NCG200362_COMPLETE FILE - HISTORICAL_20180228

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO.
/V UO3�
DOC TYPE
❑*4FIISTORICAL FILE
❑ MONITORING REPORTS
DOC DATE
❑�
YYYYMMDD
Xv

Joyner, Melissa
From: Winegar, James <[e-mail]>
Sent: Friday, December 28, 2018 2:51 PM
To: Joyner, Melissa
Cc: LaBounty, Tim L
Subject: [External] RE: OmniSource Southeast, LLC - Raeford Notice of Violation
Attachments: 12-28-18 NOV-2018-PC-0451 Response.pdf
Attached is our response to NOV-2018-PC-0451.
Let me know if there are any questions...
Thanks,
James Winegar
Environmental Manger
919,989.3102 - work
919.796,3023 - cell
From: Joyner, Melissa[mailto:[e-mail]]
Sent: Friday, November 30, 2018 4:16 PM
To: Winegar, James
Subject: [External] OmniSource Southeast, LLC - Raeford Notice of Violation
NOTICE: The email below is from a sender external to Steel Dynamics, Inc or its subsidiariesPl . ease use caution when
opening attachments or clicking on links contained in this email r-
Dear Mr. Winegar:
Our records show that you should receive a copy of the attached correspondence in reference to the
above project. A hard copy of this Notice of Violation is also being sent to you. Please feel free to contact me or
Tim LaBounty with any questions at [phone],
Melissa Joyner
Environmental Specialist
Division of Energy, Mineral and Land Resources
Department of Environmental Quality
[phone] office
melissa.ioyner(ancdenr.gov
225 Green Street, Suite 714
Fayetteville, NC 28301-5043

EL F.7TI@
='Ncthing Compares
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

'1I0 Onmisource
5 0 J T H E A S T
VIA F'lecrr7rric Dclirerr
December 28. 2018
Timothy L. La OI.11ity. Rcgloiial l;ngineer
North Carolima Department cif i atyironmental Qrr:llity
FRO --- Division of 1 ncray. b]incral and Lund R sources
225 Green St.. Suite 714
Favetteville. NC 28301
RE: Response to Notice ol'Violation (NOV-2018-11C-0=15i )
MIMS Gencral Pcrnlil I'CG200000J'C0C' NU1200362
Dear NIr. LaBounty:
72 1.1 Wal-par Road
Smithfield. NC 27377
ph: 919,989. 3.102
Fax: 919.989, 3462
In response to the NNOV i NOV-2018-11C:'-045 I ) isstrcd in 01.11- Rtleti�rd facility (NC67-0) 362) can November
21). 2018. 1 am providing the (ollowinu,:
Qualitative 'Monitoring — \Vc did not document Qualitative N-Ionitoring during Tier 11 sampling
events as required. This was ;imply all oversight on our part and we gill doclnl ew this data from
here 161-ward.
Analvtical Monitoring — We feel that Nve have conducted analytical rLN-Ionitoring per the
rcquirerrlems ot* the permit. Specitic,911y. monthl", monitoring, has becn curlulucted for, all
parameter; at ally outfall which cxcc;edcd a benchillark value in taw coii,ecutive wonitorinL,
periods, as det'ined in Table.'_.
As with talc rrccnt inspeclion of our Fayetteville facility. we iM that nloat ot- the issues noted in this
report are due ]n diff'erillU interprcrttimm ol'thc perm t requircillellta. TO elar-itV thcsc- is;ucs. l would like
to requcst a rltcetinu in FaVetteVidle. at your ccinvenience. You may colijact the via phone [phone])
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OMNISOURCE SOUTI4EAST -LLG `
ATTN-. JAMES B. WINEGAR, ENV. MG � ����
2233 WAL-PAT ROAD DEC 1
SMITHFIELD, NC 27577
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Permit: NCG200362
SOC:
County: Hoke
Region: Fayetteville
Contact Person: Steve Smith
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Compliance Inspection Report
Effective: 02/02/15 Expiration: 12/31/19 Owner : Omnisource LLC
Effective: Expiration: Facility: OmniSource Southeast, LLC - Raeford
303 S Magnolia St
Raeford NC 28376
Title: Phone: [phone]
Certification:
Phone:
Inspection Date: 11/06/2018 Entry Time: 09:40AM Exit Time: 10:35AM
Primary Inspector: Melissa A Joyner 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: ❑ Compliant Nat Compliant
Question Areas:
Storm Water
(See attachment summary)
Page: 1

Permit: NCG200382 Owner - Facility: Omnisource LLC'
Inspection Datec._11/061201S._ Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Melissa Joyner met with Mr. James Winegar, Environmental Manager and Steve Smith, YD 60 Manager at the OmniSource
Southeast - Raeford facility. The Stormwater Pollution Prevention Plan was orderly, containing the information required by
General Permit NCG200000. The Analytical and Qualitative monitoring forms were reviewed. The benchmark value for two
consecutive samples of Copper was exceeded in June and August 2015. Monthly monitoring for Copper was initiated in
September 2016. The other parameters were not monitored monthly until May 2017. In December 2017, exceedances of
benchmark values for Total Suspended Solids (TSS), Lead and Zinc were also noted. In July 2018, TSS and Lead were not
sampled. After July 2018, no additional monitoring was conducted. The facility is currently in Tier Three due to more than
four exceedances of benchmark values of Copper and four exceedances of Zinc. Qualitative Monitoring was conducted
semi-annually and was not increased to a monthly basis after the facility was in Tier Two. Analytical and Qualitative monthly
monitoring will need to be conducted until there are three consecutive sample results below the be value. Sampling
periods when no sampling is able to be conducted does not count. If a new permitting cycle begins, the facility is still
required to do monthly monitoring until the Tier Three response obligations are met. A report should be submitted to this
Office in regards to the evaluation of the measures as applicable under Tier Three.
The facility has one outfall. Slag is being used as a filter at the mouth of the outfall. It had been impacted by recent storm
events and was in need of maintenance. There were scrap pieces of metal and dirt on the ground near the drop inlet which is
associated with the outfall. Maintenance is necessary as well as the installation of additional protective measures.
Page: 2

permit: NCG200302 Owner- Facility:Omnisource LLC
Inspection Date: 11106I201a •., Inspection Type : Compliance Evaluation Reason for Visit: . Routine
Stormwater Pollution Prevention Plan
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?
# 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:
Yes No NA NE
0 ❑ ❑ ❑
®❑❑❑
®❑❑❑
■❑❑❑
e❑❑❑
■❑❑❑
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■❑❑❑
■❑❑❑
0 ❑ ❑ ❑
0 ❑ ❑ ❑
0 ❑ ❑ ❑
0 ❑ ❑ ❑
■❑❑❑
■❑❑❑
Qualitative Monitoring
Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ❑ 0 ❑ ❑
Comment: Qualitative Monitoring has been occurring semi-annually, but when the facility came under Tiers
Two and Three Qualitative Monitoring was not initiated on a monthly basis.
Analytical Monitoring
Has the facility conducted its Analytical monitoring?
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
Yes No NA NE
❑®❑❑
❑ ❑ 0 ❑
Comment: Analytical Monitorinq was initiated on a monthly basis after benchmark exceedances•of Copper
It was only initiated for Copper and not for all of the required parameters_ until. May 2017. Monthly_
monitoring of all parameters ceased after 7/30/2018 although exceedances have continued.
Permit and Outfalls Yes No. NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? 0 ❑ ❑ ❑
# 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? 0 ❑ ❑ ❑
Comment:
Page: 3

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Path: SAEAMPONl2011026416411031 OmnlSOurea SE NC FaeffifiosIPoefordlfiguros%sffo plan.mxd

NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory Donald R. van der Vaart
Governor Secretary
August 26, 2015
OmniSource Southeast.
Attn: James B. Winegar, Environmental Manager
2233 Wal-Pat Road
Smithfield, NC 27577
Subject: COMPLIANCE EVALUATION INSPECTION
OmniSource Southeast
OmniSource Southeast, Certificate of Coverage-NCG200362
NPDES Stormwater General Permit-NCG200000
Cumberland County
Dear Mr. Winegar:
On August 12, 2015, Melissa Joyner from the Fayetteville Regional Office of the Division of Energy, Mineral
and Land Resources conducted a site inspection for the OmiSource Southeast facility located on 303 South
Magnolia Street, Raeford, Hoke County, North Carolina. A copy of the Compliance Inspection Report is
enclosed for your review. Steve Smith , YD 60 Manager was also present during the inspection and his time
and assistance is greatly appreciated. The site visit and file review revealed that the subject facility is
covered by NPDES Stormwater General Perm it -NC G200000, Certificate of Coverage-NCG200362 Permit
coverage authorizes the discharge of stormwater from the facility to receiving waters designated as Town of
Raeford storm sewer system and Peddlers Branch, a class C stream in the Cape Fear River Basin.
As a result of the inspection, the facility was found to be fully in compliance with the conditions of the
NCG200000 permit. Please refer to the enclosed Compliance Inspection Report for additional comments and
observations made during the inspection.
Please be advised that violations of the NPDES Stormwater General Permit are subject to a civil
penalty assessment of up to $25,000 per day for each violation. If you or your staff has any questions,
comments, or needs assistance with understanding any aspect of your permit, please contact Melissa Joyner
or myself at [phone].
Sincerely,
Melissa Joyner
Environmental Specialist
Land Quality Section
Enclosure: Compliance Inspection Report
cc: Steve Smith, YD 60 Manager - OmniSource Southeast (email)
FRO - Land Quality Section, Stormwater Files-NCG200000
Division of Energy, Mineral, and Land Resources
Land Quality Section
Fayetteville Regional Office, 225 Green Street - Suite 714, Fayetteville, North Carolina 28301
Phone: [phone] FAX: [phone] Internet: http://portal.ncdenr,org/we,b/i
An Equal Opportunity I Affirmative Action Employer - 50% Recycled 110% Post Consumer Paper

Compliance Inspection Report
Permit: NCG200362 Effective: 02/02/15 Expiration: 12/31/19 Owner : Omnisource Southeast LLC
SOC: Effective: Expiration: Facility: OmniSource Southeast, LLC - Raeford
County: Hoke 303 S Magnolia St
Region: Fayetteville
Raeford NC 28376
Contact Person: Steve Smith Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Rep rosentative(s):
On -site representative James Winegar 919-989-3102
Related Permits:
Inspection Date: 0811212015 Entry Time: 08:30AM Exit Time: 10:00AM
Primary Inspector: Melissa A Joyner 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: Compliant Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page: 1

Permit: NCG200362 Owner- Facility:Omnisource Southeast LLC
Inspection Date: 08112/2015 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
The new permit for the facility became effective on January 1, 2015. The facility now has a Stormwater Pollution Prevention
Plan which does include a monthly stormwater facility inspection program. Qualitative and quantitative monitoring is being
conducted. This facility continues to not have to conduct analytical monitoring from vehicle maintenance areas because
they still do not meet the criteria for sampling.
There have been exceedances of the benchmark values noted during the last permitting period for COD, Copper, Zinc and
TSS. There have also been several monitoring periods where no sampling has been able to take place due to there being no
active stormwater flow at the outfall. A spread sheet has been maintained documenting these non -sampling events. Monthly
monitoring has not been initiated as a result of exceedances of the same parameters. If a parameter exceeds the
benchmark value, the facility is triggered into the Tier One response action category. If the next monitoring period results in
no sample being able to be taken due to no stormwater flow at the outfall and the following sample results in an
exceedance of the same parameter, this will trigger the facility into the Tier Two response category. The previous sampling
period when no sampling was able to be conducted does not count. When the permittee is in Tier Two, monthly monitoring
will need to be conducted until there are three consecutive sample results below the benchmark value. If a new permitting
cycle begins, the facility is still required to do monthly monitoring until the Tier Two response obligations are met. If during a
future inspection of the facility, the facility is in a Tier Two response category and monthly monitoring has not been
intitiated, a Notice of Violation will need to be sent to the facility for not fulfilling the Tier Two response Obligations.
Page: 2

Permit: NCG200362 Owner - Facility: Omnisource Southeast LLC
Inspection Dale: OW1212015 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 ❑ ❑ ❑
# Does the Plan include a General Location (USGS) map?
0 ❑ ❑ ❑
# Does the Plan include a "Narrative Description of Practices"?
0 ❑ ❑ ❑
# 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?
0 ❑ ❑ ❑
# 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)?
0 ❑ ❑ ❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
0 ❑ ❑ ❑
# Does the facility provide and document Employee Training?
E ❑ ❑ ❑
# Does the Plan include a list of Responsible Party(s)?
N ❑ ❑ ❑
# Is the Plan reviewed and updated annually?
0 ❑ ❑ Cl
# Does the Plan include a Stormwater Facility Inspection Program?
0 ❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
■ ❑ ❑ ❑
Comment:
Qualitative Monitoring
Yea No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? N ❑ ❑ ❑
Comment:
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? 0 ❑ ❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ ■ ❑
Comment:
Permit and Outfalls
Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? ❑ ❑ Cl
# Were all outfalls observed during the inspection? ❑ ❑ ❑
# 1f the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ E ❑
# Has the facility evaluated all illicit (non stormwater) discharges? 0 ❑ ❑ ❑
Comment:
Page: 3

. 'ti
Joyner, Melissa
From: Georgoulias, Bethany
Sent: Thursday, August 20, 201S 10:12 PM
To: Lawyer, Mike; Pickle, Ken; Bennett, Bradley
Cc: Joyner, Melissa
Subject: Re: Tier Two criteria
Thanks, Mike. We will follow up with guidance on this issue from Central Office and communicate it to the
Regions, as well as make it available on our website.
::
Bethany Georgoulias, Environmental Engineer
NCDENR / DEMLR / Stormwater Permitting Program
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury Street, Raleigh, NC 27604
919 / 807-6372 (phone); 9 19 / 807-6494 (fax)
Website: http://portai.ncdenr.org/web/ir/stornnvater
F.-malt correspondence to avid ftonr this address nray he subject to the Arth Carolki Public Recordv luir and may be disclosed to third parties.
From: Lawyer, Mike
Sent: Thursday, August 20, 2015 4:16 PM
To: Pickle, Ken; Georgoulias, Bethany; Bennett, Bradley
Cc: Joyner, Melissa
Subject: RE: Tier Two criteria
All,
Just to wrap up. We will be sending the facility a compliance inspection report (not an NOD or NOV) with comments
concerning the intent of the Tier Two condition that consecutive sampling/monitoring results with exceedances of the
same parameter at the same outfall trigger monthly monitoring. And that reported periods of no flow do not stay this
condition. Also, that any such scenario in the future will result in the issuance of an NOV for failure to comply with
permit conditions.
Thanks,
Mike
Michael Lawyer, CPSWQ
Environmental Program Consultant
NCDENR -- Division of Energy, Mineral and Land Resources
Land Quality Section
Fayetteville Regional Office

w
P: [phone]
F: [phone]
e-mail: [e-mail]
E-mail 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 regulation.
From: Pickle, Ken
Sent: Thursday, August 20, 2015 9:38 AM
To: Lawyer, Mike; Georgoulias, Bethany; Bennett, Bradley
Cc: Joyner, Melissa
Subject: RE: Tier Two criteria
Hi Mike,
[OK, while l was composing this it looks like BG and ML have wrapped up the topic. But, l want to send my summary
anyway, in the hope that it will be useful.]
OK, sorry to miss the key point. It sounds like we're all on the same page as to the overall structure of Tiers and permit
renewals. 5o, my much less wordy summary is this:
• We do not intend that 'No Flow' periods interrupt the count of exceedances. It's not like they are analytical
results of 'zero mg/L'. Per Two Twr o s triggered by the circumstance you describe, and monthly sampling should
have been carried over into the Feb 2015 permit term.
• Unfortunately the Tier 2 box language can be read differently; although I don't think that's the common sense
reading of it. We will be changing the language in newly issued permits to remove that possibility of confusion
henceforth.
• 1 do not recall the conversation with Mr. Winegar, and I cannot corroborate his report of the conversation;
there's no record of it; it is possible that I mistakenly advised him as he reports based on a narrow reading of the
wording in the Tier 2 box. (KBP opinion: it's also possible I advised him according to our discussions yesterday
and today, and his memory of the conversation got twisted in the intervening 10 months.)
0 DEMLR RO Action? Bradley previously advised that the RO could take Mr. Winegar's report of our
conversation at face value (or at least acknowledge the Tier 2 box language as confusing) and take no action
based on those two aspects. On the other hand, my impression is that Mr. Winegar is a sophisticated
environmental professional working for one of the big boys in his industry sector: by which I suggest he might be
expected to understand the purpose and thrust of the permit as a whole, contrary to the idea he is putting
forward now.
o KBP opinion., Ultimately I rely on the fact of the potentially confusing language in the Tier Two box to agree with
Bradley: the RO should consider letting this pass. With an explicit explanation and warning in the inspection
report letter.
Thanks Mike for the always helpful and challenging feedback from the real world.
Ken
From: Lawyer, Mike
Sent: Thursday, August 20, 2015 8:44 AM
To: Pickle, Ken; Georgoulias, Bethany; Bennett, Bradley
Cc: Joyner, Melissa
Subject: RE: Tier Two criteria
Ken,

Thanks, as always, for your detailed and thorough response. The way you've outlined the various scenarios wrt the
tiered response actions is exactly how I've understood them to be. I think I must have left out something or
misrepresented the situation with OmniSource. First, the monitoring scenario I presented in my initial e-mail was sim
an example and not representative of actual events. jTThe issue/question with the OmniSource facility is whether or n
they should have been triggered into Tier Two monthly monitoring based on sampling events with exceedances for t
same parameter interrupted by reports of 'No Discharge' within the previous permit,cycle, which would have then
carried over into the current permit cycle that began in February 2015.
Michael Lawyer, CPSWQ
Environmental Program Consultant
NCDENR — Division of Energy, Mineral and Land Resources
Land Quality Section
Fayetteville Regional Office
P: [phone]
F: [phone]
e-mail: [e-mail]
E-mail 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 regulation.
From: Pickle, Ken
Sent: Wednesday, August 19, 2015 6:53 PM
To: Lawyer, Mike; Georgoulias, Bethany; Bennett, Bradley
Cc: Joyner, Melissa
Subject: RE: Tier Two criteria
Ni Mike,
Ni Bethany — would you double check this, please? Correct me if I have garbled any of it, please.
As you say, Mike, previously, the January 1, 2010 version of NCG20 in the Tier Two box did limit the trigger for Tier 2 to
consecutive exceedances by saying, "During the term of this permit...." As you say, we removed that because it was
potentially limiting for us and confusing to all. We tried to simplify by removing that language from the Tier 2 box, and
by further fine tuning in Footnote 1 to Table 1 in 2015. Our objective was to get our permittees to understand that they
couldn't avoid their obligation for monthly sampling because of permit renewal.
As I read the General Permit today, I think the relevant language in the February 2, 2015 version of NCG20 is from Table
1 Footnote 1:
• "Measurement Frequency: Twice per year (unless other provisions of this permit require monthly sampling) during a
measureabie storm event, until either another permit is issued for this facility or until this permit is revoked or
rescinded, If the facility is monitoring monthly because of Tier Two or Three response actions under the previous
General Permit the facility shall continue a monthly monitoring and reporting schedule in Tier Two or Tier Three status
until relieved by the provisions of this permit or the Division."
So, for the two COD exceedances at OmniSource what we have in 2014 and 2015 are exceedances under two
different versions of NCG20. The exceedance in Jan —Jun 2014 triggered Tier One; and the subsequent No
Flow did not trigger anything more or less. So, at the end of the term of the 2009/2010 permit the facility was in
Tier One for COD. Note that per the footnote, it's only Tiers 2 and 3 where any monthly monitoring carries
forward. The 2010 version did not speak to a continuation of the obligation or of the count. If anything, it
seemed to limit the count and subsequent response action to only during the term of the permit.

s
And for the COD exceedance in Jan — Jun 2015 Tier One was triggered again. Notice the footnote above
establishes only that if the permittee is already into monthly monitoring, he has to continue under his
obligation. Until he's out of the Tiers altogether, according to the Tier 2 text box by having three consecutive
below benchmark monthly results; or until he is out of it and into Tier Three, according to the Tier 3 text box, by
having two more exceedances for a total of four.
Last comment on_this _approach: We constructed the permit like this in part with an eye towards Tier 3 being triggered
by any four exceedances. We were looking for the best approach to answering the question, "Well, you say we're in Tier
3 after four exceedances. Do you mean four exceedances ever? Or just in the last 10 years? Orjust in the last permit
cycle?" We felt it was unfruitful to go back very far in counting exceedances for Tier 3. So, we considered a couple of
alternate scenarios, but picked what seemed a simple time frame: 4 exceedances during the 5-year permit term. So,
with the Tier 3 trigger tied to a count that re -starts with each permit term, it seems to hang together to impose the
same time frame on the other Tiers. The count starts over, but any obligations incurred continue until fulfilled.
As to „ how new is this approach: per NCG20 we did not speak directly to continued monthly sampling in the Jan 1, 2010
._....
permit but we did in Feb 2, 2015. For the batch of four permits issued in 2014 only three (NCG16, NCG17, and
NCG18) contained analytical monitoring requirements, and all of them included the changes as per the 2015 version of
NCG20. For the batch of five permits issued in 2013 (NCG05, NCG07, NCG11, NCG13, and NCG21) all had similar
changes to the vehicle monitoring section and process stormwater section (NCG21, only). For the batch of six permits
issued in 2012 (NCG03, NCG06, NCG08, NCG09, NCG10, NCG12) none contained requirements related to continued
monthly sampling under Tiers 2 and 3 at permit renewal. So, it looks like we began to clarify that Tiers 2 and 3
continued on into the next permit cycle with the batch of General Permits in 2013.
My summary of our intent and our permits as I understand them now:
If the analytical results trgg_er Tier 1, the permittee must execute the Tier 1 response actions, even if the timing
is such that those actions would occur during the new permit term. The new permit re -starts a new, separate
count.
If the analytical results trigger Tier 2, the permittee must execute the Tier 2 response actions, even if the timing
of monthly sampling would occur during the new permit term. The new permit re -starts a separate count, but
the permittee must still fulfill the prior permit Tier 2 requirement. I'm making a distinction between the
fulfillment of an obligation incurred under a valid past permit, and the restarting of a separate count under the
new permit.
If the analytical results trigger Tier 3, the permittee must contact the Regional Office, and must execute the Tier
3 response actions as directed by the Regional Office, even if the timing of those actions would occur during the
new permit term. I anticipate that the Regional Office can provide a wide range of directions as to sampling
frequency: everything from "We are going to keep you in Tier 3status, please continue to sample monthly until
enough data is in hand to help us determine what's going on at your site" to "you may drop out of the Tier 3
status and go back to twice per year sampling as per your new permit."
In the present case revolving around COD it seems to me the key issue is that the two exceedances under two
different permit versions did not trigger Tier Two, because the count starts anew with the new permit.
Circling back to the beginning: It's possible that Mr. Winegar has accurately reported our conversation, that I told him
that "consecutive monitoring periods" would mean an intervening No Flow followed by another hit would not trigger
Tier 2. 1 don't think it's likely I said that, but I do not remember it. But he's off the hook by this analysis above even if I
did fail last year to accurately and consistently report our present interpretation of the permit text. I retract my slight
preference for an NOV/NOD from earlier this morning.
Ken

From: Lawyer, Mike
Sent: Wednesday, August 19, 2015 1:44 PM
To: Pickle, Ken; Georgoulias, Bethany; Bennett, Bradley
Cc: Joyner, Melissa
Subject: RE: Tier Two criteria
Please see inserted comments in red below...
Michael Lawyer, CPSWQ
Environmental Program Consultant
NCDENR — Division of Energy, Mineral and Land Resources
Land Quality Section
Fayetteville Regional Office
P: [phone]
F: [phone]
e-mail: [e-mail]
E-mail 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 regulation.
From: Pickle, Ken
Sent: Wednesday, August 19, 2015 12:45 PM
To: Lawyer, Mike; Georgoulias, Bethany; Bennett, Bradley
Cc: Joyner, Melissa
Subject: RE: Tier Two criteria
Hi Mike,
I have no problem with your approach to investigating Mr. Winegar's report, so I'm ok on that point.
Perhaps more to the point than what I can't remember, or more to the point than "he said, she said": I note that
NCG20 was renewed in February 2015. That would make his COD exceedance in Jan -Jun 2015 the first exceedance of
the new permit term. With some circumstantial exceptions, we are now implementing a general policy that the
exceedance count starts over with each 5-yr renewal (Neither the text of the 2009 permit nor 2015 permit speaks
directly to this policy, however.) —Is this a new policy/change in previous policy? I distinctly remember having
discussions with CO and RO staff about this (perhaps during a consistency meeting) and it being decided that Tiered
response actions would continue through/after permit renewal, which is why the phrase `During the term of this
permit...' was removed from the Tier text boxes from the previous permit cycle. He does not have two consecutive
exceedances, he has one in the 2009 version of the permit, and one in the 2015 version. --According to Mr. Winegar,
there have been multiple exceedances for various parameters throughout the previous permit cycle, but there always
seems to be a period or two of 'No Discharge' in between the sampling events with exceedances. Based on everyone's
response about the intent of the permit, the facility would have been in Tier Two monthly monitoring at some point
during the last permit cycle. However, this would be a moot point if we are now (or have been) implementing the
above policy where the exceedance count starts over upon permit renewal. No basis for a Tier 2 status, yet. {lust a
guess: Perhaps in Mr. Winegar's memory this re -setting of the count got twisted into "No Exposure" counts as a
monitoring event or some other rationale that told him it's not Tier 2.)
Other background on the question of what I may have told Mr. Winegar.

6
Mr. Winegar and I have had a very few (<5) conversations over the years, and I recognize OmniSource as a scrap metal
recycler, presumably covered under NCG20.
I do not recall this conversation. Did he report that I sent a confirming email? —1 asked him if he had anything in writing
including an e-mail from you to which he responded no. I usually volunteer to follow up on such conversation with a
confirming email, but sometimes I don't. It's possible that there was such a conversation and I have forgotten it. It's
also possible we had a conversation more or less on this topic and Mr. Winegar has lost some of the details of it in the
10 months that have passed. If we had such a conversation, I have lost all of the details of it in the last 10 months.
However, presuming a conversation in September/October 2014, 1 note that while such a conversation could have
included the specifics of a COD exceedance in the first half of 2014, it could not have included the specifics of a "No
Flow" report in the second half of 2014 or a follow up COD exceedance in the first half of 2015. So, we absolutely did
not have a conversation about his two COD exceedances in the September/October 2014 period, or about whether No
Flow counted towards the consecutive monitoring periods count.
Without these other specifics, I suppose our discussion could have been just about the language in the permit, with no
specific bearing on Mr. Winegar's not -yet -established circumstances at the permitted site. So, a non-specific
conversation about the language of the permit, without the COD information, could have taken place. I do not
remember it, however. If indeed he called me to point out and ask about the language that says, "consecutive
monitoring periods", it's coincidental that he subsequently has been the only one to bring it up and actually rely on that
interpretation.
To be fair, and as I indicated in my earlier response this morning, I can see that the text might be interpreted as Mr.
Winegar reports. I can only trust that if there was a conversation on this point ! would have been quick to point out that
our interpretation is that two consecutive results establish Tier2, and the No Flow response does not allow you to claim
results were not consecutive.
So, I would hesitate to contradict Mr. Winegar, but I cannot corroborate what the contents of the conversation were, or
even that the conversation occurred. I find no record of it in my saved emails, but again I don't always make such a
record.
I worked on the renewal of NCG20 in October, November, and December 2014. We received only one set of public
comments on NCG20, and I find no notes in the 2014/2015 GP renewal file indicating a comment on the Tier 2 language.
Ken
From: Lawyer, Mike
Sent: Wednesday, August 19, 2015 10:40 AM
To: Pickle, Ken; Georgoulias, Bethany; Bennett, Bradley
Cc: Joyner, Melissa
Subject: RE: Tier Two criteria

-1
Ken,
Thanks for your input. Now that you have also responded, here comes the kicker in this particular situation. Please note
that 1 purposefully left the following information out of the discussion until now so as not to sway anyone's thoughts on
the matter. The facility is OmniSource in Hoke County and the facility contact, Mr. James Winegar, claims that he had a
conversation with you back in September/October about this very situation. He further claims that you relayed to him
that, based on the permit language, the facility would not be triggered into Tier Two monthly monitoring. I was
wondering if you would recall this and bring it up in your response. My apologies for the somewhat underhanded way of
investigating this claim, but I'm assuming that either you never even had such a conversation with. Mr. Winegar or
perhaps don't recall the conversation that took place almost a year ago. Can you validate Mr. Winegar's claim? We were
set to issue the facility an NOV for failing to comply with the TierTwo permit condition. When Melissa called Mr.
Winegar on Monday to inform him about the forthcoming NOV, he claimed he had spoken with you about this and that
he was following the permit as it is worded. With such a claim, we decided to hold off on our inspection report/NOV
until we could verify both his claim as well as the intent of the permit.
Again, my apologies to all (especially you Ken) for initially leaving out the information above, but I hope you can
understand why I did.
Michael Lawyer, CPSWQ
Environmental Program Consultant
NCDENR -- Division of Energy, Mineral and Land Resources
Land Quality Section
Fayetteville Regional Office
P: [phone]
F: [phone]
e-mail: [e-mail]
E-mail correspondence to and from this address is subject to the North Carolina Public Records taw and may be
disclosed to third parties unless the content is exempt by statute or other regulation.
From: Pickle, Ken
Sent: Wednesday, August 19, 2015 10:00 AM
To: Lawyer, Mike; Georgoulias, Bethany; Bennett, Bradley
Cc: Joyner, Melissa
Subject: RE: Tier Two criteria
Friends,
Thanks for copying me on this email string.
• I concur with the proposed, revised, sharper language in the Tier 2 box for our individual and General Permits
with analytical monitoring, and for it to be incorporated henceforth in new and renewed individual permits and
General Permits.
• 1 concur with the analysis by Bethany and Mike.
• As to the present case of the facility with:
o Two consecutive analytical results at the same outfall above the COD benchmark,
o But not with COD exceedances in two consecutive monitoring periods (because an intervening period was 'no
flow'):

o => 1 would yield to the Region's preference on the response to the permittee. The Region may want to consider
the other observed site conditions, the permittee's compliance history, the sensitivity of the receiving water, etc.:
ail those things that the Regional inspector brings to any of our judgements in the follow up to inspections.
However, I favor slightly an NOV/NOD. lust to re -hash what has already been said:
• As Bethany says, our intent was that consecutive results triggered Tier 2.
• Further as Bethany says, the focus of the text is on the analytical results as the trigger, and that we could argue
that the No Flow is not an analytical result. ( I also agree with Mike that there is a pretty good counter -argument
from the permittee's interpretation that he did not have exceedances in 'consecutive monitoring periods.') So,
it's a close call in my mind, but these two bullets (recalling our initial intent, and interpreting the results
themselves as the trigger), seem to me to have more weight than the permittee's observation that the
exceedances did not occur in two consecutive periods (because one was No Flow.)
■ More on our intent: Our objective is that the permittee is actively involved in controlling the potential for polluted
discharges in his stormwater runoff. We want him actively involved to the extent that polluted discharges are
addressed in months, rather than in years. One possible interpretation of the two COD data points is that the
facility has been exceeding COD at outfoll 1 with every rain for the last year. By that interpretation the permittee
certainly needs to move to Tier 2 with a more focused management plan on what to do about their polluted
discharges.
o Here's what comes to my mind as to some alternative responses to this permittee:
• Say to the permittee, Yes you're right, the text of the permit does say "monitoring periods" . We will be guided
strictly by that phrase, and you have not violated the permit. (Not my preference, but arguable.)
■ Say to the permittee, Our closer reading of the text supports that the analytical results are a trigger, and the Tier 2
text box does not anticipate that a 'No Flow' period interrupts that consideration of whether two consecutive
results ore exceedances. Here's your NOV/NOD. Start your monthly sampling immediately, consistent with the
Tier requirements.
• We understand your confusion, our wording could be mis-interpreted. However, you have violated the permit,
and are in Tier Two. Please begin submitting monthly results to the Regional Office and act according to the Tier
2 and Tier 3 requirements of your permit. We will withhold on NOV based on your confusion over the wording
of our Tier 2 box, but we are informing you that you must comply with the Tier 2 (immediately) and Tier
3 (potentially) provisions of the permit.
• Each of these responses could also include an informational bit to the permittee advising him that:
• We have never previously had a permittee interpret the Tier 2 box language as he has;
• Future permits will have slightly revised language in the Tier 2 box to make our intent clear.
Ken
From: Lawyer, Mike
Sent: Tuesday, August 18, 2015 10:34 AM
To: Georgoulias, Bethany; Pickle, Ken; Bennett, Bradley
Cc: Joyner, Melissa
Subject: RE: Tier Two criteria
Awesome! Thanks!
Michael Lawyer, CPSWQ
Environmental Program Consultant
NCDENR — Division of Energy, Mineral and Land Resources
Land Quality Section
Fayetteville Regional Office
P: [phone]

F: [phone]
e-mail: [e-mail]
E-mail 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 regulation.
From: Georgoulias, Bethany
Sent: Tuesday, August 18, 2015 10:28 AM
To: Lawyer, Mike; Pickle, Ken; Bennett, Bradley
Cc: Joyner, Melissa
Subject: RE: Tier Two criteria
We talked about this in our staff meeting today, and we also agreed we should put Technical Guidance together on this
issue. We can distribute that to the ROs and post it on our website for future questions. I will make revisions to the
NCG02, other permit templates, and work with Ken on that guidance.
Thanks, Mike!
Bg
Relhu1{v Georgoulicrs, Environnienlctl Engineer
NCDENR / Division of Energy. Mineral, and Land Resources
Stormcvater Permitting Program
1612 Mail Service Center, Raleigh; NC 27699-1612
S 12 N. Salisbury Street. Raleigh. NC 27604
919 / 807-6372 (plione); 919 / 807-6494 (fax)
Website: littp://portal.iicden r. ory/« eb/Ir/storrmaater
r-mail correspondence to arid, from this address port, he suhjecr to the North Carolina Public Records law rnul nrcny he disclosed to third parties.
From: Lawyer, Mike
Sent: Tuesday, August 18, 2015 9:40 AM
To: Georgoulias, Bethany; Pickle, Ken; Bennett, Bradley
Cc: Joyner, Melissa
Subject: RE: Tier Two criteria
Adding the `(omitting periods with no discharge)' sounds good and should be clear enough.
Despite this issue never really being brought up before, whatever decision is made regarding the current language and
intent of the Tier Two response action, I think we need to make sure that all the other regional offices are informed.
I'm not too concerned about the time lapse issue. Industrial facilities tend to have very consistent/routine operations
and can either easily identify the source of a pollutant or have no clue as to the cause of an exceedance. 1f it's the latter
situation, then we can usually provide assistance or they could hire a consultant.
Michael Lawyer, CPSWQ
Environmental Program Consultant
NCDENR — Division of Energy, Mineral and Land Resources
Land Quality Section
Fayetteville Regional Office
P: [phone]
F: [phone]
e-mail: [e-mail]

r
E-mail 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 regulation,
From: Georgoulias, Bethany
Sent: Tuesday, August 18, 2015 8:59 AM
To: Lawyer, Mike; Pickle, Ken; Bennett, Bradley
Cc: Joyner, Melissa
Subject: RE: Tier Two criteria
Mike,
We'll discuss this when Ken returns and get back with you. It is a big question.
In the meantime, we are getting down to the wire with the NCG02 revisions in preparation for issuance (if EPA will buy
off on it soon). I have a chance to clear this language up before we finalize. Here's one way to do it in the Tier Two
language; what do you think?
"The first valid sampling results from two consecutive monitoring periods (omitting periods with no discharge) are
above the benchmark values for any specific parameter at a specific discharge outfall..."
I'm not sure how to handle exceedances that happen with a year or more between them, though... we should consider
whether to also work in a time lapse limitation I suppose.
LE
Bethany Georgoulias, Environmental L`nA,yineer
NCDENR / Division of Energy. Mineral, and Land Resources
Stornrwater Permitting Program
1612 Mail Service Center, Ralei-h. NC 27699-1612
512 N. Salisbury Street, Raleigh, NC 27604
919 / 807-6372 (phone); 919 / 807-6=494 (fax)
Website: http:f/portal.ncdenr.orglweb/Ir/storniwater
C-mai! rorrc;:pondenc'e cn and from this uddress nury be sullen to the North Carolina Public Remrdv lase oral inav he disclosed to third parlres.
From: Lawyer, Mike
Sent: Monday, August 17, 2015 3:18 PM
To: Georgoulias, Bethany; Pickle, Ken; Bennett, Bradley
Cc: Joyner, Melissa
Subject: RE: Tier Two criteria
Bethany,
Greatly appreciate the feedback. I had the same initial thought as you that the permittee would be triggered into
monthly monitoring because the no discharge period wouldn't "count". However, we have a facility that was recently
inspected with this exact scenario and when they were verbally informed that they would be getting an NOV for not
following the tiered response actions they argued that they haven't had exceedances for two consecutive monitoring
periods. After reading the permit language, I felt like their argument had some merit. The facility personnel also relayed
that it could be difficult to pinpoint a specific cause for an exceedance when the two sets of monitoring results are
almost a year or more apart. I'm also surprised this hasn't come up before, but I think it's a pretty big deal when you
consider how offices might be handling compliance in these situations. I am interested in Ken's and Bradley's thoughts
10

on the matter before we move forward with our inspection report/potential NOV. So far, it sounds like there might be a
need for some revision/clarification to permit language/intent during the next round of renewals.
Thanks again,
Mike
Michael Lawyer, CPSWQ
Environmental Program Consultant
NCDENR — Division of Energy, Mineral and Land Resources
Land Quality Section
Fayetteville Regional Office
P: [phone]
F: [phone]
e-mail: mike.lawyer@_ncdenr.gov
E-mail 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 regulation.
From: Georgoulias, Bethany .
Sent: Monday, August 17, 2015 2:31 PM
To: Lawyer, Mike; Pickle, Ken; Bennett, Bradley
Cc: Joyner, Melissa
Subject: RE: Tier Two criteria
So I read this through and took note of my gut response:
Yes, the intent is for the scenario that you describe to kick the permittee into Tier Two, regardless of a "no discharge"
period in between the two exceedances.
read it through two more times and thought:
Well, a good lawyer would argue the permittee is not necessarily in Tier Two yet because of the wording of "consecutive
monitoring periods." But boy does that make things complicated and very luck -of -the -draw for many of our permittees
out there.
Then I read it again with my practical glasses on, and thought:
Our intent has always been that a set of back-to-back benchmark exceedances triggers Tier Two. That's what we were
trying to communicate, but we might not have gotten it perfect. And 1 would argue back with said good lawyer that
consecutive monitoring periods means periods monitoring could actually be accomplished, because thetrigger is tied to
sample results.
But I'm not sure that would fly. So hopefully there aren't any lawyers involved, except you, Mike Lawyer! Maybe next
time we should word it as "consecutive sampling results."
I'll also let Ken (away until Wed) and Bradley weigh in. This is a GREAT question, Mike, and I can't believe it hasn't come
up before now.
Bg
Bethany Ge:nrgouliiis, Environmental Entiineer
NCDENR / Division of Energy, Mineral, and Land Resources
Stormwater Permitting Program
1612 Mail Service Center. Raleigh, NC 27699-1612
I

12 N. Saiisbur V Street. Raleigh, NC 27604
919 / 807-6372 (phone); 919 1 807-6494 (fax)
Website: httpJ/poiial.iicdenr.orghweb/Ir/stoi-inwater
E-mail correspondence io and,rrom this address mar he subiect to the worth Carolina Public Recordslain and noy be disclosed to third purges.
From: Lawyer, Mike
Sent: Monday, August 17, 2015 11:00 AM
To: Pickle, Ken; Georgoulias, Bethany; Bennett, Bradley
Cc: Joyner, Melissa
Subject: Tier Two criteria
All,
Need some assistance with interpretation of the Tier Two criteria in our general stormwater permits. Permit language
under the Tier Two section reads: "If: The first valid sampling results from two consecutive monitoring periods are above
the benchmark values for any specific parameter at a specific discharge outfall;" I've underlined the two phrases above
to emphasize the need for interpretation. My question is whether or not the phrase "...consecutive monitoring
periods..." trumps the phrase "...valid sampling results..." In a scenario where a facility has a benchmark value
exceedance and then has and reports 'no flow' or 'no discharge' for the next monitoring period, then an exceedance for
the same parameter at the same outfall for the next discharge/sampling event, would they be in Tier Two or not? Does
the lack of sampling results for the no flow/no discharge monitoring period in between the two sampling events with
exceedances count as the consecutive monitoring period, therefore the facility would not be triggered into Tier Two?
Here's another way to look at this scenario:
January — June 2014: discharge/sampling event with exceedance of COD at outfall 1
July— December 2014: no discharge recorded/reported for the entire period
January —June 2015: discharge/sampling event with exceedance of COD at outfall 1
Based on the permit language, we would consider a facility with the above scenario to be in Tier Two monthly
monitoring?
Thanks,
Mike
Michael Lawyer, CPSWQ
Environmental Program Consultant
NCDENR — Division of Energy, Mineral and Land Resources
Land Quality Section
Fayetteville Regional Office
P: [phone]
F: [phone]
e-mail: mike.lawyer(@ncdenr.gov
E-mail 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 regulation.
12

Georgoulias, Bethany
From:
[e-mail]
Sent:
Tuesday, March 10, 2015 4:24 PM
To:
SVC DENR.stormwater
Subject:
Confirmation for Renewal of DEMLR Stormwater NPDES General Permit
** Do not reply to this e-mail as it is from an unmonitored mailbox. **
Thanks for renewing your permit using our online option. No further action is necessary. The new General
Permit is available for printing from our website at http://poi-tal.ticdenr.ora/web/lr/storiiiwiter .
If you have questions, please contact Bethany Georgoulias at bethany.ecor_,[e-mail] phone (919)
807-6372 or Bradley Bennett at bradley.bennett@rncdenr.5zov phone [phone]. If you forgot to print your
Certificate of Coverage (COC), you can resubmit the data and print another copy.
This COC is issued 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 October 15, 2007 (or as subsequently amended.)
The General Permit authorizes discharges of stormwater and specifies your obligations for discharge controls,
management, monitoring, reporting, and record -keeping. Please review the new permit to familiarize yourself
with all of the changes. Parts III and IV contain the Standard Conditions, including Compliance and Liability,
Reporting, Monitoring and Records requirements; Operation and Maintenance obligations; and Definitions.
Your facility has six months from receipt of the COC to update its Stormwater Pollution Prevention Plan
(SPPP) to comply with changes in SPPP requirements. Other changes are effective immediately. Please note
that Tier 3 Actions (if applicable) are triggered by four benchmark exceedances beginning on the effective
date of the renewal permit and do not count prior exceedances. Please visit our website above to review the
new General Permit carefully.
Your coverage under the General Permit is transferable only through the specific action of DEMLR. This
permit does not affect the legal requirements to obtain other permits which may be required by DENR, nor does
it relieve the permittee from responsibility for compliance with any other applicable federal, state, or local law,
rule, standard, ordinance, order, judgment, or decree.
CONFIRMATION DETAILS
Permit Number:
Effective Date:
Expiration Date:
Organization Name:
Facility Name:
Admin Region:
County Name:
Regulated Activity:
Receiving Stream Name:
Receiving Stream Class:
NCG200362
02-02-2015
12-31-2019
OmniSource Southeast, LLC
OmniSource Southeast - Raeford
Fayetteville
Hoke
Wholesale Trade of Metal Waste and Scrap Stormwater Discharge
COC
Pedler Branch
C

Basin:
Facility Address:
Facility City:
Facility State:
Facility Zip:
Affiliation Type:
Fax Number:
Work Phone Number
First Name:
Middle Name:
Last Name:
Email:
Cape Fear
303 S Magnolia St
Raeford
NC
28376
Owner
[phone]
Rich
Brady
[e-mail]
5
6

DENR--FRO
DEC 0 3 2012
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P. E.
Governor Director
November 29, 2012
Bob Brewer
Omri1SOU['CC Southeast LLC
PO Box 578
Lyman.' SC 29365
Dee Freeman
Secretary
Subject: NI'DES General Permit NCG200000
Certificate of Coverage NCG200362
Omnisource Southeast -Raeford
Formerly Raeford Salvage Co
Hoke COUnt1'
Dear Mr. Brewer:
Division personnel received your request to revise your storrnwater pert -nit Certificate of Coverage to",
accurately reflect your new company and facility narne. 1
Please find enclosed the revised Certificate of Coverage. The terms and conditions contained in the
General Permit remain unchanged and in full effect. This revised Certificate of Coverage is issued under
the requirements of North Carolina General Statutes 143-215.1 and the Memorandum of Agreement
between North Carolina and the U.S. Environmental Protection Agency.
If you have any questions, please contact the Stormwater Permitting Unit at 919-807-6300.
Sincerely,
ORIGINAL SIGNED 6)
KEN PICKLE
for Charles Wakild, P.E.
cc: Fayetteville Regional Office
Central Files
Stormwater Permitting Unit
Wetlands and Stormwater Branch
1617 Mail Service Center, Raleigh, 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.ncwaterquality.org
NorthCarolina
Naturallrf
An Equal Opportunity 1 Affirmative Action Employer

T �~
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG200000
CERTIFICATE OF COVERAGE No. NCG200362
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,
0111n1SOn1'Ce Southeast L,LC
is hereby authorized to discharge stormwater from a facility located at
OmniSOUrce SOUt:heast-Raeford
303 South Magnolia St .
Raeford
Hoke County
to receiving waters designated as Peddlers Branch, a class C, waterbody in the Lumber River Basin in
accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts
1, 11, III, IV, V and VI oi'General Permit No. NCG200000 as attached.
This certificate of coverage shall become effective November 29, 2012.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this clay November 29. 2012. ORIGINAL SIGNED Bl
KEN PICKLE
for Charles Wakild, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

I ,
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
September 3, 2010
.lames Winegar, Environmental Manager
Omnisource Southeast
2233 Wal-Pat Road
Smithfield, NC 27577
Subject: COMPLIANCE EVALUATION INSPECTION
Raeford Salvage Co Inc
NPDES Stormwater Permit-NCG200362
Hoke County
Dear Mr. Winegar:
On September 1, 2010, I, Hughie White from the Fayetteville Regional Office of the Division of Water
Quality, conducted a site inspection at the Raeford Salvage Co Incorporated facility located on Magnolia Street
in Raeford, Hoke County, North Carolina. A copy of the Compliance Inspection Report is attached for your
review. Thank you for assisting with this inspection. Your time and assistance is greatly appreciated.
Stormwater from this facility drains to Peddlers Branch, a Class C water located in the Cape Fear River Basin.
The site visit and file review revealed that the subject facility is covered by NPDES Stormwater Permit-
NCG200362.
Accordingly, the following observations were noted during the Division of Water Quality inspection:
1) Stormwater Pollution Prevention Play (SPPP)
A Stormwater Pollution Prevention Plan (SPPP) has been developed, recorded, and properly implemented.
Yes ® No ❑
2) Qualitative Monitorinll
Qualitative monitoring has been conducted and recorded in accordance with permit requirements.
es® No❑
Location: 225 Green Street, Suite 714, Fayetteville, North Carolina 28301 One, t
Phone: [phone] FAX: 91OA86-0707 I Customer Service: 1-677-623-6748 Nol 111 Carolina
tntemat www.ncwaterqualiry.org a'� ` 1�H� //�
An Equal Opportunily'i Affirmative Action Employer (f L "

3) Analytical Monitoring
Analytical monitoring has been conducted and recorded in accordance with permit requirements.
Other Observations:
Please refer to the attached Compliance Inspection Report for additional observations and comments.
Please be advised that violations of the NPDES Permit are subject to a civil penalty assessment of
up to S25,000 per day for each violation. If you or your staff has any questions, comments, or needs
assistance with understanding any aspect of your permit; please do not hesitate to contact me at (910) 4 -3-3308.
Sincerely,
Hughie White
Environmental Specialist
Attachment
cc: FRO -Surface Water Protection
NPS-Assistance & Compliance Oversight Unit
Location: 225 Green Street, Suite714, Fayetteville, North Carolina 28301 One
Phone: [phone] FAX: [phone] Customer service: 1-877-623-6748 N ofth Cax'ol i na
Internal'. www.ncwaterqualify.org ������/ a'll//I ,
An Equal OpportunitylAffinnativeActon Employe ;

Compliance Inspection Report
Permit: NCG200362 Effective: 01/01/10 Expiration: 12/31/14 Owner: Raeford Salvage Cc Inc
SOC: 'Effective: Expiration: Facility: Raeford Salvage Cc Incorporated
County: Hoke 303 S Magnolia St
Region: Fayetteville
Raeford NC 28376
Contact Person: Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 09/01/2010 Entry Time: 09:D0 AM Exit Time: 10:10 AM
Primary Inspector: Hughie White �� Phone: [phone]
Ext.708
j ijie"�
Belinda S Henson Phone: [phone] Ext.726
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Wholesaie Trade of Metal Waste and Scrap Stormwater
Discharge COC
Facility Status: ® Compliant ❑ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page: 1
AA11 .

Permit: NCG200362 Owner - Facility: Raeford Salvage Co Inc
Inspection Date: 09/01/2010 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection summary:
The new permit for this facility became effective January 1, 2010. This facility currently does have a stormwater pollution
prevention plan, however, a new modified plan is currently being developed. As noted within the inspection checklist, the
current plan does not have a stormwater facility inspection program. The new plan will include an inspection program and
the facility inspections will be performed monthly. Qualitative monitoring is being performed as required. With the
issuance of the new permit at the beginning of this year, this facility did not receive that actual permit and certificate of
coverage until the end of February, which shortened the time frame for them to sample for the first monitoring schedule of
January 1, 2010 thru June 30, 2010. Also, with the drought and lack of rain, this facility was not able to sample a
representative storm event until July 27, 2010. An exception will be made for this particular instance due to the delayed
receipt of the permit. This facility will sample again this calendar year, as required, to meet the semi-annual monitoring
requirement. Also, this facility does not have to conduct analytical monitoring from vehicle maintenance areas because
they do not meet the criteria for sampling. This facility is currently in the Tier One response action category because
sample results for COD, Copper and Zinc exceeded the benchmark values.
Page. 2

Permit: NCG200362 Owner - Facility: Raeford Salvage Ca Inc
Inspection Date: 09101/2010 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?
®
n
n
n
# Does the Plan include a General Locatien (USGS) map?
®
r-I
n
n
# Does the Plan include a "Narrative Description of Practices"?
®
n
n
D
# Does the Plan include a detailed site map including outfall locations and drainage areas?
®
n
n
n
# Does the Plan include a list of significant spills occurring during the past 3 years?
n
n
®
n
# Has the facility evaluated feasible alternatives to current practices?
®
n
n
n
# Does the facility provide all necessary secondary containment?
®
n
n
n
# Does the Plan include a BMP summary?
®
n
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
# 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
n
n
# Does the Plan include a Stormwater Facility Inspection Program?
n
®
n
n
Has the Stormwater Pollution Prevention Plan been implemented?
®
n
n
n
Comment: A new stormwater pollution prevention plan is currently being developed
and the new plan will include the stormwater facility inspection program. The
inspections will be performed on a monthly basis.
Qualitative Monitoring
Yes
No
NA
NE
Has the facility conducted its Qualitative Monitoring semi-annually?
®
❑
n
❑
Comment:
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
Comment:
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? ® ❑ n n
# If the facility has representative outfall status, is it properly documented by the Division? n n ■ n
# Has the facility evaluated all illicit (non stormwater) discharges? ® n n n
Page: 3

Permit: NCG200362 Owner • Facility: Raeford Salvage Co Inc
Inspection Date: M0112010 inspection Type: Compliance Evaluation Reason for Visit: Routine
Comment:
Page: 4

OOF WArFi9QG Michael F. Easley, Governor
C William G. Ross Jr„ Secretary
r- North Carolina Department of fEnvironntent and Natural Resources
Q Alan W. Klimek, P,E. Director
Division of Water Quality
November 20, 2006 EN R-FID®
Michael Green 1 9 20M
Raeford Salvage Co Inc
PO Drawer 510
Fayetteville NC, 28302 W a
Subject: NPDES Stormwater Permit Coverage Renewal
Raeford Salvage Co Incorporated
COC # NCG200362
Hoke County
Dear Permittee:
In response to your renewal application for continued coverage under general permit NCG200000 the Division of
Water Quality (DWO) 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 Cape Fear of the Central Office Stormwater
Permitting Unit at [phone], ext. Bethany Georgoulias.
Sincerely,
Bradley Bennett, Supervisor
Stormwater and General Permits Unit
cc: Central Files
Stormwater & General Permits Unit Files
Fayetteville Regional Office
No e hCarolina
Naturally
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 Acton Employer- 50% Recycledl10% 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. NCG200362
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,
RAEFORD SALVAGE CO INC
is hereby authorized to discharge stormwater from a facility located at
Raeford Salvage Co Incorporated
303 S Magnolia St
Raeford
Hoke County
to receiving waters designated as , a class Peddlers Branch stream, in the C River Basin in accordance
with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, If, 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 Green
Raeford Salvage Co Incorporated
PO Drawer 510
Fayetteville, NC, 28302
Dear Permittee:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.P. Director
Division of Water Quality
July 25, 2005 RECEIVED
JUL 2 6 M
DENR — EAYEi IE111LLE REGIONALr E
Subject: NPDES Stormwater Permit Coverage Renewal
Raeford Salvage Co Incorporated
COC Number NCG200362
Hoke County
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 httpa/h2o.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
Fayetteville Regional Office
SWPU Files
One
Npr hCarolina
�l ai irally
Wetlands and Stormwater Branch 1617 Mail Service Center
Raleigh, NC 27699-1617
Phone [phone]
Intemet: h2o.enr.slate.nc.us 512 N. Salisbury St.
Raleigh, NC 27604
FAX [phone]
An Equal Opportunity/Affirmative Action Employer — 50% Recycled110% Post Consumer Paper

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
Sherri Evans -Stanton, Acting Secretary
Kerr T. Stevens, Director
1 � •
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
January 19, 2001�^�
MICHAEL GREEN
RAEFORD SALVAGE CO., INC. 2 z 2001
P.O. DRAWER 510
FAYETTEVILLE, NC 28302 FAY M EkriL L E
Subject: Reissue - NPDES Stormwater Permit REG 01t =if'l=
Raeford Salvage Co., Inc.
COC Number NCG200362
Dear Permittee: Hoke County
In accordance with your application for a discharge permit received on July 31, 1995 we are forwarding herewith
the subject certificate of coverage to discharge under the subject state - NPDES general permit. This permit is
issued pursuant to the requirements of North Carolina General Statute 143-215 .1 and the Memorandum of
Agreement between North Carolina and the US Environmental Protection agency dated December 6, 1983.
If any parts, measurement frequencies or sampling requirements contained in this permit are unacceptable to you,
you have the right to request an individual permit by submitting an individual permit application. Unless such
demand is made, this certificate of coverage shall be final and binding. -
Please take notice that this certificate of coverage is not transferable except after notice to the Division of Water
Quality. The Division of Water Quality may require modification or revocation and reissuance of the certificate of
coverage.
This permit does not affect the legal requirements to obtain other permits which may be required by the Division of
Water Quality or permits required by the Division of Land Resources, Coastal Area Management Act or any other
Federal or Local governmental permit that may be required.
Enclosed is a permit package which contains the following information:
* A stortnwater 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 Bill Mills at telephone number [phone] ext.
548.
Sincerely,
WGIRM SIGNED %Y
for Kerr T. Stevens W.U11MC, M1LLS
cc: Central Files
Stormwater and General permits Unit Files
Fayetteville Regional Office
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, NCG200362
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,
RAEFORD SALVAGE CO., INC.
is hereby authorized to discharge stormwater from a facility located at
RAEFORD SALVAGE CO., INC.
HOKE COUNTY
to receiving waters designated as TOWN OF RAEFORD STORM SEWER SYSTEM & PEDDLERS BRANCH, a
class C stream, in the River Basin in accordance with the effluent limitations, monitoring requirements, and other
conditions set forth in Parts I, 1I, II1, IV, V, and VI of General Permit No. NCG260000 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.
W SIGNED MY
tit � �AnAn Mt! 1
for Kerr T. Stevens, Director`
Division of Water Quality
By Authority of the Environmental Management Commission

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Soil Map —Cumberland County, North Carolina
Area of Interest (AOI)
Area of Interest (AOI)
soils
a
Soil Map Unit Polygons
.�•
Soil Map Unit Lines
Soil Map Unit Points
Special
Point Features
V
Blowout
Orr It
Xr
Clay Spot
0
Closed Depression
X
Gravel Pit
Gravelly Spot
0
Landfill
A.
Lava Flow
Marsh or swamp
spa
Mine or Quarry
Miscellaneous Water
®
Perennial Water
V
Rock Outcrop
Saline Spot
Sandy Spot
Severely Eroded Spot
Q
Sinkhole
Slide or Slip
Sodic Spot
LEGEND
g
SpciI Area
10
Stony Spot
Very Stony Spot
Wet Spot
�. Special Line Featun
Water Features
r r Streams and Canal!
Transportation
++ 4 Rails
ti Interstate highways
yy US Routes
Major Roads
Local Roads
Background
FJ Aerial Photography
MAP INFORMATION
The soil surveys.that comprise your AOI were mapped at
1:24,000,
Warning: Soil Map may not be Sle
t this scale.
Enlargement of maps beyond the of mapping can cause
misunderstanding of the detail of mapping -and accuracy of soil
line placement. The mi�ps.do.ttot show the small areas of
contrasting soils that -could have bee shown at•a more detailed
scale.
"I-,
Please rely on the bar scale on each map shee or map
measurerhents!
Source of M\p Natural Resources Conservation Se ice
Web Soil Survey t f;tL'-
Coordinate System: Web'Mercator (EPSG:3857)
Maps from the Web Soil•Surv\re based on the Web Mercato
projec -Qp which preserves,direction and shape but distorts
di an
anarea. A`projeron-that reserves area, such as
A bers equal-area conic projection, should-6'e'used-if mo
)Th
urate calculations of distance oarea are required-
s product is�generated from the USDA-NRCS certified data as
he versiondates) listed below.t Survey Ar l: Cumberland County, North Carolina
rvey Area Data: Version 18, Sep 26, 201,7
Soil map uni8rer.
re b\ (as space allows) for map scales
1:50,000 or 1
were photographed: Aug 1$, 2014---Feb
4, 28-1.74 \
The orthophoto\or other base map on which the soil lines were
compiled and digitized probably differs from the background
imagery displayed on these maps. As a result, some minor
shifting of map unit boundaries may be evident.
USDA Natural Resources Web Soil Survey 11/8/2017
r Conservation Service National Cooperative Soil Survey Page 2 of 3