NCG030181_COMPLETE FILE - HISTORICAL_20020619

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT N0.
NUG 03 0
DOC TYPE
STORICAL FILE
❑ MONITORING REPORTS
DOC DATE
0 C76 ba Q (0 G I
YYYYMMDD

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Alan W. Klimek, P.E., Director
June 19, 2002
Mr. Al Metzger
Southern Steel Company, LLC
12933 Sam Neely Road
Charlotte, North Carolina 28241
4 11111111
IT
A2
NCDENR
NORTH CAROLINA C)EPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: NPDES Permit Modification — Name/Ownership Change
Permit NCG030181
Southern Steel Company LLC
(Formerly Valmet Paper Machinery, Inc.)
Mecklenburg County
Dear Mr. Metzger;
In accordance with your request received May 24, 2002, the Division is forwarding the subject permit
modification. This modification documents the change in name at the subject facility. All other terms and
conditions in the original permit remain unchanged and in full effect. This permit modification Is Issued under the
requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North
Carolina and the U. S. Environmental Protection Agency dated December 6, 1983.
If any parts, measurement frequencies or sampling requirements contained in this permit modification are
unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty (30) days
following receipt of this letter. This request must be a written petition conforming to Chapter 150B of the North
Carolina General Statutes, filed with the Office of Administrative Hearings, 6714 Mail Service Center, Raleigh,
North Carolina 27699-6714. Unless such demand is made, this decision shall be final and Finding.
This permit does not affect the legal requirement to obtain other permits which may be required by the
Division of Water Quality, the Division of Land Resources, Coastal Area Management Act, or any other Federal or
Local government permit that may be required. If you have any questions concerning this permit, please contact
Valery Stephens at the telephone number or address listed below.
Sincerely,
NC DEPT. OF ENVIRONMENT �
.p G
OFFICE
tom" ,f„
an W. Klimek, P.E.,
JUN 2 5 2002
cc: Central Files
CMooresville) Regional Office, Water Quality Section
NPDES Unit
I JOIN
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
919 733.5083, extension 520 (fax) 919 733.0719
VISIT US ON THE INTERNET @ hhpJ/h2o.enr.state.nc.us/ Valery,Stephens Oncmailnet

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG030000
CERTIFICATE OF COVERAGE No. NCG030181
Sl'ORMWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the
Federal Water Pollution Control Act, as amended,
Southern Steel Company, LLC
Is hereby authorized to discharge stormwater from a facility located at
Southern Steel Company, LLC
12933 Sam Neely Road
Charlotte
Mecklenburg County
to receiving waters designated as unnamed tributary to Steele Creek, a class C water in the Catawba River Basin
in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II,
III, IV, V, and VI of General Permit No. NCG030000 as attached.
This certificate of coverage shall become effective June 19, 2002.
This Certificate of Coverage shall remain In effect for the duration of the General Permit.
Signed this day June 19, 2002.
uL4-�
�41an W. Klimek, P.E., Director
Division of Water Quality
By Authority of the. Environmental Management Commission

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Alan W. Klimek, P,E. Director
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
ATTN: JOHN C DUNNINGTON
VALMET-CHARLOTTE
12933 SAM NEELY RD
CHARLOTTE, NC 28278
Dear Permittee:
ALTT4'w A
. Av
0
NCDENR
ENV;RONMENT ANo NATURAL RESOURCES
06/06/2002 - -
e
-J U N 2 5 2002
Subject: NOTICE OF VIOLATION 1''a ` ` ' "' °' ` mod' ' 6�
FAILURE TO SUBMIT RENEWAL APPLICATION
VALMET-CHARLOTTE
NCG030000
COC NUMBER NCG030181
MECKLENBURG COUNTY
This letter is to inform you that, as of the date of this letter, the Division of Water Quality has not received a
renewal request for the subject permit certificate of coverage. This is a violation of NCGS §143.215.1 (c)(1) which
states "All applications shall be filed with the commission at least 180 days in advance of the date on which it is
desired to commence the discharge of wastes or the date on which an existing permit expires, as the case may be".
Any permittee that has not requested renewal at least 180 days prior to expiration or permittee that does not have a
permit after the expiration and has not requested renewal at least 180 days prior to expiration, will be subjected to
enforcement procedures as provided in NCGS §143-215.6 and 33 USC 1251 et. seq.
In order to prevent continued, escalated action, including the assessment of civil penalties you must submit a
completed permit coverage renewal application to the attention of the "Stormwater and General Permits Unit" at
the letterhead address within ten (10) days of your receipt of this letter (renewal application enclosed). If the
subject discharge has been terminated, please complete the enclosed rescission request form. Mailing instructions
are listed on the bottom of the form. You will be notified when the rescission process has been completed.
Thank you for your prompt attention to this situation. If you have any questions regarding this matter, please
contact Mack Wiggins of the central office Stormwater and General Permits Unit at 919-733-5083, ext. 542.
Sincerely,
for Alan W. Klimek, P.E.
Director, Division of Water Quality
cc: Stormwater and General Permits Unit Files
Central Files
Mooresville Regional Office
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

�0� W A T�C9Q
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
JOHN C DUNNINGTON
VALMET
12933 SAM NEELY RD
CHARLOTTE, NC 28278
Dear Permittew
December 27, 2001
Gregory J. Thorpe, Ph.D.
Acting Director
Division of Water Quality
APR 1 0 2002
Subject: NPDES Stormwater Permit Renewal
VALMET _
COC Number NCG030181 ;"„ -� ;'y .,;'„�;-',.� y i '� 1 ;4J #�
Mecklenburg County
Your facility is currently covered for stormwater discharge under General Permit NCG030000, This permit expires
on August 31, 2002. The Division staff is currently in the process of rewriting this permit and is scheduled to have
the permit reissued by late summer of 2002. Once the permit is reissued, your facility would be eligible for
continued coverage under the reissued permit.
In order to assure your continued coverage under the general permit, you must apply to the Division of Water
Quality (DWQ) for renewal of your permit coverage. To make this renewal process easier, we are informing you in
advance that your permit will be expiring. Enclosed you will find a General Permit Coverage Renewal
Application Form. The application must be completed and returned by March 4, 2002 in order to assure continued
coverage under the general permit.
Failure to request renewal within this time period may result in a civil assessment of at least $250.00. Larger
penalties may be assessed depending on the delinquency of the request. Discharge of stormwater from your facility
without coverage under a valid stormwater NPDES permit would constitute a violation of NCGS 143-215. l and
could result in assessments of civil penalties of up to $10,000 per day.
Please note that recent federal legislation has extended the "no exposure exclusion" to all operators of industrial
facilities in any of the I 1 categories of "storm water discharges associated with industrial activity," (except
construction activities). If you feel your facility can certify a condition of "no exposure", i.e. the facilty industrial
materials and operations are not exposed to stormwater, you can apply for the no exposure exclusion. For additional
information contact the Central Office Stormwater Staff member listed below or check the Stormwater & General
Permits Unit Web Site at http://h2o.enr.state.nc.us/su/storinwater.littnl
If the subject stormwater discharge to waters of the state has been terminated, please complete the enclosed
Rescission Request Form. Mailing instructions are listed on the bottom of the form. You will be notified when the
rescission process has been completed.
If you have any questions regarding the permit renewal procedures please contact Mike Parker of the Mooresville
Regional Office at 704-663-1699 or Bill Mills of the Central Off ice Stormwater Unit at [phone], ext. 548
Sincerely,
11.tC CSLey t 5v,. PVK?
Bradley Bennett, Supervisor
Stormwater and General Permits Unit
cc: Central Files
Mooresville Regional Office
T
NCDCNR
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone] Customer Service
1- 800-623-7748

July 17, 2008
Ms. Marcia Allocco
North Carolina Division of Water Quality
Mooresville Regional Office
610 East Center Avenue, Suite 301
Mooresville, North Carolina 28115
CERTIFIED tNAI•L$ 21,11,$
7003 2260 0005 6847 9072
NC DENR MRO
DWQ-Surface Water 'P,otect;on
SUBJECT: May 23, 2008, Compliance Inspection Report for Southern Steel Company, LLC,
Sam Neely Road, Charlotte, North Carolina, Certificate of Coverage Number
NCG030181
Dear Ms. Allocco:
On behalf of Southern Steel Company, LLC, I'd like to thank Ms. Heather Sorensen and
Ms. Erin Hall for taking the time to review our operations with respect to the stormwater general
permit and to provide their insight to help ensure full compliance with all applicable
requirements. I offer this response in accordance with Mr. Robert B. Krebs' June 23, 2008,
request.
• Compliance Inspection Report (CIR) page 2 states, "(t)he permittee shall investigate
methods to reduce stormwater contamination from this area of the facility including
removal of the connection between the trench drains and the stormwater system." CIR
page 6 restates concerns regarding the trench system.
Removal of the trench / stormwater drainage connection may adversely affect water
quality. Removal would likely cause prolonged contact of metal shavings / cuttings with
standing water. This prolonged contact would likely increase the potential for metal
rusting. In North Carolina, it is unlikely that water in the trench would evaporate so that
a trench overflow would be avoided. Removal of the trench system would likely increase
water contamination, creates a standing water nuisance and would not eliminate the
potential for storm water discharges from this area.
In addition to considering isolation of the trench, (1) improving housekeeping in the drill
house and saw house and (2) employing solid controls were investigated. It seems
obvious that the best solution is to improve housekeeping to avoid drill shavings and saw
cuttings from entering the trench system rather than filtering them out after they enter the
trench. It should be noted that no metal shavings were observed at the outfall.
For this reason, we intend to focus on improving housekeeping in these areas including
implementing a Weekly Stormwater Best Management Practices (BMP) Inspection (see
form enclosed). rA&eta International
SOUTHERN STEEL_ • LYNCHBURG STEEL • CAROLINA REBAR
12933 Sam Neely Road • Charlotte, North Carolina, 26273 • Phone[phone] • Fax:[phone] • www.betainternational.com
Certified by the American Institute of Steel Construction for Category I and II Steel Structures and for Sophisticated Paint and Complex Structures
MR

Ms. Marcia Allocco
July 17, 2008
Page 2
CIR page 2 states, "(t)he permittee shall monitor this additional outfall as per the
requirements of the permit." CIR page 6 restates concerns regarding the two pipes
making up old Outfall 001.
The facility has been monitoring the convergence of the two pipes draining the west part
of the facility. The inspection report is incorrect in stating that analytical monitoring was
not performed on the second pipe. The site plan does not adequately show the joint
monitoring point. The site plan's mislabeling likely lead to this misunderstanding.
Previous Mecklenburg County inspectors have reviewed the joint monitoring location
without raising a concern.
The Stormwater Pollution Prevention Plan (SPPP) has been amended to show the far
west pipe as Outfal1001 and the pipe just to the east as new Outfall 004. A request to
obtain representative outfall status for Outfall 001 to be considered representative of
Outfall 004 has been submitted to Mr. Bradley Bennett of Division of Water Quality,
Stormwater Permitting Unit.
CIR page 3 states, "(t)he permittee should ensure proper containment and disposal of all
spills."
The annual spill response training stresses that spills are to be immediately reported to the
Environmental Emergency Coordinator and that the coordinator is to take prompt action
to clean up the spill. The SPPP Spill Response Procedure requires that (1) spilled
materials and contaminated soils (if any) are placed into a container, (2) that the container
is sealed closed after use and (3) that appropriate container labels are proved.
To help ensure that these procedures are maintained, a Weekly Stormwater BMP
Inspection has been implemented. It is the intent of this inspection to frequently review
areas where housekeeping has been an issue and ensure that appropriate procedures are
maintained.
CIR page 3 states, "(t)he permittee should implement best management practices as
needed to ensure proper containment and disposal of all particulate materials generated
on site."
Both the plasma dust collector and shot blast dust collector have the potential to result in
dust spills. Instructions have been given to supervisors and operating personnel that close
monitoring of the drums is needed to ensure that the collection drums are changed out
before the potential for a spill is encountered. The Weekly Stormwater BMP Inspection
has been implemented to help ensure the drum monitoring and timely drum changing is
maintained.

Ms. Marcia Allocco
July 17, 2008
Page 3
• CIR page 3 states, "(t)he permittee should ensure proper containment and clean up of all
spills."
While it is our intent to maintain outdoor equipment such that oil leaks do not occur,
areas where there is forklift and other vehicle traffic will be inspected for oil staining as
part of the Weekly Stormwater BMP Inspection. In the event oil staining is discovered,
the inspector should ensure that the staining is promptly removed and determine the
cause so that the appropriate corrective actions can be taken to avoid additional leaks.
• CIR page 4 states, "(t)he facility should perform proper maintenance of the storm drain
outfalls and limit the impact of industrial activities on stormwater discharges."
The obstructions to Outfall 002 have been removed and maintenance performed on the
main trench. The actions taken to limit the potential impact of plasma dust on the
discharge is provided with the response to the request to implement BMPs to ensure
proper containment and disposal of all particulate materials generated on site.
• CIR page 4 states, "(t)he permittee will re-evaluate the industrial usage in the drainage
area." CIR page 6 restates concerns regarding the grass swale leading to Outfall 003.
Since the development of the SPPP, the facility converted the employee parking area into
structural steel storage. With this change in use, Outfall 003 clearly became are regulated
outfall. Due to the intermittent nature of this outfall monitoring may be difficult. Since
the industrial activity in the Outfall 003 basin is similar to Outfall 002, a request for
representative status has been submitted to Mr. Bennett.
• CIR page 5 indicates that the SPPP does not include a list of significant spills occurring
in the past 3 years. Page 5 also states, "(a)s per the new general permit issued in
November of 2007 the spill section of the SPPP must be updated annually."
There have been no significant spills since Southern Steel Company, LLC began
operating this facility. The Comprehensive Stormwater Inspection Checklist, Evaluation
and Report has been revised to provide for identifying significant spills or certifying that
no spills have occurred since the last inspection.
• CIR page 5 indicates that the SPPP does not include accurate latitude and longitude
coordinates for points of discharge.
The SPPP has been amended to provide this information.

Ms. Marcia Allocco
July 17, 2008
Page 4
• CIR page 6 states "(a)s per the general permit issued in November 2007 an illicit
discharge evaluation must be completed annually."
The Comprehensive Stormwater Inspection Checklist, Evaluation and Report has been
revised to help ensure that this new requirement is performed annually.
A copy of the "Weekly Stormwater BMP Inspection Checklist and Report", the revised
Comprehensive Stormwater Inspection Checklist, Evaluation and Report (performed twice a
year), and the amendment to the SPPP are enclosed.
It is our intent to fully comply with the stormwater general permit and any comments to this
purpose will be appreciated.
Should you have any questions, comments and/or recommendations regarding this response,
please do not hesitate to contact Guy Lee, our consultant, at [phone] or me at
[phone].
Respectfully,
Mike Welch
Plant Manager
MW/gl
enclosure
Copy: Guy Lee, Guy Lee IV, P.E., Catawba, North Carolina
Joe Miner, Southern Steel Company, LLC, Charlotte, North Carolina
Heather Sorenson, Mecklenburg County, Charlotte, North Carolina

SOUTHERN STEEL COMPANY, L.L.C.
SAM NEELY ROAD
CHARLOTTE, NORTH CAROLINA
WEEKLY STORMWATER BMP INSPECTION CHECKLIST AND REPORT
This inspection was developed to help ensure that the best management practices (BMPs) identified in
the stormwater pollution prevention plan are maintained. This inspection should be performed weekly.
Date of Inspection:
Inspector's Name(s):
BMP
Time of Inspection:
Maintain steel off ground (most commonly on wood planks or flat bed trailers).
— Inspect outdoor steel storage yards to ensure steel is not in contact with the
ground.
Remove steel shavings and cuttings from steel moved through drill and saw houses.
Maintain trench and area draining to the trench.
— Inspect drill and saw houses to ensure shavings and cuttings are removed
before moving steel outside.
— Inspect trench and trench drainage area for shavings and cuttings.
— Ensure any spills are promptly removed.
Manage plasma cutter and shot blast dust collector drums to minimize the potential for
spills. Clean up spills promptly.
— Ensure operating personnel are routinely inspecting drums and replacing
drums prior to overfilling.
— Inspect collector areas for evidence of spills.
— Ensure any spills are promptly removed.
Promptly identify and clean up equipment leaks and spills.
— Inspect areas where forklifts and other outdoor motorized equipment is used
for evidence of oil staining.
— Ensure any spills or leaks are promptly removed.
Comments, Observations and/or Corrective Actions (use back if needed):
Signature of Chief Inspector
Date
Status
Southern Steel Company, LLC July 16, 2008

SOUTHERN STEEL COMPANY, L.L.C.
SAM NEELY ROAD
CHARLOTTE, NORTH CAROLINA
COMPREHENSIVE STORMWATER INSPECTION CHECKLIST,
EVALUATION AND REPORT
This report documents compliance with General Permit NCG030000 with respect to inspections,
evaluation and reporting requirements. This inspection should be performed at least twice a year, once
during the first six months and once during the last six months with at least a 60 day separation.
Date of Inspection:
Inspector's / Evaluator's Name(s):
Inspection Items
Time of Inspection:
Have there been any significant (reportable) spills since the last inspection?
Was an evaluation for non-stormwater discharges been performed this year?
Inspect the steel outdoor storage best management practice (BMP).
Inspect the drill and saw houses 1 trench system BMP.
Inspect the dust collectors BMP.
Inspect conveyances, controls, and methods used to limit or prevent erosion associated
with stormwater systems.
Inspect area of outfall for evidence of spots, staining, garbage or waste materials.
Inspect areas where spills or leaks occurred in the past.
Inspect basin area for spots, spills, windblown dry chemicals, garbage and waste.
Ensure outside areas are neat and orderly.
Inspect pipes, pumps, valves, tanks, bins, and secondary containment systems for
evidence of leaks, corrosion, support or foundation failure.
Inspect drums to ensure that they are closed and in good condition.
Inspect perimeter of buildings for evidence of leaks.
Inspect material handling area(s) and loading/unloading equipment area(s) for signs
of spills or leaks.
Inspect material handling equipment for evidence of improper maintenance.
Ensure spill response procedures are known and used.
Ensure no new industrial activities (not included in the SPPP) are exposed.
Considering the current storm water management practices, evaluate and implement
(if any) new measures for reducing pollutant loading to storm water.
Review SPPP to determine if revision is needed.
Comments, Observations and/or Corrective Actions (use back if needed):
Signature of Chief Inspector / Evaluator
Date
Status
Southern Steel Company, LLC July 15, 2008

SOUTHERN STEEL COMPANY, LLC
SAM NEELY ROAD
CHARLOTTE, NORTH CAROLINA
SPPP GENERAL LOCATION MAP NOTES
Receiving Waters and Locations
Outfall Number
Receivin Waters
Latitude
Longitude
001
Unnamed tributary to
3887400 N
17502290 E
Steel Creek
002
Unnamed tributary to
3887358 N
17502400 E
Steel Creek
003
Unnamed tributary to
3887400 N
17502290 E
Steel Creek
004
Unnamed tributary to
3887331 N
17502453 E
Steel Creek
Latitude and longitude measures taken by Magellan GPS Tracker using WSG84 Map Datum.
Current Status of Steel Creek
No Total Maximum Daily Load (TMDL) has been established for Steel Creek.
The North Carolina 303(d) List, Draft for Public Review, January 10, 2008, does not list Steel
Creek as impaired. No TMDL are planned or proposed according to the North Carolina Division
of Water Quality internet site.
Guy Lee IV, P.E.
July 16, 2008

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Reprints/Updates of this document are available at our website:
http://www.cimcool.com
CIMCOOL Material Safety Data Sheet
Gk" &**nrPhW Fn.+da
CIMTECH® 495
METALWORKING FLUID CONCENTRATE
DATE EFFECTIVE: 09-23-2008
1 CHEMICAL PRODUCT AND COMPANY IDENTIFICATION
Manufacturer: Milacron Marketing Company, Global Industrial Fluids
3000 Disney Street
Cincinnati, OH 45209 United States
Emergency: Telephone (USA): 1-800-424-9300 (CHEMTREC)
Telephone (Outside USA): 1-703-527-3887 (CHEMTREC)
General Information. Telephone: [phone]
Generic Name: Water Soluble Metalworking Fluid Concentrate
2 EMERGENCY INFORMATION
Product is alkaline. Product is a primary eye irritant. Highway spills could result in slippery
conditions. No other significant health effects are associated with this material.
3 POTENTIAL HEALTH EFFECTS OF DIRECT EXPOSURE
Product
Inhalation: Not Applicable
Eye Contact: Product is a primary eye irritant.
Skin Contact: Product is not a primary skin irritant.
Ingestion: Not orally toxic.
Product at Use Dilution
Extended exposure to mist may cause upper
respiratory irritation.
Will cause stinging sensation in the eye.
Not irritating to the skin when used as directed and
good personal hygiene is practiced.
Swallowing small quantities may cause diarrhea,
nausea or vomiting.
Medical Conditions generally aggravated by exposure
May aggravate existing skin irritation where further defatting or skin penetration could occur.
Skin irritation (redness and dryness of hands) may be experienced when the diluted product has been
contaminated by certain oils, by dissolved metals, or when mix ratio is too strong. When problems
occur, use of water-resistant barrier creams may be a temporary control measure. Contact Milacron
Marketing Company, Global Industrial Fluids Technical Services at 1-513-458-8199 for specific
recommendations.
When used in applications generating high levels of mist, operator exposure can be minimized by
proper ventilation, use of mist collectors or splash guards, as appropriate. If there is doubt about
actual mist levels present, monitoring should be conducted. Contact Milacron Marketing Company,
Global -industrial Fluids at 1-513-458-8199 for specific recommendations.
Repeated excessive exposures to high amounts of triethanolamine may cause liver and kidney
effects.
Material Dame: CIMTECHO 495
1OTBZ296
Effective Date: 09-23-2008
1/6

Carcinogen Listings: NTP: No IARG: No OSHA: No
Signs and symptoms of exposure
Acute
Eye injury may result from contact with product. Skin irritation can result from improper use and
handling of product.
4 EMERGENCY AND FIRST AID PROCEDURES
Eyes
In case of eye contact, flush immediately with running water for at least 15 minutes, and get prompt
medical attention.
Skin Contact
For skin contact flush with large amounts of water while removing contaminated clothing. Remove
contaminated shoes and clothing and launder before reuse.
Product is not irritating to the skin when used as recommended and good personal Hygiene is
practiced.
Ingestion
Do not induce vomiting. If the material is swallowed, get immediate medical attention or advice. DO
NOT INDUCE VOMITING. Give two glasses of water or milk. Immediately contact a physician and
obtain treatment. Swallowing small quantities of diluted product may cause nausea, diarrhea or
abdominal distress.
Inhalation
Inhalation can occur in applications where high mist levels are generated. OSHA has set a PEL of 15
mglm3 for any airborne particulate as a nuisance level of exposure. NIOSH has set a REL of 0.5 mglm3
for metalworking fluid mist. If symptoms are experienced, remove source of contamination or move
victim to fresh air. If symptoms persist, get medical attention.
5 CONTROL MEASURES
Respiratory protection
Product is not volatile.
In applications where time -weighted exposures are 0.5 to 5 mglm', mist reduction through improved
ventilation, mist collection or process modification is recommended by NIOSH. Where this is not
possible, NIOSH recommends the use of any air purifying, half -mask respirator including a disposable
respirator, equipped with any P- or R-series particulate filter. If the average exposure will exceed 5
mglm3, NIOSH recommends use of a powered, air -purifying respirator equipped with a hood or helmet
and a HEPA filter. If respiratory problems are present when mist levels are < 0.5 mglm', respiratory
protection should be based on the individual recommendation of a qualified health care provider.
Caution
The appropriate use and type of respirator is dependent upon use of the product and local operating
conditions.
Ventilation
For most applications, normal shop ventilation is needed. However, when high mist levels are
generated or where machines are close together or ventilation is inadequate, operators may
experience respiratory irritation. For such applications, use of splash guards or mist collectors is
recommended.
Eye protection
Proper metalworking plant eye protection required when handling product concentrate.
Material Name: CIMTECH(D 495 Effective Date: 09-23-2008
1 OTBZ296 21 6

r
i
Other protective clothing or equipment
Use effective metalworking plant protective clothing as appropriate.
Work / Hygiene Practices
Good personal hygiene should always be followed.
Protective Gloves
Impervious gloves, such as nitrile gloves, are recommended when handling product concentrate.
6 HAZARDOUS INGREDIENTS / IDENTITY INFORMATION
These ingredients may contribute to the acute product hazards listed under the Potential Health
Effects section. Other substances, not hazardous under the OSHA Hazard Communication
Standard, may be present. Further composition information may be available to health professionals
as provided in the Standard.
Component CAS # Percent
NEODECANOIC ACID 26896-20-8 7 - 13
TRIETHANOLAMINE 102-71-6 5 - 10
MONOETHANOLAMINE 141-43-5 1-5
NONANOIC ACID 112-05-0 1-5
7 FIRE AND EXPLOSION HAZARD DATA
Extinguishing Media
Not Applicable
Hazardous Combustion Products
Smoke, fumes, and oxides of carbon
Flash Point:
Not Applicable
Lower Explosive Limit:
Not Applicable
Upper Explosive Limit:
Not Applicable
HMIS RATINGS
Health
1
Flammability Classification
0
Reactivity
0
NFPA RATINGS
Health
1
Flammability Classification
0
Reactivity
0
8 ACCIDENTAL RELEASE MEASURES
Contain the spill, collect on absorbent material, and discard as dictated by Federal, state and local
regulations that may apply. Flush area thoroughly with water.
Reportable Quantity: None
Material Name: CIMTECHO 495 Effective Date: 09-23-2008
1 OTBZ296 3/6

1
9 WASTE DISPOSAL
For Used Product
Disposal procedures must comply with local, county, state and Federal regulations. If pre-treatment is
needed, ultrafiltration, emulsion breaking or evaporation may be used. Contact Milacron Marketing
Company, Global Industrial Fluids at 1-513-458-8199 for assistance.
For Unused Product
Product is not a hazardous waste as defined under 40 CFR 261. Contact Milacron Marketing
Company, Global Industrial Fluids at 1-513-458-8199 for assistance.
Empty Containers
Empty containers will contain a residue which is not considered a hazardous waste under RCRA
regulations. Drums can be drained to a "drip dry" condition by inversion and can be offered for
recycling or scrap.
10 HANDLING AND STORAGE
Avoid all contact of product with eyes or skin. Wash thoroughly after handling. Do not swallow. Do not
store product concentrate in direct sunlight or elevated temperatures. Use only as recommended by
Milacron Marketing Company, Global Industrial Fluids . If frozen, thaw completely at room
temperature prior to use.
Other Precautions
Contains amines. Do not add sodium nitrite or other nitrosating agents to this product because
suspected cancer -causing nitrosamines may be formed.
11 PHYSICAL 1 CHEMICAL CHARACTERISTICS
Boiling Point:
Specific Gravity:
Evaporation Rate:
Solubility (H20):
Volatile Organic Content (by
ASTM D2369):
pH (Concentrate):
pH (Mix):
Recommended Starting
Dilution:
Appearance/Odor:
12 REACTIVITY
Stability
Stable under normal conditions.
Conditions to avoid
Use as directed.
Materials to avoid
212 °F (100 °C)
1.07
Like water when diluted
100 % Miscible
12%
8.4
8.3 @ 5.0%
5% (1:20) to 20% (1:5)
Clear/Chemical
Avoid contact with strong acids or oxidizers to product.
Hazardous Polymerization
Will not occur.
Material Name: CIMTECHO 495 Effective Date: 09-23-2008
1 OTBZ296 4 1 6

Combustion Products
Smoke, fumes, and oxides of carbon
13 TRANSPORTATION INFORMATION
BY LAND
Hazardous Materials Description and Proper Shipping Name (49 CFR 172.101)
Not a Hazardous Material
BY AIR OR VESSEL
Hazardous Materials Description and Proper Shipping Name (49 CFR 172.101)
Not a Hazardous Material
14 REGULATORY INFORMATION
EXPOSURE GUIDELINES
REGULATED MATERIAL NIOSH REL OSHA PEL OSHA STEL ACGIH TLV ACGIH STEL
MONOETHANOLAMINE 3 ppm 6 ppm 3 ppm 6 ppm
TRIETHANOLAMINE 5 mg/m'
METALWORKING FLUID MIST 0.5 mg/m3
CERCLA
No components of this product are present at levels which require reporting under 40 CFR 302.4.
EPCRA (SARA) TITLE III Extremely Hazardous Substances (302): None
Hazardous Substances (3111312)
Product is a hazardous substance as defined under the OSHA Hazard Communication Standard and
may be reportable under the provisions of SARA Sections 311 and 312.
HAZARD CATEGORIES
Acute Health: Yes
Chronic Health: No
Fire: No
Sudden Release of Pressure: No
Reactive: No
RCRA
Product concentrate does not meet the definition of a hazardous waste as defined under 40 CFR 261.
It is possible that in use, the product may be contaminated by metals or by chlorinated solvents and
the final waste may meet the TCLP definition. Each facility should assess each waste stream to
determine if the used fluid should be treated as a hazardous waste.
TSCA
The ingredients of this product are on the TSCA inventory.
State Right to Know
Many states have enacted Community Right -To -Know laws which require information beyond that
mandated by federal laws. Since some of these laws are inconsistent with the federal laws, the
information in this sheet may not fully meet the requirements of every state.
Toxic Substances (313)
Component CAS # Max % Comments
None
Material Name: CIMTECHO 495 Effective Date: 09-23-2008
1OTBZ296 5/6

GLOSSARY OF ABBREVIATIONS
ACGIH American Conference of Governmental Industrial Hygenists
CAS Chemical Abstracts Service
CERCLA Comprehensive Environmental Response Compensation and Liability Act
CFR Code of Federal Regulations
COC Cleveland Open Cup
DOT Department of Transportation
EPCRA Emergency Planning and Community Right -to -Know Act (aka SARA)
]ARC International Agency for Research on Cancer
NIOSH National Institute for Occupational Safety and Health
NTP National Toxicology Program
OSHA Occupational Safety and Health Administration
PEL Permissible Exposure Limit
RCRA Resource Conservation and Recovery Act
REC Recommended
REL
Recommended Exposure Limit
SARA
SuperFund Amendments and Reauthorization Act
STEL
Short -Term Exposure Limit
TCLP
Toxicity Characteristics Leaching Procedure
TLV
Threshold Limit Value
TSCA
Toxic Substances Control Act
VOC
Volatile Organic Compounds
Disclaimer
NOTE: The opinions expressed herein are those of qualified experts within Milacron Marketing
Company, Global Industrial Fluids and of their suppliers. We believe that the information contained
herein is current as of the date of this Material Safety Data Sheet. Since the use of this information and
of these opinions and the condition and use of the product are not within the control of Milacron
Marketing Company, Global Industrial Fluids , it is the user's obligation to determine the conditions of
safe use of the product.
Material Name: CIMTECHO 495 Effective Date: 09-23-2008
1 OTBZ296 61 6

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Reprints/Updates of this document are available at our website:
http://www.cimcool.com
6CIMCOOL Material Safety Data Sheet
ak" vxhostrhm ft-da
ClMTECH® 95
METALWORKING FLUID CONCENTRATE
DATE EFFECTIVE: 05-22-2008
1 CHEMICAL PRODUCT AND COMPANY IDENTIFICATION
Manufacturer: Milacron Marketing Company, Global Industrial Fluids
3000 Disney Street
Cincinnati, OH 45209 United States
Emergency: Telephone (USA): 1-800-424-9300 (CHEMTREC)
Telephone (Outside USA): 1-703-527-3887 (CHEMTREC)
General Information: Telephone: [phone]
Generic Name: Water Soluble Metalworking Fluid Concentrate
2 EMERGENCY INFORMATION
Product is alkaline. Product is corrosive to aluminum. Product is a primary eye irritant. Product may
be a primary skin irritant. Highway spills could result in slippery conditions. No other significant health
effects are associated with this material.
3 POTENTIAL HEALTH EFFECTS OF DIRECT EXPOSURE
Product
Inhalation: Not Applicable
Eye Contact: Product is a primary eye irritant.
Skin Contact: Product may be a primary skin irritant.
Ingestion: Not orally toxic.
Product at Use Dilution
Extended exposure to mist may cause upper
respiratory irritation.
Will cause stinging sensation in the eye.
Not irritating to the skin when used as directed and
good personal hygiene is practiced.
Swallowing small quantities may cause diarrhea,
nausea or vomiting.
Medical Conditions generally aggravated by exposure
May aggravate existing skin irritation where further defatting or skin penetration could occur.
Mild skin irritation (redness and dryness of hands) may be experienced when the diluted product has
been contaminated by certain oils, by dissolved metals, or when mix ratio is too strong. When
problems occur, use of water-resistant barrier creams may be a temporary control measure. Contact
Milacron Marketing Company, Global Industrial Fluids Technical Services at 1-513-458-8199 for
specific recommendations.
Material Name: CIMTECHO 95
30U UQ264
Effective Date: 05-22-2008
1/ 6

1
When used in applications generating high levels of mist, operator exposure can be minimized by
proper ventilation, use of mist collectors or splash guards, as appropriate. If there is doubt about
actual mist levels present, monitoring should be conducted. Contact Milacron Marketing Company,
Global Industrial Fluids at 1-513-458-8199 for specific recommendations.
Repeated excessive exposures to high amounts of triethanolamine may cause liver and kidney
effects.
Carcinogen Listings: NTP: No IARC: No OSHA: No
Signs and symptoms of exposure
Acute
Eye injury may result from contact with product. Skin irritation can result from improper use and
handling of product.
4 EMERGENCY AND FIRST AID PROCEDURES
Eyes
In case of eye contact, flush immediately with running water for at least 15 minutes, and get prompt
medical attention.
Skin Contact
Product is not irritating to the skin when used as recommended and good personal hygiene is
practiced. For skin contact flush with large amounts of water while removing contaminated clothing.
Remove contaminated shoes and clothing and launder before reuse.
Ingestion
If the material is swallowed, get immediate medical attention or advice. DO NOT INDUCE VOMITING.
Give two glasses of water or milk. Immediately contact a physician and obtain treatment. Swallowing
small quantities of diluted product may cause nausea, diarrhea or abdominal distress.
Inhalation
Inhalation can occur in applications where high mist levels are generated. OSHA has set a PEL of 15
mglm3 for any airborne particulate as a nuisance level of exposure. NIOSH has set a REL of 0.5 mglm3
for metalworking fluid mist. If symptoms are experienced, remove source of contamination or move
victim to fresh air. If symptoms persist, get medical attention.
5 CONTROL- MEASURES
Respiratory protection
Product is not volatile.
In applications where time -weighted exposures are 0.5 to 5 mglm3, mist reduction through improved
ventilation, mist collection or process modification is recommended by NIOSH. Where this is not
possible, NIOSH recommends the use of any air purifying, half -mask respirator including a disposable
respirator, equipped with any P- or R-series particulate filter. If the average exposure will exceed 5
mglm3, NIOSH recommends use of a powered, air -purifying respirator equipped with a hood or helmet
and a HEPA filter. If respiratory problems are present when mist levels are < 0.5 mglm3, respiratory
protection should be based on the individual recommendation of a qualified health care provider.
Caution
The appropriate use and type of respirator is dependent upon use of the product and local operating
conditions.
Ventilation
For most applications, normal shop ventilation is adequate. However, when high mist levels are
generated or where machines are close together or ventilation is inadequate, operators may
experience respiratory irritation. For such applications, use of splash guards or mist collectors is
recommended.
Material Name: CIMTECHO 95 Effective Date: 05-22-2008
3000Q264 2 / 6

Ir
Eye protection
Proper metalworking plant eye protection required when handling product concentrate.
Other protective clothing or equipment
Use effective metalworking plant protective clothing as appropriate.
Work 1 Hygiene Practices
Good personal hygiene should always be followed.
Protective Gloves
Impervious gloves, such as nitrile gloves, are recommended when handling product concentrate.
6 HAZARDOUS INGREDIENTS 1 IDENTITY INFORMATION
These ingredients may contribute to the acute product hazards listed under the Potential Health
Effects section. Other substances, not hazardous under the OSHA Hazard Communication
Standard, may be present. Further composition information may be available to health professionals
as provided in the Standard.
Component CAS # Percent
MONOETHANOLAMINE 141-43-5 3-7
TRIETHANOLAMINE 102-71-6 3-7
NEODECANOIC ACID 26896-20-8 1 - 5
NONANOIC ACID 112-05-0 1 - 5
7 FIRE AND EXPLOSION HAZARD DATA
Extinguishing Media
Not Applicable
Hazardous Combustion Products
Smoke, fumes, oxides of nitrogen, and oxides of carbon
Lower Explosive Limit:
Not Applicable
Upper Explosive Limit:
Not Applicable
HMIS RATINGS
Health
1
Flammability Classification
0
Reactivity
0
NFPA RATINGS
Health
1
Flammability Classification
0
Reactivity
0
8 ACCIDENTAL RELEASE MEASURES
Contain the spill, collect on absorbent material, and discard as dictated by Federal, state and local
regulations that may apply. Flush area thoroughly with water.
Reportable Quantity: None
Material Name: CIMTECHO 95 Effective Date: 05-22-2008
30UUQ264 31 6

9 WASTE DISPOSAL
For Used Product
Disposal procedures must comply with local, county, state and Federal regulations. If pre-treatment is
needed, ultrafiltration, emulsion breaking or evaporation may be used. Contact Milacron Marketing
Company, Global Industrial Fluids at 1-513458-8199 for assistance.
For Unused Product
Product is not a hazardous waste as defined under 40 CFR 261. Contact Milacron Marketing
Company, Global Industrial Fluids at 1-513-458-8199 for assistance.
Empty Containers
Empty containers will contain a residue which is not considered a hazardous waste under RCRA
regulations. Drums can be drained to a "drip dry" condition by inversion and can be offered for
recycling or scrap.
10 HANDLING AND STORAGE
Avoid all contact of product with eyes or skin. Wash thoroughly after handling. Do not swallow. Do not
store product concentrate in direct sunlight or elevated temperatures. if frozen, thaw completely at
room temperature prior to use. Use only as recommended by Milacron Marketing Company, Global
Industrial Fluids .
Other Precautions
Contains amines. Do not add sodium nitrite or other nitrosating agents to this product because
suspected cancer -causing nitrosamines may be formed.
11 PHYSICAL 1 CHEMICAL CHARACTERISTICS
Boiling Point:
Specific Gravity:
Evaporation Rate
Solubility (H20):
Volatile Organic Content (by
ASTM D2369):
pH (Concentrate):
pH (Mix):
Recommended Starting
Dilution:
Appearance/Odor:
12 REACTIVITY
Stability
Stable under normal conditions.
Conditions to avoid
Use as directed.
Materials to avoid
212T(100°C)
1.03
Like water when diluted
100 % Miscible
10%
9.7
9.0
5%
Clear/Chemical
Avoid contact with strong acids or oxidizers to product.
Hazardous Polymerization
Will not occur.
Material Name: CIMTECH@) 95 Effective Date: 05-22-2008
30UUQ264 41 6

:j Combustion Products
Smoke, fumes, oxides of nitrogen, and oxides of carbon
13 TRANSPORTATION INFORMATION
Hazardous Materials Description and Proper Shipping Name (49 CFR 172.101)
Not a hazardous material
BY AIR OR VESSEL
Hazardous Materials Description and Proper Shipping Name (49 CFR 172.101)
Corrosive liquid, basic, organic, n.o.s. (contains ethanolamine)
Hazard Class (49 CFR 172.101): 8
Identification Number: UN3267
Packaging Group: III
14 REGULATORY INFORMATION
EXPOSURE GUIDELINES
REGULATED MATERIAL NIOSH REL OSHA PEL OSHA STEL ACGIH TLV ACGIH STEL
MONOETHANOLAMINE 3 ppm 6 ppm 3 ppm 6 ppm
TRIETHANOLAMINE 5 mg/m'
METALWORKING FLUID MIST 0.5 mg/m3
CERCLA
No components of this product are present at levels which require reporting under 40 CFR 302.4.
EPCRA (SARA) TITLE III Extremely Hazardous Substances (302): None
Hazardous Substances (311/312)
Product is a hazardous substance as defined under the OSHA Hazard Communication Standard and
may be reportable under the provisions of SARA Sections 311 and 312.
HAZARD CATEGORIES
Acute Health: Yes
Chronic Health: No
Fire. No
Sudden Release of Pressure: No
Reactive: No
RCRA
Product concentrate does not meet the definition of a hazardous waste as defined under 40 CFR 261.
It is possible that in use, the product may be contaminated by metals or by chlorinated solvents and
the final waste may meet the TCLP definition. Each facility should assess each waste stream to
determine if the used fluid should be treated as a hazardous waste.
TSCA
The ingredients of this product are on the TSCA inventory.
State Right to Know
Many states have enacted Community Right -To -Know laws which require information beyond that
mandated by federal laws. Since some of these laws are inconsistent with the federal laws, the
information in this sheet may not fully meet the requirements of every state.
Material Name: CIMTECHO 95 Effective Date: 05-22-2008
30UUQ264 5 / 6

Toxic Substances (313)
Component
None
GLOSSARY OF ABBREVIATIONS
CAS # Max % Comments
ACGIH American Conference of Governmental Industrial Hygenists
CAS Chemical Abstracts Service
CERCLA Comprehensive Environmental Response Compensation and Liability Act
CFR Code of Federal Regulations
COC Cleveland Open Cup
DOT Department of Transportation
EPCRA Emergency Planning and Community Right -to -Know Act (aka SARA)
IARC
International Agency for Research on Cancer
N10SH
National Institute for Occupational Safety and Health
NTP
National Toxicology Program
OSHA
Occupational Safety and Health Administration
PEL
Permissible Exposure Limit
RCRA
Resource Conservation and Recovery Act
REC
Recommended
REL
Recommended Exposure Limit
SARA
Superfund Amendments and Reauthorization Act
STEL
Short -Term Exposure Limit
TCLP
Toxicity Characteristics Leaching Procedure
TLV
Threshold Limit Value
TSCA
Toxic Substances Control Act
VOC
Volatile Organic Compounds
Disclaimer
NOTE: The opinions expressed herein are those of qualified experts within Milacron Marketing
Company, Global Industrial Fluids and of their suppliers. We believe that the information contained
herein is current as of the date of this Material Safety Data Sheet. Since the use of this information and
of these opinions and the condition and use of the product are not within the control of Milacron
Marketing Company, Global Industrial Fluids , it is the user's obligation to determine the conditions of
safe use of the product.
Material Name: CIMTECHO 95 Effective Date: 05-22-2008
30UUQ264 6 / 6

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95
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METALWORKING FLUID
CONCENTRATE
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Global IndusNal Fluids
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USA 1-80042"800 (CHEMTREC)
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CONCENTRATE
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QUTSIOE USA 1-703-637 3887 (CHEMTRECI
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Mr. Joseph Miner, Safety Coordinator
Southern Steel Company, LLC
12933 Sam Neely Road
Charlotte, N.C. 28273
Subject
Dear Mr. Miner:
Michael F. Easley, Governor dp
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
June 23, 2008
Compliance Evaluation Inspection
Southern Steel Company, LLC.
Stormwater Permit COC NCG030181
Mecklenburg County, NC
Coleen H. Sullins, Director
Division of Water Quality
Enclosed is a copy of the Compliance Evaluation Inspection (CEI) report for the inspection
conducted at the subject facility on May 23, 2008, by Ms. Heather Sorensen and Ms. Erin Hall of
Charlotte -Mecklenburg Storm Water Services. This inspection was conducted as part of a cooperative
working agreement between Mecklenburg County and the Division of Water Quality. In addition, the
inspection was conducted on behalf of the City of Charlotte in compliance with the City's NPDES Permit,
NCS000240, Part II Section H. Thank you for your assistance and cooperation during the inspection.
The inspection found that Southern Steel Company, LLC has developed and implemented a
Stormwater program and this Office commends the permittee's efforts to ensure compliance with your
NPDES permit. However, deficiencies were noted as detailed in the Industrial Operations/City of
Charlotte Stormwater Ordinance Review, Stormwater Pollution Prevention Plan, and Analytical
Monitoring sections of the attached report.
It is requested that a written response be submitted to this Office by July 21, 2008, addressing
the above -noted violations in the enclosed report. In responding to the violations, please address your
comments to the attention of Ms. Marcia Ailocco at the letterhead address.
The enclosed report should be self-explanatory; however should you have any questions
concerning this report or have any questions regarding your permit, please do not hesitate to contact Ms.
Allocco of this Office at [phone].
Enclosure
cc: NPS-ACO Unit
��Lr
WDENR
Sincerely,
.............. M N I
for Robert B. Krebs
Rusty Rozzelle, Mecklenburg County
Craig Miller, City of Charlotte
Regional Supervisor
Surface Water Protection Section
Mooresville Regional Office
Non thCarolina
,Vatumllff
Mooresville Regional Office Division of Water Quality Phone [phone] Customer Service
Internet: waw.ncw•aterquality.ora 610 East Center Ave, Suite 301 Mooresville, NC 28115 Fax [phone]
An Equal Opportunity/Affirmative Action Employer — 50% Recycled110%, Post Consumer Paper

Permit: NCG030181
SOC:
County: Mecklenburg
Region: Mooresville
Compliance Inspection Report
Effective: 11/01/07 Expiration: 10/31/12 Owner: Southern Steel Comapny LLC
Effective: Expiration: Facility: Southern Steel Company LLC
12933 Sam Neely Rd
Contact Person: Joe Miner
Directions to Facility:
System Classifications:
Primary ORC: ,
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Title:
Certification
Charlotte NC 28273
Phone:
Phone:
Inspection Date: 06/23/2008 Entry Time: 09 00 AM Exit Time: 12:00 PM
Primary Inspector: Water Quality Program Mecklenburg County Phone:
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Metal Fabrication Stormwater Discharge COG
Facility Status: ❑ Compliant ■ Not Compliant
Question Areas:
0 Storm Water
(See attachment summary)
Page: 1

Permit: NCG030181 Owner — Facility: Southern Steel Company LLC - Southern Steel Company LLC
Inspection Date: 05/23/08 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Facility Description:
This facility prepares steel beams for sale, which includes drilling, sawing, painting, burning, welding, and plasma
cutting. Maintenance and fueling of forklifts also occurs on site. Two tractor -trailers are based out of this facility. This
facility is a small generator of hazardous materials, primarily waste paint. A locked chain link fence surrounds the
facility's perimeter. Palmetto Environmental collects and disposes of used oils, paint, and oil absorbent materials. This
facility uses less than 55 gallons of new motor oil per month when averaged over a calendar year.
Compliance History:
CMSWS conducted an inspection of the facility on April 4, 2007. A number of deficiencies were noted during the
inspection and a Notice of Violation (NOV) issued by the City of Charlotte. Southern Steel submitted a written
response on June 20, 2007, documenting the corrective actions that had been taken.
Industrial Operations/CityOperations/City of Charlotte Stormwater Ordinance Review:
Steel Storage Yards —
This outside area is mostly gravel with some paved areas and extends along the perimeter of the facility between the
chain link fence and the shop building.
The western steel storage yard is the staging area for steel beams that are delivered to the facility to be
processed. One storm drain in this area had a dry weather flow observed. The flow was clear with no odor. A
previous evaluation for illicit discharges determined that this flow was groundwater. Facility personnel noted
that the property was historically a wet area and there are several sump pumps under the building. This area
appeared to be in good condition.
The northern steel storage yard is a staging area for smaller steel pieces, plate steel, and attachments. A dry
weather flow was observed in a storm drain in this area and the water was clear with no odor. A previous
evaluation for illicit discharges determined that a dewatering foundation sump pump drains to this storm drain.
This area appeared to be in good condition.
The eastern steel storage yard consists mainly of flat bed trailers loaded with finished steel beams, awaiting
delivery. This area appeared to be in good condition.
Scrap Metal Bins —
Four large scrap metal bins were located outside and uncovered. These bins appeared to be in good condition.
Trash Dumpster —
One large trash dumpster was located outside and uncovered. No corrosion was observed around the base of the
dumpster and it appeared to be in good condition.
Drill House and Saw House --
Two drill houses and two saw houses are located outside the main shop building. Conveyor belts are located around
the houses that aid in the transport of steel beams. The area is located on a concrete pad with an evaporation trench
drain that collects runoff from the area. Oil and metal particles are allowed to enter the trench drain. Facility staff
commented that the trench drains did not discharge anywhere, the drains are never cleaned out, and stormwater
evaporates from the drains. The SPPP Site Plan indicated a connection of the storm drain system to the trench drains. After the
inspection, facility staff verified the connection.
The permittee shall investigate methods to reduce stormwater contamination from this area of the facility including
removal of the connection between the trench drains and the stormwater system. The permittee shall monitor this
additional outfall as per the requirements of the permit.
Page: 2

Permit: NCG030181 Owner - Facility: Southern Steel Company LLC - Southern Steel Company LLC
Inspection Date: 05/23/08 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Industrial OoerationslCity of Charlotte Stormwater Ordinance Review (cont.):
Wash Bay -
This enclosed wash bay is no longer in use but mop water was observed in the area. The associated oil/water
separator and oil skimmer are also no longer in use. This area appeared to be in good condition.
Blasting Grit -
Used blasting grit, also known as "shot" was observed on the ground near the Outfall 2 access gate. The used shot
contained iron debris. Facility personnel commented that the company policy is to haul off used blasting grit in the
trash dumpster and that the spilled material will be removed.
The permittee should ensure proper containment and disposal of all spills.
Hazardous Waste Storage Shed -
This storage shed is covered and open on one side. The shed is located on a concrete pad with a concrete
containment structure built into the building. During the inspection, eight 55-gallon barrels of waste paint were
observed in the storage shed. Palmetto Environmental collects and disposes of the hazardous waste. This area
appeared to be in good condition.
Dust collector --
A dust collector for the Plasma Punch Machine is located outside in a covered area along the northern side of the shop
building. During the inspection red dust material was observed on the wall and ground in this area. A storm drain catch
basin that discharges to Outfall 2 is located within 10 feet of the dust collector. Red staining was observed on the catch
basin. Facility personnel commented that the release of dust from the collector was due to operator error and more
attention will be used to prevent discharges of particulate material.
The permittee should implement best management practices as needed to ensure proper containment and disposal of
all particulate materials generated on site.
Diesel Fueling Area -
Two off -road diesel fueling pumps are located outside on a concrete pad, exposed to Stormwater. A spill kit is located
accessible inside.the shop building. This area appeared to be in good condition.
Diesel Tank -
One 2,000-gallon diesel tank is located outside and exposed to stormwater. The tank is double walled and located on
a concrete pad. During the inspection this tank was empty and not in service. The 2,000-gallon tank will replace the
older 10,000-gallon diesel tank. Staff explained that they have a storm drain cover in the event there is a fuel spill in
this area. This tank appeared to be in good condition.
Forklifts -
Forklifts are maintained and repaired as needed, either inside the shop building or outdoors. Staining was observed on
the ground around the new paint storage shed and diesel tank. Facility personnel explained that the stains were from
leaking forklifts.
The permittee should ensure proper containment and clean up of all spills.
New Paint Storage Shed -
This shed is covered and opened on one side with a concrete containment structure built into the shed. New
containers of paint were stored on pallets inside the shed. This area appeared to be in good condition.
Paint Barrels -
Three new 55-gallon barrels of paint were observed outside on a gravel surface. Facility personnel explained that the
barrels had just been delivered and will be stored inside the new paint storage shed. The barrels appeared to be in
good condition.
Page: 3

Permit: NCG030181 Owner — Facility: Southern Steel Company LLC - Southern Steel Company LLC
Inspection Date: 05/23/08 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Industrial Operations/City of Charlotte Stormwater Ordinance Review (cont.):
Shop Building —
Steel beams are blasted, primed, painted, welded, and burned (plasma cutting) inside the shop building. There are no
floor drains located inside the building and the floors are cleaned by sweeping. Barrels were located on spill carts in
waste disposal areas. Used paint cans are drained, dried, and crushed.
Oil Storage Area --
Oils and spill kits are located in this area inside the shop building. Seven 55-gallon barrels of hydraulic oil, motor oil,
and antifreeze were located on a rack above a steel containment structure. Six 55-gallon barrels of waste oil were
located on pallets or in a steel containment structure in this area. One 55-gallon barrel of gear oil was located inside a
steel containment structure. This area appeared to be in good condition.
Diesel Tank —
One 10,000-gallon diesel tank is located outside and exposed to stormwater. The tank is located within a concrete
containment structure. Two stormwater release valves are located in the containment structure. Both valves were
locked shut during the inspection. A supply line pump is located within the concrete containment structure. During the
inspection heavy oil staining was observed on the concrete around the pump. Secondary containment stormwater
release records indicate a history of an oily sheen inside the containment structure. Facility staff explained they are in
the process of installing a new diesel tank. Upon installation of the new 2,000-gallon double -walled tank the 10,000-
gallon tank will be removed. Facility personnel stated that absorbent pads have been used to remove the oil sheen
from the stormwater released from the containment structure before release.
Permit and Outfalls (cont�
Outfall 2 --
This outfall receives stormwater runoff from the eastern side of the facility along the shop building. The outfall is
located along a channelized tributary located on the property. Due to the tributary, standing water was observed at the
outfall. The outfall was approximately 65% blocked by a fallen tree and sediment. The water was red in color and a
ferrous bacteria sheen was observed on the surface of the water. No odor was observed. Red iron dust was observed
around the storm drain catch basin near the dust collector for the plasma punch machine. It was determined this was
the source for the discolored water at the outfall. The facility should perform proper maintenance of storm drain outfalls
and limit the impact of industrial activities on stormwater discharges.
Out€all 3 —
A grassed swale is located along the length of the eastern side of the facility. This outfall receives stormwater runoff
from the eastern side of the facility between the shop building and the chain link fence. The primary use of this area is
staging of the flat bed trailers loaded with finished steel beams awaiting delivery. The swale joins into the channelized
tributary on the property, beyond the chain link fence. Facility personnel noted that they are not currently conducting
analytical sampling for the grassed swale outfall. The permittee will re-evaluate the industrial usage in the drainage
area.
Page: 4

Permit: NCGO30181 Owner - Facility: Southern Steel Comapny LLC
Inspection Date: 05/2312008 Inspection Type: Compliance Evaluation
Stormwater Pollution Prevention Plan
Does the site have a Stormwater Pollution Prevention Plan?
# Does the Plan include a General Location (USGS) map?
# Does the Plan include a "Narrative Description of Practices"?
# Does the Plan include a detailed site map including outfail locations and drainage areas?
# Does the Plan include a list of significant spills occurring during the past 3 years?
# Has the facility evaluated feasible alternatives to current practices?
# Does the facility provide all necessary secondary containment?
# Does the Plan include a BMP summary?
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
# Does the facility provide and document Employee Training?
# Does the Plan include a 4ist of Responsible Party(s)?
# Is the Plan reviewed and updated annually?
# Does the Plan include a Stormwater Facility Inspection Program?
Has the Stormwater Poilution Prevention Plan been implemented?
Reason for Visit: Routine
Comment: The SPPP contained a general location map but it did not include accurate
latitude and longitude coordinates for points of discharge. The 2004 section of the
SPPP notes that no spills have occurred in the past three years. As per the new
general permit issued in November of 2007 the spill section of the SPPP must be
updated annually (Part II, Section A, Item #7). The permittee started documenting the
releases of stormwater from secondary containment structures on June 4, 2007.
Qualitative Monitoring
Has the facility conducted its Qualitative Monitoring semi-annually?
Comment: The permittee has completed the semi-annual qualitative monitoring at
Outfall 001 and 002.
Analytical Monitoring
Has the facility conducted its Analytical monitoring?
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
Yes No NA NE
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Page:5

Permit: NCG030181 Owner - Facility: Southern Steel Comapny LLC
Inspection Date: 05123/2008 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Comment: The permittee has conducted annual analytical monitoring at Outfalls 001
and 002 since 2004. All of the monitored parameters were below the cut-off
concentrations except for the TSS concentrations at Outfall 002 in 2004 and 2005 (280
mg/L and 110 mg/L respectively).
A grassed Swale is located on the eastern side of the facility. Analytical monitoring has
not been conducted at this stormwater discharge point. Facility staff commented that
the drainage area had not received stormwater from industrial activities in the past and
stormwater runoff had not been observed in the Swale. The permittee will re-evaluate
the industrial usage in the drainage area. A second storm drain outfall pipe was
observed adjacent to Outfall 001 and the facility site plan notes the second outfall as a
separate storm drain system. However, analytical monitoring has not been conducted
at this storm drain.
Permit and Outfalis Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? Q ❑ 0
# Were all cutfalls observed during the inspection? ❑ Q
# If the facility has representative outfali status, is it properly documented by the Division? Q [I ❑ 0
# Has the facility evaluated all illicit (non stormwater) discharges? ■ 0 ❑ 0
Comment: The stormwater outfalls were last evaluated for illicit discharges in 2003.
As per the general permit issued in November 2007 an illicit discharge evaluation must
be completed annually (Part II, Section A, Item #7).
Outfall 1 — receives stormwater runoff from the western and southern portions of the
facility. Two separate outfalls are present in this area, which are located along a
channelized tributary located on the property. Due to the tributary, standing water was
observed at both outfalls. The water was clear with a minor oily sheen. After the
inspection, it was discovered that the trench drain system is connected to the
stormwater drainage system. The permittee shall investigate methods to reduce
stormwater contamination from this area of the facility including removal of the
connection between the trench drains and the stormwater system. The permittee shall
monitor this additional outfall as per the requirements of the permit.
This section continued in the Summary section of the repor
Page: 6

Us
Souther
h
July 17, 2008
Mr. Bradley Bennett
Stormwater Permit Unit
North Carolina Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
SUBJECT: Representative Outfall Status Request by Southern Steel Company, I.ILC,
Sam Neely Road, Charlotte, North Carolina, Certificate of Coverage Number
NCG030181
Dear Mr. Bennett:
Southern Steel Company, LLC, requests that the Stormwater Permit Unit allow for (1) sampling
of Outfall 001 to be considered representative of Outfall 004 and (2) sampling of Outfall 002 to
be considered representative of Outfall 003. The background and basis for this request is
provided by the accompanying report.
Should you have any questions regarding this request, please contact Guy Lee, our consultant, at
[phone].
Respectfully requested,
Mike Welsh
Plant Manager
MK/gl
enclosure
a-z.,
.T.SUL 2 1 2D0$
WAi7EFi OU
1N W^star
Copy: Guy Lee, Guy Lee 1V, P.E., Catawba, North Carolina
Joe Miner, Southern Steel Company, LLC, Charlotte, North Carolina
-leather Sorenson, Mecklenburg County, Charlotte, North Carolina
rA Beta International
SOUTHERN STEEL • LYNCHBURG STEEL • CAROLINA REBAR
12933 Sam Neely Road • Charlotte, North Carolina, 28273 • Phone[phone] • Fax:[phone] • www.betainternational.com
Certified by the American Institute of Steel Construction for Category I and 11 Steel Structures and for Sophisticated Paint and Complex Structures
M