NCG200424_COMPLETE FILE - HISTORICAL_20151221

STORMWATER DIVISION CODING SHEET
RESCISSIONS
PERMIT NO.
E
/ V C G a U C f
DOC TYPE
❑ COMPLETE FILE - HISTORICAL
DATE OF
RESCISSION
❑l s���
YYYYMMDD

Energy, Mineral
and Land Resources
ENVIRONMENTAL QUALITY
December 21, 2015
Mr. J. Mark Lozier
Keywell Metals, LLC
7808 W. College Park Drive
Palos Heights, IL 60463
PAT MCCRORY
( iorernnr
DONALD R. VAN DER VAAR`I'
.lei rerrrry
TRACY DAVIS
1)ire<tor
Subject: Rescission of NPDES Stormwater Permit
Certificate of Coverage Number NCG200424
Union County
Dear Mr. Lozier:
On October 30, 2015, the Division of Energy, Mineral and Land Resources received your request to
rescind your coverage under Certificate of Coverage Number NCG200424. In accordance with your
request, Certificate of Coverage Number NCG200424 is rescinded effective immediately.
Operating a treatment facility, discharging wastewater or discharging specific types of Stormwater to
waters of the State without valid coverage under an NPDES permit is against federal and state laws and
could result in fines. If something changes and your facility would again require stormwater or
wastewater discharge permit coverage, you should notify this office immediately. We will be happy to
assist you in assuring the proper pert -nit coverage.
If the facility is in the process of being sold, you will be performing a public service if you would inform
the new or prospective owners of their potential need for NPDES permit coverage.
If you have questions about this matter, please contact us at 919-707-9200, or the Stormwater staff in our
Mooresville Regional Office [phone],
Sincerely,
ORIGINAL SIGNED M
KEN PICKLE
for Tracy E. Davis, PE, CPM, Director
Division of Energy, Mineral and Land Resources
cc: Mooresville Regional Office
Stormwater Permitting Program
Central Files - w/attachments
State of North Carolina I linvirontnental Qualily [ Fnergy, Mineral and Land Resources
1612 Mail Service Center 1 512 North Salisbury Street I Raleigh, North Carolina 27699-1612
919 707 9220 T

KEYWELL METALS
Aerospace & Specially Sleel Recycling
7808 W. College Park Drive
Palos Heights, IL 60463
October 28, 201:5
Storm Water Permitting Unit
Division of Energy, Mineral, and Land Resources
Attention: Bradley Bennett
1612 Mail Service Center
Raleigh, NC 27699-1612
RECEIVED
DENR-LAND QUALITY
STORMWATER PERMITTING
Re: Termination of Coverage Under Stormwater Certificate of Coverage NCG200424
Keywell, L.L.C.
1157 Curtis Street
Monroe, NC 28112
To Whom It May Concern:
We respectfully request that the referenced stormwater certificate of coverage for our 1157 & 1163 Curtis
Street, Monroe, NC facility be terminated. We ceased all industrial activity at this location in August and
have removed all emission sources from the facility prior to this notification and request.
If you have any questions or concerns, please feel free to contact me at 708-608-8021 or our consultant,
Rob Duffy of Antea Group at 704-543-3919.
Sincerely,
11A�
J. Mark Lozier
Keywell Metals, L.L.C-
President
Cc: Ronald G. Gostek, Director -- Safety, Environmental & Construction
4

Compliance Inspection Report
Permit: NCG200424 Effective: 09/29/15 Expiration: 12/31/19 Owner: Keywell Metals LLC
SOC: Effective: Expiration: Facility: Keywell LLC - Curtis Street/Monroe
County: Union 1163 Curtis St
Region: Mooresville
Monroe NC 26112
Contact Person: Ronald G Gostek Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC{s):
On -Site Representative(s):
Related Permits:
Inspection Date: 11/19/2015
Primary Inspector: Tamera H Eplin
Secondary Inspector(s�:
Certification:
Phone:
Entry Time: 11:45AM Exlt Time: 12:15PM
Phone: [phone]
Reason for Inspection: Other Inspection Type: Technical Assistance
Permit Inspection Type: Wholesale Trade of Metal Waste and Scrap Stormwater Discharge COC
Facility Status: Compliant Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page: 1

Permit: NCG200424 Owner - Facility: Keywell Metals LLC
Inspection pate: 11/19/2015 Inspection Type : Technical Assistance Reason for Visit: Other
Inspection Summary:
Inspection conducted due to request to terminate coverage of NCG00424. The facility was apparantly vacant with no
exposed stormwater sources. The following was on a posted sign "Moved to 1035 Commercial Drive, Matthews 28104
704-234-8630,"
Recommend rescission of NCG200424.
Page: 2

Permit: NCG200424 Owner - Facility: Keywetl Metals LLC
Inspection Date: 11/19/2015 Inspection Type: Technical Assistance Reason for Visit: Other
Page: 3

Division of Water Quality / Surface Water Protection
s
�d NR
� National Pollutant Discharge i-llmination System
NCDE
"°" "0""°°"'°"THE "TO' ErPERMIT NAMEIOWNERSHIP CHANGE FORM
viaoHHe�r .Nn Nwrun.u. AEsaAecs
FOR AGENCY USE ONLY
Date Received
Year
Month Day
I. Plea Se enter the Permit IlLlrllbcl' 10r w111c11 the dmilgc is rCCILIeJted.
NPDFS Permit (or) Ccr•ti!icate ol,covcrals;c
N C S 0 ���� N C G �� 0 {1 Ak- IA
IL Perilmit status >'r Liar to requested Change.
a. Pcrnlit issued to (company name): Keywell L.L.C.
b. Person legally responsible for permit: Ronald G Gostek
First M I l.;ist
Scnior VP, Operations & Corporate Services
11900 South Cottage Grove Ave
�J Permit Holder Mailing Address
Chicago IL 60628
City State Zip
[phone] (773) 660-2-64 -
Phone F;Iz
C. Facility narllc (discharge): Ke},well Metals LLC
d. Facility address: I Ib3 CLI11i; Jtreet
l'lollroe NC. 28112
City w Slulc Zip
e. Facility contact Person: Daneel I'. 13uwalda [phone]
First 1 MI / Last Phone
III. Please provide the following for the requested chalige (revised permit).
a. Request for change is a result of: X Change in ownership of the facility
X Name change of the facility or owner
If olher please explain:
b. Permit issued to (company name):
c. P I- ' rl o�o/];sib!e for perrr.it:
FEB - 3 2017
D ✓VR - WA tMA1.tTy
Wedanes i c._�_
d. Facility name (discharge):
e. Facility address:
1. Facility colltact Pei -soil:
Keywell Metals LLC
_ Mar
J k_ Lozier
First M I I'asl
r
President
I ille
11900 SOLltll COlt;kt;e Grove AvVntic
Permit Holder \Mailing Address
Chicago I1, 00628
City Stale Zip
[phone] .IMI.Lozier@*Lk �welLcom _
Phone 1--mail Address
Keywell Metals LLC
1 163 Curtis Street
Address
Monroe NC 28112
City Stale Gip
Daniel P f3uwalda
First N11I Last
[phone] DPIIuwaIdat ra kevwell.com
Phone F-mail Address
Revised 2012Apr23

NPDES PERMIT NAME/OWNERSHIP CHANGE FORM
Page 2 of 2
IV. Permit contact information (if different from the person legally responsible for the permit)
Permit contact: Ronald G Gosick
First mi Last
Director— E?nvironmental & Corporate Services
Title
11900 South Cottaee Grove Ave
Mailing Address
Chicago 11, 60628
Cite State Zip
[phone] lt(i(-iu_ stc_kLo_1k_LyxyeIk:om
Phone I� mail rldch'css
V. Will the permitted facility continue to conduct the same industrial activities conducted prior
to (Iris ownership or name change?
0111
X Y:s
❑ No (please explain)
Required Items: THIS APPLICATION WILL BE RETURNED UNPROCESSED IF ITEMS
ARE INCOMPLETE OR MISSING:
X This completed application is required for both name change and/or ownership change
inquests.
X Legal doclnllCritatlon 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 incorponrtion 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. Fora name change request, the signed
Applicants Certification is sufficient.
I'1?RMITTEE CF10 1FICATION (fermis holder prior to ownership chan,,e):
I, Ronald G. Gostek, attest that this application fnr a name/ownership change has been rcvic%ved and is
accurate and complete to the best ofmy knowledge. I understand that il•all required parts O!'this
application are not completed ar7d that ifall required supporting inl•orrnation is not incluc[ecl this applicatiom
package will be returned as incomplete.
�A, Ax-�12/31/13
Signature �"4z Vf' 4�5 t�'2f Sew ✓r e F'S Date
APPLICANT CERTIFICATION
],,I. Mark Lezier, attest that this application for a name/ownership change has been reviewed and is
accurate and complete to the best of my knowledge. I 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 incomple r�
Sign lure Date
PLEASE SEND THE COMPLL 14' APPLICATION PACKAGE TO:
Division of Water Quality
Surface Water Protection Section
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Revised 712008

Pickle, Ken
From: Pickle, Ken ,
Sent: Monday, July 30, 2012 4:12 PM
To: Pickle, Ken; Parker, Michael
Cc: Bennett, Bradley
Subject: RE: Keywell, 1163 Curtis Street, Monroe, Tiered response monitoring
Unlikely alternative evaluation: Flawed field protocol or flawed lab work. But, the consultant is supposed to catch that
sort of thing.
Kbp
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. [e-mail]
Website: htta://Portal.ncdenr.org/web/wa/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations."
From: Pickle, Ken
Sent: Monday, July 30, 2012 4:08 PM
To: Parker, Michael
Cc: Bennett, Bradley
Subject: RE: Keywell, 1163 Curtis Street, Monroe, Tiered response monitoring
Hi Mike,
Just scanned the second Keywell request, for the site at 2826 Top Hill Road, in Monroe. Not such a bad site, and
probably we can work with them to a greater degree at this site.
HOWEVER, concerning the report assembled by,the consultant, Antea Group of North Carolina, from Charlotte.
• Now that I've read closely the Curtis Street report, I note that this one from Top Hill Road presents the same
language, in a formulaic approach that suggests a lack of attention to the project details and realities.----KBP
personal opinion.
• Speaking of details in the consultant's report: the first graph of the pH of the outfall, pH of the background
sample, and pH of the rainfall shows rainfall pH as fairly consistently running between 0.2 and 1.7. Obvious to
me that these guys have extraordinarily poor quality control in their work product, or the report author really
doesn't understand either rainfall, or pH.
• Further, on the copper graph, note that the rainfall copper concentration is shown in one sample as —1.75 mg/L.
Not possible. Inexcusable in a final product subject to senior review.
• Similarly for lead, with a graph showing again, 1.75 mg/L lead content in rainfall. Inexcusable.

Similarly for zinc, with a graph showing again, 1.75 mg/L zinc content in rainfall. This begins to look like one
mistake, compounded multiple times, and yet still escaping the notice of senior review.
As to the tabulated data at Top Hill Road:
No recurring problems with pH, COD, TSS, O&G, Cd, or Fe ---Good.
Pb monthly sampling returned to twice per year based on three consecutive results below the benchmark in
2011 ---Good.
As per the other site, however, Cu and Zn were reported greater than the benchmark in 9 of 11 samples, and 7
of 11 samples, respectively.
o For Cu, 6 background samples were below the PQL of 0,005 mg/L, one was below the benchmark, and
only one was in excess of the benchmark. Hard to tie off -site copper into the 9 copper exceedances
when really only one off -site background value would have been an exceedance on its own.
o For Zn, 6 background samples were below the benchmark, and two were above the benchmark. Hard to
tie off -site zinc into the 7 zinc exceedances, when only two off -site background values would have been
exceedances on their own. Of the two off-site'exceedances', one was associated with a discharge
exceedance — and one was associated with a compliant discharge. Again, hard to explain a connection
where none apparently exists.
What is still worth our attention and caution, however, is that both copper and zinc can be present in the environment,
and their toxicity is hardness dependant We should be cautious in how we use the zinc and copper exceedances as we
work with this facility.
(OK, back checking the graphs in the first report: l see C00s in rainfall of 30 mg/L and 50 mg/1---not possible; T55
reported as 300, 500, and 600 mg/L in rainfall --- not possible; copper at 0.62 mg/L, roughly 100 times the stormwater
benchmark; similarly for lead and zinc. I hove been there in my past life as a consultant putting together a report for
someone else, or at the last minute, and skipping senior review due to the press of time. Even when you know how it
happens, however, it's still awful.)
kbp
kbp
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. oickle(c ncdenr.gov
Website: httg://i)ortal.ncdenr.ora/web/wq/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From:, Pickle, Ken
Sent: Monday, July 30, 2012 2:38 PM
To: Parker, Michael
Cc: Bennett, Bradley
Subject: Keywell, 1163 Curtis Street, Monroe, Tiered response monitoring

'Hi Mike,
Thanks for the discussion this morning. I have a few comments on the request from the permittee, Keywell, to
discontinue the monthly sampling, and to return to the twice per year sampling regimen.
Based on our discussions, I also wonder what reduction of pollutant discharges from this site might be
feasibly/reasonably achievable, given the reported site configuration and other circumstances. I agree with you that
ultimately some accommodation or extended period of working with this site may be our best path forward.
But I have some contrary comments, too, on their proposal. While it is commendable that the permittee has done a
good bit of sampling (but not all the'permit requires of them), I would describe their interpretation that the monitoring
results support their request for a reduction in sampling effort as wishful thinking, at best. My inspection of the data
included in support of their request identified the following problems.
• Several notations in the tabulated data of 'Missed' or 'Not Sampled', including the entire second half of 2010.
• Several notations in the tabulated data of 'No Flow' spanning March, April, May, and June 2011, during which
time they were obligated to perform monthly sampling. Really? Four months without rainfall?
For COD, with a benchmark of 120mg/L: Ten of eleven sampling results exceeded the benchmark. In addition,
sixteen background samples were obtained in eight of the eleven events, and in no case did background
concentrations exceed the value reported from the site outfall, nor did any background value exceed the
stormwater benchmark, had it been applicable. -)There is no basis to conclude that this collection of data
points supports the argument that COD exceedances may be attributed in any significant part to off -site
sources.
For TSS, with a benchmark of 100 mg/L: Eleven of eleven sampling results exceeded the benchmark. In
addition, seventeen background samples were obtained in nine of the eleven sampling events, and in no case
did background concentrations exceed the value reported from the site outfall, nor did any background value
exceed the stormwater benchmark, had it been applicable. -)There is no basis to conclude that this collection
of data points supports the argument that TSS exceedances may be attributed in any significant part to off -site
sources.
• No continuing problems indicated for pH, O&G, Cd, or Fe, except that Keywell missed the required sampling
event in the first half of 2012 for Cd and Fe.
For the other metals, we need to proceed with a little caution in the interpretation of the permittee's results,
due to the factors affecting the toxicity of the heavy metals in the environment.
o For lead, with a benchmark of 0.03 mg/L: Four of eleven samples exceeded the benchmark.
Seventeen background samples were obtained, and in no case exceed either the benchmark, or the
reported discharge value. 4 There is no basis to conclude that this collection of data points supports
the argument that Pb exceedances may be attributed in any significant part to off -site sources.
o For copper, with a benchmark of 0.007 mg/L: Eleven of eleven samples exceeded the benchmark.
Thirteen of seventeen background samples would have exceeded the stormwater permit benchmark,
had it been applicable. Still however, in none of the seventeen background samples did the background
concentration exceed the concentration reported at the permittee's outfall. Typically we consider
copper as a 'ubiquitous' metal based on its presence in the soils in many places in North Carolina.
Further, its toxicity is related to hardness of the receiving water. On these points we are cautious as to
allowing our regulatory actions to be totally based on copper exceedances. it's still there in the runoff
from this site; it's still bad; but as a fully defensible basis for action, we are cautious in our
interpretation of copper values. In the worst reported outfall exceedance from this permittee, the
copper content was 27 times the benchmark value (0.193 mg/L on Nov 17, 2011 vs 0.007 mg/Q. It's
unclear to me whether we could conclude that off -site copper affected site discharges, but I suspect
that they did not impact the discharge value significantly.

o For zinc, with a benchmark of 0.067 mg/L., Eleven of eleven samples exceeded the benchmark.
Thirteen of seventeen background samples would have exceeded the stormwater permit benchmark,
had it been applicable. But again, in no case did any of the background concentrations exceed the
concentration reported at the permittee's outfall. Zinc is another metal we treat cautiously as a basis
for regulatory action, for the same reasons as listed for copper. But still, it's there in the runoff from
this site; it can be toxic depending on the receiving water hardness and dilution. The worst reported
value discharged from the site was 6 times the benchmark value (0.438 mg/L on March 2, 2012 vs 0.067
mg/L benchmark.) it's unclear to me whether we could conclude that off -site zinc affected site
discharges, but I suspect that they did not impact the discharge value significantly.
Beyond just the data, the consultant's report graphically suggests an area 11mile east to west by —Y, mile north to south
as discharging through the permittee's facility. I would expect to see a rather substantial channel for an area this large
in a developed urban area. But, the feature is barely visible in the aerial photo, and appears to run through the middle
of the permittee's site. Something's wrong here, either in my expectations, or in the conclusion that several industrial
operations, including some % mile distant drain through this facility.
So, what has this permittee done to address his exceedances? Commendably, a good bit of sampling, although not all
that he was required to do. And he has thrown out some hay bales. And he has explored the cost of repaving the gravel
area or of moving the site, concluding in both cases that it was too costly. And he has offered an extraordinarily weak
argument that off -site contributions exist at a level sufficient to excuse him from the continued monthly monitoring.
And further, by omission, that he be excused from further attempts to address the discharges of pollutants from his site.
It seems to me that he needs to explore more creative engineering alternatives to address his discharge of pollutants.
It's possible we Will wind up in the same place we are now, having to make some accommodations. And that would be
fine; if that's all we can feasibly do. But as far as we know, he has not really explored anything other than the two most
costly alternatives: Pave the world, and move. These are not real -world approaches. A more serious effort at problem
solving is indicated by the site circumstances, in my opinion.
ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. ickle ncdenr, ov
Website: htt ortal.ncdenr.or web w ws su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
4

Pickle, Ken
From: Bennett, Bradley
Sent: Monday, July 30, 2012 8:34 AM
To: Pickle, Ken
Subject: RE: Keywell, LLC Facilities - NCG200424 and NCG200463
I'll bring you the request. Could you try and talk to Mike.
Thanks
Bradley Bennett
Stormwater Permitting Unit
NC Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Phone: [phone]
Fax: [phone]
Email: bradley.bennett(@ncdenr.gov
Web: tp:Uportal.ncdenr.org/web/wq/wslsu
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
From: Pickle, Ken
Sent: Monday, July 30, 2012 8:06 AM
To: Bennett, Bradley
Subject: RE: Keywell, LLC Facilities - NCG200424 and NCG200463
Good morning Bradley,
Did you want me to follow up with these folks br with Mike?
Do you have the incoming requests for revision's to the Tiered structure?
Presumably Mike Parker would be the lead on this (as per our conceptualization of how this Tiered structure would work
upon the fourth exceedance), but we need to prime the pump a little with some initial input? Or do we need to take the
lead?
Ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mall Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. fickle@ncdenr,00v
Website: htto:L/portal.ncdenr.org/web/wq/ws/su

** Cfin6il correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Bennett, Bradley
Sent: Friday, July 27, 2012 3:37 PM
To: Parker, Michael
Cc: Pickle, Ken
Subject: Keywell, LLC Facilities - NCG200424 and NCG200463
Mike,
We just received requests for both of these facilities for modification to the tiered response monitoring requirements
think you got copies of these requests as well. I wanted to check and see what your thoughts were on their requests
and what they have done to this point under the permit to address their tier requirements. Please let me know what
you think.
L&I
Bradley Bennett
Stormwater Permitting Unit
NC Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Phone: [phone]
Fax: [phone]
Email: [e-mail]_
Web: http://p_ortal.ncdenr.org/webLwa/ws/su
Emall correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.

July S, 2012
Mr. Bradley Bennett, Unit Supervisor
Division of Water Quality
Stormwater Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Request for Storm Water Tiered Response Relief
Keywell L.L.C.
1163 Curtis Street
Monroe, NC 28112
General Perm}t Number NCG200424
Dear Mr. Bennett:
Kjwvw:LL
L. L. C.
__ 6W,96,46E /
MEN
Keywell L.L.C. (Keywell) located at 1163 Curtis Street, Monroe, Union County, North Carolina in
accordance with National Pollution Discharge Elirnination System (NPDFS) general permit number
NCG200000, discharges storm water to waters of the State.
The referenced facility has been performing tiered response monitoring since February 2G11 for chemical
oxygen demand, total suspended solids, copper, lead, and zinc. Lead concentrations have since fallen
below the benchmark values and are no longer a part of the tiered response. Keywhas conducted Q Ha
r
exhaustive research into the source of the metal pollutants as well as installed structure MPS to Combat
7SS levels. Up -gradient monitoring has demonstrated that a significant contribution of the metal( r44 S Ads �a
pollutants is coming fro p-gradient sources. Therefore, at this time we are writing to request relie` bee j sX. 01?.
from storm water tiered response with a return to semi-annual monitoring.
Please find enclosed a report prepared by our consultant that provides supporting information to our
request for relief from continued storm water tiered response monitoring. if you have any questions or
concerns, please feel free to contact me at [phone], or our environmental consultant, Rob Duffy of
Antea of USA, Inc., at [phone]. r__
Sincerely.' ' 4
K"' LX '�. P"'a-_
Ronald G. Gostek
Keywell, L.L.C.
Sr. VP Corporate Services
R
@I ffl
U
.1I.1! 2 6 2012
4ENFf yy�
gins Q a►nirrr
Cc: Mr. Michael Parker, NCDENR-Surface Water Protection Section, Mooresville Regional Office
Dan Buwalda, General Manager, Keywell, 11C
Tracy Owens, Manufacturing Engineer, Keywell, LLC
Louis F. Wagner, Jr.,.EVP and Corporate Counsel, Keywell. LLC
Attachment
of Scrap Q
�•
ISHI Recycling
Industries, Inc.
er■
KEYWELL L.L.0
11900 Soutn Cottage Grove Avenue
Chicago, IL 60625
[phone]
FAX [phone]

anteagroup
Request for Relief from Storm Water
Tiered Response Monitoring
Keywell, L.L.C.
1163 Curtis Street
Monroe, Union County, NC 28112
Antea Group Project No. 5E1201123P
June 28, 2012
Prepared for:
Keywell, L.I.C.
11900 South Cottage Grove Avenue
Chicago, IL
[phone]
Prepared by:
AnteaTmGroup of North Carolina, Inc.
8008 Corporate Center Drive, Suite 100
Charlotte, North Carolina 28226
[phone]

Request for Relief from
Storm Water Tiered Response
Antea Group Project No. 5E1201123P
To61e of Contents
anteagroup
1.0 INTRODUCTION - BACKGROUND.................................................................................................. 1
2.0 NCDENR ASSISTANCE.................................................................................................................................................. 1
3.0 RESULTS OF IMPLEMENTATION OF NCDENR RECOMMENDATIONS.......................................................................... 2
4.0 CONCLUSIONS.............................................................................................................................................................3
5.0 RECOMMENDATIONS..................................................................................................................................................3
6.0 REMARKS ......................................... .............................................................................................. I.,.... I......................3
Figures
Figure 1 Aerial Location Photograph
Figure 2 Site Layout Diagram
Appendices
Appendix A Laboratory Analytical Results Summary
Appendix B Laboratory Analytical Results Charts
Appendix C Site Photographs
www.anteagroup.com

Keywell, L.L.C.
Request for Relief of
Storm Water Tiered Monitoring
1.0 INTRODUCTION - BACKGROUND
Keywell L.L.C. (Keywell) located at 1163 Curtis Street, Monroe, Union County, North Carolina recycles nickel alloys.
The material handled by this facility is shipped in via truck, processed, and delivered to Keywell's customers or
other Keywell locations by truck. All processing operations are conducted under roof in the warehouse. A plasma
cutting operation is conducted outside on a covered pad and slag is not anticipated to collect in the area. The
torch cutting and abrasive blasting operations utilize dust collectors located outside to capture all dust, which is
not expected to deposit dust to the ground under normal operating conditions. Containerized materials are stored
outside. Up to approximately 400 tons per month of nickel alloy scrap are received by truck and in multiple
palletized containers. All containers of scrap are covered to prevent storm water contact. Lift trucks are used to
unload and transfer the alloys from trucks and around the facility. All materials are hand sorted. Approximately
80% of the solids are shot blasted, reloaded and shipped to customers and approximately 20% of the solids are
torch cut prior to shot blasting.
Keywell, in accordance with National Pollution Discharge Elimination System (NPDES) general permit number
NCG200000 discharges storm water to waters of the state. Beginning in February of 2011, Keywell has been
performing tiered response monitoring for the benchmark exceeding pollutants: total suspended solids, copper
and zinc in accordance with the requirements of the referenced permit. The materials processed at this facility do
not contain copper or zinc.
Keywell requested assistance from the Surface Water Protection Section of the North Carolina Department of
Environment and Natural Resources (NCDENR) Division of Water Quality, Mooresville Regional office as soon as
the tiered response requirements went into effect.
2.0 NCDENR ASSISTANCE
Mr. Michael Parker and Mr. Robert Krebs, both of the Mooresville Regional office conducted a site visit on April 1,
2011 in response to Keywell's request for assistance. At the conclusion of the April 1, 2011 visit by NCDENR, a
number of recommendations were made in an attempt to identify the source of the copper and zinc since Keywell
does not manufacture or process any materials that could potentially contribute copper and zinc to the storm
water discharge.
The recommendations included additional background sampling up -gradient of the facility to identify potential
sources of copper and zinc. Keywell identified the presence of a former automobile salvage yard that is now
closed and several other manufacturing sites up -gradient of their property. In addition, storm water flow follows a
railroad line that serves as a drainage corridor for storm water up -gradient of the Keywell property. According to
GoD
i � o
O�ri
?o
Cd
• ool
C�
,007
an 0 067
1 www.anteagroup.com

Keywell, L. L. C C�
Request for Relief from
Storm Water Tiered Response
Antea Group Project No. 5E1201123P a ntea g ro u p
local knowledge, the salvage yard was in operation for a period of greater than 50 years and the site still contains
much of the debris from the salvage operation. The identified numerous industrial manufacturing operations up -
gradient exhibit potential for contributions of copper and zinc. Drainage from the salvage yard and industrial
manufacturing properties all traverse the Keywell property via sheet flow as well as channelized flow via defined
drainage features that surround the Keywell property. Figure 1 presents an aerial photograph of the surrounding
area in which the various potential sources have been identified.
3.0 RESULTS OF IMPLEMENTATION OF NCDENR RECOMMENDATIONS
Just prior to Keywell's storm water outfall, sheet flow and channelized flows converge prior to discharge from the
Keywell property. Keywell began the implementation of background sampling in July 2011 and has performed
background sampling in conjunction with tiered response sampling through today. Background testing has
documented copper and zinc exceedences of the benchmark values. Appendix A presents a summary of the
analytical data to date. While the outfall monitoring results have continually demonstrated a higher concentration
for copper and zinc than the background monitoring results, the increase has be directly correlated to the amount
of rainfall received by the area. Analysis of the background sample results has indicated that the higher the
volume of water that traverses the Keywell property, the higher the copper and zinc concentrations as detected at
the outfall. Appendix B presents the analytical results charted for the identification of trends. There appears to be
a cumulative effect.
Keywell has had issues with total suspended solids exceeding the benchmark value. The gravel lot accounts for the
majority of the property and serves as a product storage area for materials to be processed and shipped to and
from the facility. The gravel lot is sloped from the rear of the property towards the buildings. This gravel lot is the
primary source of the total suspended solids. Keywell has implemented structural controls such as hay bales and
storm water diversion channels to alleviate the contact of storm water with their gravel lot. Keywell has explored
the possibl4ity of paving this area to prevent storm water runoff from capturing and transporting the gravel
material but costs are prohibitive. Keywell has also researched the possibility of moving to a location where
operations, loading/unloading, and staging of materials could all take place under roof. However, moving the
operation was also deemed cost prohibitive at this time.
Upon recommendation by NCDENR, the outfall sampling location has been moved to the end of a natural
vegetated channel approximately 75 feet in length from the original outfall location to the point of discharge to a
drainage ditch that follows Curtis Street. One monitoring event has been performed at this new monitoring
location. The resultantTSS concentration is still over the benchmark value, though vastly improved with a
concentration of approximately one half of the typical historical monitoring results. Figure 1 is an aeriai
photograph of the subject property and surrounding area. Figure 2 is a site layout diagram depicting the structural
www.anteagroup.com

Keywell, L.L.0
Request for Relief from
Storm Water Tiered Response
Antea Group Project No. 5EI201123P
r.�
anteagroup
controls that have been implemented at the site. Additionally, the site photographs in Appendix C depict the
conditions at the site.
4.0 CONCLUSIONS
Antea Group offers the following conclusions based on the analytical results, background monitoring, and site
improvements made by Keywell.
• Keywell has exhaustively investigated potential sources of copper and zinc on their property.
• Keywell has conducted investigations for potential up -gradient sources of copper and zinc through
background sampling.
• Sufficient evidence has been presented to indicate a significant contribution of copper and zinc from up -
gradient sources, whether point sources or non -point sources, which appears to be connected to the total
rainfall received by the area.
IP Keywell lies at the convergence of several channelized storm water drainage features that are
contributing significantly to Keywell's exceedences of the benchmark values for copper and zinc.
5.0 RECOMMENDATIONS
At this time and in light of the evidence collected which supports significant contributions of copper and zinc from
up -gradient sources as well as the recommendation of the NCDENR Moores0le Regional Office, Keywell would like
to request relief from the tiered response monthly monitoring requirements and resume semi-annual monitoring.
6.0 REMARKS
The conclusions and recommendations contained in this report represent Antea USA, Inc.'s professional opinions
based upon the currently available information and are arrived at in accordance with currently accepted
professional standards. This report is based upon a specific scope of work requested by the client. The contract
between Antea USA, Inc. and its client outlines the scope of work, and only those tasks specifically authorized by
that contract or outlined in this report were performed. This report is intended only for the use of Antea USA,
Inc.'s client and anyone else specifically identified in writing by Antea USA, Inc. as a user of this report. Antea USA,
lnc. will not and cannot be liable for unauthorized reliance by any other third party. Other than as contained in
this paragraph, Antea USA, Inc. makes no express or implied warranty as to the contents of this report.
3 www.anteagroup.com

Keywell, L.L.C.
Request for Relief From
Storm Water Tiered Response
Antea Group Project No. 5E1201123P
Figures
Figure 1 Aerial location Photograph
Figure 2 Site layout Diagram
anteagroup
www.anteagroup.com

y a a i1 �i3i tig ; t 1 b7 `i ti, S
12
IN' 5 -
yi
f I 7
M�
'4. -
3 _ tit ;
rit ?3.tp�
Fes.
_ "t'}¢atFz,
�•t ':YI's 4�q"
vert Pipe
4 r
perty Boundary

vgrc
0 BG001
a x X - _ BG002
X X X X X X x X x k X v
x x x x x x x x xi
x x x x x x x x x
x x x x x x x x x x x x x
x x x x x x x x x\Xx
x x
x x x x x x x x x x x
x x x x x x x x x xx x
x x x x x x x x x x
1x x x x x x x x x x x x
DS x x x X x X x X X x x
x x x x X X X x x x x x x
i X X,, X X x x x x x X x X x
Ik x x x x x x x x x x x x
jx x x x x x x x x x x x
x x x x x x x x x x x x
x x x x x x x x x x x x
x"u—.N x x x x x x x x x x x` r
x % X x x x x x x x x 9,
Legend
Grass
x x x Concrete Pad
s Gravel
Parking
Property Line
Building Outline
(� Storm Water Drain
Outfall 001
® Background
Sampling Location
-' Storm Water Flow
Hay Bale TSS
Blockade/Filtration
Q Sampling Location
Per NCDENR
x x . x x x x x X x x x x X i X x X X\`
x x x X X X x X X X x x -1 X X x X\
x x x x x x x x x x x x
x x x x x x x x x x x x x x x x x X X `'x a�x x x x x x
x X X X x x x x x X X x x x x x, x x x x x X x X X" x X X X
i x, x X x X X X X X x X x x x x x- x x x% x x x x x x x x
x x x x x x X X x x x x X x x X x X x X x X x X x x x x X. r
x x x x x X Y x X X x C X x x X X X x X X x x X X X
% x x x x x% x (r� x x x x x x x X x X x x X X X X x x
X x x x x x x€`• X hx�, �X_ x x x x x
X x x x x x x x x x x x x x x X X x x x tl `
x
x
X
OF001
Sampling Location
Figure 2: Site Layout Diagram Drawn By: RD
Keywell, L.L.C. Checked: RD ��_--
1163 Curtis Street Date: 6/7/2012 8008 Corporate Center Drive
Monroe, NC28112 Scale: NTS A"'1l5AnfN^•9^C^•NIIIA•I^C Charlotte, NC28226

Keywell, L.L.0
Request for Relief from
Storm Water Tiered Response
Anteo Group Project No. 5EI201123P
Appendix A
Laboratory Analytical Results Summary
antea'group
www.anteagroup.com

Parameter:
Rainfall
pH
COP
T55
O&G
Cadmium
Copper
Iron
Lead
Zinc
Method:
Local Rain Gauge
9040
5220D
2540D
1664A
200.7
2003
200.7
200.7
200.7
8MV:
>0.V.
6.0-9.0
120
100
30
0.001
0.007
NA
0.03
0.067
Units:
in
std.
mg/I
mg/I
mg/I
mg/I
mg/I
mg/I
mg/I
mg/I
Semi -Annual Period
Date
Type
Outfali
Comments
1st Half 2010
4/27/2010
Semi -Annual
OF001
None
0.30
6.3
55.00
1,720.00
<5.0
<0.001
0.130
62.6
0.0458
0.317
6/1/2010
Special
BG001
None
NA
NA
NA
<16.7
NA
NA
0.0063
75.1
<0.0050
0.162
2nd Half 2010
7/10 - 12/10
Semi-Annu4
NA
Not Sampled
2/4/2011
Tier I
OF001
None
0.10
8.2
529.00
2,110.00
<5.0
<0.001
0.366
88.700
0.0715
0A825
3/28/2011
Tier ll
OF001
No Flaw
1st Half 2011
April
Tier it
NA
No Flaw
May
Tier 11 y(
NA
No Flow
June
Tier II Y.NA
No Flow
7/31/2011
Tier II
OF001
None
0.10
NA
122.00
181.00
NA
NA
0.0627
NA
0.A068
0.160
7/31/2011
Tier II
8G001
None
0.10
NA
65.00
16.20
NA
NA
0.021
NA
<0.005
0.0956
7/31/2011
Tier II
BG002
None
0.10
NA
63.00
13.60
NA
NA
0.0218
NA
<0.005
0.100
8/12/2011
Semi -Annual
OF001
None
0.52
7.9
1.37.00
350.00
<5.0
<0.001
0.0626
10.400
0.0124
0.169
9/12/2011
Tier III
OF001
None
0.52
NA
128.00
478.00
NA
NA
0.0764
NA
0.0136
0.198
8/12/2011
Tier Ill
BG001
None
0.52
NA
<25.0
8.50
NA
NA
0.0056
NA
<0.005
0.0324
8/12/2011
Tier III
BG002
None
0.52
NA
<25.0
13.00
NA
NA
0.0064
NA
<0.005
0.037
9/6/2011
Tier III
OF001
INane
0.38
NA
265.00
1,190:00
NA
NA
0.181
NA
0.322
0.379
9/6/2011
Tier III
BG001
INone
0.38
NA
78.00
28.9
NA
NA
0.0215
NA
<0.005
0.108
2nd Half 2011
9/6/2011
Tier ill
BG002
I None
0.38
NA
75.00
31.6
NA
NA
0.023
NA
<0.005
0.114
10/11/2011
Tier III
OF001
None
0.41
NA
181.00
492.00
NA
NA
0.098
NA
0.018
0.213
10/11/2011
Tier III
BG001
None
0.41
NA
51.00
18.2
NA
NA
0.0177
NA
<0.005
0.0888
10/11/2011
Tier III
8GO02
None
0.41
NA
46.00
17.8
NA
NA
0.0184
NA
<0.005
0.0931
11/17/2004
Tier III
OF001
None
0.25
NA
380.00
233.00
NA
NA
0.193
NA
0.029
0.379
11/17/2011
Tier III
BGD01
None
0.25
NA
59.00
27.8
NA
NA
0.0204
NA
0.0083
0.118
11/17/2011
Tier III
BG002
None
0.25
NA
68.00
28.1
NA
NA
0.0215
NA
0.0075
0.123
12/7/2011
Tier III
OF001
None
0.24
NA
172.00
883.00
NA
NA
0.165
NA
0.028
0.357
12/7/2011
Tier III
BG001
None
0.24
NA
27.80
34
NA
NA
0.0155
NA
<0.005
0.116
12/7/2011
Tier III
BG002
None
0.24
NA
55.00
36.9
NA
I NA
0.0222
NA
0.0063
0.157
1/1/2012
Tier III k
All
No Flow
2/1/2012
Tier III k
All
No Flow
3/2/2012
Comp
OF001
None
0.22
7.2
330.00
1,080
<5.0
Missed
0.189
Missed
0.0236
0.438
3/2/2012
Comp
BG001
None
0.22
5.9
33.00
24
<5.0
Missed
0.014
Missed
c005
0.0722
1st Half 2012
3/2/2012
Comp
BG002
None
0.22
5.9
44.00
28
<5.0
Missed
0.0131
Missed
<.005
0.0716
4/1/2012
Tier III
OF001
No Flow
5/9/2012
Tier III
OF001
None
0.62
NA
424.00
388
NA
Missed
0.0633
Missed
0.0126
0.157
5/9/2012
Tier III
BG001
None
0.62
NA
<25.0
10.8
NA
Missed
0.0071
Missed
<.005
0.041
5/9/2012
Tier Ifl
IBG002
None
0.62
NA
<25.0
8.8
NA
Missed
0.0069
Missed
<.005
0.0387
cNP<} ari�p5 ll 11/
�I rnrS�d} 11 f� 1
��'S `lJ

Keywell, L.L.0
Request for Relief from
Storm Water Tiered Response
Anteo Group Project No, 5E1201123P
Appendix B
Laboratory Analytical Results Charts
anteagroup
www,anteagroup.com

Chart Data
Date
Rainfall
OF -COD
BG1-COD
BG2-COD
OF-TSS
BG1-TSS
BG2-TS',
4/27/2010
0.30
0-55
0_00
1.72
2/4/2011
010
5.29
0.00
2.11
7/31/2011
0.10
1.22
0.65
0.63
0.181
0.0162
0.0136
8/12/2011
0.52
1.37
0-473
0-0085
0.0013
9/6/2011
0.38
2-65
O.78
0.75
1.19
0.0289
0.0316
10/11/2011
0.41
1.81
0.51
0.46
0.492
0.0182
0.0178
11/17/2004
(.25
3.80
0.59
0.68
0.233
0.0278
0.281
12/7/2011
0.24
1.72
0.28
0.55
0.883
0.034
0.0369
3/2/2012
0.22
0.33
0.03
0.04
1.08
0.024
0.028
5/9/2012
0.62
0.42
0.00
0.00
;0.388
0.0108
0.0088
3F-Cu
BG1-Cu
BG2-Cu
OF -Ph
BG1-Ph
B(52-Pr
0.130
0.0458
0.366
0.0715
).0627
0.021
0.0218
0-0068
0-000
0.000
).0626
0.0056
0.0064
0.0124
0
0
0.181
0.0215
0.023
0.322
0
0
0.099
0.0177
0.0184
0.018
0
0
0.193
0.0204
0.0215
0.029
0.0083
0.0075
0.165
0.0155
0.0222
0.028
0
0.0063
0.189
0.014
0.0131
).0633
0.0071
0.0069
;.0126
0
0
OF-Zn
BG1-Zn
BG2-Zn
0.317
).0825
0.160
0.0956
0.100
0.169
0.037
0.379
0.379
0.108
0.114
0.213
0.0888
0.0931
0.379
0.118
0.123
0.357
0.116
0.157
0.438
0.0722
0.0716
0.157
0.041
0.0387

N'1
tLo
E
a
a
c
0
5.50
5.30
5.10
4.90
4.70
4.50
4.30
4.10
3.90
3.70
3.50
3.30
3.10
2.90
2.70
2.50
2.30
2.10
1.90
1.70
1.50
1.30
1.10
0.90
0.70
0.50
0.30
0.10
-0.10
6
COD: OF-001 vs. BG-001 vs. BG-002
-Rainfall tOF-COD —di BGI-COD --&—BG2-00D
irclIm /Of/ c o
�o T

TSS: OF-001 vs. BG-001 vs. BG-002
--*---Rainfall —43--OF-TSS ,n--BG3-TSS --#o*^BG2-TSS
2.20
2.10
2.00 -- --
C j 1.90
1.80
1.70
E 1.60
0 1.50
0 1.40
v
t 1.30
� V
a S 1.20
a E
1.10 -- --- -- —
o
o 0.90
0.80
d 0.70
U
0 0.60
0.50
0.40
10,20—
TSS BMV = 100 mg/I 1,00 0.1
.-
O O O O O O O O O ti 1 y -, 1 L ti ti ti ti 1 ti 'L '1 `L ", '11
O~ O, Oti Oti O� O~ O~ O� O, O~ O~ O, Q) 01 01 Q� O~ O, (3 Oti Q) O, (3 O, Oti 01
�\ti �\ti I\f" ,\ �V \ti ,\\T A\� A\� -\\� A\', A\'" -\\�" Al�v A\'' -N\;" A\, A\�'
4V r\ do\� titi,\ titi\� ti\� ti\ti \� o, 4\ , �\V � V 4V �\V ti0\� titi\� titi\� ti\� )\�
I?
Date
r
L
7-S

/) -.,a ./I
0.65
0.60
0.55
`0.50
0.45
0.40
ao
E s
aj 0.35
a
c w 0.30
a
o 0.25
c.�
r
0.20
0.15
0.10
0.05
0.00
L°�� L°tip Lati° L°ti1 L�ti1 L�ti1 L��� L°tip '4°ti~ 1°tit L°�� LQ) LQ) 'LQy 1°L��L L°�L '1°1'4 L°Zy
Date
?- 0- 7
!� /z- o4

0.65
0.60
0.55
0.50
0.45
0.20
0.15
0.10
0.05
0.00
�Q 1 yQ tiQ
N) 1Q y0 Z) 1Q 1� y1 titi 1b ti~ 1� 1ti ti� by �b �1 1ti tii 1l 1L tiL 1i 11
PJ� SQQ O�� boa Oe� >ac Fea lac PQc' �aa >J� �J\ P`,a; h�Q OG� ��, Oe` lac F�a' mac PQc' �aA ,J�

0.65
0.60
0.55
0.50
0.45
0.40
E s
-�
V
0.35
.2
0
ro
L
c 0.30
c �
u 0.25
0.20
0.15
0.10
0.05
0.00
Zinc: OF-001 vs. BG-001 vs. BG-002
--*--Rainfall --(D---OF-Zn -tea. BG1-Zn--,br-•BG2-Zn I
1
1A V
y /\ ��JA
Zn BMV = 0.067 mg/I
r�
10 NI) ;-1 N1 1� b� �� 1L ti� ,ti1 NN 11 �� b� ti� 1'L ", ti� 1i ti`L
le &c- �� Oe lam llz� `1`at PQ V
`1`a� �J� ��� J� SeQ O4ti boa 110 mat PQt �a� ,gyp

Keywell, L.L.C.
Request for Relief From
Storm Water Tiered Response
Antea Group Project No. SE1201123P
Appendix C
Site Photographs
C7
anteagroup
www.anteagroup.com

Photo 1: Primary storm water drain with grate and straw hales.
Photo 3: View- northerly from primary storm water drain.
Photo 5: View southwesterly from northern corner of property.
rI t.
fi
tt
r
�s. r a',�.
s 9s
!j to ,.`i:'h �F !; t
,t ti �•{ t
t , z •� ,� v4.�I •t.k
• ' - ' � rs^' n'�� to �
to
t
l ti ;, * e.. rE.� r � tE-;,,_ y 7 -� i ➢� �,y=if1 ��.
Phote 2: Primary storm water grate in loading dock area
0 ;i':
0�� tl: �-'
-n
t ,fit 1 r t3 s k4. r
Photo 4: View - northerly from loading docks
Photo 6: View southeasterly from northern corner of property.
Site Photographs• Page 1 PRDtECT NO: SE1201123P r '�
Keywell, Ill 6/7/2012
1163 Curtis Street & 8008 Corporate Center Drive, Suite 100
Monroe, NC 28112 anteagl00r Charlotte, North Carolina 28226

Photo 7: View -northerly- Loading docks during 0.29" storm event.
Photo 9: View -northerly. Loading docks alter 0.29" storm event.
Photo 11: View -northeasterly. Loading docks during 2D09's hurr ica nQ Ida.
Photo 8: View -easterly, Loading docks during 0.29" storm event.
Photo 10: View - southerly. Loading docks Biter 0,29" storm event.
Photo 12: View -northerly. Loading docks during 2009's hurricane Ida.
Site Photographs - Page 2 PROJECT NO: Si t
Keywell, L.L.C. DATE: 6/7/2012
1163 Curtis Street Q—f 8008 Corporate Center Drive, Suite 100
Monroe, NC 28112 ante8C roue Charlotte., North Carolina 28226

Photo 13: View -southerly. Loading docks during 2009's hurricane Ida.
Photo 1S: Aerial photo of 1157 Curtis Street's former tenant: truck salvage yard.
Photo 14: View -easterly. Loading docks during 2009's hurricane Ida.
Site Photogrpahs - Page 3 PROJECT NO: 5E 1201123F r
Neywell, L,L C. DATE; 6/7/2012"-�
1163 Curtis Street & 9008 Corporate Center Drive, Suite 100
Monroe, INC 28212 anteagroup Charlotte. North Carolina 28226

L
SUSTAINABLE STRATEGIES FOR GLOBAL LEADERS
October 28, 2009
Storm Water Permitting Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Storm Water Permit Renewal Application
Keywell, L.L.C.
1 163 Curtis Street
Monroe, NC 28112
SW Certificate of Coverage Number: NCG200424
To Whom It May Concern:
2
o
On behalf of our client, Keywell, L.L.C. (Keywell), we are submitting the
attached Storm Water Permit Renewal Application for the facility as referenced.
Please find an application package including the following.
• Two (2) copies of the applicable application forms and supporting
documentation; and
• A permit application fee for $100.00;
Please contact Rob Duffy of Delta Consultants at [phone] if you have any
questions during your review of the permit application.
Sincerely,
DELTA CONSULTANTS
eft*-C-/-
Rob Duffy
Project Manager
Enclosures
8008 Corporate Center Drive Suite 100 Charlotte, NC 28226 USA
Phone: 704,541.9890 / 800.477.7411 Fax:704,543.4035
www.deltaenv,yom

EMPTY DRUM STORAGE
TRASH
DOCK AREA FORKLIFT
RAMP
FRADI FRAD F L 4 OVERHEAD ROLL -UP TRUCK DOORS
RADIATION
DETECTORS
HEAR
FLOOR
SCALE
MATERIAL
STORAGE
PARTS
k
STORAGE
EVACUATION
MEETING
AREA
TaE:
SITE PROCESS DIAGRAM
KEYWELL, LLC.
MONROE, NC
D E LTA.
CONCRETE
STORAGE
AREA
TORCH -AREA - ---�
I
I
I
I
I
I
TORCH
L:�P
POWER AREA
COLLECTOR
WHEELEBRATOR -
DUST COLLECTORS
CHOPPER
PANGBORN --
r_- 0
TRANSFORMER
AND ELECTRIC
BOXES
L_�]
BATH I BATH
OFFICES, LUNCH AREA
AND UPSTAIRS STORAGE
I
DWN: DES.:
SH ftD
up�mNiff7
10/23/09 110/23/09
PROJECT NO.:
5EO909219P
FIGURE NO.:
2

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W, Klimek, 11.H. Director
Division of Water Quality
November 20, 2006
Keywell LLC
11900 S Cottage Grove Ave
Chicago IL, 60628
Subject: NPOES Stormwater Permit Coverage Renewal
Keywell LLC
COC # NCG200424
Union County
Dear Permittee:
In response to your renewal application for continued coverage under general permit NCG200000 the Division of
Water Quality (DWQ) is forwarding herewith the reissued stormwater general permit. Due to resource constraints,
the Division has been unable to adequately consider appropriate modifications to the permit. Therefore, the permit
has been reissued without changes from the previous permit, so all conditions remain the same. The permit term for
the reissued permit is two years, expiring on September 30, 2008. The general permit may be modified and reissued
prior to its expiration. The permit is reissued pursuant to the requirements of North Carolina General Statute 143-
215.1 and the Memorandum of Agreement between the state of North Carolina and the U.S. Environmental
Protection Agency, dated December 6, 1983.
The following information is included with your permit package:
A new Certificate of Coverage
A copy of General Stormwater Permit NCG200000
Your coverage under this general permit is not transferable except after notice to DWQ. The Division may require
modification or revocation and reissuance of the Certificate of Coverage. This permit does not affect the legal
requirements to obtain other permits which may be required by DENR or relieve the permittee from responsibility for
compliance with any other applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or
decree.
If you have any questions regarding this permit package please contact Yadkin -Pee Dee of the Central Office
Stormwater Permitting Unit at [phone], ext. Ken Pickle.
Sincerely,
tllaUlt:y M11111Uit, JUJACWLtt"Vt
Stormwater and General Permits Unit
cc: Central Files
Stormwater & General Permits Unit Files
Mooresville Regional Office
One
NorthCarolina
�1 atrrrrr!!�
Wetlands and Stormwater 13rurch 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone]
Internet: h2o.enr.state.naus 512 N. Salisbury St. Raleigh, NC 27604 FAX [phone]
An Equal OpportunitylAffirmative Action Employer — 50% Recycled/10% Post Consumer Paper

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG200000
CERTIFICATE OF COVERAGE No. NCG200424
STORMWATER 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,
KEYWELL LLC
is hereby authorized to discharge stormwater from a facility located at
Keywell LLC
1163 Curtis St
Monroe
Union County
to receiving waters designated as , a class Richardson Creek stream, in the C 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. NCG200000 as attached.
This certificate of coverage shall become effective November 20, 2006.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day November 20, 2006
for Alan W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

Michael 1. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Iaiviranment and Natural Resources
Alan W. Klimek, F.1;, Director
Division of Water Quality
July 25, 2005
Tony Tyson
Keywell LLC
11900 S Cottage Grove Ave
Chicago, IL, 60628
Subject: NPDES Stormwater Permit Coverage Renewal
Keywell LLC
COC Number NCG200424
Union County
Dear Permittee:
Your facility is currently covered for Stormwater discharge under General Permit NCG200000. This permit expires on
October 31, 2005. The Division staff is currently in the process of renewing this permit. When a draft version is
available for notice and public comment, it will be posted on our website at http://h2o.enr.state.nc.us/su/. 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, enclosed you will find a
Permit Coverage Renewal Application Form. The application must be completed and returned by August 19, 2005 in
order to assure continued coverage under the general permit. Letters confirming our receipt of the completed
application will not be sent.
Failure to request renewal within the time period specified 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 143-215.1 and
could result in assessments of civil penalties of up to $10,000 per day.
Please note that "no exposure exclusion" is now available to all operators of industrial facilities in any of the
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 facility 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 Permitting Unit Web Site at
http://h2c.enr.state.nc.us/su/.
If the subject stormwater discharge to waters of the state has been terminated, please complete the enclosed
Rescission Request Form. Mailing instructions can be found 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 Jonathan Diggs of the Central
Office Stormwater Permitting Unit at [phone], ext. 537.
Sincerely,
Bradley Bennett
Supervisor, Stormwater & General Permit Unit
Cc: Central Files
Mooresville Regional Office
SWPU Files
Wetlands and Stormwater nrancli 1617 Mail Scrvice Center Raleigh, NC 27699-1617 Phone [phone]
Intemet: h2o.em.state.ne us 512 N. Salisbury St. Raleigh, NC 27004 FAX [phone]h12
An Equal OppertunitylAffirmative Action Employer — 50% Recycled110% Post Consumer Paper
NunihCaruiina
�/�lltlll'lllilf

Michael F. Easley
Governor
William G. Ross Jr„ Secretary
Department of Environment and Natural Resources
October 18, 2002
Mr. Ronald G.Foster, Senior Vice President, Corporate Series
Keywell LLC
11900 South Cottage Grove Avenue
Chicago, IL 60628
Subject: General Permit No. NCG200000
Cert. of Coverage NCG200424
Keywell LLC
Union County
Dear Mr, Foster:
Alan W. Klimek, P.E.'Director
Division of Water Quality
In accordance with your application for discharge, the Division is forwarding herewith the subject Certificate of
Coverage to discharge under the subject state-NPDES general permit. This permit is issued pursuant to the requirements
of North Carolina General Statue 143-215 .1 and the Memorandum of Agreement between North Carolina and the US
Environmental Protection agency dated December 6; 1983.
If any parts, measurement frequencies or sampling requirements contained in this general permit are
unacceptable to you, you have the right to request an individual permit by submitting an individual permit application.
Unless such demand is made, the certificate of coverage shall jDgjinal and binding.
Please take notice that this Certificate of Coverage is not transferable except after notice to the Division of Water
Quality. The Division of Water Quality may require modification or revocation and reissuance of the certificate of
coverage.
This permit does not affect the legal requirements to obtain other permits which may be required by the Division
of Water Quality or permits required by the Division of Land Resources, Coastal Area Management Act or any other
Federal or Local governmental permit that may be required.
If you have any questions concerning this permit, please contact Mack Wiggins at telephone number 9191733-
5083, extension 542.
Si e1V,
Alan W. Klimek, P.E.
cc: Central Fifes
Mooresville Regional Office, Water Quality
Stormwater and General Permits Unit
Union County Health Department
T WIT
Ai
,NCDENR
Customer Service
1 800 623-7748
Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone]

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG200000
CERTIFICATE OF COVERAGE No. NCG200424
STORMWATER 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 nmetided,
Keywell LLC
is hereby authorized to disc;iaq,e stormwater from a facility located at
Keyweil LLC
t 163 Cbrtis Street
east Nloriroe
Union County
to receivin4, waters designated as ;rn unnamed tributary to Richardson Creek. a class C water in the Yadkin -Pee Dec
River Basin
in accordance with the effluent limitations, monitoring requirements. and other conditions set North in !'arts 1. 11, I11,
IV, V. and VI of General Permit No. NCG200000 as attached.
This certificate of coverage shalf"ZrMt effective October IS. 2002,
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day October 15, 200?. f
Alan W. KlimeT-P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

Markers
Name: Discharge Site-NCG200424
Short Name: Dschrg
Coordinates: 034' 58' 45.9" N, 080' 31' 34.1" W
Comment: Keywell LLC, Subbasin 030714, Yadkin -Pee Dee River Basin, Union County, unnamed
tributary to Richardson Creek, Class C, Quad H16NE