NCG200339_COMPLETE FILE - HISTORICAL_20181107

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO.
/V Z�C) 33 1
DOC TYPE
A HISTORICAL FILE
❑ MONITORING REPORTS
DOC DATE
❑ 20/� / ( D
YYYYMMDD

T
ROY COOPER NORTH CAROLINA
Governor Environmental Quality
MICHAEL S. REGAN
Secretary
WILLIAM E. (TOBY) VINSON, JR,
lnrerim Director
November 7, 2018
Biltmore Iron & Metal Co Inc.
Attn: Vonna Cloninger, CEO
Post Office Box 5616
Asheville, North Carolina 28813
Subject: Compliance Evaluation Inspection
Permit: NCG200339
Buncombe County, North Carolina
Dear Mrs. Cloninger:
Enclosed please find a copy of the Compliance Evaluation Inspection Report for the
inspection I conducted at the subject facility on October 24, 2018.
The report should be self-explanatory; however, should you have any questions
concerning this report, please do not hesitate to contact me at [phone] or by email
at [e-mail].
Sincere)
T ..
saiah Reed; t=PSC1,. MS4C Cl
Environmental Specialist
Land Quality Section
Enclosure: Inspection Report
oea�e�s vi tempt �+a\ %�
North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
Asheville Regional Office 12090 U.S. Highway 70 I Swannanoa, North Carolina 28778
828.296.4500

Iq
Compliance Inspection Repo
Permit: NCG200339 Effective: 02/02/15 Expiration: 12/31/19 Owner: Biltmore Iron & Metal Co Inc
SOC: Effective: Expiration: Facility: Biltmore Iron & Metal Co Inc
County: Buncombe 1 Meadow Rd
Region: Asheville
Asheville NC 28803
Contact Person: Vonna Cloninger Title: Phone: [phone] Ext,11
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 10/24/2018
Primary Inspector: Isaiah L Reed
Secondary Inspector(s):
Certification:
Phone:
Entry Time: 09:15AM Exit Time: 10:OOAM
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
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

V}
Permit: NCG200339 Owner - Facility:Siltmore Iron & Metal Co Inc
Inspection Date: 10124/2018 Inspection Type : Compliance Evaluation Reason for Visit: Routine
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 outfail status, is it properly documented by the Division?
# Has the facility evaluated all illicit (non stormwater) discharges?
Comment:
Yes No NA NE
❑ ❑ ❑
® ❑ ❑ ❑
❑ ❑ ® ❑
❑ ❑ ❑ IN
Page: 3

Compliance Inspection Report
Permit: NCG200339 Effective: 02/02/15 Expiration: 12/31/19 Owner: Biltmore Iron & Metal Co Inc
SOC: Effective: Expiration: Facility: Biltmore Iron & Metal Co Inc
County:
Buncombe 1 Meadow Rd
Region: Asheville
Asheville NC 28803
Contact Person: Vonna Cloninger Title: Phone: [phone] Ext.11
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 10124/2018
Primary Inspector: Isaiah L Reed
Secondary Inspector(s):
Certification: Phone:
Entry Time: 09:15AM Exit Time: 10:OOAM
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
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; NCG200339 Owner - Faculty: Biltmore Iron & Metal Co Inc
inspection Date; 10124/2018 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
On October 24, 2018 this facility was inspected For compliance, During the inspection, the following items were noted:
1 j The vehicle draining area has been cleaned and no evidence of further spills was observed during the inspection. However,
the permitee is directed to further evaluate the practice of liquid waste products in the vehicle draining area.
2) The Basin and basin walls have been cleaned and vegetation is becoming established on the basin walls. However, further
- _cleaning .and.removal.of metal waste from the basin walls in needed. The permitee is directed to continue cleanup efforts in
the basins and on the basin walls.
The compliance deadline has been extended for evaluation needed for the basin.
The facility remains under Notice of Violation until the evaluation described in the Notice of Violation dated September 21,
2018 has been addressed.
Page: 2

Permit- NCG200339 Owner - Facility: Biltmore Iron 6 Metal Co Inc
Inspection Date: 10/2412018 Inspection Type : Compliance Evaluation Reason for Visit: Routine
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
❑ ❑ ❑
❑❑■❑
❑ ❑ ❑
Page: 3

ROY COOPER NORTH CAROUNA
Governor .Environmental Quality
MICHAEL S. REGAN
Secretary
WILLIAM E. (TO BY) VINSON, JR.
Interim Director
Dear Mrs. Cloninger, CEO,
I have received your letter dated October 4, 2018. After reviewing the violation and information
available concerning your facility, an extension of 60 days (90 days after the original letter of
receipt) will be allotted for the following corrective action:
"While the intention is that the facility does not have a stormwater discharge, the permitee
shall show that such is the case. A plan showing the dimensions of the basin, estimated
stormwater runoff for a 25 year storm event, and calculations showing that the basin will
not discharge in that scenario shall be submitted to the Department of Environmental
Quality for review. This study should have previously been conducted in accordance with
Part II, Section A:8 of the Industrial Stormwater General Permit."
For all other corrective actions, the deadline for completion will remain October 24, 2018,
(30 days after the original letter of receipt). An inspection will be performed on or after that
date to confirm that all other issues have been addressed.
Thank you for your response and efforts to correct the issues at your facility.
If you have questions about this matter, please contact me at [phone].
Sincerely,
-- to ley E. Aiken" GA
Regional Engin er
Land Quality Section
Department of Environmental Quality
ec: Alaina Mormon- Environmental Specialist Alaina.mormang, ncdenr.gov
Bethany Georgoulias, Environmental Engineer bethany.georgoulias{,ncdenr.gov
Isaiah Reed- Environmantal Specialist [e-mail]
North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
Asheville Regional Office 1 2090 U.S. Highway 70 1 Swannanoa, North Carolina 28778
828.296.4500

a
PO Box 5616 (Mailing Address)
Asheville, NC 28813
[phone]-Phone
[phone]-Fax
bimco(ftellsouth. net
October 1, 2018
Stanley E. Aiken, Regional Engineer
NC Environmental Quality
2090 US 70 Highway
Swannanoa, NC 28778-8211
Dear Mr. Aiken:
Received
OCT -42018
Land Quality Section
Asheville
I am writing in response to the letter I received dated September 21, 2018 regarding
NOV/Recommendation for Enforcement of Biltmore Iron and Metal Co., Inc. We have remedied most of
the permit conditions but have a couple more to address. I have engaged ECS Southeast to address the
remaining issues. I am asking for an extension of up to 6 months so that ECS can explore your requests
and possible reconstruction of a new vehicle draining area. I appreciate your assistance with this
matter.
I am emailing a copy this letter to Isaiah Reed in your office. Thank you!
Rega rL,
Vonna F. Cl er, C

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Article Addressed to:
Biltrnare Iron d'iIetal Co Ine.
Alln: Vorina Cloninger. CEO
Post arrce Box 1,61f)
t' A%heville. North Carolina 28813
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Energy, Mineral
and Land Resources
ENVIRONMENTAL QUALITY
September 21, 2018
CERTIFIED MAIL: 7017 2620 0000 97-59 0119
RETURN RECEIPT REQUESTED
Biltmore Iron & Metal Co Inc.
Attn: Vonna Cloninger, CEO
Post Office Box 5616
Asheville, North Carolina 28813
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
WILLIAM E. VINSON, JR.
Interim Director
Subject:NOTICE OF VIOLATION (NOV-2018-PC-0362)
RECOMMENDATION FOR ENFORCEMENT
Biltmore Iron and Metal Co Inc., Certificate of Coverage-NCG200339
NPDES Stormwater General Permit-NCG200000
Buncombe County
Dear Mrs. Cloninger:
On August 15, 2018, Isaiah Reed from the Asheville Regional Office of the Division of Energy, Mineral and Land
Resources, conducted a site inspection for the Biltmore Iron & Metal facility located at 1 Meadow Road in Asheville,
Buncombe County, North Carolina. A copy of the Compliance Inspection Report is enclosed for your review. Permit
coverage authorizes the discharge of stormwater from the facility to receiving waters designated as a tributary of the
Swannanoa River, a Class C waterbody in the French Broad River Basin. The site visit and File review revealed that the
subject facility is covered by NPDES Stormwater General Permit-NCG200000, Certificate of Coverage-NCG200339.
As a result of the site inspection, the following permit conditions violation(s) were noted:
1) Preventative Maintenance and Good Housekeeping, Spills
The soil around the vehicle draining area was discolored due to release and spill of oiYcoolant. The oil containment
structure showed visible signs of overtopping. The permitee shall report any oil spill regardless of amount occurring
within 100 feet of surface waters. This area is in violation of (Part 11, section A:4 and A:9) and (Part III, Section
E:7) of the Industrial Stormwater General Permit NCG20.
2) Preventative Maintenance and Good Housekeeping
The Stormwater basins were not maintained and were overgrown to the point that the discharge point was not visible,
This area is in violation of Part 11, section A:4, A:9 and Part III, section C:I of the Industrial Stormwater
General Permit NCG20.
3) Preventative Maintenance and Good Housekeeping
Metal waste was observed in the stormwatei-basins. This area is in violation of Part H, section A:4, A:9 and Part
III, section C:1 of the Industrial Stormwater General Permit NCG20.
4) Analytical/qualitative Monitoring
Analytical and Qualitative monitoring has not been conducted and recorded in accordance with permit requirements.
Evidence of discharge from the basin was observed, and due to the condition and visibility of this area, it very likely
that this basin discharges into a tributary of the Swannanoa River. This area is in violation of Part 11, sections B and
C of the Industrial Stormwater General Permit NCG20.
State oiNortlt Carolina j Environmental Quality ( Energy, Mineral and Land Resmuces
7090 US 70 Highway I Sivannanoa, NC 28778-8211
828 296 4500 T

Notice of Violations
Biltmore Iron & Metal Co Inc.
August 28, 2018
Page 2 of 2
5) Stormwater Pollution Prevention Plan (SPPP)
Due to these violations, the Stormwater Pollution Prevention Plan (SPPP) has not been implemented in compliance with
Part II, Section'A:9 of the Industrial Stormwater General Permit.
Requested Response: You are asked to respond to this office, in writing, within 30 calendar days from receipt of this notice. Your written
response should include a reasonable explanation as to why the aforementioned violation(s) have occurred as well as a
Plan of Action to prevent these violation(s) from recurring,
Thank you for your attention to this matter. This Office is considering sending a recommendation for enforcement to the
Director of the Division of Energy, Mineral & Land Resources regarding these issues. Your above -mentioned response
to this correspondence will be considered in this process. This office requires that the violations, as detailed above,
be properly resolved. These violations and any future violations are subject to a civil penalty assessment of up to
525,000 per day for each violation. Your efforts to undertake activities to bring the subject site back into compliance is
not an admission, rather it is an action that must be taken in order to begin to resolve ongoing environmental issues.
Your above -mentioned response to this correspondence, the degree and extent of harm to the environment and the
duration and gravity of the violation(s) will be considered in any civil penalty assessment process that may occur.
Should you have any questions regarding these matters, please contact Isaiah Reed or myself at 828 296 4500.
Sincerely,
anley E. Aiken,�PE'
Regional Engine
Land Quality Section
Enclosure
ec: Laura Alexander - Administrative Assistant laura.alexander cr,ncdenr.lrov
Stanley E. Aiken - Regional Engineer [e-mail]
Annette Lucas - Program Manager [e-mail]_
Linda Wiggs - DWR Linda. wiggs@nc_denr,t?oy
State or North Carolina I Environmental Quality I Energy, Mineral and Land Resources
2090 US 70 Highway I Swannanoa, NC 29778-8211
828 296 4500 T

Compliance Inspection Report
Permit: NCG200339 Effective: 02/02/15 Expiration: 12/31/19 Owner : Bilimore Iron & Metal Co Inc
SOC: Effective: Expiration: Facility: Biltmore Iron & Metal Co Inc
County: Buncombe 1 Meadow Rd
Region: Asheville
Asheville NC 28803
Contact Person: Vonna Cloninger Title: Phone: [phone] Ext.11
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 08/1612018 EntryTime: 10:OOAM Exit Time: 11:OOAM
Primary Inspector: Isaiah L Reed Phone: [phone]
'Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Wholesale Trade of Metal Waste and Scrap Stormwater Discharge COG
Facility Status: ❑ Compliant ® Not Compliant ~
Question Areas:
® Storm Water
(See attachment summary)
Page: 1

Permit: NCG200339 Owner - Facility: Biitmore Iron & Metal Co Inc
Inspection Date: 0811512018 Inspection Typo: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
On August 15, 2018 this facility was inspected for compliance. Vonna Cloninger was not available on site,
During the inspection, the following items were noted:
1) The soil around the vehicle draining area was discolored due to release and spill of oillcoo€ant. The oil containment
structure -showed visible signs of overtopping. The permitee shall report any oil spill regardless of amount occurring within
100 feet of surface waters. This area is in violation of (Part II, section A.4 and A:9) and "(Part ill, Section-E:7)•of the,industrial. -
Stormwater General PermitNCG20.
2) The stormwater basins were not maintained and were observed to be overgrown. This area is in violation of Part II, section
A:4, A:9 and Part III, section C:1 of the Industrial Stormwater General Permit NCG20.
3) Metal waste was observed in the stormwater basins. This area is in violation of Part 11, section AA A:9 and Part III,
section C:1 of the Industrial Stormwater General Permit NCG20.
4) Analytical and Qualitative Monitoring had not been conducted. Evidence of discharge from the basin was observed,
making it very likely that this basin discharges into a tributary of the Swannanoa River. This area is in violation of Part 11,
sections B and C of the Industrial Stormwater General Permit NCG20.
To correct these violations, you must
1) Remove all contaminated soils around the vehicle draining area, and immediately implement a revised and improved plan
of action concerning preventative maintenance and good housekeeping on site. This area should have been evaluated during
the annual SPPP update, as outlined in Part 11, Section A:8 of the industrial Stormwater General Permit NGG20,
2) The basin shall be cleaned out and maintained. In accordance with Part II, section AA, A:9 and Part Ili, section C;1 of the
Industrial Stormwater General Permit NCG20. This area should have been evaluated during the annual SPPP update, as
outlined in Part II, Section A:8 of the industrial Stormwater General Permit NCG20.
3) All metal waste shall be removed from the basin and basin walls. In accordance with Part 11, section AA, A:9 and Part ill,
section CA of the Industrial Stormwater General Permit NCG20. This area should have been evaluated during the annual
SPPP update, as outlined in Part 11, Section A:8 of the industrial Stormwater General Permit NCG20.
4) While the intention is that the facility does not have a stormwater discharge, the permitee shall show that such is the
case, A plan showing the dimensions of the basin, estimated stormwater runoff for a 25 year storm event, and calculations
showing that the basin will not discharge in that scenario shall be submitted to the Department of Environmental Quality for
review. This study should have previously been conducted in accordance with Part II, Section A:8 of the Industrial
Stormwater General Permit.
Page: 2

Permit: MCG200339 Owner - Facility: Biltmore Iron & Metal Co Inc
Inspection Date: 08/15/2018 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?
® ❑ ❑ ❑
# Does the Plan include a General Location (USGS) map?
®❑ ❑ ❑
# Does the Plan include a "Narrative Description of Practices"?
®❑ ❑ ❑
# Does the Plan include a detailed site map including 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?
❑ ®❑ ❑
# Does the Plan include a BMP summary?
11 ❑ ❑ ❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
®❑ ❑ ❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
®❑ ❑ ❑
# Does the facility provide and document Employee 'training?
® ❑ ❑ ❑
# Does the Plan include a list of Responsible Party(s)?
®❑ ❑ ❑
# Is the Plan reviewed and updated annually?
® ❑ ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
®❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
❑ [] ❑
Comment: See summary for more information
Qualitative Monitorincl
Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ❑ ®❑ ❑
Comment: See summary for more information.
Analytical Monitoring_ Yes No NA NE
Has the facility conducted its Analytical monitoring? ❑ ®❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ ® ❑
Comment: See summary for more information.
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? ig ❑ ❑ ❑
# 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 stormwaler) discharges? ❑ ®❑ ❑
Comment: See summary for more information.
Page: 3

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Station Fields: NC-ac-3' ClStation Number ❑Station Name
Location: USA North Carolina BC - Buncombe
Date Range:
Start Date: 1/1/2013 -- End Date: 12/19/2013
Precip Value: Total Precip >= 1
Search
Searched: Station Number contains NC-BC-37. Stations in Buncombe, North Carolina. Report
date between 1/1/2013 and 12/19/2013. Total Precip - 1.00
Ch^winn 17 l7nrnrrlc
Date A
Time
Station Number
Station Name
Total
Precip
in.
New
Snow
in.
Total
Snow
in.
State
County
i
View
11/27/2013
7:00 AM
NC-BC-37
Asheville 3.3 SE
1.96
1.0
1.0
NC
Buncombe
10/7/2013
7:00 AM
NC-BC-37
Asheville 3.3 SE
1.44
NA
NA
NC
Buncombe
9/22/2013
7:00 AM
NC-BC-37
Asheville 3.3 SE
1.52
NA
NA
NC
Buncombe
7/27/2013
7:00 AM
NC-BC-37
Asheville 3.3 SE
1.30
NA
NA
NC
Buncombe
7/6/2013
7:00 AM
NC-BC-37
Asheville 3.3 SE
1.47
NA
NA
NC
Buncombe
7/5/2013
7:00 AM
NC-BC-37
Asheville 3.3 SE
2.13
NA
NA
NC
Buncombe
7/4/2013
7:00 AM
NC-BC-37
Asheville 3.3 SE
2.81
NA
NA
NC
Buncombe
7/1/2013
7:00 AM
NC-BC-37
Asheville 3.3 SE
1.12
NA
NA
NC
IBuncombe
6/10/2013
7:00 AM
NC-BC-37
Asheville 3.3 SE
2.42
NA
NA
NC
IBuncombe
6/8/2013
7:00 AM
NG-BC-37
Asheville 3.3 SE
1.01
NA
NA
NC
Buncombe
5/6/2013
TOO AM
NC-BC-37
Asheville 3.3 SE
1,98
NA
NA
NC
Buncombe
�
4/2912013
TOO AM
NC-BC-37
Asheville 3.3 SE
1.68
NA
NA
NC
Buncombe
4/12/2013
TOO AM
NC-BC-37
Asheville 3.3 SE
2.05
NA
NA
NC
Buncombe
�
311212013
7:00 AM
NC-SC-37
Asheville 3.3 SE
1-Og
NA
NA
NC
Buncombe
1/31/2013
7:00 AM
NC-BC-37
Asheville 3.3 SE
2.67
NA
NA
NC
Buncombe
4%
1/18/2013
7:00 AM
NC-BC-37
Asheville 3.3 SE
2.12
NA
NA
NC
Buncombe
1/15/2013
7:00 AM
NG-SC-37
Asheville 3.3 SE
1.32
NA
NA
NC
Buncombe
ao x 3b
For questions or comments concerning this web page please contact infortcocorahs.org.
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Privacy Policy Data Usage Policy Copyright ® J998-2011, Colorado Climate Center, All rights reserved.
http://www.cocorahs.org/ViewData/1-istDailyPrecipReports.aspx 12/19/2013

Stepp, Jonathan
From: Vonna Cloninger <[e-mail]>
Sent: Monday, December 30, 2013 4:09 PM
To: Stepp, Jonathan
Cc: Herbert, Laura C; Kucken, Darlene
Subject: Re: Detention Ponds
Our SPPP was approved by your office and EPA. Is this a new ruling that the dimensions are to be in the SPPP; if so will
you send me the ruling. Our consultant is out of the office until the 2nd. Their fees are quite substantial. Therefore, if
there is no ruling that the dimensions of ponds are to be included in all NC SPPPs, then I will not rehire the consultant to
redo the SPPP. If you simply want to know for your own information the dimensions, you are quite welcome to come
and measure them. The depth and width of one is very deep and not sure not to get to the middle unless you use a boat
(it was built years ago!).
Vonna Cloninger, CEO
On 12/30/2013 3:19 PM, Stepp, Jonathan wrote:
Ms. Cloninger,
Last week we discussed your facility located at 1 Meadow Rd. in Asheville, NC. Based on our
conversation and your DMR reports I unde,rstand that you had no discharge from this property for all of
2013. Additionally, we discussed the sizing of your stormwater detention ponds. Please send the sizing
calculations for these ponds to me as an email attachment (or by mail at the address below), If these
calculations are not available, please send me the dimension of each pond including the depth. Thank
you for your assistance and Happy New Year.
Sincerely,
Jonathan
Jonathan Stepp — Jonathan.SteppPncdenr.Rov
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Energy, Mineral, and Land Resources - Land Quality Section
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public
Records Law and therefore may be disclosed to third parties.
Vonna Fisher
Biltmore Iron
Po Box 5616
Asheville, NC
Cloninger, CEO
and Metal Co., Inc.
28813

Stepp, Jonathan
From:
Stepp, Jonathan
Sent:
Monday, December 30, 2013 2:54 PM
To:
Fox, Tim
Subject:
Detention Ponds
Ms. Cloninger,
Last week we discussed your facility located at 1 Meadow Rd. in Asheville, NC. Based on our conversation and your DMR
reports I understand that you had no discharge from this property for all of 2013. Additionally, we discussed the sizing
of your stormwater detention ponds. Please send the sizing calculations for these ponds to me as an email attachment
(or by mail at the address below). if these calculations are not available, please send me the dimension of each pond
including the depth. Thank you for your assistance and Happy New Year.
Sincerely,
Jonathan
Jonathan Stepp—Jonathan.Stepp(@ncdenr.gov
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Energy, Mineral, and Land Resources - Land Quality Section
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and
therefore may be disclosed to third parties.

s COMPREHENSIVE SITE COMPLIANCE EVALUATION
(Page 1 of 10)
Biltmore Iron and Metal Company, Inc.
Asheville, ,NBC
Date: Completed By:, h ��a Cb�lQ , Cam- .'
dr �:F"ATij=-H
U �.�(�1L - � 2012QUALITY GLCTION ARE IONAL 0FFlCE i
Y
errous �1Von-Ferrous - Ferrous' ..
Area
Office
Scales` ,
Metal - '
Roarri - :
Fluld.
Reclamation ..
: Malnteriance .
Sho
Nori=F
Xard.
Warehfluse
Yat`ti
Description in Plan Suitable?
Y-
Materials and potential
pollutants identified in Plan
\/ ✓
r
✓
`�
�,{ ''
I
✓
' `�
accurately?
r
Location on site map in Plan
correct?
�� ✓
�/
✓
4�
y `�"
l f
�—
��
Area orderly and neat?
Improper Materials Present?
Evidence of S ills/Leaks or
Pollutants? p
Erosion Debris or Residue
Present?
no
n
11 �
r� D
`Complete table by indicating yes, no or not applicable (NIA). Identify required actions and schedule for completion
PROVIDE A DETAILED DESCRIPTION OF ANY IDENTIFIED PROBLEMS, REQUIRED ACTIONS, AND SCHEDULE FOR COMPLETION:

COMPREHENSIVE SITE COMPLIANCE EVALUATION
(Page 2 of 10)
Biltmore Iron and Metal Company, Inc.
Asheville, NC
(Inspection must be performed once in the Fall (September -November) and once in the Spring (April -June))
Date: Completed By: La h111CL
Detention
Pond
` Dltch on .West .
Side :of
.
Outfalt 001
Corhments.and;Schedt.ile for:Required Action.
Pro erti
De
scription an in Plan Suitable?
Suitable .
Materials and potential
pollutants identified in Plan
accurately?
Location on Site map in Plan
correct?
`;
t
`�
1�11 ��
Evidence at Spills/Leaks or
Pollutants? .
-
Debris or Residue Present?
��
Evidence of erosidn?
r)�
Improper Materials Present
near detention pond, ditch
or outfall 001?
Do qualitative monitoring
results indicate the
presence of pollutants in(,s,
stormwater?
Do analytical monitoring
results exceed cut-off
concentrations?
*Complete table by indicating yes, no or not applicable (NIA). Identify required actions and schedule for completion

COMPREHENSIVE SITE COMPLIANCE EVALUATION
(Page 3 of 10)
Biltmore Iron and Metal Company, Inc.
Asheville, NC
Date: Completed By:
Location
;Response
Equlprnent '_
present..(y.es
orno?
'GIST EQUIPMENT7HAT S" PRESENT
(e.g., loose sor�ionts,.sorlaent sacks;.Personal:`ptatective
egi"lpment; etc:)
Maintenance Shop

COMPREHENSIVE SITE COMPLIANCE EVALUATION
(Page 4 of 10)
Biltmore Iron and Metal Company, Inc.
Asheville, NC
Date: Com pfeted By, �`t I
'
Automobile'Reclamatlon Tariks
275 gallon
used olVfilel!
276 gallon;.
150 gallon
•Comments Acid Schedule For Regolrec#'Action
. .
antltreeze':
,=use d olE
;used
Location on site map in Plan correct?
��1�
, , �,<
J �
�• ��
�
Evidence of Spills/Leaks or Pollutants?
rZU
Debris or Residue Present?
y� r }
Check condition of tanks and drums looking for drip
marks, discoloration, puddles of spilled or leaked
material, corrosion, cracks, other damage etc. Check tank
vents for obstructions.
Check alarms, gauges and other instrumentation.
Perform required testing.
f•�`
Check condition of secondary containment and nearby
area looking for damage, corrosion, cracks, presence of
leaked or stained material, settling, presence ; of
ve etation, etc.
Check that tank valves and loading/unloading
connections, and drums are securely closed.
Check containment for the presence of liquid. For
double -walled mobile tanks check interstitial space.
/
Check containment drain valves are securely locked.
r
Check truck loading/unloading area for evidence of a
r
release
*Complete table by indicating yes, no or not applicable (N/A). Identify required actions and schedule for completion.

COMPREHENSIVE SITE COmPLIANCE EVALUATION
(Page 5 of 10)
Biltmore Iron and Metal Company, Inc.
Asheville, NC
L>Ivrl
Date: Completed Bv:� �_ 11VAkn
Vehidle Malntenance Containers
275-gallons
:. 55"gallon .
off road
Comments And Schedules=or aequired-Action
°hydraulic oil .::.
. ,
motor. oil:; .
diesel ..
.
Location on site map in Plan correct?
UZs
Evidence of Spills/Leaks or Pollutants?
Jebris or Residue Present?
Check condition of tanks and drums looking for drip
marks, discoloration, puddles of spilled or leaked
f
/
v/
material, corrosion, cracks, other damage etc. Check tank
✓
vents for obstructions.
Check alarms, gauges and other instrumentation.
f
Perform required testing.
`
Check condition of secondary containment and nearby
area looking for damage, corrosion, cracks, presence of
leaked or stained material, settling, presence of
vegetation, etc.
Check, that tank valves and loading/unloading
connections, and drums are securely closed.
✓
�'
;heck containment for the presence of liquid. For
double -walled mobile tanks check interstitial space.
Check containment drain valves are securely locked.
f
Check truck loading/unloading area for evidence of a
release
*Complete table by indicating yes, no or not applicable (NIA). Identify required actions and schedule for completion.

COMPREHENSIVE SITE COMPLIANCE EVALUATION
(Page 6 of 10)
Biltmore Iron and Metal Company, Inc.
Asheville, NC
i1� 1
Date:,.,. �� 1C� ,Completed By: � l l
5ennebogen
Serinebagen'
Crane (1i0
Chine (70 .`
COMMENTS ��AND REQUIRED ACTIONS '
Operating: Equ�prnerit
= ' Baler
gallon
reservoir)
gallon
reaerr►olr)
Parked:
:,Pa. keti'at lower
beside sho
entl'of' and
Description in Plan Suitable?
Description of containment suitable?
Location on site map in Plan correct?
Check condition of baler reservoirs and baler operating
equipment and mobile cranes looking for: drip marks,
discoloration, puddles of spilled or leaked material,
corrosion, cracks, other damage etc.
Checks condition of haler and cranes: piping, valves,
flanges, etc. looking for droplets of oil, discoloration,
bowing of between
corrosion, pipe supports, evidence of
releases from valves or seals.
Check condition of baler reservoir room and parking area
for mobile equipment looking for damage, corrosion,
cracks, presence of leaked or stained material,. settling,
presence of vegetation, etc.
Check that any valves are securely closed.
LZ
*Complete table by indicating yes, no or not applicable (N/A). Identify required actions and schedule for completion.

COMPREHENSIVE SITE COMrLIANCE EVALUATION
(Page 7 of 10)
Biltmore Iron and Metal Company, Inc.
Asheville, NC
Date:— Completed By: i1 ±IZ ' r�
Volve Crane
with Shear
Vblve Crane
Western Star':
-
COMMENTS AND REQUIRED ACTIONS
(1fi0 gallon
�(70 gallon
Truck {55.
Operating Equipment
reservoir)
-at
reservoir)
Parked'at
gallon
reservoir)'
Parked
lower end of
lower end of
Parked 'at.
and
yard
`Metals Building
Description in Plan Suitable?
c�`'-
,
L
Description of containment suitable?
Location on site map in Plan correct?
,
Check condition of crane, shear and truck hydraulic
reservoirs looking for: drip marks, discoloration, puddles
/
of spilled or leaked material, corrosion, cracks, other
}�
damage etc.
Checks condition of cranes, shear and hydraulic lift:
piping, valves, flanges, etc. looking for droplets of oil,
discoloration, corrosion, bowing of between
pipe
supports, evidence of releases from valves or seals.
c
Check condition of parking area for mobile equipment
/
looking for damage, corrosion, cracks, presence of
1/
/
leaked or stained material, settling, presence of
V
vegetation, etc.
Check that any valves are securely closed.
*Complete table by indicating yes, no or not applicable (NIA). Identify required actions and schedule for completion.

COMPREHENSIVE SITE COMPLIANCE EVALUATION
(Page 8 of 10)
Biltmore Iron and Metal Company, Inc.
Asheville, NC
Date: f] ) ;;� Completed Bv: \' im h\a_ [ A I 1 Ni 1 C-tof—
Program Area
: Siatus
Commentsnd Required Action
Acceptable Materials
Program Status (SPPP
Appendix VI1)?
O Y
Spill Prevention and
Response Program Status
(SPPP Section 4)?
Preventative Maintenance
Program Status (SPPP
Section 5.3)?
Good Housekeeping
Program Status (SPPP
n
�.
Section 5.4)?
Inspections conducted and
documented (SPPP
Sections 5.1)?
Containment Drainage to
Stormwater Conveyances
Documented (SPPP Section
3.2.2)?
Employee Training
Conducted and
l�(�
Documented (Section 5.5)?
Analytical Monitoring
Conducted and Submitted'
to NCDENR (Section
--'
5.6.1)?
Qualitative Monitoring
Conducted? (Section
5.6.3)?
*Review program for compliance with Plan requirements including maintenance of
required documentation. Identify required actions and schedule for completion.
Indicate NIA if not applicable

COMPREHENSIVE SITE COMPLIANCE EVALUATION
(Page 9 of 10)
Biltmore Iron and Metal Company, Inc.
Asheville, NC
Date: Completed
Based on site inspection, review of facility records, and stormwater monitoring reports,
determine if any results or recurring conditions indicate a need for implementation of additional
best management practices or for changes in facility practices or procedures.
List any changes in facility storage areas, materials, operations, practices or program areas that
require revisions to the Plan.
Describe any significant spills, leaks or releases that have occurred during the previous three
years. i _

COMPREHENSIVE SITE COMPLIANCE EVALUATION
(Page 10 of 10)
Biltmore Iron and Metal Company, Inc.
Asheville, NC
Evaluate the stormwater outfalls for the presence of non-stormwater discharges and attach a
completed non-stormwater discharge evaluation and certification form.
This certification is to be completed by an authorized signatory after each annual site compliance
evaluation:
I 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 gather and evaluate the information submitted.
Based on my inquiry of the person or persons who manage the system, or those
perso directly responsible for gathering the information, the information submitted
is to th best of my knowledge and belief, true, accurate and complete. I am aware
that the a are si a e ties for submitting false information, including the
possibi! of fine ri�ent for knowing violations_
or duly authorized

PO Box 5616 (Mailing Address)
Asheville, NC 28813
[phone]-Phone
[phone]-Fax
[e-mail]
February 2, 2012
Ms. Susan Pope
US EPA, Region 4
61 Forsyth St. SW
Atlanta, GA 30303
Dear Susan,
X`SiL a*Eltr r fl^ -.
This is in response to the January 31, 2012 letter regarding AO# CWA 04-2012-4759.
Biltmore Iron's responses are as follows:
A. You are correct the SWPPP was signed and dated November 3, 2011 which you
received a signed copy of the entire SWPPP in December (ECS, our
environmental engineering company sent the SWPPP to you via email in
November so that copy was not signed by me --- it came from their office).
B. 1. and 2. The Environ Rack installation completion date was January 10, 2012.
The system was working full force on that date.
3. Larger drip pans were installed in November as an interim fix before the Environ
Rack was installed in January. 2012. As noted in the January 20, 2012 letter, the
drip pans (or as I called totem in the letter, the catch pans) are 249 gallons with an
additional 360 gallon spill tank/drip pan.
4. Training was performed by all that signed on page b of the SWPPP on November
3, 2011 to all employees. I did not realize you wanted a copy of the training form
where the employees signed in. It is attached with this letter.
5. Sweeping of concrete and asphalt areas is performed every Monday (sometimes
2-3 times a week). No formal records are kept. This has been taking place for
many years — I do,not know what year this started but we have owned a total of
two sweepers through the years.

#11' ^-�

EPA letter
2/2/12
Page Two
6. No inspection records are kept but the operators have known through the years
what to inspect on their piece of equipment before starting work each morning
and Jeff Cloninger, President, walks the yard each morning to make sure these are
performed.
7. All materials were removed from the storage area by November 1, 2011.
S. Detention pond was increased in size and completed on December 14, 2011.
9. I have notes on my calendar to have gravel delivered and spread the first working
day of every other month -sometimes more if needed (2012 dates are: Jan. 3,
March 1, May 1, July 2, Sept. 4, Nov. I
10. Erosion mat is in place and seeding will take place in spring.
11. The stormwater ditch did drain into the stream before the grading was clone in
December. It was decided in December that the ditch could drain into the pond if
the pond was increased in size which was performed then.
12. Monthly inspection program has been instituted (1 have not seen a note stating
that 1 was to send these monthly Forms to the EPA only that it be instituted.
However, I have sent December and January monthly inspection forms).
C. These inspections will be completed biannually on the Comprehensive Site
Compliance Evaluation Forms (10 pages found in SWPPP Appendix IX).
D. DMR.s are being transmitted monthly to the EPA and to NCDEHNR.
E. Semi-annual report to be sent to EPA in July 2012.
Biltmore Iron costs (Environ Rack, paving, erosion mat, ECS engineering services,
grading) thus far are $45,550 (this does not include overtime labor from myself and other
staff to *et with engineers, surveyors, contractors, prepare reports).
Vo$nd F.
Attachments: Nov. 3, 2011 Training Form
Monthly equipment inspection form (2)

4F 1•y

f1 '�i N.r.. ..?N-,;'•:��YwK-`�R•aA '4i.£r ... =^M.. xt; �. ..
..�, I
y�,zEu sr1}Fr
r) i UNITED STATES ENVIRONMENTAL PROTECTION AGE
.�rrr�r►„ REGION a
ATLANTA FEDERAL CENTER
61 EORSYTH STREET
ATLANTA, GEORGIA 30303-8960
JAN 31 2012
CERTIFIED MAIL 7010 1060 0002 1705 8103
RETURN RECEIPT REQUESTED
Ms. Vonna Cloninger
Chief Executive Officer, Biltmore Iron and Metal
Company, incorporated
One Meadow Road
Asheville, North Carolina 28803
1[
r r FEB — 6 2012
VVA'i'ER QtJALiTY SECTlCN R�
b L ASHEVILLE REGIONAL CFMCE
�L. ROiC:S��„.'A6•N'. e."V'3�/[ lwt�► �i�iira�i^.44-'�f- S .SY•_w
Re: Administrative Order No. CWA 04-2012-4759
National Pollutant Discharge Elimination System Permit No. NCG200339
Dear Ms. Cloninger:
The U.S. Environmental Protection Agency, Region 4 has received Biltmore Iron and Metal Company,
Incorporated's (BIMCO) submissions in response to Administrative Order (AO) No. CWA 04-2012-
4759. The first submission was not dated; however, it was stamped received by the EPA on December
28, 2011; the second response is dated January 20, 2012, and was received by the EPA on January 17,
2012. "rhe EPA has reviewed both submissions. To ensure that the EPA and BIMCO are in accord and
to eliminate any confusion, the following comments and questions are offered; Paragraphs I 7A through
E of the AO are referenced:
A. Immediately upon receipt of this Order, sign the Stormwater Pollution Prevention
Plan (SWPPP) as required by Parts II.A.7 and III.B.5 of the Permit. Within 30 days of the date
of receipt of this Order, submit a copy of the signed SWPPP.
A signed copy of the SWPPP was attached to the December 28, 2011,
submission; the SWPPP was dated November 3, 201 L
B. Immediately upon receipt of this Order, as required by Part II.A.9 of the Permit,
implement elements contained in the SWPPP as follows:
Provide containment to the 55-gallon motor oil drum in the maintenance
shop;
2. Provide containment to the 275-gallon used oil/fuel/antifreeze drum,
275-gallon used gasoline drum and 150-gallon used oil drum in the automobile fluid
reclamation area;
The December 28, 2011, response stated that a large containment platform had
been ordered and would be installed. 13IMCO's Ietter dated January 20, 2012,
stated that the platform had been installed. Please provide the date the platform
was installed and its use implemented.
I1it9rtt$t Address (URL) . http;/lwww.apa.gov '
Recycled/Recyctahlo • Printed wAh Vego[abie Oil Based Inks on P"Cled Paper (MInlmum 30"/. Postconsumer}

Provide containment or drip pans in the fluid reclamation yard;
The December 29, 2011, submission states that this was accomplished on
November 30, 2011. However, the January 20, 2012, submission, states
that this is being accomplished by the large containment platform.
Information provided is confusing; how will the platform replace drip pans
in the reclamation yard? Please provide details of how BIMCO
accomplished this task and how it will be accomplished in the future.
4. Provide employee training on Spill Prevention and Response procedures;
The December 28, 2011, submission stated that training was completed on
November 3, 2011. The January 20, 2012, response refers to page 6 of the
SWPPP for proof of training. Page 6 of the SWPPP contains the names of the
members of the Pollution Prevention Team. Training is referenced on page 30 of
the SWPPP. Please provide a training attendance list and how B1MCO will
institute training on a recurring basis for all employees.
Increase sweeping of concrete and asphalt areas;
The December 28, 2011, submission states that sweeping is done on a weekly
basis. Please provide the date that weekly sweeping was instituted and any
records reflecting the weekly events.
f. Conduct monthly inspections of the mobile equipment areas;
The December 28, 2011, response states that inspections are being done monthly,
beginning with December 1, 2011. The January 2012 submission states that
inspections of equipment are conducted on a daily basis. Please provide a copy of
any inspection records or logs that are being kept to documents these inspections.
7. Ensure that there are no materials stored in stormwater conveyance
areas;
The December 281h response states that this item was completed. The
January 20, 2012, submission states that there are no materials stored in
the conveyance area. Please provide the date materials were removed.
8. Evaluate the detention pond for either an increase in capacity or
provide for regular sediment removal;
Both submissions state that the evaluation was completed and that the
detention pond size was increased as of December 14, 2011.
9. Replenish the compacted gravel surface of the ferrous yard
roadway;

The December 28`h submission states that this is an ongoing activity and a
stockpile of gravel is kept on site. The January submission further states
that the gravel is replenished bi-monthly. Please provide any records or
logs kept to document this activity.
10. Provide vegetative cover to the stormwater ditch on the eastern property
boundary and on the detention pond berm and perimeter;
Both submissions state that an erosion mat is in place and that seeding will
take place in the spring.
It. Evaluate the feasibility of routing the stormwater Glitch discharge to the
detention pond; and
The December 281h submission does not address the stormwater ditch. The
January submission states, "... the stormwater ditch that discharges into
the stormwater pond was re-routed on December 14, 2011." It was the
EPA's impression that the stormwater ditch discharged directly to the
receiving stream. The EPA's AO requested a review of whether it might
be appropriate to route the stormwater ditch to the pond. Please provide
the EPA with the correct information.
12. Institute a monthly inspection program as required by the Oil Contingency
Plan of the mobile cranes, crane/shear and trucks with hydraulic lifts.
The January 20`h submission states that the equipment is inspected on a
daily basis by the operator. Please provide the EPA with records or logs
documenting the inspections.
C. ' Continue operating an inspection program in accordance with Part II.A.8
of the Permit. The inspection program shall include inspections of the facility and all stormwater
systems on at least a semi-annual basis, as part of the Preventative Maintenance and Good
Housekeeping Program, with copies of inspections being kept with the SWPPP. Provide copies
of these inspections for the first half of 2012 within ten (10) days of completion of the
inspection.
The December 28, 2011, submission stated that a monthly inspection
program had been instituted but did not state what that entailed. The
January 20, 2012, letter stated that inspections would continue and copies
provided in July 2012. Please clarify when these inspections are being
conducted; i.e., monthly, weekly, biannually, etc. and the date the
inspections began.
D. Continue operating an analytical monitoring program in accordance with
Part 11.13 of the Permit. Ensure that all parameters required by the Permit are sampled and the
analyses provided on a Discharge Monitoring Report (DMR) form as required by the Tier I and
Tier II Evaluations. Provide copies of DMRs for the period covering November 2011 through
March 2012, within 30 days of completion of the sampling and analysis.

Copies of DMRs for November and December 2011 were provided to the
EPA in the December 28, 2011, letter. The January 20, 2012, letter states
that the monthly sampling will continue through March 2012. Please make
note that each DMR should be transmitted to the EPA upon its completion
each month.
E. Continue the qualitative monitoring and visual inspection program in
accordance with Part II.0 of the Permit. Provide copies of qualitative monitoring and visual
inspection reports for half of 2012, within ten (10) days of completion.
The December 28, 2011, submission stated that a monthly inspection
program had been instituted but did not state what that entailed. "The
January 20`h submission simply states that the monitoring and visual
inspection program will continue. A copy of an inspection on December
22, 2011, was included. Please make note that these inspections are semi-
annual and that a report is due to the EPA in July 2012,
Please provide the EPA with a response addressing the items listed above within ten (10) days of receipt
of this letter.
In order to resolve BIMCO's liability for civil penalties, the EPA is offering your company the
opportunity to discuss the violations and settle all claims. Please contact Ms. Susan Pope at (404) 562-
9770 within five (5) days of receipt of this letter to make arrangements for representatives to discuss the
violations and the EPA's possible continuing enforcement. In lieu of appearing in the EPA's office for
this meeting, a telephone conference may be scheduled. Please provide any relevant information
regarding the costs of compliance with the Nf DES Permit. Representatives should be prepared to
provide all relevant information including, but not limited to, any financial information which may
reflect an ability to pay a penalty. You have the right to be represented by legal counsel. Failure to
contact Ms. Pope or appear may result in enforcement action against your company.
Should you have any questions or concerns, please contact Ms. Pope via phone or e-mail at
[e-mail] or forward written comments to the address on the letterhead. Legal inquiries
should be directed to Mr. Rolando Bascumbe, Associate Regional Counsel, at [phone].
Sincerely,
Denisse D. Diaz, Chief
Clean Water Enforcement Branch
Water Protection Division
cc: Mr. Charles Wakild
North Carolina Department of Environment and Natural Resources

PO Box 5616 (Mailing Address)
Asheville, NC 28813
[phone]-Phone
[phone]-Fax
[e-mail]
January 20, 2012
Susan Pope
US EPA, Region 4
61 Forsyth St., SW
Atlanta, GA 30303
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JAN 12 2012
WATER QUALITY SECTION
ASHEVILL E RGGIGNAL GFFIGE r
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Susan,
This letter is for the purposes of responding to the Administrative Order # CWA 04-2012-4759
issued December 16, 2011 page three III. Order 17. Also, enclosed are our Discharge Monitoring
Reports and Qualitative Monitoring Reports from August 2011-December 2011.
A. The entire bound SWPPP was received by Susan Pope (signed for by Tracy Jackson) on
December 27, 2011. Please note that it is signed on the necessary pages.
B. 1. The 55 gallon motor oil drum has been completely contained in the maintenance shop
(see picture #1).
2. All of the drums of used oil, used gasoline and used antifreeze have been
eliminated with the purchase of the Iron Ax Environ Rack automobile reclamation
center which is totally self-contained (249 gallon catch pan and a 360 gallon
additional tank to catch spills) which meets all EPA and state standards. (see pie
#2).
3. See #2 response and picture above for containment of drips pans.
4. Employee training on Spill Prevention and Response implemented on 11/3/11
(signed page 6 in SWPPP). Each person received training and copy of SWPPP by
Vonna Cloninger.
5. Sweeping of concrete and asphalt areas is being performed on a weekly basis by
one of our employees using our sweeper (see pie #3).
6. The employee responsible for their equipment performs a daily inspection of their
equipment and the area around their equipment. This has been ongoing for many
years.
7. There are no materials stored in the stormwater conveyance areas (see pie #4).
8. The stormwater detention pond has been increased and an additional overflow
pond has been constructed. This has completed December 14, 2011 (see pie #5).

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or 7

Letter to Susan Pope, EPA
1/10/12
Page Two
9. Gravel on road is replenished bi-monthly or on an as needed basis (see pic #6).
10. Vegetative cover/erosion mat is in place and seeding to begin in spring (see pic
#7).
11.The stormwater ditch that discharges into the stormwater pond has been re-routed
by a construction company and completed on December 14, 2011 (see pic #8.)
12. Inspections program of all equipment on a daily basis by operator.
This response has been completed by the 30 days of receipt of the Administrative
Order and all aspects have been totally completed.
C. The inspection/good housekeeping programs and all preventative maintenance programs
will continue and copies of these inspections will be sent to EPA the first week of July 2012
as requested.
D. Analytical monitoring will continue as requested through March 2012. (see attached
reports).
E. Qualitative monitoring and inspection will continue as requested (see attached reports).
I certify under the 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 gather and evaluate 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, 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.

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MONTHLY INSPECTION FORM
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Asheville,,.NC
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*Complete table by indicating yes, no or not applicable (N/A). Identify required actions and schedule for completion

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*Complete table by indicating yes, no or not applicable (N/A). Identify required actions and schedule for completion

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Check condition ofi parking area fior mobile equipment
looking for damage, corrosion, cracks, presence of
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Check that any valves are securely closed.
*Complete table by indicating yes, no or not applicable (N/A). Identify required actions and schedule for completion

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Asheville, NC
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piping, valves, flanges,- etc. looking for droplets of oil,
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*complete table by indicating yes, no or not applicable (N/A). Identify required actions and schedule for completion

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UNITED STATES ENVIROIVMENTAf_ PROTECTION AGENCY
REGION 4
o ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
DEC 1$ 2011 -
CERTIFIED MAIL 7010 1060 0002 1705 7861
RETURN RECEIPT REQUESTED
Ms. Coleen H. Sullins V
Director, Division of Water Quality
North Carolina Department of Environment ,F..:I '"E C EI +;
and Natural Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617`:' DEC 28 2011
Re: Administrative Order No. CWA 04-2012-4 WATER QUALITY SECTION t�S
cucVILLE REGIONAL OFFICE "£
National Pollutant Discharge Elimination System Permit No. NCG. :39-...., .. .
Biltmore Iron and Metal Company, Incorporated``""'
Asheville, North Carolina
Dear Ms. Sullins:
Pursuant to Sections 308 and 309(a) of the Clean Water Act (CWA), 33 U.S.C. §§ 1318 and 1319(a),
I have determined that the above referenced facility is in violation of Section 402(p) of the CWA,
33 U.S.C. § 1342(p).' As a result, I have issued an Administrative Order (AO), a copy of which is
enclosed for your reference. The AO is presently being served. Also enclosed is a copy of.the
Compliance Stormwater Evaluation Inspection performed at the site.
Enclosure
Sincerely,
7--tames D. Gi tttina
Director
Water Pr4ction Division
Intemet Address (URL) • http://www.apa.gov
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UNITED STATES ENVIRONMENTAL:PROTECTION AGENCY
REGION 4
ATLANFA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
DEC 16 2011
CERTIFIED MAIL 7010 1060 0002 1705 7854
RETURN RECEIPT REQUESTED
Ms. Vonna Cloninger
Chief Executive Officer, Biltmore Iron and Metal
Company, Incorporated
One Meadow Road
Asheville, North Carolina 28803
Re: Administrative Order No. CWA 04-2012-4759
National Pollutant Discharge Elimination System Permit No. NCG200339
Dear Ms. Cloninger:
On July 6, 2011, the U.S-E �ronmental Protection Agency issued Administrative Order (AO) No.
CWA 04-2011-4771 Baltimor�Ton and Metal (BIMCO) which is being; superseded by copy of this
letter by AO No. CWA 04-2012-4759. Pursuant to Sections 308 and 309(a) of the CWA, 33 U.S.C. §§
1318 and 1319(a), the Director of the Water Protection Division, EPA Region 4, has determined that
BIMCO is in violation of Sections 301 and 402(p) of the CWA, 33 U.S.C. §§ 13 11 and 1342(p). As a
result, the Director has issued the enclosed AO.
This AO does not replace, modify or eliminate any other requirement of the CWA or the Permit:
Notwithstanding the issuance of this AO, the EPA retains the right to bring further enforcement action
Linder Sections 309(d) or 3,09(g) of the CWA, 33 U.S.C. §§ 13 19(d) or 1319(g),,for the violations
cited therein or for any other violation of the CWA. Violations of the CWA, including requirements
coritained.in a National Pollutant Discharge Elimination System (NPDES) permit or an AO issued under
Section 309(a) of the CWA, remain subject to a civil penalty of up to $37,500 per day for each violation,
pursuant to Sections 309(d) or 309(g) of the CWA, 33 U.S.C. §§ 1319(d) or 1319(g), as amended by the
Civil Monetary Penalty Inflation At justment Rule. 73 Fed. Reg. 75340 (December 11, 2008). Such
violations may also be subject to criminal penalties pursuant to Section 309(c) of the CWA, 33 U.S.C.
§ 1319(c). -
In order to resolve BIMCO's liability for civil penalties, the EPA is offering your company the
opportunity to further discuss the violations in the AO. The EPA requests that representatives of
134MCO contact Ms. Susan -Pope -of my staff at [phone] within five (5) days of receipt of this
letter to make arrangements for representatives to discuss the violations and the EPA's possible
enforcement action. In lieu of appearing in the EPA's office for this meeting, a telephone conference
may be scheduled. Representatives should be prepared to provide all relevant information with
documentation, pertaining to the above referenced violations including, but not limited to, any financial
information which may reflect an ability to pay a penalty. You have the right to be represented by legal
counsel. Failure to appear may result in enforcement action against your company.
} Intennet Address (UAL) • �http;t/www.apa,gov
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Should you have any questions concerning; the requirements contained in the enclosed AO, please
contact Ms. Pope or submit written comments to the address on the letterhead. Legal inquiries should
be directed to Mr. Rolando Bascumbe, Associate Regional Counsel at [phone].
Sincerely.
Denisse D. Diaz, Chief
Clean Water Enforcement Branch
Water Protection Division
Enclosure
cc: Ms. Coleen H. Sullins
Director, Division of Water Quality
North Carolina Department of Environment and Natural Resources

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
IN THE MATTER OF: . l ADMINISTRATIVE ORDER
BILTMOPE [RON AND METAL CO., INC. )
ASHEVILLE, NORTH CAROLINA ) DOCKET NO. CWA-04-2012-4759
ADMINISTRATIVE ORDER
I. Statutory_ Authority
I . Section 309(a) of the Clean Water Act ("CWA"), 33 U.S.C. §- 1319(a), provides
that, whenever the U.S. Environmental Protection Agency finds that any person is in violation of
any condition or limitation which implements, inter alia, Sections 301 and 402 of the CWA,
33 U.S.C. §§ 131 l and 1342, the EPA may issue an order requiring such person to comply with
such condition or limitation, and shall specify a time for compliance that the EPA determines to
be reasonable.
2. The following Findings are made and Order issued pursuant to the authority
vested in the EPA by Section 309(a) of the CWA, 33 U.S.C. § 1319(a), as amended. This
authority has been delegated to the Regional Administrator of EPA, Region 4, and further
delegated by the Regional Administrator to the Director of the Water Protection Division, EPA,
Region 4.
If. Findings
3. Biltmore Iron and Metal Company, Incorporated ("BWCO"), is a corporation
duly organized and existing under the laws of the State of North Carolina and, therefore, is a
"person" within the meaning of Section 502(5) of the CWA, 33 U.S.C. § 1362(5).
4. At all times relevant to this action, BM4CO_ owned and/or operated a scrap metal
facility located at 1 Meadow Road -in Asheville, North Gargling.+~ W T - v� W"-_
5. To accomplish the objective of the CWA, defined in Section 101(a) of the CWA, .
33 U.S.C. § 1251(a), to restore and maintain the chemical, physical and biological integrity of the
nation's waters, Section 301(a) of the CWA, 33 U.S.C. § 1311(a), prohibits the discharge of
pollutants by, any person into waters of the United States except as in compliance with a National
Pollutant Discharge Elimination System ("NPDES") permit issued pursuant to Section 402 of the
CWA, 33 U.S.C. § 1342.
6. Section 402 of the CWA, 33 U.S.C. § 1342, establishes an NPDES Permit
Program authorizing the EPA or authorized states to administer the NPDES Permit Program,

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including the issuance of NPDES permits allowing; for the discharge ofpollutants, including
stormwater, into navigable waters subject to specific terms and conditions. The EPA has granted
the State of North Carolina, through the Department of Environment and Natural Resources
("NCDENR"), approval to issue NPDES permits pursuant to Section 402(b) of the CWA.
7. The NCDENR issued General Pet-mit to Discharge Stormwater Under the
Mational Pollutant Discharge Elimination Svstein, Permit No. NCG200000 ("Permit") for
establishments primarily engaged in assembling;, breaking; up, sorting and whole trade of scrap
metal (Standard Industrial Classification ("SIC") 5093 and areas at scrap metal recycling
facilities which are used to process other scrap materials (plastic, paper, glass, rubber and
textiles) or used for vehicle maintenance activities, in accordance with North Carolina General
Statute 143-215.1 and the CWA. The Permit was effective January I, 2010, and shall expire on
December 31, 2014.
S. The NCDENR Division of Water Quality is responsible for the approval of
coverage under the Permit upon receipt of a Notice of Intent ("NOI").
9. ' : On February 11, 2010, BIMCO received coverage under the Permit from
NCDENR. The Permit shall expire on December 31, 2014.
10. On July 6, 2011, the EPA issued Administrative Order ("AO")No.
CWA 04-201 1-4771 to BIMCO requiring compliance with the Permit which included the
development of Stormwater Pollution Prevention Plan ("SWPPP"), institution ofan inspection
and monitoring program, and a Tier One and Tier Two Evaluation.
11. The EPA and BIMCO had a conference call in September 2011 to discuss the
requirements of the Permit and the AO. BINICO provided elements required by the AO to the
EPA via email in November 201'1.
12. Part II.A.7 of the Permit requires the SWPPP to be signed by a responsible party
and refers to Fart EIl.B.S of the Permit.
13. Part I1.A.8 of the Permit requires inspections of the facility and all stormwater
systems as part of the Preventative Maintenance and Good Housekeeping Program on at least a
semi-annual schedule; once during the first half of the year (January to June) and once in the
second half of the year (July to December), with at least sixty (60) days separating inspection
dates (unless performed more frequently than semi-annually).
14. Part II.A.9 of the Permit requires the implementation of the developed SWPPP.
15. Part 11.13 of the Permit requires analytical monitoring of stormwater discharges at
least twice per year via grab samples for pH, Chemical Oxygen Demand ("COD"), Total
Suspended Solids ("TSS"), Oil and Grease, Total Recoverable Cadmium, Total Recoverable
Copper, Total Recoverable Iron, Total Recoverable Lead, Total Recoverable Zinc and Total
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Rainfall. All analytical monitoring Shall be performed during a representative storm event at each
stormwater discharge outfall and shall not exceed the benchmark values contained in Table 3 of
the Permit. Exceedance of the benchmark values require the permittee to increase monitoring,
increase management actions, increase recordkeeping, and/or install stormwater BMPs as
required in the tiered program contained in the Permit.
15. Part II.0 of the Permit requires qualitative monitoring which includes visual
inspection of each stormwater outfall regardless of representative status at [east twice per year
during a representative storm event. If the qualitative monitoring indicates either that the existing
stormwater WON are ineffective, or that significant stormwater contamination is present, the
permittee sliall investigate potential courses, evaluate the feasibility of corrective actions, and
implement those corrective actions appropriate. A written record of the investigation, evaluation
and response actions shall be kept in the SWPPP.
16. Part III.B.5 of the Permit provides signatory requirements which includes, for a
corporation, signature by a responsible corporate officer.
17. Part III.C. I of the Permit requires proper operation and maintenance of all
fitcilities and systems of treatment and control (and related appurtenances) which are installed or
used to achieve compliance. Proper operation and maintenance also includes adequate laboratory
controls and appropriate quality assurance procedures.
I& The EPA has reviewed the SWPPP and Tier 1 and Tier 2 Evaluations submitted
by BIMCO and has determined that BIMCO is not in compliance with the Permit as all
recommendations contained in the reports have not' been instituted_ As a result, BIMCO
continues to be in violation of Sections 301 and 402(p) of the CWA, 33 U.S.C. 5§ 011 and
1342(p), by failing to comply with the NCDE,IR Permit_
F1L Order
17. Based on the foregoing Findings and pursuant to the authority of Sections 308 and
309(a) of the CWA, 33 U.S.C. § § 13 18 and 1319(a), IT IS HEREBY ORDERED that BIMCO
comply with the following requirements:
A. Immediately upon receipt ofthis Order, sign the SWPPP as
required by Parts II.A.7 and III.B.5 of the Permit. Within thirty (30)
clays of the date of receipt of this Order, submit a copy of the .
signed SWPPP.
B. - Immediately upon receipt of this Order, as required by Part II.A.9
of the Permit, implement elements contained in the SWPPP as
follows:
3'

I. Provide containment to the 55-gallon motor oil drum in the
maintenance shop;
2. Provide containment to the 275-gallon used
oil/fuel/antifreeze drum, 275-gallon used gasoline drum and
150-gallon used oil drum in the automobile fluid
reclamation area;
3. Provide containment or drip pans in the fl.lud reclamation
yard;
4. Provide employee tmining-on Spill Prevention and' -
Response procedures;
5. Increase -sweeping of concrete and asphalt areas;
6. Conduct monthly inspections of the mobile equipment
areas;
7. Ensure. that there are no materials stored in stormwater
conveyance areas;
S. Evaluate the detention pond for either an increase in
capacity or provide for regular sediment removal;
9. Replenish the compacted _Gavel surface of the ferrous yard
roadway
10. Provide vegetative cover to the stormwater ditch.on the
eastern property boundary and on the detention pond berm
and perimeter; '
It. Evaluate the feasibility of routing the stormwater ditch
discharge to the detention pond; and .
12. Institute a monthly inspection program as required by the
Oil Contingency Plan. of the mobile cranes, crane/shear and
trucks with hydraulic lifts.
Within thirty (30) days of receipt of this Order, -provide notice, .
including pictorial evidence; that these elements have been
completed. If completion is..not possible within thirty _(30)days
provide,a schedule for implementation.
C. Continue operating an inspection program in accordance with
Part II.A.8 of the Permit. The inspection program shall include
inspections of the facility and all stormwater systems on at least a
semi-annuai basis, as part of the Preventative Maintenance and
Good Housekeeping Proggam; with copies of inspections being
kept with the SWPPP. Provide copies of these inspections for the
first half of 2012 within ten (10) days of completion of the
inspection.
D. Continue operating an analytical monitoring program in
accordance with Part I1.13 of the Permit. Ensure that all parameters
4

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required by the Permit are sampled arid the analyses provided on a
DNIR form as required by the Tier I and Tier If Evaluations.
Provide copies of DMRs for the period covering November 2011
through March 20I2 within thirty (30) Mays of completion of the
sampling and analysis.
E. Continue the qualitative monitoring and visual inspection program
in accordance with Part ILC of the Permit. Provide copies of
qualitative monitoring and visual inspection reports.for half of
2012 within ten (10) days of completion.
27. BIMCO may submit a request for anyextension of time to comply with the
requirements of this Order in writing. Such request must include the reasons for the extension
request and a date when compliance will be achieved. Any extension must be approved by the
EPA in writing to be effective.
28. All reports, notifications, documentation and submittals required by this Order
shall be signed by a duly authorized representative of BIMCO as specified by 40 C.F.R.
§§ 122.22(b)(2) and (d) and shall include the following statement:
"I certify under the 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 gather and evaluate 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, 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." '
29. All reports, notifications. documentation and submittals required
be sent by certified mail or its equivalent to the following addresses:
Denisse D. Diaz, Chief
Clean Water Enforcement Branch
Water Protection Division
ATTN: Susan Pope
U.S. Environmental Protection Agency, Region 4
61 Forsyth Street, S.W.
Atlanta, Georgia 30303-3960
and
5
this Order shall

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Coleen H. Sullins
Director, Division of Water Quality
North Carolina Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
IV. General Provisions
30. FaiiLire to comply with the requirements herein shall constitute a violation of this
Order and the CWA, and may subject BIiVICO to penalties as provided in Section 309(d) of the
CWA, 33 U.S.C. § 1319(d).
31. This Order shall not relieve BIMCO of its obligation to comply with all applicable
provisions of federal, state or local law, nor shall it be construed to be a ruling on, or
determination of, airy issue related to any other federal, state or local permit. Compliance with
this Order shall not be a defense to any actions subsequently commenced pursuant to federal laws
and regulations administered by the EPA.
32. Nothing in this Order shall be construed as prohibiting, altering, or in any way
limiting the ability of the United States to seek any other remedies or sanctions available by
virtue of BlNICO's violation of this Order or of the statutes and regulations upon which this
Order is based, or for BIMCO's.violation of any other federal or state statute, regulation or
permit.
33. Nothing in this Order is intended to nor shall be construed to operate in any way
to resolve any criminal liability of BIMCO, or other liability resulting from violations that were
riot alleged in this Order. The United States does not waive. any right to bring an enforcement
action against BIMCO for violation of any federal or state statute, regulation or permit, to initiate
an action -tor imminent and substantial endangerment or to pursue criminal enforcement.
34. This Order applies to and is binding upon.BIMCO and its officers, directors
employees, agents, successors and assigns.
35. Any change in the legal status of BIMCO, including but not limited to any transfer
of assets of real or personal property, shall not alter BIMCO's responsibilities under this Order.
36. Pursuant to Section 309(a)(4) of the CWA, 33 U.S.C. § 1319(a)(4), the EPA has
sent a copy of this Order to the State of North Carolina.
37. The provisions of this Order shall be deemed satisfied upon a detelznmation by "
the EPA that BIMCO has fully completed and implemented the actions required by this Order.
0

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V. Effective Date
3g. The effective date of this Order shall be the (late upon which it is received by
BINICO.
IT IS SO ORDERED,
BY THE U.S. ENVIRONNIENTAL PROTECTION AGENCY, REGION 4:
71 DEC 16 2011
tt� An ,- /
e ��-�LCc. -`, Date:
1 es D. iattina
Direct r
Wate Pr tection Division

TABLE 1
TIER ONEITIER TWO RESPONSE ACTIONS
(page 1 of 3)
Biltmore Iron and Metal Company, Inc.
Asheville, North Carolina
Potential BMPs
Required Action
Required Actions and
Status
Schedule
Acceptable Materials Program
Fully implemented
No Action Required
Fully implemented
Spill Prevention and Response Program
Requires formal training program
Begin Immediately
To be completed by Nov. 30, 2011
C Ie d t>
Good Housekeeping Program
Requires increased frequency of sweeping of
Begin Immediately
Fully implemented
hard surfaces and removal of scrap metal
p� S
and other improper materials located outside
the maintenance shop,
Preventative Maintenance Program
Fully Implemented
No Action Required
Fully implemented
Inspections Program
Not Implemented
Begin Immediately
To begin Nov. 30, 2011 — ongoing
thereafter 1E
Automobile Fluid Removal Practices
Fully Implemented
No Action Required
Implemented but am investigatin a
Large containment platform �Ab�r; r hS
Battery Handling Procedures
Fully Implemented
No Action Required
Fully implemented Fn .
Limit Material Storage in Stormwater
Remove scrap material and other debris
Complete by November 1,
Fully implemented L/1
Conve once Areas
surrounding the stormwater detention pond.
2011
Diversion of Runoff from Outdoor Material
Evaluate feasibility of Installing containment
Complete by December 31,
To be completed by Dec.31, 2011
Storage Areas
around fluid reclamation area. If not feasible,
use drip pans when draining vehicles.
2011
C9 I
Provide containment for ASTs.
Cover Material Storage Areas
Not technically feasible for storage piles or
No Action Required
Not feasible
warranted for fluid reclamation area
i

TABLE 1
TIER ONElTIER TWO RESPONSE ACTIONS
(page 2 of 3)
Biltmore Iron and Metal Company, Inc.
Asheville, North Carolina
Potential BMPs
Required Action
Required Actions and
Status
Schedule
Detention Pond
Evaluate possibility of increasing detention
Begin evaluation of
Talks have begun with grading
pond capacity by increasing the height of the
increase in detention pond
Contractor — completion no later than
berm and/or removal of sediment. An
capacity or sediment
December 31, 2011
engineering evaluation should be performed
removal immediately. If
if there is a significant increase in berm
height planned or the geometry of the pond is
feasible, complete by�
December 31, 2011
significantly modified.
Following implementation and evaluation of
effectiveness of lower cost BMPs, future
activities may consider evaluation of
economic feasibility of site grarding with
construction of engineered stormwater
control and detention facilities.
Impervious Surface Sediment Control
Installation of additional impervious surfaces
Replenish compacted
Gravel is received on a bi-monthly
prohibited by local ordinances and local
gravel surface of ferrous
basis. Will continue to replenish the
regulatory agencies. It is allowable to
yard roadway. Complete
Gravel -ongoing process
replenish additional gravel roadways.
by December 31 2011,
✓/
Vegetative Swale, Buffer, or Filter Strip
Limited area does not allow installation of
When weather permits
This will need to take place in the
much additional vegetated area. However,
attempt to establish
spring — too cold now. Will set a
grassy vegetation should be established
vegetation immediately
completion date of April 15, 2012.
along stormwater conveyances. An erosion
mat should be installed along the Swale
surrounding the detention
pond.CD
cam. Y1
located at the eastern property boundary.
The detention berm be
pond should
compacted and an erosion mat installedb
around the perimeter of the detention pond.
When weather permits these areas should be
seeded and vegetation established. All large
vegetation in stormwater conveyances
n
1i
should be removed.

TABLE 1
TIER ONE/TIER TWO RESPONSE ACTIONS
(page 3 of 3)
Biltrnore Iron and Metal Company, Inc.
Asheville, North Carolina
Potential BMPs
Required Action:
Required Actioris and
Status .
Schedule .
Slormwater Treatment
Advanced treatment required to consistently
No Action Required
Ongoing monitoring
meet benchmark limitations is not
economically feasible.
Other — Monthly Analytical and Qualitative
BIMCO has initiated an appropriate monthly
Continue until three
As of November 1, 2011, no outfall has
Monitoring
monitoring program.
samples For each
occurred,.. Will continue monthly
parameter are below the
monitoring/testis Ideally, our goal is
benchmark values or within
to have runoff.
the benchmark ran e
Other — Potential additional discharge
A potential discharge point may be located
Observe the area during
Hopefully completed by December 31,
point
south of the maintenance shop.
precipitation events for the
2011. No outfall in last three months.
presence of a discrete
discharge point. If present,
cc) W\V
pipe the stormwater from
this location to the
detention pond. Complete
by December 31, 2011.
Other —The USEPA recommended the
Enlarge the stormwater ditch located along
Complete
Completed.
stormwater conveyance ditch located
the west side of the property. Additionally,
along the west side of the property be
provide a small area to allow for settling.
enlaroed.

STORM WATER POLLUTION PREVENTION TRAINING FORM
Biltmore Iron and Metal Company, Inc.
Asheville, NC
�Employee:
Name
F.PA F, L
raining: Initial, AnnualRefresher, Plan Modification, Spill Follow-up, May also incorporate_
SPCC Training

` OCT 18 "Oil
1 fi
'i
11t'1TER OLSALffY S CTICN
FFICE
y. � _.,._.:ice .----w•—..�+..�
I
TIER ONE/TIER TWO EVALUATION
}
BILTMORE IRON AND METAL COMPANY, INCORPORATED
ONE MEADOW ROAD
ASHEVILLE, NORTH CAROLINA 28803
ECS PROJECT 09-20321
PREPARED FOR
.BILTMORE IRON AND METAL COMPANY, INCORPORATED
ASHEVILLE, NORTH CAROLINA 28803
OCTOBER 14, 2011
0

ECS CAROLINAS, LLP
"Setting the Standard for Service"
Geotechnical • Construction Materials • Environmental • Facilities NC Registered Engineering Firm F-1078
October 14, 2011
Ms. Vonna Fisher Cloninger, CEO
Biltmore Iron and Metal Company, Incorporated
One Meadow Road
Asheville, North Carolina 28803
Reference: Tier One/Tier Two Evaluation
Biltmore Iron and Metal Company, Incorporated
Asheville, North Carolina 28803
ECS Project No. 09-20321
Dear Ms. Cloninger:
ECS Carolinas, LLP- (ECS) is pleased to submit the; enclosed Tier One/Tier Two
Evaluation for the. Biltmore Iron and Metal Company,! Incorporated (BIMCO) facility
located at One Meadow Road in Asheville, North Carolina. This Tier One/Tier Two
Evaluation has been prepared to comply with requirements contained in the North
Carolina General Permit to Discharge Storrnwater at Scrap Metal/Matedal Facilities
(NCG200000). '
To complete the Tier One/Tier Two Evaluation, the facility CEO, or properly authorized
representative, must sign the Management Certification statements contained in
Section 4.0, Appendix II and Appendix III, The completed Tier One/Tier Two evaluation
must be forwarded to the United States Environmental Protection Agency and the North
Carolina Department of Environment and Natural Resources.
We appreciate the opportunity to provide our services to you. Under separate cover,
we will soon be forwarding you the revised Stormwater Pollution Prevention Plan
(SPPP). If there are questions regarding this Tier Ona/Tier Evaluation or the SPPP,
please contact us at [phone] ' or [phone].
Respectfully submitted,
ECS CAROLINAS, LLP
Miriam S. White, P.E.
Senior Environmental Engineer
'--fi(,vJwJ Tba pu lig,
L�tJ
Michael Brame, PWS
Principal Scientist
4811 Koger Boulevard • Greensboro, NC 27407 • T: 336-856-7150 • F: 336-856-7160 www.ecslimited.com
ECS Carolinas, LLP • ECS Florida, LLC • ECS Mid -Atlantic, LLC • ECS Southeast, LLC ECS Texas, LLP

Tier Onell-ler Two, Eva, �n
Biltmore Iron and Meta! Company, Inc.
ECS Project 0920321
October 14, 2011
TABLE OF CONTENTS
1.0 INTRODUCTION... ................... ............................... ........... ! ..........................
2.0 FACILITY INSPECTION.... _. ............. I .....................................
3.0 TIER ONEMER TWO RESPONSE ACTIONS ......................... ............................ 1
4.0 CERTIFICATION—,.. ............ ............................. .................... ......... 2
1
LIST OF TABLES
Table
I
Tier One/Tier Two Response Actions
LIST OF APPENDICES
.ARp2:ndl)t.
Stormwater Monitoring Data
Tier One/ Two Inspection
Non-Stormwater Discharge Certification
E
A

Tier OneMjer Two EYi 7n
Biltm_vre Iron and Metai company, Inc: j
ECS Project 09 20321.
October 14, 2D1 I
. a
1.0 INTRODUCTION'
Stormwater. discharges from scrap metal recycling facilities are permitted under North
Carolina_ Department of Environment and Natural Resources (NCDENR),"permit. number
NCG200000. The general.permit for scrap metal facility stormwater discharge hasobeen
issued.to,the Biltmore Iron and Metal -Company, Incorporated (BIMCO) under NCDENR
Certifieate'of Coverage number NCG200339. .
BIMCO collected stormwater samples on'.March 9, 2011 and March 20, 2011. These
samples wereanalyzed for cadmium,, lead; total suspended solids, and chemical .oxygen
demand'. 'The,* results- :of. the, laboratory.'analyses. - are . summarized in Appendix .I.
Benchmark valees were. exceeded: by both "samples analyzed for cadmium, lead, and
COD and one sample analyzed for TSS. "Based on•these results, BIMCO. must conduct
Tier One and Tier Two response actions, -including. monthly analytical and ' qualitative
monitoring. Monthly monitoring must continue until the:,results of laboratory. analyses for _
three consecutive months are below benchmark values.:
ECS Carolinas,, LLP (ECS) was contracted to perform a Tier One/Tier Two Evaluation.
This evaluation included an inspection of the facility operational areas and stormwater
conveyances and controls; an,evaluation of facility stormwater management -programs;
and identification of best management practices requiring improvements that will
potentially reduce, concentrations of the parameters of concern. ;
Based on the results of the site inspection conducted on October 3,2011, ECS is updating,
the `facility Stormwater Pollution'. Prevention Plan (SPPP). " This revision will address
requirements generated by the general permit number NCG200000 that became effective
January 1, 2010 and comments on'the modified SPPP provided by -the UPSEPA in a letter
dated July 29, 2011.
f 2.0 FACILITY INSPECTION
ECS performed a facility inspection on October 3, 2011. The results of this inspection
are documented on forms contained ,in Appendix II. The inspection included the annual
evaluatiori of .the stormwater oetfall? for'. the:"presence of non-stormwater discharge.
There was
.no discharge from.outfall 001 during this inspection (Appendix III).
3.0 TIER ONEMER TWO. RESPONSE ACTIONS.
Table 1 contains a summary of the status.of applicable best management practices
(BMPs). BMPs requiringimprovement, required actions_ and a schedule: for completion
are also identified in that table.

E
Tier One/T'ier Two F an
8iitmore,Iron and Meta,. ,ompa_rry, Inc.
EeS Project 0920321
October 14, 2011
4.0 CERTIFICATION
I certify under penalty of law that this document and,411I attachments were prepared under
my direction or supervision in accordance with a system designed to assure that qualified
personnel properly gather and -evaluate 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 tto the best of my knowledge and
belief, true, acc rate and complete. I am aware that ,there are significant penalties for
submitting false)nformation)2di��ossibility of fine and imprisonment for knowing
violations.. ,
2.

TABLE 1
TIER ONE/TIER TWO RESPONSE ACTIONS
(page 1 of 3)
Biltmore Iron and Metal Company, Inc.
Asheville, North Carolina
tilIi�riged�Act#a�� e�ricl WC16' diitpiyey R ._ '
Acceptable Materials Program
Fully Implemented
No Action Required
Spill Prevention and Response Program
Requires formal training program
Begin Immediately
Good Housekeeping Program
Requires increased frequency of sweeping of
Begin Immediately
hard surfaces and removal of scrap metal and
other improper materials located outside the
maintenance shop.
Preventative Maintenance Program
Fully Implemented
No Action Required
Inspections Program
Not Implemented
Begin Immediately
Automobile Fluid Removal Practices
Fully Implemented
No Action Required
Battery Handling Procedures
Fully Implemented
No Action Required
Limit Material Storage in Stormwater
Remove scrap material and other debris
Complete by November 1, 2011
Conveyance Areas
surrounding the stormwater detention pond.
Diversion of Runoff from Outdoor Material
Evaluate feasibility of Installing_ containment
Complete by December 31, 2011
Storage Areas
around fluid reclamation area. If not feasible,
use drip pans when draining vehicles.
Provide containment for ASTs.
Cover Material Storage Areas
Not technically feasible for storage piles or
No Action Required
warranted for fluid reclamation area

TABLE 1
TIER ONE/TIER TWO RESPONSE ACTIONS
(page 2 of 3)
Biltrnore Iron and Medal Company, Inc.
Asheville, North Carolina
Requfr-Actiarisisfid - �iriielabla -
Detention Fond
Evaluate possibility of increasing detention
Begin evaluation of increase in detention pond
pond capacity by increasing the height of the
capacity or sediment removal immediately. If
berm and/or removal of sediment. An
feasible, complete by December 31, 2011
engineering evaluation should be performed if
there is a significant increase in berm height
planned or the geometry of the pond is
significantly modified.
Following implementation and evaluation of
effectiveness of lower cost BM Ps, future
activities may consider evaluation of economic
feasibility of site grarding with construction of
engineered stormwater control and detention
facilities.
Impervious Surface Sediment Control
Installation of additional impervious surfaces
Replenish compacted gravel surface of ferrous
prohibited by local ordinances and local
yard roadway. Complete by December 31, 2011.
regulatory agencies_ It is allowable to
re lenish additional ravel roadways.
Vegetative Swale, Buffer, or Filter Strip
Limited area does not allow installation of much
When weather permits attempt to establish
additional vegetated area. However, grassy
vegetation immediately surrounding the detention
vegetation should be established along
pond.
stormwater conveyances. An erosion mat
should be installed along the swale located at
the eastern property boundary. The detention
pond berm should be compacted and an
erosion mat installed around the perimeter of
the detention pond. When weather permits
these areas should be seeded and vegetation
established. All large vegetation in stormwater
conveyances should be removed.

TABLE 1
TIER ONEMER TWO RESPONSE ACTIONS
(page 3 of 3)
Bittmore Iron and Metal Company, Inc.
Asheville, North Carolina
Pca,
•
v
Kill'
r
Stormwater Treatment
Advanced treatment required to consistently
No Action Required
meet benchmark limitations is not economically
feasible.
Other — Monthly Analytical and Qualitative
BIMCO has initiated an appropriate monthly
Continue until three samples for each parameter
Monitoring
monitoring program.
are below the benchmark values or within the
benchmark ran
Other — Potential additional discharge
A potential discharge point may be located
Observe the area during precipitation events for
point
south of the maintenance shop.
the presence of a discrete discharge point. It
present, pipe the stormwater from this location to
the detention pond. Complete by December 31,
2011.
Other -- The USEPA recommended the
Enlarge the stormwater ditch located along the
Complete
stormwater conveyance ditch located
west side of the property. Additionally, provide
along the west side.of the_property.be
a small area to allow.for settling.
enlarged.

STORMWATER MONITORING DATA
Biltmore Iron. and Metal Company, Inc.
Asheville, North Carolina
H
7.1
6.6 to 9.0 S.U.
Chemical OxygenDemand
298
131
120 MgA
Total Suspended Solids
125
50
100 MgA
Oil and Grease
30 m
Cadmium, total recoverable
0.0025
0.0018
0.001 mgA
Co r total recoverable
0.007 mgA
Iron total recoverable
N/A -
Lead total recoverable
0.336
0.165
0.03 mgA
Zinc total recoverable
0.067 mgA
`Not Analyzed

Date: 10/3/2011
Area "orderly and neat?
Improper Materials Present
Evidence of Spills/Leaks or
Pollutants?
Erosion, Debris or Residue
Present?
IDENTIFIED PROBLEMS:
4
y4Gi +- t
TIER ONEITWO INSPECTION 5'6"" p° AJ
(Page 1 of 6)
Biltmore Iron and Metal Company, Incorporated
Asheville, NC
Completed By: Miriam White, ECS Carolinas, LLP
"itxs6 Ire` i G onWFIU1�1� 191 4" tMon
Dorn eclamaii>anS' YslEct ,��.�.m„
Yes Yes Yes No No Yes Yes Yes
No No No No Yes No No No
No No No Yes No No No No
.No i No
No
No
�tl•���
Fluid Reclamation Area: During the inspection there was released material on the floor of the fluid reclamation area. This material was covered with a
granulated oil absorbent with the intent of removing the spilled material at a later time. It appears releases occur periodically during fluid removal activities.
Containment should be provided around the fluid reclamation area. If containment is not feasible, drip pans should be provided. The ASTs in the fluid
reclamation area are not contained and require adequately sized secondary containment. Additlonally, there is currently insufficient room in the fluid
reclamation area.to allow visual examination of the ASTs during inspections.
Maintenance Shop: There is debris and improper materials stored outside of the maintenance shop_ These materials should be disposed or stored In an
appropriate location.

TIER ONEii'WO INSPECTION
(Page 2 of 6)
Biltrnore Iron and Metal Company, Incorporated
Asheville, NC
Date: 101312011 Completed By: Miriam White, £CS Carolinas,'LLP
�' �
� `Z�irti�n-Pc i!�
�1;31:t�h',""- �
; , 'fli
f'Ciimrt;Ed�t�l��n�?Ffe�r�fecll �►ctlon ri .F .��, ��1.
Evidence of Spills/teaks or
Pollutants?
No
No
No
Debris or Residue Present?
No
No
No
Evidence of erosion?
No
No
No
Improper Materials Present
There is scrap metal surrounding the detention pond. This material
near detention pond, ditch
Yes
No
No
should be relocated.
or outf all 001?
Do qualitative monitoring
results indicate the
N/A
NIA
Has not been
Based on exceedance of benchmark levels, qualitative monitoring
presence of pollutants in
conducted
must be conducted on a monthly basis.
stormwater?
Do analytical monitoring
Monitoring data for the past two sampling events indicate
results exceed cut-off
NIA
NIA
Yes
exceedance of benchmark levels requiring initiation of monthly
concentrations?
monitoring.___
General Comments:
Facility personnel have indicated it is possible stormwater Irom an area'east of the maintenance shop does not flow to outfall 001. - If a discharge is identified in
this location, it should be piped or otherwise redirected to the detention pond.
L 13

TIER ONE/TWO INSPECTION
(Page 3 of 6)
Biltmore Iron and Metal Company, Incorporated
Asheville, NC
Date: 10/3/2011 Completed By: Miriam White, ECS Carolinas, LLP
LotfQri�
HIM i
quipmerl
Yt�s=cry
p x�:15 :EQi7NPlk# TxTEE��►T 1S F ENT�.x
(: �,f�aae sol bents, s+b r1 KR';Parl �o ectlive ipm M,
Maintenance Shop
Yes
Pallet of 50 pound bags of granulated sorbents. Protective equipment shouid
be purchased (e.g., gloves, safety glasses, etc.)
General Comments:
Facility operations are conducted on an area of less than three acres. During an USEPA inspection, it was recommended spill response equipment be stored in
multiple locations. Based on facility layout and vehicular traffic, storage containers located in the yard could not be easily protected from vehicles and equipment.
The maintenance shop is a central location, which is easily and quickly accessible. Therefore, the facility has elected to store spill response equipment in this
one location.

VIER ONEMER TWO INSPECTION
(Page 4 of 6)
Biltmore Iron and Metal Company, Inc.
Asheville, NC
Date: 10/312011 Completed By: Miriam White, ECS Carolinas, LLP
u
#AttfomobileR.mati���tlie �T�'`
A�
275-ga n`�
IP
�tatkg�'a�llay
OMMENTSSAiD_ QU RED ACTT©hf' "^ ,
-'ol`Vluelf'
ciii
W_1414 s _
t�se�i4viIl!-
p.o
"-
Check condition of tanks and drums looking for drip
No problems
Released
No
Drips noted on 275-gallon used oil AST
marks, discoloration, puddles of spilled or leaked
noted
material on
problems
material, corrosion, cracks, other damage etc. Check
tank
noted
tank vents for obstructions.
Check alarms, gauges and other instrumentation.
NIA
N/A
N/A
Perform required testing.
Check condition of secondary containment and nearby
No contain-
No contain-
No contain-
Containment must be provided.
area looking for damage, corrosion, cracks, presence of
-meat.
ment.
ment.
leaked or stained material, settling, presence of
ve etation, etc.
Check that tank valves and loading/unloading
Not checked.
Not checked.
Not checked.
connections, and drums are securely closed.
Check containment for the presence of liquid. For
Single walled
Single walled
Single walled
Containment must be provided.
double -walled mobile tanks check interstitial space.
tank. No
tank. No
tank. No
containment.
containment.
containment.
Check containment drain valves are securely locked.
NIA
NIA
NIA
Check truck loading/unloading area for evidence of a
No releases
No releases
No releases
release
identified,
identified.
identified..

TIER ONErrIER TWO INSPECTION
(Page 5 of 6)
Biltmore Iron and Metal Company, Inc.
Asheville, NC
Date: 10/3/2011 Completed By: Miriam White, ECS Carolinas, LLP
V al a4 t n �G 'ntalnera x t=
� .�
7 a1y+v�_
�� riot r
cif=road
tJ M S ANO+REt l f ED�AC' iDNS
�'�. �
�yc�raulla'oll
ol�'`
�
'r� .� - ,' :�, -� • �-�_
��- ,�..
.tllesel
Check condition of tanks and drums looking for drip
No problems
No problems
No problems
marks, discoloration, puddles of spilled or leaked
noted
noted
noted
material, corrosion, cracks, other damage etc. Check
tank vents for obstructions.
Check alarms, gauges and other instrumentation.
NIA
NIA
NIA
Perform required testing.
Check condition of secondary containment and nearby
No contain-
Located in
Double-
Motor oil drum located in building, but in
area looking for damage, corrosion, cracks, presence of
meat.
building.
walled tank
immediate vicinity of open doorway. Requires
leaked or stained material, settling, presence of
containment.
vegetation, etc.
The 275-gallon hydraulic oil tank is located within
a building away from the open doors. Since the
tank is located in the center of the room, the room
appears to provide adequate containment.
Check that tank valves and loading/unloading
Not checked.
Not checked.
Not checked.
connections, and drums are securely closed.
Check containment for the presence of liquid. For
No problems
Single wailed
Interstitial
double -walled mobile tanks check interstitial space.
noted
tank. No
space not
containment.
checked.
Check containment drain valves are securely locked.
NIA.
NIA
NIA
Check truck loadinglunloading area for evidence of a
No releases
No releases
No releases
release
identified.
identified.
identified.

TIER ONE/TIER TWO INSPECTION
. (Page 6 of 6)
Biltmore Iron and Metal Company, Inc.
Asheville, NC
Date: 10/3/2011 Completed By: Miriam White, ECS Carolinas, LLP
:, OperaiingdEqulp eten�t : r "
filet,
M bli+e $ Ir
MoblteE ra a
CO It4ENTSIF Ef A T�#ONS
5 ;'=
Check condition of baler reservoirs and baler operating
'No problems
Not checked.
Crane was being
Leaking equipment requires drip pan or
equipment, mobile shear and mobile crane looking for:
noted.
repaired in
impervious surface with containment.
drip marks, discoloration, puddles of spilled or leaked
outdoor location.
material, corrosion, cracks, other damage etc.
Released noted.
Checks condition of baler, shear and crane: piping,
No problems
Not checked.
Crane was being
Leaking equipment requires drip pan or
valves, flanges, etc. looking for droplets of oil,
noted.
repaired in
impervious surface with containment.
discoloration, corrosion, bowing of pipe between
outdoor location.
supports, evidence of releases from valves or seals.
Released noted.
Check condition of baler reservoir room looking for
No problems
N/A
N/A
damage, corrosion, cracks, presence of leaked or stained
noted.
material, settling, presence of vegetation, etc.
Check that any valves are securely closed.
Not checked.
Not checked.
Not checked.

TIER ONEMER TWO INSPECTION
(Page 7 of 10)
Biltmore Iron and Metal Company, Inc.
Asheville, NC
Date. 10/3/2011 Completed BY Miriam White, ECS Carolinas, LLP
Acceptable Materials
Written material
List of unacceptable materials available. Requires
Program Status (SPPP
requires
updating to indicate batteries are currently accepted.
Appendix VII)?
update.
Spill Prevention and
Requires
Written program in SPPP. Protective equipment should
Response Program Status
protective
be obtained and stored with absorbents.
(SPPP Section 4)?
equipment to
full implement
Preventative Maintenance
Fully
Personnel responsible for . equipment perform
Program Status (SPPP
implemented.
preventative maintenance. Activities are not
Section 5.3)?
documented.
Good Housekeeping
Requires
Written program in SPPP. Remove improper material
Program Status (SPPP
Implementation
stored in the vicinity of the maintenance shop and
Section 5.4)?
surrounding the detention pond.
Inspections conducted and
Requires
Required inspections have not been performed. Semi -
documented (SPPP
implementation
annual inspections, annual comprehensive site
Sections 5.1)?
evaluation and monthly inspections of mobile baler and
mobile shear are required. Inspections must be
documented.
Containment Drainage to
N/A
No containment structures are present at the facility.
Stormwater Conveyances
Documented (SPPP
Section 3.2.2)?
Employee Training
Requires
Employee training reportedly conducted.
Conducted and
written
Documentation required.
Documented (Section 5.5)?
documentation
Analytical Monitoring
Requires
Based on exceedance of benchmark levels, qualitative
Conducted and Submitted
implementation
monitoring must be conducted on a monthly basis. A
to NCDENR (Section
rain gauge must be installed to obtain storm event
5.6.1)?
precipitation.
Qualitative Monitoring
Requires
Has not been conducted. Based on exceedance of
Conducted? (Section
implementation
be levels, qualitative monitoring must be
5.6.3)?
conducted on a monthly basis.

TIER ONE/TIER TWO INSPECTION
(Page 8 of 10)
1311tmore Iron and Metal Company, Inc.
Asheville, NC
Date:10/3/2011 Completed By: Miriam White, ECS Carolinas, LLP
Based on site inspection, review of facility records, and stormwater monitoring reports, determine if
any results or recurring conditions indicate a need for implementation of additional best
management practices or changes to facility practices or procedures.
Formal training required for spill prevention and response program.
Increased frequency of hard surface sweeping required. _
Remove Improper materials located outside of maintenance shop. ,
Remove scrap material and debris surrounding the stormwater detention pond.
Attempt to establish vegetative cover in the immediate vicinity of the detention pond.
Install containment around the fluid reclamation area or use drip pans.
Provide containment for aboveground storage tanks.
Evaluate possibility of increasing detention pond capacity by increasing the height of the walls.
a
As necessary, obtain an engineering evaluation to establish strength of raised walls.
Replenish compacted gravel surface of ferrous yard roadway. T
Describe any significant spills, leaks or releases that have occurred during the previous three
years.
Facility personnel state no reportable releases during the previous three years.

TIER ONE/TIER TWO INSPECTION
(Page 9 of 10)
Biltmore Iron and Metal Company, Inc.
Asheville, NC '
Evaluate the stormwater outfalls for the presence of non-stormwater discharges and attach the
completed non-stormwater discharge certification statements.
A visual inspection was conducted during a period of dry weather and no discharge was noted. _
I 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 gather and evaluate 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, accurate and complete. I am aware that there are significant penalties for
submitting false information, includiW ti}� po "ibility of fine and imprisonment for knowing
violations. ml /// i //
Ms. bbnna

TIER ONEMER TWO INSPECTION
Biltmore Iron and Metal Company, Inc.
Asheville, North Carolina
The following evaluation was conducted to confirm that the facility does not have unpermitted non -
storm water discharges to outfall 001:
Date of Test or Evaluation:
10/3/2011
Method used to Test or Evaluate Outfall for Non-
Stormwater Discharges (e.g., visual inspection
during dry weather; dye testing, plant schematic
Visual evaluation during period of dry weather
review, etc.):
Describe results from test or evaluation for the
No discharge at outfall 001
presence of non-stormwater discharge (e.g., water
present or no water present)
Identify potential source(s) if non-stormwater flow is
present. Indicate if source is permitted and permit
Inspection did not identify unpermitted discharge.
number:
Name of person conducting the test or evaluation:
Miriam White, ECS Carolinas, LLP
Jeff Cloninger, BIMCO
1 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 gather and evaluate 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, th information submitted is to the best of my knowledge and belief, true, accurate and
complete. I am ware that there are s' nificant penalties for submitting false information, including
the possibility oj fine and impr' t f knowing violations.

UNITED STATES' ENVIRONMENTAL PROTECTION AGENCY
L REGION 4
O � J
ATLANTA FEDERAL CENTER
r +�t FORSYTH STREET
stir c.`,3
ATLANTA, GEORGIA 30303-8960
JUL 6 2011
CERTIFIED MAIL 7005 2570 0001 4886 8625
RETURN RECEIPT REQUESTED
Ms. Vonna Cloninger
Chief Executive Officer, Biltmore Iron and Metal
Company, Incorporated
One Meadow Road
Asheville, North Carolina 28803
Re: Administrative Order No. CWA 04-2011-4771
NPDES Permit No. NCG200339
Dear Ms. Cloninger:
On March 2, 2011, the U.S. Environmental Protection Agency and the North Carolina Department of
Environment and Natural Resources (NCDENR) performed a Compliance Stormwater Evaluation
Inspection (CSWEI) of Biltmore Iron and Metal Company, Incorporated (BIMCO). The EPA's
participation in this inspection was to evaluate BIMCO's compliance with the treatment and disposal of
stormwater in accordance with the requirements of Sections 301 and 402(p) of the Clean Water Act
(CWA), 33 U.S.C. §§ 1311 and 1342(p), the regulations promulgated thereunder at 40 Code of Federal
Regulations § 122.26 and the North Carolina General Permit to Discharge Stormwater Under the
National Pollutant Discharge Elimination System Permit No. NCG200000 (Permit), effective
January I, 2010, with an expiration date of December 31, 2014. The CSWEI revealed that BIMCO failed
to comply with the requirements of the Permit and CWA as outlined in the enclosed CSWEI report and
Administrative Order (AO).
As a result of the CSWEI and pursuant to Sections 308 and 309(a) of the CWA, 33 U.S.C. §§ 1318
and 1319(a), the Director of the Water Protection Division. EPA Region 4, has determined that BIMCO
is in violation of Sections 301 and 402(p) of the CWA, 33 U.S.C. 8§ 1311 and 1342(p). As a result, the
Director has issued the enclosed AO.
This AO does not replace, modify or eliminate any other requirement of the CWA or the Permit.
Notwithstanding the issuance of this AO, the EPA retains the right to bring further enforcement action
under Sections 309(d) or 309(g) of the CWA, 33 U.S.C. §§ 1319(d) or 1319(g), for the violations cited
therein or for any other violation of the CWA. Violations of the CWA, including requirements contained
in a National Pollutant Discharge Elimination System (NPDES) permit or an AO issued under
Section 309(a) of the CWA, remain subject to a civil penalty of up to $37.500 per day for each violation,
pursuant to Sections 309(d) or 309(g) of the CWA, 33 U.S.C. §§ 1319(d) or 1319(g), as amended by the
Civil Monetary Penalty Inflation Adjustment Rule, 73 Fed. R� 75340 (December 11, 2008). Such
violations may also be subject to criminal penalties pursuant to Section 309(c) of the CWA, 33 U.S.C.
§ 1319(c).
:nt&met Address (URL) - http://www.apa,gov
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In order to resolve BIMCO's liability for civil penalties, the EPA is offering your company the
opportunity to discuss the violations in the AO. The EPA requests that representatives of BIMCO
contact Ms. Susan Pope of my staff, at [phone] within five (5) days of receipt of this letter to
make arrangements for representatives to discuss the violations and the EPA's possible enforcement
action. In lieu of appearing in the EPA's office for this meeting, a telephone conference may be
scheduled. Representatives should be prepared to provide all relevant information with documentation,
pertaining to the above referenced violations including, but not limited to, any financial information
whichmay-reflect-anabilityto-pay-a penalty. You -have-the-rightto be represented-by,iegal counsel.
Failure to appear may result in enforcement action against your company.
Enclosed is a document entitled U.S. EPA Small Business Resources -Information Sheet for your use and
to assist you in understanding the compliance assistance resources and tools available to you. However,
any decision to seek compliance assistance at this time does not relieve you of your obligation to the
IPA, does not create any new rights or defenses, and will not affect the EPA's decision to pursue
enforcement action. In addition, the Securities and Exchange Commission requires its registrants to
periodically disclose environmental legal proceedings in statements filed with the Commission. To assist
you, the EPA has also enclosed a document entitled Notice of Securities and Exchange Commission
Registrants' Duty to Disclose Environmental Legal Proceedings.
Should you have any questions concerning the requirements contained in the enclosed AO, please
contact Ms. Pope or address written comments to the address on the letterhead. Legal inquiries should be
directed to Mr. Rolando Baseumbe. Associate Regional Counsel, at [phone].
Sincerer,
Denisse D. Diaz, Chief
Clean Water Enforcement Branch
Water Protection Division
Enclosures
cc: Ms. Coleen H. Sullins
NCDENR

r�Y.0 i'7�rC^
UNITED STATES ENVIRONMENTAL. PROTECTION AGENCY
A
r REGION 4
A rLANTA FEDERAL CENTER
LFAw
' 61 FORSYTH STREET
Jf4r `mut''� A. rt-ANTA. GEORGIA 30303-8960
JUL 6 2011
CERTIFIED MAIL 7005 2570 0001 4886 8632
RETURN RECEIPT REQUESTED
Nis. Coleen H. Sullins
Director, Division of Water Quality
North Carolina Department of Environment
and Natural Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Re: Administrative Order No. CWA 04-201 1-4771
National Pollutant Discharge Elimination System Permit No. NCG200339
Biltmore Iron and Metal Company, Incorporated
Asheville, North Carolina
Dear Ms. Sullins:
Pursuant to Sections 308 and 309(a) of the Clean Water Act (CWA), 33 U.S.C. §§ 1318 and 1319(a), I
have determined that the above referenced facility is in violation of Section 402(p) of the CWA,
33 U.S.C. § 1342(p). As a result, I have issued an Administrative Order (AO), a copy of which is
enclosed for your reference. The AO is presently being served. Also enclosed is a copy of the
Compliance Stormwater Evaluation Inspection performed at the site.
Enclosures
Sincerely,
dames D. Giattina
Director
Water Protection Division
Internet Andress (LJRL) • http://www.spa.gov
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
IN THE MATTER OF: ) ADNIINISTRATIVE ORDER
BILTNIORE IRON AND METAL CO., INC. )
ASHEVILLE, NORTH CAROLINA ) DOCKET NO. CWA-04-2011-4771
ADMINISTRATIVE ORDER
I. Statutory Authority
I. Section 309(a) of the Clean Water Act ("CWA"), 33 U.S.C. § 1319(a), provides that,
whenever the U.S. Environmental Protection Agency Finds that any person is in violation of any
condition or limitation which implements, inter alia, Sections 301 and 402 of the CWA, 33 U.S.C.
§§ 1311 and 1342, the EPA may issue an order requiring such person to comply with such condition or
limitation, and shall specify a time for compliance that the EPA determines to be reasonable.
2. The following Findings are made and Order issued pursuant to the authority vested in the
EPA by Section 309(a) of the CWA, 33 U.S.C. § 1319(a), as amended. This authority has been delegated
to the Regional Administrator of EPA, Region 4, and further delegated by the Regional Administrator to
the Director of the Water Protection Division, EPA, Region 4.
II. Findings
3. Biltmore Iron and Metal Company, Incorporated ("BIMCO"), is a corporation duly
organized and existing under the laws of the State of North Carolina and, therefore, is a "person" within
the meaning of Section 502(5) of the CWA, 33 U.S.C. § 1362(5).
4. At all times relevant to this action, BIMCO owned and/or operated a scrap metal facility
located at I Meadow Road in Asheville, North Carolina.
5. To accomplish the objective of the CWA, defined in Section 101(a) of the CWA,
33 U.S.C. § 1251(a), to restore and maintain the chemical, physical and biological integrity of the
nation's waters, Section 301(a) of the CWA, 33 U.S.C. § 1311(a), prohibits the discharge of pollutants
by any person into waters of the United States except as in compliance with a National Pollutant
Discharge Elimination System ("NPDES") permit issued pursuant to Section 402 of the CWA,
33 U.S.C. § 1342.
6. Section 402 of the CWA, 33 U.S.C. § 1342, establishes an NPDES Permit Program
authorizing the EPA or authorized states to administer the NPDES Permit Program, including the
issuance of NPDES permits allowing for the discharge of pollutants, including stormwater, into
navigable waters subject to specific terms and conditions. The EPA has granted the State of North
Carolina, through the Department of Environment and Natural Resources ("NCDENR"), approval to
issue NPDES permits pursuant to Section 402(b) of the CWA.

7. The NCDENR issued General Permit to Discharge Stormwater Under the National
Pollutant Discharge Elimination System, Permit No. NCG200000 ("Permit") for establishments
primarily engaged in assembling, breaking up, sorting and whole trade of scrap metal (Standard
Industrial Classification ("SIC") 5093 and areas at scrap metal recycling facilities which are used to
process other scrap materials (plastic, paper, glass, rubber and textiles) or used for vehicle maintenance
activities, in accordance with North Carolina General Statute 143-215.1 and the CWA. The Permit was
effective January 1, 2010, and shall expire on December 31, 2014.
S. The NCDENR Division of Water Quality is responsible for the approval of coverage
under the Permit upon receipt of a Notice of Intent ("NO1").
9. On February 11, 2010, BIMCO received coverage under the Permit from NCDENR. The
Permit shall expire on December 31, 2014.
10. fart II_A.1 of the Permit requires the development of a Stormwater Pollution Prevention
Plan ("SWPPP") which shall include:
A. a site plan which provides a description of the physical facility and the potential
pollutant sources which may be expected to contribute to contamination of stormwater discharges;
B. a general location map showing the facility's location in relation to transportation
routes and surface waters, the name of the receiving water, and accurate latitude and longitude of the
point(s) of discharge;
C. a narrative description of storage practices, loading and unloading activities,
outdoor process areas, dust or particulate generating or control processes, waste disposal practice$ and a
description of the potential pollutants which could be expected to be present in the any stormwater
discharge from each outfall; and
D. a site map depicting the site property boundary, the stormwater discharge outfalls,
all on -site and adjacent surface waters and wetlands, industrial activity areas, site topography, all
drainage features and structures, drainage areas for each outfall, direction of flow in each drainage area,
industrial activities occurring in each drainage area, buildings, existing Best Management Practices
("BMPs"), impervious surfaces and a distance legend indicating the percentage of each drainage area
that is impervious.
11. Part I.I.A.2 of the Permit requires the SWPPP to include a Stormwater Management Plan
which contains a narrative description of the materials management practices which control or minimize
the exposure of significant materials to stormwater, including structural and nonstructural measures.
The Stormwater Management Plant shall include:
A. a feasibility study to include a review of the technical and economic feasibility of
changing the methods of operations and/or storage practices to eliminate or reduce exposure of materials
and processes to stormwater. Wherever practical, BIMCO shall prevent exposure of all storage areas,
material handling operations, and manufacturing or fueling operations, In areas where elimination of
2

exposure is not practical, the stormwater management plan shall document the feasibility of diverting
stormwater runoff away from areas of potential contamination; and
B. a listing of site structural and non-structural BMPs. A BMP Summary shall
include a written record of the soecitic rationale for installation and implementation of the selected site
BiiilPs and shall be reviewed and updated annually.
12. Part II.A.3 of the Permit requires a Spill Prevention and Response Plan ("SPRP"),
contained in the SWPPP, which shall incorporate an assessment of potential pollutant sources based on a
materials inventory of the facility. The SPRP team shall be identified in a written list incorporated into
the SPRP signed and dated by each individual acknowledging their responsibilities for the SPRP. An oil
Spill Prevention Control and Countermeasure Plan "SPCC") may be a component of the SPRP.
13. Part II.AA of the Permit requires the SWPPP to include a preventative maintenance and
good housekeeping program which shall list all stormwater control systems, stormwater discharge
outfalls, on -site and adjacent surface waters and wetlands, industrial activity areas, drainage features and
structures and existing BMPs. The program shall establish schedules of inspections, maintenance and
housekeeping activities of stormwater controls systems, facility equipment, facility areas and facility
systems that present a potential for stormwater exposure or pollution. Inspection of material handling
areas and regular cleaning schedules of these areas shall be incorporated into the program. Timely
compliance with the established schedules for inspections, maintenance and housekeeping shall be
recorded in writing and maintained in the SWPPP.
14. Part II.A.5 of the Permit requires the SWPPP to contain a training program that provides,
at a minimum, annual training for facility personnel with responsibilities for: spill response and cleanup,
preventative maintenance activities and for any of the facility's operations that have the potential to
contaminate stonnwater runoff''. Facility personnel responsible for implementing the training shall be
identified and their annual training shall be documented by the signature of each employee trained.
15. Part II.A.7 of the Permit requires amendment to the SWPPP whenever there is a change
in design, construction, operation or maintenance which has a significant effect on the potential for the
discharge of pollutants to surface waters. All aspects of the SWPPP shall be reviewed and updated on an
annual basis. The annual update shall include: an updated list of significant spills or a statement that no
spills have occurred; written re -certification that the stormwater outfalls have been evaluated for the
present of non-stormwater discharges; and a documented re-evaluation of the effectiveness of the BMPs
listed in the BMP Summary of the Stormwater Management Plan.
16. Part [[_A.S of the Permit requires inspections of the facility and all stormwater systems as
part of the Preventative Maintenance and Good Housekeeping Program on at least a semi-annual
schedule; once during the first half of the year (January to June) and once in the second half of the year
(July to December), with at least sixty (60) days separating inspection dates (unless performed more
frequently than semi-annually).
17. Part 11.13 of the Permit requires analytical monitoring of stormwater discharges at least
twice per year via grab samples for pH, Chemical Oxygen Demand ("COD"), Total Suspended Solids
("TSS"), Oil and Grease, Total Recoverable Cadmium, Total Recoverable Copper, Total Recoverable
3

Iron, Total Recoverable Lead, Total Recoverable Zinc and Total Rainfall. All analytical monitoring shall
be performed during a representative storm event at each stormwater discharge outfall and shall not
exceed the benchmark values contained in Table 3 of the Permit. Exceedance of the benchmark values
rcquire the permittee to increase: rnonitoring, increase management actions, increase recordkeeping,
and/or install stormwater BMPs as required in the tiered program contained in the Permit.
18. Part II.0 of the Permit requires qualitative monitoring which includes visual inspection of
each stUnnNvater uu'tf ll regardless elf fep eesentative status at least twice per year during a representative
storm event. if the qualitative monitoring indicates either that the existing stormwater BMPs are.
ineffective, or that significant stormwater contamination is present, the permittee shall investigate
potential courses, evaluate the feasibility of corrective actions, and implement those corrective actions
appropriate. A written record of the investigation, evaluation and response actions shall be kept in the
SWPPP.
19. Part III.C. I of the Permit requires proper operation and maintenance of all facilities and
systems of treatment and control (and related appurtenances) which are installed or used to achieve
compliance. Proper operation and maintenance also includes adequate laboratory controls and
appropriate quality assurance procedures.
20. Part 111.13 of the Permit contains the requirements for monitoring, sampling, recording
sampling results, test procedures and records retention.
21. On March 2, 2011, representatives of the EPA, in conjunction with NCDENR,
performed a Compliance Stormwater Evaluation Inspection (,,CswE1") at BIMCO to evaluate the
treatment and disposal of stormwater in accordance with the CWA, the regulations promulgated
thereunder at 40 Code of Federal Regulations ("C.F.R.") § 122.26 and the Permit.
22. As a result of the CSWEI. the EPA, Region 4 determined that stormwater associated with
industrial activity was discharged from BIMCO within the meaning of Section 442(p) of the CWA,
33 U.S.C. § I342(p), and its implementing regulations into an unnamed tributary of the Swannanoa
River, a water of the United States.
23. During the CSWEI, the EPA inspectors provided a copy of an "NPDES Inspection
Observation Form" to BIMCO representatives. As noted on the "NPDES Inspection Observation Form"
and in the CSWEI Report, the following was observed:
A. BIMCO failed to develop and implement a SWPPP in accordance with
Part 11.A.I of the Permit. Specifically, BIMCO failed to: sign and date the
SWPPP; develop a site plan; develop a general location trap; provide a
narrative description of storage practices, loading and unloading activities,
outdoor process areas and waste disposal areas; and develop a site map.
B. BIMCO failed to develop a Stormwater Management Plan in accordance
with Part li.A.2 of the Permit. The Stormwater Management Plan should
have included a narrative description of the materials management
practices; a feasibility study; and a BMP Summary.
4

C. BIMCO failed to develop SPRP and SPCC Plans in accordance with
Part II.A.3 of the Permit.
D. BIMCO failed to include a preventative maintenance and good
housekeeping progiram in its SWPPP as required by Part II.A.4 of the
Permit.
E. BIMCO failed to provide a training program in the SWPPP as required by
Part II.A.S of the Permit.
F. BIMCO failed to review and update its SWPPP on an annual basis as
required by Part II.A.7 of the Permit.
G. BIMCO failed conduct inspections on a semi-annual basis as required by
Part tI.A.S of the Permit. Specifically, the inspections for 2009 were not
available.
H. BIMCO failed to conduct all analytical monitoring as required by Part [I. B
of the Permit. Specifically, the data for 2009 was not available. Only one
sample was collected for 2010. For that one 2010 sample, the benchmark
values for COD, Total Recoverable Cadmium and Total Recoverable Lead
were exceeded. No samples were analyzed for pH, Oil and Grease, Total
Recoverable Copper and Total Recoverable Zinc.
1. BIMCO tailed to conduct all qualitative monitoring and visual inspections
required by Part ILC of the Permit.
24. On February 18, 2008, NCDENR sent BIMCO a Notice of Violation ("NOV") requiring
the modification of the SWPPP and sampling per permit requirements. NCDENR issued another NOV
on April 11, 2011, noting violations of the SWPPP and monitoring requirements of the Permit. In
response BIMCO provided a response on May 2, 2011, stating that the SWPP had been updated and that
qualitative monitoring; had been submitted to NCDENR.
25. Therefore, BIMCO has violated Sections 301 and 402(p) of the CWA, 33 U.S.C. §§ I3I 1
and 1342(p), by failing to comply with the NCDENR Permit.
1I1. Order
26. Based on the foregoing Findings and pursuant to the authority of Sections 308 and 309(a)
of the CWA, 33 U.S.C_ §§ 1318 and 1319(a), IT IS HER EBY ORDERED that BIMCO comply with the
following requirements:
A. Immediately upon receipt of this Order, as required by Part II.A.1,
Part II.A.2, Part II.A.3, fart ILAA, Part II.A.5 and Part ILA.7 of the
Permit, develop and implement a SWPPP. Specifically, ensure that all

requirements of the SWPPP are incorporated, including: sign and date the
SWPPP: sign and date the non-stormwater certification statement: a site
plan-, a general location map; a narrative description of storage practices,
loading and unloading activities. outdoor process areas and waste disposal
areas; a site map; a Stormwater Management Plan; SPRP and SPCC Plans;
a preventative maintenance and good housekeeping prot7am; a training
_ program; and review and update the SWPPP on an annual basis. Within
thirty (30j days ot'the date of receipt -of this Order, submitt-a copy of the
Updated SWPPP which includes all the requirements of this Paragraph.
B. Immediately upon receipt of this Order, institute an inspection program in
accordance with Part I I.A_8 of the Permit. The inspection program shall
include inspections of the facility and all stormwater systems on at least a
semi-annual basis, as part of the Preventative Maintenance and Good
Housekeeping Program, with copies of inspections being kept with the
SWPPP. Provide copies of these inspections for second half of 2011 and
the first half of 2012 within ten (10) clays of completion of the inspection.
C. Immediately upon receipt of this Order, institute an analytical monitoring
program in accordance with Part 11.13 of the Permit. Ensure that all
parameters required by the Permit are sampled and the analyses provided
on a DMR form. Provide copies of DMRs for the January -June 2011 and
July -December 2011 monitoring period within thirty (30) days of
completion of the sampling and analysis.
D. Immediately upon receipt of this Order, provide the Tier One review and
responses required by the Permit for exceeding the benchmarks in the
2010 monitoring of COD, Total Recoverable Cadmium and Total
Recoverable Lead. Within thirty (30) days of the date of receipt of this
Order, submit documentation that this requirement of the Order has been
met.
E.. Immediately upon receipt of this Order, institute a qualitative monitoring
and visual inspection program in*accordance with Part II.C. of the Permit.
Provide copies of qualitative monitoring and visual inspection reports for
the second half of 2011 and the first half of 2012 within ten (10) days of
completion.
27. BIMCO may submit a request for any extension of time to comply with the requirements
of this Order in writing. Such request must include the reasons for the extension request and a date when
compliance will be achieved. Any extension must be approved by the EPA in writing to be effective.
28. All reports, notifications, documentation and submittals required by this Order shall be
signed by a duly authorized representative of BIMCO as specified by 40 C.F.R. §§ 122.22(b)(2) and (d)
and shall include the following statement:
r

"I certify under the 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
quaiitied personnel properly gather and evaluate 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, accurate, and complete. 1 am aware that there are significant
penalties for submitting false information, including the possibility of tine and
imprisonment for knowing violations."
29. All reports, notifications, documentation and submittals required by this Order shall be sent
by certified mail or its equivalent to the following addresses:
Denisse D. Diaz, Chief
Clean Water Enforcement Branch
Water Protection Division
ATTN. Susan Pope
U.S. Environmental Protection Agency, Region 4
61 Forsyth Street, S.W.
Atlanta, Georgia 30303-8960
and
Coleen H. Sullins
Director, Division of Water Quality
North Carolina Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
IV. General Provisions
30. Failure to comply with the requirements herein shall constitute a violation of this Order
and the CWA, and may subject BIMCO to penalties as provided in Section 309(d) of the CWA,
33 U.S.C. § 1319(d).
31. This Order shall not relieve BIMCO of its obligation to comply with all applicable
provisions of federal, state or local law, nor shall it be construed to be a ruling on, or determination of,
any issue related to any other federal, state or local permit. Compliance with this Order shall not be a
defense to any actions subsequently commenced pursuant to federal laws and regulations administered
by the EPA.
32. Nothing in this Order shall be construed as prohibiting, altering, or in any way limiting
the ability of the United States to seek any other remedies or sanctions available by virtue of BIMCO's
violation of this Order or of the statutes and regulations upon which this Order is basest, or for BIMCO's
violation of any other federal or state statute, regulation or permit.
7

33, Nothing; in this Order is intended to nor shall lie construed to operate in any way to
resolve any criminal liability of BIMCO, or other liability resulting from violations that were not alleged
in this Order. "ihe United States does not waive any right to bring an enforcement action against BIMCO
for violation of any tWeral or state statute, regulation or permit, to initiate an action for imminent and
substantial endangerment or to pursue criminal enforcement.
344• W This Order applies to and is binding; upon BIMCO and its officers, directors, employees,
agents, successors and assigns.
35. Any change in the legal status of 131MC0, including but not limited to any transfer of
assets of real or personal property, shall not alter BIMCO's responsibilities under this Order.
36. Pursuant to Section 309(a)(4) of the CWA, 33 U_S.C. § 131 }(a)(4), the EPA has scltt a
copy of this Order to the State of North Carolina.
37. The provisions of this Order shall be deemed satisfied upon a determination by the EPA
that BIMCO has fully completed and implemented the actions required by this Order.
V. Effective Date
38. "rile effective date of this Order shall be the date upon which it is received by BINiCO.
IT IS SO ORDERED,
BY THE U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION 4:
Date:
James/D. is tin
Dir
Water Protection Division

United States Environmental Protection Agency
Washington, D.C. 20460
V-�EPA Water Compliance Inspection Report
Section A: National Data System Coding i.e., PCS
Transaction Code NPDES yrlmolday Inspection Type Inspector Fac Type
N NGG200339 11 /03/02 J
Remarks
Inspection Work Days Facility Self -Monitoring Evaluation Rating BI QA — •Reserved -- --
Section B. Facility Data
Name and Location of Facility Inspected {For industrial users discharging to POTW, also include
POTW name and NPDES permit number)
Entry TimelDate
Permit Effective Date
Biltmore Iron and Metal Co., Inc.
1 Meadow Rd.
Asheville, NC 28803
2:55 P.M.-03/02111
02/11/2010
Exit TimelDate
Permit Expiration Date
5:30 P.M.-03102111
12131/2014
Name(s) of On -Site Representative(s)/Title(s)lPhone and Fax Number(s)
Vonna Cloninger, C.E.O
Biltmore Iron and Metal Co.. Inc.
1 Meadow Rd.
Asheville, NC 28803
Tel, [phone], Fax [phone]
Other Facility Data (e.g., SIC NAILS, and other descriptive
information)
Other represenlas ves present during the inspection:
Susan Willson- NC DWQ
Jeff Cloninger- Biltmore Iron and Metal Co., Inc.
Name, Address of Responsible OffEciaffiidefPhone and Fax Number
Vonna Cloninger, C.E.O
Biltmore Iron and Metal Co., Inc.
1 Meadow Rd,
Asheville, NC 28803
Tel. [phone], Fax [phone]
Section C: Areas Evaluated Durinq Inspection
Check only those areas evaluated)
Pretreatment MS4
X
Permit
Self -Monitoring Program
X
RecordslReports
Compliance Schedules
Pollution Prevention
X
X
Facility Site Review
Laboratory
Storm Water
Effluent/Receiving Waters
Operations & Maintenance
Combined Sewer Overflow
Flow Measurement
Sludge Handling/Disposal
Sanitary Sewer Overflow
Section D: Summary of Findings/Comments
Attach additional sheets of narrative and checkfists, including Single Event Violation codes, as necessa
SEV Codes SEV Description
❑❑❑❑❑
❑❑❑❑❑
❑❑❑❑❑
Name($) and Signature(s) of Inspector(s)
Agency/Office/Phone and Fax Numbers
Date
A eli Bonilla U
USEPA Region 4lWPO-CWEB-SWRES
Ph: (404) 562- 9 Fax: [phone]
Signa re oflManagee%gnt Reviewer
Christopher L. Plymale, Chief• tormwater id Residuals
AgencylOfficelPhone and Fax Numbers
USEPA Region 4NVPD-CWEB
Date
& — 1 3 i
Enforcement Section
Ph: [phone] Fax: [phone]
EPA Form 3560.3 (Rev 1.06) Previous wilions are ahsoEete.
Page 1 of 5

Section E: NPDES Industrial Storm Water Worksheet (North Carolina)
1. FACILITY LOCATION INFORMATION
35034' 10" N gitude 82° 32' 46" W
GAS Coordinates, „- Latitude [::Lfon
if
,. y 5
Ftecoiy_lpg,W ter(a) or MS_ 4 '
Site Acreage: 3 acres
Weather Condition: Sunny, Mild
buts .o 'Swanriario ivi3r
bate'of<l�tbl - ,M
SIC
Date:of Perrriit'Goveraga °
-Dlschacge to 3t13()
No
LL r .0 .
Code(s)
:..-`' (13wk after N01`dato rig-..`.
02/11110
listed orLTMDt. ►raters_
1
5093
imittedlateif prevlrxus ptrirlit
N,
a ;
coverage existed}
.2. BASIC STORMWATER POLLUTIONPREVENT
INFORMATION -Part
YIES'
"NO'
NIE~
Plan on -site?
X
Plan has date and signature? The Plan was not signed at the time of the Inspection. However, an
X
updated with the signature was provided signed and dated March 7, 2011.
Plan contain site map wldrainage area, structural controls, material slareasexposed to precipitation,
X
storage areas, surface water bodies, locations of major spills/leaks, locations exposed to precipitation,
and storm water outfall? Part II.A.1 a - c
Plan Include list of significant spills or leaks previous 3 yrs & corrective actions? None were recorded in
the past 3-years, Pall ll.A,J.(d)
X
Plan contains Certification of non-stormwater evaluation? The non-stormwater certifications were
X
stormwater Management Plan containing narrative of mat'Is mgmt developed wlfeasibility study,
X
secondary containment rqmts & records, & BMP summary? Part II.A.2
Spiii Prevention & Response Plan? Part Il.A.3
X
Spill Prevention & Countermeasure Plan (SPCC)?
X
Date?
Preventative Maintenance and Good Housekeeping Program w/list of sw controls, outfalls, surface
X
waters, ind activity areas, drainage features & structures, existing BMPs, schedule for Inspections,
maintenance & housekeeping, facility areas? Part II.A.4
Plan contains des criptionlfrequency for employee training? Part II.A.5
X
Pollution Prevention Team named in Plan? Part II.A.6
X
Plan modified or update to current conditions? Part II.A.7
X
A coat' of Plan may be broucht back to office for a complete review
The site Is a scrap metal facility that receives scrap metal material such as household, commercial (construction sites), and car
(less than 3%) scrap. Once the scrap metal is received, it is collected, handled, sorted, and processed. Processed scrap metal is
shipped from the facility by truck or rail car.
There is a catch basin behind the maintenance shop that collects a portion of the stormwater flow from the site, Photo #11. The
catch basin does not have an outfall. Three (3) 275 gallon tanks and one (1) 150 gallon tank were observed near the vehicle fluid
draining area outside of the maintenance shop, Photos #2, 3, and S. There were also a few hydraulic fluid and oil tanks Inside the
maintenance shop, Photos #6 and 7. A 500 gallon dual walled tank was observed near the catch basin, Photo #10. Oil staining
was observed near the vehicle fluid draining area, Photos #1 and 4. A small antifreeze fluid spill was seen on the southeastern
portion of the site, Photo #36. Mr. Jeff Cloninger stated that there was a drainage ditch just west of the railroad tracks that
collected stormwater and directed it towards the Outfall #001, Photos #29, 30, and 31. The drainage ditch was very shallow and
Page 2 of 5

did not appear to provide adequate - ,mage for the site.
Biltmore Iron and Metal Co., Inc. (BIMCO) was issued an NOV on February 18, 2008 by NC DWQ. The NOV findings included the
need to modify and update the Stormwater Pollution Prevention Plan (Plan) to current conditions and to begin sampling per the
permit requirements. At the time of the inspection, it was noted that the Plan was not updated to reflect the current conditions no
was it updated annually. Semi-annual routine inspections and analytical sampling records were not available at the time of the
inspection for 2009. Only one semi-annual inspection and sampling record for 2010 was reviewed. The one analytical sample
was collected March 22, 2010, and some of the required parameters were not analyzed. Some of the benchmarks were exceeded
such as, COD, total recoverable cadmium, and total recoverable lead. Other sampling parameters were not analyzed such as pH,
Oil and Grease, total recoverable copper, and total recoverable zinc.
r . ,
RHCord Review `_ a 9 ys -'s ` 4 F '�a J 4
S
NO
c i y E
Representative on -site
X
Semi-annual (J-J & J-D) routine inspections conducted of facility 8 sw systems? Missing 2009 records
X
Part II.A.8
Semi-annual Analytical Sampling Reports on -site? Missing 2009 records Part II.B.
X
Analytical Sampling Non-compliance? Proceed wl Tier One, Tier Two, or Tier Three?
X
Visual Inspections during analytical sampling? Part II.C.
X
Inspection reports complete and adequate?
X
Records of employee training on -site?
X
On Site Vehicle Maintenance? Part II.D.
X
P.oitu�ta t Sources; r
( �.F' .�� rf.'Ta.$�
t" location;Jiiiantltati4e`descrriipttan, desigr€ iss�e,,O&M-def 6iencies (including the nature an' i
a =
extent}`and�pollutsnts aft "sirvte 3 s
Loading/Unloading Area
There was loadingiunloading area with a scale near the main office, Photo #9.
Outdoor Storage Facilities
A majority of the property was used for outside storage/processing operations of scrap metal
materials, Photos #12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 26, 32, 33, 34, 35, 37, 38, and 39.
Outdoor
See above "Outdoor Storage Facilities" However, there were indoor processing operations Inside
Manufacturing/Processing
he non-ferrous warehouse that included a baler for soda can compaction, Photos #40 and 41.
Operations
Dust Generating Activities (Dirt
roads? Dust control plan?)
Not applicable.
Waste
Treatment/Storage/Disposal
Three (3) 275 gallon tanks and one (1) 150 gallon tank were observed near the vehicle Fluid
Areas
draining area outside of the maintenance shop, Photos #2, 3, and 5.
ere was a maintenance shop located on the northeastern portion of the site. There was a few
Fueling/Equipment
hydraulic fluid and oil tanks inside the maintenance shop, Photos #6 and 7.
Maintenance areas &
lCleaning areas
Page 3 of 5

There is a catch basin behind the maintenance shop that collects a portion of the stormwater flow
Management of Run-off
from the site, Photo #11. The catch basin does not have an outfall. . Mr. Jeff Cloninger stated tita
Controls (Storage areas,
there was a drainage ditch just west of the railroad tracks that collected stormwater and directed it
diversion ditches, dumpsters,
towards the Outfall #001, Photos #29, 30, and 31. The drainage ditch was very shallow and did not
secondary containment, etc...}
appear to provide adequate drainage for the site.
Not applicable
Sediment & Erosion Controls
BMPs
if staining was observed near the vehicle fluid draining area, Photos #1 and 4. A small antifreeze
fluid spill was seen on the southeastern portion of the site, Plioto #36.- --
Spills/Leaks Handling
STORMr
OBSERVATIONS
OutfaEl,=Starinwater ' '.• YES
Disclzar
Fir b,. _"rc ,-
Nume€ & iQGation of i
X
Describe: Mr, Jeff Cloninger stated that there was a drainage ditch just west of the
stormwater -, _
railroad tracks that collected stormwater and directed it towards the Outfall #001, Photos
discharges}loutfa[!(s?3
#29, 30, and 31. The drainage ditch was very shallow and did not appear to provide
consistent with Use Map
adequate drainage for the site, Outfall 9001 discharged to an unnamed tributary of the
;-
� x_
Swannanoa River, Photos #27 and 28.
Evidence of.off slte. ° .3
X
Describe: Not applicable
aceuriiufation a�:paElutants. � 1
obs,6rved'in r meiving'water, T
dischargewor potential =
X
Describe: Not applicable
°disc,Other
h'arges'�off;site-(not;::` :� �w
frougl=perrrtitted autfalls)r
q- �,G�....y.' ;.^.•'"fig. :.�kz:.r .r.� ac#"�r
Non -storm wafer.dlscharge .
X
Describe: Not applicable
Page 4 of 5

Additional inspection summary, narrative, findings, comments, photos, and schematic diagram of the
facility area as necessary:
Exit interview conducted with: Vonna Cloninger with BIMCO at 5:30 P.M.
PHOTO LOG:
Photo #1- View of a car being drained of fluids (transmission, oil, etc.) near the maintenance shop.
Photo #2- View of tank used to store transmission fluids, used oil, gasoline and antifreeze.
Photo #3- View of tanks looking west.
Photo #4- View oil staining near the car that was being drained of fluids in Photo #1.
Photo #5- Another view of the tanks looking northeast.
Photo #6- Another fuel tank located inside the maintenance shop.
Photo #7- Engine oil tank located inside the maintenance shop.
Photo #8- View looking east of the car in Photo #1. Note tire storage outside the maintenance shop.
Photo #9- View of drop-off are near the non-ferrous warehouse.
Photo #10- 500 gallon dual walled diesel tank outside the maintenance shop.
Photo #11- Catch basin south of the maintenance shop. The basin does not have an outfall.
Photo #12- View of cars south of the catch basin.
Photo #13- View household scrap metal west of the catch basin.
Photo #14- Another view of the scrap metal behind the non-ferrous warehouse.
Photo #15- Scrap metal beside the railroad tracks.
Photo #16- More scrap metal west of the railroad tracks.
Photo #17- Closer view of Photo #16. Note the car engines and vehicle scrap.
Photo #18- Scrap metal south of the non-ferrous warehouse.
Photo #19- Scrap metal near the McDowell St. bridge.
Photo #20- View of the southern perimeter of the property near McDowell St. bridge.
Photo #21- Scrap mufflers on the southeast portion of the property.
Photo #22- View looking south of scrap metal on the railroad tracks.
Photo #23- Another view of the scrap metal on the railroad tracks.
Photo #24- View of scrap metal east of the railroad tracks.
Photo #25- View of area east of the railroad tracks.
Photo #26- View of the BIMCO property taken from the location of Photo #25 looking west.
Photo #27- Upstream view of the tributary of the Swannanoa River.
Photo #28- Downstream view of the tributary of the Swannanoa River.
Photo #29- Outfall #001 at the tributary of the Swannanoa River. (Lat: 350 34' 08" N, Long: 820 32' 46" W)
Photo #30- View of inlet to the pipe known as Outfall #001. Note there is a shallow ditch just south of the
inlet.
Photo #31- Closer view of the inlet described in Photo #30.
Photo #32- View of area just west of the inlet in Photo #31. Note the piled up scrap metal.
Photo #33- View of scrap metal on the southwestern portion of the site.
Photo #34- Closer view of the scrap metal in Photo #33.
Photo #35- View of the property looking north.
Photo #36- View of antifreeze spill on the southeastern portion of the property.
Photo #37- View looking north of scrap metal being loaded onto truck.
Photo #38- View of empty gas tanks and other scrap metal in bins outside the non-ferrous warehouse.
Photo #39- Closer view of Photo #38. Note ballasts were observed in the bins. However, they did not
contain PCBs per Mr. Jeff Cloninger.
Photo #40- View inside the non-ferrous warehouse on the northeastern portion of the property.
Photo #41- Another view of Photo 940
Photo #42- View of BIMCO entrance facing Meadow Rd.
Page 5 of 5

Biltmore Iron & Metal Co., Inc.
Ferr6w
Plant L
Post Office Box 5616
shevillc, NC 28813-5616
" 'D,
Phone [phone]
v F%
Ma 2, 2011 MAY ` 4 201 tacsi'h le [phone]
birijcori?bellsoutlt.net
Roger C. Edwards, Reg. SuperViso
N C D E N R , �; V4�e�'F�t� :��A:''!T�•: s� � i�E� � .�
rt;?;YY„•V."6€?, isx v�"',�'i
Division of Water Quality
2090 US Highway 70
Swannanoa, ,NC 2877$
Dear Mr. Edwards -
This letter is written in response of Notice of Violation (NOV-2011-PC-0237).
have rewritten our Stormwater Pollution. Prevention Plan (SPPP) and brought it
up to date and current and have.enclosed relevant portions..I have the entire
SPPP available at, our office. If you would like.for me to send the entire revised -
SPPP to you, I certainly can do so. I have enclosed the revised site map that
shows the stormwater discharge outfa11.
sy�
I have sent to Susan Wilson the current Qualitative Montoring _Report which was �p
completed by Pace -Analytical dated March 22, 2011.. She stated that she has
indeed received this report. I have since made notes to monitor our stormwater,
.discharge semi-annually. I was totally confused about the need. for semi-annual
testing. I -understood the form reads Annual reporting and thought'l only needed
to test annually. Now I know!
Analytical monitoring will also occur semiannually (I have already placed this on
our calendar for March 1 and August 1 of each year.
Jeff Cloninger_ has brought in equipment and reconfigured an_area of our scrap
yard for better drainage into our detention basin. The area near the railroad will /
be completed (scrap metal pile moved a'nd ditch graded) by May 5, 2011.
appreciate your understanding and welcome. a follow-up visitl, If there are
further questions, please contact me. Thank'you.
Reg s,
nna Fisher 4oninCEO
Cc:. Susan Wilson

•
�' ' �
r �
• •
1'

S WP3
BIMCO
Revision to page 4
2.3.3 Site Drainage
The facility drainage is controlled by the surface topography. Approximate
drainage patterns are indicated on Figure 2. On the northern portion of the site,
drainage is to the southeast by overland flow toward s catch basin (Outfall 001).
Outfall 002 was been eliminated. On the eastern and southern portions of the site,
drainage is to the northeast by overland flow and through a ditch towards the catch
basin (Outfall 001). On the western portion of the site, drainage is to the east and
northeast by overland flow towards the catch basin (Outfall 001).
Storm water outfalls are indicated on Figures 1 and 2 and are as follows:
Outfall Latitude Longitude Receiving Water Body
001 350, 341508' N 820, 32% 46' W Swannanoa River
2.3.4 Spill History
The facility has never had any spill events. This section shall be updated during
the term of the permit.
5

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y REFERENCE: FIGURE 1
SITE LOCATION MAP
USGS ASHEVILLE, NC ���
QUADRANGLE -- HILTMORE IRON AND METAL
ENGINEERING HILTIUMORE, NORTH CAROLINA
SCALE' I�-20Of3� CONSULTING
SERVICES,LTD

ASPHALT SUBSURFACE
PIPE
METAL
ROOM
OFFICE
RAILROAD
SPUR
ASPHALTNNON-FERROUS
wr FHGImf
OUTFALL
CATCH 001
BASIN
CREEK
SOIL
ENGINE
BLOCKS
DITCH
FERROUS
YARD
SOIL
z
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MCDOUELL STREET
SCALE (IN FEET)
50 100
i00 O
x
• FIGURE 2
-�® SITE PLAN
REFERENCE: BILTMORE IRON AND METAL
AERIAL PHOTOGRAPH BILTMORE, NORTH CAROLINA
PROVIDED BY CLIENT ENGINEERING
CONSULTING
SERVICES,LTD """n®/e-27-a2 "�' 0-!iwm

PO Box 5616 (Mailing Address)
Asheville, NC 28813
[phone]-Phone
[phone]-Fax
NON -STORM WATER DISCHARGE CERTIFICATION
The following evaluation is provided as demonstration that the facility does not
have unpermitted non -storm water discharges:
1. There are no floor drains inside the facility buildings that are connected
to the storm water system.
2. Residual fluids are collected and properly disposed.
3. The facility has no equipment or truck cleaning operations with outside
discharges.
4. All sanitary discharges are to the municipal sanitary sewer system. f
5. This evaluation is based on the personal knowledge of facility
personnel. No other evaluative approaches were utilized or deemed
necessary.
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 gather and evaluate 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, accurate, and complete. I am aware that there are significant penalties for
submirse� ation, including the possibility of fine and imprisonment for
knowi
inger, CEO / E Date

I
Ln r, ,
m
-
WI
Q Postage $ �.`ob pPI `c
— - --- — - - - - — rn CerUftd Pee-
Q Reim Receipt Foe
— — C7 (Endorsement Required) .0 i} - 12 M -
Restricted Delivery Fee " !
4 (EndOhOrmntRequired)
TOW Postage & Fees $
a Vohna winger
r, Biltmore Iron a .._.._ 1" nd Metal Co., Inc. �
1 Meadow Road
Asheville,'NC 28803 _. --

■ Complete Items 1, 2, and 3. Also complate a slgna
Rem 4 If Restricted Delivery Is desired. X �}
e Print your name and address on the reverse
so that we can Tatum the card to you. 13' Received by (Printed
jr --4 •-+k. h—lr of tha rnailnlar•.a-
North Carolina Department of
Environment and Natural Resources rery+
Division of Water Quality y
I NCDE�dR 2090 U.S. Highway
Water Protection Section j
70, Swannanoa, NC 28778i
Vonna Cloninger
Biltmore Iron and Metal Co., Inc
1 Meadow Road
Asheville, NC 28803
111111IL11,11111111111111111411
C. Date
=m
irent-f6n item�19 ❑
r
rddress below: ❑
rig r �
p 4-
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> F" O
0 J
4
sZ'e
TypelcizrtifiedMall 13f-kpress Mailgistered Return Reoelpt for M
❑ Insured Mall C-6b,
4. Restricted Delivery? (Extra Fee) ❑
r 70�10 1870 0003 0874 6352 JU(A) -ZO//-P/- -4 2 317
PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540

UNITED STATES POSTAL SERVICE
First -Class Mail
Postage & Fees Paid
USPS
Permit No. G-10
• Sender: Please print your name, address, and ZIP+4 in this box •
CHUCK CRANFORD 4
i NCDENR-DWQ SWP
2090 U.S. HIGHWAY 70
SWANNANOA NC 28778

I L E C v PY
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director -Secretary
April 11, 2011
CERTIFIED MAIL
RETURN RECEIPT REQUESTED —
Ms. Vonna Cloninger
Biltmore Iron and Metal Co., Inc.
1 Meadow Road
Asheville, NC 28803
SUBJECT: Notice of Violation
NOV-2011-PC-0237
Biltmore Iron and Metal
7010 1870 0003 0874 6352
NPDES General Stormwater Permit — NCG200339
Buncombe County
Response Deadline: May 9, 2011
Dear Ms. Cloninger:
This letter is in follow-up to the NPDES Stormwater Permit Compliance Inspection conducted on
March 8, 2011. Susan Wilson, Division of Water Quality (DWQ) and Araeeli Bonilla (EPA
Region IV) met with Mr. Jeff Cloninger and you at Biltmore Iron and Metal off Meadow Road in
Asheville, Buncombe County. The facility was found to be in violation of permit NCG200339.
The following stormwater permit violations were noted during the site inspection:
1. Stormwater Pollution Prevention Plan (SPPP)
➢ The Stormwater Pollution Prevention Plan (SPPP) was not up-to-date (and had not been
updated annually). A site plan map with all stormwater discharge outfalls should also
be included, as required, with the SPPP.
2. Qualitative Monitoring
➢ Qualitative monitoring has not been conducted and recorded in accordance with permit
requirements (see comments in inspection report).
3. Analytical Monitoring
➢ Analytical monitoring has not been conducted and recorded in accordance with permit
requirements (see comments in inspection report).
Location: 2090 U.S. Highway 70. Swannanoa, North Carolina 28778 One
828.296•A5001 FAX: [phone] Customer Service: 1-877-623.6748 NorthCarolina
h
Internet: Www,ncwaterquality.org Aat�ira!!y
r
G An Equal Dpporlunity 1 Affirmative Acton Employer

Ms. clonirtger
April 11, 2011
Page 2 of 2
Enclosed is a copy of the Compliance Inspection Report, which contains additional observations
and comments for your reference.
Please explain why these problems occurred and when Biltmore Iron and Metal will be in full
compliance with the stormwater permit.
Please -contact Susan A.-Wilson-at-(828)-296-4665'or'susan a-.wilson@ncdenr:gov, should -you-
- have questions regarding the inspection or this letter. - -
You may also wish to contact Chuck Cranford at [phone] or chuck. cranfordCa,�ncdcringov ;
he is the DWQ stormwater inspector for Buncombe County and will conduct a follow-up site visit
in the near future.
Sincerely,
Roger C. Edwards, Regional Supervisor
Surface Water Protection
Asheville Regional Office
Enclosure: Inspection Report
NCG0200000
cc' ARO File Copy (w/Inspection Report)
Araceli Bonilla, EPA Region IV (wAnspection Report)
McCray Coates, Stormwater Services, City of Asheville (wllnspection Report)
S:ISWP\Haywood\StormwaterWCG12 LandfillMaywood Co landfilKEI.NOV-201 I-PC-02351andfill.4 201 l.doc

Compliance Inspection Report
Permit: NCG200339 Effective: 01/01/10 Expiration: 12/31/14 Owner: Biltmore Iron & Metal Co Inc
SOC: Effective: Expiration: Facility: Biltmore Iron & Metal Co Inc
County: Buncombe 1 Meadow Rd
Region: Asheville
Asheville NC 28803
Contact Person: Vonna Cloninger Title: Phone: [phone] Ext.11
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Certification: Phone:
Inspection Date: 03/08/2011 Entry Time: 02:58 PM Exit Time: 05:30 PM
Primary Inspector: Susan A Wilson Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Wholesale Trade of Metal Waste and Scrap Stormwater
Discharge COC
Facility Status: Q Compliant ■ Not Compliant
Question Areas:
E Storm Water
(See attachment summary)
Page: 1

Permit: NCG200339 Owner - Facility: Bittmore Iron & Metal Co Inc
Inspection Date: 03/08/2011 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Araceli Bonilla (EPA Region IV) and Susan Wilson (ARO-DWO) conducted a site inspection at Biltmore Iron and Metal on
March 2, 2011. Biltmore Iron and Metal receives scrap metal and materials — the site has been in operation at the
existing location for approximately 70 years. They are also taking a very minor amount of vehicles (less than appx. 3%).
Mr. Jeff Cloninger gave a tour of the site and Ms. Vonna Cloninger spoke with us about the permit requirements.
There is a small detention basin on -site, which a portion of stormwater flow is directed. Another area drains past the
railroad spur. The detention'beisih-rarely disch— rges (ps(Mr: Cloninger); dbring very heavy rains a sample -can be
collected at the area near the railroad .spur.
Several elements of the qualitative and analytical sampling requirements were missing (although it was noted that March
2010 data had been collected; 2009 was missing; there was some data from 2008 in response to the Notice of Violation
dated February 18, 2008). There was some confusion about where to report the analytical data (see reference in Permits
and Outfalls question of this inspection report). The Stormwater Pollution Prevention Plan should be updated — and must
be updated annually, Ms. Cloninger has stated that the plan has been updated now (per phone call March 25, 2011). A
site plan should be updated noting the drainage to the detention basin and noting the drainage near the railroad spur
(where samples are collected).
The general permit for scrap metal facilities (NCG200000) was renewed and effective January 1, 2010. Another copy is
being sent to Biltmore Iron and Metal for their records (with certain areas highlighted, esp. regarding the reporting).
An inspection report from EPA Region IV is also forthcoming. DWQ is unaware of the timeline of that report.
Page: 2

Permit: NCG200339 Owner - Facility: Biltmore Iron & Metal Co Inc
Inspection Dale: 0310812011 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?
❑
■ ❑
❑
# Does the Plan include a General Location (t1SGS) map?
❑
■ ❑
❑
# Does the Plan include a "Narrative Description of Practices"?
❑
■ ❑
❑
# 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?
❑
■ ❑
❑
# 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?
❑
■ Cl
❑
# Does the facility provide and. document Employee Training?
❑
■ ❑
❑
# Does the Plan include a list of Responsible Party(s)?
❑
❑
❑
# Is the Plan reviewed and updated annually?
❑
■ ❑
❑
# Does the Plan include a Stormwater Facility Inspection Program?
❑
■ ❑
Cl
Has the Stormwater Pollution Prevention Plan been implemented?
❑
■ ❑
❑
Comment: The existing SWPPP should be updated, along with the site plan. An older
version was on -site during the inspection. Per Ms. Cloninger in follow-up conversations,
she has completed (or almost completed) updating and revising the SWPPP.
Qualitative Monitoring
Yes
No NA
NE
Has the facility conducted its Qualitative Monitoring semi-annually?
❑
a ❑
❑
Comment: Qualitative monitoring was completed once in 2010 (this requirement was
partially completed). Semi-annual qualitative monitoring is required from the stormwater
discharge outfalls.
Analytical Monitoring
Yes
No NA
NE
Has the facility conducted its Analytical monitoring?
❑
■ ❑
❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
❑
■ ❑
❑
Comment. One analytical sample was collected 3/22/2010. Semiannual analytical
sampling is required. Some required parameters were not analyzed. Some
benchmarks were exceeded (TSS, COD, cadmium, and lead).
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?
■
❑ ❑
❑
Page: 3

Permit: NCG200339 Owner - Facility: Biltmore Iron & Metal Co Inc
Inspection Date: 03/08/2011 Inspection Type: Compliance Evaluation Reason for Visit: Routine
# If the facility has representative outfall status, is it properly documented by the Division? D D ■ D
# Has the facility evaluated all illicit (non stormwater) discharges? D D D
Comment: A copy of the permit was on -site. There was some confusion regarding
when/where to report analytical data. Please refer to Part III, Section E.1. and E2.
regarding analytical reporting requirements._A,copy of -the _ general. permit -with -these --
areas high'llghted is attached with the inspection report. In addition, all monitoring shall
be retained on-site-for-5-years (ref. Part -III; Section D.6. of the permit). - -
Discharge points were observed and discussed with Mr. Cloninger while on -site. There
may be a way to reconfigure part of the area to better retain stormwater. Per Mr.
Cloninger, due to the.site layout, it is very difficult to collect a sample except during
extreme rain events (most normal event rainfall does not leave site - due to site layout
and small retention pond.
Page: 4

S rty�+
._.� r
NC®ENR
North Carolina Department of Environment and
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
April It, 2011
CERTIFIED MAIL
RETURN RECEIPT REQUESTED --
Ms. Vonna Cloninger
Biltmore Iron and Metal Co., Inc.
1 Meadow Road
Asheville, NC 28803
SUBJECT: Notice of Violation
NOV-201 I-PC-0237
Biltmore Iron and Metal
NPDES General Stormwater Permit — NCG200339
Buncombe County
Response Deadline: May 9, 2011
Dear Ms. Cloninger:
Natural Resources
Dee Freeman
Secretary
This letter is in follow-up to the NPDES Stormwater Permit Compliance Inspection conducted on
March 8, 2011. Susan Wilson, Division of Water Quality (DWQ) and Araceli Bonilla (EPA
Region IV) met with Mr. Jeff Cloninger and you at Biltmore Iron and Metal off Meadow Road in
Asheville, Buncombe County. The facility was found to be in violation of permit NCG200339-
The following storm -water permit violations were noted during the site inspection:
1. Stormwater Pollution Prevention Plan (SPPP)
The Stormwater Pollution Prevention Plan (SPPP) was not up-to-date (and had not been
updated annually). A site plan map with all stormwater discharge outfalls should also
be included, as required, with the SPPP.
2. Qualitative Monitoring
Qualitative monitoring has not been conducted and recorded in accordance with permit
requirements (see comments in inspection report).
3. Analytical Monitoring
➢ Analytical monitoring has not been conducted and recorded in accordance with permit
requirements (see comments in inspection report).
Location; 2090 U.S. Highway 70, Swannanoa, North Carolina 2a778 Phone: 828-296A5001 FAX: [phone] Customer Service: 1-877-623-6748 One Ofie `Lro lnc`l
Internet: www,ricwaterqualiiy.org NorthC,Nqtur�11w
An Equal Opportunity I Affirmative Action Employer LE

Ms. Cloninger
April 11, 2011
Page 2of2
Enclosed is a copy of the Compliance Inspection Report, which contains additional observations
and comments for your reference.
Please explain why these problems occurred and when Biltmore Iron and Metal will be in full
compliance with the stormwater permit.
Please contact..Susan.A. Wilson at_(828)_296-4665 or susan.a.wilsorigncdenr. gov.,should you have questions regarding the inspection or this letter. _
You may also wish to contact Chuck Cranford at [phone] or [e-mail] ;
he is the DWQ stormwater inspector for Buncombe County and will conduct a follow-up site visit
in the near future.
Sincerely,
Roger C. Edwards, Regional Supervisor
Surface Water Protection
Asheville Regional Office
Enclosure: Inspection Report
NCG0200000
cc: ARO File Copy (wflnspection Report)
Araceli Bonilla, EPA Region IV (w/Inspection Report)
McCray Coates, Stormwater Services, City of Asheville (wllnspection Report)
S:IS WP111aywoodlStormwatcrlNCG l2 Landf lis4laywood Co landti[RCUNOV-201 ]-PC-0235, I,andf i 11,4 201 I .doc

Z!2eeAnalytical-
March 22, 2011
Private Drinking Wate Client
Private Drinking Water Client
Client Services Dept.
Asheville, NC 28804
Pace Analytical Services, Inc.
205 Ea.% Meadow Road - Suite A
Eden, NC 27288
(3M)623.8921
RE: Project: Biltrrlore iron & Metal SW
Pace Project No.: 9289515
Dear Private Wate Client:
Pace Analytical . .sces, Inc.
2225 Riverside Dr.
AShevitle, NC 28B04
[phone]
Pace Analytical Services, Inc.
%W Kinsey Ave. 5uile 100
Huntersville, NC 28076
(704;B75.9092
Enclosed are the analytical results for sample(s) received by the laboratory on March 10, 2011. The
results relate only to the samples included in this report. Results reported herein conform to the
most current NELAC standards, where applicable, unless otherwise narrated in the body of the
report.
Analyses were performed at the Pace Analytical Services location indicated on the sample analyte
page for analysis unless otherwise footnoted.
It you have any questions concerning this report, please feel,free to contact me.
Sincerely,
. 4z-
Jane Meehan
jane.meehan @pacelabs.com
Project Manager
Enclosures
REPORT OF LABORATORY ANALYSIS.
This report shall not be reproduced, except in Full,
wilhout the written consent of Pace Analytical Services, Inc..
�tea�
�c
r1{P P,.
Page 1 of 10

Pace Analytical Services, Inc. Pace Analytical b� ..ces, lnc.
205 East Meadow Road - Suite A 2225 Riverside Dr.
c�Analytieal
Eden, NC 27288 Ashovifle, NC 28604
www.aacalabacam
[phone] [phone]
CERTIFICATIONS
Project: Biitmore Iron $ Metal SW
Pace Project No.: 9289515
Charlotte Certification IDS
9800 Kincey Ave. Ste 100, Huntersville, NO 28078
Louisiana/LEtAP Certification #: 04034
New Jersey Certification #: NC012
North Carolina Drinking Water Certification #: 37706
North Carolina Field Services Certification #: 5342
North Carolina Wastewater Certification #: 12
Pennsylvania Certification #: 68-00784
South Carolina Certification #. 990DOD01
Asheville Certification IDS
2225 Riverside Dr., Asheville, NO 28804
Connecticut Certification #: PH-0106
Florida/NELAP Certification #: E87648
Massachusetts Certification #: M•NC030
New Jersey Certification #: NC011
North Carolina Bioassay Certification #: 9
North Carolina Drinking Water Certification #; 37712
South Carolina Drinking Water Cert. #: 99006003
Virginia Certification C D0213
Connecticut Certification #: PH-0104
Plorida/NELAP Certificalion #: E87627
Kentucky UST Certification #: 84
Louisiana DHH Drinking Water # LA 100031
West Virginia Certification #: 357
North Carolina Wastewater Certification #: 40
Pennsylvania Certification #: 68-03578
South Carolina Bioassay Certification #: 99030002.
South Carolina Certification #: 99WO001
Virginia Certification #: 00072
West Virginia Certification #: 356
REPORT OF LABORATORY ANALYSIS
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersvilre, NC 2W78
[phone]
Page 2 of 10
This report shall not be reproduced, except in full,
without the written Conant of Pace Analytical Services, Inc..

Pace Analytical Servicea, Inc. Pace Analytical a_.+ices, Inc.
• 205 East Meadow Road - Suite A 2225 Riverside Dr.
ace&alyrical Eden, NC 27286 Asheville, NC 28804
paceraba
(336)623-892t [phone]
SAMPLE ANALYTE COUNT
Project: Biltmore Iron & Metal SW
Pace Project No.: 9289515
Pace Analytical Services, Inc.
9BOD Kincey Ave. Suite 1100
Hur4arsvite, NC 2a078
[phone]
Analytes
Lab ID Sample ID Method Analysis Reported
9289515001 BI&M•Outfall 001 EPA 1654A Cl-W 1
EPA 200.7 JMW 2
SM 2540D JKS 1
EPA 9040 SAJ 1
SM 5220D SDH 1
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical services, inc..
c
Laboratory
PAS!-C
PASt-A
PASI-A
PASt-A
PAST -A
Page 3 of 10

/72ceAnalyfiGal-
f
www.panNabstmr
Pace Analplical Services, Inc.
205 East Meadow (toad - Suite A
Eden, NO 27288
[phone]
Pace Analytical _ ,,ces, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
ANALYTICAL RESULTS
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersvi€le, NO 28078
[phone]
Project: Biltmore Iron & Metal SW
Pace Project No-: 9289515
Sample: 91&M-Outlalt 001 Lab ID: 9289515001 Collected: 03/09/11 15:35 Received: 03/10/11 08:54 Matrix: Water
Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual
1664 SGT-HEM, TPH
Analytical Method. EPA 1664A
Totet Petroleum Hydrocarbons
ND mgll,
6.0
1
03/21M 1 09:33
200.7 MET ICI
Analytical Method: EPA 200.7 Preparation Method:
EPA 200.7
Cadmium
2.5 ug/L
1.0
1
03/18111 16:05 03/18/11 02:37,7440-43-9
Lead
336 ug/L
5.0
1
03/18/11 16:05 =18/11 02.37 7439-92-1
2540D Totat Suspended Solids
Analytical Method: SM 2640D
Total Suspended Solids
125 mgtL
16.7
1
03/16/11 21,50
9040 pH
Anaiytical Method: EPA 9040
pH
7.1 Std. Units
0.10
1
U21/11 15:41
5220D COD
Analytical Method: SM 5220D
Chemical Oxygen Demand
298 mg/L
25.0
1
03/22/11 15:18
Date: =22/2011 03:42 PM REPORT OF LABORATORY ANALYSIS
This repvn shall not be reproduced, except in Intl,
without the written consent of Pace Analytical Services, Inc..
If
Page 4 of 10

ace Analytical"
www,ps 8bS.CM
Pace Analytical Services, Inc.
205 East Meadow Road - Suite A
Ellen, NO 27288
[phone]
Project: Billmore Iron & Metal 5W
Pace Project No.: 9289515
QC Batch: OCSV/9427
QC Batch Method: EPA 1664A
Associated Lab Samples: 9289515001
METHOD BLANK: 580135
Associated Lab Samples: 9289515001
Parameter Units
Total Petroleum Hydrocarbons Mg/L
LABORATORY CONTROL SAMPLE: 580136
Parameter Units
Total Petroleum Hydrocarbons mg/L
I
Date: 03/22Wl 1 03,42 PM
Pace Analytical—rvlces, Ine.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
QUALITY CONTROL DATA
Analysis Method: EPA 1664A
Analysis Description: 1664 SOT -HEM, TP14
Pace Analytical Services, Inc.
WKinceyAve, Suite 100
Hunlersville, NO 26078
[phone]
Matrix: Water
Stank Reporting
Result Limit Analyzed Qualifiers
ND 5.0 03/21/1109:32
Spike LCS LCS % Rec
Conc. Result % Rec Limits Qualifiers
20 16.0 80 64-132
REPORT OF LABORATORY ANALYSIS
This report shall nat be reproduced, except in full,
without the written consent c f Pace Analylical Servings. Inc--
.i�
�r
Page 5 of 10

ZCwAnalyfical"
�' ,�wN.p9terebs.cam
race Analytical Services, Inc.
205 East Meadow Road - Suite A
Eden, NC 27288
(3361623-8921
Project: Biltmore Iron & Metal SW
Pace Project No.: 9289515
Pace Analytical . ceg, Inc.
2225 Riverside Dr.
Asheville, NC 213804
[phone]
QUALITY CONTROL DATA
QC Batch: MPRP/8025 Analysis Method: EPA 200.7
QC Batch Method: EPA 200.7 Analysis Description; 200.7 MET
Associated Lab Samples: 9289515001
Pace Analytical Service$, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
METHOD BLANK: ' 878234
Matrix: Water
Associated Lab Samples: 9289515001
Blank
Reporting
Parameter
Units
Result
Limit
Analyzed Qualifiers
Cadmium
ug/L
NO 1.0
=1811101:39
Lead
ug/L
NO 5,0
03/1811101:39
LABORATORY CONTROL SAMPLE:
578235
Spike
LCS
LCS % Rec
Parameter
Units
Conc,
Result % Rae Limits Qualifiers
Cadmium
ug1L
Soo
484
97 85-115
Lead
ug/L
500
482
96 85.115
0
MATRIX SPIKE SAMPLE:
578236
9209725004
Spike
MS
MS
% Rec
Parameter
Units
Result
Conc.
Result
%Rec
Limits Qualifiers
Cadmium
ug/L
NO
500
475
95
70.130
Lead
ug/L
ND
5D0
458
92
70-130
MATRIX SPIKE SAMPLE:
576238
9289528004
Spike
MS
MS
% Roo
Parameter
units
Result
Conc.
Result
% Rea
Limits Qualifiers
Cadmium
ug/L
ND
500
501
100
70-130
Lead
ug/L
NO
500
494
99
70-130
SAMPLE DUPLICATE: 578237
9289763001 Dup
Parameter Units Result Result RPD Qualifiers
Cadmium ug/L ND NO
Lead ug& ND ND
SAMPLE DUPLICATE: 578239
9289540002 Dup
Parameter Units Result Result RPD Qualifiers
Cadmium ug/L NO ND
Lead u911, ND ND
Date: 03(22I2011 03:42 PM
REPORT OF LABORATORY ANALYSIS
This report shot! not be reproduced, except in tun,
without the written consent of Pace Analytical SaMoes, Inc..
R+t o -SRO..C.
Flinnr�S
Page Sol 10

C Analytical'
*%w.0ava40stan
race Analytical Servlces, Inc.
205 East Meadow Road - Suite A
Eden, NC 272N
[phone]
Project: Biltmore Iron & Metal SW
Pace Project No.: 9289515
Pace Analytical aces, Inc.
2225 Riverside Dr.
AShevilfe, NC 28804
[phone]
QUALITY CONTROL DATA
QC Batch: WET/15705 Analysis Method: SM 25400
QC Batch Method: SM 2540❑ Analysis Description: 25400 Total Suspended Solids
Associated Lab Samples: 9289515001
METHOD BLANK: 578273
Associated Lab Samples: 9289515001
Parameter Units
Total Suspended Solids mg/L
Matrix: Water
Blank Reporting
Result Limit Analyzed Qualifiers
NE) 2.5 03116(1121:46
Pace Analytical 5ervtces, Inc.
9800 Kincey Ave. Suite 100
HunlerswIle, NC 28078
[phone]
LABORATORY CONTROL SAMPLE 578274
Spike LCS LCS % Rec
Parameter Units Gone. Result % Rec Limits Ouaiiliers
Total Suspended Solids MA 250 264 100 80-120
SAMPLE DUPLICATE: 578275
Parameter
Total Suspended Solids
Date: 03/22/2011 03:42 PM
9289435001 Dup
Units Result Result
mgA- 14.2 14.7
RPb Qualifiers
3
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in lull,
without the written consent of Pace Analytical Services, Inc..
Page 7 of 10

Pace Analytical Services, Inc. Pace Analyticai races, Inc. Pace Analytical Services, Inc.
�e� fat �Gaf s 205 East Meadow Road - Suite A 2225 Riversice Dr. 9B00 Kincey Ave. Suite 100
Edan, NC 27288 Ashevitte, NC 26804 Huntersvitre. NC 26o7a
w+vwpaearabacam
[phone] (MI254.7176 [phone]
Project: Billmore Iron 8, Metal SW
Pace Project No.: 9289515
QC Batch: WET115759
QC Batch Method: EPA 9040
Associates! Lab Samples: 9280515001
SAMPLE DUPLICATE: 580291
Parameter Units
pH
SAMPLE DUPLICATE: 580292
Parameter
pR
Dale: 03/22/2011 03:42 PM
Std. Units
QUALITY CONTROL DATA
Analysis Method: EPA 9040
Analysis Description: 9040 pH
9289245001 Dup
Result Result RPD Qualifiers
6.9 TO 00
9289570001 Dup
Units Result Result RPD Qualifiers
Std. Units 0.3 6.2 00
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the wrilten consent of Pace Analytical Services, Inc..
_cta�e
Y`e`l7l
r:-
Page 8 of 10

/�2eAnalyfical'
�` �vecehaacwr�
race Analytical Services, Inc.
205 East Meadow Road - Suite A
Eden, NC 27288
(33f1629-8921
Project: Bittmore Iron & Metal SW
Pace Project No.: 9289515
Pace Analytical vices, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
QUALITY CONTROL DATA
QC Batch: WETA19347 Analysis Method: SM 5220D
QC Batch Method: SM 52200 Analysis Description: 5220D COD
Associated Lab Samples: 9289515001
Pace Analytical Services, rnc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
METHOD BLANK: $80690 Matrix: Water
Associated Lab Samples: 9289515001
Blank Reporting
Parameter Units Result Limit Analyzed Qualifiers
Chemical Oxygen Demand mg/L NO 25.0 03122/1 t 15:18 -
LABORATORY CONTROL SAMPLE: 580891
Spike LCS LCS % Rec
Parameter Units Conc. Result % Rec Limits Qualifiers
Chemical Oxygen Demand mg/L 750 720 97 90.110
MATRIX SPIKE SAMPLE: 580693
9289494001 Spike MS MS % Rec
Parameter Units Result Conc, Result % Rec Limits Qualifiers
Chemical Oxygen Demand mg/L ND 750 797 104 75-125
MATRIX SPIKE SAMPLE: 680695
9289494002 Spike FITS MS % Rec
Parameter Units Result Conc. Result % Rec Limits Qualifiers
Chemical Oxygen Demand mg/L 31.0 750 833 107 75-125
SAMPLE DUPLICATE: 580692
9289494001 Dup
Parameter Units Result Result RPD Qualifiers
Chemical Oxygen Demand mg/L NO ND
SAMPLE DUPLICATE: 580694
9289544002 Dup
Parameter Units Result Result RPD Qualifiers
Chemical Oxygen Demand mg/L 52.0 54.0 4
Date: 03M2/2011 03:42 PM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in lull,
without the written consent of PaCe Analytical Services, Inc -
Page 9 of 10

pace Analytical Services, Inc.
Pace Analytical , ces, ire,
Pace Analytical Services, Inc.
Analytical'
205 East Meadow Road - Suite A
2225 Riverside Or.
9800 Kncey AVG, Suite 100
_
Eden, NC 2720B
Asheville, NC 28804
1 iuntersville, NC 28078
wfvw.pacNaCi.C(NTT
(336)623-&a21
[phone]
[phone]
QUALIFIERS
Project: Bilimore Iron & Metal SW
Pace Project No.: 9289515
DEFINITIONS
OF - Dilution Factor, it reported, represents the factor applied to the reported data due to changes in sample preparation, dilution of
the sample aliquot, or rnoisture content.
NO - Not Detected at or above adjusted reporting limit.
MDL - Adjusted Method Detection Limit.
S - Surrogate
1,2-Diphenylhydrazine (8270 listed analyte) decomposes to Azobenzene.
Consistent with EPA guidelines, unrounded data are displayed and have been used to calculate % recovery and RPD values.
LCS(D) - Laboratory Control Sample (Duplicate)
MS(D) - Matnx Spike (Duplicate)
DUP - Sample Duplicate
RPD - Relative Percent Difference
NC - Not Calculable.
SG - Silica Gel - Clean -Up
U - Indicates the compound was analyzed for, but not detected.
N-Nitrosodipheny!arnine decomposes and cannot be separated from Dipheny#amine using Method 8270. The result reported for
each analyte is a combined concentration.
Pace Analytical is NELAP accredited. Contact your Pace PM for the current list of accredited analytes.
LABORATORIES
PASI-A Face Analytical Services - Asheville
PASI-C Pace Analytical Services - Charlotte
ANALY(E QUALIFIERS
Q Sample held beyond the accepted holding time.
Date: oa/22I2011 03:42 PM REPORT OF LABORATORY ANALYSIS Page 10 of 10
This report shall not be reproduced, except in full,
vAlhW the written consent of Paco Ar4ytical Services. Inc..
.eev,e
..•ilw:.

aceAnalytical
ww,rpecr/ L=M
J.
Pace Analytical Services, Inc.
205 East hlaaaDw Roan - Svita A
Aden, NO 27288
(336)6?.3.6g21
Project Biltmore Iron & Metal SW
Pace Project No.: 9289515
Lab ID Sample ID
9289515001 BI&M-Out1all001
Pate Analytical ServiCeS, Inc.
2225 Riverside Dr.
Asheville, NC 28804
($28)254.7176
SAMPLE ANALYTE COUNT
Method
EPA1664A
EPA 200.7
5M 25400
EPA 9040
SM 5220D
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in gull,
without the whtton consent of Pace Analytical Services. Inc..
.-:rYalar"�
Pace Analytical Services, Inc.
9800 Kincey Ave, Suite 100
Huntersvilia, NC 28078
[phone]
Analytes
Analysts Reported Laboratory
CLW
1
PASI-C
JMw
2
PASI-A
JKS
1
PASI-A
SAJ
1
PASI-A
SDH
1
PASI•A
Page 3 of 10

e
10
Pace Analytical Services, Inc. Pace Analytical Services, Inc.
�ceAnaVicaI4 205 East Meadow Road - Suite A 2225 Riverside Dr.
Eden, NC 27288 Asheville, NC 26804
www,pamrabsmm
! [phone] (8281254-7176
ANALYTICAL RESULTS
Project: Siltmore Iron & Metal SW
Pace Project No.: 9289515
Sample: BI&M-Outtall001
Parameters
1664 SGT-HEM, TPH
Total Petroleum Hydrocarbons
200.7 MET ICP
Cadmium
Lead
2540D Total Suspended Solids
Total Suspended Solids
9040 pH
pH
5220D COD
Chemical Oxygen Demand
Pace Analytical Services, Inc.
9800KinceyAve. Suite 100
Huntersville. NC 28078
[phone]
Lab ID: 9289515001 Collected: 03/09/11 15:35
Received: 03/10/11 08:54 Matrix: Water
Results--- _ ' Jnits
Report Limit
DF
—Piepared- -"Analyzed CAS'No.-- Quay
Analytical Method: EPA 1664A
ND mg/L
5.0
1
03/21/11 09:33
Analytical Method: EPA 200.7
Preparation Method: EPA 200.7
2.5 ug/L
1.0
1
03/16/11 16:05 03/18/11 02,37 7440-43-9
336 ug/L
5.0
1
03/16/11 16:05 03/18/11 02:37 7439-92-1
Analytical Method: SM 2540D
125 mg/L
16.7
1
03/16/11 21:50
Analytical Method: EPA 9040
7.1 Std. Units
0.10
1
03/21/11 15:41 Q
Analytical Method, SM 5220D
298 mg/L
25.0
1
03/22/11 15:18
Date: 03/22/2011 03:42 PM REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent at Pace Anatytical Services, Inc..
eeara
Page 4 of 10

0
d
aceAnalytical
wwwpacetaas.com
Pace Analytical Services, Inc.
205 East Meadow Road - suite A
Ellen, NC 27288
(336) 623.89P I
Project: Biltrnore iron & Metal SW
Pace Project No_: 9289515
CC Batch: GCSW9427
QC: Batch Method: EPA 1664A
Associated Lab Samples: 9289515001
METHOD BLANK: 580135
Associated Lab Samples: 92895150DI
Parameter Units
Total Petroleum Hydrocarbons mg/L
LABORATORY CONTROL SAMPLE: 560136
Parameter Units
Total Petroleum Hydrocarbons rng/L
Date; 03/22/2011 03:42 PM
Pace Analytical Services, rric.
2225 Riversido Dr.
Ashevilie, NC 28804
[phone]
QUALITY CONTROL DATA
Analysis Method: EPA 1664A
Analysis Description: 1664 5GT-HEM, TPH
Matrix: Water
Blank Reporting
Result Limit Analyzed Qualifiers
ND 5.0 03/21/11 09:32
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Hunlersville, NC 28078
[phone]
Spike LCS LCS % Rec
Conc. Result % Rec Limits Qualdiers
20 16.0 80 64-132
REPORT OF LABORATORY ANALYSIS
This report shalt not be reprpduCed, except in lull,
without the written consent of Pace Analytical Services, Inc,.
Page 5 of 10

0
Pace Analytical Services: Inc. Pace Analytical Services, Inc.
2ceAnalytieal • 205 East Meadow goad - Suite A 2225 Riverside Or.
Eden, NC 27288 Asheville, NC 28804
www.pacwa6icarli
� [phone] [phone]
QUALITY CONTROL DATA
Project: Biftmoro Iron & Metal SW
Pace Project No.: 9289515
Pace Analytical Services, Inc_
9800 Kincey Ave. Sui[a 100
Huntersviile, NC 28078
[phone]
QC Batch: MPRP/8025
Analysis Method;
EPA 2001
QC Batch Method:-EPA7200.7 -
^"'—Analysis-Descriptldn:
—200:7 MET
Associated Lab Samples: 9289515001
METHOD BLANK: 578234
Matrix: Water
Associated Lab Samples: 9289515001
Blank Reporting
Parameter
Units
Result Limit
Analyzed Qualifiers
Cadmium
ug/L
ND
1,0 03118/1101:39
Lead
ug/L
ND
&0 03/18/1101:39
LABORATORY CONTROL SAMPLE:
578235
Spike LCS
LCS % Rec
Parameter
Units
Conc. Result
% Ree Limits Qualifiers
Cadmium
ug/L
500 484
97 65-115
Lead
ug/L
500 482
96 85-115
MATRIX SPIKE SAMPLE:
578236
9289725004
Spike
MS
MS
% Rec
Parameter
Units
Result
Conc.
Result
%Rec
Limits Qualifiers
Cadmium
ug/L
ND
500
475
95
70A30
Lead
ug/L
NO
500
458
92
70430
MATRIX SPIKE SAMPLE:
578236
9289528004
Spike
MS
MS
% Rec
Parameter
Units
Result
Conc.
Result
% Rec
Limits Quatifiers
Cadmium
ug/L
ND
500
501
100
70-130
Lead
ug/L
ND
500
494
99
70-130
SAMPLE DUPLICATE: 578237
9289763001
Dup
Parameter
Units
Result
Result
RPD
Qualifiers
Cadmium
ug/L
ND
ND
Lead
ug/L
ND
ND
SAMPLE DUPLICATE: 578239 -
9289540002
Dup
Parameter
Units
Result
Result
RPD
Qualifiers
Cadmium
ug/L
ND
ND
Lead
ug/L
ND
ND
Date: 03/22/2011 03:42 PM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in kdl,
without the written consent of Paco Analytical Services, Inc..
«e�
tea`! t r
Page 6 of 10

aceAoalytical
_, wwwpacale0&cam
i
Pace Analytical Services, Inc.
205 East Meadow Road - Suite A
Edon, NC 27288
(336)623-B921
Project: Biltmore Iron & Metal SW
Pace Project No.: 9289515
QC Balch: WET/15705
QC Batch Method: SM 25400
Associated Lab Samples: 9289515001
METHOD BLANK: 578273
Associated Lab Samples: 9289515001
Parameter Units
Total Suspended Solids mg/L
LABORATORY CONTROL SAMPLE: 578274
Parameter Units
Total Suspended Solids mg/L
SAMPLE DUPLICATE: 570275
Parameter Units
Total Suspended Solids mg/L
Date: 03/22/2011 03A2 PM
Pate Analytical Services, Inc.
2225 Fiverside Dr.
Asheville, NC 28804
[phone]
QUALITY CONTROL DATA
Analysis Method: SM 2540D
Analysis Description; 25400 Total Suspended Solids
Matrix: Water
Blank Reporting
Result limit Analyzed Qualifiers
ND 2.5 03/16111 21:46
Pace Analytical Services, Inc.
WW Kinsey Ave. state 100
Hunlersville, NC 28078
[phone]
Spike LGS LCS % Rec
Conc. Result %Rec Limits Qualifiers
250 264 106 80-120
9289435001 Dup
Result Result RPD Qualifiers
14.2 14.7 3
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the writlen consent of Pace Analytical Services, Inc..
Page 7 of 10

I
Pace Analytical Services, Inc. Pace Anaiylicaf Services, Inc.
* 205 East Meadow Road - Suite A 2225 Riverside Dr.
,1!aceAnalytical Eden, NC 27288 Asheville, NC 28804
� www.pacde6scom
1 (33ti)fi23 892t [phone]
QUALITY CONTROL DATA
Project: Biltmore Iron & Metal SW
Pace Project No.: 9289515
QC Batch: WET/15759 Analysis Method: EPA 9040
QC Batch Method:-- - EPA 9040 '" "" '"""" Analysis Description: 9040 pH -
Associated Lab Samples: 9289515001
SAMPLE DUPLICATE: 580291
9289245001 Dup
.Parameter Units Result Result APO Qualifiers
PH Std. Units 6.9 7.0 00
SAMPLE DUPLICATE: 580292
Parameter
pH
Date: 03/22/2011 03:42 PM
9289570001 Dup
Units Result Result
Std- Units 6.3 6.2
RPD Qualifiers
00
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in fu:l,
without the wrilten consent of Pace Analytical Services, tnc..
Pace Analytical Services, Inc.
9800 Kincey Ave, Suite roc
Hunlersville, NC 28078
[phone]
Page 8 of 10

aceAnalytical'
wv+N.pecvmos.mrn
r
Pace Analytical Services, Inc.
205 East MeaOaw Road - Suite A
Eden, NC 27288
[phone]
Project: Billmore iron & Metal SW
Pace Project No.: 9289515
QC Batch: W ETA/9347
QC Batch Method: SM 52200
Associated Lab Samples: 9289515001
METHOD BLANK: 580690
Associated Lab Samples: 9289515001
Parameter
Units
Chemical Oxygen Demand
mg/L
LABORATORY CONTROL SAMPLE:
580691
Parameter
Units
Chemical Oxygen Demand
mg/L
MATRIX SPIKE SAMPLE;
580693
Parameter
Units
Chemical Oxygen Demand
mg/L
MATRIX SPIKE SAMPLE:
680695
Parameter
Units
Chemical Oxygen Demand
mg/L
SAMPLE DUPLICATE: 580692
Parameter
Units
Chemical Oxygen Demand
mg/L
SAMPLE DUPLICATE: 580694
Parameter
Chemical Oxygen Demand
Date' 03/22/2011 03:42 PM
Pace Analytical Service8, Inc.
2225 Riverside Or.
Asheville, NC 28604
[phone]
QUALITY CONTROL DATA
Analysis Method: SM 5220D
Analysis Description; 52200 COD
Matrix: Water
Blank Reporting
Result Limit Analyzed Qualifiers
ND 25.0 03/22/1115:18
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
Spike LCS LCS % Rec
Conc. Result % Rec Limits Qualifiers
750 726 97 90-110
9289494001 Spike MS Ms % Rec
Result Conc. Result % Rec Limits Qualifiers
ND 750 797 104 75-125
9289494002 Spike MS MS %Rec
Result Conc. Result % Rec Limits Qualifiers
31.0 750 833 107 75-125
9289494001 Dup
Result Result RPD Qualifiers
ND ND
9289544002 Dup
Units Result Result RPD Qualifiers
mg/L 52.0 54.0 4
REPORT OF LABORATORY ANALYSIS
Thls report shall not be reproduced, except in lull,
without the written consent of Pace Analytical Services, Inc..
Page 9 of 10

Pace Analytical Services, Inc.
Pace Analytical Services, Inc.
Pace Analytical Services, Inc.
aceAnalytical a
205 East Meadow Road - Suite A
2225 Riverside Dr.
9800 Kincey Ave. Suite 100
Eden, NC 27288
Asheville, NC 28804
Huntersvdle, NC 28078
w ..pecdebsxom
i
[phone]
[phone]
[phone]
QUALIFIERS
Project: Biltmore Iron & Metal SW
Pace Project No.: 9289515
DEFINITIONS
DF - Dilution Factor, if reported, represents the factor applied to the reported data due to changes in sample preparation, dilution of
the sample aliquot, -or moisture content. - -
NO - Not Detected at or above adjusted reporting limit.
MDL - Adjusted Method Detection Limit.
S - Surrogate
1,2-Diphenylhydrazine (8270listed analyte) decomposes to Azobenzene.
Consistent with EPA guidefnes, unrounded data are displayed and have been used to calculate % recovery and RPD values.
LCS(D) - Laboratory Control Sample (Duplicate)
MS(D) - Matrix Spike (Dupticato)
DUP - Sample Duplicate
RPD - Relative Percent Difference
NC - Not Calculable.
SG - Silica Gel - Clean -Up
U - Indicates the compound was analyzed for, but not detected.
N-Nitrosodiphenylamine decomposes and cannot be separated from Diphenylamine using Method 8270. The result reported for
each analyte is a combined concentration.
Pace Analytical is NELAP accredited. Contact your Pace PM for the current list of accredited analytes.
LABORATORIES
PASI-A Pace.Analytical Services - Asheville
PAST-C Pace Analytical Services - Charlotte
ANALYTE QUALIFIERS
Q Sample held beyond the accepted holding time.
Date: 03/22/2011 03:42 PM REPORT OF LABORATORY ANALYSIS Page 10 of 10
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
`r�`r

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CHAIN -OF -CUSTODY 1 Analytical Request Document
The Chaert�of-Q*tpdy is a LEGAL DOCUMENT. A!I reEevant fields must be completed accurately.
Sactlon A Section B Section C
Page. of
Required Client Information: Required Project tnformaton: Invoice Information:
Report To: Atlentia :
r yrnr)fp.
1410008
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Company Name:
REGULATORY AGENCY
F NPDES f GROUND WATER i DRINKING WATER
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Order No.:
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ADDITIONAL COMMENTS
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IV
ORIGINAL SAMPLER NAME AND SIGNATURE
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SIGNATURE or SAMPLER Slphed
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'ImVWant Nate: By s9rdN this form you we amepLng Pace's N£T 30 day paymml lama and evmnv to 1816 merges or 1.5% per nMeAn fir t w . Mn 30 days. F-ALL-Q-020rev.07. T SMay-2007

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Analytical
)acelabs,com
Sold -To: —
Private Drinking Wate Client_
Private Drinking Water Client
Client Services Dept.
Asheville. NC 28804
INVOICE
/ Pace Analytical Services, Inc.
I V y 9800 Kincoy Ave., Suite 100
Huntersville, NC 28079
Phone: [phone]
Invoice Number: 119283461
Date: 03/28/2011
Total Amount Due: $150.00
- - -Please-Remit To - ---
Pace -Anal Ocal Services, Inc.
P.D. Box 684056
Milwaukee, WI 53268-4056
�(�T. �.y11 mow + ''•'. i P,l{
93-703954193-Private W, 'AV, Jane Meehan
f
V„G," ".1— YIIL,I IV,o II VII - IYI{ilU, V , . a.! 11 11G1— --Olt; LP1111%111C1VVdLUl %jKV1 IL
Pace Project No: 9289515 Sample Received: 3110/2011
Report Sent To: Private Drinking Wate Client, Private Drinking Water Client
Comments:
Quantity Unit
Description
ANALYTICAL CHARGES
Method
Matrix _ _
Price
Total
i Ea
1664 SGT-HEM, TPH
EPA 1664A
Water
$40.00
$40.00
1 Ea
200.7 ICP Metals
EPA 200.7
Water
$20.00
$20.00
1 Ea
254017 Total Suspended Solids
SM 2540D
Water
$20.00
$20.00
1 Ea
5220D COD
SM 5220D
Water
$25.00
$25.00
1 Ea
9040 pH
EPA 9040
Water
$5.00
$5-00
1 Ea
Client Services Charge
Miscellaneous Charges
Water
$40.00
$40.00
Analytical Subtotal $150.00
Total Number of Charges 8 Total Invoice Amount $150.00
Samples Received for analysis:
Lab ID Client Sample ID Received
9289515MI BIBM-outfall001 3/i0/20118:54:00
if you have any questions or to pay by credit card, please contact Jane Meehan at Pace.
Phone: [phone] Emailrjana.meehan®pacelabs.com
Page 1 of 1
**1 5% MONTHLY FINANCE CHARGE ASSESSED AFTER 30 DAYS OR TERMS OF CONTRACT.
PLEASE REFERENCE THE INVOICE NUMBER ON ALL REMITTANCE ADVICE.
AN EQUAL OPPOATUWY EMPLOYER
Please complete and return copy of invoice with your payment.
INVOICE TOTAL. $150.00
Amount Paid: $
Check No:
Customer No: 93-703954 Invoice No; 119283491

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Permittee (facility) Name and Address: I hAo r. A A\e! PA. Pr,,Wvt 11 C• + m r, -QRio3
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During the Compliance S[ormwater Evaluation Inspection (CSWEI) conducted on M2— / �� I ! the
following observation(s) were noted.
SITE OBSERVATION(s) f
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Requested : t ctlon: Please describe in writing any actions taken or planned to correct the items identified above- Your response
will he considered in the determination of the need for further enforcement action. This is not a Normal inspection report
nor f(irrnal Nmice of ViOlation letter. A formal CSWET report will be sent to your facility by U.S.EPA.
Mail your written response to: term ce, t 1 '60V l 0,
U.S. Environmental Protection ,agency i EPA)
Rerion 4, Water Protection Division
Clean Water Enforcement Branch
hl Forsyth Street. SW
Atlanta- Georgia 30303
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are Analytical
wwwpaCelab&C=
j
February 25, 2008
FEB 2 9
WATER QUALITY SECTION
ASHEVILLi= P1=( JnrJAL n=—
Biltmore Iron & Metal
PO Box 5616
Asheville, NC 28813
RE: Project: Bilt. Iron & Metal
Pace Project No.: 9213765
Pace Analytic?' Aces, Inc.
22. _rside Dr.
Asheville, NC 28804
[phone]
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
ltuntersville, NC 28078
[phone]
Dear Private Wate Client:
Enclosed are the analytical results for sample(s) received by the laboratory on February 18, 2008.
The results relate only to the samples included in this report. Results reported herein conform to the
most current NELAC standards, where applicable, unless otherwise narrated in the body of the
report.
Inorganic Wet Chemistry and Metals analyses were performed at our Pace Asheville laboratory and
Organic testing was performed at our Pace Huntersville laboratory unless otherwise footnoted. All
Microbiological analyses were performed at the laboratory where the samples were received.
If you have any questions concerning this report, please feel free to contact me,
Sincerely,
Jane Meehan
[e-mail]
Project Manager
Enclosures
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Page 1 of 7

s
ace Analytical
www.paCWabs WM
Project: Silt. Iron & Metal
Pace Project No.: 9213765
Pace Analytic*' •1cos, Inc. Paco Analytical Services, Inc.
22. aside Dr. 9800 Kincey Ave. Suite 100
Asheville, NC 28804 . HuntersvUle, NC 28078
[phone] [phone]
CERTIFICATIONS D
i FEB 2 9 20d8
WATER QUF,Lii Y 5ct,i SUN
Charlotte Certification IDs A�;Hrv' i_E
FloridalNELAP Certification Number E87627 North Carolina Field Services Certification'Nuniber: 5342 '—
Kansas Certification Number: E-10364 South Carolina Certification Number 990060001
t_ouisianalLELAP Certification Number: 04034 South Carolina Bioassay Certification Number. 990060003
North Carolina Drinking Water Certification Number: 37706 Tennessee Certification Number: 04010
North Carolina Wastewater Certification Number: 12 Virginia Certification Number: 00213
Asheville Certification IDs
Florida/NELAP Certification Number: E87648 Pennsylvania Certification Number: 68-03578
Louisiana/LEtAP Certification Number: 03095 South Carolina Certification Number: 99030001
New Jersey Certification Number: NCO11 South Carolina Bioassay Certification Number: 99030002
North Carolina Drinking Water Certification Number: 37712 Tennessee Certification Number: 2980
North Carolina Wastewater Certification Number: 40 Virginia Certification Number: 00072
North Carolina Bioassay Certification Number: 9
Eden Certification IDs
North Carolina Drinking Water Certification Number: 37738 North Carolina Wastewater Certification Number: 633
Virginia Drinking Water Certification Number: 00424
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written Consent of Pace Analytical Services, Inc..
o Leto...
(n6hC}
Page 2 of 7

Pace Analytic: -ices, Inc. Pace Analytical Services, Inc.
aceAnalytical w 22 arside Dr. 9800 Kincey Ave. Suite 100
Asheville, NC 28804 Huntersville, NC 28078
www.pacelabsx"
[phone] [phone]
ANALYTICAL RESULTS
Project: Bilt. Iron & Metal
Pace Project No.: 9213765
Sample: OUTFALL 001
Lab Ib: 9213765001 Collected: 02118/08 08:05
Received: 02118108 13:00 Matrix: Water
Parameters
Results Units
Report Limit
DF
Prepared Analyzed CAS No. Qual
200.7 MET ICP
Analytical Method: EPA 200.7
Preparation Method: EPA 200.7
Cadmium
1.6 ug/L
1.0
1
02119/08 11:19 0212010815:45 7440-43-9
Lead
78.8 uglL
5.0
1
02/19/08 11:19 02/20/08 15:45 7439-92-1
2540D Total Suspended Solids
Analytical Method: SM 25400
Total Suspended Solids
16.3 mg/L
3.3
1
02119/08 14:34
5220D COD
Analytical Method: SM 5220D
Chemical Oxygen Demand
89.0 mg/L
25.0
1
02/19/08 21:27
Date: 02/25/2008 04:14 PM
REPORT OF LABORATORY ANALYSIS
This report shalt not he reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
.«o
Ahielk:
Page 3 of 7

aceAnalytieal.
• .pecekbs.cw»
Project: Bilt. Iron & Metal
Pace Project No.: 9213765
Pace Analytic' vices. Inc.
22 arside Dr.
Ashevwe, NC 28804
[phone]
QUALITY CONTROL DATA
QC Batch: MPRP/1893
Analysis Method:
EPA 200.7
QC Batch Method: EPA 200.7
Analysis Description:
2001 MET
Associated Lab Samples: 9213765001
METHOD BLANK: 78452
Associated Lab Samples: 9213765001
Blank Reporting
Parameter
Units
Result Limit
Qualifiers
Cadmium
uglL
ND 1.0
Lead
ug/L
ND 5.0
LABORATORY CONTROL SAMPLE:
78453
Spike LCS
LCS
Parameter
Units
Conc. Result
% Rec
Cadmium
uglL
500 519
104
Lead
ug/L
500 520
104
MATRIX SPIKE SAMPLE:
78454
9213664001 Spike
MS
Parameter
Units
Result Conc.
Result
Cadmium
ug/L
ND 500
50'
Lead
ug/L
ND 500
49,
SAMPLE DUPLICATE: 78455
9213668001 Dup
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
% Rec
Limits Qualifiers
85-115
85-115
MS % Rec
% Rec Limits Qualifiers
100 70-130
99 70-130
Parameter Units Result Result RPD Qualifiers
Cadmium uglL ND ND 8
Lead uglL ND ND 0
Date: 02/25/2008 04:14 PM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
• ea.
f eiac}=
Page 4 of 7

aceAnalytical"
' w�wpecsrebs.cam
Project: Bill. Iron & Metal
Pace Project No.: 9213765
QC Batch: WET13127
QC Batch Method: SM 25400
Associated Lab Samples: 9213765001
METHOD BLANK: 78610
Associated Lab Samples: 9213765001
Parameter Units
Total Suspended Solids mg/L
Pace Analytic. aces, Inc.
22. erside Dr.
Asheville, NC 28804
[phone]
QUALITY CONTROL DATA
Analysis Method: SM 2540D
Analysis Description: 2540D Total Suspended Solids
Blank Reporting
Result Limit Qualifiers
ND 1.0
Pace Analytical Services, Inc.
9800 Yancey Ave. Suite 100
Huntersville, NC 28078
[phone]
LABORATORY CONTROL SAMPLE: 78611
Spike LCS LCS % Rec
Parameter Units Conc. Result % Rec Limits Qualifiers
Total Suspended Solids mglL 250 274 110 80-120
SAMPLE DUPLICATE: 78612
Parameter
Total Suspended Solids
Date: 02125/2008 0414 PM
9213414005 Dup
Units Result Result
mglL ND ND
RPD Qualifiers
25
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Page 5 of 7

ace Analytical
*WWPacetsea.eom
Project: Bilt. Iron & Metal
Pace Project No.: 9213765
Pace Analytic, ices, Inc.
22 'Hide dr.
Asheville. NC 28804
[phone]
QUALITY CONTROL DATA
QC Batch: WETA/2138 Analysis Method: SM 5220D
QC Batch Method: SM 5220D Analysis Description: 5220D COD
Associated Lab Samples: 9213765001
METHOD BLANK: 78994
Associated Lab Samples: 9213765001
Parameter
Units
Chemical Oxygen Demand
mg/L
LABORATORY CONTROL SAMPLE:
78995
Parameter
Units
Chemical Oxygen Demand
mglL
MATRIX SPIKE SAMPLE:
78996
Parameter
Units
Chemical Oxygen Demand
mglL
SAMPLE DUPLICATE: 78997
Parameter
Chemical Oxygen Demand
Date: 02125/2008 04:14 PM
Blank Reporting
Result Limit Qualifiers
ND 25.0
Pace Analytical Services, Inc.
98M Kincey Ave- Suite 100
Huntersville, NC 28078
[phone]
Spike LCS LCS % Rec
Conc. Result % Rec Limits Qualifiers
750 762 102 90-110
9213181002 Spike MS MS % Rec
Result Conc. Result % Rec Limits Qualifiers
109 750 885 103 75-125
9213615001 Dup
Units Result Result
mg/L 1050 1050
RPD Qualifiers
0
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
aC
Page 6 of 7
S

Pace AnalyticF ices, Inc. race Analytical Services, Inc.
° 22, erside Dr. 9800 Kincey Ave. Suite 100
aCeAnalytical Asheville, NC 28804 Nuniersville, NC 28078
• wwwpacefabs.com
[phone] [phone]
QUALIFIERS
Project: Bilt. Iron & Metal
Pace Project No.: 9213765
DEFINITIONS
DF - Dilution Factor, if reported, represents the factor applied to the reported data due to changes in sample preparation, dilution of
the sample aliquot, or moisture content.
ND - Not Detected at or above adjusted reporting limit.
J - Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit.
MDL - Adjusted Method Detection Limit.
S - Surrogate
1,2-Diphenylhydrazine (8270 listed analyte) decomposes to Azobenzene.
Consistent with EPA guidelines, unrounded data are displayed and have been used to calculate % recovery and RPD values_
LCS(D) - Laboratory Control Sample (Duplicate)
MS(D) - Matrix Spike (Duplicate)
DUP - Sample Duplicate
RPD - Relative Percent Difference
NC - Not Calculable.
Pace Analytical is NELAP accredited. Contact your Pace PM for the current list of accredited analytes.
Date: 02/25/2008 04:14 PM REPORT OF LABORATORY ANALYSIS Page 7 of 7
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..

2aceAnal>�/%ical-
J`
CHAIN-OF-CUSTODY I Analytical Request Document
The Chain -of -Custody is a LEGAL DOCUMENT. All relevant fields must be completed accurately.
Page: of
Section A Section B Section C
Required Client Information: Required Project Information: Invoice Information:
a Report To: Attention:
Company:
1161697.
Itmore Iron & Metal Vnnna Gloninger Tammy Ray
Add,et Copy
0 Box 5616
To:
Company Name:
REGULATORY'AGENCY
Asheville,NC 28813
Address:
F NPIDES F GROUND WATER DRINKING WATER
F UST F RCRA F OTHER
Email To:
[e-mail] Purchase
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Pam Quote
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Phone: " Project
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Name:
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'Important Note: By signing this famn you are accepting Pace's NET 30 day payment terms and agreeing to late charges of 1.5% per month Wan+nwnms not paid mllhAa&�ays. F-ALL-Q-020rev.07, 15-May-2007

7902 0460 00011,E 9899 6784
y;
North Carolina
* r Environment and Natt
Division of
Surface Water Prot,
i ,=NR 2090 U.S. Highway 70. Swannanc
t
v T _ VONNA CLONINGER
BILTMORE IRON B"METAL CO INC i
POST OFFICE BOX 5616
ASHEVILL'E NC 28813
x�

UNITED STATES POSTAL L SERVICE
a.a..lx...U5P,5u.JJ
of�
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North Depar_tme- r
'tur4'Rigsou Environment affig fia rce
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2090 U.S. HighWt- O'�",,n,, Ma77B
NCDENR C
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STARR SILVIS,\\
NCDENR-DWQ��W
2090 U.S. HIGHWAY
SWANNANOA NC 28 78
G-10

e Complete items 1, 2, and 3. Also complete A. gnature
item 4 if Restricted Delivery is desired. X ❑ Agent
■ Print your name and address on the reverse 0 Addressee
so that we can return the card to you. B. Received by (Print ame) .Date of Delivery
■ Attach this card to_the-tothe _
AFF, _ _ North Carolina Department of •M ditf Yes
Environment and Natural Resources
Division of Water Quality'l�ery a7041�1�
�� �'lQ
NCD�NR Surfaceer Protection Section2090 U.S. Highway 7 vpnnanoa. NC 28778 w
LO
VONNA CLONINGER
BILTMORE IRON &METAL CO INC' Type
Certified Mail ❑ Express Malt -
POST OFFICE BOX 5616 %13 Registered Return Receipt for a tgndlse
ASHEVILLE NC 28813 i3 Insured Mail �c.o.D.
Ti. Restricted Delivery? (Ex" roe) ❑ Y
7002 0460 0001 9899 6784 woo Z0v6! D// Cp
�S Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 ;

CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Vonna Cloninger
Biltmore Iron & Metal Co Inc
PO Box 5616
Asheville NC 28813
Dear Mrs. Cloninger:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
FI A �P C 0 Pf h Carolina Department of Environnnent and Natural Resources
I( �l L� Coleen H. Sullins, Director
Division of Water Quality
Asheville Regional Office
February 18, 2008
7002 0460 0001 9899 6784
Subject: NOTICE OF VIOLATION
NOV-2008-PC-0116
Compliance Evaluation Inspection
Biltmore iron & Metal Co Inc
Permit No. NCG200339
Buncombe County
Enclosed please find a copy of the Inspection Report from the inspection conducted by Starr Silvis and
Chuck Cranford on February 1, 2008. The facility was found to be in violation of Permit NCG200339 for the
following:
• The facility's Stormwater Pollution Prevention Plan was last updated in 2002. The information in the
Plan does not reflect current site conditions.
• No.monitoring has been done at the site.
Please refer to the enclosed -Inspection Report for any additional observation and comments.
To prevent further action, carefully review these violations and deficiencies and respond in writing to
this office within fifteen (15) working day of receipt of this letter. Please provide a timeline for bringing the
facility into compliance with permit conditions. If you should have any questions, please do not hesitate to
contact Starr Silvis at [phone].
Sincerely,
Roger C. Edwards, Regional Supervisor
Surface Water Protection
Attachment
cc: ARO
Central Files
John Hennessy, NPS-ACO
North Carolina Division of Water Quality 2090 US. Highway 70 Swannanoa, N.C. 28778 Phone[phone]
Internet: www.ncwaterguality-org FAX [phone]
NorthCaroHna
� lahirally
Customer Service
1-8771623-6748

Compliance Inspection Report
Permit: NCG200339 Effective: 10/03/06 Expiration: 09/30/08 Owner: Biltmore Iron & Metal Co Inc
SOC: Effective: Expiration: Facility: Biltmore Iron & Metal Co Inc
County: Buncombe 1 Meadow Rd
Region: Asheville
Asheville NC 28803
Contact Person: Vonna Cloninger Title: Phone: [phone] Ext.11
Directions to Facility:
System Classifications:
Primary ARC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Certification: Phone:
Inspection Date: 02/01/2008 Entry Time: 11:30 AM Exit Time: 01:09 PM
Primary Inspector: Starr Silvis Phone: [phone]
Secondary Inspector(s):
Chuck -Cranford Phone: -
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Wholesale Trade of Metal Waste and Scrap Stormwater
Facility Status: I) Compliantarge C �3 Compliant
Question Areas:
® Storm Water
(See attachment summary)
Page: 1

Permit: NCG200339 Owner - Facility: Biltmore Iron & Metal Co Inc
Inspection Date: 02/01/2008 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Vonna Cloniger was very helpful during the inspection. We went over the current Stormwater Pollution Prevention Plan
(the Plan) in relation to permit conditions, Mrs. Cloninger is currently working on updating the Plan to reflect current
conditions at the facility. She is also going to conduct required monitoring.
_The inspectors walked.the site.and_observed,the_outfall.from_the_small.pond_on the site. The.pond was discharging
response to a rainfall/sleet event earlier in the day. No obvious water quality issues were noted in the discharge. A creek
runs under the property from the Mission Hospital Area. The outfall tlischarges into the creek. It was noted that the
discharge was less visibly polluted than the receiving creek.
The facility will notify the inspectors once the Plan has been updated and the facility will then be reinspected.
Page: 2

Permit: NCG200339 Owner - Facility: Biltmore Iron & Metal Co Inc
Inspection date: 02101/2008 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?
®
0
n
# Does the Plan include a General Location (USGS) map?
n
n
n
# Does the Plan include a "Narrative Description of Practices"?
n
n
n
# Does the Plan include a detailed site map including outfall locations and drainage areas?
®
❑
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
n
# Does the facility provide all necessary secondary containment?
n
n
n
# Does the Plan include a BMP summary?
n
®
n
❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
n
n
n
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
n
n
n
# Does the facility provide and document Employee Training?
n
n
n
# Does the Plan include a list of Responsible Party(s)?
®
n
n
n
# Is the Plan reviewed and updated annually?
n
e
n
n
# Does the Plan include a Stormwater facility Inspection Program?
n
®
n
n
Has the Stormwater Pollution Prevention Plan been implemented?
❑
m
n
❑
Comment: The facility has a SWPPP, however the Plan has not been updated since
2002. The maps and information in the Plan need to be updat ed to reflect current
conditions in accordance with permit conditions.
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ❑ ■ ❑ ❑
Comment: Monitoring is not being done currently.
Analytical Monitoring
Yes
No
NA
NE
Has the facility conducted its Analytical monitoring?
n
■
n
n
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
n
n
®
n
Comment: The facility is not currently doing monitoring. The facility does not have
Vehicle Maintenance as defined in the permit.
Permit and Outfalls
Yes
No
NA
NE
# Is a copy of the Permit and the Certificate of Coverage available at the site?
®
n
n
n
# Were all outfalls observed during the inspection?
M
n
n
n
# If the facility has representative outfall status, is it properly documented by the Division?
n
n
M
n
# Has the facility evaluated all illicit (non Stormwater) discharges?
n
W
n
EI
Page: 3

Permit: NCG200339 Owner - Facility: 6iltmore Iron & Metal Co Inc
Inspection Date: 02/01/2008 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Comment: All outfalls and discharges need to be identified and documented during the
Plan update.
Page: 4

Biltmore Iron & Metal Co., Inc.
Ferrous and Non -Ferrous Metals
Plant Location - 1 Meadow Road
February 12, 2008
Starr Silvis
NCDEHNR
Water Quality Division -Asheville Region
2090 US Hwy.70
Swannanoa, NC 28778
Starr,
Post Office Box 5616
Asheville,'NC 28813-5616
Phone [phone]
Facsimile [phone]
[e-mail]
SCE
FEB 15 2008 �
F
WATER QUALITY SECTION '
ASHEV1LLc RFC.IONIAL CFrICE
I picked up a testing kit from Pace Analytical last week — we've had no rain,
or at least enough to have any flow from our outfall. I'll send the report as
soon as available. Let me know if this is everything') need to update my
SWPP file. Take care.
ReIFnall.
,
Cloninger
Attached forms are as.follows:
(1) 'Non -Storm Water Discharge Certification
(2) Pollution � Prevention Team update sheet
(3) Semi -Annual Storm Water Inspection Forms
(4) SWPP Training Form
(5) Inspection certification signature form
EN

a
'
I
I
f
I
A
I
I
'
I

NON -STORM WATER DISCHARGE CERTIFICATION L i, FEB 1 5 2008 _ J
Biltmore Iron & Metal Co., Inc. i
Asheville, North Carolina WATER Qu1.._1T SECTION
L :A'_ C: �- fCE
The following evaluation is provided as demonstration that the facility does not have unpermitted non -
storm water discharges: `
There are no floor drains inside the facility buildings that are connected to the
storm water system.
Residual fluids are collected and properly disposed.
3.. The facility has no equipment or truck cleaning operations with outside discharges.
4. All sanitary discharges are to the municipal sanitary sewer system.
This evaluation is based on the personal knowledge of facility personnel, No other
evaluative approaches wete utilized or deemed necessary.
I 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 gather and evaluate 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, accurate and complete. I am aware that there are significant penalties for
submitting f lse information, including the possibility of tine and imprisonment for
[crowing viol�tions. r /I
iIAi I,I I A� (0//I� a1 WID�
onna Clonii gery- CEO 1) Date

Biltmore Iron and Metal Co., .-5WP3-Asheville, North Carolii
February 4, 2008
2.0 FACILITY INFORMATION
2.1 GENERAL INFORMATION
No Changes
2.2 POLLUTION PREVENTION TEAM - note changes
Name and Position Phone Number
Ms. Vonna Cloninger, CEO [phone]
Responsibility
Commitment of corporate resources to
implement the Plan
Mr. Mike Cloninger, COO same Overall implementation
Implementing containment and cleanup
Mr. Jeff Cloninger, President same Notifications
Compliance during containment and cleanup
Comprehensive site compliance audits
Training of facility personnel
Inspections
Maintenance
Corrective measures

SEW -ANNUAL STORM WATER INSPECTION FORM
Biltmore Iron & Metal Co., Inc.
Asheville, North Carolina
(Inspection must be performed once in the pall (September -November) and once in the Spring (April -June))
Date: 2/4/0$ Time: 9:30 am inspected By: Jeff_Cloninger
Entrance/Office:
Item
Condition
Action to be Taken
Date
Cornleted
Cotments
Irrt ro er Materials
none
Evidence of
Spills/Leaks
none
Debris or Residue
none
Drop Inlets
nQT1Q
Pollutants in S.W.
none
Metal Room:
Item
Condition
Action to be Taken
Date
Completed
Comments
Im ro er Materials
none
Evidence of
Spills/Leaks
none
Two 275-gallon fuel
oil ASTs and
containment
removed
Lo shop area
Debris or Residue
none
Drop Inlets
none
Pollutants in S.W.
none

Date: 2 / 4 / 08 Time: 9 : 30 am Inspected By: Taff CjnnjngPr
Aluminum Non -Ferrous Warehouse:
Item
Condition
Action to be Taken
Date
Corn leted
Comments
Improper Materials
none
Evidence of
S illsfLeaks
none
Shear Equipment
moved to
outside of buil.di
g-no sp ills/leaks
Baler Equipment
goo
none
550-gallon diesel
ASTand
containment
moved to
outside of building
-no spills/leaks
100-gallon reservoir
for shear
removed
completely
75-gallon reservoir
(for baler
changed
to 200 gallon - good
Condit
on no action
55-gallon drum of
near motor oil
moved to
shop
55-gallondrum of
r
hydraulic dl
changed
to 275 above groan
tank -
ood condition -no action
Debris or Residue
usual
astic
Pollutants in S.W.
none
Spill Supplies
on site
several bags of
"
Maintenance Shom
Item
Condition
Action to be Taken
Date
Com leted
Comments
-improper Materials
none
Evidence of
S ilis[Leaks
none
Debris or Residue
none
Pollutants in S.W.
none
Equipment
Washing
none on
site

Bate: 2/4/08 Time: 9:30 am Inspected By: Jeff Cloninger
Ferrous Yard:
Item
Condition
Action to be Taken
Date
Com leted
Comments
Improper Materials
none
Evidence of
S ills/Leaks
none
Debris or Residue
none
Outfall 001 Cond.
goo
Outfall 002 Conti.
no long
r outfall. --cloy
_d
Shear Equipment
good--n-Ol
used in several y
ars
1,400-gallon
reservoir and
containment (for
shear
removed
Vegetative Buffer
stormwa
er pond in zoocl coidition-no
Pollutants in S.W.
none
COMMENTS:
Inspector's Signature

STORM WATER POLLUTION PREVENTION TRAINING FORM
Biltmore Iron & Metal Co., Inc.
Asheville, North Carolina
Employee Name
Date
Initial or Annual
Training
Signature
Jeff Cloninger, leader
2/12/0
Annual
Tommy _Ra-y
2 12 08
Annual
Tammy Ray2
12 08
Annu�
i ,
Mark Ray
2/12/08
Annual
Roy Jones
2/12/08
Annual
Jonah Cloninger
2/12/08
Annual
Will Sellers
2 12 08
Annual
Blake Cloninger
2/12/08
InitialM.
1-.qa-qsy Schultz
2/12/08
Initial
Nick Tucci
2/12/08
Initial
Jo h Taylor
2 12 08
Initial
i
Mark Jones'
Initial
John Fullam
.2/12/08
2/12/08
Initial
*Training: Initial, Annual Refresher, Plan Modification, Spill Follow-up

r-�
Date: 2 / 12 /08
Time: 3 : 35 pm Inspected By: gonna F . Gloninger
Review inspection records and monitoring reports. Discuss any results or recurring conditions indicative of a need for
new efforts in implementing best management practices or for changes in practices, procedures, or the Plan.
Make effort to possibly enlarge stormwater pond due to excessive stormwater
runoff from Habitat for Humanity builUin97 !hey Fave retused to put gutters
on back of building due to appearance...
Try to find " e" for millions of plastic bags brought in with aluminum cans--
__- mop if they have, a , rec; c l ab Q._source . _
Discuss any changes in facility storage areas, materials or operations that require revisions to the Plan.
Metal room — the fuel tanks were moved to tanks outside the shop area
This was recommended by OSHA inspection.
Aluriinum Warehouse — shear has been moved outside along with ue storage tank.
New Harris baler in place since flood — large reservoir — constantly c ec e by
aluminum warehouse personneT on daily basis lor any leaks during daily
maintenance checks
This certification is to be completed by an authorized signatory after each annual site compliance evaluation. It indicates
that the Storm Water- Pollution Prevention Plan was evaluated as part of an inspection, is adequate for control of facility
storm water discharges, and that the facility is in compliance with the Plan. If changes to the Plan or the site are
necessajy as a result of the inspection, these changes should be performed before this -get tification is completed,
I certify under penalty of law that this document and all attachments weir prepared under my direction
or supervision in accordance with a system designed to assure that qualified personnel properly gather
and evaluate 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, 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_ / / /I /
Ms. Vonna Clon

W A T 4�9pG
CO
November 20, 2006
Vonna Cloninger
Biltmore Iron & Metal Co Inc
PO Box 5616
Asheville NC, 28813
Michael F.-Easley, Governor
William G. Ross Jr., Secretar%
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
Subject: NPDES Stormwater Permit Coverage Renewal
Biltmore Iron & Metal Co Inc
COC # NCG200339
Buncombe 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 French Broad of the Central Office
Stormwater Permitting Unit at [phone], ext. Aisha Lau.
Sincerely,
Bradley Bennett, Supervisor
Stormwater and General
cc: Central Files
Stormwater & General Permits Unit Files
Asheville Regional Office
C E
NOV 2 9 2006
WATER QUALITY SECTION
L G Rr=(-,iCnIAL OFFICE
Wetlands and Stormwater Branch 1617 Mail Service Center Raleigh, NC 27699-1617
Internet: h2o.enr.state.nc.us 512 N. Salisbury St. Raleigh, NC 27604.-
An Equal Opportunity/Affirmative Action Employer - 50% Recycled110°% Post Consumer Paper
Phon
FAX` 19) 733-9612

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG200000
CERTIFICATE,OF COVERAGE.No.-NCG200339- - - - -
- - -- 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,
BILTMORE IRON & METAL CO INC
is hereby authorized to discharge stormwater from a facility located at
Biltmore Iron & Metal Co Inc
1 Meadow Rd
Asheville
Buncombe County
to receiving waters designated as , a class Unamed Tributary to Swannanoa River 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 R 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
March 31, 2006
Biltmore Iron & Metal Co Inc_
1 Meadow_ Rd
Asheville, NC 28803
Subject: General Stormwater Permit Inspections
Biltmore Iron & Metal Co Inc
Permit No. NCG200339
Buncombe County
Dear Sir or Madam:
Your facility holds a general permit from the North Carolina Division of Water Quality to
discharge stormwater. associated with industrial activities performed at your facility. Please be
advised that the Asheville Regional Office will be performing NPDES stormwater inspections
sometime in the near future.
If this office has not previously inspected your facility, you should be prepared to demonstrate
compliance with all terms and conditions included in the permit. Specifically, we will be
evaluating the following: your stormwater pollution prevention plan, stormwater outfall
locations, qualitative and analytical monitoring data and any other activities required by your
permit. Please note that any data reported to the State must be analyzed by a facility that has a
North Carolina laboratory certification, either as a full laboratory or as a facility certified to
perform on -site field testing. If you have any questions regarding the generation of your
facility's data, please feel free to call Gary Francies at [phone].
Copies of the general permits and accompanying documents can be accessed from the following
webpage: hitp:/hi;iipiv.)zcii)atergzrcrlrty.org/su/Farms_Doccinzents.ht»t#stormii,atet-GP.
If you have any questions, please contact me in the Asheville Regional Office at [phone],
cc: NPS Compliance & Assistance Oversight Unit
SWP-Central Files
ARO Files
Sincerely,
14rrthCarolina
)Wura!!il
North Carolina Division of Water Quality 2090 U.S. UAvy 70
Internet: http:tlwww.ncwaterquality.org/
An Equal OpportunitylAtfirmative Action Employer
swannanoa, NC 28778 Phone [phone] Fax [phone]

Michael F. Easley, Governor
0�0� W A r�q�G
co
July 25, 2005
Vonna Cloninger
Biltmore Iron & Metal Co Inc
PO Box 5616
Asheville, NC, 28813
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P-E. Director
[Xvision of Hater Quality
Subject: NPDES Stormwater Permit Coverage Renewal
Biltmore Iron & Metal Co Inc
COC Number NCG200339
Buncombe 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 httq:Ilh2o.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://h2o.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 Aisha Lau of the Central Office
Stormwater Permitting Unit at [phone], ext. 578.
Sincerely,
Bradley Bennett
Supervisor, Stormwater & General Permit Unit
Cc: Central Files
Asheville Regional Office
SWPU Files ow
Nl yhCarolina
;il;rr 1187!!11
Wetlands and Stormwater Branch 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone]
Internet: h2o.enr.state,nc.us 512 N. Salisbury St. Raleigh, NC 27604 FAX [phone]
An Equal OpportunitylAffirmative Action Employer — 50% Recycled/10% Post Consumer Paper

State tiff North Carollnp
Department of Enviror,. ;nt
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
Sherri Evans -Stanton, Acting Secretary
Kerr T. Stevens, Director
January 19, 2001
1�•
NCDENR
NORTH CAROL-INA DEPARTMENT OF
ENVIRONMENT ANO NATURAL RESOURCES
VONNA CLONINGER
BILTMORE IRON & METAL CO. INC.
P.O. BOX 5616
ASHEVILLE, NC 28813 ! r f! 1
Subject: Reissue - NPDES Stormwater' Permit1AN % 32001 f Ji
Biltmore Iron & Metal Col Inc.
COC Number NCG200339-r�`-�-.--
Buncombe County t'"`"`C ' _1 �E RGiQ �h Otv�'
Dear Pennittee: """
In accordance with your application for a discharge permit received on July 19, 1995 we are forwarding herewith the
subject certii kale of coverage to discharge under the subject slate - 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.
Upon issuance of this new Certificate of Coverage your existing Certificate of Coverage, NCG030339, is rescinded
simultaneously.
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 sliall be final and binding.
Please take notice that this certificate of coverage is not transferable except alter 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.
Enclosed is a permit package which contains the following information:
* A stormwater pollution prevention plan (SPPP) implementation certification form
* A copy of' general stormwater permit NCG200000
* Five copies of the Analytical Monitoring form and five copies of the Qualitative Monitoring form
* A copy of a Technical Bulletin for the general permit which outlines key requirements and addresses
frequently asked questions
* A Certificate of Coverage
If you have any questions concerning this permit, please contact Aisha Lau at telephone number [phone] ext. 578.
5inccrel
C.
cc: Central Files for Ker sevens
Stormwater and General Permits Unit Files
Asheville Regional Office
Compliance Section - Mr. Robert Farmer
Budget Office - Ms. Fran McPherson
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] Fax [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG200000
CERTIFICATE OF COVERAGE No. NCG200339
STORMWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215. I, other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the
Federal Water Pollution Control Act, as amended,
BILTMORE IRON & METAL CO. INC.
is hereby authorized to discharge stormwater from a facility located at
BILTMORE IRON & METAL CO. INC.
BUNCOMBE COUNTY
to receiving waters designated as an unnamed tributary to the Swannanoa River, a class C stream, in the French
Broad River Basin in accordance with the efflucnt limitations, monitoring requirements, and other conditions set
forth in Parts I, 11, III, IV, V, and VI of Gencral Permit No. NCG200000 as attached.
This certificate of coverage shall become effective January 19, 2001,
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day January 19, 2001.
for Kerr T. Stevens, Director
Division of Water Quality
By Authority of the Environmental Management Commission

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INFORMATION UPDATE FORM
1 � •
NCDENR
NORTH CAROLINA DEPARTMENT OF
EWRONMENT AND NATURAL RE50URCE5
National Pollutant Discharge Elimination System
Stormwater General Permit NCG200000
Biltmore Iron & Metal Co. Inc.
COC Number NCG200339
Buncombe County
PLEASE COMPLETE AND MAIL 'PHIS FORM BACK TO THE DIVISION BY DECEMBER 1, 2000,
REGARDLESS OF WHETHER OR NOT ANY CHANGES NEED TO BE MADE.
PERMIT CONTACT INFORMATION
The following is the information currently in our database for your facility. Please review this information carefully
and make all corrections as necessary in the space provided to the right of the current information.
Facility Name: Biltmore Iron & Metal Co. Inc.
Owner Name: Biltmore Iron & Metal Co. Inc.
Mailing Address*: P.O. BOX 5616
ASHEVILLE, NC 28813
Location Address: 1 MEADOW ROAD
ASHEVILLE, NC 28813
Facility Contact:
VONNA CLONINGER
Phone Number:
[phone]
Fax Number:
No number on file
E-mail address:
No address on file
Is this facility located in the 100 year flood plain? yesy no—
* This is the address to which all permit correspondence will be mailed
CERTIFICATION
I certify that I am familiar with the information contained in the application and that to the best of my knowledge
and belief such it urmation is true, complete and accurate.
{{
Signature Date I i AD. D(7
—\J F}. P.
Print or type name of person sign14 above Title
Please return this completed renewal form to:
Ms. Valery Stephens
Division of Water Quality/ WQ Section D
Stormwater and General Permits Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
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State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
November 9, 2000
VONNA CLONINGER
BILTMORE IRON & METAL CO. INC.
P.O. BOX 5616
ASHEVILLE, NC 28813
+ 0 •
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: NPDES Stormwater Permit Renewal
Biltmore Iron & Metal Co. Inc.
COC Number NCG030339
Buncombe County
Dear Permittee:
The general stormwater permit for scrap metal recycling industries, NCG200000, was issued on
November 1, 2000. Since there has been a considerable time lag since your permit application was received on
July 19, 1995 this letter is being sent to ensure that the contact information that we have is correct.
Enclosed with this letter you should find a contact information update form with the information that the
Division has on your facility. Please check to see whether or not this information is correct. if any of the
information has changed from what our records show, please make the appropriate corrections in the empty
blanks to the right of the information and mail the corrected form to us by December 8, 2000. Sign and mail the
information form regardless of whether or not any changes need to be made.
Upon receipt of your information form you will be mailed a Certificate of Coverage with a new number of the
format NCG200***. If you were one of the few facilities that received coverage under the NCG030000 general
permit prior to the issuance of this permit your existing NCG030000 permit coverage will be rescinded
concurrent with the issuance of your new Certificate of Coverage.
Thank you for your continued cooperation in complying with the Federal NPDES stormwater permitting
program. If you have any questions regarding this request please contact Ms. Valery Stephens at
[phone], ext. 520.
Sincerely,
Bradley Bennett, Supervisor
Stormwater and General Permits Unit
CC' Stormwater and-General'Peimits Unit
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

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