NCG200495_COMPLETE FILE - HISTORICAL_20130114

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO.
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DOC TYPE
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❑ MONITORING REPORTS
DOC DATE
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NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
Mr. Louis Gordon, Vice President
L Gordon Iron & Metal Company, Inc.
1300 Salisbury Road
Statesville, North Carolina 28037
Dear Mr. Gordon:
Division of Water Quality
Charles Wakild, P.E.
Director
January 14, 2013
John E. Skvarla, III
Secretary
Subject: General Permit No. NCG200000
L Gordon Iron & Metal Company, Inc.
COC No. NCG200495
Iredeil County
In accordance with your application for a discharge permit received on November 28, 2012, 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).
If any parts, measurement frequencies, or sampling requirements contained in this permit are
unacceptable to you, you have the right to request an individual permit by submitting an individual permit
application. Unless such demand is made, this certificate of coverage shall be final and binding.
Please take notice that this certificate of coverage is not transferable except after notice to the
Division of Water Quality. The Division of Water Quality may require modification or revocation and
reissuance of the certificate of coverage. This permit does not affect the legal requirements to obtain other
permits which may be required by the Division of Water Quality or permits required by the Division of Land
Resources, Coastal Area Management Act or any other federal or local governmental permit that may be
required.
If you have any questions concerning this permit, please contact Bill Diuguid, Stormwater Staff
Planner at telephone number [phone].
Sincerely,
ORIGINAL SIGNED BZ
KEN PICKLE
Charles Wakild, P.E.
cc: Mooresville Regional Office
Central Files
Stormwater Permitting Unit Files
Attachments
Wetlands and Stormwater Branch
1617 Mai! Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St Raleigh, North Carolina 27604
Phone: [phone] t FAX [phone]
Internet: www.ncwaterquality.org
An Equal Opportunity 1 Affirmative Action Employer
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.NorthCarolina
;Vaturallry

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG200000
CERTIFICATE OF COVERAGE No. NCG200495
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,
L Gordon Iron & Metal Company, Inc.
is hereby authorized to discharge stormwater from a facility located at
L Gordon Iron &: Metal Company, Inc.
735 Monroe Street
Statesville
Iredeil County
to receiving waters designated as an unnamed tributary to Third Creek, a Class C waterbody, Yadkin River Basin; in
accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, 111, 1V,
V and VI of General Permit No. NCG200000, as attached.
This Certificate of Coverage shall become effective January 14, 2013.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day January 14, 2013.
ORIGINAL SIGNED 131
KEN PICKLE
Charles Wakild, A.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

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March 11, 2011
Mr. Louis Gordon, Vice President
L. Gordon Iron & Metal Company
Post Office Drawer 1192
Statesville, NC 28687
Subject: Technical Site Visit
L. Gordon Iron & Metal Company
Certificate of Coverage No. NCG200363
Iredell County
Dear Mr. Gordon:
On March 8, 2011, a site visit was conducted at the subject facility by representatives of the
Division of Water Quality's Mooresville Regional Office and Raleigh Central Office for tine purpose of
evaluating existing site conditions and to offer suggestions that may improve the ability of L. Gordon
Iron & Metal (the Company) to comply with the benchmark levels established in the subject Certificate of
Coverage. Representing the Regional Office were Michael Parker and Rob Krebs, and representing the
Central Office were Michael Randall and Ken Pickle. Mr, Scott Powell with L. Gordon Iron & Metal
accompanied DWQ staff during the site visit.
As DWQ staff toured your facility, there were a number of observations made by both Regional
and Central Office staff that should be considered as you look to improve your stormwater (SW) runoff
quality. Some of these suggestions may require you to re-evaluate existing facility operations and others
may be as simple as re -locating potential contamination sources away from nearby stormwater
conveyances. As mention above, there were a number of areas identified during our visit where site
improvements may ultimately enhance your ability to contain and/or remove pollutants from your
stormwater. These suggested site improvements are listed below and are in no specific order:
First and foremost, it is important that you identify where the stormwater pipe located adjacent
to the railroad tracks and just west of the Warehouse outlets. This pipe appears to receive SW
from. existing outfalls 004, 005, 006, and 007, which drain a substantial portion of the SW from
your site. If this pipe outlets into the junction box designated as outfall 009 on your site drawing,
then it may be possible to route a substantial portion of your site's SW through a redesigned BMP
that would be constructed behind the non-ferrous storage area. This BMP would also continue to
receive SW from facility operations associated with the storage bins. In reviewing recent SW
sampling data, high TSS values highlight the multiple benchmark exceedances, so some type of
pre-settlung design such as fore bays, coarse or multiple settling chambers, or even dual train
configurations maybe necessary to achieve the desired results. Bear in mind any structural BMP
measure should focus first on the amount of TSS to be removed, however, consideration should

Mr. Louis Gordon
March 11, 2011
Page Two
also be given to the frequency of cleaning and maintenance and access. Hopefully, the removal
of TSS will also affect a significant fraction of the metals, however, you won't really know until a
TSS removal plan is implemented. If you can contain/ remove the TSS, you may see additional
benefits such as the lowering the concentrations of your other benchmark parameters.
As mentioned to you in our post tour discussion, of all the suggestions that came out of this visit,
the most important observation from an analytical testing standpoint is to try to bring your total
number of stormwater outfalls you are sampling down from the seven (7) you are currently
sampling to a more manageable two or three. If this can be accomplished, and you are able to
install some type of engineered Best Management Practice (BMP) on the remaining outfalls, a
significant reduction in the pollutants found in your stormwater may be possible. Based on
observations made during the site visit, the combining of outfalIs 004, 005, 006, 007 (and possibly
008) into outfaI1003 would bring you down to two outfalls.
Housekeeping is also problematic at this site. There were a number of areas where potential
contamination sources were noted at or near site boundaries that could be eliminated with some
general housekeeping. The area draining behind the bins adjacent to outfall 008 and 009 could be
cleaned up and the area stabilized with vegetation, which may improve SW quality. Stockpiled
materials along Salisbury Road near the Auto Storage area and down closer to the Office near the
storage trailers should be moved away from the site perimeter and a vegetated berm established
to prevent off -site SW migration. There were also a lot of barrels and containers located at
different points throughout the site that of themselves present potential SW risks. The barrels
and containers should be identified, characterized, and either recycled or consideration given to
locating them underneath roofs or in areas where SW contact is minimized. As required by your
permit, your Stormwater Pollution Prevention Plan (SPPP) should identify all potential pollutant
sources and describe any attempts to eliminate or minimize their exposure. If bottom access of
your ferrous and non-ferrous storage piles (as well as other stacked material piles) is not
necessary, something as simple as placing hay bales on the downstream (lower) side of the piles
may provide effective TSS containment. Wire mesh baskets placed in the inlet drains may
produce some TSS removal, however, this will not address the root source of the TSS and will
likely not prevent future TSS Benchmark exceedances. DWQ staff are of the opinion that
operational changes (ie. relocation of contaminant sources, moving some sources under roof,
berming or securing problematic materials from SW contact, etc.,) may go much further than
BMP construction in getting your SW back to below benchmark values. The Company should
also encourage their employees to Iook for ways to improve SW pollution awareness and
prevention. You may find that your employees have suggestions on both operational and site
improvements that will improve SW quality.
A site survey, complete with topographic constraints, property lines, top of inlets, bottom of catch
basins, and gravity pipe inverts should be prepared. The survey should also follow the DOT
ditch line in the front of the property to its ultimate receiving water so the Company will know
where their SW goes once it leave the property line.

Mr. Louis Gordon
March 11, 2011
Page Three
Oil/water separator maintenance is vital if compliance with the permit is to be achieved. The
oil/water separator that discharges at outfall 008 has established an area of oily residue on the
rocks immediately below the discharge pipe suggesting that routine maintenance/cleaning is
minimal, at best. Although the current discharge location is permissible, it is suggested that in
the future the discharge from this device be routed into the BMP to be constructed just above
outfall 003. It may be necessary to relocate this separator to achieve this action, but this discharge
is Iikely to be problematic with regards to compliance as long as it remains in its present location.
The SPPP requires that all oil/water separators be properly maintained and records kept of
maintenance and of pumping dates and quantity.
OutfaIl 001 is problematic in that it drains directly into your entrance road and follows the DOT
right-of-way down to a DOT drop inlet. A number of suggestions were made regarding
improvements in this area including stockpile relocation, moving nearby storage trailers and
material away from the area to eliminate potential pollutant sources, and the installation of some
type of settling device (possibly a drop inlet with cIean-out) constructed in the access road where
it joins Salisbury Road. Any construction in this area would require DOT approval, and they
should be brought into the discussion if and when you begin to address the off -site
contamination from this area.
These are just a few of the ideas that were generated during the tour of your facility. Obviously, a
more detailed site inspection by individuals familiar with industrial SW operations such as yours will
help you characterize any changes deemed necessary and their effect on your facility's operation. As
suggested in our post tour discussion, you should look for a firm or individual familiar with industrial
SW treatment design when you are ready to begin the process of designing SW BMPs, especially with
the limited amount of area you have to work with and the complex waste streams typically produced
from salvage yard sites. As you begin this process, this Office is prepared to offer our assistance in your
efforts to achieve compliance with current permitted benchmark values. In the meantime, you should
continue to monitor your SW at the locations and frequencies identified in the subject permit, which will
help establish a baseline for evaluating the efficiency of BMP construction and operational changes.
If you have any questions or comments concerning this letter, please contact Mr. Parker or me at
[phone].
Sincerely,
Robert B. Krebs
Regional Supervisor
Surface Water Protection
cc: Bradley Bennett

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6937
NC DENR - DIV OF -WATER 4UALIT',Y'
Vendor # NCDH2O
INV NO TP ENV DATE GROSS-AMT DISC AMT NET AMT'DESCRIPTION
116017-DI '11/26/12 100.00 .00 100.00
VENDOR NCDH2O 100.00 0.,00 100.00 CHK# 006937 DATE 11/26/12
Date: 11/26/12
Ci eck. No: 006937
GoTdon.Ite[yclers'Inc BANK OF AINERICA"
STATESVILLE, NORTH CAROLINA T- 693�
dba .L._ Gordons[ron:'Arid Metal Co.' . `
PO. Driwer1192 66-19/53D NC 006937.
uv Statesvt[fe North Cwollna - 28687
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fax [phone] - - - -- ° DATE _ AMOUNf
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PAfY EXACTLY Or eWundred aiid 00%900 Dollars
DAY
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NC DENR DIV OF WA TER QUALITY Check Vaid After 60 Days
STO_ RMWATER PERMIT UNIT
9617 MAIL -SERVICE CENTER . ¢�,a�
RALEIGH,NC_2769974617 ' ..
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