NCG200463_COMPLETE FILE - HISTORICAL_20150227

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO.
IV C& a UbLJI03
DOC TYPE
HISTORICAL FILE
❑ MONITORING REPORTS
DOC DATE
❑ 5 C%i a %
YYYYMMDD

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO.
NCGNE
DOC TYPE
❑ HISTORICAL FILE
DOC DATE
❑
YYYYM MDD

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NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory Donald R. van der Vaart
Governor Secretary
February 27, 2015
Ron Gostek
Director Safety, Environmental and Construction
Key -well Metals, LLC
7808 West College Drive
Suite 3-NE
Palos Heights, IL 60463
Subject: Return of Check No. 5963
Key -well Metals LLC
Certified Mail #70032260000553808061
Mr. Gostek:
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Your check made payable to "North Carolina Dept of Environment" in the amount of $100.00 is
being returned to you. Your account for Permit # NCG260463 is up to date, and no fee is due for
permit renewal.
Please call me at 919-807-6370 if you have any questions.
Sincerely,
�� 014"--mv
Julie Ventaloro
Stormwater Permitting Unit
Enclosures: Check No. 5963; Copy of cover letter dated 2/9/2015
cc: Laura Alexander, Stormwater Permitting Unit
Division of Energy, Mineral, and Land Resources
Energy Section - Geological Survey Section • Land Quality Section
1612 Mail Service Center, Raleigh, North Carolina 27699-1612.919-707-9200 I FAX: [phone]
512 North Salisbury Street, Raleigh, North Carolina 27604 • Internet: hUp:/Iportal.ncdenr.or /wg ebllr!
An Equal Opportunity 1 Affirmative Action Employer — 50% Recycled 110% Post Consumer Paper'

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February 9, 2015
Storm Water Permitting Unit
Division of Water Quality
1601 Mail Service Center
Raleigh, NC 27699-1601
Re: Storm Water Permit Renewal Application
Keywell Metals, L.L.C.
2826 Tophill Road
Monroe, NC 28110
SW Certificate of Coverage Number: NCG200463
To Whom It May Concern:
KEYWELL METALS
Aerospace & Specially Steel Recycling
7808 West College Drive, Suite 3-NE
Palos Heights, IL 60463
Phone: [phone]
Fax: [phone]
RECEIVED
[C8 -82015
rl'h'R-LAND QUALITY
.ciTQR✓ltItA/ATER PERM17TING
We are submitting the attached Storm Water Permit Renewal Application for the facility as referenced.
Please find an application package including the following:
• Two (2) copies of the applicable application forms and supporting documentation;
• Annual Discharge Monitoring Report; and
• A permit application fee for $100.00;
Please contact me or our environmental consultant, Rob Duffy of Antea Group at [phone] if you have any
questions during your review of the permit application.
Sincerely,
—�
Ron Gostek
Director Safety, Environmental and Construction
Keywell Metals, L.L.C.
[phone]

anteagroup
General Stormwater Permit
Renewal Application
Keywell Metals, L. L. C.
2826 Top Hill Road
Monroe, NC 28110
Antea Group Project No. 141260033A
February 6, 2015
Prepared for:
Keywell Metals, L.L.C.
7808 W. College Drive
Palos Heights, IL 60463
[phone]
�A41
Prepared by:
AnteaO Group
8008 Corporate Center Drive, Suite
Charlotte, North Carolina 28226,E
[phone]

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antea�group
Notice of Intent

Division of Energy, Mineral and Land Resources
Land Quality Section
NCDENRNational
Pollutant Discharge Elimination System
EnV �..vCwT w!19 Il-w,ti Rt7.={,wC _5
NCG200000
NOTICE OF INTENT
FOR AGENCY USE ONLY
Date Received
Year
I Month Dao
Certificate orCo,era m
Lt i�
Check # I Amount I
I I
Permit Ass, ned to
U
National Pollutant Discharge Elimination System application for coverage under General Permit NCG200000:
STORMWATER DISCHARGES associated with activities classified as:
SIC 5093 Scrap Metal Recycling (except as specified below)
SIC" NIA Like activities deemed by DEMLR to be similar in the process and/or the exposure of raw materials,
products, by-products, or waste materials
The following activities are specifically excluded from coverage under this General Permit:
Automobile Wrecking for Scrap (SIC 5093)
Non -Metal Scrap Recycling (SIC 5093)
Used Motor Vehicle Parts (SIC 5015)
Standard Industrial Classification Code
1) Mailing address of owner/operator: (address to which all permit correspondence will be mailed):
Name
Street Address
City
Telephone No.
Keywell Metals, L.L.C.
7808 W. College Drive
Palos Heights State IL ZIP Code 60463
708 608-8021 Fax:
E-mail Address [e-mail]
2) Location of facility producing discharge:
Facility Name
Facility Contact
Contact E-mail
Street Address
City
County
Telephone No.
Keywell Metals, L.L.C.
Tracy Owens
[e-mail] _
2826 Top Hill Road
Monroe State NC ZIP Code 28110
Union
704 292-1409 Fax:
3) Physical Location Information:
Narrative description of how to get to the facility (use street names, state road numbers, and distance and direction
from a roadway intersection). From State HWY 74 East, north on Chamber Drive, west on Starcrest Drive, south on
Too Hill Road.
(A copy of a county map or USGS quad sheet with facility clearly located on the map is required to be submitted with
this application)
4) Latitude 35 deg 03 min 14.1 sec N Longitude so deg 37 min 09.1 sec w (degrees, minutes, seconds)
5) This NPDES Permit Application applies to which of the following:
❑ New or Proposed Facility Date operation is to begin
IN Existing
6) Standard Industrial Classification:
Provide the 4 digit Standard Industrial Classification Code (SIC Code) that describes the primary industrial activity at
this facility:
SIC Code: 5 0 9 3
7) Provide a brief description of the types of industrial activities and products produced at this facility:
Recycling of specialty aerospace metal consisting of titanium alloy.
Page 1 of 3
SWU-235-11.16.09 Last revised 712114

NCG200000 N.O.I.
8) Discharge points:
How many discharge points (ditches, pipes, channels, etc.) convey stormwater from the property? 1
Receiving water classification (if known): NA
9) Receiving waters:
What is the name of the body or bodies of water (creek, stream, river, lake, etc.) that the facility stormwater
discharges end up in? Un-Named tributary to South Fork Crooked Creek
Receiving water classification (if known): C
If the site stormwater discharges to a separate storm sewer system, name the operator of the separate storm sewer
system (e.g. City of Raleigh municipal storm sewer). NA
10) Does this facility have any other NPDES permits?
M No
❑ Yes
If yes, list the permit numbers for all current NPDES permits for this facility: _
11) Does this facility have any Non -Discharge permits (ex: recycle permits)?
* No
❑ Yes
If yes, list the permit numbers for all current Non -Discharge permits for this facility:
12) Does this facility employ any best management practices for stormwater control?
❑ No
M Yes
If yes, please briefly describe: InventorV control curbing, landscaping, routine visual inspection, stormwater drain
inlet protection. _
13) Does this facility have a Stormwater Pollution Prevention Plan?
❑ No
49 Yes
If yes, when was it implemented?
14) Are vehicle maintenance activities occurring at this facility?
m No
❑ Yes
15) Hazardous Waste:
a) Is this facility a Hazardous Waste Treatment, Storage, or Disposal Facility?
w No
❑ Yes
b) Is this facility a Small Quantity Generator (less than 1000 kg. of hazardous waste generated per month) of
hazardous waste?
ID No
❑ Yes
c) Is this facility a Large Quantity Generator (1000 kg. or more of hazardous waste generated per month) of
hazardous waste?
M No
❑ Yes
d) If you answered yes to questions b. or c., please provide the following information:
Page 2 of 3
SWU-235-11,16.09 Last revised 712114

NCG200000 N.O.I.
Type(s) of waste:
How is material stored:
Where is material stored:
How many disposal shipments per year:
Name of transport / disposal vendor:
Vendor address:
16) Certification:
North Carolina General Statute 143-215.6 b (i) provides that:
Any person who knowingly makes any false statement, representation, or certification in any application, record, report, plan, or other
document fled or required to be maintained under this Article or a rule implementing this Article; or who knowingly makes a false
statement of a material fact in a rulemaking proceeding or contested case under this Article; or who falsifies, tampers with, or knowingly
renders inaccurate any recording or monitoring device or method required to be operated or maintained under this Article or rules of the
[Environmental Management] Commission implementing this Article shall be guilty of a Class 2 misdemeanor which may include a fine not to
exceed ten thousand dollars ($10,000).
I hereby request coverage under the referenced General Permit. I understand that coverage under this permit will
constitute the permit requirements for the discharge(s) and is enforceable in the same manner as an individual permit.
certify that I am familiar with the information contained in this application and that to the best of my knowledge and
belief such information is true, complete, and accurate.
Printed Name of Person Signing: Ron Gostek
Title: Director - Safety, Envirggrnental & Construction
(Signature of Applicant)
Final Checklist
(Date Signed)
This application will be returned as incomplete unless all of the following items have been included:
N Check for $100 made payable to NC DENR
00 This completed application and all supporting documents
Im Copy of county map or USGS quad sheet with location of
facility clearly marked on map
Mail the entire package to: Stormwater Permitting Unit Program
Division of Energy, Mineral and Land Resources
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
Note
The submission of this document does not guarantee the issuance of an NPDES permit.
For questions, please contact the DEMLR Central Office or Regional Office for your area.
DEMLR Regional Office Contact Information_
Asheville Office ......
[phone]
Fayetteville Office ...
[phone]
Mooresville Office ...
[phone]
Raleigh Office ........
[phone]
Washington Office ...(252)
946-6481
Wilmington Office ...
[phone]
Winston-Salem ......
[phone]
Central Office .........
[phone]
Page 3 of 3
SVVU-235-11,16.09 Last revised 712114

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Figures

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Figure T: Site Location Map

Figure 1: Site Location Map Antea USA of North Carolina, Inc.
Keywell Metals, LLC DATE: 2/6/2015 `-� 8008 Corporate Center Drive
2826 Tap Hill Road SCALE: NTS Suite 100
Monroe, NC28110 DRAWN BY: RD 8ntea-groUr- Charlotte, North Carolina 28226

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Figure 2: Site Layout Diagram
Keywell Metals, LLC DATE: 2/6/2015
2826 Top Hill Road SCALE: NTS
Monroe, NC 28110 DRAWN BY: RD
LEGEND
_- IMPERVIOUS SURFACE
___ PROPERTY LINE
A STORhI,^INTER OUTEALL
-=-> STORMWATER FLOW DIRI CTION
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Antea uSA of North Carolina, Inc.
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8008 Corporate Center Drive
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Suite 100
Charlotte, North Carolina 28226

NCDENR
N - GAO.- OEP�T..CHi pF
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Division of Water Quality° / Surface Water Protection
National Pollutant Discharge Elimination System
PERMIT NAMEIOWNERSHIP CHANGE FORM
FOR AGENCY USE ONLY
Date Received
Year
Month
Day
1. Please enter the permit number for which the change is requested.
NPDES Permit (or) Certificate of Coverage
N C '$ 1 0 N C 16 2 1 0 1 0
If. Permit status prior to requested change.
a. Permit issued to (company name): KevNvell L.L.C.
b. Person legally responsible for permit: Ronald G Gostek
First Ml Last
Senior VP. Operations & Corporate Services
1 1900 South Cottat:C Grove Ave
Permit Holder,llailing Address
Chicago I 60628
Cite State Zip
[phone] (773) 660-2-64
Phone Fax
c. Facility name (discharge): Keyweli Metals LLC
d. Facility address: 2826 Top Hill Road
Address
Monroe NC 28110
Cite Slate Zip
e. Facility contact person: Daniel P. Buwalda [phone]
First / MI / Last Phone
lll. Please provide the following for the requested change (reviser! I)ermit).
a. Request for change is a result of X Change in o%%rilershi1) of the fitcility
X Name change of the facility or owner
If other please explain:
b. Permit issued to (company name):
c. Person lega!ly responsible for permit:
FEB - 3 2014
d. Facility name (discharge):
e. Facility address:
f. Facility contact person:
Key_well Metals LLC_
Mar y
1 k Lozier
First 1%111 Last
President
Title
Ill 900
South Cottage Grove Avenue
Permit Holder Mailing Address
Chicago
- l_L- 60628
Cite
State Zip
[phone]
1m1-ozier_Pokev�ve11.coin
Pf1nne
L-mail Address
Kevwell Metals LLC
-
—2826 "Fop Hill Road -- -
Address
N30111-0e
NC 2
Cite
State Zip
Daniel
P Btiwalda
First
MI Last
704) 292-1409
Dl1l3uNvalda a keywell.com
Phone
E-mail Address
Revised 2012Apr23

NPDES PERMIT NAME/OWNERSHIP CHANGE FORM
Page 2 of 2
IV. Permit contact inforr�taticfn (if dihferent from the person le�ally respunsihl< liir lfic pet'n�il)
Permit contact: Konald G Gostck
F irst \111 last
Director-- Environmental & Corporate Services
Title
11900 South Cottage Grove Ave
Mailing Address
Chicago IL 60628
City State Zip
[phone] RGGostek rr,kevNvell.corn
Phone E-mail Address
V.
Will the permitted facility continue to conduct the same industrial activities conducted prior
to this ownership or name change?
1u
X Yes
❑ No (please explain)
Required Items: THIS APPLICATION WILL BE RETURNED UNPROCESSED IF ITEMS
ARE INCOMPLETE OR MISSING:
X This completed application is required for both name change and/or ownership change
requests.
X Legal documentation of the transfer of ownership (sucli as relevant pa4.zes of a contract (Ieed.
or a hill of sale) is required for an ownership change request. Articles of incorporation are
not sufficient for an ownership change.
The certifications below must be completed and signed by both the permit holder prior to the change, and
the new applicant in the case of an ownership change request. For a name change request, the signed
Applicant's Certification is sufficient.
PERMITTEE CERTIFICATION (Permit holder prior to ownership change):
i, Ronald G. Gostek, attest that this application for a name/ownership change has been reviewed and is
accurate and complete to the best of my knowledge. I understand that if all required parts of this
application are riot completed and that if all required supporting information is not included, this application
package will be returned as incomplete.
Rprt"Za h,_ _ 12/3 1 / 13
Signattrre ��dp OJ'St Cr i�'/" �i,'/GE=S W Datte Y.
APPLICANT CERTIFICATION
1, J. Mark Lozier, attest that this application for a name/ownership change has been reviewed and is
accurate and complete to the best of my knowledge. I understand that if all required parts of this
application are not completed and that ifjaI14equired supporting information is not included, this application
package will be returned as inconipl
Sii�re W Date
PLEASE SEND THE COMPLETE APPLICATION PACKAGE TO:
Division of Water Quality
Surface Water- Protection Section
1617 Mail Service Center
Raleigh. North Carolina ?7699-1617
Revised 712008

`I Mr. Ronald G. Gostek
( Keywell, LLC
September 12. 2012
o For Zinc, 6 background samples were below the benchmark, and two were above the benchmark.
Again, it is hard to connect off -site zinc concentrations with the 7 zinc exceedances, when only two
off -site background values would have been exceedances on their own. Of the two off -site
'exceedances', only one was associated with a discharge exceedance and one was associated
with a compliant discharge.
There were a number of discrepancies noted in the Top Hill Road site report that should be examined for
accuracy. These include:
The pH graph appears to indicate a pH of the rainfall running between 0.2 and 1.7 standard units,
which is not possible.
On the copper graph, one rainfall concentration for copper is shown at 1.75 mg/l. This same value
repeats itself on the lead graph and the zinc graph.
As noted in our comments for your Curtis Street facility, the Division must take into consideration the
documented results and how they are interpreted due to the factors affecting the toxicity of the heavy metals in the
environment especially when toxicity is related to hardness`
In an attempt to address both sites' benchmark exceedances, a commendable amount of analytical testing
has been performed at each Keywell facility and, at the suggestion of Mooresville Regional Office staff, hay bales
were installed at strategic locations at the Curtis Street site: Regional Office staff have also been able to confirm
that consideration was given to repaving the gravel area at the Curtis Street site or possibly moving the site
altogether, although both options were subsequently found to be too costly. Keywell personnel have implemented
suggested monitoring location changes at the Curtis Street site, and initial results show a positive improvement in
effluent stormwater quality. The additional off -site testing and the use of the hay bales at internal stormwater inlets
are both steps in a positive direction, but the stormwater outfall monitoring data as presented does not offer a
definitive correlation that would allow Division staff to conclude that outfall benchmark exceedances at either facility
may be attributed in any significant part to off -site sources. Such being the case, we cannot support a reduction in
pollutant testing and relief from addressing the ultimate removal of pollutants from these two Keywell sites at this
time.
In an effort to achieve a positive solution to this matter, this Office recommends that Keywell continue to
evaluate other creative engineering alternatives at both sites that would be both operationally and economically
feasible. Aside from a few strategically placed hay bales, additional consideration should be given to the use of
structural BMP remedies that may offer additional pollutant removal. Even with the addition of structural BMPs,
there are a number of factors that influence pollutant removal effectiveness (including past site history). It is
entirely possible that additional measures may not reduce pollutant levels to where consistent compliance with
benchmark values can be consistently obtained. Under such circumstances, the Division would be prepared to re-
evaluate the decision for a reduction in tiered sampling provided all reasonable alternatives have been explored.
If you have any questions or comments concerning this letter, please contact Mr. Michael Parker at (704)
235-2194 or via email at Michael. [e-mail].
Sincerely,
i 13
Robert B. Krebs
Regional Supervisor
Surface Water Protection
cc: Mooresville Regional Office
Central Office/Stormwater Permitting Unit

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

Similarly for zinc, with a graph showing again, 1.75 mg/L zinc content in rainfall. This begins to look like one
mistake, compounded multiple times, and yet still escaping the notice of senior review.
As to the tabulated data at Top Hill Road:
No recurring problems with pH, COD, TSS, O&G, Cd, or Fe ---Good.
Pb monthly sampling returned to twice per year based on three consecutive results below the benchmark in
2011 ---Good.
As per the other site, however,-Cu and Zn were reported greater than the benchmark in 9 of 11 samples, and 7
of 11 samples, respectively.
o For Cu, 6 background samples were below the PQL of 0.005 mg/L, one was below the benchmark, and
only one was in excess of the benchmark. Hard to tie off -site copper into the 9 copper exceedances
when really only one off -site background value would have been an exceedance on its own.
o For Zn, 6 background samples were below the benchmark, and two were above the benchmark. Hard to
tie off -site zinc into the 7 zinc exceedances, when only two off -site background values would have been
exceedances on their own. Of the two off -site 'exceedances', one was associated with a discharge
exceedance — and one was associated with a compliant discharge. Again, hard to explain a connection
where none apparently exists.
What is still worth our attention and caution, however, is that both copper and zinc can be present in the environment,
and their toxicity is hardness dependant. We should be cautious in how we use the zinc and copper exceedances as we
work with this facility.
(OK, back checking the graphs in the first report: I see CODS in rainfall of 30 mg/L and 50 mg/1---not possible; TSS
reported as 300, 500, and 600 mg/L in rainfall --- not possible, copper at 0.62 mg/L, roughly 100 times the stormwater
benchmark, similarly for lead and zinc. 1 have been there in my post life as a consultant putting together a report for
someone else, or at the last minute, and skipping senior review due to the press of time. Even when you know how it
happens, however, it's still awful)
kbp
kbp
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email-. ken, picklepncdenr.gov
Website: http://r)ortal.ncdenr.org/web/wQ/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Pickle, Ken
Sent: Monday, July 30, 2012 2:38 PM
To: Parker, Michael
Cc: Bennett, Bradley
Subject: Keywell, 1163 Curtis Street, Monroe, Tiered response monitoring

Pickle, Ken
From: Bennett, Bradley
Sent: Monday, ,July 30, 2012 8:34 AM
To: Pickle, Ken
Subject: RE: Keyweil, LLC Facilities - NCG200424 and NCG200463
I'll bring you the request. Could you try and talk to Mike.
Thanks
I:l 3
Bradley Bennett
Stormwater Permitting Unit
NC Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Phone: [phone]
Fax: [phone]
Email: bradley.ben nett(ancdenr.gov
Web: htti)://portal.ncdenr.org/web/wglws/su
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties
From: Pickle, Ken
Sent: Monday, July 30, 2012 8:06 AM
To: Bennett, Bradley
Subject: RE: Keywell, LLC Facilities - NCG200424 and NCG200463
Good morning Bradley,
Did you want me to follow up with these folks or with Mike?
Do you have the incoming requests for revisions to the Tiered structure?
Presumably Mike Parker would be the lead on this (as per our conceptualization of how this Tiered structure would work
upon the fourth exceedance), but we need to prime the pump a little with some initial input? Or do we need to take the
lead?
Ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. [e-mail]
Website: http://portal.ncdenr.ora/web/wq/ws/su

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

Hi Mike,
Thanks for the discussion this morning. I have a few comments on the request from the permittee, Keywell, to
discontinue the monthly sampling, and to return to the twice per year sampling regimen.
Based on our discussions, I also wonder what reduction of pollutant discharges from this site might be
feasibly/reasonably achievable, given the reported site configuration and other circumstances. I agree with you that
ultimately some accommodation or extended period of working with this site may be our best path forward.
But I have some contrary comments, too, on their proposal. While it is commendable that the permittee has done a
good bit of sampling (but not all the permit requires of them), 1 would describe their interpretation that the monitoring
results support their request for a reduction in sampling effort as wishful thinking, at best. My inspection of the data
included in support of their request identified the following problems.
• Several notations in the tabulated data of 'Missed' or 'Not Sampled', including the entire second half of 2010.
• Several notations in the tabulated data of 'No Flow' spanning March, April, May, and June 2011, during which
time they were obligated to perform monthly sampling. Really? Four months without rainfall?
• For COD, with a benchmark of 120mg/L: Ten of eleven sampling results exceeded the benchmark. In addition,
sixteen background samples were obtained in eight of the eleven events, and in no case did background
concentrations exceed the value reported from the site outfall, nor did any background value exceed the
stormwater benchmark, had it been applicable. 4There is no basis to conclude that this collection of data
points supports the argument that COD exceedances may be attributed in any significant part to off -site
sources.
For TSS, with a benchmark of 100 mg/L: Eleven of eleven sampling results exceeded the benchmark. In
addition, seventeen background samples were obtained in nine of the eleven sampling events, and in no case
did background concentrations exceed the value reported from the site outfall, nor did any background value
exceed the stormwater benchmark, had it been applicable. —>There is no basis to conclude that this collection
of data points supports the argument that TSS exceedances may be attributed in any significant part to off -site
sources.
• No continuing problems indicated for pH, O&G, Cd, or Fe, except that Keywell missed the required sampling
event in the first half of 2012 for Cd and Fe.
For the other metals, we need to proceed with a little caution in the interpretation of the permittee's results,
due to the factors affecting the toxicity of the heavy metals in the environment.
o For lead, with a benchmark of 0.03 mg/L: Four of eleven samples exceeded the benchmark.
Seventeen background samples were obtained, and in no case exceed either the benchmark, or the
reported discharge value. 4 There is no basis to conclude that this collection of data points supports
the argument that Pb exceedances may be attributed in any significant part to off -site sources.
o For copper, with a benchmark of 0.007 mg/L: Eleven of eleven samples exceeded the benchmark.
Thirteen of seventeen background samples would have exceeded the stormwater permit benchmark,
had it been applicable. Still however, in none of the seventeen background samples did the background
concentration exceed the concentration reported at the permittee's outfall. Typically we consider
copper as a 'ubiquitous' metal based on its presence in the soils in many places in North Carolina.
Further, its toxicity is related to hardness of the receiving water. On these points we are cautious as to
allowing our regulatory actions to be totally based on copper exceedances. It's still there in the runoff
from this site; it's still bad; but as a fully defensible basis for action, we are cautious in our
interpretation of copper values. In the worst reported outfall exceedance from this permittee, the
copper content was 27 times the benchmark value (0.193 mg/L on Nov 17, 2011 vs 0.007 mg/L). It's
unclear to me whether we could conclude that off -site copper affected site discharges, but I suspect
that they did not impact the discharge value significantly.

o For zinc, with a benchmark of 0.067 mg/L: Eleven of eleven samples exceeded the benchmark.
Thirteen of seventeen background samples would have exceeded the stormwater permit benchmark,
had it been applicable. But again, in no case did any of the background concentrations exceed the
concentration reported at the permittee's outfall. Zinc is another metal we treat cautiously as a basis
for regulatory action, for the same reasons as listed for copper. But still, it's there in the runoff from
this site; it can be toxic depending on the receiving water hardness and dilution. The worst reported
value discharged from the site was 6 times the benchmark value (0.438 mg/L.on March 2, 2012 vs 0.067
mg/L benchmark.) It's unclear to me whether we could conclude that off -site zinc affected site
discharges, but I suspect that they did not impact the discharge value significantly.
Beyond just the data, the consultant's report graphically -suggests an area — lmile east to west by —% mile north to south
as discharging through the permittee's facility. I would expect to see a rather substantial channel for an area this large
in a developed urban area. But, the feature is barely visible in the aerial photo, and appears to run through the middle
of the permittee's site. Something's wrong here, either in my expectations, or in the conclusion that several industrial
operations, including some 3/ mile distant drain through this facility.
So, what has this permittee done to address his exceedances? Commendably, a good bit of sampling, although not all
that he was required to do. And he has thrown out some hay bales. And he has explored the cost of repaving the gravel
area or of moving the site, concluding in both cases that it was too costly. And he has offered an extraordinarily weak
argument that off -site contributions exist at a level sufficient to excuse him from the continued monthly monitoring.
And further, by omission, that he be excused from further attempts to address the discharges of pollutants from his site.
It seems to me that he needs to explore more creative engineering alternatives to address his discharge of pollutants.
It's possible we will wind up in the same place we are now, having to make some accommodations. And that would be
fine; if that's all we can feasibly do. But as far as we know, he has not really explored anything other than the two most
costly alternatives: Pave the world, and move. These are not real -world approaches. A more serious effort at problem
solving is indicated by the site circumstances, in my opinion.
ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken,[e-mail]
Website: httg://oortal.ncdenr.org/web/wq/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**

,r
NCDENR
_ - •North Carolina Department -of -Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, PE Dee Freeman
Governor Director Secretary
September 12, 2012
Mr. Ronald Gostek, Senior VP, Corporate Services
Keywell, LLC
11900 South Cottage Grove Avenue
Chicago, Illinois 60628
Subject: Request for Reduction in Tiered Monitoring
Keywell, LLC
2826 Top Hill Road
NPDES General Permit No. NCG200463
1163 Curtis Street
NPDES General Permit No. NCG200424
Union County
Dear Mr. Gostek,
This Office is in receipt of two letters both dated July 5, 2012, requesting relief from tiered monitoring at
both your Curtis Street and Top Hill Road facilities in Union County. Specifically, these requests involved relief
from tiered monitoring of TSS, COD, copper, and zinc at your Curtis Street location and copper and zinc at your
Top Hill Road location. Your justifications for these requests were based on the results from additional off -site
testing and the implementation of structural BMPs (hay bales) at both sites. Staff from both the Regional Office and
the Central Office have reviewed the information submitted with your request and offer the following comments:
Curtis Street Facility
Although a significant amount of sampling has been conducted at this facility, in our review of the data
there were a number of areas identified that are somewhat problematic to this request.
• Several notations in the tabulated data indicated 'Missed' or'Not Sampled', including the entire second half
of 2010.
• Several notations in the tabulated data indicated 'No Flow' with entries spanning March, April, May, and
June 2011. Keywell was obligated to perform monthly sampling during this period.
• For CO©, with a benchmark of 120mg/L: Ten of eleven sampling results exceeded the benchmark. In
addition, sixteen background samples were obtained in the eleven sampling events. In no case did
background concentrations exceed the value reported from the site outfall, nor did any background value
exceed the stormwater benchmark, had it been applicable.
• For TSS, with a benchmark of 100 mg/L: Eleven of eleven samp€ing results exceeded the benchmark,
In addition, seventeen background samples were obtained in the eleven sampling events. In no case did
background concentrations exceed the value reported from the site outfall, nor did any background value
exceed the stormwater benchmark, had it been applicable.
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115
Phone: [phone] Fax: [phone]
Intemet: www.ncwaterquality.org
One
Noi-thCarol ina
Natimally
An Equal Opportunity 1 Affirmative Action Employer - 30% Recycled/10% Post Consumer paper

Mr. Ronald G. Gostek
Keywell, LLC
September 12, 2012
There were no problems indentified with pH, O&G, Cd, or Fe. However, Keywell missed required sampling
events in the first half of 2012 for Cd and Fe.
In reviewing the information submitted for the other metals contained in the Curtis Street's General Permit,
the Division must take into consideration the documented results and how they are interpreted due to the
factors affecting the toxicity of heavy metals in the environment.
For lead, with a benchmark of 0.03 mg1L: Four of eleven samples exceeded the benchmark.
Seventeen background samples were collected, and in no case did a background sample exceed
either the benchmark, or the reported discharge value. It is difficult to conclude that this collection
of data points supports the argument that lead exceedances may be attributed in any significant
part to off -site sources. It was noted in your letter that lead concentrations have since fallen below
benchmark levels and are no longer a part of a -tiered response.
For copper, with a benchmark of 0.007 mg/L: Eleven of eleven samples exceeded the
benchmark. Thirteen of seventeen background samples would have exceeded the stormwater
permit benchmark, had it been applicable. It should be noted that in none of the seventeen
background samples did the background concentration exceed the concentration reported at the
permittee's outfall. Copper is generally considered a 'ubiquitous' metal based on its presence in
the soils in many places in North Carolina and its toxicity is related to hardness of the receiving
water. Such being the case, the Division is generally cautious when applying regulatory actions
based strictly on copper exceedances. In the worst reported outfall exceedance from this site, the
copper content was 27 times the benchmark value (0.193 rng/L on Nov 17, 2011 vs a benchmark
of 0.007 mg/Q. Although off -site copper has been documented at this facility, it does not appear
that off -site sources have significantly influenced the resulting discharge values.
o For zinc, with a benchmark of 0.067 mglL: Eleven of eleven samples exceeded the benchmark.
Thirteen of seventeen background samples would have.exceeded the stormwater permit
benchmark, had it been applicable. But in no case did any of the background concentrations
exceed the concentration reported at the permittee's outfall. Zinc is another metal that the Division
treats cautiously as a basis for regulatory action, for the same reasons as listed above for copper.
It is present in the runoff from this site and it can be toxic depending on the receiving water
hardness and dilution. The worst reported value discharged from the site was 6 times the
benchmark value (0.438 mg/L on March 2, 2012 vs 0.067 mg/L benchmark.). As with copper, it is
possible that off -site zinc affected the site's SW discharge, however, it does not appear that off -site
zinc sources significantly affected the resulting discharge values.
Top Hill Road Facility
No recurring issues with SW testing for pH, COD, TSS, O&G, Cd, or Fe.
• Monthly sampling for Lead returned to twice per year based on three consecutive results below the
benchmark in 2011. A positive improvement.
• As with the Curtis Street facility, Copper and Zinc were reported greater than the benchmark value in 9 of
11 sampling events, and 7 of 11 sampling events, respectively.
o For Copper, 7 background samples were below the benchmark value 0.007 mg/L and only one
was in excess of the benchmark. For this parameter, it is hard to connect off -site copper
concentrations with the 9 copper exceedances when only one off -site background value would
have been an exceedance on its own.

July S, 2012
Mr. Bradley Bennett, Unit Supervisor
Division of Water Quality
Stormwater Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Mm"11MMILL
Re: Request for Storm Water Tiered. Response Relief eLp
Keywell L.L.C.
2826 Top Hill Road
Monroe, NC 28110
General Permit Number NCG7094T4- V66000VS
Dear Mr. Bennett:
Keywell L.L.C. (Keywell) located at 2826 Top Hill Road, Monroe, Union County, North Carolina in
accordance with National Pollution Discharge Elimination System (NPDES) general permit number
NCG200000, discharges storm water to waters of the State.
The referenced facility has been performing tiered response monitoring since February 2011 for copper,
lead, and zinc. Lead concentrations have since fallen below the benchmark values and are no longer a
part of the tiered response. Keywell has condu�ti�ted exhaustive research into the source of the meta!
tural BMPYt pollutants as well as installed struco combat TSS 'eveis. Up -gradient monitoring has
demonstrated that a significant contribution of the metal pollutants is coming from up -gradient sources(D
Therefore, at this time we are writing to request relief from storm wal.er tiered response with a return to
semi-annual monitoring.
Please find enclosed a report prepared by our consultant that provides supporting information to our
request for relief from continued storm water tiered response monitoring. If you have any questions or
concerns, please feel free to contact me at [phone], or our environmental consultant, Rob Duffy of
Antea of USA, Inc., at [phone].
Sincerely, r■(�L% V DO
JUL 2 6 2012
Ronald G. Gostek
Kevwell, L.L.C. DENR - WArER DUALITY
Sr. VP Corporate Services Wetlande 3 Skjnwetee Branch
Cc: Mr, Michael Parker, NCDENR-Surface Water Protection Section, Mooresville Regional Officr,
Dan Buwalda, General Manager, Keywell, LLC
Tracy Owens, Manufacturing Engineer, Keywell, LLC
Louis E. Wagner, Jr., EVP and Corporate Counsel, Keywell, LLC
Attachment
Institute
of Scrap SRC-
R,,�,�
I(�QlRecycling
s °r lit "
1R
un Industries, Inc.
KEYWELL L.L.0
11900 South Cottage Grove Avenue
Chicago. IL 60628
[phone]
FAX [phone]

anteagroup
Request for Relief from Storm Water
Tiered Response Monitoring
Keywell, L.L.C.
2826 Top Hill Road
Monroe, [Union County, NC 28110
Antea Group Project No. 5E1201123P
June 28, 2012
Prepared for:
Keywell, L.L.C.
11900 South Cottage Grove Avenue
Chicago, IL
[phone]
Prepared by:
AnteaTMGroup of North Carolina, Inc.
8008 Corporate Center Drive, Suite 100
Charlotte, North Carolina 28226
[phone]
.:4,�.�.

Request for no0eƒ/rovn
Storm Water Tiered Response
Antea Group Project No. 5EI201123P
Table of Contents
��
aK���aC3rouO
� r
1.0 INTRODUCTION BACKGROUND ........................................... ... —... ............................... ---------....... —'1
2.0 N[DENRASSISTANCE ............................................................................. .................................. ---....... ............... l
3.0 RESULTS OFIMPLEMENTATION OFmCDEmRRECOMMENDATIONS ............... .......................................................... Z
4.0 CONCLUSIONS ............................................. .................................. .............................. --...................................... -2
5.0 RECOMMENDATIONS ........................................................ —....... .............................. --....... ....................... .... 3
6,0 REM4mKS------------------------------------------------------. 3
Figures
Figure Aerial Location Photograph
Figure Site Layout Diagram
Appendices
Appendix4 Laboratory Analytical Results Summary
Appendix Laboratory Ana|ytica|Results Charts
Appendix Site Photographs

Keywell, L.L.C.
Request for Relief of
Storm Water Tiered Monitoring
1.0 INTRODUCTION - BACKGROUND
Keywell L.L.C. (Keywell) located at 2826 Top Hill Road, Monroe, Union County, North Carolina recycles titanium
alloys at this facility. The material handled by this facility is shipped in via truck, processed, and delivered to our
customers or other Keywell locations by truck. All processing operations are conducted under roof in the
warehouse. A torch cutting operation is conducted outside on a downdraft table under an awning on a covered
concrete pad and slag is not anticipated to collect in the area. The dust collector located outside is not expected to
deposit dust to the ground under normal operating conditions. Up to approximately 400 tons per month of
titanium alloy scrap is received by truck and in multiple palletized containers. Lift trucks are used to unload the
alloys. Ali materials are hand sorted. Approximately 90% of the solids are shot blasted, reloaded and shipped to
customers. Approximately 80% of the solids are torch cut prior to shot blasting.
Keywell, in accordance with National Pollution Discharge Elimination System (NPDES) general permit number
NCG200000 discharges storm water to waters of the state. Beginning in February of 2011, Keywell has performed
tiered response monitoring for the benchmark exceeding pollutants: TSS, pH, copper and zinc in accordance with
the requirements of the referenced permit. TSS and pH have been intermittent over the past two years. The
materials processed at this facility are exclusively titanium alloys, which do not contain copper or zinc.
Keywell requested assistance from the Surface Water Protection Section of the North Carolina Department of
Environment and Natural Resources (NCDENR) Division of Water Quality, Mooresville Regional office as soon as
the tiered response requirements went into effect.
2.0 NCDENR ASSISTANCE
Mr. Michael Parker and Mr. Robert Krebs, both of the Mooresville Regional office conducted a site visit on April 1,
2011 in response to Keywell's request for assistance. At the conclusion of the April 1, 2011 visit by NCDENR, a
number of recommendations were made in an attempt to identify the source of the copper and zinc since Keywell
does not manufacture or process any materials that could potentially contribute copper and zinc to the storm
water discharge.
The recommendations included additional background sampling up -gradient of the facility to identify potential
sources of copper and zinc. Figure 1 presents an aerial photograph of the surrounding area.
1 www.anteagroup.com

Keywell, L. L. C 10
Request for Relief from Q
Storm Water Tiered Response
Anted Group Project No. 5E I201123P a n to a g ro u p
3.0 RESULTS OF IMPLEMENTATION OF NCDENR RECOMMENDATIONS
There were two occasions over the last two years in which total suspended solids exceeded the benchmark value.
The total suspended solids issues were effectively addressed through the implementation of structural BMPs.
Keywell has implemented structural controls such underground storm water conduits, erosion control matting, rip
rap, planting of vegetative cover, and the construction of a concrete outfall structure. Keywell considered paving
the industrial activity area to the rear of the facility but found it to be cost prohibitive at this time. Keywell has also
researched the possibility of moving to a location where operations, loading/unloading, and staging of materials
could all take place under roof. To address the total suspended solids issue, all exterior operations were covered
and roof drainage was diverted from the downspouts underground in the spring of 2011 to prevent contact of
storm water with industrial activities. However, moving the operation was also deemed cost prohibitive at this
time. Figure 2 presents a site layout diagram depicting the location of the site outfall and structural BMPs.
Additionally, the site photographs in Appendix C depict the conditions at the site.
Keywell began the implementation of background sampling in July 2011 and has performed background sampling
in conjunction with tiered response sampling through today. Keywell has investigated their property for potential
sources of copper and zinc to include the possibility that the building itself may be the source. The investigation
has resulted in no evidence of any potential sources onsite. The building that Keywell is operating from has intact
paint with no visible rusting.
Background testing has documented copper and zinc exceedences of the benchmark values. Appendix A presents
a summary of the analytical data to date. While the outfall monitoring results have continually demonstrated a
higher concentration for copper and zinc than the background monitoring results, the increase has be directly
correlated to the amount of rainfall received by the area. Analysis of the background sample results has indicated
that the higher the volume of water that traverses the Keywell property, the higher the copper and zinc
concentrations as detected at the outfall. Appendix B presents the analytical results charted for trend
identification.
Figure 1 is an aerial photograph of the subject property and surrounding area. Figure 2 is a site layout diagram
depicting the structural controls that have been implemented at the site.
4.0 CONCLUSIONS
Antea Group offers the following conclusions based on the analytical results, background monitoring, and site
improvements made by Keywell.
• I Keywell has exhaustively investigated potential sources of copper and zinc on their property.
�ze7 /7,0 "S/
2 www.anteagroup.com

Keywell, L.L.0
Request for Relief from
Storm Water Tiered Response a ntea g ro u p
Antea Group Project No. 5E1201123P
• Keywell has conducted investigations for potential up -gradient sources of copper and zinc through
background sampling.
• Sufficient evidence has been presented to indicate a significant contribution of copper and zinc from up
gradient sources, which also appear to be naturally occurring non -point sources.
• Total rainfall amount influences the concentrations of the subject pollutants of concern — the higher the
rainfall, the higher the concentrations. Sd tt)12d0L
Up -gradient sources of Popper and zinc are contributing significantly o Keywell's exceedences of the
benchmark values. ! ,7G�//-t�G�
pH, while exceeding the benchmark valu is consistent with naturally occurring pH associated with the
Piedmont Region of North Carolina. LL
/�iGO rl �GT
5.0 RECOMMENDATIONS
At this time and in light of the evidence collected which supports significant contributions of copper and zinc from
up -gradient sources as well as the recommendation of the NCDENR Mooresville Regional Office, Keywell would like
to request relief from the tiered response monthly monitoring requirements and resume semi-annual monitoring.
6.0 REMARKS
The conclusions and recommendations contained in this report represent Antea USA, Inc.'s professional opinions
based upon the currently available information and are arrived at in accordance with currently accepted
professional standards. This report is based upon a specific scope of work requested by the client. The contract
between Antea USA, Inc. and its client outlines the scope of work, and only those tasks specifically authorized by
that contract or outlined in this report were performed. This report is intended only for the use of Antea USA,
Inc.'s client and anyone else specifically identified in writing by Antea USA, Inc. as a user of this report. Antea USA,
Inc. will not and cannot be liable for unauthorized reliance by any other third party. Other than as contained in
this paragraph, Antea USA, Inc. makes no express or implied warranty as to the contents of this report.
3 www.anteagroup.com

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

magili
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:Sfiv{S
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L'fIC�S
CO'+EWEn CROP 9 iy r
ANO CJv C;L!E -
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Roof drainage conveyed via
/ underground conduit to discharge
d channel in spring 2011.
} Storm water discharge channel was
seeded, matted, and rip -rapped in spring
A 2011.
0 50 100
Fr
EED � Qrool
FEET
Outfall was formed with concrete in spring 2011
to allow TSS to settle prior to discharge.
LEGEND
IMPERVIOUS SURFACE
PROPERTY LINE
STORMWA T ER OUTFALL
- > STORMWATER FLOW DIRECTION
O BACKGROUND SAMPLE LOCATION
I AAINAGE AP. A CALCVlAT10',S
IJAW';nCE AREA ICUTFALL
IaPEA (So. 134'4`9 _ I
�.01A1. AREA 216
T. W.PCr ,QUS 1, 5.i I
S-rNlFJCAaT v 3E?I:�',
i
I
AREAS
i
<RFA UESCR'.?7=3r1
i
F �TwVTU,!
---------._..--------- i.
hT:J:PUV
jSCWUS' SOLIDS
I ,
S;S;vi.,t4'
' jvrooi7F'J
2 iPAIIETS,
iC.ir03�AxD
5.DNENT
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3 iClli?IKu STATFC'J„
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4 OLIVPS1CRS,
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Figure 2: Site Layout Diagram Drawn By: RD
Keywell, L.L.C. Checked: RD
2826 Tap Hill Road Date: 6/7/2012 8008 Corporate Center Drive
Monroe, NC 28110 Scale: NTS""'^ ^'" Charlotte, NC 29226

Keywell, L.L.0
Request for Relief from
Storm Water Tiered Response
Anteo Group Project No. 5E1201123P
Appendix A
Laboratory Analytical Results Summary
antea'group
www,anteagroup.com

Keywell, L.L.C.
2826Top Hill Road
Monroe, NC 28110
Laboratory Analytical Results Summary
Parameter:
Rainfall
pH
COD
TSS
O&G
Cadmium
Copper
Iron
Lead
Zinc
Method:
Local Rain Gauge
9040
5220D
2540D
1664A
200.7
Z00.7
200.7
200.7
200.7
BMV:
>0.1"
6.0-9.0
120
100
30
0.001
0.007
NA
0.03
0.067
units:1
in
std.
mg/I
mg/l
mg/1
mg/1
mg/I
mg/1
mg/1
mg/I
Semi -Annual Period
Date
Type
Outfall
Comments
None.
No Flow
None
No Flow
None
No Flow
No Flow
No Flow
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
1st Half 2010
5/11/2010
Semi -Annual I
OF001
0.23
7.0
72.00
668.00
<5.0
<0.001
0.0553
S4.7
0,0371
0,302
2nd Half 2010
7/10- 12/10
Semi -Annual
NA
1st Half 2011
1/2/2011
Tier 1 7
OF001
0.38
7.0
56-00
47-80
<5.0
<0.001
0.094
85.600
0.0740
0.1100
February
Tier II
OF001
3/28/2011
Tier d g
OF001
0.17
NA
NA
NA
NA
NA
0.0076
NA
0.0058
0.11
April
Tier II
OF001
May
Tier 11
01`001
rune
Tier Il
OF001
2nd Half 2011
7/31/2011
Tier II
OF001
0.10
NA
NA
NA
NA
NA
0.0135
NA
0.0366
0.0532
7/31/2011
Tier II
8GO01
0.10
NA
NA
NA
NA
NA
0.0175
NA
0.0134
0.0129
8/5/2011
Tier II
OF001
0,10
NA
NA
NA
NA
NA
0.0225
NA
0.0162
0.0128
8/5/2011
Tier II
BG001
0.10
NA
NA
NA
NA
NA
<0.005
NA
0.196
0.151
9/6/2011
Semi -Annual (p
OF001
0.38
5.2
62.00
28.00
<5.0
<0.001
0.0078
2.04
0.0118
0,0838
9/6/2011
Tier III
BG001
0.38
NA
NA
NA
NA
NA
0.0068
NA
<0.005
0.0251
10/11/2011
Tier III
OFOC1
0-36
NA
NA
NA
NA
NA
0.0143
NA
0.0169
0.181
1011112011
Tier III
BG001
0.36
NA
NA
NA
NA
NA
<0.005
NA
C.0057
0.0382
11/4/2011
Tier III
OF001
0.10
6.6
NA
NA
NA
NA V
0.0056
NA
0.0067
0.0581
11/4/2011
Tier 111
BG001
0.10
5.3
NA
NA
NA
NA
<0.005
NA
0.0058
0.0642
1st Half 2022
12/7/2011
Tier III
OF001
0.24
7.8
NA
NA
NA
NA
0.0783
NA
NA
0.309.
12/7/2011
Tier III
8G001
0.24
4.6
NA
NA
NA
NA
<0.005
NA
NA
0.0788
1/18/2012
Tier III t 0
OF001
0.29
6.4
NA
NA
NA
NA
0.0069
NA
NA
0.0658
1/18/2012
Tier III
BG001
0.29
5.2
NA
NA
NA
NA
<0.005
NA
NA
0.0472
F-
5/9/2012
lComp y
OF001
1.76
8.2
110.00
17100
<5.0
<0.001
0.053
41.6
0.0282
0.19
5/9/2012
lComp
ISGO01
1.76
1 5.5
35.00
15.40
<5.0
<,OW1
<.005
1.14
0.0096
0,0564
G L° S t�� rl o n id, 2/4 rn on/4 non %i^

Keywelf, c.c.c
Request for Relief from
Storm Woter Tiered Response
Antea Group Project No. SE1201123P
Appendix B
Laboratory Analytical Results Charts
0
antea'group
www.anteagroup.com

Chart Data
Date
Rainfall
OF -pH
5/11/2010
0.23
7.0
1/2/2011
0.38
7.0
3/28/2011
0.17
7/31/2011
0.10
8/5/2011
0.10
9/6/2011
0.38
5.2
10/11/2011
0.36
11/4/2011
0.10
6.6
12/7/2011
0.24
7.8
BG-pH OF-Cu
BG-Cu
OF-Pb
SG-Pb
OF-Zn
BG-Zn
0.0553
0.0371
0.302
0.094
0.0740
0.1100
0.0076
0.0058
0.11
0.0135
0.0175
0.0366
0.0134
0.0532
0.0129
0.0225
0.0000
0.0162
0.196
0.0128
0.151
0.0078
0.0068
0.0118
0
0.0838
0.0251
0.0143
0
0.0169
0.0067
0.181
0.0382
5.3 0.0056
0
0.0067
0.0058
0.0581
0.0642
4.6 0.0783
0
0.309
0.0788

pH: OF-001 vs. BG-001
May 11, 2010 Through December 7, 2011
--n—Rainfall--*--OF-pH—o--BG-pH

1.80
1.60
1.40
1.20
W
E�
c 1.00
0
0.80
0
O
V
0.60
0.40
0.20
0.00
10 10 ti0 �Q) �Q) ,O �O y0 1b ti~ L~ ;N~ N% 'N" 1ti 1ti 1~ titi tiL ti� 1L N" NIV NIV 11 1L
p�� �o� Qe� sac 4eo fat �Qt �av ,mac �J\ Q�pO heQ p�` 4 �� fat PQt �aJ ,mac
Date

1.80
1.75
1.70
1.65
1.60
1.55
1.50
1.45
1.40
1.35
1.30
1.25
1.20
1.15
m � 1.10
E s 1.05
1.00
o - 0.95
'� •E 0.9p
0.85
0.80
u 0.75
o 0.70
v 0.65
0.60
0.55
0.50
0.45
0.40
0.35
0.30
0.25
0.20
0.15
0.10
0.05
0.00
'oA ,J� lJ� Q�°O heQ p�� �o, �e� sac �e� lac P�� �aA ���
Date

Zinc: OF-001 vs. BG-001
RA-.., 11 'fA7A TN.......L. 1'1.,. ., w,L..,. 7 'Intl
1.90
1.75
1.70
1.65
1.60
1.55
1.50
1.45
1.40
1.35
1.30
1.25
1.20
1.15
m Qj 1.10
E r 1.05
o 0.95
- 0.90
0.85
0.80
0.75
o x 0.70
u 0.65
0.60
0.55
0.5Q
0.45
0.40
0.35
0.30
0.25
0.20
0.15
0.10
0.05
0.00
ti0 �� ti0 ti0 �� ti0 ti0 �� yti 1~ 1y ti~ tit ti~ 1ti titi titi �� �� �� tiL 1l 11 tit tiL ti�
'leea Q�� C:p pp� spa Q�c lac �e� le Q0 �a� ,J� ��\ Q�aQ `7p 6 �o�' Qv� lac Ile
Date

Keywell, L.L.C.
Request for Relief From
Storm Water Tiered Response
Antea Group Project No. 5EI201123P
Appendix C
Site Photographs
0
antea'group
www.anteagroup.com

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Photo 7: View -southwesterly, Parking lot.
Photo 9: View - northerly from Outfall 001. Entry road to left and industrial
activity area to right.
Photo 8: View-souteasterly. Right side drive to rear of plant.
Site Photographs - Page 2 PROJECT NO: 5E1201123P r
Keywell, L.L.C. DATE: 6/7/2D12
2826 Top Hill Road �'� $008 Corporate Center Drive, Suite 100
Monroe, INC 28110 anteagrCUr, Charlotte, North Carolina 28226

NC®EN R
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director ' Secretary
August 7, 2009
Mr. Ronald G Gostek
Keyweil LLC
11900 S Cottage Grove Ave
Chicago, Illinois 60628
Subject: General Permit No. NCG200000
Keywell LLC Vac Air Division
COC No. NCG200463
Union County
Dear Mr. Gosteck:
In accordance with your application for a discharge permit received on July 20, 2009 we are
forwarding herewith the subject certificate of coverage (COC) to discharge under the subject state -
NPDES general permit. This permit is issued pursuant to the requirements of North Carolina General
Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the US
Environmental Protection Agency dated October 15, 2007 (or as subsequently amended).
Please take notice that this certificate of coverage is not transferable except after notice to the
Division of Water Quality. The Division of Water Quality may require modification or revocation and'
reissuance of the certificate of coverage. This permit does not affect the legal requirements to obtain
other permits which may be required by the Division of Water Quality or permits required by the
Division of Land Resources, Coastal Area Management Act or any other federal or local governmental
permit that may be required.
Please note that the attached permit has been temporarily extended until December 31, 2009,
however, we expect the final permit to be issued sometime during November of this year. We
suggest you that review the proposed general permit at www.ncwaterguality.org/su/publicnotice.htm
to become familiar with any changes that will affect your facility. Your COC will be automatically
renewed to cover the full 5 year term of the soon to be reissued permit. In the interim you must abide
by the terms of the expiring permit.
If you have any questions concerning this permit please contact Cory Larsen at telephone
number [phone] or cory.larsen(a)ncdenr.gov.
cc: Mooresville Regional Office
Central Files
Stormwater Permitting Unit Files
Attachments
Wetlands and Stormwater Branch
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: W N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: 919M7-64941 Customer Service: 1-877-623-6748
Internet: www,ncwaterquality.org
An EQual O000rtunity 1 Affim)ative Adon EmOloYer
Sincerely,
ORIGINAL SIGNED
BY
for Coleen Fi.lft'i�i
NorthCarolina
Naturally

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
. GENERAL PERMIT NO. NCG200000
CERTIFICATE OF COVERAGE No. NCG200463
STORMWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
KEYWELL LLC
is hereby authorized to discharge stormwater from a facility located at
Keywell LLC Air Vac Division
2826 Tophill Road
Indian Trail
Union County
to receiving waters designated- as South Fork Crooked Creek, a class C water in the Yadkin-
PeeDee 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 August 7, 2009.
This Certificate of Coverage'shall remain in effect.for the duration of the General Permit.
Signed this day August 7, 2009.
ORIGINAL SIGNED 8Y
KEN PCKLI~
for Coleen H. Sullins., Director
Division of Water Quality
By the Authority of the Environmental Management Commission

LOCATION MAP:
NCG200463
S .
AW Scala 1:20,000
� r >y., f �1.� .'.1 Ls� Y,p gi &"E„x1 r - �
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Keywell LLC Air Vac Diuisio I
�� �� �F'',I�' �1 .�� �� ♦ ems= iz � y_'
y y
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� l I r !:.�"da! pTi/""�'"�"h6`lJ�� • � --u�t ! rxl�,-µ-�'w c �ri<
iko,
Keywell LLC
Keywell LLC Air Vac Division
Latitude: 35° 03' 13" N
Longitude: 800 37' 11" W
County: Union
Recei,qing Stream: South Fork Crooked Creek
Stream Class: C
Sub -basin: 03-07-12 (Yadkin-PeeDee River Basin)
Facility Location

Larsen, Cory
From: Larsen, Cory
Sent: Wednesday, August 05, 2009 1:35 PM
To: Parker, Michael
Subject: RE- Keywell NGG20W3
think everyone just wants to have their paperwork lined up .... the owners are in Chicago. I would rather not have to
deal with them twice either buy I'll issue away. Thanks.
From: Parker, Michael
Sent: Wednesday, August 05, 2009 11:14 AM
To: Larsen, Cory
Subject: RE: Keywell NCG200463
I don't see any problem with going ahead and issuing them a permit now, but I also don't see why they couldn't wait and
just let us send them the revised permit when it becomes effective? It's not like we are going to sneak down there and
cite them for operating without a SW permit for the couple of months they will be in operation prior to the new permit
being effective??? Whatever.
Mike
From: Larsen, Cory
Sent: Tuesday, August 04, 2009 12:36 PM
To: Parker, Michael
Subject: Keywell NCG200463
Mike,
We were going to wait on this facility because NCG20 is going to renew soon (see my letter) but they called and it is a
new operation set to open up this month. Can I go ahead and issue? We'll have to send them the new permit in a
couple months once it is finalized.
Cory
Cory Larsen
Environmental Engineer
NCDENR j DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
E-mail correspondence to and from this address may be subject to the worth Carolina Public Records Law and r:tay.be
disclosed to third parties. ,

Dwo ftlf-. C.R.I. fl-fb-u P
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DWQ To Move
Internet Site To
The DENR Portal
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sed diam nonummy nibh euismod.
SPECIAL
ANNOUNCEMENTS:

NC®ENR
North Carolina Department of Environment and
Division of Water Quality
Beverly Eaves Perdue Coleen P. Sullins
Governor Director
July 28, 2009
Mr. Ronald G Gostek
Keywell LLC
11900 S Cottage Grove Ave
Chicago, Illinois 60628
Natural Resources
Subject: General Permit No. NCG200000
Keywell LLC Vac Air Division
COC No. NCG200463
Union County
Dear Mr. Gostek:
Dee Freeman
Secretary
The Division of Water Quality's Stormwater Permitting Unit (SPU) acknowledges receipt of your notice
of intent (NOI) for coverage under NPDES General Permit Number NCG200000 on July 20, 2009. General
Permit NCG20000 is in the process of being renewed and significant changes in the permit are anticipated.
We expect the final permit to be issued sometime in November of this year. You can review the proposed
general permit changes here: www.ncwaterquality.org/su/publicnotice.htm.
SPU has initiated review of your NOI application but will not issue a permit for this facility until
NCG200000 is finalized so as to limit potential non-compliance between the requirements of the current permit
and the new permit. No additional information is required at this time, but we may contact you in the future.
Please notify us if any significant changes have taken place at this facility since you submitted the renewal
package.
If you have any questions about this matter, please contact me at [phone] or at
[e-mail].
cc
Mooresville Regional Office
Stormwater Permitting Unit Files
Central Files
Wetlands and Stormwater Branch
1617 Mail Service Center, Ralegh, North Carolina 27699-1617
Location: 512 N, Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet www.ncw3terquality.org
An Equai Opportunity 1 Affirmalive Action Employer
Sincerely,
*Envir
• en
mental Engineer
Stormwater Permitting Unit
One
NorthCarolina
Naturally

I)CUbv `f&3
July 16, 2009
NCDENR
Division of Water Quality/Water Quality Section
RE. NCG 200000
To Whom It May Concern:
HEMELL
We currently conduct operations at 1163 Curtis Street, Monroe, NC 28112. Records will
show that we are in compliance. Our primary, local customer presented us with an
immediate opportunity to expand our business and we only received zoning approval this
week, hence the less than 180-day notice filing. A Storm Water Pollution Prevention
Plan is in the process of being developed and will be in place prior to operations.
Upon occupancy, all operations and material storage will be conducted in the warehouse
with no exposure of process or materials. Our processing operations do not require
process water usage or discharge. Within the next several weeks and months, we will be
installing shotblasters and a torch cutting emission control station concurrent with
approval of our pending permit application with NCDENR air quality.
Thank you for your understanding. Please call if you have any questions. si c
Regards,
Ronald G. Gostek
Senior Vice President, Corporate Services
te
0,s c'a
of Scrap
ISHI
Recycling
IIndustries, Inc..
BIR
KEYWELL L.L.C.
11900 5outn Cottage Grove Avenue
Chicago. 160628
[phone]
FAX [phone]