NCG030402_COMPLETE FILE - HISTORICAL_20181114

STORMWATER DIVISION CODING SHEET
NCG PERMITS .
PERMIT NO.
DOC TYPE
OF HISTORICAL FILE
❑ MONITORING REPORTS
DOC DATE
❑ 14
YYYYM MDD

RESEA11Ch & ANAyiriCA1
Report of Analysis
LA`11'1l A/•4T`U Ri ESp INC.
I012212018
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030CJ0-
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For: Universal Steel, Inc.
4,p4`� ••"'� •.,
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630 Bassett Drive
RECEIVED
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Thomasville, NC
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NC#34 z�
NOV 14
Attn: Angie Smith
2018
w NC A37701
CENTIV�L FILES
f�,'�+•'•�.�EG"T� ��5-.`•
DVVR SECTION
...' S
Client Sample ID: SW-1
Lab Sample ID:
57653-01
Site: Universal Steel
Collection Date:
10/11/2018 8:50
Parameter Method
Result Units Rep Limit AnalVs Analysis DatelTime
Copper, Total EPA 200.7
0.006 mglL 0.005
JF 10117/2018
Hydrocarbon O&G EPA 1664 Revision BlSilica Gel
<5 mglL 5
EE 10/17/2018
Lead. Total EPA 200.7
<0.005 mg1L 0.005
JF 10/17/2018
PH SM 4500 H+8-2000
7.23 Sid. Units
AP 10/22/2018 1003
r
Total Suspended Solids (TSS) SM 2540 D-1997
29.3 mg/L 5
AW 10/17/2018
Zinc, Total EPA 200.7
0.058 mglL 0.01
JF 10/1712018
Client Sample ID: SW-2
Lab Sample M.
57653.02
Site: Universal Steel
Collection Date:
10/11/2018 8:55
Parameter
Method
Result
Units
Rep Limit Analyst Analysis Dat%rrim_e
Copper, Total
EPA 200.7
0.011
mg1L
0.005
JF 10/1712018
Hydrocarbon O&G
EPA 1664 Revision B/Silica Gel
<5
mg1L
5
EE 10/17/2018
Lead, Total
EPA 200.7
0.016
mg1L
0.005
JF 10/1712018
pH
SM 4500 H+13-2000
7.37
Std. Units
AP 10/22/2018 1005
Total Suspended Solids (TSS)
SM 2540 D-1997
161
mg/L
5
AW 10/17/2018
Zinc, Total
EPA 200.7
0.104
mg1L
0.01
JF 10/17/2018
Client Sample ID: SW-3 Lab Sample ID: 57653-03
Site: Universal Steel Collection Date: 10/11/2018 9:00
Parameter Method Result Units Rep Limit Analyst Analysis DatelTi e
----9------
P.O. Box 473 106 ShortStreet Kernersville, Norih Carolina 27284 Tel: [phone] Fax: [phone] www.randalabs.com Page 1

RESEARCh & AAA y1fiCAL
Report
of Analysis
U b o Rego R i E S INC.
1 aiz2iz01 s
Client Sample ID:
Lab Sample ID:
Site:
Collection Date:
9:00
Parameter Method
Result
Units
Rep Limit Anatyst Analysis Date/Time
Copper, Total EPA 200.7
0.018
mg1L
0.005 JF
10/17/2018
Hydrocarbon O&G EPA 1664 Revision B1Silica Gel
<5
mg1L
5 EE
1011712018
Lead, Total EPA 200.7
0.083
mg1L
0.005 JF
10/17/2018
pH SM 4500 H+B-2000
7.61
Sid. Units AP
10/22/2018 1007
Total Suspended Solids (TSS) SM 2540 0-1997
119
mglL
5 AW
10/17/2018
Zinc, Total EPA 200.7
0.258
mg1L
0.01 JF
10/17/2018
NA = not analyzed
P.O. Box 473 106 Short Street Kernersville, North Carolina 27284 Tel: [phone] Fax: [phone] www.randalabs-com Page 2
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PAT McCRORY
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DONALD k, VAN,DER VAART
Secretary
Energy,. Mineral & TRACY DAMS
Land. Resources Illretior
ENV I RONMENTA46tUALITY
October 17, 2016
Angie Smith, Document Control
Universal Steel of NC, Inc.
630 Bassett Drive
Thomasville, NC 27360
Subject: Compliance Inspection
Permit No. NCG 030402
Universal Steel of NC, Inc.
Davidson County
Dear Ms. Smith:
On October 11, 2016 Glen White of the North Carolina Department of Environmental Quality —
Department of Energy, Minerals & Land Resources met with you and Patrick Hinshaw (Plant
Manager) at the subject facility, located at 630 Bassett Drive in Thomasville, to conduct a
compliance inspection for the facilities Industrial Stormwater Permit.
Permit:
This facility holds General Stormwater Permit NCG030402 to discharge stormwater from
industrial activity classified as Heat Treating of Metal (SIC 3398), Fabricating of Metal
Products (SIC 3398), Manufacturing of Measuring and Analyzing Instruments (SIC 38)
wider the National Pollutant Discharge Elimination System (NPDES)_ The permit became
effective November 1, 2012 and expires on October 31, 2017. A copy of the current permit is
required to be maintained with the Stormwater Pollution Prevention Plan (SPPP) documents. A
copy of the current permit was available for review at the time of inspection.
Records/Reports:
This facility was required to develop and maintain a Stormwater Pollution Prevention Plan
(SPPP) in accordance with Part 11, Section A of the permit. Inspector reviewed the SPPP and
each of its components. The SPPP has been updated annually as required. Training is conducted
monthly along with other required training and emergency response training. All employees
sign off on training log with pen and ink signatures. Monitoring is conducted according to the
permit. No deficiencies noted.
Facility Site Review:
This facility manufactures beams and structural steel components used in building construction.
There are less than 50 employees total with approximately 26 employees in the shop. The
remainder are office personnel. Clients are both local and in other states. Beams are
manufactured to customer specifications, loaded onto semi -trailers and delivered to the job site.
State of North Carolina. I Environmental Quality I Energy, Mineral and Land Resources
W ni ton -Salem Regional Office 1450 Hanes Mill Road, Suite 300 1 Winston-Salem, NC 27103
336 776 9800

Inspector walked the site with Ms. Smith and Mr. Hinshaw. The site appeared clean and well
maintained. There were loaded trailers waiting to be delivered and raw steel materials neatly
placed on the yard. All of the facilities production is performed under roof.
Effluent Receiving Waters:
Effluent from this facility drains to Hunt's Fork Creek, class "C" waters of the Yadkin Pee -Dee
River Basin,
Self -Monitoring Program;
Part II, Sections B & D of the permit require this facility to perform qualitative and analytical
monitoring on a semi-annual basis unless a Tiered Response is triggered. The site has been in a
Tier III response for some time due to consecutive samples resulting in exceedance of parameters
for Zinc and Copper. All other parameters have tested within limits except for one recent
exceedance for TSS. The issue has been investigated by Ms. Smith and Mr. Hinshaw.
Rainwater that has had no contact with any surface has tested with results that exceed the limit
for copper and zinc.
This letter will grant relief from monthly monitoring for the Zinc and Copper parameters
only. Monitoring may return to a semi-annual basis in Tier I Response. All parameters will
continue to be sampled bi-annually as per the permit. Consecutive exceedance under any other
parameter'will require the facility to return to a Tier II Response. Please continue to submit
monitoring results to the Stormwater Permitting Unit in Raleigh.
If you have further questions or require additional assistance please contact Glen White of
NCDEQ at 336-776-9660.
Enclosures: .
Inspection Report
Sincerely,
Matthew E. Gantt, P.E.
Regional Engineer
Land Quality Section
Winston-Salem Regional Office
cc: Division of Mineral and Land Resources (WSRO)
State of North Can:iGna I Environmental Quality. I Energy. Mineral and Land Resources
Winston-Salem Regional Office 1 450 Hanes Mill Road. Suite 300 I Winston-Salem. NC 27103
336 776 9800

Permit: NCG030402
SOC:
County: Davidson
Region: Winston-Salem
Compliance Inspection Report
Effective: 12/12/12 Expiration: 10131/17 Owner: Universal Steel of NC LLC
Effective: Expiration: Facility: Universal Steel of NC, LLC
630 Bassett Dr
Contact Person: William I Noethling Title:
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s)-
Related Permits:
Inspection Date: 10/11/2016 EntryTime: 10:OOAM
Primary inspector: Glen White
Secondary Inspector(s):
Certification:
Thomasville NC 27360
Phone: [phone]
Phone:
Exit Time: 11:OOAM
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Metal Fabrication Stormwater Discharge COC
Facility Status: ® Compliant [] Not Compliant
Question Areas:
® Storm Water
(See attachment summary)
Page: 1

permit: NCG030402 Owner - Facility: Universal Steel of NC LLC
Inspection pate:-1Oil 1/2016 Inspection Type : Compliance Evaluation Reason for Visit: • Routine
Inspection Summary:
(See Compliance Letter)
Page: 2

permit: NCGO30402 Owner - Facility: Universaf Steel of NC LLC
Inspection Date: fol1112016 . . • - .. Inspection Type : Compliance Evaluation Reason for Visit: Routine -
Analytical Monitoring
Has the facility conducted its Analytical monitoring?
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
Comment: Analytical monitoring currently monthly in Tier III Resoonse due to exceedance of zinc and
Yes No NA NE
■❑❑❑
❑❑®❑
copper on many occasions. The facility appears well maintained. The nature of this business_
requires storage__of steel... galvanized steel in many locations onsite. All materials are neatly
stacked and on gravel or paved areas or on trucks awaiting delivery. Relief will be granted for
Copper and Zinc only. Return to semi-annual monitoring. If other parameters are exceeded on
three consecutive occasions, Tier II response will be initiated. Monitoring frequency can be
reevaluated attain at any time and by any NCDEQ inspector.
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? ® ❑ ❑ ❑
# Were all outfalls observed during the inspection? ® ❑ ❑ ❑
# If the facility has representative outfalt status, is it properly documented by the Division? ❑ ❑ ® ❑
# Has the facility evaluated all illicit (non stomiwater) discharges? ❑ ❑ ❑
Comment: All outfalls observed. Site clean and well maintained. No deficiency found.
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ■ ❑ ❑ ❑
Comment: Qualitative monitoring performed at the same time analytical samples are taken. No
deficiencies.
Stormwater Pollution Prevention Plan
Yes No NA NE
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"?
N ❑ ❑ ❑
# Does the Plan include a detailed site map including outfall 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?
E ❑ ❑ ❑
# 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?
® ❑ ❑ ❑
Page: 3

Permit: NCG030402 Owner - Facility: Universal Steel of NC LLC
Inspection Date: 10/11/2016 Anspection Type; Compliance Evaluation ... , . . Reason for Visit: - Routine
Stormwater Pollution Prevention Plan Yes No NA NE
# Does the Plan include a list of Responsible Party(s)? ® ❑ ❑ ❑
# Is the Plan reviewed and updated annually? E ❑ ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program? ®❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented? ❑ ❑ ❑ ❑
Comment: All records appear to be maintained and current. Stormwater training added to monthly training
along with other required training and emergency response. No deficiencies.
Page: 4

Taylor -Smith, Aana
From: Taylor -Smith, Aana
Sent: Friday, August 23, 2013 10:40 AM
To: 'Bill Noethling'
Subject: RE: Request for information -Storm Water Pollution Prevention Plan
Sounds great! Email will be perfectly fine. Thanks very much, and have a great weekend!
Aana Taylor -Smith
Land Quality Section
Division of Energy, Mineral, and Land Resources
NC DENR Winston-Salem Regional Office
Phone: [phone]
Fax [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to
third parties.
From. Bill Noethling [mailto:[e-mail]]
Sent: Friday, August 23, 2013 10:40 AM
To: Taylor -Smith, Aana
Subject: RE: Request for information -Storm Water Pollution Prevention Plan
I am very close to having the plan ready to Submit to you.
Will emailing of the documents be OK?
Bill Noethlinq
Executive VP
Universal Steel Inc.
Buford Office 770-932-0415 ext 204
President
Universal Steel of North Carolina
North Carolina Office 336-474-2860 (Direct Line)
CELL 404-281-0300
bnoethling(a_universalsteelinc.com
From: Taylor -Smith, Aana [mailto:Aana.Taylor-Smith(a)ncdenr.gov]
Sent: Wednesday, August 07, 2013 3:17 PM
To: Bill Noethling
Subject: RE: Request for information -Storm Water Pollution Prevention Plan
Sounds good. It's always a good idea to be vigilant. lust let me know if there's anything else I can help you with.
Thanks, and have a great day!
Aana Taylor -Smith
Land Quality Section
Division of Energy, Mineral, and Land Resources

NC DENR Winston-Salem Regional Office
Phone: [phone]
Fax [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to
third parties.
From: Bill Noethling [mailto:bnoethlin universaisteelinc.com]
Sent: Wednesday, August 07, 2013 2:57 PM
To: Taylor -Smith, Aana
Subject: RE: Request for information -Storm Water Pollution Prevention Plan
We met with R&A today and they say they are on schedule but I have my concerns. [ will not
offer an extension unless we look. like there is no other way.
Thanks for your reply. We will be in touch soon.
Bill Noethling
Executive VP
Universal Steel Inc.
Buford Office 770-932-0415 ext 204
President
Universal Steel of North Carolina
North Carolina Office 336-474-2860 (Direct Line)
CELL 404-281-0300
bnoethlingCa7universaisteelinc.com
From: Taylor -Smith, Aana[maiIto: Aana.Taylor-SmithCa_ncdenr.gov]
Sent: Wednesday, August 07, 2013 2:41 PM
To: bnoeLhiing cuuniversaisteelinc.com
Subject: RE: Request for information -Storm Water Pollution Prevention Plan
Hi Bill,
As1en mentioned, I will be handling your file as of the August 1 transition of stormwater programs to the Land Quality
Section. Thanks for contacting us and being proactive about the Stormwater Pollution Prevention Plan! If R&A Labs is
unable to meet the August 31 deadline for your new Plan, I would be happy to work with you on an extension. Please let
me know if you have any questions about the Plan or the permitting process. You can reach me at [phone],
though i am often in the field, so email may be more convenient. Additionally, if your contacts at R&A Labs have any
questions, feel free to send them my way.
Thanks again, and I look forward to working with you!
Aana Taylor -Smith
Land Quality Section
Division of Energy, Mineral, and Land Resources
NC DENR Winston-Salem Regional Office
Phone: [phone]
Fax [phone]

E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to
third parties.
From: Carter, Jenifer
Sent: Tuesday, August 06, 2013 1:22 PM
To: Bill Noethling
Cc: Taylor -Smith, Aana
Subject: RE: Request for information -Storm Water Pollution Prevention Plan
RED
I apologize, but due to recent changes to the division, you will now be dealing with Aana Taylor -Smith in the Division of
Energy, Mineral & Land Resources (DEMLR). She has been made aware of your pending work & deadline, and will work
with you from this point forward. I have cc'd her on my response to you, so you should receive a reply from her. She
can be reached at 336-771-5034 or [e-mail].
It was a pleasure working with you. I'm sure you will find Aana easy to work with.
Best of luck,
Jenifer Carter
Before printing this email, please consider your budget and the environment.
If yt)u must print, pleasz print only «•hilt you sized and sari ink with the free Eco-Font.
NC DENR Winston-Salem Regional Office
Division of Water Resources
585 Wau-htown Street
Winston-Salem, NC 27107
Voice: [phone]
FAX: [phone]
E-mail correspondence to and from this address may be subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Bill Noethling[mailto:bnoethlingCabuniversalsteelinc.com]
Sent: Tuesday, August 06, 2013 1:00 PM
To: Carter, Jenifer
Subject: RE: Request for information -Storm Water Pollution Prevention Plan
I have retained the firm Research & Analytical Labs to prepare the stone.i water plan and do
subsequent monitoring until such time as .I can have our folks trained to do the sample. R&A
will still do the lab work.
My question is this:
Can I get an extension past 8/31 if R&A misses the date they have promised me?
They are supposed to have me something ready to submit to you by 8/20 but I am just trying to
cover my bases should they drop the ball.
Thanks

Bill Noethling
Executive VP
Universal Steel Inc.
Buford Office 770-932-0415 ext 204
President
Universal Steel of North Carolina
North Carolina Office 336-474-2860 (Direct Line)
CELL 404-281-0300
bnoethlingAuniversallsteelinc.com,
From: Carter, Jenifer [mailto:[e-mail]]
Sent: Monday, June 24, 2013 3:31 PM
To: Bill Noethling
Subject: RE: Request for information -Storm Water Pollution Prevention Plan
Here you go. Let me know if you need anything else.
Jenifer
A
Before printing this email, Please consider your budget and the environment.
If you nIust print. please print only what you need and sage ink with the iree Eco-Font. .
NC DENR Winston-Salem Regional Office
Division of Water Quality
585 Waughtown Street
Winston-Salem, NC 27107
Voice: [phone]
FAX: [phone]
E-mail correspondence to and from this address may be subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Bill Noethling [mailto:[e-mail]]
Sent: Monday, June 24, 2013.12:22 PM
To: Carter, Jenifer
Subject: Request for information -Storm Water Pollution Prevention Plan
Dear Ms. Carter:
Back in February you visited our plant in Thomasville. You issued a "Notice of Deficiency"
dated 2/25/13.
In this letter you stated that a list of certified laboratories was enclosed.
I seem to have misplaced this list and was wondering if you could supply this list to me again.
I have begun the process and plan to have all items addressed before the 8/31/13 deadline.
Please forward this list to me at your earliest convenience so that I may continue with my
process to come into compliance.
Thank You.
Bill Noethling

Executive VP
Universal Steel Inc.
Buford Office 770-932-0415 ext 204
President
Universal Steel of North Carolina
North Carolina Office 336-474-2860 (Direct Line)
CELL 404-281-0300
[e-mail]

UNIVERSAL STEEL
STORM WATER POLLUTION PREVENTION PLAN
SWPPP
630 Bassett Drive formerly 502 Albertson Road
Thomasville, North Carolina 27360
DATE: August 9, 2013
PREPARED BY:
HUGH CREED ASSOCIATES, INC., P.A.
1306 W. WENDOVER AVENUE
GREENSBORO, NORTH CAROLINA 27408
TELE: 336-275-9826
FIRM LICENSE 4 C-0551
KAUniversal SteellStormwater Pollution Prevention Plan.doc
1
ge,C)d Tey'►uiL 5123 + k3 Aa

1.0 INTRODUCTION
1.1 BACKGROUND
The U.S. Congress passed the Federal Water Pollution Control Act (FWPCA), also
known as the Clean Water Act (CWA) in 1972 to restore and maintain the quality of our
nation's waterways. The ultimate goal of this action was to ensure that our rivers and
streams were fishable, swimmable, and drinkable. In 1987, the Water Quality Act (WQA)
implemented provisions to the CWA that allows the EPA to govern storm water
discharges from industrial activities. The EPA published the final notice for Phase I of
the Multi -Sector General Storm Water Permit Program (Federal Register, volume 60 no.
189, September 20, 1995, page 50804) in 1995, which included provisions for the
development of a Storm Water Pollution Prevention Plan (SWPPP) by each industrial
facility discharging storm water, including steel fabrication facilities.
The development, implementation, and maintenance of the SWPPP will provide
Universal Steel Inc. with the ability to reduce pollutants contained in their storm water
discharges and comply with the requirement of the General Storm'Water Permit issued
by the State of North Carolina (Permit No. NCG030000). The primary goals of this
SWPPP will be as follows:
• Identify potential sources of pollutants that affect storm water discharges from the
site.
• Describe the practices that will be implemented to prevent or control the release
of pollutants in storm water discharges.
• Create an implementation schedule to ensure that the practices described in this
SWPPP are in fact implemented and to evaluate the plan's effectiveness in
reducing the pollutant levels in storm water discharge.
2.0 SWPPP COORDINATOR AND DUTIES
The SWPPP Coordinator for Universal Steel is Plant Manager Mr. Richard Roth
(telephone no. [phone]). Mr. Roth's duties include the following:
• Create and maintain a SWPPP team to assist in the implementation of the
SWPPP.
• Implement the SWPPP.
• Oversee maintenance practices for all containment areas in the SWPPP.
• Implement and oversee employee training.
KAUniversal StechStormwater Pollution Prevention Plan.doc
2

• Schedule inspections and/or monitoring activities.
• Identify new sources of potential pollutants, and ensure they are added to the
SWPPP.
• Identify any deficiencies in the SWPPP and make sure they are corrected.
• Prepare and submit testing and reports.
• Identify any changes in the facility's operation and ensure they are addressed in
the SWPPP.
3.0 FACILITY DESCRIPTION
3.1 FACILITY LOCATION
Universal Steel is located at 502 Albertson Road in Thomasville, North Carolina. Figure
I is a vicinity map showing the facility's location. The facility is located on a 9.10-acre
parcel, which is described in Deed Book 1841, Page 595 in the Davidson County Register
of Deeds. The facility is bound on the north by commercial property owned by the
Eddinger Real Estate Lp, on the east and south by a commercial business owned by 416
Albertson LLC., on the west by Albertson Road.
3.2 SITE ACTIVITIES
The facility is a custom fabricator of steel products. Large, pieces of steel of various
types are stored indoors or on -site in the storage yard beside the facility. Customers order
the aesirea type of product ( i-ocani5 ac steel panels to be rnauz ►vr custom pu,yoscs.
The base steel pieces are delivered to the facility in the receiving/storage area. The steel
is then cut, shaped, and welded to the desired length, depth, and width. The saws use a
lubricant to reduce wear and heat that is stored inside and is recycled as needed. The
punches and drills use an oil based lubricant that is stored inside and is recycled as
needed.
After the cutting process is complete the metal parts are welded and grindedldressed in
preparation for painting. The steel products are then painted on site in a separate area of
the facility, with the paint being stored under a covered shelter attached to the facility.
The empty paint containers are stored in an outside area until they are recycled.
3.3 SITE DESCRIPTION
The site is a 9.10-acre lot on the east side of Albertson Road. Approximately 4.97 acres is
impervious surface area, (i.e. pavement, concrete, building and gravel storage yard) for a
total of 55% impervious surface. ,
K:\Universal SteehStormwater Pollution Prevention Plan.doc
3

3.4 STORM WATER DRAINAGE SYSTEM
This site is divided into five major drainage areas. Table 1 describes the significant
characteristics of each drainage area. Figure 2 shows the locations of the drainage
patterns. Area 1 is the asphalt parking area that has potential vehicle leaks that require
observation and response for potential contamination. Area 2 is the gravel parking area
that has potential vehicle leaks that require observation and response for possible
contamination. Areas 3 and 4 are within gravel areas and have elevated potential for
contamination from empty paint containers. This area should have routine monitoring of
containment area for paint contamination. Area 5 is a gravel/grass area on the south side
of the building. This area has a low possible contamination from the paint storage area (
covered and contained). Area 6 is a gravel/grass area that has potential vehicle leaks from
employee's car that will require observation and response for possible contamination.
All drainage areas drain into the existing Hunts Fork creek running south of the site (not
on site), which then drains South West to Rich Fork Creek then to Abbots Creek then
High Rock Lake and ultimately to the Yadkin -Pee Dee River System.
TABLE 1
CHARACTERISTICS OF STORM WATER DRAINAGE
DRAINAGE
STORM WATER
TOTAL SIZE
IMPERVIOUS
RUN-
DRANAGE
AREA
FLOW
(SQ. FT.)
SURFACE AREA
OFF
DISCHARGE
DESCRIPTION
(SQ. FT.)
COEFF.
POINT
DA-01
ROOF DRAIN
54.786 SQ. FT.
33,213 SQ. FT.
HIGH
PROPERTY LINE
DISCHARGES
DRAW TO THE
AND PARKING
EAST
LOT RUNS TO
DITCH BESIDE
GRAVEL DRIVE
DA-02
ROOF DRAINS &
86,100 SQ. FT.
567111 SQ. FT,
LOW
DITCH ALONG
GRAVEL
GRAVEL DRIVE
PARKING LOT
TO THE NORTH
RUN-OFF;GRASS
AREA
DA-03
ROOF DRAINS
40,074 SQ. FT.
40,074 SQ. FT.
HIGH
YARD INLET;
& GRAVEL
PROPERTY LINE
DRIVE, AND
DRAW TO EAST
REAR GRAVEL
STORAGE YARD
ALONG BUILD.
DA-04
ROOF DRAINS &
24.721 SQ. FT.
14,862 SQ. FT.
HIGH
YARD INLET:
REAR GRAVEL
PROPERTY LINE
STORAGE AREA
DRAW TO
ALONG BUILD.
EAST
ROOF DRAINS &
26,350 SQ.FT.
19,033 SQ.FT.
HIGH
YARD INLET:
DA-05
GRAVEL LOT
PROPERTY LINE
DRAW TO EAST
ROOF DRAINS &
66,475 SQ.FT.
26,115 SQ.FT.
LOW
DRAW TO
DA-06
GRAVEL DRIVE;
SOUI'H;PROPERTY
GRASS AREA
LINE DRAW TO
EAST
KAUniversal SteeINStormwater Pollution Prevention Plan.doc

4.0 IDENTIFICATION OF POTENTIAL STORM WATER CONTAMINANTS
This section identifies significant materials and operations located at the facility that may
potentially contaminate storm water. Additionally, this section presents a record of past
spills and identifies potential areas for storm water contamination, and summarizes
available storm water sampling data.
4.1 SIGNIFICANT MATERIAL INVENTORY
The materials used by this facility that has a potential to be present in the storm water are
the paint residues form the empty painter containers. The containers should be stored
inside or stored outside in a covered area with containment. There may be large amounts
of iron oxide ( rust) present in the runoff from the steel itself. The iron oxides are inert
and pose no chemical pollution to the environment, other than the suspended sediment
particles that could make storm water run-off "cloudy" colored until they settle out.
4.2 HISTORIC SPILL AND LEAK RECORD
There have been no reported leaks or spills at this facility within the past 3 years
4.3 POTENTIAL AREAS FOR STORM WATER CONTAMINATION
The following potential source areas of storm water contamination were identified in
each drainage area and evaluated as follows:
DA-0 I
East Side Building has a paved parking area that has potential for storm water pollution
from vehicles leaking fluids onto the parking lot and running off into the ditch along the
gravel drive. The roof drains have some potential if they were to washout at the
downspouts.
DA-02
Vehicle Parking Lot on the north side of the property from trucks delivering raw
materials and turning around. Possible vehicles leak contamination. Roof drains have
some potential if they were to washout at the downspouts
DA-03
Gravel storage lot along build has a possible contamination from storage of empty paint
containers. Roof Drains have some potential if they were to washout at the downspouts.
KAUniversal Stec AStormwater Pollution Prevention Plan.doc
5

DA-04
North Gravel Storage Area has the potential for storm water pollution from vehicle fluid
leaks and overflow during heavy ran events from empty paint storage containers.
DA-05
Southern Gravel Storage Area has potential for water pollution from a major spill in the
paint storage area. Roof Drains have some potential if -they were to washout at the
downspouts.
DA-06
Southern most drive parking area has potential from vehicle fluid leaks from employee
parking area.
Table 2 presents site -specific information regarding storm water pollution potential from
each of these areas:
TABLE 2
LOCATIONS OF POTENTIAL SOURCES
OF STORM WATER CONTAMINATION
DRAINAGE
POTENTIAL STORM WATER
POTENTIAL
POTENTIAL PROBLEM
AREA
CONTAMINATION POINT
POLLUTANTS
DA-01
DOWNSPOUTS, PARKING
SEDIMENT,
POSSIBLE WASHOUTS AT
LOT ALONG GRAVEL DRIVE.-
OIL,FLUIDS FROM
DOWNSPOUTS. POSSIBLE
DITCH -DRAW ALONG EAST
CARS
LEAKING OF VEHICLE
PROPERTY LINE
FLUIDS PARKED IN LOT
DA-02
VEHICLE LEAKS: GRAVEL
VEHICLE OIL,
POSSIBLE LEAKING OF
LOT/STORAGE AREA:DTTC1.1
FLUIDS
VEHICLE FLUIDS PARKED
NORTHERN PROPERTY LINE
IN GRAVEL LOT
DA-03
DOWNSPOUTS:GRAVEL
SEDIMENT, PAINT
POSSIBLF WASHOUTS AT
STORAGE AREA: PIPE OUTLET
RESIDUE FROM
DOWNSPOUTS, POSSIBLE
— DRAW TO EAST PROPERTY
PAINT CONTAINERS
PAINT RESIDUE WASHING
LINE
INTO STORM INLET
DA-04
DOWNSPOUTS:GRAVEL
SEDIMENT, PAINT
POSSIBLY: WASHOUTS AT
STORAGE AREA/DRIVE: PIPE
RESIDUE
DOWNSPOUTS, POSSIBLE
OUTLET DRAW ALONG EAST
PAINT RESIDUE WASHING
PROPERTY LINE
INTO STORM INLET
DA-05
DOWNSPOUTS: GRAVEL
SEDIMENT, PAINT
POSSIBLE WASHOUTS AT
DRIVETIPE OUTLET DRAW
DOWNSPOUTS, POSSIBLE
ALONG EAST PROPERTY LINE
PAINT LEAK WASHING
INTO STROM INLET
DA-06
DOWNSPOUTS, GRAVEL DRIVE
SEDIMENT.VEHICLE
POSSIBLE WASHOUTS AT
PARKING LO'r
OIL, FLUIDS
DOWNSPOUTS,LEAKING
OF VEHICLE FLUIDS
PARKED IN GRAVEL LOT,
5.0 STORM WATER MANAGEMENT CONTROLS
This section discusses the storm water management controls in place and additional
control measures selected to address the areas of concern identified in Section 4 of this
SWPPP.
K:\Universal SteehStormwater Pollution Prevention Plan.doc

5.1 STORM WATER MANAGEMENT PRACTICES
Upon reviewing the potential pollutants at the facility and the facility operations, a list
was prepared of planned best management practices (BMPs) for each area of concern.
DA-01
This area is the office parking area for the facility. This area should be policed daily to
check under and around vehicles for spills or leaks. Spills should be cleaned up
immediately and properly disposed of. Leaks should have a container placed under the
vehicle to catch the leak until it can be properly fixed.
DA-02
This area is the northern/western gravel area. Although no vehicles park in this area on a
regular basis, they do drive in and out of this area. These vehicles should be checked for
leaks or spills and any leaks should be cleaned up immediately.
DA-03
This area is the northern gravel area. Although no vehicles park in this area on a regular
basis, they do drive in and out of this area. These vehicles should be checked for leaks or
spills and any leaks should be cleaned up immediately. Also any empty painter containers
in this area should be sealed and disposed of in a timely manner to prevent
contamination. If contamination is found a containment area should be built with a cover
to protect against storm«rater runoff.
DA-04
This area is the northwest rear gravel storage area. Although no vehicles park in this area
on a regular basis, they do drive in and out of this area. These vehicles should be checked
for leaks or spills and any leaks should be cleaned up immediately.
DA-05
This area is the southern rear gravel drive area. Although no vehicles park in this area on
a regular basis, they do drive in and out of this area. These vehicles should be checked for
leaks or spills and any leaks should be cleaned up immediately. Also, care should be
taken to avoid paint spills from paint storage area, the area should be checked daily to
ensure no paint leaks enter storm water inlet 93
DA-06
This area is the western side of building and southern property line area. This area is the
employee parking area for the facility. This area should be policed daily to check under
and around vehicles for spills or leaks. Spills should be cleaned up immediately and
properly disposed of. Leaks should have a container placed under the vehicle to catch the
leak until it can be properly fixed.
KAUniversal SteehStormwater Pollution Prevention Plan.doc
7

6.0 FACILITY MONITORING PLAN
A. SEMI-ANNUAL DRY WEATHER INSPECTION
Visual inspections of all drainage areas will be made quarterly, during dry weather
conditions, for evidence of non -storm water discharges. The visual inspection will be
completed by an employee under the SWPPP coordinator's direction. The dry weather
inspections will verify the site is not discharging sanitary or processed water to the storm
system. Information recorded on the inspection log shall include: date of inspection,
location point (# ON site Plan), inspection results, and potential significant sources of
non -storm water discovered. Blank Dry -Weather Inspections forms can be found in
Appendix A of this SWPPP.
B. SEMI-ANNUAL RAIN EVENT INSPECTION
Universal Steel will perform quarterly visual inspections of all drainage area points
during rain events to look for evidence of storm water contamination. Inspections will be
conducted within the first thirty (30) minutes of discharge or soon thereafter, but not
exceeding sixty (60) minutes. The visual inspection shall include any observations of
color, odor, turbidity, floating solids, foam, oil sheen, or other obvious indicators of
storm water pollution. Information recorded during the quarterly inspection shall include:
date of inspection, location points (# on Site Plan), inspection results, and potential
significant sources of storm water contaminants, if discovered. Blank Quarterly
Inspections forms can be found in Appendix A of this SWPPP.
C. ANNUAL STORM WATER COMPLIANCE INSPECTION
An annual storm water compliance inspection will be conducted approximately one year
following implementation of this SWPPP and annually thereafter. The inspection will
determine if site operations have changed since development of this SWPPP. If
operational changes have been made, the SWPPP coordinator will determine if those
changes will impact storm water quality and develop new BMPs to address the change.
All operational changes and new BMPs will be recorded in this SWPPP. Additionally,
the inspection date, the inspection personnel, the scope of the inspection, major
observations, and any needed revisions will be recorded. Revisions to the plan will occur
within thirty (30) days after the annual inspection. Blank Annual Compliance Inspections
forms can be found in Appendix A of this SWPPP.
7.0 COMPLIANCE AND REPORTING REQUIREMENTS
7.1 SWPPP AND SWPPP SUMMARY
As per the requirements of the general permit No. NCG030000, Universal Steel is
required to prepare and implement a SWPP Plan. The SWPPP will be kept at the facility
and will be made available to the state or federal compliance inspection officer upon
request.
K:\Universal SteehStormwater Pollution Prevention Plan.doc
8

7.2 EMPLOYEE TRAINING
An employee training program will be developed and implemented to educate employees
about the requirements of the SWPPP. This education program will include background
on the components and goals of the SWPPP and hands-on training in spill prevention and
response, good housekeeping; proper material handling, disposal and control of waste,
container filling and transfer, and proper storage, washing and inspection procedures. All
new employees will be trained within one creek of their start date. Additionally, all
employees will be required to participate in an annual refresher training course. An
employee sign in sheet for the refresher course can be found in Appendix A of this
document. The training program will be reviewed annually by the SWPPP coordinator to
determine its effectiveness and to make any necessary changes to the program.
7.3 IMPLEMENTATION SCHEDULE
Specific actions that must be taken to fully implement this SWPPP as dictated in General
Permit No. NCG030000 are identified in the following table:
SWPPP IMPLEMENTATION
ACTIONS
SCHEDULE
PLAN CERTIFICATION
UPON RECEIPT OF PLAN
STORM WATER POLLUTION PREVENTION TEAM
MEETINGS
ANNUALLY SEPTEMBER/OCTOBER
ANNUAL TRAINING
ANNUALLY SEPTEM BE R/OCTOBER
CONDUCT FACILITY INSPECTIONS
SEMI-ANNUALLY SEPTEMBER/ OCTOBER AND
MARCI I/APRIL
CONDUCT VISUAL OBSERVATION OF OUTFLOW
SEMI-ANNUALLY SEPTI:MBER/ OCTOBER AND
MARCH/APRIL
CONDUCT STORM WATER MONITORING
SEMI-ANNUALLY SEPTEMBER/ OCTOBER AND
MARCHIAPRIL
UPDATE AND AMEND PLAN
ANNUALLY AND AS NECESSARY TO ADDRESS
MODIFICATIONS AT THE FACILITY
7.4 RECORDS RETENTION REQUIREMENTS
Records described in the SWPPP must be retained on -site for five (5) years (the permit
effective coverage) and shall be made available to the state or federal compliance
inspection officer upon request. Additionally, employee training records and waste and
recycling receipts or vouchers shall also be maintained.
K:1Universal Steel\Stormwater Pollution Prevention Plan.doc
9

7.5 PROVISIONS FOR AMENDMENT OF THE SWPPP
If the facility expands, experiences any significant process modifications, or changes any
significant material handling or storage practices which could impact storm water, the
SWPPP will be amended appropriately. The amended SWPPP will have a description of
the new activities that contribute to the potential increased pollutant loading and planned
source control measures. The SWPPP will also be amended if the state or federal
compliance inspection officer determines that it is ineffective in controlling storm water
pollutants discharged to receiving waters.
7.6 SWPPP CERTIFICATION
certify under penalty of law that this document and all attachments were prepared under
my direction or supervision in accordance with a system designed to assure that qualified
personnel properly gathered and evaluated the information submitted. Based on my
inquiry of the person or persons who manage the system, or those persons directly .
responsible for gathering the information, the information submitted is, to the best of my
knowledge and belief, true and accurate and complete. I am aware that there are
significant penalties for submitting false information, including the possibility of fine and
imprisonment for knowing violations.
NAME: TITLE:
SIGNATURE: DATE:
KAUniversal SteellStormwater Pollution Prevention Plan.doc
10

APPENDIX A
INSPECTION LOGS
FIGURES
AND
VICINITY MAP
KAUniversal Steel\Stormwater Pollution Prevention Plan.doc
I

UNIVERSAL STEEL STORMWATER
POLLUTION PREVENTION
REFRESHER COURSE
EMPLOYEE SIGN -IN SHEET
DATE EMPLOYEE NAME EMPLOYEE
SIGNATURE
KAUniversal SteekStormwater Pollution Prevention Plan.doc
12

SEMI ANNUAL NON -STORM WATER
DISCHARGE ASSESSMENT LOG
I OF 2
DATE
I DRAINAGE AREA CHECK POINTS
FLOW
YES/NO
DA-01
DOWNSPOUTS, PARKING LOT, INSPECTION POINT
#2
DA-02
GRAVEL LOT, INSPECTION POINT 41
DA-03
DOWNSPOUTS,YARD INLET #l, INSPECTION POINT
#3
DA-04
DOWNSPOUTS,YARD INLET92, INSPECTION POINT
#3
DA-05
DOWNSPOUTS,YARD INLET43, INSPECTION POINT
#3
DA-06
DOWNSPOUTS,GRAVEL PARKING LOT,
INSPECTION POINT #3
K:1Universal SteehStormwater Pollution Prevention Plan.doc
i3

SEMI ANNUAL NON -STORM WATER
DISCHARGE ASSESSMENT LOG
20F2
IF FLOW IS YES, COMPLETE THIS SECTION
DRAIN
POSSIBLE
OBSERVATIONS
CORRECTIVE
AREA
SOURCE
ACTION
DA-01
DOWNSPOUTS,
PARKING LOT,
VEHICLE FLUID
LEAKS
DA-02
VEHICLE FLUID
LEAKS
DA-03
EMPTY PANT
CONTAINERS
DA-04
VEHICLE FLUID
LEAKS.
DA-OS
PAINT STORAGE
LEAKS; VEHICLE
FLUID LEAKS
DA-06
VEHICLE FLUID
LEAKS.
INSPECTORS NAME:
K:\Universal SteellStormwater Pollution Prevention Plan.doc
14

SEMI ANNUAL VISUAL
MONITORING INSPECTION LOG
WITHIN 30 MINUTES TO 60 MINUES OF STORM EVENT
DATE
TIME
DRAINAGE AREA
WEATHER
OBSERVATIONS
PROBABLE
INSPECTION POINTS
CONDITIONS
(COLOR, ODOR,
SOURCE OF ANY
TURBIDITY,
OBSERVED
FLOATING
CONTAMINATION
SOLIDS, FOAM.
OIL SHEEN, ETC.
D A-01
DOWNSPOUTS,
PARKING LOT,
INSPECTION POINT 42
DA-02
DOWNSPOUTS,GRA VEL
LOT INSPECTION
POINT #1
DA-03
DOWNSPOUTS,
GRAVEL DRIVE/AREA.
INSPECTION POINT 93
D A-04
DOWNSPOUTS,
GRAVEL DRIVE/AREA,
INSPECTION POINT #3
DA-05
DOWNSPOUTS,
GRAVEL DRIVE/AREA,
INSPECTION POINT #3
DA-06
DOWNSPOUTS,
GRAVEL DRIVE/AREA,
INSPECTION POINT 93
INSPECTORS NAME:
K:IUniversal Steel\Sto rm water Pollution Prevention Plan.doc
15

ANNUAL FACILITY SITE COMPLIANCE
INSPECTION LOG
DATE
DRAINAG
POTENTIAL
CHANGES SINCE
COMMENTS OF
E AREA
POLLUTANTS AND
LAST INSPECTION
STORM WATER
SOURCE
AFFECTING STORM
POLLUTANT
WATER AND/OR
CONTROLS
POLLUTANTS.
EFFECTIVENESS
DA-01
DOWNSPOUTS,
LEAKING VEHICLE,
FUEL SPILL.
DA-02
DOWNSPOUTS,
LEAKING VEHICLE,
FUEL SPILL
DA-03
DOWNSPOUTS,
LEAKING VEHICLE,
FUEL SPILL, EMPTY
PAINT CONTAINER
AREA
DA-04
DOWNSPOUTS,
LEAKING VEHICLE,
FUEL SPILL
DA-05
DOWNSPOUTS,
LEAKING VEHICLE,
FUEL SPILL, PAINT
STORAGELEAKS
DA-06
DOWNSPOUTS,
LEAKING VEHICLE,
FUEL SPILL
INSPECTORS NAME:
FIGURE 1
KAUniversal Stec hStorm water Pollution Prevention Plan.doc
16

VICINITY MAP
KAUniversal Steel%Stormwater Pollution Prevention Plan.doc
17

TABLE I
CHARACTERISTICS OF STORM WATER DRAINAGE
K:IUniversal StechStormwater Pollution Prevention Plan.doc
18

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Taylor -Smith, Aana
From: Taylor -Smith, Aana
Sent: Friday, August 23, 2013 11:58 AM
To: 'Bill Noethling'
Subject: RE: Storm water pollution prevention plan
M1
Thanks so much for sending that along! I'll add it to our file. So far, everything looks good. lust make sure to keep
records of inspections, training, monitoring, etc. with the plan at your facility. Let me know if I can be of any further
assistance and I'll be glad to help in any way I can!
Best,
Aana Taylor -Smith
Land Quality Section
Division of Energy, Mineral, and Land Resources
NC DENR Winston-Salem Regional Office
Phone: [phone]
Fax [phone]
E-mail correspondence to and from this address may be subject to the !North Carolina Public Records Law and may be disclosed to
third parties.
From: Bill Noethling[mailto:[e-mail]]
Sent: Friday, August 23, 2013 11:46 AM
To: Taylor -Smith, Aana
Cc: Hugh Creed lh1��VCiatGJ, Inc, rA
Subject: Storm water pollution prevention plan
Importance: High
Please find attached our Storm Water Pollution Prevention Plain along with marked up site plan.
Please advise of any further requirements.
Thanks
Bill Noethling
Executive VP
Universal Steel Inc.
Buford Office 770-932-0415 ext 204
President
Universal Steel of North Carolina
North Carolina Office 336-474-2860 (Direct Line)
CELL 404-281-0300
bnoeth I ing(c u niversalsteel inc.com
From: Taylor -Smith, Aana [mailto:Aana.Ta for -Smith ncdenr. ov]
Sent: Wednesday, August 07, 2013 3:17 PM

Taylor -Smith, Aana
From: Carter, Jenifer
Sent: Thursday, August 01, 2013 3:08 PM
To: Taylor -Smith, Aana; White, Sue
Subject: SW NOD - actions pending
I've attached a copy of an NOD I sent to Universal Steel (NCG030402) in February. They are supposed to create &
submit their SPPP by the end of August. Let me know which one of you is handling the NCG03s and I'll bring the file to
you, along with contact info.
Jenifer
IWA
Before printing this email, please consider your budget and 'the environment.
If you must print, please print only what you need and save ink with the free Eco-Font.
NC DENR Winston-Salem Regional Office
Division of Water Quality
585 Waughtown Street
Winston-Salem, NC 27107
Voice: [phone]
FAX: [phone]
E-mail correspondence to and from this address may be subject to the
North Carolina Public Records Law and may be disclosed to third parties.

;X4
HCDEHR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor.
Universal Steel Inc.
Attn: W.I. (Bill) Noethling, Jr., President
P.O. Box 1125 .
Buford, GA 30515
Subject: NOTICE OF DEFICIENCY
Division of Watelr Quality
Charles Wakild, P.E.
Director
February 25, 2013
Certificate of Coverage #NCG030402
Universal Steel of NC, LLC
Davidson County
Dear Mr. Noethling:
John E. Skvarla, III
Secretary
On January 31, 2013, Jenifer Carter, of the Division of Water Quality, performed a stormwater
inspection at Universal Steel of North Carolina in Thomasville, North Carolina. You were present during the
inspection. The following are the findings from the subject inspection:
o A Stormwater Pollution Prevention Plan (SWPPP) has not been developed in accordance with the permit
(Part II Section A).
O Analytical monitoring has not been conducted in accordance with permit (Part II Section B).
o Qualitative monitoring has not been conducted and recorded in accordance with the permit (Part II Section
D).
Other Observations:
o There is no vehicle maintenance performed on site.
o There is one (1) stormwater discharge outfall, which appears to drain the entire site. Access to the outfall
may need to be improved and maintained in order to allow access for monitoring purposes.
Requested Response:
A copy of the permit text can be found at http://portal.nedenr.org/web/wq/ws/su/npdessw. Click on the blue
`General Permits.' tab at the top and scroll down to `NCG030000'.
G Complete and submit an SWPPP by August 31, 2013. Guidance can be found on the Division's website by
clicking on the blue `SPPP Resources' tab.
o Begin semi-annual analytical monitoring immediately, using copies of the monitoring form found under the
`Monitoring Forms' tab.
➢ A list of certified laboratories is enclosed.
➢ Results must be submitted within 30 days of receiving results from the lab (as per Part III Section E).
➢ Please note that monitoring for Total Toxic Organics (TTO) may'not apply (see footnote 94 under Table
1 (of Part II Section B), and then can only be waived as per Part II Section A-10 of the permit.
North Carolina Division of Water Quality, Winston-Salem Regional office None,
a
Location: 585 Waughtown Street, Winston-Salem, NC 27107
Phone: [phone] Fax: [phone] Customer Service: 1-877-623-6748 �7atural �
Internet.http://portal.ncdenr.org/web/wq
An Equal Opportunity 1 Affirmative Action Employer g r

o Begin qualitative monitoring immediately, using copies of the monitoring form found under the `Monitoring
Forms' tab. These forms do not need to be submitted and must be maintained on site.
Hard copies of any of the above -mentioned documents can be provided upon request.
Thank you for your attention to these matters. Your efforts toward obtaining compliance as noted above will be
taken into account before deciding on any future enforcement actions. These violations and any future
violations can be subject to a civil penalty assessment of up to $25,000.00 per day for each violation. Should
you have any questions regarding these matters, please contact Jenifer Carter at [phone].
Sincerely,
W. Corey Basinger
Surface Water Regional Supervisor
{ Winston-Salem Regional Office
Division of Water Quality
enclosures:
cc: r_WSRO:FiIi?�
NPS-ACO Unit
SWP — Central Files
W.I. (Bill) Noethling (University Steel of NC, LLC; 630 Bassett Dr., Thomasville, NC 27360)

Compliance Inspection Report
Permit: NCG030402 Effective: 12/12/12 Expiration: 10/31/17 Owner: Universal Steel of NC LLC
SOC: Effective: Expiration: Facility: Universal Steel of NC, LLC
County: Davidson 630 Bassett Dr
Region: Winston-Salem
Thomasville NC 27360
Contact Person: William I Noethling Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 01/31/2013 Entry Time: 11:00 AM Exit Time: 12:00 PM
Primary Inspector: Jenifer Carter Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Metal Fabrication Stormwater Discharge COC
Facility Status: ❑ Compliant ■ Not Compliant
Question Areas:
0 Storm Water
(See attachment summary)
Page: 1

Permit: NCG030402 Owner - Facility: Universal Steel of NC LLC
Inspection Date: 01/31/2013 Inspection Type: Compliance Evaluation Reason for Visit: Routine
&JN5A ggHflfi-Ar§tormwater questions did not show up when this inspection was entered in to the database. Cover
letter (copied below) illustrates findings during the inspection:
February 25, 2013
Universal Steel Inc.
Attn: W.I. (Bill) Noethling, Jr., President
P.O. Box 1125
Buford, GA 30515
Subject: NOTICE OF DEFICIENCY
Certificate of Coverage #NCG030402
Universal Steel of NC, LLC
Davidson County
Dear Mr. Noethling:
On January 31, 2013, Jenifer Carter, of the Division of Water Quality, performed a stormwater inspection at Universal
Steel of North Carolina in Thomasville, North Carolina. You were present during the inspection. The following are the
findings from the subject inspection:
• A Stormwater Pollution Prevention Plan (SWPPP) has not been developed in accordance with the permit (Part II
Section A).
• Analytical monitoring has not been conducted in accordance with permit (Part 11 Section B).
• Qualitative monitoring has not been conducted and recorded in accordance with the permit (Part 11 Section D).
Other Observations:
• There is no vehicle maintenance performed on site.
• There is one (1) stormwater discharge outfall, which appears to drain the entire site. Access to the outfall may need
to be improved and maintained in order to allow access for monitoring purposes.
Requested Response:
A copy of the permit text can be found at httpalportal.ncdenr.org/web/wq/ws/su/npdessw. Click on the blue 'General
Permits' tab at the top and scroll down to 'NCG030000'.
• Complete and submit an SWPPP by August 31, 2013. Guidance can be found on the Division's website by clicking
on the blue 'SPPP Resources' tab.
Begin semi-annual analytical monitoring immediately, using copies of the monitoring form found under the 'Monitoring
Forms' tab.
A list of certified laboratories is enclosed.
Results must be submitted within 30 days of receiving results from the lab (as per Part III Section E).
Please note that monitoring for Total Toxic Organics (TTO) may not apply (see footnote #4 under Table 1 (of Part 11
Section B), and then can only be waived as per Part II Section A-10 of the permit.
Page: 2

Permit: NCG030402 Owner -Facility: Universal Steel of NC LLC
Inspection Date: 01/31/2013 Inspection Type: Compliance Evaluation Reason for Visit: Routine
• Begin qualitative monitoring immediately, using copies of the monitoring form found under the 'Monitoring Forms' tab.
These forms do not need to be submitted and must be maintained on site.
Hard copies of any of the above -mentioned documents can be provided upon request.
Thank you for your attention to these matters. Your efforts toward obtaining compliance as noted above will be taken into
account before deciding on any future enforcement actions. These violations and any future violations can be subject to a
civil penalty assessment of up to $25,000.00 per day for each violation. Should you have any questions regarding these
matters, please contact Jenifer Carter at [phone].
Sincerely,
W. Corey Basinger
Surface Water Regional Supervisor
Winston-Salem Regional Office
Division of Water Quality
enclosures:
cc: WSRO Files
NPS-ACO Unit
SWP — Central Files
W.I. (Bill) Noethling (University Steel of NC, LLC; 630 Bassett Dr., Thomasville, NC 27360)
Page: 3

r.
Permit: NCG140411
SOC:
County: Davidson
Region: Winston-Salem
Compliance Inspection Report
Effective: 07/01/i i Expiration: 06/30/16 Owner: Balfour Beatty Infrastructure Inc & Austin
Bridge & Road LP A Joint Venture
Effective: Expiration: Facility: Interstate 85 Reconstruction temporary
Read Mixed Concrete Facility
324 go -Imes Rd
Contact Person: Stephen Kitchen
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 04/10/2013
Primary Inspector: Jenifer Carter
Secondary Inspector(s):
Title:
Entry Time: 01:00 PM
Linwood NC 27299
Phone: [phone]
Certification:
Exit Time: 02:00 PM
Phone:
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Ready Mix Concrete Stormwater/Wastewater Discharge
COC
Facility Status: 0 Compliant ■ Not Compliant
Question Areas:
0 Storm Water
(See attachment summary)
Page: 1

f
Permit: NCG140411 Owner - Facility: Balfour Beatty Infrastructure Inc & Austin Bridge &
Road I-P A Joint Venture
Inspection Date: 04/10/2013 Inspection Type: Compliance Evaluation Reason for Visit: Routine
sent. The facility closed down, as had been previously scheduled, in July 2013.
April 12, 2013
Balfour Beatty Infrastructure Inc. &
Austin Bridge & Road
Attn: Mr. Joe Byington
1216 Belmont Rd.
Linwood, NC 27299
Subject: NOTICE OF DEFICIENCY
Certificate of Coverage #NCG140411
1-85 Reconstruction Temporary Ready -Mixed Concrete Facility
Davidson County
Dear Mr. Byington:
On April 10, 2013, Jenifer Carter, from the Winston-Salem Regional Office of the Division of Water Quality, performed a
stormwater inspection at the 1-85 Reconstruction Temporary Ready -Mixed Concrete facility located on Holmes Rd in
Linwood, North Carolina. The following observations & deficiencies were noted during the inspection:
A Stormwater Pollution Prevention Plan (SWPPP) has been developed, but not fully implemented. Annual updates,
employee training, and monitoring have not been done and/or documented. Since the inspection, training and monitoring
has been arranged.
There are three wastewater outfalls. Settling Basin #2 outfall receives flow from the truck wash station and has never
discharged, as it was designed and built to hold a 10-yr 24-hr storm. Erosion Control Basins (ECB) #1 & #2 receive runoff
from stockpiles and do discharge. Analytical monitoring of ECBs #1 and #2 has not been performed quarterly as required
by the permit. Within 24 hours of the inspection, you contacted Statesville Analytical and arranged for them to perform
sampling immediately, and agreed to have them collect samples monthly thereafter. Upon receiving results from samples
taken by Statesville Analytical, please contact Jenifer Carter to schedule a follow-up inspection.
Qualitative monitoring has documented semi-annually as required by the permit. You have arranged for this to be
done monthly, in conjunction with the above sampling.
There were no negative impacts observed to surface waters. The site appeared to be well -maintained overall,
including the pH control unit between the two settling basins.
Thank you for your attention to this matter. Your swift action to correct the above -noted deficiencies is greatly
continued on reverse...
appreciated. Should you have any questions regarding these matters, please contact Jenifer Carter or myself at (336)
771-5000.
Page: 2

Permit: NGG140411 Owner -Facility: Balfour Beatty -Infrastructure Inc & Austin Bridge &
Road LP A Joint Venture
Inspection Date: 04/10/2013 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Sincerely,
W. Corey Basinger
Surface Water Regional Supervisor
Winston-Salem Regional Office
Division of Water Quality
cc: WSRO Files
NIPS-ACO Unit
SWP — Central Files
Walter McDaniel (Balfour Beatty Infrastructure Inc.; 420 Eastwood Rd; Wilmington, NC 28403)
Steven J. Strohm, P.E. (Austin Bridge & Road; 801 Jones Franklin Rd, Ste. 300; Raleigh, NC 27606)
Page: 3

FA
Permit: NCG140411 Owner - Facility: Balfour Beatty Infrastructure Inc & Austin Bridge &
Road LP A Joint Venture
Inspection Date: 04/1012013 Inspection Type: Compliance Evaluation
Reason for Visit:
Routine
Stormwater Pollution Prevention Plan
Yes
No
NA
NE
Does the site have a Stormwater Pollution Prevention Plan?
■
❑
Q
❑
# Does the Plan include a General Location (USGS) map?
■
0
❑
Q
# Does the Plan include a "Narrative Description of Practices"?
■
0
# Does the Plan include a detailed site map including outfall locations and drainage areas?
■
❑
n
n
# Does the Plan include a list of significant spills occurring during the past 3 years?
n
n
■
n
# Has the facility evaluated feasible alternatives to current practices?
■
❑
n
n
# Does the facility provide all necessary secondary containment?
■
n
n
n
# Does the Plan include a BMP summary?
■
0
n
n
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
■
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
■
n
n
n
# Does the facility provide and document Employee Training?
Q
■
❑
0
# Does the Plan include a list of Responsible Party(s)?
■
n
n
n
# Is the Plan reviewed and updated annually?
n
■
n
n
# Does the Plan include a Stormwater Facility Inspection Program?
■
n
n
n
Has the Stormwater Pollution Prevention Plan been implemented?
n
■
n
n
Comment: The SPPP developed but not updated or implemented fully
Qualitative Monitoring
Yes
No
NA
NE
Has the facility conducted its Qualitative Monitoring semi-annually?
n
■
Cl
Cl
Comment: .
Analytical Monitoring
Has the facility conducted its Analytical monitoring?
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
Comment: .
Permit and Outfalls
# Is a copy of the Permit and the Certificate of Coverage available at the site?
# Were all outfalls observed during the inspection?
# If the facility has representative outfall status, is it properly documented by the Division?
# Has the facility evaluated all illicit (non Stormwater) discharges?
Comment: .
Yes No NA NE
C0.■nn
C1p■n
Yes No NA NE
Page: 4

A
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Mr. William I. Noethling, Jr.
Universal Steel of NC
PO Box 1862
High Point, NC 27261
Alan W. Klimek, P.E. Director
Division of Water Quality
Subject: Permit name or ownership change request
Permit NCG030402
Your request for a permit name change or ownership change received on 2 b ,96, is being
returned due"to: -
❑ Permit Name/Ownership Change Form is missing.
❑ Permit Name/Ownership Change Form is incomplete.
❑ Permit Name/Ownership Change Form signatures missing.
I2""Missing legal document of the transfer of ownership (such as a contract or a deed).
❑ Other Pl&se SeeJ fr, [ma ap aiL —
Please return the information so we can continue processing your request. If you have any
additional questions, please contact Sarah Young at [phone] extension 502. Our mailing
address is as follows: Wetlands and Stormwater Branch
1617. Mail Service
Raleigh, NC 27699-1617
r
DWQ Stormwater Permitting Unit
Cc:
DWQ Central Files
SPU
North Carolina
)Vatumlly
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Inlemet: h2o.enr.state.nc.us 512 N. Salisbury St. Raleigh, NC 27604 FAX [phone]
An Equal opportunity/Affirmative Action Employer — 50% Recycled110% Post Consumer Paper

O�OF W A T �RQG
r
C a —i
4 `'c
DOUGLAS WENT?
TRIAD STEEL COMPANY-DAVIDSON
P O BOX 1862
HIGH POINT, NC 27261
Dear Permittee:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
August 23, 2002
Subject: NPDES Stormwater Permit Renewal
TRIAD STEEL COMPANY-DAVIDSON
COC Number NCG030402
Davidson County
In response to your renewal application for continued coverage under general permit NCG030000, the Division of
Water Quality (DWQ) is forwarding herewith the reissued stormwater general permit. This 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 NCGO30000
* A copy of the Analytical Monitoring Form (DMR)
* A copy of a Technical Bulletin for the general permit
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 Bill Mills of the Central Office Stormwater
and General Permits Unit at [phone] ext. 548
Sincerely,
Bradley Bennett, Supervisor
Stormwater and General Permits Unit
cc: Central Files
Stormwater & General Permits Unit Files
Winston-Salem Regional Office
N. C. Division of Water Quality 1617 Mall Service Center Raleigh, NC 27699-1617 [phone]
NCernDENR
Customer Service
1-800-623-7748

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG030000
CERTIFICATE OF COVERAGE No. NCG030402
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,
TRIAD STEEL COMPANY
is hereby authorized to discharge stormwater from a facility located at
TRIAD S'rEEL COMPANY-DAVIDSON
BUSINESS 85 - ALBERTSON R
THOMASVILLE
DAVIDSON COUNTY
to receiving waters designated as a UT to Hunts Fork, a class C stream, in the Yadkin - Pee Dee River Basin in
accordance with the effluent limitations, monitoring requirements. and other conditions set forth in Parts 1. 11. 111,
IV, V, and VI of General Permit No. NCG030000 as attached.
This certificate of coverage shall become effective September 1, 2002.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day August 23, 2002.
for Alan W. Klimek, N.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

W A TF9pG
r
0 Y
DOUGLAS WENTZ
TRIAD STEEL COMPANY-DAVIDSON
P O BOX 1862
HIGH POINT. NC 27261
Dear Per nittee:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Gregory J. Thorpe, Ph.D.
Acting Director
Division of Water Quality
December 27, 2001
Subject: NPDES Stormwater Permit Renewal
TRIAD STEEL COMPANY-DAVIDSON
COC Number NCG030402
Davidson 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 he 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 he expiring. Enclosed you will find aGeneral 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 143-215.1 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 1 1 categories of "stoat; 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 hitp:/fh2o.enr.state.nc.us/su/stormwater.html
If the subject stormwater dischargc 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 Corey Basinger of the
Winston-Salem Regional Office at 336-771-4600 or Bill Mills of the Central Off ice Stormwater Unit at (919)
733-5083, ext. 549
Sincerely,
Bradley Bennett, Supervisor
Stormwater and General Permits Unit
cc: Central riles
Winston-Salem Regional Office
���
NCDENR
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone] Customer Service
1- 800-623-7748

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
October 1, 1997
DOUGLAS WENTZ
TRIAD STEEL COMPANY-DAVIDSON
P.O. BOX 1862
HIGH POINT, NC 27261
LT A.
1q? 0
[DEHNF1
Subject: Reissued Stormwater General Permit for Certificate of Coverage No. NCG030402
Davidson County
Dear Permittee:
In response to your renewal application for continued coverage under the subject permit, the Division
of Water Quality (DWQ) is forwarding herewith the reissued stormwater general permit. This permit
is reissued pursuant to the requirements of North Carolina General Statute 143-215 .1 and the
Memorandum of Agreement between North Carolina and the US Environmental Protection agency
dated December 6, 1983.
The following information is included with your permit package:
■ A copy of the stormwater general permit.
■ A Stormwater Pollution Prevention Plan Certification Form. This form certifies that you have
developed and implemented the Stormwater Pollution Prevention Plan (SPPP) required in your
permit. This form must be completed and returned to the Division within 30 days of receipt of
this letter. DO NOT send the SPPP with the signed form.
■ Five copies of Analytical Monitoring forms.
N Five copies of Qualitative Monitoring forms.
■ A copy of a Technical Bulletin on the stort-nwater program with outlines program components
and addresses frequently asked questions.
a A corrected Certificate of Coverage if you indicated a name or address change on the Renewal
Form returned to the Division.
Your certificate of coverage is not transferable except after notice to DWQ. The Division of Water
Quality may require modification or revocation and reissuance of the certificate of coveragge.
This permit does not affect the legal requirements to obtain other permits which may be required by
DWQ or permits required by the Division of Land Resources, Division of Air Quality, Coastal Area
Management Act or anv other Federal or Local governmental permits that may be required.
If you have any questions concerning this permit or other attached documents, please contact the
Stormwater Group at telephone number [phone]
Sincerely,
r �,r1
fo A. Preston Howard, Jr., P. E.
P.O. Box 29535, Raleigh. North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 1017c post -consumer paper

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG030000
CERTIFICATE OF COVERAGE NO. NCG030402
STORMWATER DISCHARGES
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,
TRIAD STEEL COMPANY-DAVIDSON
is herby authorized to discharge stormwater from a facility located at:
BUSINESS 85 - ALBERTSON RD
THOMASVILLE, NC
DAVIDSON COUNTY
to receiving waters designated as Ut Hunts Fork in the YADKIN-PEE DEE River Basin
in accordance with the effluent limitations, monitoring requirements and other conditions set forth in Parts I,
II. 111 and IV of General Permit No. NCG030000 as attached.
This Certificate of Coverage shall become effective September 15, 1997
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day October 1,1997
for A Preston Howard, Jr., P.E., Director
Division of Water Quality
By Authorization of the Environmental Management Commission

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
November 27, 1996
Mr. Douglas H. Wentz, President
Triad Steel Company
P. O. Box 1862
High Point, NC 27261
Subject: General Permit No. NCG030000
Triad Steel Company
COC NCG030402
Davidson County
Dear Mr. Wentz:
In accordance with your application for discharge permit received on June 14, 1996, we are 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 Statute 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 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, this certificate of coverage shall be final 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 Mr. Bill Mills at telephone number gign33-
5083 ext. 548.
Sincerely,
OPJGNAL SIGNED BY
BRADLEY BENNEfT
A. Preston Howard, Jr., P. E.
cc: Winston-Salem Regional Office
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO, _NCG030000
CERTIFICATE OF COVERAGE No. NCG030402
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,
Triad Steel Company
is hereby authorized to discharge stormwater from a facility located at
Triad Steel Company
Business 85 & Albertson Road
Thomasville
Davidson County
to receiving waters designated as an unnamed tributary to Hunts Fork hi the Yadkin - Pee Dee River Basin
in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, H, III
and IV of General Permit No. NCG030000 as attached.
This certificate of coverage shall become effective November 27, 1996.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day November 27, 1996.
®R:.1N& StGNE-0 BY
BRADLEY BENNO T
A. Preston Howard, Jr., P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

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FACILITY -Tlrtaj s4ep-( Come
COUNTY
NPDES
MAP #
D�il FLOW � / R
SUB 6,,A,.SIN -0�
LATTITUDE
0 / if
Nr6 0 3
LOi%.'..;]vTUDE
STREAM (k
CLASS
I
-.,.-CLASS
EX. P 'I R DATE
S+o,r m W AN-C r-
09/31 (q7