NCG200516_Tier Relief_20191220

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
IMET Alloys
Attention: Mike Oruska
300 Stitt St, Suite 150
Monroe, North Carolina 28110
Dear Mr. Oruska:
NORTH CAROLINA
Environmental Quality
December 20, 2019
Subject: Relief from Monthly Monitoring
Stormwater Permit # NCG200516
IMET Alloys, Inc
Union County
We are in receipt of your August 20, 2019 letter requesting relief from monthly
monitoring at the IMET Alloys Monroe facility. Based on past site inspections, the facility is
in compliance with the tiered response actions and other conditions of the NCG200000
General Permit. Therefore, the Division is granting regulatory relief from the Tier
responses. Upon receipt of this letter, the subject facility may resume the permit specified
semi-annual analytical monitoring for the remainder of the current permit term which
expires on May 31, 2024. This decision applies only to the copper and zinc benchmarks. A
benchmark exceedance of any other parameter listed in your permit will trigger the tiered
response actions as described in the general permit.
You must notify this office, in writing, within five business days if you become
aware of any other significant source of zinc or copper at your facility that has the
potential to be exposed to stormwater. The relief granted in this letter is contingent
upon the current industrial practices at [MET Alloys Monroe facility. Please retain and
append this letter to your Stormwater Pollution Prevention Plan (SPPP) or permit. If you
have any questions or comments concerning this letter, please contact me at 704-663-
1699.
Sincerely,
rZahid S. Khan, CPM, CPESC, CPSWQ
Regional Engineer
Land Quality Section
cc: Stormwater Laserfiche
North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
�� Mooresville Regional Office 1 610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115
ORT NH C:AROURMA
a d F /"� 704.663.1699

Via Email
August 20, 2019
NCDEQ/DEMLR/LQ
Mooresville Regional Office
610 East Center Avenue, Suite 301
Mooresville, NC 28115
Attn: Ms. Lily Kay, CSI
Re: Tier II Sampling Status
IMET Alloys (COC #200516)
Monroe, NC
H&H Job No. IME.002
Dear Ms. Kay:
ENVIRONMENTALSMARTER . e
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As of January 2019, Hart and Hickman, PC (H&H) has been contracted by IMET Alloys (IMET)
to monitor and sample their one stormwater outfall in accordance with their stormwater permit.
During this time, H&H has collected a sample from Outfall-1 on a monthly basis in accordance
with their Tier II status due to copper and zinc concentrations that exceeded the NC DEQ permit
benchmarks.
On February 12, 2019, you conducted a site inspection and made recommendations to do site
improvements, and also to collect rainfall, roof runoff, and down spout background samples in an
effort to determine the source of the copper and zinc exceedances. The site improvements, such is
improved housekeeping, have reduced the zinc concentrations to below NCDEQ benchmarks, and
the copper concentrations have also been reduced from these improvements. Copper
concentrations were below the State's benchmarks for two consecutive months (before the recent
July 2019 sampling event) while zinc has three consecutive below benchmark readings (including
the July 2019 sampling event).
2923 SouthTryon Street, Suite 100 3921 Sunset Ridge Rd, Suite 301
Charlotte, NC 28203 Raleigh, NC 27607 wwwr.harthickmenxorn
70-4. $6, 0107, train 919.847.4241 main

Ms. Lily Kay, CSI
August 20, 2019
Page 2
The roof runoff background sample indicated that it is contributing to metals in stormwater. The
roof runoff sample contained copper (0.0106 mg/L) which exceeds the NCDEQ permit benchmark
of 0.010 mg/L. The last Outfall-1 sample that was collected in July 2019 indicated a result of
0.0115 mg/L for copper, while zinc remained below benchmark value. H&H has also collected
samples from a culvert that feeds Outfall-1 in an effort to determine the source of the copper. This
culvert carries water from the roof runoff and also off -site water. These results also show copper
results that are similar to Outfall-1.
Based on the roof runoff and the culvert sampling, the copper results appear to be elevated from
the roof runoff. Further, the July 2019 copper concentration at Outfall-1 is essentially the same as
the benchmark. Therefore, based on the site improvements and low copper detections near
background levels and the benchmark, H&H requests that IMET Alloy be moved from their
current Tier II status to Tier I status.
In anticipation that NC DEQ will approve this request, H&H plans to discontinue monthly Tier II
sampling at IMET Alloy at this time. However, if DEQ desires that IMET to continue monitoring
on a monthly basis, please do not hesitate to contact me. We look forward to your response.
Sincerely,
Hart & Hickman, PC
Matt Bramblett, PE
Principal Engineer
cc: Mr. Mike Oruska, IMET (via email)
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SAAAA-Master ProjectsUmet Alloys\MIE-002 Stormwater Monroe\Final to Client\Letter on Copper and Tier ii.docx
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