NCS000562_COMPLIANCE_20170519

---STORIVIINATER-DIVISfON-CODFNG-SHEET - ---
PERMIT NO.
N(iScoo
DOC TYPE
❑FINAL PERMIT
❑ MONITORING INFO
APPLICATION
COMPLIANCE
❑ OTHER
DOC DATE
❑ a C)I� os- Iq
YYYYMMDD
0
S�

A7411il,h
Division of Energy, Mineral & Land Resources
Land Quality Section/Stormwater Permitting
�
NCDENR
National Pollutant Discharge Elimination System
.� F�
PERMIT NAME/OWNERSHIP CHANGE FORM
I. Please enter the
permit number for which the change is requested.
FOR AGENCY USE ONLY
Date Received
Year
Month
Day
NPDES Permit (or) Certificate of Coverage
N G S 1 0 10 1 0 1 5 B 2 I N 10. 1 ;G
II. Permit status Rrior to requested change. Horsehead Metal Products, LLC (successor to Horsehead
a. Permit issued to (company name): Products, Inc.)
b. Person legally responsible for permit: Robert D. Williamson
RVCs�\] S[D
vi0 191011
1_ANp Q RM��ING pENR. it<R F
g'�ORMWA
First MI Last
General Manager
Title
484 Hicks Grove Road
Permit Holder Mailing Address
Mooresboro NC 28114
City State Zip
( 828 ) 919-3134 (828 ) 245-0291
Phone Fax
c. Facility name (discharge): Rutherford County Production Facility
d. Facility address: 484 yaks Grnyp Roan
Address
Mooresboro NC 28114
City Stale Zip
e. Facility contact person: James D. Harris ( 828 ) 919-3139
First I MI 1 Last Phone
111. Please provide the following for the requested change (revised permit).
a. Request for change is a result of: ❑ Change in ownership of the facility
® Name change of the facility or owner
If other please explain:
b. Permit issued to (company name):
c. Person legally responsible for permit:
American Zinc Products LLC
Robert D. Williamson
F i rst MI Last
General Manager
484 Hicks Grove Road
Permit Holder Mailing Address
Mooresboro NC 28114
City State Zip
(828 ) 919-3134 [e-mail]
Phone E-mail Address
d. Facility name (discharge): Rutherford County Production Facility
e. Facility address: 484 Hicks Grove Road
Address
Mooresboro NC 2814
City State Zip
f. Facility contact person: James D. Harris
First lVtl Last
(828 ) 919-3139 [e-mail]
Phone E-mail Address
i✓
IV. Permit contact information (if different from the person legally responsible for the permit)
Revised Jan. 27, 2014

NPDES PERMIT NAME/OWNERSHIP CHANGE FORM
Page 2 of 2
Permit contact: James D. Harris
First MI Last
Environmental Manager
Title
484 Hicks Grove Road
Mailing Address
Mooresboro NC 28114
City State Zip
( 828 ) 919-3139 [e-mail]
Phone E-mail Address
V. Will the permitted facility continue to conduct the same industrial activities conducted prior
to this ownership or name change?
0 Yes
❑ No (please explain)
VI Required Items: THIS APPLICATION WILL BE RETURNED UNPROCESSED IF ITEMS
ARE INCOMPLETE OR MISSING:
❑ This completed application is required for both name change and/or ownership change
requests.
❑ Legal documentation of the transfer of ownership (such as relevant pages of a contract deed,
or a bill of sale) is required for an ownership change request. Articles of incorporation are
not sufficient for an ownership change.
The certifications below must be completed and signed by both the permit holder prior to the change, and
the new applicant in the case of an ownership change request. For a name change request, the signed
Applicant's Certification is sufficient.
PERMITTEE CERTIFICATION (Permit holder prior to ownership change):
Robert D.
1,attest that this application for a name/ownership change has been reviewed and is accurate and
complete to the best of my knowledge. 1 understand that if all required parts of this application are not
completed and that if all required supporting information is not included, this application package will be
returned as incomplete.
Signature Date
APPLICANT CERTIFICATION
Robert D.
I, wniamsap attest that this application for a name/ownership change has been reviewed and is accurate and
complete to the best of m owledge. I understand that if all required parts of this application are not
completed and that if r u'ILqd supporting information is not included, this application package will be
returned as incompl
r
S- L/C 17
Signature Date
PLEASE SEND THE COMPLETE APPLICATION PACKAGE TO:
Division of Energy, Mineral and Land Resources
Stormwater Permitting Program
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
Revised Jan. 27, 2014

—� SOSID: 1280147
Dole Filed: 4/26/2017 8:12;00 ANI
Effective: 5/l/2017
} Elaine 1. 11irshall
Norlh Carolinn Secretary ot'State j
Stale of Noah Cm-olina j C2017 116 01406 _ J
Department of the Seeretaly nj'stwe T
Limited Liability Company
AMENDMENT OF ARTICLES OF ORGANIZATION
Pursuant to §571a-2-22 of the General Statutes of North Carolinn, the undersigned limited liability company hereby submits the
following Articles of Arneridment for ilie purpose of amending its Articles ofOrganizatiori.
'l-he name of cite liniked liability campar)y is: Florseliend Mctal Products, LLC
2. The text ofeach amend:Went adopted is as follows (atlach additional pages if necessary):
The first switcncc of Paragraph I of the Articles ol'Orgimiz•ltion, inchrding Arlieles ofConversioti, Is hereby replaced And
amended it) read n% follow,,;: The iiame of (lie limited liability company is Americim Zlnc Pro{lnc(s LLC.
(Check either a or b, whichewr is applicable)
A. l'hc aniendmen((s) was (were) duly adopted by the majority vote of the organizers of fhe limited liability company
prior to the identification of initial membeis of the liniked liability company.
B._ X •The amendmcnt(s) was (were) duly iidopled by the imammous vote of the members of /lie limited liability company
or was (were) ndnp(ed as otherwise, provided in the limited liability company's Articles of Organization or a written ope)ating
ngrcenicnt.
4. 'These articles will be effeclivo upon filing, unless a date and/or time is specified: May 1, 2017
This ihe2w. day of*Af . , 2017•
HORSEHEAD METAL PRODUCTS, LLC
hnme of Limiled iabiWy C nrl)any
Sig rat rr•e
Gcul R. �hiluker
Vice Pre'sidem, Gen end Counsel acid Secr•elmy
Edit TE s:
I . Filing fee is $50. This document must be filed with the Sccretaty ofS(atc.
CORPORATIONS DIVISION P. O. BOX 29622 RALEiGH, NC 27626-0622
fRcvi.vac1 Jamuw), 2014) (Porn? L-17)

NORTH CAROLINA
- Department of the Secretary of State
To all whom these presents shall come, Greetings:
I, Elaine F. Marshall, Secretary of State of the State of North Carolina, do hereby certify
the following and hereto attached to be a true copy of
ARTICLES OF ORGANIZATION
OF
HORSEHEAD METAL PRODUCTS, LLC
the original of which was filed in this office on the 30th day of September, 2014.
IN WITNESS WHEREOF, i have hereunto set my
hand and affixed my official seal at the City of
Raleigh, this 30th day of September, 2014.
��11 blSb � � � Scan to verify online.
Certificationg C201427200792-1 Reference;# C201427200792-I Page: I of 4 Secretary of State
Verify this certificate online at WWW.secretary.state.ne.us/'Verification

State of North Carolina
Department of the Secretary of Slate
ARTICLES OF ORGANIZATION
INCLUDING ARTICLES OF CONVERSION
SOSID: 1280147
Date Filed: 9/30/2014 2.07:00 PM
Elaine F. Marshall
North Carolina Secretary of State
C2014 272 00792
Pursuant to §§ 57D-2-21, 57D-9-20 and 57D-9-22 of the General Statutes of North Carolina, the undersigned
converting business entity does hereby submit these Articles of Organization Including Articles of Conversion
for the purpose of forming a limited liability company pursuant to the conversion of another eligible entity.
I . The name of the limited liability company is: Horsehead Metal Products, LLC
The limited liability company is being formed pursuant to a conversion of another business entity.
(See Item 1 of the Instructions far appropriate entity designation)
2. The name of the converting business entity is: Horsehead Metal Products, Inc.
and the organization and internal affairs of the converting business entity are governed by the laws of the
state or country of Norlh Carolina
A plan of conversion has been approved by the converting business entity as required by law.
3. The converting business entity -is a (check one): Q domestic corporation; []foreign corporation;
❑ foreign limited liability company; [ domestic limited partnership;
foreign limited partnership; [ domestic registered limited liability partnership;
❑ foreign limited liability partnership; [ professional corporation; or [ other partnership as defined in
G.S. 59-36, whether or not formed under the laws of North Carolina,
4. The mailing address of the converting entity prior to the conversion is:
Number and Street: 484 Hicks Grove Road
City: Mooresboro State: NC Zip Code: 28114-8268 County:
If different, the mailing address of the resulting business entity is:
Number and Street;
City: State: Zip Code: County:
Cleveland
5, The name and address of each person executing these articles of organization is as follows: (State
whether each person is executing these articles of organization in the capacity of a member,
organizer or both. Note, This document must be signed by all persons listed,)
Samuel W. Whitt, Organizer
4141 Parklake Ave., Suite 200
Raleigh, NC 27612
CORPORATIONS DIVISION P.O. BOX 29622 RALEIGIA, NC 27626-0622
(Revised Jot?ua+y 2014) Page t (Form L-01A)
1-'InI.11-7'1nn'701 i "IRI AIa�nn'io� n-- I -rA

6. The name of the initial registered agent is: CT Corporation System
7. The street address and county of the initial registered office of the limited liability company is:
Number and Street: 150 Fayetteville Street, Box 1011
City: Raleigh - State: NC Zip Code: 27601 County: Wake
8. The North Carolina mailing address, if different from the street arlrlress, of the initial registered office is:
Number and Street:
City: State: NC Zip Code: County:
9. Principal Office information: ,Select either a or b.
a. 0 The limited liability company has a principal office.
The principal office telephone number: 828-919-3134
The street address and county of the principal office of the limited liability company is:
Number and Street: 484 Hicks Grove Road
City: Mooresboro State: NC Zip Code: 28114-8268 County: Cleveland
The mailing address, if different from the street address, of the principal office of the limited liability
company Is:
Number and Street:
City: State; Zip Code:
b. ❑ The limited liability company does not have a principal office.
County:
10. Any other provisions which the limited liability company elects to include (e.g., the purpose of the entity)
are attached.
11. (Optional): Please provide a business e-mail address:
The Secretary of State's Office will e-mail the business automatically at the address provided at no
charge when a document is filed. The e-mail provided will not be viewable on the website. For more
information on why this service is being offered, please see the instructions for this document.
CORPORATIONS DIVISION P.O. BOX 29622 RALEIGH, NC 27626-0622
(Revised Jan uary 2014) Page 2 (Farnr L-01A)
r1ni Al07Inn'/n9 1 n r - u r"In A'7ann�a1 n.,,...- z. f n

12. These articles will be effective upon filing, unless a future date is specified: Sept 30, 2014
This is the 29 day of September 20 14
Horsehead Metal Products, LLC
ptioncr1: Busgr
nte)
Signature
Samuel W. Whitt, Organizer
Type or Print Name and Title
The below space to be used if more than one organizer or member is listed in Item #5 above.
(Optional: Business Entity Name)
Signature
Type or Print Nome and Title
(Optional: Business Entity Name)
Signature
Type or Print Name and Title
NOTF S:
1. Filing fee is S125. This document must be riled with the SccrelRry orsolte.
CORPORATIONS DIVISION P.O. BOX 29622
(Revised Jan Crary 2014) Page 3
(Optional: Business Entity Name)
Signature
Type or Print Name and Title
(Optional: Business Entity Name)
Signature
Type or Print Maine and Title
RALEIGH, NC 27626-0622
(Form L01A)
'....F:R.... FS....N t`4111 A779nn'71Y1 1 u..r ..........R !`1n1 d979nn7Q4 D---. A -T 3

4a4 HICKS GROVE ROAD
MOORESSORO. NC 2$114
March 9, 2016
WWW.HORSEH£AD.NET
Via Electronic Mail 'ef%menzel nedenr. ov and U.S. Mail
Jeff Menzel, Western Region Environmental Specialist
Hazardous Waste Section
Division of Waste Management
PO Box 1568
Black Mountain, NC 28711
RE: Immediate Action Notice of Violation
Docket # 2016-006
Cell House Investigation
Horsehead Metal Products, LLC
Dear Mr. Menzel,
H H�
METAL PRODUCTS, LLC
a ju&idlary of Homehead Corporaflon
Enclosed is the report of findings from the recent field investigation completed in the cetlhouse area of
the Horsehead Metal Products, LLC ("Horsehead") facility in Mooresboro, NC. This investigation was
performed in response to the Immediate Action Notice of Violation (Docket #2016-006) issued by the North
Carolina Department of Envirorunental Quality ("NCDEQ") on October 28, 2015. Field work was conducted
in.accordance with the Work Plan submitted to, and approved by, NCDEQ, on December 4, 2015 and
December 16, 2015, respectively.
If you have any questions, please contact Tim Basilone at [phone].
Sincerely,
Anthony Sta ey
cc: Tim Basilone, Horsehead
Mark Wilkins, NC DEQ
Brent Burch, NC DEQ

ENSAFF
a global professional services company
creative thinking. custom solutions.°
313 Wingo Way I Mount Pleasant, South Carolina 29464 i Telephone [phone] Facsimile 843-856-0107 1
wwm ensafe.corr7
March 8, 2016
Mr. Timothy R. Basilone
Vice President, Environmental Affairs
Horsehead Corporation
4955 Steubenville Pike, Suite 405
Pittsburgh, Pennsylvania 15205
Re: Cell House Investigation
Horsehead Metal Products, LLC.
Mooresboro, North Carolina 28114
Dear Mr. Basilone:
EnSafe Inc. is pleased to provide this letter summarizing field work and analytical results
from investigation activities conducted in January 2016 at the Horsehead Metal
Products, LLC. (Horsehead) facility located at 484 Hicks Grove Road in Mooresboro
(the Site), Rutherford County, North Carolina. Field activities were implemented in
accordance with the Investigation Work Plan — Cell House Release dated
December 4, 2015 ("the Work Plan'.
The Work Plan was developed in response to an Immediate Action Notice of Violation
(Docket # 2016-006) issued on October 28, 2015, requiring Horsehead to conduct an
evaluation of potential impacts to environmental media from a release of process liquid to
the subsurface that had previously occurred in the vicinity of the Cell House. In accordance
with the Immediate Action Notice of Violation, the Work Plan was submitted to the
North Carolina Department of Environmental Quality (NCDEQ) on December 4, 2015.
Approval of the Work Plan was provided by NCDEQ in a letter dated December 16, 2015.
BACKGROUND
On Saturday, September 5, 2015, an aqueous solution exhibiting a low pH and containing
lead, chromium, cadmium, and zinc entered the storm drain system and was discharged to
the (storm water retention) Basin 1 at the facility. Following investigation, it was
determined that a transfer pump in the Cell House had malfunctioned, which led to
circumstances whereby aqueous solution containing process liquid was released to the
subsurface through an open joint in the surface concrete. The open joint, which has since
been repaired, is located at the edge of the concrete floor located beneath the Cell House,
specifically between the wall of a recirculation tank and the floor. Aqueous liquid at the
open joint entered the subsurface soil and infiltrated into the nearby underground storm
drain pipe, and was discharged to Basin 1. It was determined that the liquid had infiltrated
the underground storm pipe between catch basins CB 74 and CB 73. These basins are
shown on the attached map.
engineering I environment I health & safety I technology

Mr. Timothy R. Basilone
March 8, 2016
Page 2
FIELD ACTIVITIES
Field activities commenced on January 25, and were completed on January 26, 2016.
After subsurface utilities were located in the Cell House investigation area, the specific
surface locations for three subsurface borings were identified. A survey using ground
penetrating radar was conducted to gather information in order to position one of the
subsurface borings, specifically SB-02, to encounter the fill material, which was placed in
the excavation following installation of the storm water drain pipe.
Three borings were installed according to the Work Plan, at locations identified on the
attached figure. Borings were advanced via Direct Push Technology using a dual -tube
sample system to a depth of 12 feet below the ground surface (bgs). Logs (attached) were
developed describing the nature of soil and materials encountered in each boring, and
noting observations made as to moisture content and the presence of free water.
Four soil samples were collected from each boring and sent for laboratory analysis.
Soil sample intervals are depicted on the attached boring logs.
After field information at each boring was gathered, the boreholes were abandoned with a
bentonite slurry, in accordance with protocol required by the North Carolina Administrative
Code (Title 15A, Subchapter 2C, Section .0113), and the surface was restored using high
strength concrete, Investigation derived material generated during field activities, including
decontamination water and soil cuttings, was placed in drums and temporarily stored
onsite. Samples of the material were collected for hazardous waste characterization
purposes. Following evaluation of analytical results, investigation derived material was
disposed of at a Subtitle D municipal solid waste landfill in the state of North Carolina.
Coordinates for the soil borings could not be obtained using a Global Positioning System, as
planned. Measurements using a tape measure were obtained to identify and describe
boring locations with respect to fixed facilities.
Samples collected during the investigation, including soil samples from the borings,
field duplicate samples, and an equipment blank sample, were submitted to
Shealy Environmental Services, Inc. (NELAC No: E87653, NCDEQ No: 329) for metals
analysis including cadmium, chromium [total], lead, and zinc using Method SW846-6010C,
and pH using Method SW846-9045D.
Summary of Field Observations
Free liquid was not encountered in any of the borings. Observations for free liquid in each
open boring were made over a period of one hour following advancement of the boring to
a depth of 4 feet bgs. As indicated in the attached boring logs, soil was encountered
immediately beneath the asphalt surface. A stone fill layer was not encountered between
the base of the asphalt and soil, as anticipated based on preliminary construction
information.

Mr. Timothy R. Sasilone
March 8, 2016
Page 3
As shown in the attached boring logs, subsurface lithology beneath the paved concrete and
asphalt surface consists of soil fill layer of varying thickness, and indigenous soil.
Soil consists primarily of inorganic silt with varying percentages of clay, and some gravel
and sand. Density of the soil ranged from soft to medium, and soil cohesion was sufficient
to maintain sidewall stability in the boring. Soil was dry immediately under the asphalt
surface at each boring, despite the presence of surface water runoff on the pavement
surface at each location.
Lithology encountered in borings SS-01 and SB-03 consisted primarily of compacted and
consolidated silt and clay with sparse layers of sand. Whereas, soil encountered in SB-02
was not as dense, and consisted primarily of unconsolidated fill. This was to be expected
since SB-02 was located within the fill zone for placement of the storm pipe. SB-01 and
SB-03 were located in areas underlain primarily by consolidated indigenous soil, overlain by
a thin layer of fill.
Subsurface Conditions
The preliminary conceptual site model, as presented in the Work Plan, had shown a
continuous gravel layer that extended laterally beyond the subsurface portion of the
Cell House secondary containment basin, and into the subsurface area underlying the
adjacent access roads.
As discussed above, a gravel layer was not encountered during the investigation.
On the contrary, the predominant grain size encountered consisted generally of a dry,
low plasticity/friable silt, which is typically characterized by low permeability rates.
It is believed that the low permeability properties of the compacted fill and native soil
material surrounding the secondary containment basin would have acted as a baffle to
lateral migration of the released aqueous solution.
The section of storm water conduit pipe and associated installation trench between CB 74
and CB 73 is located in dose proximity to the Cell House secondary containment basin, at a
point approximately 30 feet to the northwest of SB-02. The proximal location of the
storm water installation trench to the secondary containment basins and the general
location of infiltration to the pipe suggest there may be lateral connectivity between the
gravel layer underlying the secondary containment basin, and the storm water installation
trench.
Based on these findings, it appears that the preferential pathway for liquid migration in the
subsurface was to the storm water system at a point where the storm water conduit pipe
approaches, and may intersect, sub -based gravel beneath the southwest corner of the
secondary containment basin at the Cell House.
ENSAFF

Mr. Timothy R. Basilone
March 8, 2016
Page 4
Summary of Soil Sample Analytical Results
Four soil samples were collected from each of three borings installed in the closest
proximity to the location where the release of process liquid to the subsurface had
occurred. Soil samples from select depths in each boring, to a depth of 12 feet bgs, were
analyzed for lead, cadmium, total chromium, zinc, and pH. A summary of metal
concentrations in soil samples from each of the borings is provided in Table 1.
From previous studies conducted at the Site, it was determined that the typical pH for
indigenous are naturally acidic, ranging from 4.18 to 5.2 standard units. All pH results for
soil samples collected from the borings were within the background range.
Analytical results for samples collected during the investigation were screened against the
NCDEQ Protection of Groundwater Preliminary Soil Remediation Goals (PSRG)
(NCDEQ, September 2015). As shown on Table 1, cadmium, total chromium, and lead
concentrations in soil samples from all three borings did not exceed their respective PSRG
values. Zinc levels in all soil samples collected from SB-1 and S13-3 did not exceed the
PSRG value. The zinc concentration in one of the four samples collected at SB-02,
specifically the sample collected at the bottom of the boring (11-12 feet bgs), exceeded the
PSRG value. The PSRG value is 1,200 milligrams per kilogram (mg/kg), and the subject soil
sample contained 2,700 mg/kg. A duplicate analysis was conducted on the sample, and a
zinc concentration of 2,300 mg/kg was detected.
Of the 12 samples analyzed, all analyzed parameters were below their respective PSRG
value with the exception of one sample that exceeded the Protection of Groundwater PSRG
value for zinc. Based on the location of the three borings in close proximity to the area
where the release occurred, the spatial (vertical and lateral) distribution of samples
obtained from the collective borings, and only one sample containing zinc above the
Protection of Groundwater PSRG, any potential residual metal concentration in the
subsurface soil would be limited to a relatively small area underlying the storm water
installation trench in the immediate vicinity of the release.
CONCLUSION
Potential risk to human health and the environment as a result of zinc at the concentration
noted above would be limited to the potential groundwater pathway. Groundwater is not
used at the Site for industrial purposes or consumption, thus eliminating risk to human
health. In light of this and information presented above, a comparison to Groundwater
PSRG's as a decision tool may be less relevant because the preferential pathway for
contaminant transport now appears to be the storm water pipe. Furthermore, soil
immediately below the asphalt layer at each borehole location was dry, despite the
presence of surface water runoff on the pavement surface above at each location.
This provides evidence that the surface pavement in the Cell House area is an effective
barrier to surface water infiltration to the subsurface.
EMSAFE

Mr. Trmothy k Basilone
March 8, 2016
Page 5
Initial expectations that the release from the Cell House may have created elevated soil
contamination requiring remediation and potentially a threat to groundwater now appear to
be unjustified. Dry soil below the asphalt surface, the absence of a permeable layer
facilitating contaminant migration, and the soil analytical results showing very low levels of
heavy metals, all suggest that the preferential pathway of the release was to the
storm water system, which mitigated impacts in the area of the release. The low metals
concentrations, generally even for zinc, and absence of risk receptors in this industrial
complex suggest further investigation is unwarranted.
Should you have any questions or require additional information, please contact me at
[phone] or [e-mail].
Sincerely,
EnSafe Inc.
By: J. Adam Freeze
Geologist/Environmental Scientist
Attachments: Table 1 — Soil Sample Results
Soil Boring Location Map
Soil Boring Logs
ENSAFE

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Legend SOIL BORING LOCATION MAP
6
CELL HOUSE INVESTIGATION
So•, 8a::ng wcaapn HORSEHEAD METAL PRODUCTS
r.at®r G-asn MOORESBORO. NORTH CAROLINA
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PROJECT NO 0861a1 7148

ENSA FE
Location ID: SB-01
Soil Boring Log
Start Dateffime: 1-26-16109:20
313 Wingo Way, Mt. Pleasant,
End Dateffime: 1-26-16 / 13:10
SC 29464
Total Depth: 12'
Client: Horsehead Metal Products
Sample Method: Direct Push
Ground Elevation: 856.2'
Project #: 0888817148
Purpose: Cell House Investigation
Drill Equipment: Geoprobe 66200T
Easting: NA
Project: Horsehead Mooresboro
Drilling Company: M & W Drilling
Northing: NA
Location: Mooresboro, NC
Geologist: A. Freeze
G
b
'
Lithologic Description
-
o
Visual -Manual Description (ASTM D 2488-06)
0
856
ksphal
Asphalt
$M
Brown grading to reddish orange, silty fine SAND, little coarse gravel (-0.5 - 1.5' diameter, construction), little silt,
7
few mica, angular, loose, dry
-1
SP
Gray, fine to medium SAND, little coarse gravel (construction), trace siltimica, loose, angular, dry
855
ML
Red/orange mottled, clayey SILT, little day. few micalcoarse gravel (native), soft to medium stiff, low plasticity, dry
2
to slightly moist
854
100%
NA
-3
853
SP
Gray, fine to medium SAND, little coarse gravel (native), trace silt, loose, angular, dry (Note: potential slough from
852
higher interval)
5
851
NA
ML
Brown/orange mottled, clayey SILT, little clay, few mica/fine gravel (native), soft, low plasticity, dry
$
�J
W
850
Light gray, medium to coarse quartz SAND layer (-1" thick), little fine to coarse gravel, trace silt, angular, loose, dry
(USCS = SP)
ML
7
Red, SILT, few claylmica, medium stiff, friable (low plasticity), dry
849
95%
NA
848
ML
Reddish orange, SILT, few fine gravel (native), few clay/mica, medium stiff, friable (low plasticity), dry
-9
847
ML
Brownish red, clayey SILT, little clay, few micalfine gravel (native), medium stiff, slight plasticity, dry to slightly moist
10
at 11' bgs
846
NA
11
845
90%
-12
End of Boring @ 12.0' bgs
Notes:
LEGEND: ppm - parts per million ft. - feet
Sample Intervals110s:
2.5-3.0' = S801 SOO10116, 5.5-6.0' = SBO1 S0020116,
s - below round surface
J 9 Laboratory Sample Interval
8.5-9.0' = S601 SO030116, 11.0-12.0' - SBOi SO0401161SB01 SO040116-FD1
NA - Not applicable OVA - organic vapor analyzer
Page 1 of I

ENSAFE
Soil Boring Log
Location ID: SB-02
Start Dater ime: 1-26-16113:40
313 Wingo Way, Mt. Pleasant,
End Date/Time: 1-26-16 ! 15:20
SC 29464
Total Depth: 12'
Client: Horsehead Metal Products
Sample Method: Direct Push
Ground Elevation: 856.2'
Project #: 0888817148
Drill Equipment: Geoprobe 6620DT
Easting: NA
Purpose: Cell House Investigation
Project: Horsehead Mooresboro
Drilling Company: M & W Drilling
Northing: NA
Location: Mooresboro, NC
Geologist: A. Freeze
c
>
c
Lithologic Description
g
x
o
E
U
j
Visual -Manual Description (ASTM D 2488-06)
0
856
sphal
Asphalt
SM
Red, SILT, little coarse gravel (construction), few day/mica, soft to medium stiff, low plasticity, dry
-1
855
-2
854
100%
NA
3
853
852
SM
Red, SILT, little weathered fine to coarse gravel (native), few mica, loose/friable (low plasticity), occassional
5
medium to coarse sand layer (-1" thick), dry to slightly moist at 11' bgs
851
NA
850
7
6.75' = Gray, coarse quartz SANE) layer, -1" thick
849
75%
NA
-8
848
8.5' = Gray, coarse quartz SAND layer, partially indurated, -1" thick
9
847
10
84fi
NA
11
845
75%
12
End of Boring @ 12.0' bgs
Notes:
LEGEND: ppm - parts per miIiion ft. - feet
Sample InfervalsllDs
3.0-3.5' = SB02S0010116, 6.3-6.8' = SB02SO020116,
s - below round surface
g �� Laboratory Sample Interval
SB02S0030116, 11.0-12.0' = S602S00401161SB02SO040116-FD
NA - Not applicable OVA - organic vapor analyzer
Page 1 of 1

ENSAFE
Location ID: SB-03
Soil Boring Log
Start Daterrime: 1-27A6109:00
313 Wingo Way, Mt. Pleasant,
End Daterrime: 1-27.16 ! 11:00
SC 29464
Total Depth: 12'
client; Horsehead Metal Products
Sample Method: Direct Push
Ground Elevation: 856.2'
Project #: 0888817148
Drill Equipment: Geoprobe 6620DT
Easting: NA
Purpose: Cell House Investigation
Project: Horsehead Mooresboro
Drilling Company: M & W Drilling
Northing: NA
Location: Mooresboro, NC
Geologist: A. Freeze
o
}
d
a
e
o
Lithologic Description
W
x
E
o a
{„
Visual -Manual Description (ASTM D 2488-06)
a
0
856
Asphalt
7sphat
p
Brown, fine SAND, little fine gravel (construction), few silt, loose, angular. dry
ML
Red, SILT, few mica/fine gravel (construction), soft, friable (low plasticity), dry
-1
855
ML
Brownish red, SILT, little coarse gravel (native), few mica, soft to medium stiff, friable (low plasticity), dry
-2
854
100%
NA
-3
853
-4
852
5
851
NA
850
ML
Orangetred mottled, clayey SILT, little Gay, few fine to medium quartz sandlmica, soft to medium stiff, friable (low
plasticity)- dry, sand percentage increases with depth, becomes sandy SILT, little fine to medium sand, trace
coarse sand
7
849
85%
NA
-8
848
-9
847
SM
Orange, silty medium SAND, little silt, few mica/coarse sand, medium dense/stiff, angular, dry
10
846
NA
90%
ML
Tanlorange mottled, SILT, few fine sandlmica, soft, friable (low plasticity), dry
-11
845
-12
End of Boring @ 12.0' bgs
Notes:
LEGEND: ppm - pans per million ft - feet
Sample Intervals]IDS:
2.5-3.0' = S803S0010116, 5.5-6.0' = S803SO020116,
s - below round surface
b9 9 Laboratory Sample Interval
8.5-9.0' = SB03S0030116, 11.0-12.0' = SB03S00401161SB03SO040116-FO
NA - Not applicable OVA - organic vapor analyzer
Page 1 of 1

0
TIMOTHY R. BASII.ONE
Via. !'mar lent - lar3inmmenirrl l ff airs
4955 STEUBENVILIX PIKH
SUITE 405
PITTSBURGH, PA 152GS
June 4, 2012
WWW,HORSF.HEAO.NET 724.773.2223
[e-mail] 412.788,4526
Mr. Chuck Cranford, Regional Supervisor
Surface Water Protection
Division of Water Quality, Asheville Regional Office
2090 U.S. Highway 70
Swannanoa, North Carolina 28778
0
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RE: Response, DWQ NOV
Horsehead Corporation, Rutherford County Facility
NOV-2012-PC-01 S3
Dear Mr. Cranford:
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Horsehead Corporation ("Horsehead") appreciates this opportunity to respond to your
May 9, 2012 letter. In your letter, the North Carolina Division of Water Quality,
Asheville Regional Office ("the Department") references various deficiencies and areas
of concern based on a compliance inspection which was conducted by members of the
Department on April 19, 2012.
Required responses to each of the specific comments, as requested in your May 91h, 2012
letter, are provided below:
1. Construction Stormwater Permit NCGO1000
Please explain when you anticipate being in full conipliance. with the
NCG010000 Permit, Please also explain which entity will take
responsibilityfor storm water inspection and monitoring, etc. DWQ
suggests better coordination beN,een all parties on site.
Since receiving your letter our consultant, McGill Associates, has been in communication
with Ms. Susan Wilson and Mr. Tim Fox in your office. A meeting was held at the site
on May 1 &, 2012 between Horsehead representatives, site contractors, Mr. Tim Fox
(Division of Water Quality), Ms. Laura Herbert (Division of Land Resources-DLR), Mr.
Charles Koontz (DLR), Ms. Darlene Kucken (DLR), McGill Associates, Odom
Engineering, and S&ME Engineering. Mr. Forrest Westall and Mr. Mark Cathey from
McGill Associates met with Mr. Tim Fox on May 18"', 2012 in the Department's
Regional Offices. During these meetings an organizational structure was described for
management of erosion and sediment control measures at the site, .which includes
provisions for daily inspections and assurance that control measures are effective.

0 9
Procedures provide for daily updates sent to me which highlight evaluations of site
BMPs, and for identification of corrective actions that may be required. In addition,
measures have been established for implementation of monitoring and reporting
procedures, record keeping and coordination of activities among various contractors on
the site. Later on that date, Mr. Westall met with Ms. Laura Herbert with the Division of
Land Resources to review this information as well.
Arrangements have been made with McGill Associates to serve as the point of contact for
the Department, and for daily coordination of environmental compliance activities at the
Rutherford County site. A Construction Environmental Management Plan (CEMP) is
being developed to document monitoring, recordkeeping, and reporting activities. I
believe these measures address the concern for on site coordination noted in your letter.
A meeting has been scheduled for June 7`h, 2012 with your Division and the Division of
Land Resources to review measures established for environmental management at the
site, and the role of McGill Associates as the single point of contact for coordination of
site environmental activities, and communication with the Department.
Following receipt of your letter, issues dealing with erosion and sediment control
measures were immediately addressed. As of the date of this letter, sediment and erosion
control measures are in place and in good condition.
b. You should include in your response an explanation of why proper
operation and maintenance of stormwater measures was not performed to
optimum efficiency and you propose to prevent these problems from
reoccurring on this project and on future projects.
Issues related to management of information and control measures at the site are
addressed in the information provided above. To the degree that your comment pertains
to sediment observed in the stream, the following information is being provided. As
background information, Horsehead conducted an extensive evaluation of the Rutherford
County site prior to purchase and commencement of development activities in the
watershed noted. As part of the evaluation, existing environmental conditions at the site
were photo -documented at that time to establish a baseline recognizing pre -project site
conditions. Conditions that were documented include sediment in the streams and
wetlands from nearby erosion of slopes along the power line right of way. These same
conditions were observed during the Departments' recent inspection, and which is one
item included in the notice of violation. Information will be presented in our meeting
scheduled on June 7, 2012 to demonstrate the existence of sediment in the stream prior to
commencement of construction activity.
Stormwater measures beyond the sediment issues in the stream have been maintained,
and their effectiveness confirmed. These measures are evaluated as required and
inspections are being conducted on a frequent basis, with daily records being kept.

0 •
2. Stream Standard — Other Waste (In -Stream Sediment)
a. Please provide a map of the project area. The map must include all
streams and wetlands, detailing impacts on both on and off -site.
A site map is attached. There have been no significant erosion and sediment impacts to
existing streams on the site or downstream off site areas resulting from Horsehead site
development activities.
b. Please submit a Sediment Removal Plan (Plan) to this off ce for review
and approval. (contents of the plan identified in letter, not provided here)
On several occasions following the NOV, we discussed with your staff the presence of
sediment in the subject stream which was observed during the inspection, and the fact
that this condition was documented prior to commencement of construction activities.
We discussed that based on observations made at that time (prior to construction) the
sediment in the stream resulted from erosion of the slopes in the power line right of way
located across the tributary. A detailed evaluation of this area and the condition of the
stream was conducted in September 2011 with photo documentation of existing
conditions. This information was conveyed to Mr. Fox during the meeting on May 18th,
2012 with McGill Associates representatives. Following the meeting, Mr. Fox
acknowledged that the information provided clearly documented that sediment was
released from the described area which resulted in the deposition sediment in the stream.
Based on information provided regarding the sediment observed in the stream, Mr. Fox
provided an e-mail indicating that development of a Sediment Removal Plan would not
be necessary.
This sediment condition was discussed with the United States Army Corp of Engineers
(USACE) prior to commencement of construction. At that time the USACE advised that
in ther opinion removal of the sediment from the stream was likely not warranted, since
removal activities would likely result in further degradation of the stream. They advised
that their view was that natural recovery of the stream was the hest approach.
Since commencement of construction activities, the western slope has been stabilized
using wood mulch developed from site grading operations.
We acknowledge the Departments reminder that Section IIB.3.(f) of the construction
stoimwater permit requiring that we report to DWQ any visible sediment being deposited
in any stream or wetland. We believe that measures to recognize and report such
conditions have been established. I remain confident that with our establishment of
management control measures for coordination of environmental activities at the site, that
environmental control measures will be consistently implemented.

0
0
I look forward to meeting with the Department on June 7"' to discuss remaining concerns,
and provide information with respect to noted deficiencies raised in your letter. In the
meantime, please contact me if you have any questions or concerns.
�You�rs truly,
/�7a.�i114
Timoth. Basilone
Y
Encl.
CC. Ms. Susan Wilson, NCDENR, DWQ
Mr. Tim Fox, NCDENR, DWQ
Ms. Laura Herbert, NCDENR, DLR
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JOB NO.: 11,00306
DATE: JUNE, 2012 NOV RESPONSE
cn DESIGNED BY: MDC
CARD BY: KS NOV-2012-PC-0153
DESIGN REVIEW:_ �14 „
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SITE MAP E! FILENAME: HORSEHE_AD CO_ RPORATIO_N
FILE NAA S S O C i ATE S
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•
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Site Inspection Report
Site Number: WT000075
Site Name: Horsehead Site
Site Address: 347 Hicks Grove Rd
County: Rutherford
Directions: off US Hwy 221 and Hicks Grove Rd., near Rutherfordton
Latitude:
Site Owner Name: Horsehead Holding Corporation
Inspection Date: 08/01/12
Reason for Inspection: Routine
Inspection Type. Site Inspection (non -DOT)
Inspection Contact Person:
On -Site Representative(s):
Primary Inspector: Timothy R Fox
Secondary Inspector(s):
Region: Asheville
Longitude:
Facility compliance Status: N Compliant ❑ Not Compliant
Program Area: Construction SW (NCG010000)
Question Areas:
E NCG010000 Permit
Phone:
Phone: [phone]
Inspection Summary:
I inspected the site along with Darlene Kucken with DENR Land Quality section, Jim Harris of Horsehead Corporation and Jay Stewart
with McGill & Associates.
Several large rain events occurred during the week of 7109112 through 7115/12. These large rain events flushed remaining
pre-existing sediment in stream channels. Streams were evaluated and conditions documented.
Record keeping was in order and erosion control measures were maintained. Continue to monitor and maintain the site appropriately.
Page: 1

•
•
Site Number: VVT000075 Owner: Horsehead Holding Corporation
Inspection Date: 08/01/12 Inspection Type: Site Inspection (non -DOT) Reason #or Visit: Routine
NGG010000 Permit
Yes No NA NE
# Is this inspection related to a DLRldelegated program inspection?
■ D ❑ D
If Yes, what was the DLRldelegated program inspection date?
0810112012
Is the site following its E&SC Plan as per DLR or delegated program?
■ D D D
Is the site maintaining their E&SC measures as per DLR or delegated program?
■ ❑ D D
Is a copy of the approved E&SC plan on site?
■ D D n
Is a rain gauge present on -site or is MPE in use for the site?
■ 0 ❑
Is rain gauge data or MPE data recorded?
■ 0 D D
Are inspection records complete?
■ ❑ D D
Is the site compliant with other conditions of the NCGO10000 permit?
■ D D D
Comment: This was a routine inspection. The site was found to be in compliance. I
toured the site with Darlene Kucken with The Division of Land Resources, Jim Harris
with Horesehead Corporation and Jay Steward with McGill & Associates.
Several large rain events occurred during the week of 7109/12 through 7115112. These
large rain events flushed remaining pre-existing sediment in stream channels. Streams
were evaluated and conditions documented.
Record keeping was in order and erosion control measures were maintained.
Page: 2

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Site Inspection Report
Site Number: WT000075
Site Name: Horsehead Site
Site Address: 347 Hicks Grove Rd
County: Rutherford
Directions: off US Hwy 221 and Hicks Grove Rd., near Rutherfordton
Latitude:
Site Owner Name: Horsehead Holding Corporation
Inspection Date: 07/06/12
Reason for Inspection: Routine
Inspection Type: Site Inspection (non -DOT)
Inspection Contact Person:
On -Site Representative(s):
Primary Inspector: Timothy R Fox
Secondary Inspector(s):
Region: Asheville
Longitude:
Facility compliance Status: E Compliant n Not Compliant
Program Area: Construction SW (NCG010000)
Question Areas:
0 NCG010000 Permit
Phone:
Phone: [phone]
Inspection Summary:
I inspected the site along with Darlene Kucken with DENR Land Quality section, Jim Harris of Horsehead Corporation, Jay Stewart
with McGill & Associates and Jay Woodward with S&ME. The site is in compliance and record keeping was in good order. The site is
being maintained and monitored well..
Page: 1

E
i
Site Number: WT000075 Owner: Horsehead Holding Corporation
Inspection Date: 07/06/12 Inspection Type: Site Inspection (non -DOT) Reason for Visit: Routine
NCG010000 Permit
# Is this inspection related to a DLRldelegated program inspection?
If Yes, what was the DLR/delegated program inspection date?
Is the site following its E&SC Plan as per DLR or delegated program?
Is the site maintaining their E&SC measures as per DLR or delegated program?
Is a copy of the approved E&SC plan on site?
Is a rain gauge present on -site or is MPE in use for the site?
Is rain gauge data or MPE data recorded?
Are inspection records complete?
Is the site compliant with other conditions of the NCG010000 permit?
Comment: This was a routine inspection. The site was in compliance. I toured the
site with Jim Harris with Horesehead Corporation, Jay Steward with McGill &
Associates and Jay Woodward with S & ME. There has been alot of grading work done
since my last inspection and erosion control measures have been installed and are
being maintained. Site records and documentation was provided and in compliance.
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Page: 2

NCDENR
North Carolina Department of Environment and
Division of Water Resources
Water Quality Programs
Pat McCrory Thomas A. Reeder
Governor Director
August 30, 2013
Horsehead Metal Products, Inc.
Attn: Jim Harris, Environmental Manager
484 Hicks Grove Road
Mooresboro, NC 28114
Subject: Incident Closure
Project: Horsehead Metal Products, Inc.
Rutherford County
Dear Mr. Harris:
Natural Resources
John E. Skvada, III
Secretary
The Division of Water Resources (DWR) has received the cleanup status from Clearwater
Environmental Consultants, Inc. dated August 28, 2013, related to the release of sediment from a
large rain event that occurred on May 23, 2013 located at the Horsehead Corporation construction
site in Rutherford County. DWR also visited the site on July 16, 2013 to evaluate the cleanup
efforts.
DWR has reviewed the information provided. The written response and sediment removal activities
performed have satisfactorily resolved all issues concerning this incidence.
Thank you for your communication and cooperation in resolving this matter. Should you have any
questions regarding these matters, please contact Tim Fox at [phone] or
tim.fox(cr)ncdenr.gov .
Sincerely
t
Tim Fox
Environmental Specialist
Surface Water Protection Section
cc: Laura Herbert — DEMLR (ecopy)
Clement Riddle - C1earWater Environmental Consultants, Inc. (ecopy)
ARO File Copy
SURFACE WATER PROTECTION SECTION-ASHEVILLE REGIONAL OFFICE One
Location; 2090 U.S. Highway 70, Swannanoa, North Carolina 28778 North Carolina
Phone: [phone]M FAX: [phone] Internet: www.ncwaterquality.org v
An Equal Opportunity l Affirmative Actien Employer /�VaL}ura!!ff

cluear Ler
C1earWater Environmental Consultants, Inc.
www.cwenv.com
August 28, 2013
Mr. Tim Fox
NC Division of Water Quality
2090 US Highway 70
Swannanoa, North Carolina 28778
RE: Sediment Removal
Horsehead Corporation
Rutherford County, North Carolina
Dear Mr. Fox,
Horsehead Corporation notified the North Carolina Division of Water Quality (DWQ) on May 23,
2013 regarding excessive rainfall (2.9 inches) and release of sediment into an unnamed tributary to the
Broad River and an adjacent wetland. A site visit with Tim Fox, Division of Water Quality and
Darlene Kucken, Division of Land Quality, occurred on -site June 11, 2013. The stream and wetlands
on site are located north of Hicks Grove Road in Rutherford County, North Carolina. C1earWater
Environmental Consultants, Inc. (CEC) attended this inspection and provided an evaluation of the
impact to the streams and wetlands that received the sediment. A remediation plan was submitted and
approved by the DWQ. The DWQ requested a final report be submitted after remediation activities
were complete at the site.
Mountain Environmental represented by Mr. David Walker conducted remediation activities
according to the submitted plans over 3 days during the week of July 8, 2013. Accumulated sediment
was removed using a sediment vacuum loader and hand -labor. Sediment was skimmed from the
surface of the wetland and in the stream until native material was found. Approximately 137 tons of
sediment was removed from the wetland and stream channel. The sediment has been spread in an
upland area on the road adjacent to the area of impact. The road is currently being graded and has silt
fencing between it and the wetland and stream areas. Mr. Kevin Mitchell (CEC) conducted a final site
inspection on July 23, 2013. A wetland seed mix was also spread on August 12, 2013 to promote
vegetative stability. Representative before and after photographs of the site are included in
Attachment A.
It is the opinion of CEC that remediation activities at the site are complete. CEC respectfully requests a
letter of concurrence be sent to the Horsehead Corporation resolving this matter. Should you have any
questions or comments concerning this project please do not hesitate to contact me at 828-698-9800.
Sincerely,
Kevin Mitchell RECEIVED R. Clement Riddle, P.W.S.
Project Biologist Principal
AUG 2 92013
224 South Grove Street, Suite F
Hendersonville, NC 28792 DWQisurrace water Protection Section
828-698-9800 Tel Asheville Re final Office
828-698-9003 Fax

Photo 1. A2. Note sediment accumulation in the wetland.
Photo 2. A2. Noted sediment has been removed.
Appendix A Representative Photographs

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1-.ref ���.°3� 1 :: � % ��ti �''� v'�•, "*� 'zt
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Photo S. A6. Note sediment in foreground.
Photo 6. A6. Noted sediment has been removed.
Appendix A Representative Photographs

1Oh I :
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AM

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C�eear aLer
ClearWater Environmental Consultants, Inc.
www.ewenv.com
June 13, 2013
Mr. Tim Fox
NC Division of Water Quality
2090 US Highway 70
Swannanoa, North Carolina 28778
RE: Sediment Removal
Horsehead Corporation
Rutherford County, North Carolina
Dear Mr. Fox,
RECEIVED
JUN 1 9 2013
T)Wolsurfhee water Pmftction Sec6w
Asheville Regkonalf Officc,
Horsehead Corporation notified the North Carolina Division of Water Quality (DWQ) on
May 23, 2013 regarding excessive rainfall (2.9 inches) and release of sediment into an
unnamed tributary to the Broad River and an adjacent wetland. A site visit with Tim
Fox, Division of Water Quality and Darlene Kucken, Division of Land Quality, occurred
on -site June 11, 2013. The stream and wetlands on site are located north of Hicks Grove
Road in Rutherford County, North Carolina. ClearWater Environmental attended this
inspection and provided their evaluation of the impact to the streams and wetlands that
received the sediment. The following activities are recommended by Clearwater
Environmental to remove the sediment from the affected areas.
1. The impacted areas consist of a wetland (Area A) and an unnamed tributary to
the Broad River (Area B). A USGS topographic map indicating the area of
impact is included for review (Figure 1). It is the opinion of ClearWater
Environmental Consultants, Inc. (CEC) that approximately 1,529 linear feet of
stream channel below Area A has been impacted by sediment.
2. CEC observed sediment deposition that varied from 4-12 inches in an
unnamed tributary to the Broad River and from 1-1 b inches in 'adjacent
wetlands. Sediment will be removed from the stream and wetlands using
shovels and buckets for a distance of approximately 1,529 linear feet.
Portions of the wetlands have sediment deposition approximately 2-3 inches
or less. Wetland systems are capable of handling some sediment
accumulation, and CEC advises sediment removal from a wetland only if the
accumulation is such that the wetland system is essentially unable to recover
through natural processes. In the wetlands area, the vegetative diversity is
224 South Grove Street, Suite F
Hendersonville, NC 28792
828-698-9800 Tel
828-698-9003 Fax

• i
Mr. Tim Fox
06/ 13/2013
Page 2 of 3
currently so abundant that CEC advises against heavy machinery methods to
remove sediment which could destroy this rich plant community. After
sediment removal, CEC recommends spreading a wetland native seed mixture
on the areas with sediment accumulation throughout the approximately 0.20
acre wetland. Sediment removal will begin at the upstream wetland (Area A)
and will continue downstream through area B. ClearWater Environmental
Consultants, Inc. will be on site periodically to provide oversight during the
sediment removal process. The number of buckets will be recorded to
estimate the amount of sediment removed from the three areas. Sediment
removed from the streams and wetland areas will be hand carried in buckets
and placed in upland locations and stabilized.
Horsehead Corporation is also researching the use of a vacuum truck to
remove sediment from the stream and wetland areas. The vacuum method
removes the fine sediments, while leaving in place most original stream
cobble and larger particle sizes in the substrate. If this method proves feasible
from an access and operation evaluation, then then vacuum truck would be the
preferred method of sediment removal from the stream and wetlands.
Sediment collected in the vacuum truck will be disposed of in an upland area
and stabilized.
3. Sediment removal, as outlined above, will begin immediately above approval
and a final report will be submitted within 45 days of plan approval.
4. Representative photographs of the site prior to the clean-up are attached for
review (Attachment A). Photographs after clean-up will be included in the
final report.
5. Prior to sediment removal, two coir logs will be staked into the stream channel
at different locations at the downstream end of the removal area and act as
temporary sediment dams during the removal process. Sediment removal will
be conducted upstream to downstream. Sediment that is re -suspended during
the cleanout process will collect behind the logs. Sediment caught by the coir
logs will be cleaned out last. There may be a short term minor increase in
turbidity during remediation activities. However, turbidity levels should
return to normal quickly following remediation activities.
6. A final report will be submitted to Tim Fox upon completion of the sediment
removal.
Horsehead Corporation and C1earWater Environmental are aware of the presence of the
federally threatened dwarf flowered heart -leaf (Hexastylis naniflora) adjacent to the
stream. Precautions will be taken to identify the plant and to train workers to avoid them

0
•
Mr. Tim Fox
06/13/2013
Page 3 of 3
during the sediment removal process. Please do not hesitate to contact me at 828-698-
9800 if you have any questions or comments.
Sincerel ,
iRClement Ri dle, P.W.S.
Principal

0
•
Mr. Titre Fox
06/13/2013
Page 2 of 3
currently so abundant that CEC advises against heavy machinery methods to
remove sediment which could destroy this rich plant community. After
sediment removal, CEC recommends spreading a wetland native seed mixture
on the areas with sediment accumulation throughout the approximately 0.20
acre wetland. Sediment removal will begin at the upstream wetland (Area A)
and will continue downstream through area B. ClearWater Environmental
Consultants, Inc. will be on site periodically to provide oversight during the
sediment removal process. The number of buckets will be recorded to
estimate the amount of sediment removed from the three areas. Sediment
removed from the streams and wetland areas will be hand carried in buckets
and placed in upland locations and stabilized.
Horsehead Corporation is also researching the use of a vacuum truck to
remove sediment from the stream and wetland areas. The vacuum method
removes the fine sediments, while leaving in place most original stream
cobble and larger particle sizes in the substrate. If this method proves feasible
from an access and operation evaluation, then then vacuum truck would be the
preferred method of sediment removal from the stream and wetlands.
Sediment collected in the vacuum truck will be disposed of in an upland area
and stabilized.
3. Sediment removal, as outlined above, will begin immediately above approval
and a final report will be submitted within 45 days of plan approval.
4. Representative photographs of the site prior to the clean-up are attached for
review (Attachment A). Photographs after clean-up will be included in the
final report.
5. Prior to sediment removal, two coir logs will be staked into the stream channel
at different locations at the downstream end of the removal area and act as
temporary sediment dams during the removal process. Sediment removal will
be conducted upstream to downstream. Sediment that is re -suspended during
the cleanout process will collect behind the logs. Sediment caught by the coir
logs will be cleaned out last. There may be a short term minor increase in
turbidity during remediation activities. However, turbidity levels should
return to normal quickly following remediation activities.
6. A final report will be submitted to Tim Fox upon completion of the sediment
removal.
Horsehead Corporation and C1earWater Environmental are aware of the presence of the
federally threatened dwarf flowered heart -leaf (Hexastylis naniflora) adjacent to the
stream. Precautions will be taken to identify the plant and to train workers to avoid them

I A
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Photo 5. Station A9. Sediment accumulation of 4-6 inches to be removed.
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Photo 6. Station Al 1. Sediment deposition on left side of channel (looking
downstream).

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13 0,:M.

Beverly Eaves Perdue
Governor
May 9, 2012
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Charles Wakild, P.E.
Director Dee Freeman
Secretary
Mr. James M. Hensler, President and CEO
Horsehead Corporation
4955 Steubenville Pike, Suite 405
Pittsburgh, PA 15205
SUBJECT: NOTICE OF VIOLATION
Horsehead Corporation — Rutherford County, NC Facility
DWQ Tracking Number: NOV-2012-PC-0153
Construction Stormwater Permit NCGO10000
Stream Standard Violation - Other Waste (In -stream sediment)
Rutherford County -
Response deadline: June 11, 2012
Dear Mr. Hensler:
On April 19, 2012, Susan A. Wilson and Tim Fox, from the Asheville Regional Office of the
Division of Water Quality (DWQ), conducted a site inspection at Horsehead Corporation off US
Highway 221 S in Rutherford County, North Carolina. Ms. Carol Owens, Mr. Lance Davis, and
Mr. Jay Woodward were also present, and Mr. Woodward guided staff through the site.
Construction Stormwater Permit NCGO10000 and stream standard violations were noted during
the inspection and file review. Sediment impacts to an unnamed tributary to the Broad River, a
Class C stream in the Broad River Basin, were documented.
As a result of the site inspection and file review, the following violations were identified:
VIOLATIONS
L Construction Stormwater Permit NCG010000 - A Construction Stormwater Permit
(NCG010000) is issued upon the approval of an Erosion and Sedimentations Control
Plan for sites greater than one acre.
a. Approved Plan (Part I. Section A: No. 2.) During DWQ's site inspection, a copy
of the approved Erosion and Sediment Control Plan was on site and available for
SURFACE WATER PROTECTION SECTION—ASHEVILLE REGIONAL OFFICE One
Location: 2090 U.S. Highway 70, Swannanoa, North Carolina 28778 NorthCarolina
Phone: [phone]M FAX: B28-299-7043 Internet: www.newaterquaijty.org Natural&

Mr. Hensler
May 9, 2012
Page 2 of 4
•
review (Odom Engineering S&EC Plan). However, Ms. Owen did not have an
approved site plan for the McGill and Associates area.
DWQ is unsure of the coordination between all entities at the site and suggests that
this be improved (and clarified for DWQ). DWQ is also unsure if a modified plan
was approved for the road along the railroad track at the time of inspection.
b. BMPs and Control Measures (Part I. Section A. No. 2) Failure to maintain BMPs
and control measures that minimizes pollutants, represents a violation of
NCGO10000 Permit. DWQ observed measures that had been affected by the rain
storm during the previous 24 hours, which likely had caused the sediment
deposition to the unnamed tributary and wetland area. Representatives from the
Division of Land Resources (DLR) were not present during the day of the DWQ
inspection, so Horsehead Corporation has not been cited for failure to maintain
measures (and Horsehead site representatives were in the process of repairing
measures). DWQ will coordinate with DLR at a future date to inspect the site
again.
II. Stream Standard. Violation - Other Waste (In -stream sediment) 15A NCAC 02B .0211
(3)f - Approximately 2080 feet of an unnamed tributary to the Broad River was impacted
by sediment deposition in pockets and throughout the stream reach, representing Water
Quality Stream Standard violation of 15A NCAC 02B .0211 (3) (f). A small area of
wetlands was also impacted by sediment (it should be confirmed if sediment entered the
delineated wetland area).
REQUIRED RESPONSE
The DWQ requests that you respond by June 11, 2012. Your response should be sent to the
attention of Ms. Susan A. Wilson, Division of Water Quality, 2090 US HWY 70, Swannanoa, NC
28778 and should address the following items:
1. Construction Stormwater Permit NCG010000
a. Please explain when you anticipate being in full compliance with the NCG010000
Permit. Please also explain which entity will take responsibility for stormwater
inspection and monitoring, etc. DWQ suggests better coordination between all
parties on -site.
b. You should include in your response an explanation of why proper operation
and maintenance of stormwater measures was not performed to optimum
efficiency and how you propose to prevent these problems from reoccurring
on this project and on future projects.

MHensler •
May 9, 2012
Page 3 of 4
2. Stream Standard - Other Waste (In -Stream Sediment)
a. Please provide a map of the project area. The map must include all streams and
wetlands, detailing impacts both on- and off -site.
b. Please submit a Sediment Removal Plan (Plan) to this office for review and
approval. The Plan must address removal of accumulated sediment from all surface
waters. You must secure an environmental consultant experienced in stream
restoration to assist you with developing your Plan, and obtaining any necessary
approvals. It is recommended that your consultant contact Tim Fox or Susan
Wilson of the Asheville Regional Office for additional guidance during Plan
development. The Plan should include:
• A narrative explaining how sediment will be removed; including, techniques,
manpower and tools to be used.
• A proposed schedule with dates that indicate when you expect to begin and
complete the removal of sediment.
• A diagram of the stream channel, referenced with photo documentation of
sediment impacts before and after removal.
• A narrative explaining how and where the removed sediment will be disposed
and stabilized.
Please explain how turbidity standards will not be exceeded.
c. Once the work is complete, a final report documenting the results of the sediment
removal activities should be submitted to Mr. Fox.
The Division reminds you that Section II.13.1(f) of the construction stormwater permit requires
that you report to DWQ any visible sediment being deposited in any stream or wetland.
Thank you for your attention to this matter. This office requires that the violations, as detailed
above, be abated immediately. These violations and any future violations are subject to a
civil penalty assessment of up to $25,000.00 per day for each violation.

Mr_ Hensler •
May 9, 2012
Page 4 of 4
Should you have any questions regarding these matters, please contact Ms. Wilson or Mr. Fox at
[phone] or (susan.a.wilsonr�ncdenr.Rov or tim.fox ncdenr. ov ).
Sincerely,
Chuck Cranford, Regional Supervisor
Surface Water Protection
Asheville Regional Office
Eric: Inspection Report
cc: Karen Higgins - WeBSCaPU
ARO File Copy
Laura Herbert - Division of Land Resources
Lance Davis - S&ME
David Odom - Odom Engineering
Mark Cathey - McGill and Associates
S:ISWPIRutherford\StormwaterWCGOI ConstructionlHorsehead CorpWOV-2012-PC-0153.Horsehead.4 2012.doc

0 0
Site Inspection Report
Site Number: WT000075
Site Name: Horsehead Site
Site Address: 347 Hicks Grove Rd
County: Rutherford
Directions: off US Hwy 221 and Hicks Grove Rd., near Rutherfordton
Latitude:
Site Owner Name: Horsehead Holding Corporation
Inspection Date: 04/19/12
Reason for Inspection: Routine
Inspection Type: Site Inspection (non -DOT)
Inspection Contact Person -
On -Site Representative(s):
Primary Inspector: Susan A Wilson
Secondary Inspector(s):
Timothy R Fox
Facility compliance Status: Q Compliant
Program Area: Construction SW (NCG010000)
Question Areas:
0 NCG010000 Permit
Region: Asheville
Longitude:
Not Compliant
Phone:
Phone: [phone]
Phone: [phone]
Page: 1

• 0
Site Number: WT000075 Owner: Horsehead Holding Corporation
Inspection Date: 04/19/12 Inspection Type: Site Inspection (non -DOT) Reason for Visit: Routine
Inspection Summary:
Susan Wilson and Tim Fox (DWQ) met Lance Davis, Carol Owens, and Jay Woodward (S&ME) on site April 19, 2012. Mr. Woodward
performed his site inspection with us. The facility had 2 inches of rain on the day/night prior to the inspection.
The site was compliant with DLR during their prior inspection. However, the site did not appear to be compliant with measures at the
time of DWQ's inspection 4/19/2012. A follow-up site inspection will be conducted by DLR and DWQ in May.
No E&SC plan was on site for the road leading to the Broad River (however, the plan for the project area was on -site). There seemed
to be some disconnect regarding the approved site plans. S&ME had Odom Engineering's approved site plans, but had not received
McGill's site plans for the road/utilities down to the Broad River.
Records and rainfall recording appeared to be well kept.
Sediment was observed in the northeast tributary (nearest the utlity access road and RR tracks) from near the wetland area to the
Broad River (appx. 2080 ft). A small amount of sediment was observed in the wetland area. The silt fence in the area appeared to be
breached/co mpromised after the previous day's rain event.
The northwest tributary appeared turbid - and the measures near the headwater of the tributary appeared inadequate. Should these
measures not be improved, headcuts will become more pronounced and will result in continued erosion of the tributary.
The southeast pond (owned by Horsehead) continues to act a sediment trap. Horsehead may wish to consider sediment removal of
this pond/basin to ensure no sediment is released to the downstream pond owner.
Page: 2

Ai2i
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Charles Wakild, P. E.
Beverly Eaves Perdue Director
Governor
June 19, 2012
Mr. James M. Hensler, President and CEO
Horsehead Corporation
4955 Steubenville Pike, Suite 405
Pittsburgh, PA 15205
Subject: NOV Incident Closure
Horsehead Corporation — Rutherford County, NC Facility
DWQ Tracking Number: NOV-2012-PC-0153
Construction Stormwater permit — NCG010000
Rutherford County
Dear Mr. Hensler:
Dee Freeman
Secretary
The Division of Water Quality (DWQ) has received the Response to the Notice of Violation letter
sent on May 9, 2012 related to the Notice of Violation (NOV-2012-PC-0153) at the Horsehead
Corporation site in Rutherford County NC.
DWQ has reviewed the information provided and conducted a follow-up site visit on June 8, 2012
(along with Darlene Kucken, Division of Land Resources). The written response and the results
observed at the site have satisfactorily resolved the violations noted in the subject NOV. As a result
of the inspection it has been determined that no clean up will be required. The NOV sent on May 9,
2012 will be closed out.
This letter in no way precludes this office from taking action on this or any other violation.
Violations are subject to civil penalty assessment of up to $25,000.00 per day for each
violation.
Thanks to Tim Basilone, Vice President of Environmental Affairs for Horsehead Corporation,
Forrest Westall and Mark Cathey of McGill and Associates for meeting with us and improving
communication with this project. If you have any additional questions please contact Tim Fox at
[phone].
Sincerely, `
Tim Fox
Environmental Specialist
Surface Water Protection Section
SURFACE WATER PROTECTION SECTION - ASHEVILLE REGIONAL OFFICE One
Location: 2090 U.S. Hghway 70, Swannanoa, North Carolina 28778 NorthCarohna
Phone: [phone] FAX [phone]
Internet: www.ncwaterquality.org ;Vatmrally
An Equal Opportunity i Afrmat ve Action Em*yer

cc: Karen Higgins - WeBSCaPU
ARO File Copy
Laura Herbert — Division of Land Resources
Timothy R Basilone — Horsehead Corporation
Forrest Westall- McGill and Associates
Mark Cathey- McGill and Associates
Jay Stewart -- McGill and Associates
David Odom — Odom Engineering
SS:ISWP1RutherfordlStormwaterlNCG01 Construction\Horsehead Corp1CLO.Horsehead.06-11-12.docx

ZOW
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Charles Wakild, P. E.
Beverly Eaves Perdue Director Dee Freeman
Governor Secretary
June 14, 2012
Mr. James M. Hensler, President and CEO
Horsehead Corporation
4955 Steubenville Pike, Suite 405
Pittsburgh, PA 15205
Subject: NOV Incident Closure
Horsehead Corporation — Rutherford County, NC Facility
DWQ Tracking Number: NOV-2012-PC-0153 �8 ]
Construction Stormwater permit — NCG010000
Rutherford County
04
Dear Mr. Hensler:
The Division of Water Quality (DWQ) has received the response to the(NOV)etter sent on May 9,
2012 related to the Notice of Violation (NOV-2012-PC-0153) at Horsehead Corporation site in
Rutherford County NC.
DWQ has reviewed the information provided and conducted a follow-up site visit on June 8, 2012
(along with Darlene Kucken, Division of Land Resources). The written response and the results
observed at the site have satisfactorily resolved the violations noted in the subject Noti�a .oJ oV.
V4oiatiun. As a result of the inspection it has been determined that no clean up will be required.
The NOV sent on May 9, 2012 will be closed out.
This letter in no way precludes this Office #9taking action on this or any other violation.
Violations are subject to civil penalty assessment of up to $25,000.00 per day for each
violation.
Thanks to Tim Basilone, Vice President of Environmental Affairs for Horsehead Corporation,
Forrest Westall and Mark Cathey of McGill and Associates for meeting with us and improving
communication with this project. If you have any additional questions please contact Tim Fox at
[phone].
Sincerely,
Tim Fox
Environmental Specialist
Surface Water Protection Section
SURFACE WATER PROTECTION SECTION — ASHEVILLE REGIONAL OFFICE
Location: 2090 U.S. Highway 70, Swannanoa, North Carolina 28778
Phone: [phone]M FAX: [phone]
Internet: www.nc,vaterquality.org
An Fqua1 Opporftlnity 1 Affirmative Action E nployer
None
rthCarolina
Naturally
f I

0 0
cc: Karen Higgins - WeBSCaPU
ARO File Copy
Laura Herbert -- Division of Land Resources
Timothy R Basilone — Horsehead Corporation
Forrest Westall- McGill and Associates
Mark Cathey- McGill and Associates
Jay Stewart — McGill and Associates
David Odom Odom Engineering
SS:ISWP1Rutherford\Stormwater\NCG01 ConstructionlHorsehead Corp\CLQ.Ho€sehead.06-11-12.docx

• 0
Site Number: VVT000075 Owner: Horsehead Holding Corporation
Inspection Date: 04/18/12 Inspection Type: Site Inspection (non -DOT) Reason for Visit: Routine
NCGO10000 Permit
# Is this inspection related to a DLRldelegated program inspection?
If Yes, what was the DLR/delegated program inspection date?
Is the site following its E&SC Plan as per DLR or delegated program? yt
Is the site maintaining their E&SC measures as per DLR or delegated program? y7
Is a copy of the approved E&SC plan on site?
Is a rain gauge present on -site or is MPE in use for the site?
Is rain gauge data or MPE data recorded?
Are inspection records complete?
Is the site compliant with other conditions of the NCG010000 permit?
Comment:
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Page: 2

•
Site Inspection Report
Site Number: WT000075
r
Site Name: , Horsehead Site
Site Address: '347 Hicks Grove Rd
County: Rutherford Region: Asheville
Directions: off US Hwy 221 and Hicks Grove Rd., near Rutherfordton
Latitude: Longitude:
Site Owner Name: Horsehead Holding Corporation
Inspection Date: 04/18/12
Reason for Inspection: Routine
Inspection Type: Site Inspection (non -DOT)
/ Inspection Contact Person: Phone:
r
Can -Site Representative(s):
Primary Inspector: Susan A Wilson Phone: [phone]
Secondary Inspector(s):
Facility compliance Status: Compliant. Q Not Compliant
Program Area: Construction SW (NCG010000)
Question Areas:
NCG010000 Permit
Inspection Summary:
c
.S, _ v�
v N
(41 v,
w Page: 1
r
..1:+'e

Rutherford Co, NC -- Printabl4up
Page 1 of 1
Rutherford County, NC
DISCLAIMER: The information contained on this page is NOT to be construed or used as a "legal description". Map information is
believed to be accurate but accuracy is not guaranteed.
Parcels
Tax PIN: 1619999
No. of Bldgs: 0
Map/Blk/Lot: 300 1 15
Apt nbr:
GPIN: 1543009804460000
Deed Bk/Pg: 1029/634
Nbr Land Seg.: 2
Account No.: 15250203
Deed Date: 9/19/2011., .
Stamps:
Owners Name1: HORSEHEAD CORP
Land Value: $214,400 I'.
Land Use:
Owners Name2: r
Bldg. Value: $0 ' ,
Township Code: 13
Addressl: 4955 STEUBENVILLE PIKE
Defr. Value: $0,
Exempt_pro:
Address2: SUITE 405 I/
Total Value: $214,400 `
Exempt_amt: 0
1 `
City: PITTSBURGH
Sale Price: $0
Flood Plain:
State: PA
✓
Neighborhood Code: A31M
St nbr: 347
Zip: 15205
Neighborhood Desc.: AVERAGE
St dir:
Property Address: 347 HICKS GROVE
RURAL
St name: HICKS
RD
Property Desc.: SR 1113
GROVE
Acres: 199.37
Zoning:
St -suffix: RD
Other Attributes
at point 1149106, 538855
Fire Districts:
None
Sheet Index:
Tile: 1543
Townships:
:: SULPHER SPRINGS
Voter Districts:
:: Name field not found.
�j Watersheds:
None
hhoalw ow webais.net Anderson & Associates, Inc. htto:8www.andassoc.com ,
http://arcims.webgis.net/nc/rutherford/printable2.asp'
tV
12/29/2011

rJ
Wilson, Susan A
From: Kucken, Darlene
Sent: Wednesday, December21, 2011 3:20 PM
To: Wilson, Susan A; Koontz, Charles; Parker, Mike
Subject: horsehead pond complaint
1 just spoke with Howard Parris - 828-248-2464 and 7061 US Hwy 221 S, Mooresboro NC
28114.
This is the owner of the turbid pond below Horsehead Corp. project that Susan and i
checked out on 12119. Neither of us could see that Horsehead was the culprit to his
turbid pond at the time we were out there. Horsehad likely contributes some turbidity
(not sediment) from a sediment basin. But DOT work appears to be the major contributor
of stormwater and turbidity. The additional stormwater across the Harris property is
causing erosion and therefore turbid water. In addition, Mr. Harris says that when it
rains there is artesian type water that he feel sis coming from a buried pipe from across
the railroad tracks. He is still upset about his turbid water and wants them to clean it
up.
Mr. Harris is also very concerned, and has talked to DOT engineer, about the new
driveway and that DOT cannot dump the stormwater off this driveway into his pond. He's
hoping he can get support from us to talk with DOT about this. Mr. Harris reports that his
emergency spillway has engaged 3 times in the last couple months and before the DOT
work it almost never engaged. So more water•from the new driveway is very much a
concern to him.
f�
Darlene Kucken - Darlene.KuckenPncdenr.eov
North Carolina Dept. of Environment and Natural Resources ,
Asheville Regional Office
Division of Land Resources, Land Quality Section t:
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and
may be disclosed to third parties.
`,. Go Green! Print this email only when necessary. Thank you for helping NCDENR be environmentally responsible.

Wilson, Susan A
From:
Parker, Mike
' Sent:
Friday, December 09, 2011 7:35 AM
To:
Wilson, Susan A
Cc:
Kucken, Darlene
Subject:
Sediment from Horsehead Corporation
Ladies, NCDOT reps. have advised me that approximately two weeks ago a large amount of sediment was lost from the
Horsehead Corporation site. Enough to fill a small pond off site and sediment made its way to a DOT culvert. Darlene
was going to look at this on December 8 or next week. Mike
Mike Parker - Mike. Parker@ncdenr,gov
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Surface Water Protection
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
1

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Aiken, Stan E
From:
Harris James <[e-mail]>
Sent:
Thursday, October 06, 2016 4:31 PM
To:
Davidson, Landon; Aiken, Stan E; Scott, Chris
Cc:
Burch, Brent; Menzel, Jeff
Subject:
Change in General Manager
For your information, we have changed our General Manager at the Horsehead Mooresboro facility. Anthony Staley's
last workday at the Mooresboro facility was last Thursday. Our new General Manager is Rob Williamson.
What do we need to do to reflect this change of Responsible Person on our permits? I am currently working with Bob
Sledge to change our eDMR reporting process to include Rob Williamson.
Also, are there other departments with NC DEQ that I should contact and provide this information?
Thanks,
Jim Harris I Environmental Manager
Horsehead Metal Products, LLC
KQ F ti E; H E:A D,
METAL PRODUCTS, INC.
484 Hicks Grove Road, Mooresboro North Carolina 28114
C: 828-748-5283 1 P: 828-919-3139
jharrisCa7horsehead.net
0