
Permit and Outfalls Observed Comments
Copy of permit and certificate of
Yes
coverage onsite
All outfalls observed
Recommendation
The majority of stormwater runoff flows to the north and west
outfalls, there is potential for runoff to drain at the south
outfall off of Lakeview road. CMSWS recommends facility
personnel contact the DEQ Mooresville Regional Office to
determine the applicability of the third outfall off Lakeview
Road.
Number of Outfalls Observed
3
Representative outfall status
N/A
documented by NCDWQ
Annual no -exposure self
N/A
re -certification documented
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To report pollution or drainage problems call: 311
http://storm water. charm eck.org
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