NCG200335_COMPLETE FILE - HISTORICAL_20151222

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO.
DOC TYPE.
LAC HISTORICAL FILE
❑ MONITORING REPORTS
DOC DATE
❑ an 5 a as
YYYYM M D D

Robinson
Bradshaw
VIA EMAIL AND US MAIL
Nicolette Fulton, Esq.
Associate City Attorney
City of Raleigh
PO Box 590
Raleigh, NC 27602-0590
` 8A
HC26"Vb
NC DENR Raleigh Regional Office
December 22, 2015
William W. Toole
Chnrtone Office
704.377.8373 Direct Phone
704.373.3973 Direct Fan
wtoole®rbh.com
rbh.com
Re: Raleigh Recycling NC Scrap Metal, LLC ("Raleigh Recycling")
2310 Gamer Road, Wake County ("Site")
Response to Correspondence of City of Raleigh dated November 23, 2015 ("City
Correspondence")
Dear Ms. Fulton:
This firm represents Raleigh Recycling with regard to the City Correspondence. This letter and
the attachments are timely submitted in response to the City Correspondence Raleigh Recycling
received on November 23, 2015. As requested in the City Correspondence, this response
includes the following:
1. A detailed report on all progress made on implementation of the Stormwater
Management Plan ("SWMP")
2. A timeline for completion for the SWMP
3. A detailed report on all progress made on the Remedial Action Plan ("RAP")
4. A timeline for completion for the RAP
5. Details of any remediation plan for capping! the Site; and
6. A timeline for completion for capping the Site
This response also corrects certain errors and a misapprehension that Raleigh Recycling has
deliberately delayed implementation of the Stormwater Management Plan, Containment Remedy
Proposal, and/or the Remedial Action Plan. As the attached. detailed timeline shows, on April
17, 2014 Raleigh Recycling volunteered to correct a historical problem created by others, and
Raleigh Recycling has taken the initiative to move a comprehensive solution forward that had
i The City Correspondence incorrectly refers to the "containment remedy barrier" as a "cap." The 2012
Containment Remedy Proposal, which is different from the RAP, proposed a barrier solution that does not meet
criteria traditionally applied to "cap" solutions.
80623440 19853.00020
Robison Bradshaw 6 Hinson, PA. r Attorneys at Law Is 101 North Tryon Street, Suite 1900 A Charlotte, NC 28246 n 704.377.2536
Charbne n Research Triangle it Rook Hill

Nicolette Fulton, Esq.
December 22, 2015
Page 2
stalled. Raleigh Recycling has faced delays that are not of its making despite aggressive efforts
to address problems it did not create.
At this time, the principal delay in project implementation is negotiating the required access
agreements with the North Carolina Railroad and Norfolk Southern. These agreements are
necessary to because North Carolina Railroad owns and Norfolk Southern operates land where
certain stormwater upgrades, installation of a portion of the containment barrier, and certain land
use restrictions must be implemented. Raleigh Recycling initiated contact with the railroads on
June 3, 2014, six weeks after taking control of environmental matters at the Site. Raleigh
Recycling did not receive a first draft of documents until November 17, 2015, eighteen months
after the initial contact was made.
By way of reminder, the contamination and stormwater discharge problems are the result of
historic activities dating back to the 1940's that were undertaken by previous site owners and
operators, primarily Seymour Brown Investment Co., Inc., formerly named Goldsboro Iron and
Metal ("SBIC'). That historic soil contamination included lead, cadmium and polychlorinated
biphenyls (PCBs). The PCBs were introduced in connection with a transformer cracking
operation that SBIC operated during the 1960's and 1970's. Raleigh Recycling has never
allowed PCBs to be transported to the Site and, since first becoming a tenant in 2007 of a portion
of the Site, has maintained a strict screening process to prevent PCBs from being introduced to
the Site.
Raleigh Recycling, formerly known as GIMCO Acquisition LLC, first had dealings with the Site
when it purchased certain operational assets and leased a portion, but not all, of the Site on
August 3, 2007. Raleigh Recycling never had any control over SBIC operations and did not own
the Site. Until April 23, 2014, Raleigh Recycling had no right to implement necessary cleanup2
to control the legacy contamination affecting stormwater discharges from the Site. Nonetheless,
Raleigh Recycling voluntarily entered North Carolina's voluntary clean up program on April 17
and Raleigh Recycling Scrap Metal NC LLC, an entity related to Raleigh Recycling, purchased
the Site on April 23, 2014 because Raleigh Recycling believed SBIC was not acting aggressively
enough to address the legacy contamination that directly and adversely affected stormwater
discharges from the Site.
On May 2, 2014, after gaining control over the Site environmental response from SBIC, Raleigh
Recycling prepared and submitted a Stormwater Management Plan to the Water Quality
] The statement in the City Correspondence that the 2012 RAP was prepared on behalf of Raleigh Recycling is not
correct. The RAP was prepared on behalf of SBIC. Raleigh Recycling has proposed improvements to the 2012
RAP that consist of two stormwater retention ponds and improvements to the proposed containment barrier
consisting of asphalt and/or concrete. These improvements render sections of the 2012 RAP obsolete.
a Pursuant to the Voluntary Clean -Up Program, Raleigh Metals has engaged Mid -Atlantic Associates, Inc. as the
Registered Environmental Consultant and Daniel Nielsen to act as the Registered Site Manager. The Registered
Environmental Consultant, through the Responsible Site Manager, is responsible to the state for certifying to DEQ
that the actions taken by Raleigh Metals comply with the rules of the Voluntary Clean -Up Program.
80623440 19853.00020

Nicolette Fulton, Esq.
December 22, 2015
Page 3
Operations of the North Carolina Department of Environment and Natural Resources (now
Department of Environmental Quality) ("DEQ") that proposed the installation of two stormwater
ponds designed to manage stormwater from 14.5 acres of the Site. The City of Raleigh received
a copy of that correspondence. On July 2, 2014, Raleigh Recycling submitted the Stormwater
Management Plan to the City of Raleigh for its review and comment. See generally "Detailed
Timeline on Stormwater Management Plan, Containment Remedy Proposal and Remedial Action
Plan Activities" ("Timeline'), attached as Exhibit 1. The location of the two Stormwater
retention ponds is shown on the survey of the Site attached as Exhibit 2.
An essential component of the comprehensive Stormwater Management Plan is the installation
of a containment barrier over those areas with soils contaminated by PCBs or metals above
certain limits, because the constituents exceeding the stormwater discharge targets adhere to soil
being mobilized during storm events.4 Beginning in August 2014 Raleigh Recycling had a
number of discussions with DEQ to expand the size and improve the barrier material that SBIC
had proposed in the 2012 Containment Remedy Proposal, and also to confirm the placement of
the two stormwater retention ponds described in the Stormwater Management Plan. See
Timeline.
As a result of those discussions, Raleigh Recycling now plans to expand the area subject to the
containment remedy to that shown as Area A on the survey of the Site attached as Exhibit 2. In
addition, at the request of DEQ Raleigh Recycling has elected to improve the durability and
imperviousness of the barrier by using either asphalt, concrete, or both, rather than the geotextile
fabric overlain by approximately 12 inches of recycled concrete or aggregate base course cover
originally proposed by SBIC in 2012.
On March 30, 2015 Raleigh Recycling received from EPA a Risk Based Clean-Up/Disposal PCB
approval ("EPA Approval"), based upon SBIC's 2012 Remedial Action Plan ("RAP") containing
a 2011 Containment Remedy Proposal. EPA's approval process, which included a community
meeting in June 2014, had been stalled until Raleigh Recycling took control over the Site
environmental response. Because the EPA Approval is based upon the 2012 RAP and the 2011
Containment Remedy Proposal, the EPA Approval will have to be amended to reflect a revised
RAP, a key component of which will be a DEQ approved Containment Remedy Proposal
showing the installation of the two stormwater retention ponds, the expanded area subject to the
containment barrier, and the use of either asphalt, concrete, or both to construct the barrier. See
Timeline, April 15, 2015. Because land use restrictions will be required to implement the
Containment Remedy Proposal, DEQ informed the Registered Site Manager that a revised
Containment Remedy Proposal should not be submitted to DEQ for final approval until after
obtaining the approval of all affected landowners. See Timeline, April 29, 2015.
4 PCBs do not readily dissolve in water and instead adhere to soil. This means that PCBs become mobile only to
the extent the soils to which they have adhered become mobile. Similarly, the metals exceedances are due primarily
to mobilized contaminated soil.
80623440 19853.00020

Nicolette Fulton, Esq.
December 22, 2015
Page 4
Legacy contamination exists on and appears to be migrating from the right of way owned and/or
operated by NC Railroad and Norfolk Southern ("Railroad Right of Way"). The Stormwater
Management Plan includes placement of the containment barrier on the Railroad Right of Way
and the upgrading of an existing outfall, the retention of a second outfall and the removal of an
existing outfall, all of which are located on the Railroad Right of Way. See generally Survey of
Railroad Right of Way, attached as Exhibit 3.
As stated by the Registered Site Manager, the permission of the railroads is required before a
revised Containment Remedy Proposal may be submitted to DEQ for concurrence. See
Correspondence from Daniel Nielsen to William Toole (December 21, 2015), attached as Exhibit
4. Because NC Railroad owns the Railroad Right of Way, its permission is also required to
install the containment barrier and to improve and maintain the stormwater outfalls that pass over
and under the Railroad Right of Way.
On June 3, 2014, six weeks after first entering the voluntary cleanup program, Raleigh Recycling
approached North Carolina Railroad about access to the Railroad Right of Way, implementation
of the containment barrier, and conducting the necessary upgrades to the stormwater outfalls
located on the Railroad Right of Way. Since then, Raleigh Recycling has aggressively pursued
the required access and permissions, promptly responded to all requests for information in a
comprehensive way, and waited for the railroads. See Timeline. Despite numerous contacts, Site
visits, and information submittals, the railroads failed to deliver a single draft access document to
Raleigh Recycling until November 17, 2015. See Timeline. The railroads' five proposed
separate and distinct legal agreements consist of a Declaration of Perpetual Land Use
Restriction; an Agreement for Land Use Restrictions and Indemnity; an Environmental Right of
Entry; a License Agreement; and a Flowage Agreement. On December 14, Raleigh Recycling
delivered to the railroads a comprehensive review and mark up of the five agreements and
proposed specific dates for an in -person meeting to discuss open issues and party positions. That
meeting is scheduled for December 23, 2015.
As stated in the December 21, 2015 correspondence of the Registered Site Manager, Raleigh
Recycling cannot submit to DEQ for its approval a revised Containment Remedy Proposal
showing stormwater retention ponds, expanded barrier area, use of asphalt and/or concrete as
construction material until Raleigh Recycling has obtained the approval of the railroads. See
Exhibit 4. Raleigh Recycling is doing and will continue to do all it can to obtain final access
agreements as soon as possible, but it has no control over railroad review. Raleigh Recycling
welcomes action from the City of Raleigh that will encourage the railroads to make the
negotiation and execution of appropriate agreements a priority.
Once DEQ has approved the revised Containment Remedy Proposal, the Registered Site
Manager can then append the revised Containment Remedy Proposal to the revised Remedial
Action Plan and obtain a revised EPA Approval to reflect the two stormwater retention ponds
and containment barrier improvements. Once the revised EPA Approval is issued, DEQ will
then issue the revised RAP for public notice and comment. The Registered Site Manager must,
80623440 19853.00020

Nicolette Fulton, Esq.
December 22, 2015
Page 5
in coordination with DEQ, respond to any substantive comments and revise the RAP, as
appropriate. Once complete, the Registered Site Manager can certify the RAP to DEQ, and
implementation can begin. See Exhibit 4.
As is evident from review of Exhibit 3, Railroad access is required even if the Site were not in
the Voluntary Clean -Up Program. Legacy contamination is located on the Railroad Right of
Way, that contamination is contributing to the stormwater discharge problems, and can only be
addressed by access to the Railroad Right of Way.
Attached as Exhibit 5 is the project timeline. The timeline for project construction is dependent
upon receipt of access to the Railroad Right of Way. Raleigh Recycling does not know when the
railroads will be prepared to finalize the necessary access agreements. Raleigh Recycling
encourages the City of Raleigh to engage the railroads on this matter.
Raleigh Recycling shares the frustration of the City of Raleigh over the length of this process and
the delay that has been imposed by parties over which it has absolutely no control. Raleigh
Recycling took control of this process so that it could push the project forward, and to some
extent it has been successful. Until November 17, however, Raleigh Recycling could not point
to any progress towards obtaining the essential railroad access, despite its many and best efforts
to do so. See Timeline. Raleigh Recycling requests that the City of Raleigh engage the railroads
on this matter so that Raleigh Recycling may proceed to project implementation.
Raleigh Recycling has promptly responded to every request of the City of Raleigh. See
Timeline. Raleigh Recycling understands that the City of Raleigh would benefit from regular
project status reports, and beginning January 2016 will have the Registered Site Manager start
sending quarterly status reports to the City at the same time such reports are sent to DEQ.
Raleigh Recycling is also prepared to meet with you on Wednesday, December 23, 2015 to
discuss this matter in more detail. Raleigh Recycling welcomes the continued engagement of the
City of Raleigh, and will continue to respond promptly to all requests it is able to honor.
Sincerely,
ROBINSON BRADSHAW & HINSON, P.A.
William W. Toole
80623440 19853.00020

Nicolette Fulton, Esq.
December 22, 2015
Page 6
W WT/tbm
cc: Mr. Gregory Brown
Daniel Nielsen (Responsible Site Manager, Mid -Atlantic Associates, Inc.)
John Holley (NCDEQ)
Danny Smith (NCDEQ)
Matt Aufman (NCDEQ)
Terri Crosby -Vega (EPA)
8062344v3 19853.00020

EXHIBIT I
Timeline on Stormwater Management Plan,
Containment Remedy Proposal
and
Remedial Action Plan Activities

Detailed Timeline on Stormwater Management Plan,
Containment Remedy Proposal and Remedial Action Plan Activities
YEAR MONTH DAY ACTIVITY
GIMCO Acquisition LLC leases a portion (but not all) of the larger property tract located at 2310
Garner Road, Raleigh, NC (the entire tract being the "Site') and undertakes certain operations
August
3
scrap metal operations; Landlord (Goldsboro Iron and Metal Company, subsequently Seymour
N
Brown Investment Company) retains all rights and obligations with regard to PCBs and other
$
contaminants discovered at the Site
N
Seymour Brown Investment Company, Inc. (SBIC) enters 2310 Garner Road, Raleigh, INC (Site) into
North Carolina Inactive ; Hazardous Site Branch Registered Environmental Consultant Program by
November
28
due to the discovery of contamination by PCBs and other chemicals
a,
Phase I Remedial Investigation Report submitted to NCDENR by SBIC
$
N
May
15
o
Phase II Remedial Investigation Report submitted to NCDENR by SBIC
o
N
August
20
..
Containment Remedy Proposal submitted to NCDENR by SBIC
0
August
9
N
ry
Revised Containment Remedy Proposal submitted to NCDENR by SBIC
0
N
April
3
N
Remedial Action Plan submitted to EPA by SBIC
0
N
June
21
Meeting with Raleigh Recycling Scrap Metal NC LLC ("Raleigh Metal Recycling INC") (legal name
later becomes Raleigh Recycling NC Scrap Metal LLC), SBIC, City of Raleigh, NCDENR (stormwater
October
7
and Inactive Hazardous Sites Branch) to discuss stormwater discharges from property owned by
SBIC, and a portion of which was leased by Raleigh Recycling Scrap Metal NC
m
0
N
Attorney for City of Raleigh (Nicolet[e Fulton) requests a final stormwater Plan and timeline for
18
implementation no later than January 3, 2014
December
Raleigh Recycling Scrap Metal NC delivers Stormwater Management Plan and timeline to City of
26
Raleigh, ahead of schedule
Stormwater NOV from NCDENR regarding complaint from City of Raleigh regarding stream
March
27
standard violations
City of Raleigh (Mark Senior) provides comments to Stormwater Management Plan delivered by
B
Raleigh Recycling Scrap Metal NC on December 26
Raleigh Metal Recycling NC Scrap Metal enters Adminstrative Agreement for Registered
April
Environmental Consultant -Directed Assessment and Remedial Action to conduct voluntary
17
remedial action pursuant to North Carolina Voluntary Clean -Up Act (NCGS 13OA-310.9(c)); Daniel
Nielsen is the Registered Site Manager
23
Related entity Raleigh Recycling Scrap Metal NC, LLC purchases Site
Raleigh Recycling Scrap Metal NC submits revised Stormwater Management plan to NCDENR for
May
2
review and comment; copies provided to City of Raleigh (Nicolette Fulton)
EPA hosts community availability session regarding barrier detailed in Containment Remedy
Proposal submitted to NCDENR in 2011, as revised; Raleigh Metal Recycling NC participates in
3
event and begins discussions with North Carolina Railroad ("NCRR") regarding site access issues
Raleigh Metal Recycling INC sends to NCRR map illustrating proposed location of stormwater
retention ponds on property owned by Raleigh Metal Recycling NC and need for access to
5
implement Containment Remedy Plan and Remedial Action Plan on NCRR property; NCRR reports
June
that Norfolk Southern Railroad ("NSR") must also be brought into access discussions
Discussions begin with NCRR regarding access agreements, to include Environmental Right of
Entry and Land License for the work associated with the Stormwater Management Plan,
21
Containment Remedy Proposal, and Remedial Action Plan, to be drafted by NCRR
Raleigh Metal Recycling INC meets with NCDENR (Danny Smith, others) regarding Stormwater
e
0
25
Management Plan
N
2
Stormwater Management Plan submitted to City of Raleigh for review and comment
July
Construction drawings (draft) for stormwater management facility prepared

September
October
November
December
January
February
29
NCRR involves NSR in discussions after prodding by Raleigh Metal Recycling NC
15
Second Revision of Containment Remedy Proposal submitted to NCDENR
19
NCDENR provides comments to Second Revision of Containment Remedy Proposal
NCRR requests a conference call to involve an NSR environmental remediation engineer and to
26
provide an overview of the scope of the project and proposed activities; Raleigh Metal Recycling
NC agrees and requests availability dates
30
NCRR proposes meeting dates
Registered Site Manager (Dan Nielsen) has conference call with NSR engineer (Scott Pittenger);
8
Pittenger concludes site visit would be helpful, which is agreed to on call
Response of Raleigh Metal Recycling NC to NCDENR comments to Second Revision of
24
Containment Remedy Proposal, including Stormwater Management Plan
ftesonsible Site Manager (Dan Nielsen) reiterates offer of site visit to NSR engineer (Scott
3
Pittenger) and requests specific dates
Attorney for Raleigh Metal Recycling INC (William Toole) sends follow up email to NSR and NCRR
13
requesting dates to schedule site visit
13
NSR responds with available dates
NSR, NCRR, Raleigh Metals Recycling INC meet on Site to discuss the proposed Stormwater
Management Plan, Containment Remedy Proposal, and Remedial Action Plan; it was agreed that
25
NCRR and NSR would wait to review the stormwater management design system after receiving
comments, if any, from NCDENR
Raleigh Metal Recycling NC meets on -site with NCDENR (Danny Smith) and others to discuss
16
stormwater plan submitted by Raleigh Metal Recycling INC on May 2, 2014
NCDENR provides comments to Raleigh Metal Recycling NC October 24, 2014 comments regarding
16
Second Revision of Containment Remedy Proposal
Raleigh Metal Recycling INC requests a status update from NCRR, informs NCRR of the December
16, 2014 Site meeting with NCDENR regarding the stormwater management plan, and of the
2
desire to move the matter along quickly; NCRR states that though it is the owner of the right of
way, NSR is the more appropriate lead negotiating entity for the railroads
Attorney for Raleigh Metal Recycling NC (William Toole) follows up by email and then by phone
with NCRR (Cathy Deeley) expressing urgency about the failure to make progress and again
requesting drafts of the access agreements from NCRR; NCRR confers with NSR and requests
14
copies of the July 25, 2014 construction drawings (draft) for the Stormwater Management Plan
which had been previously delivered to the railroads; Raleigh Metal Recycling NC delivers the
requested plans within 30 minutes
Registered Site Manager (Daniel Nielsen) follows up by email to NSR engineer (Scott Pittenger) to
see what additional information, if any, was needed by NSR since the November 25, 2014 Site visit
21
and expressing eagerness to get the necessary railroad agreements in place so as to implement
the Stormwater Management Plan, Containment Remedy Proposal, and Remedial Action Plan
Attorney for Raleigh Metal Recycling NC (William Toole) sends email to NCRR (Cathy Deeley)
informing railroad of upcoming meeting with NCDENR, again expressing urgency about the failure
to make progress and again requesting drafts of the access agreements from NCRR; Deeley asks
28
that NSR be communicated with directly, which Raleigh Metal Recycling INC promptly does by
voicemail followed by email on January 30
Raleigh Metal Recycling NC makes direct contact with the NSR attorney assigned to this matter
30
(Helen Hart) and provides a brief overview regarding conditions on the railroad right of way and
the responses proposed by Raleigh Metal Recycling NC
Representatives for Raleigh Metal Recycling NC (William Toole) and Registered Site Manager
(Daniel Nielsen) have conference call with representatives for NSR (Helen Hart, Scott Pittenger)
and NCRR (Cathy Deeley, Mary Dillon [outside attorney]); discussions involved contamination
3
history, stormwater management plan and barrier installation; Raleigh Metal Recycling INC
expressed urgency and the need to have the necessary railroad agreements in place and
construction underway by July/August
Raleigh Metal Recycling NC and Registered Site Manager meet with NCDENR to discuss and
5
resolve remaining issues assocated with the Containment Remedy Proposal
Stormwater consultant for Raleigh Metal Recycling NC (Jon Aldridge) meets with City of Raleigh,
13
Wake County and NCDENR regarding stormwater issues, informs regulators of negotiations with
railroads over required access, delays in receiving EPA approval
Raleigh Metal Recycling INC provides NSR with revised draft land use restrictions required in
18
connection with Containment Remedy Proposal
20
Attorney for City of Raleigh requests status report

Attorney for Raleigh Metal Recycling NC (William Toole) provides status report to City of Raleigh
(Nicolette Fulton) describing status of pending EPA Approval, the fact that an amendment to the
approval (once issued) will be necessary to reflect the planned stormwater retention ponds and
23
the asphalt/concrete barrier, the slow progress of the railroad negotiations that first began June 3,
2014, and that approval from the NC Inactive Hazardous Waste Sites Branch was close, but not yet
final.
Raleigh Metal Recycling NC provides NSA with written narrative description of Stormwater,
Containment and Remedial work proposed to be conducted in railroad right of way, with
3
accompanying exhibits and again expresses need to move the matter along quickly so that
agreements would be in place by June, allowing construction to begin by early August
Raleigh Metal Recycling NC provides NSR with draft survey plat showing the geographic extent of
23
the proposed barrier installation and related land use restrictions, and again expresses an urgent
desire to keep the process moving
March
Raleigh Metal Recycling NC informs NSR that the EPA Risk Based Clean-Up/Disposal PCB Approval
is imminent, which means the railroad access is the single largest issue open before project
25
construction may begin; NSR states it has requested the drafting of the necessary Environmental
Right of Entry Agreement
EPA issues Risk Based Clean-Up/Disposal PCB Approval; a revised approval will be necessary once
NCDENR provides final approval of the stormwater retention ponds and the more durable
30
asphalt/concrete barrier, both of which are different from the 2012 containment proposal that
EPA approved
Attorney for Raleigh Metal Recycling NC requests a status update from NSR by phone, then by
8
follow up email
EPA informs Registered Site Manager that Risk Based Clean-Up/Disposal PCB Approval will need
to be modified to reflect revisions to 2012 Containment Remedy Proposal due to inclusion of
15
stormwater retention ponds and changes in the materials used in the containment barrier only
after DENR approves those changes to the Containment Remedy Proposal, as included in the final
Remedial Action Plan
Attorney for Raleigh Metal Recycling NC requests a status update from NSR by phone, then by
follow up email, and again expresses the need to move the matter forward so that construction of
16
the containment barrier and stormwater retention ponds may begin
Attorney for Raleigh Metal Recycling NC (William Toole) informs attorney for City of Raleigh
April
(Nicolette Fulton) of ongoing difficulty obtaining meaningful responses from the railroads,
16
reporting that email correspondence with the railroads began in June 2014, and that there are
regular efforts to instill the railroads with a sense of urgency about the matter
DENR project manager (Matt Aufman) informs Registered Site Manager (Daniel Nielsen) that
despite delays with railroads it would be best to obtain railroad access agreements before
29
submitting final revisions to Containment Remedy Proposal reflecting the proposed installation of
two stormwater retention ponds and use of asphalt/concrete for the containment barrier
Raleigh Metal Recycling NC informs NSR of increased regulatory interest in moving the project
30
forward, and expressing both concer and urgency about delays getting meaningful responses from
the railroads
Attorney for Raleigh Metal Recycling NC (William Toole) calls, then emails, representatives for
20
each of NSR and NCRR again requesting draft access agreements, expressing the matter is an
"urgent priority"
Registered Site Manager (Daniel Nielsen) sends email to NSR engineer (Scott Pittenger) reporting
May'
the issuance of the EPA Approval, the non -responsiveness of the NSR and NCRR representatives,
reporting the impatience of regulators and requesting Pittenger's help to move the matter
28
forward; Pittenger responded that Raleigh Metal Recycling INC should submit a Right of Entry
request to NSR, and that NSR planned to send a list of "clarifying questions" to Raleigh Metal
Recycling NC "soon"
Railroads submit comprehensive 16 question written request for information to Raleigh Metal
July
Recycling NC; many questions had been answered previously
21
Complete Existing Impervious Soil Survey
11
Permitting for Impervious Surfaces
August
Raleigh Metal Recycling NC provides comprehensive response to Railroad requests for
26
information, including technical support memoranda

Attorney for Raleigh Metal Recycling INC (William Toole) emails representatives for each of NSR
September
16
and NCRR again requesting status of railroad review of August 26 response, and asking whether
additional information is needed
27
NCRR states its review of the August 26 response is ongoing
Attorney for Raleigh Metal Recycling NC (William Toole) emails representatives for each of NSR
9
and NCRR again requesting status of railroad review of August 26 response, and asking whether
additional information is needed
NSR (Helen Hart) reports it and NCRR are working on the required access agreements and
9
requesting some additional information, which Raleigh Metal Recycling INC had previously
provided but which was again provided on the same day as the request
12
Tree location survey
October
Attorney for Raleigh Metal Recycling NC (William Toole) emails representatives for each of NSR
22
and NCRR requesting status of draft access documents previously promised by the railroads
Attorney for Raleigh Metal Recycling NC (William Toole) emails representatives for each of NSR
and NCRR requesting status of draft access documents previously promised by the railroads;
27
NCRR (through outside counsel) reports it is drafting the agreements and hoped to distribute
them within a week
Attorney for Raleigh Metal Recycling NC (William Toole) emails representatives for each of NSR
12
and NCRR requesting status of draft access documents previously promised by the railroads
NSR distributes five separate access agreements: (1) Declaration of Land Use Restrictions; (2)
17
Agreement for Land Use Restrictions and Indemnification; (3) Flowage Agreement; (4)
Environmental Right of Entry; (5) Land License
November
City of Raleigh complains of delays by Raleigh Metal Recycling NC, non -responsiveness, and
excuses, and demands by December 23 detailed report on all progress made towards
23
implementation the Stormwater Management Plan and Remedial Actioni Plan, and timelines for
completion
Attorney for Raleigh Metal Recycling NC (William Toole) emails demand from City of Raleigh to
23
representatives for each of NSR and NCRR and again requests focused attention from railroads
Raleigh Metal Recycling NC delivers Comprehensive review and mark up of the railroad access
14
agreements; proposes in -person meeting to discuss the open issues and provides dates
15
NCRR requests additional information
Raleigh Metal Recycling NC delivers requested additional information, which had been previously
December
16
delivered to railroads
Railroads set December 23 as date to meet with Raleigh Metal Recycling NC for initial page
17
through of railroad access documents and to discuss open issues and party positions
Meeting (planned) between Raleigh Metal Recycling NC and railroads for initial page through of
23
railroad access documents and to discuss open issues and parry positions
Activity
Related to Approval or Implementation of Stormwater Management Plan
Related to Response to City of Raleigh Requests for Information
Related to Effort to Obtain Access from Railroads
Related to Approval or Implementation of Containment Remedy or Remedial Action Plans
Related to Site Ownership or Operation

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NOTES'
I. A OELIARA IRIN LY PERPETUAL LAND USE RESMCRONS LIMDM IHE USES
6 WS PROPERTY IS RECDPDED AT BLW . PAGE
2 AREA A OF PB PROPERTY RAS SUBSURFALY IXWTAMINAROW ME RCCLWDED
DEOARA RW OF KRPCTUA[ LAND USE RESMCRMS FOR ME PRDPERIY
FOR SP[OAC WFORMARCW
J. WEN /HIS PROPERTY OR ANY PART OF IT 15 SLED LEA5E0, CON1£YED Do
IRAR5 Rf0• NC. GS IJOA-JIaS(e) REWIRES WA WE FILL OWNG
LANWAC£ BE PLACLD /N WE DESCMPRON SECnW OF RC OCEO OR OTHER
NSIRUMENT W TRANSFER W NO SMALLER TYPE WAN NA USED IN R/C
BOGY CY NC OELD
RAS PR W RTY HAS BEEN USED AS A HAZA OUS WBSTANCE OR
WASTE p5PO 91E. A WDLT O9• NACPW HAZAROWS SUBSTAALX
OR WASTE DISPoSAL 9i[ IS RfCORLCD N WAKE COUNTY RCdSRR CY
XLDO OYAOY AT BOOK PAX WESRONS LVNXRNING
RAS MATTER YAY BF OIRCCTEO TO PLC N00?N CMLl1NA aW90N LY
WASH MANAC£NENT, SLADWZINO SECONN NACnW HAZARDOUS VMS
BRANCH 1646 MAIL SfRNLC OYNMR, RAUZIO NC 27699-1646
4 APPROYEO FOR TNC PIMPOSCS LY NCGSIMA-310.8
DAM SIFWA LURE INNIDD SYG ARMC
AM BATESLN LG
ewrR SUPERNND WCRW
aWY N Of WASTE WALAXWNT
NORTH CAROINA CWNTY
/ A NOTARY RL W SAID LWNIY AND
STATE, DO LLRERY CERRFY NAT DID PERSLWALLY
APPEAR BEFORE AND S BEFORE ME NIS THE_ DAY OK_
NOTARY PUBIC
MY GOWN/SSttN EXPIRES
S HAZA.WYX/5 WAS]£ LIST
ARSCN/L
B£NZq'B,VMCNE
BENZLd/RANR/ENE
BNZLNWC Ado
CAOYR/Y
dEOROYOPY
d ROR
COPPER
!,4-p•CHLLIPWENZCNC
1.z-adrccmxmENr
LEAD
MAMAWX
MEWVRY
PER
9L 4ER
NALANLORCRIENE
HuwM
;24- MpROPLCIHEOCNIOBENIfNE
NE M
w
YNn dncwrx
6. I E AREAS AND Tl'Po OF CONIANNADOW XRCRD UPON MIS MAP IS
APPROMMA DDNS DEFYKD FROM R/F BEST AMIABLE ROMMA DON
AT WE RUE OF RUNG
INFORYARDY WAS TAKEN FROM YAPS PRONDED BY MLD-ARANOC AS A MS
INC DATED AUGUST Mll FOR RUE METAL PRIXiSSORS SEYMWR BROW
WIE WR T C PANY. LLC L ME SOL EXCAYATKN BARBER RACEMENT AND
TREATMENT AREAS AM SITE MAP REINDIAL ACTLON RAN
1. NO TELO AIRILY AT TMS RYE. WFORYAWLI TAKEN FRW ABOW REFERENCED
MAPS AND BWMARY WFOPMATKN FMM/ NAPS BY AMMY BARBOIR SURW.L2
ENRILED "SUR4 Y FDP ARANRC SCRAP AND METAL PROC Na N/F K A' L
SCRAP AND WTAL DATN B-Sr-06'
RENSED 7-JI-MI4
ADDED PROPOSED PONDS AND
NOTES 1-7 ON 514CN 2
RENSEO 2-2J-2015
ADDED RENSEO AAEA A" PER YAP BY
MID ARANIM IAL WEERWG R ENNRO WTAL
SOURONS OA IN AN 2015
CURVE DATA TABLE
CUPW RApVS LEWN
OLL TA
CHOVO
CN.BCARWG
CI
157194'
IJ 54'
0Z9'49
1161'
W77B'OB'W
C2
9249J'
$572'
2'4955'
4571'
S144J'49'W
CJ
9B49J'
159.0'
9t5'JI
15900'
S11J0'59'W
CI
6=55'
16104'
1576'40"
162.55'
W219D6'W
C5
9849J'
44J4'
SB446'
44.34'
SO479T#E
C6
9549J'
JB535'
21W'17'
MJ IJ
N0571'DBE
O
9549J'
29156'
17; '4B"
292MY
N027072T
L/VE DATA TABLE
L.E N.P. GLPEC➢W DLSFAIICE
[I .SZJSYIIT JOW'
[1 SZJSIYIE JOOO'
LJ NB47JWT JOW'
W
OU
Z Q
Pom !
O
OLE? BO X JCSVTS
DEED BO.N 248p PACE J22
LY W
BEEP BOOK 1412 PAGE
O
J92
DENS" 12, PAGE J91
O Z
BEN BOOK 21211), PAX 28
- W 0
BLKN' P/ YAPS 1946, PAGE JI
REFERENCES'
0,
DEfD BOOK 8516. PALE 896
0 O
OEfD BOOK 1764 PALE 281
I
DEED BOgY 1764 PALL 289
, LI
OEEO BOCK' JS59. PACE 94B
O J
BOOK PT MAPS 1961, PAGE 222
4
BiXW PI MAPS 1959. PAX 42
N
BULW of MAPS 19J5 PAX 104
BIXM' of YAPS SO'Ax PAGE 662
AN / IM28M149
SYMBOL LEGEND
MW—MONITORING WELL
APPROXIMATE LOCATION OF
BARRIER AREAS
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AND STATE, Lp HEREBY CERNFY NAT
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"I4
MY O .590, [CONES
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SNEET 2 OF 2
NOTJCE OF INAC77VE HAZARDOUS
SUBSTANCE OR WASTE DISPOSAL SITE
✓IMMYBARBOUR SURVEYING, PA RALEIGH METAL
JIMMY C. BARBOUR. PLS. GSI D —WR MD—
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3 .1 a RAx6vR. nm[ay.M 1. AnKrt R. e_eau � I I W..ar�wff
SV I RENSEB 2-23-M15
AWED PENNED AREA A- PER MAP BY
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NORTH:--'.LbJL MW-„
PONO P MW-26 a A(L &'STANCES ARE IIPiIZWTA( (T'IX/NO 01SrAN[YS
AREA BY C"&NA)E MERIW
MW-5 1 5'6'J!Y I00 0 100 200 OOOEE
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b�'WIN ' /[jJ a^ 6 .......... l 1 JJ9[ GRIPNIC SCr1E - PEEI
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a p } 4 EM Qb 4 .Y. n-V N Ml ld U m a �Ad• aMAf sr. MAR T @Rry N ME R
gp [ws o-¢rem wnxaw vAs mMo /. -- al P. 0. BOX 28 Nc
6 ��i �oq [r nosrra mw .xir mw _._._._._._.-emuorwrn'wu .' SMIiHEIELD, N.C. 27577 SfRKI[a Wr ay... e.
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NOTES
1. A XCLARADON LY PER DML LAND USE RCSMCPON% LNNIM THE USES
Of 1//lS PRp'EFTY, IS RECORDED AT BDCM PACE_
2. AREA • OF JM PRCRERIY NAS SUBSURFACE IXN/lauWA ]WW SCC RECGROED
DEaARA DO! OF PERPETUAL LAND USE RESTMCPONS FOR MC PROPERTY
FCN ,SPEOAC AFORYA nO/
J WILN ]MS PRPERTY OR ANY PART O- IT a SLCO LEASED, CMl£1ZD LN
MANSEERRLD, NCGS 1JOA-JIO.B(e) REWIRES THAT ME FULOWNC
LANWAGE B£ PLACID W DN OCSGWPnON YCAOJ LY DIE DEED OR O1 R
WSWRUYCNT LP TRAN9(R W NO SMALLER T1PE DIAN MAT UMV W THE
BODY Or NE DELD.'
7M15 PRWERT✓ HAS BEEN USED AS A HAZARDOUS SUBSTANCE OR
wASTF OSPOSAL SIR. A NODCF U INACPW HAZARDOUS SUBSTANCE
OR WASP£ OSPOSAL 91E 15 RCCORMD W walE CO/NTY RCOSRR OF
XML PTLY AT BOOK , PAX WE5nWS CYRCERMNC
IRIS YA TRR YAY BE DIRECRD TO D? NCRM CAROLINA O'N90V Cr
wA5TE MANAXAM T. SUPERFUNO SCcnw, WACnW HAZARDOUS STIES
RRAMYL 1616 YM STANCE CC . RALEWOL NC 27699-1646
A APPROKD TOP ME PIMFOWS O' NCCS IJOA-JIQd
OAIF SIGNA IURE PDW RD 9CNA MOE
JM BATFSON LG
CNl£F, WP0?FZ O 56CDON
&N9ON OF WASTE MANAGEMENT
NORM CAROWA COUNTY
/, A NOTARY PUBLIC CR SAID COUNTY AND
STATE, CO NLALBY CERTFY MAl OO PCRSLWALLY
APPEAR BEFORE AND 9W t3ETOPF ME MIS 1HE DAY Or
-
NOTARY PUBLIC
MY CCWMIS9CN EXR'RES
S HAZARDOUS WASTE L15F
ARSFMC
BEND0(,PMENE
BENZO'6)FL0URANMENE
BCNZONC ACID
CRLORCRORY
CHROMIUM
COPPER
1,1-OCHLONDWNZENE
1.2-OCNOROEDICNE
LEAD
MAM ANLSF
MERCURY
PCB
9L WR
?WALNL MCT12NE
PiALLA,M,
RICHL0RO9CNZENE
MCNL
INILHLCRLCMENC
ZWC
NNK OKNBOE
6. DIE AREAS AND TYPE CY CCWTAYWAD N OEPLCIED UPON MIS MAP IS
APPRONMA PONS OEMKO FROM IN£ BEST AMAKABL£ WFCRYA MN
AT PAC WE O' fZNG
INFORMA DW WAS TAKEN FROM YAPS PRONOEO BY MID -A RANDC ASSO]ATES
INC DATED AUWST 10I1 FOR RALEIOI METAL PROCESSOR$ SEWWR BROWN
INKSOIENT COAPANY, LED OF M£ SOL EXC AADN, SARMER PLACYYENT ANO
IREAIMENT AREAS AND 9TE YAP REMEOAL ACPW PLAN.
2, NO REED AARWY AT INS TIME RPDRUADON WEN FROM AWW RCFEBENCED
MAPS AND BWWARY INTOPYATKW TRW MAPS BY JMYY BAM19O'/R WRI£)
EVRRED WRLEY FOR ARANPC SCRAP AND PETAL PRCCESSANL N/F K & L
SCRAP AND METAL DATED 8-21-06
CUR I/E DATA
TABLE
CURK RA S LENON
OEL TA
CHORD
WBEARWG
O
157J94' IJ 64'
O2948'
116I'
SO778'O9'w
C2
9219J' 4572'
1M9-55'
12 A'
511-IJ19V
CJ
98!93' 1590'
975'J1'
159.00'
SI19O59'w
CA
60155' 16101'
1528.40_
16255'
W279-MW
C5
9B49J' 14J1'
2JA'46"
11.J1'
S012909T
C6
9549JM5M'
11W'17'
J6 13'
ND5]IOST
C2
954 SJ 29156'
D¢6LB_292.40'
1022022T
LAE DATA
TABLE
L111E No. OL?ECAOv
DISTANCE
Ll S23301T
JO00'
L2 .i2J3Y11T
MOD'
LJ NBI7J'29T
MOD
IA
U1
U U
Z Z
LAROWA E h LIGHT £SVIS
~
o 2
OLEO 600o 21BB PACT J22
OE£O BOO' N21 PACE 509
' K W
W
O D
q 1922 PACE J92
DIM
U 2
bl
DECO BO..N' 1117 PACE 18
K O
BOO' of MAPS 1946. PAX JI
REFERENCES'
I O M
O£FD BOM' 8516, PACE 8M
O
GEED XOK IM'B PACE 287
GEED BUM' I266. PACE 289
ti N
DEED BUM' JJ59, PACE 91B
I i' O W
BOOM of MAPS 1962, PALE 222
BUM' of MAPS 1959, PACE 4
Z Q
i VI
BOOK of MAPS 793A PACE 101
BUM" o/ YAPS 2000. PACE 662
PW / 12018)8219
SYMBOLLEGEND
MW—MONITORING WELL
APPROXIMATE LOCATION OF
1J BARRIER AREAS
— — — ­— --- —•---— BOUNDARY OF "AREA A"
CHAIN —LINK FENCE
BULKHEAD
— — — — — GIS PARCEL LINE
GIS RAILROAD CENTERLINE
— — — — -------GIS STREAM CENTERLINE
GIS PLANIMETRICS LINE
M
fIR MMM'1
v/S
WfARK W 4t
REN5F0 7-JI-1011
W IMES
IT65 M SVTf2D
LR
[FISTXG 2M RCBM
ApOED PRC1oO5E0 PWOS AID
w/ r+
RRTLR WEiLR / vim vALri
RR55
Rranom sPn[ SD
MISS I-T W 9IE£T 2
n¢ nM�¢ M
wN/nL
wRDt Ait WKA
CLv
E>47xG GKAEIE u}IIKJR [PRU
P0.[-[PfMxFAO
iRP tM
c/L----axrtwxL
a RWO
IX c rwwLR-xM6x rue rpno
cr
qs
wrnnLD rvnn raw RLrtRL.R.w swRLn
cmron cxRm[[ WAY
RENSEO 2-2J-2015
LRM
[FrSRW PMPWO SA£ fblU
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ROF K MAY
YAP BY
d
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WD A 7LANSEOAREAA'PER
MO ARAN'DC ENO S FNNRCW£NTA< 6
%" iRw Is[ Rl tuAr r/ 4nuw
AN
AN 2O
SIXU11W5 DA Ri) 1015
KRriL �^6x �"� LMna
ExTNG W4MiC wl i0'AO
AErIIDA ¢ LC[D.T mrcc
aTCD'Qm x waY: r�¢
LAURA M. FYOOKW r(Lf51p orKIDS eY
OWNERS ACNNOMLEOCEMENT
GREG RY BROWN. PRE9C£NT
RALDO't RECYCLING NC SCRAP METAL LLC
DATE VOIAWRE
PRWW£O 96WA WAT
I, , A NOTARY PUBLIC Oo SAID COUNTY
AM STATE W HEREBY CERTIFY TNAT
OO P£RSCN4LLY APPEAR AND 9GN BEFORE ME M15 IHE DAY CY
2014
NOTARY HIAK
MY coutes4ON EXPIRES
IMS YAP IS WCOMED W 2 9IEET5
SHEFT 2 Oe 2
NOTJCE OF INACTIE HAZARDOUS
SUBSTANCE OR WASTE DISPOSAL SITE
JIMMY BARBOUR SURVEYING, PA RALEIGH METAL PROCESSORS
JIMMY C. BARBOUR, PLS, GSI I W MN96R NLD01591s
n M O RALERN RECKLWC NC SCRAP METAL LED
213 S. SECOND STREET mwrsw Sz MAR✓s �"'^ -KF T"
P. 0. BD% 29
SMITHFIELD. N.C. PS]] awtnm n5EF IpIES •xt BYONDA MLYPE
91998E 2 Bt0-BBP3p13 _A..

EXHIBIT 4
Correspondence from Daniel Nielsen to William Toole (December 21, 2015)

["ri d Atlantic
Engineering & Environmental Solutions
December 21. 2015
William W. Toole
Robinson Bradshaw & Hinson, P.A.
101 N. Tryon St., Suite 1900
Charlotte, NC 28246
Subject: REMEDIAL ACTION PLAN CERTIFICATION PROCESS
RALEIGH METALS RECYCLERS
RALEIGH, NORTH CAROLINA 27610
SITE ID 045915568
Dear Mr. Toole:
409 R,e.s Vic, Cm,,,
R,,16,1 . NC 2 16 10
OR: 919.250.991a
ltsinid 919.250.9950
MAAONLINE.COM
I am the Registered Site Manager (RSM) for the Raleigh Recyclers Site and, as such, I am
responsible for certifying to NCDEQ that the actions to be taken by Raleigh Recycling NC Scrap
Metal, LLC pursuant to the Remedial Action Plan (RAP) comply with the rules of the Registered
Environmental Consultant (also known as the Voluntary Clean -Up) Program. Per your request, I
have prepared this letter describing the process required in order to certify the RAP for the Raleigh
Metals Recyclers project. As described below, the RAP certification process cannot go forward
until the North Carolina Railroad and Norfolk Southern (the railroads) agree that the historic
contamination may remain on certain portions of the railroads' right-of-way (Railroad Right -of -Way)
at levels above unrestricted use standards.
This project is in the Registered Environmental Consultant Program (REC Program). This is a
voluntary program whereby the Remediator engages a Registered Environmental Consultant
(REC), acting through a Registered Site Manager (RSM), to conduct environmental assessment
and remediation activities in accordance the REC Program Rules (15A NCAC 13 .0300 Voluntary
Remedial Action Oversight By Registered Environmental Consultants). For the Raleigh Metals site,
Raleigh Recycling NC Scrap Metal, LLC as the Remediator, Mid -Atlantic Associates, Inc. as the
REC and me as the RSM executed an Administrative Agreement (AA) with NCDENR (now
NCDEQ) on April 17, 2014.
After extensive assessment activities conducted from 2007 to 2012 by a previous, unrelated party,
a RAP was developed to address soil and groundwater impacted by releases of metals, petroleum
compounds, chlorinated solvents and PCBs at the Raleigh Metals site. Because the RAP calls for
some contaminated soils above unrestricted standards to remain in place, Land Use Restrictions
(LURs) are a part of the remedy. Therefore, a Containment Remedy Proposal (CRP) must be
developed and receive NCDEQ concurrence before the RAP can be implemented. The project is
complicated further because PCBs are present at the Raleigh Metals site and the remediation of
PCBs is regulated by EPA through the Toxic Substance Control Act (TSCA). Therefore, in addition
to NCDEQ concurrence of the CRP, the RAP for the Raleigh Metals site must also receive EPA
approval and permission to use LURE; to address the PCB impacted soil.
In 2011, a CRP was developed and concurrence with NCDENR achieved. In 2012 the RAP was
submitted to EPA, before Raleigh Recycling NC Scrap Metal, LLC entered the program as
EXPERIENCED CUSTOMER FOCUSED INNOVATIVE

RAP Certification December 21, 2015
Raleigh Metals Recyclers Page 2
Remediator in April 17, 2014. EPA gave its approval to implement the PCB -related portions of the
RAP in 2015.
In the intervening years between the time NCDENR approved the CRP and EPA provided approval
(approximately 3 years), two significant revelations occurred in association with the project. First,
stormwater quality issues were identified at the Raleigh Metals site requiring the RAP to be
modified to address stormwater quality. .These modifications include the construction of two
stormwater retention basins and a change to hard surface pavement. Secondly, surveys revealed
that Railroad Right -of -Way proposed to be subject to the land use restrictions, barrier and certain
stormwater upgrades described in the RAP is much greater than originally thought.
In order to implement a RAP that uses a CRP and thus requires LURs, NCDEQ requires
documented permission from all property owners where LURs will be used to address
contaminated soils remaining in place at levels above unrestricted use standards. The RAP calls
for the removal of some contaminated soils from the Railroad Right -of -Way and three other
adjacent or nearby properties, and so LUR approval from these properties is not required.
However, it is not feasible to remove all contaminated soils from the Railroad Right -of -Way. Thus,
permission from the North Carolina Railroad and, we are informed, from Norfolk Southern, to leave
soil in place that does not meet unrestricted land use criteria must be obtained before a revised
CRP can be resubmitted to NCDEQ for its concurrence.
Looking forward, once permission to implement the LUR on the Railroad Right -of -Way is obtained,
we will submit the revised CRP to NCDEQ. After receiving NCDEQ concurrence, we can then
submit the revised RAP (including the revised CRP) to EPA to request an amendment to the EPA
PCB Approval issued in March 2015. With the approval of these changes documented, NCDEQ
will put the RAP out for mandatory public notice and comment. After the public comment period is
concluded, we will coordinate with NCDEQ to address public comments (if any) and modify the
RAP as necessary. Once complete, the RSM can then submit the REC-certified RAP to NCDEQ
and implementation of the RAP can commence.
I trust this letter clarifies the process mandated by 15A NCAC 13 .0300 (Voluntary Remedial Action
Oversight By Registered Environmental Consultants) to certify the RAP.
Sincerely,
Cd�Rp1
V e — SEAL
Dan` Nielsen, PE, RSM r o 10S. 149
Principal Engineer �;;, kt lT'J;-"
CC: Mr. Greg Brown — Raleigh

I
J
1TASN�
DURATION
START
FINISH __
__
Receive Required Written Access to Railroad ROW
Unknown
Day 0
Day 0
Remedial Action Plan Approval
165 days
Day 1
Day 165
NCDEQ Approval of Containment Remedy Proposal
45 days
Day 1
Day 45
EPA Approval of Revised Remedial Actoin Plan
45 days
Day 46
Day 90
Finalize and Submit RAP for Public Notice
15 days
Day 91
Day 105
Public Notice Period Complete
30 days
Day 106
Day 135
Address Public Notice Comments
15 days
Day 136
Day 150
REC Approval of RAP
15 days
Day 151
Day 165
Construction Drawing & Permitting
190 days
Day 165
Day 355
Mass Grading Submittal
60 days
Day 165
Day 225
Prepare Site CD's
30 days
Day 166
Day 195
Submittal to City of Raleigh
0 day
Day 195
Day 195
First Review by City
10 days
Day 196
Day 205
Respond to Comments / Resubmit
30 days
Day 206
Day 215
Approval / Issuance of Land Disturbance Permit
30 days
Day 216
Day 225
Railroad Construction Submittal
100 days?
Day 195
Day 295
Submittal to Railroad
0 day
Day 195
Day 195
First Review by Railroad
60 days?
Day 196
Day 255
Respond to Comments / Resubmit
10 days
Day 256
Day 265
RR Review / Approval
30 days?
Day 266
Day 295
Infrastructure Construction Plans Submittal
60 days
Day 295
Day 355
Prepare Site CD's
30 days
Day 296
Day 325
Submittal to City of Raleigh
0 days
Day 325
Day 325
First Review by City
10 days
Day 326
Day 335
Respond to Comments/Resubmit
10 days
Day 336
Day 345
Approval of Infrastructure Construction Plans
10 days
Day 346
Day 355
Construction & Implementation
435 days
Day 225
Day 660
Selection of Contractor
30 days
Day 226
Day 255
Demo/Movement of Material Onsite
45 days
Day 255
Day 300
Soil Treatment Leachable Metals
60 days
Day 301
Day 360
Barrier Placement North
90 days
Day 361
Day 451
Construction of North Basin/Infrastructure
60 days
Day 361
Day 420
Relocation of Onsite Material
60 days
Day 421
Day 480
Barrier Placement South
90 days
Day 481
Day 571
Construction of South Basin / Infrastructure
60 days
Day 481
Day 540
Certification of Basins
30 days
Day 541
Day 570
Post Construction Stormwater Quality Evaluation
90 days
Day 571
Day 660

s;•.�r.. ,r,.: use.,
.}}yy Compliance Inspection Report
Permit: NCG200335 , - Effective: 01/01/10 Expiration: 12/31/14 Owner: Elite Newco I LLC
SOC: .Effective: Expiration: Facility: Raleigh Metals
County: Wake ,•*;_t�.•.. 2310 Garner Rd
Region: Raleigh
Raleigh NC 27610
Contact Person:, . Dan , Wall Title: Phone: [phone]
r:
Directions to Facility:• '
System Classifications:
Primary ORC: Certification: Phone:
.: Secondary ORC(s).
On -Site Representative(s):
Related Permits:
Irspection Date: 08/27/2013`j: ' Entry Time: 09:30AM Exit Time: 12:OOPM
Primary Inspector: David R Parnell Phone: [phone]
Secondary Inspectors): , � j .
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Wholesale Trade of Metal Waste and Scrap Stormwater Discharge CDC
Facility Status: Compliant ® Not Compliant
Question Areas:
® Storm Water
(See attachment summary)
d -
Page: 1

permit: NCG200335
Inspection Date: 08/27/2013
Owner - Facility: Elite Newco I LLC
Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
This facility was inspected after a report to DLR of an illicit discharge which flowed onto an adjacent property. DLR RRO
reported that the clean up had been concluded.
M
Page: 2

I1t,•t 1 �' f � . .eF �'fi
Permit: NCG200335 Owner- Facility: Elite Newco I LLC
Inspection Dale: 0812712013 Inspection Type : Compliance Evaluation Reason for Visit: Routine
1 '
Stormwater Pollution Prevention Plan
Does the site have a Slormwater Pollution Prevention Plan?
r, # Does the PIan 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?
rv, ,# Does the Plan Include a list of significant spills occurring during the past 3 years?
µ•# Has the facility evaluated feasible alternatives to current practices?
# Does the facility provide all necessary secondary containment?
tip # Does,the;f Ian include aBMRsummary?
# 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?
17.1# Does the: Plan include a,list of Responsible Party(s)?
# Is the Plan reviewed and updated annually?
Does the,Plan includesSlormwater. Facility Inspection Program?
�':';Has-the Stormwate.Pollution�Preyention Plan been implemented?
Comment,
Qualitative Monitoring
Yes No NA NE
■ " ■ ■
No
■ ■ ■
■■■
it ■ ■ ■
■
�� A+■■■■"■�
Yes No NA NE
.r Has the facility,conducted. its Qualitative Monitoring semi-annually?. ® ❑ ❑ ❑
Comment: For previous monitoring periods the facility was not sampling all six of the outfalls. The
monitoring period for the last six months of 2013 was conducted properly.
.. AnalyticalMonitoring .yes No NA NE
Has -the facility conducted its Analytical monitoring? i ❑ ■ ❑ ❑
`# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ® ❑ ❑ ❑
i
Comment: For the previous sample periods the facility was not sampling all six of the outfalls. It conducted
the required outfall sampling in on June 2013. However the sample results were beyond
"•,.r ; benchmarks for many of the parameters at the outfalls. Above benchmarks at one or more of
the outfalls'Induced Cadmium. COD. Copper, Iron, Lead, Oil and Grease, TSS and Zinc.
Please adhere to the requirements of the permit with respect to the Tier program.
`PermrtLand outfalls yes No NA NE
\ # Is a, copy of the Permit and the •Cenificate of Coverage available at the site? ® ❑ ❑ ❑
. :.' # Were all oulfalls 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? ❑ ® ❑ ❑
Page: 3

Permit: NCG200335 Owner- Facility: Elite Newco I LLC
Inspection Date 08/27/2013 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Comment: An illicit discharge of oil/water was reported to DLR RRO on 8/23/2013. Highlands
Environmental Solutions. Inc: handled the cleanup. The discharge was discussed during the
inspectionand prevention actions were suggested. The facility reports that appropriate
measures have`been implemented in order to prevent such a spill from reoccuring.
�r; .x ,�! 4 ° tea:. _, ;:{ r •:8..
Page: 4

A
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory John E. Skvarla, III
Governor Secretary
December 16, 2014
RALEIGH METAL RECYCLERS—NCG20O335
Memo to file by Dave Parnell:
Subject: On site meeting between Raleigh Metal Recyclers representatives and Raleigh Regional
Office staff.
Representatives present:
Danny Smith - DWR RRO Supervisor
Dave Parnell - DEMLR Stormwater RRO
Jon Aldridge - McAdams
Dan Nielson - MiclAtlantic
Bill Toole - Robinson Bradshaw
Greg Brown - Raleigh Metal Recyclers
Meeting at the Raleigh Metal Recyclers conference room at 2:00PM - 12/16/14
The meeting was requested by RRO staff to assess the progress of the facility towards the
resolution of their NOV issued by DWR. The NOV was for DWR Stream Standard Violations. In
conjunction with a prior NOV issued by DEMLR Stormwater as well as, the installation of a barrier
(to be approved by EPA/REC) to hold in place PCB affected soil; a timeline was submitted to DWR
for implantation of those measures.
Mr. Brown described some improvements that had been implemented, but no implementation of
stormwater treatment units has been installed. Mr. Toole asked if the stormwater treatment
units had been approved by DENR, indicating this was a reason for the delays. No comments have
been issued by either DWR or DEMLR on their stormwater plan. It was suggested that a
sedimentation and erosion control plan be submitted to the City of Raleigh, which would include
the proposed stormwater treatment units. This action would enable the process to begin as soon
as possible. Mr. Parnell suggested that Mr. Aldridge be in contact with Mike Randall, of DENR
Stormwater Permitting Program, as well during this process. He could advise on the metal
reduction techniques required for these units. Mr. Brown suggested that RRO staff come to the
site every 30 days to observe the stabilization of areas of the site with vegetative cover. Mr. Smith
suggested that Mr. Brown and his consultants provide a unified response to the delays. Mr.
Brown and his consultants agreed to submit a S&E Plan to the City of Raleigh in the next two to
four weeks.
Division of Energy, Mineral, and Land Resources
Energy Section - Geological Survey Section • Land Quality Section
1612 Mail Service Center, Raleigh, North Carolina 27699-1612.919-707-9200 / FAX: [phone]
512 North Salisbury Street, Raleigh, North Carolina 27604 • Internet: htto://Portal.ncdenr.orgtweb/Ir/
An Equal Opportunity 1 Affirmative Action Employer— 50% Recycled 110% Post Consumer Paper

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NC®ENR
North Carolina Department of Environment and
Division of Water Resources
Water Quality Programs
Pal McCrory Thomas A. Reeder
Governor Director
March 27, 2014
Certified Mail
Return Receipt Requested 7012 0470 0001 3843 0822
Seymour Brown Investment Co., Inc
Registered Agent: W. Harrell Everett Jr.
507B Spence Ave
Goldsboro NC 27534
Certified Mail
Return Receipt Requested 7012 0470 0001 3843 1034
Raleigh Recycling NC Scrap Metal LLC
327 Hillsborough Street
Raleigh NC 27603
Subject: Notice of Violation NOV-2014-PC-0047
Notice of Intent to Enforce
Notice of Injunction Relief Recommendation
Stream Standard Violations
2310 Garner Road
Wake County
Dear Sirs:
Natural Resources
John E. Skvarla, III
Secretary
The Division of Water Resources Raleigh Regional Office (RRO) received a complaint from the City of Raleigh
detailing concerns about waste/pollutants coursing off the subject property and entering into surface waters. In
response, on January 11, 2014, Danny Smith, Autumn Romanski, and James Graham of the RRO Water Quality
Operations Section conducted a site visit and collected water samples.
The subject 2310 Garner Road tract is owned by Seymour Brown Investment Co., Inc. The current business
operating at the site is Raleigh Recycling NC Scrap Metal LLC and is known as Raleigh Metal Recycling. Prior
to the operations of Raleigh Metal Recycling, the footprint of this site has been industrial use and the site is
confirmed to be contaminated with polychlorinated biphenyls (PCBs).
Water Oualily Regional Operaions Section
1628 Mail service Center, Raleigh, North Carolina 27699-1629
Location: 3800 Barrett Dr., Raleigh, Noah Carolina 27609
Phone. [phone] \ FAX: [phone]
haerner www.newaterqualay org
An Equal Opponunily \ Allimwlice Action Gmployer

Raleigh Recycle -Seymour Brown Investment Co.
3/27/ t 4
Page 2 of 4
At present, 2310 Garner Road facility is being operated as a metal recycling center. Scrap/waste metal (e.g.
vehicles parts, machinery, construction debris etc.) is brought to the facility by the public and savage businesses.
This material is weighed and sorted into different piles for processing, shredding, storage and eventual shipping
(truck/railcar) such that the metal may be reused. The scrap metal is moved, stockpiled, and eventually shipped
off site. Vehicle traffic (trucks, tow motors/forklifts, cranes etc.), capable of moving, dragging, sorting, dumping
waste metal are a requisite for this type of operation. Due to this industrial traffic and land use the site is not
stable. Sediment, turbidity; -and pollutants'that are on the site from both current and past industrial activities are
easily transported from the site dining stor`ra events.
The January 11, 2014, site visit revealed/identified water discharging though an under drain from the footprint of
the site. This under drain outlet is located at the retaining wall along the edge of the railroad tracks. This water
flowed along the railroad tracks and into a culvert (pipe). This water coursed through a pipe/outlet that
discharges into an unnamed tributary to Wildcat Branch a Class C, Nutrient Sensitive Waters (NSW) in the Neuse
River Basin.

Raleigh Recycle -Seymour Brown Investment Co.
3/27/ 14
Page 3 of 4
Water samples were collected from the following locations: 1) retaining wall outlet, 2) the unnamed tributary to
Wildcat Branch, 3) the confluence of the unnamed tributary and Wildcat Branch, and 4) Wildcat Branch
(upstream).
Water discharging from the 2310 Garner Road facility contained extremely high concentrations of lead, cadmium,
mercury, polychlorinated biphenyls (PCBs), nickel, copper and zinc. This waste Flowed into surface waters and
caused stream standard violations to occur, as listed in Attachment 1.
Accordingly, the sample results confirmed violations of North Carolina General Statutes and North Carolina
Administrative Codes which states the following:
"North Carolina General Statute 143-215.1(a) states that "no person shall do any of the following things
or carry out any of the following activities unless that person has received a permit from the Commission
and has complied with all conditions set forth in the permit:
1) Make any outlets into the waters of the State.
6) that no person shall cause or permit any waste, directly or indirectly, to be discharged to or in any
manner intermixed with the waters of the State in violation of the water quality standards applicable
to the assigned classifications or in violation of any effluent standards or limitations established for
any point source, unless allowed as a condition of any permit, special order or other appropriate
instrument issued or entered into by the Commission under the provisions of this Article."
"15A NCAC 02B .0211 (3) k Turbidity: the turbidity in the receiving water shall not exceed 50
Nephelometric Turbidity Units (NTU) in streams not designated as trout waters and 10 NTU in
streams, lakes or reservoirs designated as trout waters; for lakes and reservoirs not designated as trout
waters, the turbidity shall not exceed 25 NTU."
"15 A NCAC 02B (1) Toxic substance: numeric water quality standards (maximum permissible
levels) for the protection of human health applicable to all fresh surface water are in Rule .0208 of
this Section. Numerical water quality standards (maximum permissible levels) to protect aquatic life
applicable to all fresh surface waters:
"15 A NCAC 02B (1) (iii) Cadmium: 0.4ug/I for trout waters and 2.0 ug/I for non -trout waters;
attainment of water quality standards in surface waters shall be based on measurement of total
recoverable metals concentrations unless studies have been conducted to translate total recoverable
metals to a toxic form.
15A NCAC 02B (1)(viii) lead 25uq/L
15A NCAC 02B (1)(ix) mercury 0.012 uq/L
15A NCAC 02B (1) (x) nickel 88 uq/L
15A NCAC 02B (1) (xii) polychlorinated biphenyls: (total PCB and carcinogens
identified .0.001 ug/1)
15A NCAC 02B (4) Action Level Substances:
(a) Copper 7ug/I
(d) Zinc: 50 uq/I"

Raleigh Recycle -Seymour Brown Investment Co.
3/27/ 14
Page 4 of 4
The concentrations of mercury, PCBs, lead, silver, aluminum, iron, chromium, barium, copper, nickel,
zinc, semivolatiles organics, documented discharging from this site is a significant concern. It is a concern
to not only aquatic life but to the public health.
This office requests that both parties respond to this Notice of Violation in Writing within 30 days of receipt.
Your response should minimally address the following items.
1. Please explain how you plan to stop pollutants from discharging/moving off of your site into surface waters.
2. Please explain how you will stabilize the site such that infiltration, erosion, and pollution that are coincident
to past and current land uses will be addressed to prevent ongoing and continued transport of waste to surface
waters of the state.
3. Provide a clear schedule with dates detailing how this will be accomplished such that surface water standard
violations do not continue to occur.
This office requires that the violations, as detailed above, be abated immediately and properly resolved.
Environmental damage and violations of North Carolina Administrative Codes and Statutes have been
documented for the subject site as stated above. Your efforts to undertake activities to bring the subject site back
into compliance is not an admission, rather it is an action that must be taken in order to begin to resolve ongoing
environmental issues.
Thank you for your attention to this matter. This office requires that the violations, as described above, be
properly resolved. These violations and any future violations are subject to a civil penalty assessment of up
to $25,000.00 per day for each violation.
The discharge of PCBs, mercury, semi volatiles and other metals cannot continue to occur. As requested
above, this office will review your written response and remediation schedule that you provide. This office will
consider your response as a part of any civil penalty assessment, as appropriate.
In addition, the failure to provide a clear adequate response with clear schedule to eliminate ongoing
impacts to this office will move forward an injunction relief request. This request will be forwarded to
Attorney General's Office such that a court ordered compliance schedule/injunctive relief may be secured
in order to abate continuing violations, worsening downstream impacts and to protect the public health.
Should you have any questions regarding theseVan
matters,please contact me a 919) 791-4252.
ly, /�v7/Smit egional Superysox
Water Quality Operations
Raleigh Regional Office
cc:
Division of Energy Mining and Land Resources - John Holley
Division of Energy Mining and Land resources — Bradley Bennett
Division of Waste Management - Hazardous Waste Section - Phil Orozco
Division of Waste Management — Charlotte Jesneck
City of Raleigh — Mark Senior

Attachment 1:
Notice of Violation NOV-2014-PC-0047
Parameter/Water
Outlet from
Confluence
Wildcat Branch
Quality Standard
retaining wall
Outlet to
Raleigh Metals
Waters
Recycling
Conductivity
972
805
103.4
Turbidity: 50 NTUs
550
170
75
Cadmium: 2.0 ug/I
65 ug/L
4.3 ug/L
2.2 ug/L
Lead: 25 ug/I
4300 uq/L
250 ug/L
36 ug/L
Aluminum:
100,000 ug/L
7,200 ug/L
24,000 ug/L
Human Health 8000 ug/L
Aquatic Life 87 ug/L
Mercury 0.012
16 uq/L
0.98 ug/L
Non detected
polychlorinated
biphenyls: (total PCB and
1.8 ug/L
0.58 uq/L
Non detected
congeners identified)
(PQL 1.0 uq/L)
0.001ug/I
Nickel: 88 ug/I
620 ug/L
53 ug/L
9.8 ug /L
Action Level Substances:
Copper: 7 ug/I
5000 ug/L
340 ug/L
150 ug/L
Zinc: 50 ug/I
15000 ug/L
1100 ug/L
280 ug/L
Silver: 0.06 ug/L
9 ug/L
Non detected
Non detected

s
4 a
:r
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Energy, Mineral and Land Resources
Land Quality Section Pat McCrory, Governor
Tracy E. Davis, PE, CPM John E. Skvarla, III, Secretary
Director
September 12, 2013
CERTIFIED MAIL #7012 1640 0001 9605 7874
RETURN RECEIPT REQUESTED
Mr. Paul Perrotti
Raleigh Metal Recycling
2310 Garner Road
Raleigh, NC 27610
Subject. Notice of Deficiency
NOD-2013-PC-0361
Raleigh Metal Recycling
NPDES Stormwater Permit NCG200335
Wake County
Dear Mr Perrotti:
On August 27, 2013, Dave Parnell and Chris Pullinger, from the Raleigh Regional Office of the North
Carolina Division of Energy, Mineral and Land Resources (DEMLR) conducted a compliance evaluation
inspection (CEI) at your facility, located at 2310 Garner Road in Raleigh, North Carolina. The facility lies
in the watershed of an unnamed tributary (UT) to Walnut Creek, Class C NSW waters, in the Neuse River
Basin.
The following observations were noted during the DEMLR inspection and file review.
This facility is a scrap metal processing company, which has on -site tanks utilized for used oil and
petroleum derived from junked vehicles. Andy Sanderson and you were on site during the inspection
and provided valuable assistance to DEMLR staff.
1628 Mail Service Center, Raleigh, North Carolina 27699-1628
Location: 3800 Barrett Drive, Raleigh, North Carolina 27609
Phone: 919-791 A2001 FAX: [phone]
Internet: http:portal.ncdenr.orgAvebllrl
An Equal Opponunily, 1 Affumalive Action Employer
Nne
orthCarolina
Naturally

Stormwater run-off generated at such facilities is regulated by general NPDES stormwater permit
NCG200000. The DEMLR Stormwater Program has issued certificate of coverage (COC) NCG200335.
The permit was on site and current. The Stormwater Pollution Prevention Plan (SPPP) was reviewed by
DEMLR staff. The SPPP was developed during the first half of 2013 and satisfied most of the
requirements of the permit. The plan lacked the following: documented employee training records and a
list of significant spills - for the last three years.
The monitoring reports were reviewed during the inspection. Prior to the last sampling period, only
three of the six Stormwater Discharge Outfalls (SDO) noted in the SPPP were being monitored. During
th-e last monitoring period, six SDO were monitored, qualitatively and analytically. Results from the last
analytical monitoring indicated exceedences of benchmarks at one or more of the SDO, which were for
Cadmium, COD, Copper, Iron, Lead, Oil and Grease, TSS and Zinc.
The stormwater collection system location and the drainage area flowing to each SDO were reviewed
during the inspection. Unfortunately, we were not able to determine the originating location of the
stormwater, as it flowed to each SDO and then offsite. This will make the reduction of benchmark
exceedences difficult to address, as you advance through the Tier system of your permit.
Containment and storage of oils, fuels and other liquids were adequate, with respect to secondary
containment. General housekeeping, within the shop, appeared to be adequate, as well.
DEMLR Staff and Raleigh Metal Recycling staff discussed the cause and effect of an illicit discharge that
was reported to DEMLR staff on August 23, 2013. The facility reports that measures have been taken to
assure that no further spill such as the one noted, will reoccur.
Requested response: You are directed to respond to this letter in writing to DEMLR at the address
provided below within 30 days of receipt. Please address the following items noted in bold:
• Please fully develop the Stormwater Pollution Prevention Plan by placing a list of
significant spills during the last three years, as well as documenting employee training
annually.
• The latest analytical monitoring indicated benchmark exceedences. Please adhere to the
requirements of the NPDES permit with respect to the Tier program.
• Please provide a final account of th'e illicit discharge which was reported to DENR on August
23, 2013. (It maybe helpful if your consulfa`nfprovides the report on your behalf).
1628 Mail Service Center, Ralegh, North Carolina 27699.1628
Location: 3800 Barrett Drive, Ralegh, North Carolina 27609 One
Phone: [phone] FAX: [phone] North Carol i n a
Internet: Opportunity
.Ac Affirmative
AdonlE Naturallil
An Equal Opportunity 1 Affirmative Aolion Employer

Please respond to:
Dave Parnell
NCDENR/DEMLR
Raleigh Regional Office
1628 Mail Service Center
Raleigh, NC 27699-162
Should you have questions regarding these matters, please contact Dave Parnell at [phone].
Sincerely,
L. F%oVey,yr., PE,/C
I Engineer V
Regional Office
cc: Stormwater Permitting Program Files - with attachment
DEMLR Raleigh Regional Office Files - with attachment
DWR Raleigh Regional Office Files -with attachment
City of Raleigh Stormwater Utility Division- with attachment
1628 Mail Service Center, Ralegh, North Carolina 27699-1628
Location: 3800 Barrett Drive, Raleigh, North Carolina 27609 One t
Phone: 919-79IA2001 FAX: [phone] NorthC1ro11❑a
Internet hitp:portal.
nity\Acden rmativ Action
�%i�" tu"" ��lf
An Equal Opportunity 1 Affirmative Action Employer !4 l !i

Permit: NCG200335
SOC:
County: Wake
Region: Raleigh
Compliance Inspection Report
Effective: 01/01/10 Expiration: 12/31/14 Owner: Gimco Acquisition LLC
Effective: Expiration: Facility: Gimco Acquisition, LLC
2310 Garner Rd
Contact Person: Gregory W Brown
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 08/27/2013
Primary Inspector: David R Parnell
Secondary Inspector(s):
Title:
Entry Time: 09:30 AM
Raleigh NC 27610
Phone: [phone]
Certification:
Exit Time: 12:00 PM
Phone:
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Wholesale Trade of Metal Waste and Scrap Stormwater
Discharge CDC
Facility Status: 0 Compliant ■ Not Compliant
Question Areas:
0 Storm Water
(See attachment summary)
Page: 1

Permit: NCG200335 Owner -Facility: Gimco Acquisition LLC
Inspection Date: 08/27/2013 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
This facility was inspected after a report to DLR of an illicit discharge which flowed onto an adjacent property. DLR RRO
reported that the clean up had been concluded.
Page: 2

Permit: NCG200335 Owner - Facility: Gimco Acquisition LLC
Inspection Date: 08/27/2013 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Stormwater Pollution Prevention Plan
Yes
No
NA
NE
Does the site have a Stormwater Pollution Prevention Plan?
■
❑
❑
❑
# Does the Plan include a General Location (USGS) map?
■
❑
❑
❑
# Does the Plan include a "Narrative Description of Practices"?
■
❑
❑
❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
■
❑
❑
❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
❑
■
❑
❑
# Has the facility evaluated feasible alternatives to current practices?
■
❑
❑
❑
# Does the facility provide all necessary secondary containment?
■
❑
❑
❑
# Does the Plan include a BMP summary?
■
❑
❑
❑
# 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?
■
Cl
❑
❑
# Does the Plan include a Stormwater Facility Inspection Program?
■
❑
❑
❑
Has the Stormwater Pollution Prevention Plan been implemented?
■
❑
❑
❑
Comment: The facility has a SP3 that was developed in the spring of 2013. A list of
spills for the previous three years and documented records of employee training is not
included in the plan but is required.
Qualitative Monitoring
Yes No
NA
NE
Has the facility conducted its Qualitative Monitoring semi-annually?
■ ❑
❑
❑
Comment: For previous monitoring periods the facility was not sampling all six of the
outfalls. The monitoring period for the last six months of 2013 was conducted properly.
Analytical Monitoring
Yes No
NA
NE
Has the facility conducted its Analytical monitoring?
■ ❑
❑
❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
■ ❑
❑
❑
Comment: For the previous sample periods the facility was not sampling all six of the
outfalls. It conducted the required outfall sampling in on June 2013. However the
sample results were beyond benchmarks for many of the parameters at the outfalls.
Above benchmarks at one or more of the outfalls included Cadmium, COD, Copper,
Iron, Lead, Oil and Grease, TSS and Zinc. Please adhere to the requirements of the
permit with respect to the Tier program.
Permit and Outfalls Yes No NA NE
Page:3

Permit: NCG200335 Owner -Facility: Gimco Acquisition LLC
Inspection Date: 08/27/2013 Inspection Type: Compliance Evaluation Reason for Visit: Routine
# Is a copy of the Permit and the Certificate of Coverage available at the site? ■ ❑ ❑ ❑
# Were all outfalls observed during the inspection?
■ ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ■ ❑
# Has the facility evaluated all illicit (non stormwater) discharges?
Comment: An illicit discharge of oil/water was reported to DLR RRO on 8/21 /2013.
Highlands Environmental Solutions, Inc. handled the cleanup. The discharge was
discussed during the inspection and prevention actions were suggested.
Page: 4

A
NCDENR
North Carolina Department of Environment and Natural
Division of Energy, Mineral and Land Resources
Land Quality Section
Tracy E. Davis, PE, CPM
Director
September 12, 2013
CERTIFIED MAIL #7012 1640 0001 9605 7874
RETURN RECEIPT REQUESTED
Mr. Paul Perrotti
Raleigh Metal Recycling
2310 Garner Road
Raleigh, NC 27610
Subject: Notice of Deficiency
NOD-2013-PC-0361
Raleigh Metal Recycling
NPDES Stormwater Permit NCG200335
Wake County
Dear Mr Perrotti:
Resources
Pat McCrory, Governor
John E. Skvarla, III, Secretary
On August 27, 2013, Dave Parnell and Chris Pullinger, from the Raleigh Regional Office of the North
Carolina Division of Energy, Mineral and Land Resources (DEMLR) conducted a compliance evaluation
inspection (CEI) at your facility, located at 2310 Garner Road in Raleigh, North Carolina. The facility lies
in the watershed of an unnamed tributary (UT) to Walnut Creek, Class C NSW waters, in the Neuse River
Basin.
The following observations were noted during the DEMLR inspection and file review:
This facility is a scrap metal processing company, which has on -site tanks utilized for used oil and
petroleum derived from junked vehicles. Andy Sanderson and you were on site during the inspection
and provided valuable assistance to DEMLR staff.
1628 Mail service Center, Raleigh, North Carolina 27699-1628
Location: 3800 Barrett Dnve, Ralegh, North Carolina 27609 One
Phone: 919-791 A2001 FAX: 919-571 A718 No rth C arol ina
Internet: ppo:portaLncdenr mative M1ton El Nahma�ly
An Equal OpportunirylAtirmative Action Employer K `Lt

Stormwater run-off generated at such facilities is regulated by general NPDES stormwater permit
NCG200000. The DEMLR Stormwater Program has issued certificate of coverage (COC) NCG200335.
The permit was on site and current. The Stormwater Pollution Prevention Plan (SPPP) was reviewed by
DEMLR staff. The SPPP was developed during the first half of 2013 and satisfied most of the
requirements of the permit. The plan lacked the following: documented employee training records and a
list of significant spills - for the last three years.
The monitoring reports were reviewed during the inspection. Prior to the last sampling period, only
three of the six Stormwater Discharge Outfalls (SDO) noted in the SPPP were being monitored. During
the last monitoring period, six SDO were monitored, qualitatively and analytically. Results from the last
analytical monitoring indicated exceedences of benchmarks at one or more of the SDO, which were for
Cadmium, COD, Copper, Iron, Lead, Oil and Grease, TSS and Zinc.
The stormwater collection system location and the drainage area flowing to each SOO were reviewed
during the inspection. Unfortunately, we were not able to determine the originating location of the
stormwater, as it flowed to each SDO and then offsite. This will make the reduction of benchmark
exceedences difficult to address, as you advance through the Tier system of your permit.
Containment and storage of oils, fuels and other liquids were adequate, with respect to secondary
containment. General housekeeping, within the shop, appeared to be adequate, as well.
DEMLR Staff and Raleigh Metal Recycling staff discussed the cause and effect of an illicit discharge that
was reported to DEMLR staff on August 23, 2013. The facility reports that measures have been taken to
assure that no further spill such as the one noted, will reoccur.
Requested response. You are directed to respond to this letter in writing to DEMLR at the address
provided below within 30 days of receipt Please address the following items noted in bold:
• Please fully develop the Stormwater Pollution Prevention Plan by placing a list of
significant spills during the last three years, as well as documenting employee training
annually.
• The latest analytical monitoring indicated benchmark exceedences. Please adhere to the
requirements of the NPDES permit with respect to the Tier program.
• Please provide a final account of the illicit discharge which was reported to DENR on August
23, 2013. (It may be helpful if your consultant provides the report on your behalf).
1628 Mail Service Center, Raleigh, North Carolina 27699-1628
Location: 3800 Barrett Drive, Raleigh, North Carolina 27609 One
Phone: [phone] FAX: 919a71-4718 NorthCdCO�IIIa
Internet httorpnity nA tlmative coon r/ Naturally
An Equal Opportunity) Affirmative Action Employer K !bt

Please respond to:
Dave Parnell
NCDENR/DEMLR
Raleigh Regional Office
1628 Mail Service Center
Raleigh, NC 27699-162
Should you have questions regarding these matters, please contact Dave Parnell at [phone].
Sincerely,
L. NoVey, jr., PE�
mal Engineer
gh Regional Office
cc: Stormwater Permitting Program Files - with attachment
DEMLR Raleigh Regional Office Files - with attachment
DWR Raleigh Regional Office Files -with attachment
City of Raleigh Stormwater Utility Division- with attachment
1628 Mail Service Center, Raleigh, North Carolina 27699-1628
Location: 3800 Barrett Drive, Raleigh, North Carolina 27609 One
Phone: [phone] FAX: [phone] NOrt�'1 CiirO/�/I ❑ a
Internet pponunily htIp.pertaI.noJenr.org/webIIr` AdonlE �%1%jtlfl' llb(
An Equal Opportunity 1 Affumative Action Employer

Compliance Inspection Report
Permit: NCG200335 Effective: 01/01/10 Expiration: 12/31/14 Owner: Gimco Acquisition LLC
SOC: Effective: Expiration: Facility: Gimco Acquisition, LLC
County: Wake 2310 Garner Rd
Region: Raleigh
Raleigh NC 27610
Contact Person: Gregory W Brown Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 08/27/2013 Entry Time: 09:30 AM Exit Time: 12:00 PM
Primary Inspector: David R Parnell Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Wholesale Trade of Metal Waste and Scrap Stormwater
Discharge COC
Facility Status: ❑ Compliant ■ Not Compliant
Question Areas:
■ Storm Water
(See attachment summary)
Page: i

A.
Pernik NCG200335 Owner -Facility: Gimco Acquisition LLC
Inspection Date: 08/27/2013 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
This facility was inspected after a report to DLR of an illicit discharge which flowed onto an adjacent property. DLR RRO
reported that the clean up had been concluded.
Page: 2

Permit: NCG200335 Owner -Facility: Gimco Acquisition LLC
Inspection Date: 08127/2013 Inspection Type: compliance Evaluation
Reason for Visit:
Routine
Stormwater Pollution Prevention Plan
Yes
No
NA
NE
Does the site have a Stormwater Pollution Prevention Plan?
■
❑
❑
❑
# Does the Plan include a General Location (USGS) map?
■
❑
❑
❑
# Does the Plan include a "Narrative Description of Practices"?
■
❑
❑
❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
■
❑
❑
❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
❑
■
❑
❑
# Has the facility evaluated feasible alternatives to current practices?
■
❑
❑
❑
# Does the facility provide all necessary secondary containment?
■
❑
❑
❑
# Does the Plan include a BMP summary?
■
❑
❑
❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
■
❑
❑
❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
■
❑
❑
Cl
# Does the facility provide and document Employee Training?
❑
■
❑
❑
# Does the Plan include a list of Responsible Party(s)?
■
❑
❑
❑
At Is the Plan reviewed and updated annually?
■
❑
❑
❑
# Does the Plan include a Stormwater Facility Inspection Program?
■
❑
❑
❑
Has the Stormwater Pollution Prevention Plan been implemented?
■
Cl
❑
❑
Comment: The facility has a SP3 that was developed in the spring of 2013. A list of
spills for the previous three years and documented records of employee training is not
included in the plan but is required.
Qualitative Monitoring
Yes No
NA
NE
Has the facility conducted its Qualitative Monitoring semi-annually?
■ ❑
❑
❑
Comment: For previous monitoring periods the facility was not sampling all six of the
outfalls. The monitoring period for the last six months of 2013 was conducted properly.
Analytical Monitoring
Yes No
NA
NE
Has the facility conducted its Analytical monitoring?
■ ❑
❑
❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
■ ❑
❑
❑
Comment: For the previous sample periods the facility was not sampling all six of the
outfalls. It conducted the required outfall sampling in on June 2013. However the
sample results were beyond benchmarks for many of the parameters at the outfalls.
Above benchmarks at one or more of the outfalls included Cadmium, COD, Copper,
Iron, Lead, Oil and Grease, TSS and Zinc. Please adhere to the requirements of the
permit with respect to the Tier program.
Permit and Outfalls Yes No NA NE
Page: 3

Permit: NCG200335 Owner • Facility: Gimco Acquisition LLC
Inspection Date: 0812712013 Inspection Type: Compliance Evaluation Reason for Visit: Routine
# Is a copy of the Permit and the Certificate of Coverage available at the site?
# Were all outfalls observed during the inspection?
# If the facility has representative outfall status, is it properly documented by the Division?
# Has the facility evaluated all illicit (non stormwater) discharges?
Comment: An illicit discharge of oil/water was reported to DLR RRO on 8/21/2013.
Highlands Environmental Solutions, Inc. handled the cleanup. The discharge was
discussed during the inspection and prevention actions were suggested.
Page:4

Parnell, David
From:
Greg Brown [[e-mail]]
Sent:
Monday, October 14, 2013 2:24 PM
To:
Parnell, David
Cc:
David Gibb
Subject:
Follow Up
Attachments:
storm10.14.13r1.pdf; storm. 10.14.13.pdf
Note, the below is also coming via Overnight UPS pack
Subject: NOD 2013-PC-0361
Mr. Parnell
NCDENR/DEMLR
Raleigh Regional Center
1628 Mail Service Center
Raleigh, NC 27699-162,
This is to respond to the letter of September 12, 2013 and signed for on the 16th that
asked to address the items in bold.
1) Please fully develop the Storm water pollution Prevention Plan by placing a
list of significant spills during the past three years, as well as documenting
employee training. Address: A log form to record significant spills is now in the
Dian book. Related. this email is serve to document that there have been zero
significant spills during the past three years -see attached. Also, the documentation
of "recent" training was in a different file and was not shown when asked to Andy
Sanderson, whom you met with on 8/27/13. He was not working there in April, nor
was the General Manager Paul Perrotti, so they were not aware that training had
been done by Dennis Gehle, the General Manager of our Goldsboro Operation on
April 12, 2013. Documentation of that training is now in the book. See attached.
2) The latest monitoring indicated benchmark exceedence. Please adhere to the
requirements of the NPDES permit with respect to the Tier Program. Address
We are adhering to the reauirements and are now treatina the site as a Tier 2. We
are hiring a comoanv to do monthlv testing. (thev will take samples) because we
want to ensure we are testing correctl
3) Please provide a final account of the illicit discharge which was reported to
DENR on August 23, 2013. (It may be helpful if your consultant provided the report
on your behalf). Address: See below email from the consultant with the `final'
account of what Hiahland did that day. A complete analvtical report can also be
sent if requested. Related significant remediation work was done since the event,
which was witness by you and others during the tour of 10/6/13. More has been
done since then and more continues to be done. Note the discharge was due to the

our sm
was
water
North. The onsite team, wanted to stop or slow this so they engaged a pump to
take the water to the SOUTH, away from the property to the North. Note in a
published article it was said "Workers had apparently been pumping the liquid onto a neighbor's
property", which is not true. Also, we did not send, let alone we were never planing on
sending more hazardous waste into the city's storm water pipes, which the article said the city was
concerned about. Laslty, what we believe to be the causes of the petroleum have
been addressed.
From: Joe Beaman [mailto:JBeamanCalhesnc com]
Sent: Friday, September 06, 2013 4:21 PM
To:'[e-mail]'; poerrottiCalraleighscrapmetalrecycling.com
Subject: Analytical data
Good afternoon. We finally received all of the analytical data for the soil sample that we collected during our initial
response activities. Only petroleum compounds were detected in the sample. Metals concentrations were very low,
and well below hazardous waste standards. The hydrocarbons detected consisted of diesel range organics (at a
concentration of 3400 ppm), and total oil and grease (at a concentration of 2320 ppm). Both diesel and oil and grease
were well above their state action limits.
Please contact me with questions or concerns.
Joe
� Highlands
I
Errvtronrcierttal
Solutions, Frrc.
Please visit our website at www.HESfast.com
Joe Beaman, P.G., RSM
Highlands Environmental Solutions, Inc.
8410-D Falls ofNeuse Road
Raleigh, NC 27615
P — 919-848-3155
F — 919-848-4265
C — 919-414-7081
24-Hour Emergency Response: 1-855-HES-FAST (855-437-3278)
Submitted by:
Gregory Brown
Raleigh Metal Recycling
Goldsboro Metal Recycling
"Excellence in Recycling and Services"

"We Pay Cash for Your Metal Trash"
Tel: [phone]
Cell: 734-740-9514
Email: gbrown(cDraleighscrapmetalrecycling.com
Web Addresses:
www.raleighscrapmetairecycling.com
www.goldsboroscrapmetairecycling.com

Parnell, David
From:
Senior, Mark [[e-mail]]
Sent:
Wednesday, October 16, 2013 10:50 AM
To:
Bennett, Bradley; Holley, John; Smith, Danny
Cc:
Duffy, Peter; Rall, Todd; Boyer, Kevin; Parnell, David; 'Eric.Green @wakegov.com'; Fulton,
Nicolette
Subject:
RE: Old Garner Road Metal Recycling
Attachments:
ATT00002.c; ATT00005.htm
Hi folks. Just want to keep everyone up to date on this site. The operator has enlisted the local engineering firm
McAdams to help them develop an appropriate stormwater management plan. Raleigh staff met with their representative,
Amos Clark, yesterday to discuss our concerns with the site. I told him that there were other regulators involved at the
state and county level and that any plan developed would have to be coordinated among the different agencies. It
appears they will be proposing a plan with several large sediment type basins along with diversion features to direct all
runoff from the site to the basins. They may also incorporate some kind of inverted outlet structure to contain petroleum
products. My intent is to follow up with the operator to insure that a plan is developed and implemented in a timely
manner. We may need to get together to discuss what kind of timetable is acceptable.
We have collected one runoff sample from one outfall at the site and intend to collect at least one more from another
outfall to verify what's in the stormwater leaving the site. I will provide that data when we receive it.
As I noted in our meetings, I would highly recommend that this site be considered for an individual NPDES Industrial
Stormwater Permit based on the amount of disturbed soil, the quantity and types of exposed materials, and the fact that it
is a PCB and metals hazardous waste site with noted offsite contamination.
Thanks and please let me know if you have any questions.
Mark Sr.
Mark T. Senior, PE, Senior Project Engineer
Stormwater Utility Division
City of Raleigh Public Works Department
PO Box 590
Raleigh NC 27602
Work Phone [phone]
Fax [phone]
Email mark. seniorCa raleighnc.gov
www.raleighnc.gov
From: Bennett, Bradley [mailto:[e-mail]]
Sent: Tuesday, October 01, 2013 4:38 PM
To: Senior, Mark; Holley, John; Smith, Danny
Cc: Duffy, Peter; Rall, Todd; Boyer, Kevin; Parnell, David
Subject: RE: Old Garner Road Metal Recycling
Mark
Here is the most recent permit issued in 2010. Two files are attached, their cover letter and COC are in one and the
permit is in the second file. The permit was first issued in 2001.
Bradley Bennett
Stormwater Permitting Program Phone: [phone]
NC Division of Energy, Mineral and Land Resources Fax: [phone]
1617 Mail Service Center Email: bradlev.bennettencdenr.gov

Raleigh, NC 27699-1617 1 Web: hftp://portal.ncdenr.org/web/Ir/stormwater
Email correspondence to and from this address may be subject to public records laws
From: Senior, Mark [mailto:[e-mail]]
Sent: Monday, September 30, 2013 11:20 AM
To: Holley, John; Bennett, Bradley; Smith, Danny
Cc: Duffy, Peter; Rall, Todd; Boyer, Kevin
Subject: Old Garner Road Metal Recycling
Hey guys, thanks much for meeting with us last week. I think that was very worthwhile in terms of everyone better
understanding the different parties involved and their roles. City staff are discussing the issues we are having with this
site with our attorneys and could really use a copy of their signed permit (or permit application) if you have it. We could
also use any monitoring data associated with this site including any self monitoring data they may have supplied. Our
plan is to collect and analyze samples from the site and we will forward that data to you when we have it. Our Fire
Marshal is also looking into the site based on the kinds of material stored there. They are very concerned that this site
could be hazardous to their responders.
Thanks, Mark Sr.
Mark T. Senior, PE, Senior Project Engineer
Stormwater Utility Division
City of Raleigh Public Works Department
PO Box 590
Raleigh INC 27602
Work Phone [phone]
Fax [phone]
Email mark. senior(Qraleighnc.gov
www.raleighnc.gov

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Actions to improve Storm Water Situation
7/20/14 Update
Completed between 8/21/13 and 10/15/13
1. Pumped out water with residue from small storm water pond near Maintenance building, Rai
2. Made small pond larger near Maintenance Building, Rai
3. Removed dirt that had petroleum residue near Maintenance building, Rai
4. Added pipe elbow to outflow to keep residue on site in small pond near Maintenance building
5. Rebuilt water flow channel, near maintenance building, with internal dams, Rai
6. Installed barriers around channel to keep channel maintained, Rai
7. Replaced water flow pipe, from small pond in Maintenance area, to Northern property. Had been blocked,
causing over land flow, Rai
8. Added significant rock over dirt to slow water and limit dirt migration to North overland, to the West of
Maintenance Building, Rai
9. Cleared small pond near West of property to allow large pipe with elbow to flow when pond is high, to keep
floating material on site, Rai
10. Placed booms at all outflows, including at some inflows, City, Rat
11. Began using only sealed boxes in Nonferrous area to stop residue from going in drain, Rai
12. Began policy of taking equipment out of service same day, if leaking, Rai
13. Moved steel turnings from SW corner of property to concrete pad and removed soiled dirt, Rai
14. Hired McAdams on 10/14 to advise on storm water issues
10/18/13
1. Implemented new policy of all electric motors and sealed units are stored inside (copper), Rai
2. Implemented new policy of all electric motors to be stored inside within 24 hours of being taken off incoming
large equipment, Rai
3. Implemented policy of daily ensuring all copper wire removed from roadways, Rai
10/22/13
1. Fired General Manager of site that was responsible for hiring firm to power clean crane on dirt outside
maintenance facility and did not see issue with building gutters allowing petroleum based material to flow out
> of building with rain water. Key reasons for 8/21 issue, Rat
1 /27/13
1) Hired Baker Roofing redo gutters on building to stop issue in #1 in first section. Rai
12/11/13
1) Constructed new channel, stone lined by outflow #6 to reduce sediment leaving site, Rai
2) Had conference call to review 1 s' draft of McAdams report
3) Contacted Applied Polymer Systems, re Floc Logs, per McAdams. Was given name of local distributor -
Green Resource and then call them about purchasing Floc Logs.
12/13/13
1) Fired Ferrous yard leader that was not being as responsive as he should have been, with leaks on
equipment that was causing the need for clean ups, Rat
12/19/13
1) Installed dams in Outflow #3 channel, per McAdams
2) Date approx.-hired firm to install silt fence, N and W, per McAdams. Finish date target 1/10/14
12/23/13
1) Met with Floc Company, ordered units and took water samples. Delivery said to be 1-2 weeks
2) McAdams report issued with recommendations. Implementation began earlier, based on draft of 12/11/13
12/27/13
1) Completed redo of gutters on Maintenance Building, Rai
12/30/ 13
1) Added Boom to outflow pipe at outflow #2, Rai
1 /4/14
1) Completed construction of'siit' fence, along North side of property and West (were no wall), McAdam.
1/13/14
1) While all but outflow #2 Flocs were installed last week, #2 was installed, McAdam
r30/14
,) 1) Began, weekly inspection of all booms and inspection after every rain, Rai
CONTINUED PAGE TWO

3/12/14
1) Asked Environmental Lawyer to see if we can breakout building a storm water pond West of building, from
total site plan (which continues to be delayed) and implement it now (start in weeks), Ral
-!13/14
1) Started new policy of no customers "breaking down" copper items in parking lot, effects outflow #1, Ral
2) Started new policy of no open trailers stored with material in parking lot, if rain, effects outflow #1, Ral
6/15/14-approx
1) Contracted to add curb to parking lot, which will have major reduction of sediment to outflow 1
2) Found two major roof gutters need to be reworked, replaced
6/30/14
1) Installed curb in parking lot -see above
Week of 7/14/14
1) Replaced roof gutters in Nonferrous areas
(D

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Parnell, David
From: Rall, Todd [[e-mail]]
Sent: Wednesday, August 20, 2014 9:44 AM
To: Smith, Danny; Parnell, David; Holley, John
Cc: Fulton, Nicolette; Duffy, Peter
Subject: Raleigh Metal Recycling
Attachments: ATT00001.c; ATT00002.htm
Gentlemen,
Could you provide us a status on the temporary measures that were proposed for Raleigh Metals?
Thanks,
Todd Rall
Senior Stormwater Engineer
City of Raleigh
919-996-4006
todd.rall(@raleighnc.gov
Ci 5 d c) r
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01094
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00556
DD400
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nd
Taal
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Oil and
Total
Chemical
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ase P.H
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Copper
Iron
Lead
Zinc
Total Susp.Sol
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Grease
P.H
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Zinc
ngll 6.0-9.0 s.u.
.001mgn
.007mgn
NIA mgn
.03mgn
.067 mgn
Rainfall 100mgn
120mgn
301mgn 6.0-9.0
s.u.
.001mgn
.007mgn
NIA refill
.03mgn
.067 mg11
Rainfall
100mgn
120mgn
301mgn 6.09.0
s.u.
.00lmgn
.007mgn
NIA mgn
.03mgn
.067 mgn
16 7
000359
0443
32.1
0.325
1.25
107' 850
270
10A
8.1
0,00862
0,994
39
0785
204
1.77'
- 30
78
1.6
7.5
0,00177
0D474
175
0.0278
0.364
4 8.3
00059
0,932
55.8
0737
2.31
9' 300
210
6.37
82
0.D0534
0.649
30.4
0482
1.62
9'
19
130
4.08
7.7
0,00223
0.124
4.29
0,0752
0.715
January 31, 2014
No discharge M period
of January 2 thru January 31, 2014
No discharge for period
of January 2
thou January
31, 2014
A 8
0.0137
1.74
933
1.35
49
l' 120
560
43
83
0.00174
0.298
6.81
0,174
0626
1'
0
0
0
0
0
0
0
0
0
8 7.6
0.00111
0.143
6.7
0,122
0,356
14 270
420
27.2
8.6
0.00362
0.453
19
0.369
1.24
14'
75
89
1.6
78
0.00216
0.108
7,19
0.1
0.781
269 75
0000612
0,112
238
005
0.16
15' 230
300
244
8.7
0,00245
0.404
14.3
0.304
0.82
1.5-
19
70
16
7.6
000102
0.0687
3.06
0.051
0.342
y 31, 2014
No discharge for period of May 1 thru
May 31, 2014
No discharge far period of May 1 Nm May 31. 2014
ALL 94
i56 OD400
nd
ase P.H
ngll 6.09.0 au.
01113
Cadmium
.001mg11
01119
Copper
.007mgn
00930
Iron
NIA mgn
01114
Lead
.03mgn
01094
Zinc
.067 mg11
Total
Rainfall
00530
Taal
Susp. Sol
100mg11
0034D
Chemical
Ox. Dem.
120mg11
OUTFALL95
00556 00400
Oil and
Grease P.H
301mgn 6.0-9.0 s.u.
01113
Cadmium
.001mgll
01119
Copper
.007mgll
0093D
Iron
NIA mgll
01114
Lead
.03mgn
01D94
Zinc
.067 mg11
Taal
Rainfall
00530
Total
Soap. Sol
100mgn
0034D
Chemical
Ox. Dem.
120mgn
OUTFALL06
00556 00400
Oil and
Grease P.H
301mgn 6.0.9.0 sm.
01113
Cadmium
.ODimgll
01119
Copper
.007mg0
00980
Iron
NIA mgn
01114
Lead
.03mgn
01094
Zinc
.067 mg
6 7.5
000194
00486
1,58
00221
1.21
1.77'
7.6
47
16
78
DD019
0,131
18
00226
0,234
1.07'
1400
350
3,67
8.6
0.00036
1.73
71.9
1.23
3.65
)9 7.6
000224
00439
2,23
00171
0.78
.9'
11
43
16
7.8
0.00259
0,194
3.04
00397
0.33
.9'
2600
550
7.31
8.5
0.0349
443
217
332
11
January 31, 2014
No discharge for period
of January
2 thru January 31, 2014
No discharge for period
of January 2
thou January
31, 2014
13 7.5
OD0171
0.0549
4.21
0.5
0.644
1
1
140
2.02
7.7
0.00209
0.0364
0.116
0.0021
0.223
1
900
220
5.61
9.2
000628
0.729
446
0.614
206
.7 85
0.00556
0.377
24
0.335
1.69
IA'
24
28
3.8
7.8
0.00151
0,0961
1.27
00179
0.231
1.4'
330
93
7.34
8.2
0.00361
0421
169
0,279
431
.4 7.7
0,0139
1.02
52.9
0.858
3.51
1.5'
43
55
1.6
7.7
0.00365
0346
9.13
00973
0.577
1.5'
31
51
37
86
0000535
0.0811
2.5
0.0333
0,153
y 31. 2014
No discharge
for period of May 1 thru
May 31,
2014
No discharge for period of May 1 thru May 31. 2014

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Parnell, David
From:
Bennett, Bradley
Sent:
Thursday, June 26, 2014 8:54 AM
To:
Parnell, David
Subject:
Raleigh metal
Dave,
Thanks for all your help on this one. I was wondering if you would mind checking with Raleigh Metal sometime and
make sure that they send the monitoring data they have?
12
Bradley Bennett
Stormwater Permitting Program
NC Division of Energy, Mineral and Land Resources
1612 Mail Service Center
Raleigh, NC 27699-1612
Phone: [phone]
Fax: [phone]
Email: bradley.bennettpncdenr.gov
Web: http://portal.ncdenr.org/web/Ir/stormwater
Email correspondence to and from this address may be subject to public records laws

RALEIGH METAL RECYCLING
STORM WATER SAMPLING REVIEW
Date of
12/10/2013
1/30/2014
2/5/2014
3f7/2014
4/31/2014
5130/2014
Date of
11/112013 and 11/27/13
12/10/2013
1/31/2014
21512014
3f7/2014
4131/2014
5/30/2014
OUTFALL#1
00530 00340 00556 00400 01113 01119 00980 01114 01094
Total Chemical Oil and
Total Susp. Sol Ox. Dem. Grease P.H Cadmium Copper Iron Lead Zinc
Rainfall 100ma1I 120mall 301mall 6.0.9.0 s.u. .001mall .007mall NIA mall .03mall .067 mall
.9' 680 290 94.4 8.3 0.0059 0.932
No discharge for period of January 2 thru January 31, 2014
1' 2000 730 44.4 8 0.0137 1.74
1.4' 75 59 3.8 7.6 0.00111 0.143
1.5' 68 32 2.89 7.5 0,000612 0.112
No discharge for period of May 1 thru May 31, 2014
OUTFALL#2
00530 00340 00556 00400 01113 01119 00980
Total Chemical Oil and
Total Susp. Sol Ox. Dem. Grease P.H Cadmium Copper Iron
Rainfall 100ma1I 120mall 301mall 6.0.9.0s.u. .001mg11 .007mall NIAmq
55.8 0.737 2.31 I I .9- 300 210 6.37
No discharge for period of January 2 thru January 31, 2014
93.3 1.35 4.9 1' 120 560 43
6.7 0.122 0.356 1.4 270 420 27.2
2.38 0.05 0.16 �1.5* 230 300 24.4
00530 00340 00556 00400 01113 01119 00980 01114 01094
Total Chemical Oil and
Total Susp. Sol Ox. Dem. Grease P.H Cadmium Copper Iron Lead Zinc
Rainfall 100mg11 120mg11 301mg11 6.0.9.0 s.u. .001mg11 .007mgll NIA mgll .03mg11 .067 mgll
1.77' 19 140 1.6 7.5 0.00194 0.0486
.9' 10 190 3.09 7.6 0.00224 0.0439
No discharge for period of January 2 thru January 31, 2014
1' 59 230 5.43 7.5 0,00171 0.0549
1.4' 240 130 14.7 8.5 0.00556 0.377
1.5' 550 470 16.4 7.7 0.0139 1.02
No discharge for period of May 1 thru May 31, 2014
1.58
0.0221
1.21
2.23
0.0171
0.78
No discharge
for per
4.21
0.5
0.644
24
0.335
1.69
52.9
0.858
3.51
No discharge for period of May 1 thru May 31, 2014
8.2 0.00534 0,649 30.4
8.3 0.00174 0.288 6.81
8.6 0,00362 0.453 19
8.7 0.00245 0.404 14.3
OUTFALL#5
00530 00340 00556 00400 01113 01119 00980
Total Chemical Oil and
Total Susp. Sol Ox. Dem. Grease P.H Cadmium Copper Iron
Rainfall 100mg11 120mg11 301mg1l 6.0-9.0 s.u. .001 mg1l .007mg11 NIA mgll
1.77' 7.6 47 1.6 7.8 0.0019 0.131 18
.9' 11 43 1.6 7.8 0.00259 0.194 3.04
Dd of January 2 thru January 31, 2014
1 1 140 2.02 7.7 0.00209 0.0364 0.116
1.4' 2.4 28 3.8 7.8 0.00151 0.0861 1.27
1.5' 43 55 1.6 7.7 0.00365 0.346 9.13
No discharge for period of May 1 thru May 31. 2014

Parnell, David
From:
Greg Brown [[e-mail]]
Sent:
Monday, October 14, 2013 2:24 PM
To:
Parnell, David
Cc:
David Gibb
Subject:
Follow Up
Attachments:
storm10.14.13r1.pdf; storm. 10.14.13.pdf
Note, the below is also coming via Overnight UPS pack
Subject: NOD 2013-PC-0361
Mr. Parnell
NCDENR/DEMLR
Raleigh Regional Center
1628 Mail Service Center
Raleigh, NC 27699-162,
This is to respond to the letter of September 12, 2013 and signed for on the 16th that
asked to address the items in bold.
1) Please fully develop the Storm water pollution Prevention Plan by placing a
list of significant spills during the past three years, as well as documenting
employee training. Address: A loq form to record significant spills is now in the
plan book. Related, this email is serve to document that there have been zero
significant spills during the past three years -see attached. Also, the documentation
of "recent" training was in a different file and was not shown when asked to Andy
Sanderson, whom you met with on 8/27/13. He was not working there in April, nor
was the General Manager Paul Perrotti, so they were not aware that training had
been done by Dennis Gehle, the General Manager of our Goldsboro Operation on
April 12, 2013. Documentation of that training is now in the book. See attached.
2) The latest monitoring indicated benchmark exceedence. Please adhere to the
Jrequirements of the NPDES permit with respect to the Tier Program. Address:
We are adhering to the requirements and are now treatinq the site as a Tier 2. We
are hirina a companv to do mohthly testina. (thev will take samples) because we
3) Please provide a final account of the illicit discharge which was reported to
DENR on August 23, 2013. (It may be helpful if your consultant provided the report
on your behalf). Address: See below email from the consultant with the 'final'
account of what Hiahland did that day. A complete analvtical report can also be
sent if requested. -Related significant remediation work was done since the event,
which was witness by you and others during the tour of 10/6/13. More has been
done since then and more continues to be done. Note the discharge was due to the

e that went from our small 'storm water pond to the North that was blocked. 're
storm water pond filledi and was overflowing causing water to go over ground to the
North. The onsite team wanted to stop or slow this so they engaged a pump to
take the water to the SOUTH away from the property to the North Note in a
published article it was said `Workers had apparently been pumping the liquid onto a neighbor's
property, which is not true. Also, we did not send, let alone we were never planing on
sending more hazardous waste into the city's storm water pipes, which the article said the city was
concerned about. Laslty what we believe to be the causes of the petroleum=have
been addressed. . '
From: Joe Beaman [mailto:JBeamanColhesnc.com]
Sent: Friday, September 06, 2013 4:21 PM
To:'[e-mail]'; pperrottiCalraleighscraometalrecycling. com
Subject: Analytical data
Good afternoon. We finally received all of the analytical data for the soil sample that we collected during our initial
response activities. Only petroleum compounds were detected in the sample. Metals concentrations were very low,
and well below hazardous waste standards. The hydrocarbons detected consisted of diesel range organics (at a
concentration of 3400 ppm), and total oil and grease (at a concentration of 2320 ppm). Both diesel and oil and grease
were well above their state action limits.
Please contact me with questions or concerns.
Joe
a.,.a
ISolutions, hsc.
Please visit our website at www.HESfast.com
Joe Beaman, P.G., RSM
Highlands Environmental Solutions, Inc.
8410-D Falls ofNeuse Road
Raleigh, NC 27615
P — 919-848-3155
F — 919-848-4265
C — 919-414-7081
24-Hour Emergency Response: 1-855-HES-FAST (855-437-3278)
Submitted by:
Gregory Brown
Raleigh Metal Recycling
Goldsboro Metal Recycling
"Excellence in Recycling and Services"

Y`
�O
"We Pay Cash for Your Metal Trash"
Tel: [phone]
Cell: 734-740-9514
Email: gbrown(cDraleighscrapmetalrecycling.com
Web Addresses:
www.raleighscrapmetairecycling.com
www.goldsboroscrapmetaIrecycling.com

i
Parnell, David
From: Greg Brown [[e-mail]]
Sent: Monday, October 14, 2013 3:51 PM
To: Parnell, David
Cc: David Gibb; todd.rall@raleighngov; Clark, A
[e-mail]);
[e-mail], dnielsen@ aon ne.; Andy Sanderson
([e-mail])
Subject: RE: Follow Up
Dave,
I hired McAdams company this afternoon to build on the major work we have done in the past 6
weeks and help us do what we need done going forward.
Note sure whom else needs to know, but thought I should tell you and Todd.
I know what we have done already has had a major impact. We are working on more issues as we
speak and I am sure with McAdams help we will have even more again.
Greg Brown
Raleigh Metal Recycling
Goldsboro Metal Recycling
"Excellence in Recvclina and Services"
"We Pay Cash for Your Metal Trash"
Tel: [phone]
Cell: 734-740-9514
Email: gbrown(aDraleighscrapmetalrecycling.com
Web Addresses:
www.raleighscrapmetairecycling.com
www.goldsboroscrapmetairecycling.com
From: Greg Brown
Sent: Monday, October 14, 2013 2:24 PM
To: [e-mail]
Cc: David Gibb
Subject: Follow Up
Note, the below is also coming via Overnight UPS pack
Subject: NOD 2013-PC-0361
Mr. Parnell
NCDENR/DEMLR
Raleigh Regional Center
1628 Mail Service Center
Raleigh, NC 27699-162,
This is to respond to the letter of September 12, 2013 and signed for on the 16th that
asked to address the items in bold.

i
1) Please fully develop the Storm water pollution Prevention Plan by placing a
list of significant spills during the past three years, as well as documenting
employee training. Address: A log form to record significant spills is now in the
plan book. Related, this email is serve to document that there have been zero
significant spills during the past three years -see attached. Also the documentation
of "recent" training was in a different file and was not shown when asked to Andv
Sanderson, whom you met with on 8/27/13. He was not working there in April nor
was the General Manager Paul Perrotti, so they were not aware that training had
been done by Dennis Gehle, the General Manager of our Goldsboro Operation on
April 12, 2013. Documentation of that training is now in the book. See attached
2) The latest monitoring indicated benchmark exceedence. Please adhere to the
requirements of the NPDES permit with respect to the Tier Program. Address:
We are adhering to the requirements and are now treating the site as a Tier 2 We
are hiring a company to do monthly testing (they will take samples) because we
want to ensure we are testing correctly.
3) Please provide a final account of the illicit discharge which was reported to
DENR on August 23, 2013. (It may be helpful if your consultant provided the report
on your behalf). Address: See below email from the consultant with the `final'
account of what Highland did that day. A complete analytical report can also be
sent if requested. Related significant remediation work was done since the event
which was witness by you and others during the tour of 10/6/13. More has been
done since then and more continues to be done. Note the discharge was due to the
pipe that went from our small storm water pond to the North that was blocked. The
storm water pond filled and was overflowing causing water to go over ground to the
North. The onsite team, wanted to stop or slow this so they engaged a pump to
take the water to the SOUTH, away from the property to the North. Note in a
published article it was said "Workers had apparently been pumping the liquid onto a neighbor's
property", which is not true. Also, we did not send, let alone we were never planing on
sending more hazardous waste into the city's storm water pipes, which the article said the city was
concerned about. Laslty, what we believe to be the causes of the petroleum have
been addressed.
From: Joe Beaman [mailto:JBeaman(a hesnc.com]
Sent: Friday, September 06, 2013 4:21 PM
To:'[e-mail]'; PperrottiCobraleighscrapmetalrecyclino.com
subject: Analytical data
Good afternoon. We finally received all of the analytical data for the soil sample that we collected during our initial
response activities. Only petroleum compounds were detected in the sample. Metals concentrations were very low,
and well below hazardous waste standards. The hydrocarbons detected consisted of diesel range organics (at a
concentration of 3400 ppm), and total oil and grease (at a concentration of 2320 ppm). Both diesel and oil and grease
were well above their state action limits.

4►
Please contact me with questions or concerns.
Joe
4
� Highlands
I
Emlronmerrtal
Sdutions, hic.
Please visit our website at www.HESfast.com
Joe Beaman, P.G., RSM
Highlands Environmental Solutions, Inc.
8410-D Falls ofNeuse Road
Raleigh, NC 27615
P — 919-848-3155
F — 919-848-4265
C — 919-414-7081
24-Hour Emergency Response: 1-855-HES-FAST (865-437-3278)
Submitted by:
Gregory Brown
Raleigh Metal Recycling
Goldsboro Metal Recycling
"Excellence in Recycling and Services"
"We Pay Cash for Your Metal Trash"
Tel: [phone]
Cell: 734-740-9514
Email: gbrownAraleighscrapmetairecycling.com
Web Addresses:
www.raleighscrapmetairecycling.com
www.goIdsboroscrapmetalrecycIing.com

4
Mid -Atlantic Associates
Field Notes
Job Name:
Date:
Job Number:
Technician:
Task Number:
Weather:
Location:
Arrival: Departure:
D
/Nip ¢Raze, &,,, egvzr" %/i-�212 �so1
r, 4Av 1264-(' PPP WCti-
Jz,�K Qc,IC',,— Jinn .�G�ch �_ nco%n/,fad (&SI? 19 (9 70 -74?36 6
Gr%cam G%ePrr., e,;c. 5,,.,.. Q i.✓G�:c gov. Gvn.- y�y" '7`7S =.�/yy
M���Y Ik'Aw H_ i bsodl s . h nwij) (� ncA.ni. ��U q0 _a -639,Y
n
�IpQ•C�N,�
Equipment / Expendables Used:
Page
of
Signature
maafieldnotes.xl

Parnell, David
From: Smith, Danny
Sent: Wednesday, June 18, 2014 8:37 AM
To: Bolich, Rick; Bennett, Bradley; Holley, John; Parnell, David
Cc: Payne,John
Subject: FW: Raleigh Recycling - 10:30 am June 25
This email is to confirm a meeting with Raleigh Metal Recycling for 10:30 on Wednesday June 25th at the RRO
(see Mr. Toole's email below).
• Also, we are schedule to discuss the Raleigh Recycling nov response during an internal pre -meeting on Monday
at 3:00 pm at the RRO.
Thanks!
Danny
Danny Smith
Regional Supervisor
Raleigh Regional Office
NCDENR-Division of Water Resources
3800 Barrett Drive
Raleigh, NC 27609
[phone]
[e-mail]
Email correspondence to and from this address may be subject to the North Carolina Public Records Low and may be
disclosed to third parties unless the content is exempt by statute or other reaulotion.
From: Toole, William [mailto:[e-mail]]
Sent: Tuesday, June 17, 2014 5:20 PM
To: Smith, Danny
Subject: Raleigh Recycling - 10:30 am June 25
Danny —Thanks for your call yesterday. This is to confirm that Greg Brown (President, Raleigh Recycling), Dan Nielsen
(MidAtlantic), Jon Aldridge (McAdam) and I will meet with you and your team 10:30 am June 25 in Raleigh. Please send
me the address of the meeting place at your convenience. Thanks for your help in this matter.
Bill
William W. Toole
Robinson Bradshaw & Hinson
101 North Tryon Street, Suite 1900
Charlotte, NC 28246
P: 704.377.8373 (direct)
F: 704.373.3973
[e-mail]
www.rbh.com
This message is intended solely for the addressees and may contain information that is confidential and
received this message in error, please notify me immediately by electronic mail or telephone.
If you have

STATES
k ;F al i
U.S. POSTAGE>>PITNEY BOWES
UNITED
ENVIRONMENTAL PROTECTION AGENCY
1 31 w!,-I-''I.
REGION 4
'''{
t
0
ZIP 30303 $ O 48
ATLANTA FEDERAL CENTER
r.t<€ '"+ '
G'•'
•
02 1YV
0001387202MAY 06 2014
61 FORSYTH STREET, S.W.
ATLANTA, GEORGIA 30303-8960
OFFICIAL BUSINESS
.PENALT.Y FOR PRIVATE USE, $300
o `1� Q
1_.
.G G991 GO 1 99
Mr. John Holley
Regional Engineering Supervisor,
NC Department of Environment & Natural
Resources
1601 Mai en e —
tgh, NC 27699-1601
,pli,III,IIdII,I++hllhl911r11lld,ydl4hllPll,II+1g111

I

EPA
United States
Environmental Protection
Agency
PCB APPROVAL PUBLIC NOTICE FACT SHEET
Raleigh Recycling NC Scrap Metal, LLC (RRNCSM)
Raleigh Metals Processors
2310 Garner Road, Raleigh, North Carolina
EPA ID. NCD045915568
Why am I receiriag this Fnct Slteet? You have been designated through tax records that you own property
within a'/ mile radius of this facility. The EPA wants everyone to be aware of the actions that are being
proposed in order to have opportunity to learn more about the action and the permitting process.
What isPCB?
PCB stands for polychlorinated bipheny,I. PCBs area
mamnade chemical that were manufactuied from 1929
until their manufacture was banned in'1979.PCBs -
were used in hundreds of industrial and commercial
applications before they.were banned. (i'.e. paint,
plastics, and rubber products, pigments, dyes, and
carbonless.copy paper), Information regarding PCBs
may also be found online at the EPA website with the
following, address:
http://www.epa.gov/wastes/hazard/tsd/pcbs/
Once in the environment. PCBs do.noticadily break
down and therefore may remain for long periods of
time. PCBs have a range oftoxicity and vary in
consistency. PCBs have been demonstrated to cause
cancer and other adverse health effects. Eor more
information on the health effects of PCBs refer to the
Agency for l oxic-Substances & Disease Registry at:
http://www..atsdr..Cdc.gov/toxfaqs/tEasp?id=140&ti
d=26
Background
The Raleigh Metal Processors site (the site) is
located at 2310 Garner Road in Raleigh, North
Carolina, and has operated as a scrap metal
recycling business since the 1940s.
r' Nklj
1 .
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The site is currently owned by Raleigh
Recycling NC Scrap Metal, LLC (RRNCSM).
The site was entered into the North Carolina
Inactive Hazardous Site Branch's Registered
Environmental Consultant Program in
November 2007. Both the State environmental
agency and EPA have jurisdiction on the
corrective actions performed at the site. Under
the State Program, the site has undergone
corrective action that have identified soils
contaminated with PCBs as well as all other
contaminants of concern identified at the site.
Raleigh Metal Processors ongoing activities.
At the facility in 2009, measures were
completed to remove PCBs contained in shallow
soil in some areas. Other areas were tested for
PCBs. Based on the results of PCB testing, an
excavation area was planned and corrective
action was then performed. Soils were removed
to an approximate depth of one foot and 1,326
tons of soil in the area were removed and
transported to an offsite landfill that accepts
PCB contaminated waste for disposal. After soil
removal, soil replacement consisted of crushed
concrete fill placed on top of a liner. After this
action, the areas for outstanding regulatory
action of remaining PCBs is approximately 7 acres
in size. These areas were defined by having PCB
concentrations above 1 mg/kg.
PCB Risk -Based Cleanup and Disposal
Approval
EPA will have jurisdiction over the outstanding
PCB clean-up and disposal activities. Before

any other work can be performed on the PCB
soils, a PCB Approval must be issued that
identifies what is required. The draft approval
that is the subject of this public notice identifies
barrier restrictions, inspection requirements,
recordkeeping requirements, and reporting
requirements for the work to be' performed on the
PCB soils. Additionally, the draft approval would
require RRNCSM to adhere to its Spill Prevention,
Control, and Response plan.
The proposed remedy for soils exceeding 1
mg/kg total PCBs is to construct a barrier to
human exposure. The protective barrier will
consist of a fabric overlain by recycled concrete.
In two areas near the southern property line
existing concrete pads will be . used as the
barrier. The shear in the west central portion of
the site will also function as the barrier. The
small accessible areas of PCB soil along the
railroad tracks and the drainage ditch west of the
site will be moved onsite where they will be
covered by the protective barrier. After PCB soil
is removed from the areas, soil samples will be
collected. The results of the sampling will be
used to determine if excavation activities are
Sample liner installation over contaminated soil.
The EPA has determined that implementation of
the proposed remediation plan for the site in
accordance with the approved Remedial Action
Plan (Mid -Atlantic Associates, Inc., June 21,
2012), and the approval conditions established
within the Approval will not pose an
unreasonable risk of injury to human health or
the environment. This draft approval shall
become effective on the date of signature and
shall expire ten years from the date of signature,
unless revoked, suspended, or terminated in
accordance with the approval conditions stated
therein.
Community Involvement
The draft PCB Risk -based Cleanup/Disposal
Approval is open for public comment from
May 8, 2014 to June 12, 2014. All comments
received by June 12, 2014 will be considered in
the final decision to issue the Approval. The
EPA will respond to all written comments
submitted. Copies of the draft Approval and
supporting documents (i.e., the Remedial Action
Plan and the Approval request) are available for
review in hard copy at the Southgate
Community Library, 1601-14 Cross Link Road,
Raleigh or online at
http://www.epa.gov/region4/rcra/PublicNotices.
htm.
Comments are being accepted on the draft PCB
Approval, not the supporting documents.
Comments on any other contamination or other
constituents at the site should be addressed to the
State Project_ Manager, Mattlrew Aufman at (919),
J07-8348.
In order to give area residents an opportunity to
meet and discuss the proposed PCB Approval,
the EPA will hold Availability Sessions (Open
House) on Tuesday, June 3, 2014 at 3:30 p.m.
and 6:30 p.m. at the Garner Town Hall
Complex, Building `B," 900 7°i Avenue,
Garner, NC. Each session will start with a brief
presentation to provide an overview of the PCB
requirements. Following the presentation, an
informal session will be held to provide
opportunities to discuss and ask questions.
EPA Contact for the PCB Approval:
Terri Crosby -Vega
Environmental Engineer
RCRA Division US EPA Region 4
61 Forsyth Street SW
Atlanta, GA 30303
E-mail crosbv-vega.terri a ena.eov
[phone]

e=,.EPA
United States
Environmental Protection
Agency
Availability Sessions (Open House)
In order to give area residents an opportunity to meet and discuss the
proposed Polychlorinated Biphenyls (PCB) Approval for Raleigh
Metals Processors located at 2310 Garner Road, Raleigh, the U.S.
Environmental Protection Agency will hold Availability Sessions.
Date: Tuesday, June 3, 2014
Time: 3:30 p.m. to 5:30 p.m. Brief project presentation at 3:30 p.m.
6:30 p.m. to 8:30 p.m. Brief project presentation at 6:30 p.m.
The open house sessions will begin with brief presentations; the same information will be
provided during the 3:30 p.m. and 6:30 p.m. presentations. We hope all residents who are
interested will be able to attend one session or the other.
Location: Garner Town Hall Complex
Building `B"
900 7 " Avenue.
Garner, NC
Sponsor: United States Environmental Protection Agency (U.S. EPA), Region 4
Format: Each session will start with brief presentations to provide an overview of the PCB
requirements and the need for a PCB Approval. Following the presentation, an open house
or availability session will be held. The availability sessions are opportunities for residents
to discuss issues and ask questions one-on-one or in small groups with representatives from
U.S. EPA and other project participants.
The two public availability sessions will end promptly at their designated times of 5:30
p.m. and 8:30 p.m.
Background Information:
The Raleigh Metals Processors site is located at 2310 Gamer Road in Raleigh, North Carolina, and has operated as a scrap
metal recycling business since the 1940s. The site is currently owned by Raleigh Recycling NC Scrap Metal, LLC.
Residents are encouraged to review the project documents available for review in hard copy at the Southgate
Community Library, 1601-14 Cross Link Road, Raleigh. Information regarding PCBs may also be found online at
http://www.epa.gov/wastes/hazard/tsd/pcbs/.
Contact: For additional information about the availability sessions, please contact:
Terri Crosby -Vega, Environmental Engineer, RCRA Division, U.S. EPA Region 4
Phone: [phone] or [e-mail]

Permit: NCG200335 Owner - Facility: Gimco Acquisition LLC
Inspection Date: 08/27/2013 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
This facility was inspected after a report to DLR of an illicit discharge which flowed onto an adjacent property. DLR RRO
reported that the clean up had been concluded.
Page:2

Permit:
NCG200335
SOC:
County:
Wake
Region:
Raleigh
Compliance Inspection Report
Effective: 01/O1/10 Expiration: 12/31/14 Owner: Gimco Acquisition LLC
Effective: Expiration: Facility: Gimco Acquisition, LLC
2310 Garner Rd
Contact Person: GregoryW Brown
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 08/2712013
Primary Inspector: David R Parnell
Secondary Inspector(s):
Title:
Entry Time: 09:30 AM
Raleigh NC 27610
Phone: [phone]
Certification:
Exit Time: 12:00 PM
Phone:
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Wholesale Trade of Metal Waste and Scrap Stormwater
Discharge COC
Facility Status: ❑ Compliant ■ Not Compliant
Question Areas:
0 Storm Water
(See attachment summary)
Page: 1
I

Parnell, David
From: Greg Brown [[e-mail]]
Sent: Wednesday, October 09, 2013 8:11 PM
To: Parnell, David
Cc:' David Gibb; [e-mail]; Andy Sanderson
([e-mail])
Subject: RE: Follow Up
Attachments: rear mini pond.jpg, old turnings area.storm water.jpg
Dave,
While not an official part of the requested response, I wanted to let you know that we remain on path
to hire a firm within the week of our meeting Monday to help us with Storm water issues. We are also
looking to hire a firm to do the actual sampling of storm water.
Also, see the attached. We are not waiting for any engineering firm. One photo is of the mini storm
water pond by the back, by the rail road tracks. This was done yesterday. When you were here it
was a watery pit, with a pipe in it with a bottom unknown.
It is now cleared with the pipe exposed so oily water will stay in the pit onsite. Also on Friday we are
installing an ninety degree "elbow" on the mini storm pond in the area where we had the issue, so any
material that has a sheen will stay in the pit as well. Importantly though when all were here this week,
you saw there was not sheen in this area.
I have also attached a photo of the area where the messy turnings were.
Greg Brown
Raleigh Metal Recycling
Goldsboro Metal Recycling
"Excellence in Recvclina and Services"
"We Pay Cash for Your Metal Trash"
Tel: [phone]
Cell: 734-740-9514
Email: abrown(aDraleiahscraometalrecvclina.com
Web Addresses
www.raleighscrapmetairecycling.com
www.goldsboroscrapmetairecVcling.com
From: Greg Brown
Sent: Wednesday, October 09, 2013 7:10 PM
To: [e-mail]
Cc: David Gibb; [e-mail]; Andy Sanderson
(asanderson@ra leighscrapmetal recycli ng.com )
Subject: Follow Up
Dave,
See below. Do you also need a hard copy of this delivered to the1628 Mail Service Center, Raleigh,
NC address?
Subject: NOD 2013-PC-0361
Mr. Parnell

1. re
NCDENR/DEMLR ( r s
Raleigh Regional Center
1628 Mail Service Center
Raleigh, NC 27699-162,
This is to respond to the letter of September 12, 2013 that asked to address the items
in bold.
1) Please fully develop the Storm water pollution Prevention Plan by placing a
list of significant spills during the past three years, as well as documenting
employee training. Address: A log form, to record significant spills is now in the
plan book. Related, this email is serve to document that there have been zero
significant spills during the past three years. Also, we apologize. The
documentation of "recent" training was in a different file and was not shown when
asked to Andy Sanderson, whom you met with on 8/27/13. He was not working
here in April, so he was not aware that training had been done by Dennis Gehle the
General Manager of our Goldsboro Operation on April 12 2013. Documentation of
that training is now in the book.
2) The latest monitoring indicated benchmark exceedence. Please adhere to the
requirements of the NPDES permit with respect to the Tier Program. Address:
We are adhering to the requirements.
3) Please provide a final account of the illicit discharge which was reported to
DENR on August 23, 2013. (It may be helpful if your consultant provided the report
on your behalf). Address: See below email from the consultant. A complete
analytical report can also be sent if requested. Related significant remediation
work was done since the event, which was witness by you and others during the
tour of 10/6/13.
From: Joe Beaman [mailto:JBeaman(@hesnc.com]
Sent: Friday, September 06, 2013 4:21 PM
To: '[e-mail]'; pperrottiCalraleighscrapmetalrecvcling.com
Subject: Analytical data
Good afternoon. We finally received all of the analytical data for the soil sample that we collected during our initial
response activities. Only petroleum compounds were detected in the sample. Metals concentrations were very low,
and well below hazardous waste standards. The hydrocarbons detected consisted of diesel range organics (at a
concentration of 3400 ppm), and total oil and grease (at a concentration of 2320 ppm). Both diesel and oil and grease
were well above their state action limits.
Please contact me with questions or concerns.
UO ;

A Highlands
1:
r, Ernironrrrental
Solutions, tnc.
Please visit our website at www.HESfast.com
Joe Beaman, P.G., RSM
Highlands Environmental Solutions, Inc.
8410-D Falls ofNeuse Road
Raleigh, NC 27615
P — 919-848-3155
F — 919-848-4265
C — 919-414-7081
24-Hour Emergency Response: 1-855-HES-FAST (855-437-3278)
Submitted by:
Gregory Brown
Raleigh Metal Recycling
Goldsboro Metal Recycling
"Excellence in Recyclinq and Services"
"We Pay Cash for Your Metal Trash"
Tel: [phone]
Cell: 734-740-9514
Email: gbrownAraleighscrapmetalrecvcling.com
Web Addresses:
www.raleighscrapmetairecycling.com
www.goldsboroscrapmetairecycling.com

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NCG0200335 - Stormwater Permit Violations Options
• Individual Permit Option -
TMDL (11g) pathway (Permit Coverage) - Violation of applicable water quality standards (Part 1, Section A)
Requiring Individual Permit- Discharger is a significant contributor of pollutants (Part III, Section B, 3a)
Violation of the terms of the General Permit (Part 111, Section B, 3c)
Required at Directors Discretion (Part I1I), Section B 3g)
• Permit Conditions Violations Option 1- (DLR/DWR Joint Approach)
Through Use of Part 1, Section B
All Discharges in accordance with Permit Conditions
Prohibits other point source discharge which causes standard violation
Prohibits discharges determined to be Wastewater
Through Use of Part III, Section A 2. - Duty to Comply - Must comply with all conditions of the General Permit
Through Use of Part III, Section C 1. - Proper Operation and Maintenance
• Permit Conditions Violations Option 2-
Allowing the use of the permit for implementation of requirements of Tier Program - specifically Tier 3
Enforce downstream sediment monitoring & require measures to be installed

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ID_ATLANTIC
SEYMOUR BROWN INVESTMENT COMPANY, INC.
=>a:.
REMEDIAL INVESTIGATION
I`v/■
ASSOCIATES, INC.
RALEIGH, NORTH CAROLINA
RALEIGH METALS PROCESSORS
^ J
RALEIGH, NORTH CAROLINA
°®^
Engineering & Environmental Solutions
SOIL EXCAVATION, BARRIER PLACEMENT
.nef.+.�..aR.u,w..^a.ewen.n..rc..a m..va,�ma.�.i
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AND TREATMENT AREAS
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OOOR1869.00 3

Sampling. Raleigh metal will need to begin sampling stormwater discharges monthly, from July
2014 through construction efforts and then for 12 month after the completion barrier installtiona
and stomwater pond installation. The following paramaters are to be sample:
• On site rain gauge data (daily monitoring and recording)
• Total Suspended solids, Turbidity, potassium, Cadmium, Chromium, Nickel, Lead, Zinc,
Vanadium, Aluminum, Silver, Beryllium, calcium, Cobalt, Molybdenum, Antimony, Tin,
Thallium, Titanium, Mercury, Lithium, Magnesium, Manganese, Sodium, Arsenic,
Selenium , barium,
base/neutral extractable organics
TPH Diesel range
Polychlorinated Biphenyl
• The sampling results will need to be provided to DWRs and DEMLR monthly.
• Outfall sample locations Sneed to YIdenhfy`�locahon(s)�
This data will be used to demonstrate the effectiveness of the proposed remedy and ongoing
operation and maintenance expectations.
Stormwater Pond.
• Stormwater pond design(s) — Provide engineered sealed plans to DWRs and DEMLR by
���rN m -"
Septembe`r1; 201'4,
• Provide DWRs and DEMLR stormwater monitoring plan by Septemtiet" 1 20!1'4 for the
stormwater pond influent and effluent. Using the abovementioned parameters, both the
influent and effluent samples will need to be collected monthly. These results are to be
provide to DWR and DEMRL monthly.
• Operations and Maintenance (O&M) agreement that also includes the development of a
plan for removal and testing of accumulated sediments from the stormwater basin must
be developed. (parameters?)
• Provide a written account detailing how drainage/stormwater/ and/or accumulated
groundwater behind retaining wall located adjacent to the railroad spur, will be captured
or prevented from discharging. Will this water be routed to the stormwater pond? What
treatment will this pond provide? Provide DWRs and DEMLR this written account by
Septemlieil 2014. If discharges occur after barrier placement monthly monitoring is
required to continue to occur.

1W
• Upon installation of the stormwater pond, Raleigh Metal will need to sample stormwater
pond influent and effluent for one (1) year. This sampling must include the above
mentioned parameters.
Schedule (Starting July 1, 2014)
• Monthly stormwater outfall monitoring beginning July 2014— July 2016.
• Construction Drawings and Railroad Permitting —complete by September 1, 2014 (60
days)
��4`.?=Sedimentation�andaEiostonlControlPlan;�;sec�plan�approvahSeptemberkl r20;,14;(60.
ORD
• Contractor selection — complete by October 1, 2014 (90 days)
• Site Demo/movement of onsite material December 1, 2014 (complete 150 days)
• Barrier Placement, permanent Stormwater Basins installation April 12, 104 (270 Days)
Your letter states that new stormwater retention ponds will contain plants that will be "selected for
their propensity to assimilate metals". Please provide more detail about the species of plants to be
used, their compatibility for use in stormwater retention ponds, and their ability to remove the specific
contaminants noted in the on -site stormwater.
The proposed schedule for the implementation of stormwater control measures related to the June 21,
2014 Remedial Action Plan for the PCB contaminated soil may be adequate to address the PCB
contaminated soil contamination under the DWM IHSB program, but this does not relieve you of your
obligations to stop stormwater contaminated by current waste handling activities on site that have
resulted in the contravention of state surface water quality standards. Please provide a clear schedule
with dates detailing your proposed corrective actions to mitigate the on -going surface water quality
standard violations such that these violations do not continue to occur.
The remedial action plan that you submitted to DENR's Inactive Hazardous Sites Branch and to the EPA
does not in any way relieve you of your obligations to control pollutants that are generated and
discharged by your current waste handling practices.

Parnell, David
From: Aufman, Matt
Sent: Monday, June 16, 2014 8:12 AM
To: Senior, Mark; Matthew Starr (Upper Neuse River Keeper 2013) ([e-mail]);
George Matthis (River Guardian) ([e-mail])
Cc: Fulton, Nicolette; Holley, John; Smith, Danny, Bennett, Bradley; Randall, Mike; Eric Green
([e-mail]); Parnell, David; Kenneth Rhame (EPA)
([e-mail]); Boyer, Kevin
Subject: FW: Proposed Cleanup for PCBs, Raleigh Metals Recycling, Raleigh, NC
Mark/All-
I have received the City of Raleigh's comments on the proposed containment remedy for the site. I wanted to share with
everyone the comments the REC program sent to the EPA regarding the remedy. Please note that the REC has not
submitted the final containment remedy for our concurrence, following comments that were submitted to the REC on
October 4, 2013.
Matt
Matthew Aufman
Phone: [phone]
http://portal. ncdenr.org/web/wm/sf/ihs/recprog ram
From: Aufman, Matt
Sent: Monday, June 02, 2014 4:16 PM
To: 'Crosby -Vega, Terri'
Cc: Feely, Ken; Holtzclaw, Brian; '[e-mail]'; Caulk, Kim
Subject: Proposed Cleanup for PCBs, Raleigh Metals Recycling, Raleigh, NC
Hi Terri -
I received a copy of your Public Notice, the Fact Sheet, and the proposed Cleanup for PCBs at the Raleigh Metals
Processors Facility on May 6, 2014. Upon review, I have a few comments and clarifications regarding the documents.
• The Public Notice states that the Administrative Agreement (AA) executed on November 28, 2007 was between
the NCDENR Registered Environmental Consultant (REC) Program and Raleigh Recycling NC Scrap Metal,
LLC (RRNCSM). The 2007 AA was actually executed between the REC Program and Seymour Brown
Investment Company, not RRNCSM. A new AA between the REC Program and RRNCSM was executed on
April 17, 2014.
• The Public Notice references the June 21, 2012 Remedial Action Plan (RAP) prepared by Mid -Atlantic
Associates. In the REC Program, all draft RAPS must undergo a 30-day public notice period before the REC may
certify the RAP as complete. A final RAP has not been submitted by the REC and has not been through the public
notice period; therefore a final RAP has not been approved and certified by the REC as complete.
• The Public Notice states that " The Inactive Hazardous Site Branch's (IHSB) RECP is responsible for the
remediation for soil and groundwater for all constituents except PCBs. The EPA is responsible for the PCB
remedial activities and will address only the requirements for PCBs in the proposed Approval." Similar to work
performed under CERCLA, remediating parties (RPs) may have to meet the substantive requirements of
permitting regulations (or obtain a permit). In this case the EPA may permit and approve PCB remediation
activities. However, this remediation project is being conducted under the state's IHSB Response Act and REC
regulations. Thus, the Division of Waste Management also hasjurisdiction for the PCB remediation at this site
and are responsible for the cleanup of the entire site, including PCBs. The IHSB will be overseeing the long-term
cleanup of all media and the monitoring and maintenance of the Land Use Restrictions (LURs) described in the
draft RAP.
• Page I of the Fact Sheet states "EPA will have jurisdiction over the outstanding PCB clean-up and disposal
activities". See previous comment on jurisdiction.

The fact sheet indicates that implementation of the approved June 21, 2012 RAP will not pose an unreasonable
risk to human health or the environment. As stated above, the June 21, 2012 RAP is a draft and has not been
approved by the REC.
At this time, to ensure information provided to the public is clear and accurate, please contact us prior to any
mailings that mentions our agency's personnel so we can review the details.
Section A (1)(c) of the Draft Approval (Approval Conditions) discusses jurisdiction of the PCBs and other
contaminants. See the previous comment onjurisdiction.
If you have any questions or comments, feel free to contact me.
Regards,
Matt
Matthew Aufman
Inactive Hazardous Sites Branch - REC Program
NCDENR - Division of Waste Management
217 West Jones Street
Raleigh, North Carolina 27603
Phone: [phone]
matt.aufman(ncdenr.gov
http://portal.ncdenr.org/web/wm/sf/ihs/recprogram

Parnell, David
From:
Senior, Mark ([e-mail]]
Sent:
Friday, June 13. 2014 3:33 PM
To:
Matthew Starr (Upper Neuse River Keeper 2013) ([e-mail]); George Matthis
(River Guardian) ([e-mail])
Cc:
Fulton, Nicolette; Holley, John, Smith, Danny; Bennett, Bradley; Randall, Mike; Aufman, Matt;
Eric Green ([e-mail]); Caulk, Kim; Parnell, David; Kenneth Rhame (EPA)
([e-mail]); Boyer, Kevin
Subject:
FW: City of Raleigh Comments on PCB Approval for Raleigh Recycling INC Scrap Metal, LLC
- EPA ID NCD045915568
Attachments:
ATT00002.c; ATT00003.htm
Matthew/George; since you shared your comments I thought I would share ours with you as well as the State and
County.
Thanks, Mark Sr.
From: Senior, Mark
Sent: Thursday, June 12, 2014 4:12 PM
To: Crosby -Vega, Terri
Cc: Fulton, Nicolette; Rall, Todd; Duffy, Peter; Boyer, Kevin; Kirsch, Daniel
Subject: City of Raleigh Comments on PCB Approval for Raleigh Recycling NC Scrap Metal, LLC - EPA ID NCD045915568
Ms. Crosby -Vega; Thank you for the opportunity to comment on the PCB Approval for the above referenced site. City of
Raleigh staff has reviewed the Approval and would like to offer the following comments:
1. The City of Raleigh supports the PCB Approval for the installation of a barrier to prevent human exposure.
Because it has been confirmed that PCB's are currently leaving the site, contaminating adjacent properties, and
entering surface waters in concentrations that exceed State standards, the City would encourage EPA and the
State to do whatever they can to expedite the implementation of this plan to protect the health and welfare of
the citizens of Raleigh.
2. Since this is an active site with exposed soil and it will be some time before the proposed barrier is in place, we
would encourage EPA and the State to require the implementation of interim measures to insure that PCB's and
other contaminants remain within the site until such time as installation of the barrier is complete.
3. We would recommend that compliance with the remediation plan be incorporated as a requirement of the site's
NPDES Industrial Stormwater Permit so that failure to comply with the plan would constitute a violation of the
NPDES Stormwater permit.
Sincerely;
Mark T. Senior, PE, Acting Stormwater Manager
Stormwater Division of the City of Raleigh Public Works Department

Robinson
Bradshaw
May 2, 2014
VIA EMAIL AND CERTIFIED MAIL
Danny Smith
Regional Supervisor
Water Quality Operations, Raleigh Regional Office
North Carolina Department of Environment and Natural Resources
1628 Mail Service Center
Raleigh, NC 27699-1628
William W. Toole
chadocto Office
704.377.8373 Direct Phone
704.373.3973 Direct Fax
wtoole®rbh.cam
Re: Notice of Violation NOV 2014-PC-0047 dated March 27, 2014 ("NOV")
2310 Gamer Road
Wake County
Response of Raleigh Recycling NC Scrap Metal LLC ("Raleigh Recycling")
Dear Mr. Smith:
This firm represents Raleigh Recycling with regard to the NOV. This letter and the attachments
are timely submitted in response to the NOV that Raleigh Recycling received on April 3, 2014.
As requested in the NOV, this response includes the following: (i) a comprehensive plan to stop
pollutants from discharging from the site into surface waters; (ii) a plan to stabilize the site such
that infiltration, erosion and pollution will be addressed to prevent ongoing transport of
contaminants to surface waters of the state; and (iii) an implementation schedule.
On April 23, 2014 an entity related to Raleigh Recycling obtained control over the site from the
previous owner and operator, allowing Raleigh Recycling to speed the responses necessary to
stop pollutants from discharging from the site. As detailed below, Raleigh Recycling proposes a
comprehensive approach that will stabilize PCB and metals contaminated soils with a cover
expected to be 95% impervious, treat soils with excessive metals contamination, and install two
stormwater ponds designed to manage site stormwater from 14.5 acres of the site, essentially all
but a minor gravel parking lot. Raleigh Recycling will then evaluate discharges from this
holistic system and make additional improvements as necessary and appropriate to meet
stormwater discharge requirements. Such additional measures might include some combination
of direct treatment of stormwater prior to discharge from the site.
4751031A 19853.00020
Robinson Bradshaw 6 Hinson, PA I Attorneys at Law 1%101 North Tryon Street, Suite 1900 a Chadotte, NC 28246" 704,377.2536
Chacecto a Research Triar4e 4 Rock HM

Danny Smith
May 2, 2014
Page 2
I. Current Efforts
A. April 23, 2014 Purchase of Site
Raleigh Recycling has proceeded aggressively and through a related entity bought the site so as
to speed efforts to address problems it did not create. These problems are the result of historic
activities dating back to the 1940's that were undertaken by previous site owners and operators,
primarily Seymour Brown Investment Co., Inc., formerly named Goldsboro Iron and Metal
("SBIC") which acquired the property in 1968. Raleigh Recycling, formerly known as GIMCO
Acquisition LLC, first had dealings with the site when it purchased certain operational assets, but
not the land nor responsibility to respond to historic contamination, from SBIC on August 3,
2007. Raleigh Recycling never had any control over SBIC operations and, until April 23, 2014,
neither owned the site nor had the right to implement necessary cleanup to control the legacy
contamination affecting storrrlwater discharges from the site. Nonetheless, Raleigh Recycling
Scrap Metal NC LLC, an entity related to Raleigh Recycling, purchased the site on April 23,
2014 so that the measures necessary to address the historic contamination could be implemented
aggressively.
B. Identification of and Proposed Response to Historic Contamination
1. Comprehensive Identification of Historic Contamination
Before its purchase of operational assets in 2007, Raleigh Recycling identified to SBIC site
contamination that has affected stormwater discharges from the site. In August 2010 Mid -
Atlantic Associates submitted to North Carolina Department of Environment and Natural
Resources, Inactive Hazardous Sites Branch — REC Program, a comprehensive remedial
investigation report that identified the vertical and horizontal extent of the historic contamination
("RI"). The RI may be downloaded from the Inactive Hazardous Sites Branch portal at
https://edm.nc.gov/DENR-Portal/ and referencing Site ID NCD045915568.
That historic soil contamination included lead, cadmium and polychlorinated biphenyls (PCBs),
constituents which the Water Quality Operations of DENR identified in the stormwater discharge
from outfall 4 (retaining wall outlet). The PCBs were introduced in connection with a
transformer cracking operation that SBIC operated during the 1960's. Raleigh Recycling has
never allowed PCBs to be transported to the site and since becoming an operator in 2007 has
maintained a strict screening process to prevent PCBs from being introduced to the site.
2. Historic Contamination is Primary Source of Stormwater
Exceedances
PCBs do not appreciably dissolve in water. Instead, they tend to adhere to soil. This means that
PCBs become mobile only to the extent the soils to which they have adhered become mobile.
Similarly, the metals identified in the stormwater discharges are not particularly soluble in water.
The characteristics of these constituents are such that the primary source of stormwater
exceedances is likely to be contaminated site sediments that are caught up in stormwater, not
4751031v4 19853.00020

Danny Smith
May 2, 2014
Page 3
stockpiled scrap. In fact, turbidity sampling conducted by Water Quality Operations staff in
connection with the NOV identified high levels of sediments at outfall 4 and demonstrated that
as turbidity decreased further downstream from the outfall, so did levels of metals and PCBs in
the stormwater samples analyzed.
3. Proposed Response will Stabilize Site
Raleigh Recycling regularly pressed SBIC to develop and implement a comprehensive response
to the legacy contamination at the site. In April 2012 SBIC submitted its Revised Containment
Remedy Proposal (April 3, 2012) to the Inactive Hazardous Sites Branch, and later in June 2012
SBIC submitted the Remedial Action Plan (June 21, 2012) to Region 4 of the Environmental
Protection Agency. These documents describe a remedial action plan to install a cover over
those areas with soils contaminated by PCBs higher than 1 ppm (approximately 9 acres of an
operating yard comprised of roughly 14.5 acres). The cover would consist of geotextile fabric
overlain by approximately 12 inches of recycled concrete or aggregate base course cover. Small
volumes of soil with high levels of metal contamination that are not amenable to fixing (e.g.,
soils with concentrations of lead over 10,000 mg/kg) would be excavated and disposed off -site in
a permitted landfill. Remaining site soils contaminated with metals at levels that could to leach
into water would be amended with a fixing agent to prevent leaching. These metal -contaminated
soils are generally located within the upper two feet of the soil and coincident with the PCB
contaminated soils that would be subject to the protective barrier. The Revised Containment
Remedy Proposal (April 3, 2012) may be downloaded from the Inactive Hazardous Sites Branch
portal at https://edm.nc.aov/DENR-Portal/ and referencing Site ID NCD045915568. I
understand you have already received access to the Remedial Action Plan from Mid -Atlantic
Associates. If not, let me know and I will make the necessary arrangements.
The protective cover will stop contamination of stormwater associated with turbidity by
preventing mobilization of contaminated soils into sediment. The metal excavation and fixing
process will also stop those metals contaminated soils from contributing to stormwater
exceedances. The cover is predicted to be 95% impervious, and as such the volume of
stormwater permeating through the cover and coming into contact with site soil will be limited.
C. Obtaining Required State and Federal Approvals for Response to Historic
Contamination
The remedial action described above has been approved in concept by both DENR's Inactive
Hazardous Sites Branch and Region 4 of the Environmental Protection Agency. The required
formal approval by EPA had been delayed for over 18 months, until Raleigh Recycling was able
to assert control over the regulatory negotiations from which SBIC had previously excluded
Raleigh Recycling. EPA has now committed to make approval issuance a priority and plans to
initiate mandatory 30 day public notice on May 12. Once the EPA approval has been obtained,
Raleigh Recycling will seek the required formal DENR approvals, which also involve mandatory
public notice and comment periods.
4751031v4 19853.00020

Danny Smith
May 2, 2014
Page 4
Il. Two Stormwater Management Ponds
The remedial action plan submitted by SBIC did not include any stormwater management ponds,
though a small pond was contemplated by Raleigh Recycling in the northeast portion of the site.
After receiving the results that accompanied the NOV, and in connection with obtaining control
over site remedial efforts, Raleigh Recycling engaged McAdams Co. to design permanent
stormwater control devices that would augment the site stabilization to be performed by the
protective cover.
In order to assure a comprehensive solution to controlling contaminant loading in stormwater
discharges from the site, McAdams proposes the installation of two stormwater management
ponds along the western boundary of the property that will control discharges from over 14.56
acres of the 18.64 acre site. A large portion of existing discharges to outfall numbers 2 and 6
will be re-routed to the stormwater ponds, and outfall 4 will be eliminated. These ponds are
designed to control stormwater from a 100% impervious drainage area during 100 year storm
events. The ponds will include plants required for erosion control purposes. These plants will
also be selected for their propensity to assimilate metals. A detailed description of McAdams'
two -pond concept to manage stormwater is attached.
III. Evaluation and System Improvements as Appropriate
Within 90 days after the site has been stabilized with the protective cover, the soil with excessive
metals contamination fixed, and the stormwater ponds installed and functioning, Raleigh
Recycling will evaluate stormwater discharges to determine what, if any, additional controls and
polishing of discharges will be necessary and appropriate to avoid exceedances. These
improvements could include direct treatment of stormwater discharges by installing
polyacrylamide (Floc Logs(D by Applied Polymer Systems) upstream of the forebay for each
stormwater pond; or filtration between pond risers and pond outfalls. Until the holistic system is
in place and operating, it is not possible to determine what, if any, additional measures may be
necessary and effective.
IV. Schedule of Specific Milestones
Attached please find a schedule of specific milestones for implementing the system. This
schedule has been prepared based upon the experience and expertise of McAdams and Mid -
Atlantic Associates in such matters. Where possible, activities will be conducted concurrently to
shorten the duration of project implementation.
* e x
Raleigh Recycling has moved aggressively to seize control over the implementation of measures
necessary to eliminate stormwater discharge exceedances and to stabilize the site. Since
4751031 v4 19853.00020

Danny Smith
May 2, 2014
Page 5
obtaining control, there has been identifiable progress. Raleigh Recycling is committed to
managing this site in a responsible manner. We look forward to your review and approval of the
comprehensive, holistic approach that has been designed and submitted.
Sincerely,
ROBINSON BR/nA/DSHHAAW & HINSON, P.A.
William W. Toole
W WT/tbm
Attachments
cc: Gregory M. Brown (Raleigh Recycling NC Scrap Metal LLC)
Nicolette Fulton, Esq. (City of Raleigh)
Daniel H. Nielsen (Mid -Atlantic Associates)
Jon Aldridge (McAdams)
4751031 v4 19853.00020

FINAL STORMWATER MANAGEMENT PLAN
®SUMMARY
On March 27, 2014, a Notice of Violation (NOV) was issued by the North Carolina Division of
Energy, Mineral, and Land Resources (DEMLR). The NOV stated that exceedances existed for lead,
cadmium, mercury, polychlorinated biphenyls (PCBs), nickel, copper and zinc for stormwater runoff
on the western portion of the Raleigh Metals Site (Outfall #4). This narrative and the attached
conceptual plans provide detail for the proposed stormwater management measures that will be put
in place to control sedimentary runoff and contaminants to meet applicable stormwater discharge
standards.
®DISCUSSION OF PROPOSED MEASURES
There are six existing stormwater outfalls onsite. These outfalls are shown on the attached
conceptual plans. The proposed stormwater management plan includes a variety of measures
including the placement of a cover over much of the site to stabilize contaminated sediment,
installation of two large ponds and rerouting of storm drainage to minimize the number of outfalls
present onsite. After construction of the proposed stormwater management plan, approximately 85%
of the site will be directed to one of the two stormwater management facilities. Please refer to the
attached conceptual plans that detail the proposed measures and drainage areas for each of the
outfalls described below. A conceptual plan of the existing conditions is provided as well.
COVER STABILIZING SITE
A cover will be installed over approximately nine acres of the site in those areas with soils
contaminated by PCBs higher than 1 ppm. Metal -contaminated soils are generally located within the
upper two feet of the soil and coincident with the PCB contaminated soils that would be subject to
the protective cover. The cover would consist of geotextile fabric overlain by approximately 12
inches of recycled concrete or aggregate base course cover.
OUTFALL #1
The drainage area for this outfall consists primarily of the northeast parking lot. Please note that no
operational procedures are performed in this area. Inlet protection is proposed at each inlet in this
area. Additionally, silt fence is proposed on the north side of the parking lot (recently installed).
Both measures will aid in controlling sediment laden water from flowing to downstream properties.
OUTFALL #2
A large portion of the existing drainage directed to this outfall will now be directed to the North
Pond at Outfall 43. There will be a small amount of area that will still sheet flow to this outfall.
However, silt fence is proposed to handle any sediment laden water.
OUTFALL #3
To control contaminants at this discharge point, a stormwater management facility (North Pond) is
proposed. This facility will collect approximately 5.5-acres of drainage, and as stated above, will
treat the majority of the existing drainage to Outfall #2. The North Pond is designed such that it
Raleigh Metal Recycling May 2, 2014
9 MCADAMS I

controls and provides a 2-day drawdown of the 1" water quality storm event for the associated
drainage area. The proposed facility is designed such that peak flow rates at the outfall do not exceed
the pre -development condition for the 2-, 10-, and 100-year storm events. The facility includes
several measures to help control sediment and contaminants. These measures include riprap berms, a
skimmer attached to the outlet structure, and plantings that provide uptake of metals. A detailed
cross-section of this facility is provided on the conceptual plans provided.
OUTFALL #4
This outfall will be eliminated and the entirety of the existing drainage directed to this outfall will
now be directed to the stormwater management facility at Outfall #5.
OUTFALL #5
To control contaminants at this discharge point, a stormwater management facility (South Pond) is
proposed. This facility will collect approximately 9-acres of drainage and includes portions of the
existing drainage to Outfalls #2, #4, and #6. The proposed facility is designed such that peak flow
rates at the outfall do not exceed the pre -development condition for the 2-, 10-, and 100-year storm
events. The facility includes several measures to help control sediment and contaminants. These
measures include riprap berms, a skimmer attached to the outlet structure, and plantings that provide
uptake of metals.
OUTFALL #6
A large portion of the existing drainage directed to this outfall will now be directed to the South
Pond at Outfall #5. There will be a small amount of area that still drains to Gamer Road. Inlet
protection will be used in this area.
® MAINTENANCE, MONITORING, & FURTHER CONTROL. MEASURES
A component in the performance of the stormwater measures provided is maintenance. It is
recommended that each of the practices provided be inspected monthly or after each significant
rainfall. Sediment shall be removed in each of the basins routinely and disposed of properly.
Detailed operations and maintenance manuals will be provided to the owner at the time of final
approval.
Routine monitoring will be conducted at each outfall in connection with applicable NPDES Permit
requirements. This will help in determining the effectiveness of the measures proposed. Although we
feel that the stormwater management plan proposed is adequate, additional modifications may be
needed to further enhance the proposed measures ability to remove contaminants. Depending upon
the results of 90 day post -implementation monitoring and evaluation, additional improvements may
be necessary and appropriate. These include covering all or a portion of the operating site with an
impervious cover, installing-polyacrylamide (Floc Logs® by AppliedPolymerSystems) upstream of
each of the forebays for the stormwater ponds, and installing filtration devices immediately
downstream of the ponds.
Raleigh Metal Recycling May 2, 2014
9MCADAMS 2

We appreciate the opportunity to work with you on this project, and look forward to beginning
work as soon as possible.
Sincerely,
THE JOHN R. MCADAMS COMPANY INC. .•"
Jon Aldridge, PE
Project Manager
Water Resources and Infrastructure
SEAL.
33782
A.
L rAAY 14
Raleigh Metal Recycling May 2, 2014
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Attachment 1:
Parameter/Water
Outlet from
Confluence
Wildcat Branch
Quality Standard
retaining wall
Outlet to
Raleigh Metals
Waters
Recycling
Conductivity
972
805
103.4
Turbidity: 50 NTUs
550
170
75
Cadmium: 2.0 ug/I
65 ug/L
4.3 ug/L
2.2 ug/L
Lead: 25 ug/I
4300 uq/L
250 ug/L
36 ug/L
Aluminum:
100,000 ug/L
7,200 ug/L
24,000 ug/L
Human Health 8000 ug/L
Aquatic Life 87 ug/L
Mercury 0.012
16 uq/L
0.98 ug/L
Non detected
polychlorinated
biphenyls: (total PCB and
1.8 ug/L
0.58 uq/L
Non detected
congeners identified)
(PQL 1.0 uq/L)
0.001ug/I
Nickel: 88 ug/I
620 ug/L
53 ug/L
9.8 ug /L
Action Level Substances:
Copper: 7 ug/I
5000 ug/L
340 ug/L
150 ug/L
Zinc: 50 ug/I
15000 ug/L -
1100 ug/L
280 ug/L
Silver: 0.06 ug/L
9 ug/L
Non detected
Non detected

AIC Condenser Cores
Aerosol Cans -With Holes
Air Conditioners
AlternatorstSlarlers
Aluminum Awnings
Aluminum Cans
Aluminum Gutters
Aluminum Ladders
Aluminum Sidine,
Aluminum Signs
Aluminum Wire
Aluminum Rims
Appliances -All Including Microwaves
Autos & Engines, Parts, Rines i
Ballasts -No PCBs
Barrels -Aluminum, Steel
Batlnubs-Cast Iron
Batteries-Car,'Fruck, Forklift
-Lead Acid, Ups, Lithium, Ni-Mh, NI Cad
BBO Grills
Revcmae Can "--'
Bicycles
Blenders
Blowers_Leaf, Other
Boals-Mclal Aluminum
BrasslBronze-All Types
Bronze-AIITypes
Cable-Slccl, Copper, Aluminum -
Canocs-Metal/Aluminum -
Cans -Aluminum, Steel
Carbide -Tooling, Other
Cars & Enainey, Batteries, Rims
Cast Iron -Sinks, Bathtubs. Etc.
Catalytic Converters
Coaxial Cable
Chain Saws -Drained
Christmas Lights
Circuit Breakers
Coat hangers Steel
Compressors
Computers (Not Monitors)
Computer Printers
Conduit-Pipe-Alunlinn nt/S(eel
Capon -Nitre Tube, Wim, Gutters
Crutches -Aluminum\ s
Demolition Scrap
Diesel Engines)Blocks�\
Diecas-All Types
DishwashersV,VVs\�
Cans `vv\ /
Duct Work,.
E-Scrap, &Waste
- - Electric Meters
`-Eleclric Molois
Electric Wire-StrippecYUnstripped
Electronic Scrap
Enginas-Drained-Car, Mower
—Exercise Equipment (Most)
Extension Cords
Fans
Fencing -Nu Concrete
Fire Extinguisher- With Holes Or Cut
1'aeplace Grates, Doors (No Glass)
-'Forklifts Trucks. Etc.
Freezers
Fuse Panels
Furniture „
Fir rnace
Gas lhnki Cut In IIaBOnly, ,
Genera\ors-Home, Car, Larg;
Gutters Alum. Copper, Steel
I-huger,_Coiat-Slat r '
-I Him %
Ilot Water ITeatars
I-BeamsStcel -
In igalion Pipe -Aluminum, Steel
Raleigh Metal Recycling
2310 Garner Road
Raleigh, NC 27610
Phone: [phone]
Iron -Cast, Other
Soda Cans
Insulated Wim-Copper, Ahtminum
Stainless Steel -All -Including Sinks
LaddcrsAluminum. Steel
Starters/Alternators
Lawn Mowers-Gas/Oil Out
Lawn Furniture ��-
Steel -All, Cabinets, Cans. Hangers, Scams, Etc.
Lead -Weights; Wheel Weights -Shields, Etc,
Steel Bor'gs'lurn gs, Stampings
Leaf Blowers -Gus Out
Slaves -Electric, Gas Wood
'
Light Fixturc,a-With & Without'�
stovepips
Balles'tsIrrrmsformers
Struclur l Steel
Litho Plates F "-- -
'lanks-Alum, Stainless, Steel
MlulgallelC � �
� -Cbi In llulf Orl.arpu llol�n
Metal -Galvanized, Shect, Iron, Cast, Etc.
Telephone Wire
Microwaves •
Tin,
Mixers
Tin I+oil-Clean
Motors & Blocks-Elec&
'
lbbacco Rucks
Gas -With Gas/Oil Out
4
tractors -Farm, Lawn, Other
Nails -Steel, Aluminum
Ovens -All Types
T'rnsformcrs-Oil Free
Plumbing Fixtures
Trapsmissions-Drained
Pipe -Copper, Galvanized, Steel
Triplex -Wire
ll�J L'A�LlMW1A°UIII I�LUU
C+ 3 cep1 ¢ is PER POUND
Note: Canrwt be used with "New Customer" offer, nut is good for new and exisarrg customers!
Poles -Aluminum, Steel
Pop Cans ,
Pots And Pans
Printers
Radiators -Auto, house
Railroad Rail, Plates, Nails
Rebar
Refrigerators
Rims -Steel, Aluminum . .�
Romex /
Roof Vents. Roof A1etaly '-
Screen Doors/Windows
,Screws -Steel, Brzias, AhrmiilunI
Scaled UnitslCompressors
Shells -Casings, Brass, Other %
'Siding -Aluminum
.Signs -Aluminum, Steel
.Sinks -Stainless, Cast iron, McVd
Slartcn/Alternators
Trucks & Truck Pan
Tungsten
Vacuum Cleaners
Washing Machines/Dryers
Water Heaters
Weed Wackers-No Gasoline
Wheel Rims-Slml Aluminum
Whecl Wcights-Lead/Steel
Wim-Coritar,Uum Steel Triplet
/ Slrimiellf nsulattd
Wiring Harness-Car,T'ruck, Other
i� While Goods -Appliances
Wrought Iron
X-Rav Film
-Line
TvDoNot Bon
'Fvs, Monitors, Se:ded'lanks, Ifecr Kegs
Raleigh Metal Recycling
GG Uo o
BRING A COPY OF THIS SHEET OR MENTION CODE &407 AND GET:
E3 cents + 15 cents
W wNON-FERROUS METALS ps hmdxd pounds foFERROJS METAtS
pper.Abumirum) (a.St�,PPpla^[a)
p to the first 500 pounds. Good up to the first 2.000 pounds.
-Offer only good far fire areac stares.
Rd L�J..Ld�GH METAL RECYCLN"—'
OPENTO THE E M � �Q ((° � 2310 GARNER ROAD, RALEIGH, NC o 919-828-5426
• u �o MON-FBI B:OOAM-4:30PM AND SATUDDAY 1:06AM-2:001"M
wwwlww.raleighscrapmetalrecycling.com

0
RALEIGH METALS RECYCLING
RALEIGH, NORTH CAROLINA
STORMWATER MANAGEMENT PLAN
PROJECT NUMBER:
DESIGNED BY:
DATE:
F
SPEC-13290
JON ALDRIDGE, PE
DECEMBER 2013
' MCADAMS
2905 MERIDIAN PARKWAY
DURHAM, NORTH CAROLINA 27713
NC LIC. # C-0293

STORMWATER MANAGEMENT PLAN
BACKGROUND INFORMATION
The Raleigh Metals Recycling site is located along Garner Road, approximately 0.70 miles north of
the intersection with Rush Street and Garner Road in Raleigh, North Carolina. The facility provides
services that include the collection, sorting, and exchange of scrap metal. As such, the facility is
covered by General Permit Number NCG200000. As a condition of this permit, a Stormwater
Pollution Prevention Plan (SWPPP) was developed by Golder Associates dated April 2013. In
summary, this plan provides a description of processes onsite and discusses implementation of
measures to be taken to minimize contaminants in runoff from the site. One component of the
SWPPP is a Stormwater Management Plan that addresses practices to be taken onsite to minimize
exposure of contaminated materials with stormwater runoff. These practices include storage
procedures and good housekeeping policies. On September 12, 2013, a Notice of Deficiency (NOD)
was issued by the North Carolina Division of Environmental and Natural Resources (DENR). Upon
review of further testing results, it was noted that additional exceedances of several other
benchmarks existed for Cadmium, Chemical Oxygen Demand (COD), Copper, Iron, Lead, Oil and
Grease, Total Suspended Solids (TSS), and Zinc. Noted in the NOD was that secondary containment
and general housekeeping appeared adequate. The exceedances are most likely a result of
uncontrolled sedimentation from the site. This report discusses measures taken since the NOD was
issued and further details stormwater measures that should be put into place to help control
sedimentary runoff.
The drainage patterns onsite as identified in the SWPPP, include six_stormwater outfalls. These
outfalls are referenced throughout this report and are the same as those identified -in the SWPPP.
Also provided is a brief explanation of the contributing drainage area to each of these outfalls. Please
reference the included maps that indicate each of these outfalls. For each outfall, the nine parameters
mentioned above were tested, each with a benchmark value that they are required to meet. The
facility currently does not exceed any pH or Oil and Grease benchmarks. However, many of the
other parameters are exceeded at each outfall. Both COD_and TSS can be treated by incorporating
practices that allow for controlling sedimentation_through the use of barriers, mats, settling, and
dispersion. Similar methods can be -used -to remove heavy metals and PCBs from the runoff since
most of these contaminants attach themselves to particles and are transported by the particles in
suspension. Thus, the most appropriate BMPs to control pollutants onsite will be those that minimize
release of contaminant laden sediment.
It should be noted that at this time a Remedial Action Plan (Rhas been submitted to the
Environmental Protection Agency for review. This RAP will provide measures that limit exposure of
surface runoff with the contaminated soils. These measures include amending the top layers of the
soil and installation of a protective barrier -covering roughly half of_the_17_acre site consisting of
cgeoteztile fabric overlain by recycled concre— top ssed'to resemble aggregate st3ne TfiFRAP-also'
calls-forconstruction—oot-a-stormwater-detention-pond-on-the-north side of"tl e property. This plan
dated June 21, 2012 was prepared by Mid -Atlantic Associates- Inc. Implementation of these
measures is awaiting federal approval ofthis plan.
Raleigh Metal Recycling December 23, 2013
tJ MCADAMS I

© EXISTING CONDITIONS
At the time of our site visit on October 18, 2013, several measures had already been taken by the
tenant to control contaminated sediment/oil from leaving the site. These measures included the
expansion of a small basin on the north-side.of-ttie-property, the construction of a small basin on the
west- ide ofihe ssiteanplacement of booms. _ Additional handling and pro eessing`policies have
been -put 'intoplace'to-avoid spills and contamination of the ground surface. Below is a brief synopsis
of the, measures currently installed for each outfall along with testing data. Please reference the
r, attach'ed map (EC-f,). q I
� h
Testing d'ata`Oor each outfall is provided abelow. This information is from testing by both
4! Environmental Cohservation Laboratories;] Inc: (ENCO) and Highlands Environmental Solutions,
Inc. (HES). The benchmark values shown below are from the SWPP and the North Carolina General
NPDES Permit # NCG 200000.
OUTFALL#1
The area draining to this outfall appears to be minimized to the parking lot at the northeast corner of
the property and some roof drainage. Booms have been added to the outflow.
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7.5
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7.0
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'6.0-9.0 _
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67
OUTFALL#2
The drainage to this point is comprised of areas draining to the North Basin and some bypass along
the most northern portion of the site. It is estimated that about a third of the site drains to the North
Basin. The North Basin drainage includes runoff from the Fueling Area, Vehicle Processing Area,
Bailer, Non -Ferrous Area, and portions of the Ferrous Yard. This drainage is collected in a piped
system that discharges to a channel and ultimately enters the North Basin. Check dams have been
placed in the channel to help minimize sediment entering the basin. A turn -down elbow has been
recently installed on the upstream side of the outfall to minimize the amount of oil or floating debris
from being conveyed offsite. At the time of our inspection, it was noted that this basin had been
expanded and cleaned.out. Several housekeeping improvements relating to storage and containment
of materials were made upstream that should help in minimizing pollutants coming into contact with
stormwater runoff. One such improvement was a relocation of storage from outside to inside for
electric motors and sealed units. Improvements to the bypass areas discharging to Outfall #2 were
made as well. These include the addition of gravel in high traffic areas to minimize the amount of
sediment runoff, removal of petroleum laden sediment, ,placement of booms upstream and
downstream of the outflow, and modifications to the gutter system of the maintenance building to
Raleigh Metal Recycling , December 23, 2013
�� MCADAMS

avoid water flowing into and out of the building during storm events, adding to pollutant loads in
runoff.
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100
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67 1
OITI ALL #3
The area draining to this outfall consists of primarily brush and grasses away from areas containing
metals. It is unclear as to the extents of this drainage area, as the site subsurface drainage system is
undefined at this point. It may include a portion of the Ferrous Yard. A small channel discharges
water to the adjacent railroad at the northwest corner of the site. Small booms were added to the
outflows in this area.
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ENCO 6/7/2(
Benchmark
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OUTFALL #4
The drainage area to this point is comprised of areas draining to the West Basin and some bypass to
the adjacent railroad. It is unclear as to the limits of the drainage area going to the West Basin, but it
is believed to mostly consist of the Shearing Unit, Metal Torching Area, and the Ferrous Yard. This
basin is lined with stone and discharges to the adjacent railroad. It also includes a turn -down elbow
to minimize the oil or debris from being conveyed offsite. It appeared that this basin discharged to
the adjacent railroad in the direction of Outfall #5. It is unclear as to the extent of this drainage area
(due to the same undefined drainage system), but as shown on the attached aerial map, there is a
limited amount of Wake County GIS information available for this outfall. The pipe exiting the
property discharges stormwater runoff to the adjacent railroad along the western portion of the site.
Booms have been installed on the pipe coming from the yard into the basin and on the pipe exiting
the property.
Raleigh Metal Recycling
9 MCADAMS
December 23, 2013
3

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Benchmark 6.0-9.0
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30 67
The area draining to this outfall
mostly consists of the Metal Torching Area and Ferrous Yard. At the
time of initial testing, turnings soaked with petroleum were stored in the southwest corner of the site.
These have since been removed.
Booms have been installed in the outflow.
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OUTFALL#6
It is unclear as to the extents of this drainage area. It is believed to include a portion of the Ferrous
Yard, Scales, and parking area at the southeast corner of the site. This outfall is also identified on the
Wake County GIS information provided on the aerial map. The pipe exiting the property discharges
stormwater runoff into` the existing storm drainage system in Garner Road. A channel lined with
stone has been constructed to minimize sediment transport. Additionally, small booms have been
placed around the inlet draining into this system.
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8.6
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Raleigh Metal Recycling
U MCADAMS
December 23, 2013
4

® STORMWATERMANAGEMENT PLAN — PHASE I
This initial phase of stormwater management onsite is intended to expand upon measures already
taken to improve sediment capture onsite. These measures are intended to be implemented quickly
and are also considered temporary until the final stormwater management plan for the site is
R approved and/or developed. Once these measures are in place, additional testing will be completed to
rl' monitor how the Phaserj practices are working. At that time review of the testing data may show that
additional measures are necessary (i.e. Phase II). Please reference the included Phase I map (SW-1)
for additional information. One of the main goals of Phase 1 is to determine -conclusively the
1r— —�--
d�rainage areas to each of the outfalls, and locating all subsurface drainage and inlets. Once the
drainage boundaries are known conclusively to each outfall—it will -be possibl o tailor the
stormwater management to the drainage area of the outfall.
OUTFAU, #1
The extents of this drainage area as shown on the attached map are believed to be fairly accurate.
Where possible, inlet protection should be placed around each inlet in accordance with the North
Carolina Erosion and Sedimentation Control Manual. This will help to minimize the COD and TSS
loading to the benchmark values. To address the heavy metal pollutants, the placement of a
polyacrylamide (Floc Logs® by Applied Polymer Systems or an approved equivalent) is
recommended at-each_inlet.,A data sheet fTr the Floc log product is provided at the end of this
report. It is also recommended that silt -fence -be installed on the north side of the parking lot to
6 minimize anv sediment Paden water from flowing to downstream properties.
OUTFALL #2
As part of Phase 1, it is recommended that further exploration into the exact drainage area for this
outfall be provided. Based on the testing results it appears that the North Basin is providing equate
COD and TSS removal. To address the heavy metal pollutants, the placement of a couple Floc
Logs® is recommended in each of the ditches draining to -the basin. It is also recommended that silt
'fence be installed on thenorth sidee of the ssife tominimize any sediment laden water from flowing to
downstream properties.
OUTFALL #3
As part of Phase 1, it is recommended that further exploration into the exact drainage area for this
outfall be provided. To aide in the remova of COD and TSS. check dams or waddles are
recommended in the existing ditch. To address the hea metal pollutants, the placement of a couple
Floc tiogs®-is recommendedin the ditch draining to the outfall. It is also recommended that silt
fe cn e be ni stalled on the west side of the site to minimize any sediment laden water from flowing to
downstream properties.
OUTt ALL#4 ; A
As part of Phase 1, it is recommended that further exploration into the exact drainage area for this
outfall be provided. Where possible, inlet protection should be placed around each=inlevdraining to
this outfall. This will help to minimize the COD and TSS loading to the benchmark values. To
address the heavy metal pollutants, the placement of a Floc Log® is recommended at each inlet. It is
C::
Raleigh Metal Recycling December 23, 2013
9 MCADAMS 5

also recommended that silt fence be installed on the west side of the site to minimize any sediment
laden water from flowing to downstream properties.
OU'rFALL #5
As part of Phase 1, it is recommended that further exploration into the exact drainage area for this
outfall be provided. Based on the testing results it appears that the West Basinasin —providing adequate
COD and TSS removal. To address the heavy metal pollutants, the placement of a Floc Log® is
recommended at each inlet contributing to the drainage to the basin. It is also recommended that silt
fence be installed on the west
f the site to minimize any sediment laden water from Flowing of
downstream properties.
OUTFALL #6
As part of Phase 1, it is recommended that further exploration into the exact drainage area -for this
outfall be provided. Where possible, inlet protection should be placed arouned each inlet draining to
this outfall. This will help to minimize the COD and_TSS_loading to the benchmark values. To
address the heavy metal pollutants, the placement of a Floc Log® is recommended at each inlet. For
Outfall 46, we suggest that this phase of the study _determi� ne wh to her or not to redirect discharge to a
In addition to the data sheet for the Floc Logs®, details for the silt fence, inlet protection, and check
dams are provided.
A key component in the functionality of all of the stormwater measures mentioned above is
maintenance. It is recommended that each of_ the -practices -provided be inspected monthly or after
ne — --
each significant rainfall -Sediment shall -be removed in each of the basins'routinely-and'disposed off
pro
e
The facility shall continue monitoring at each outfall as outlined in the NPDES General Permit
Number NCG200000. This additional testing shall be provided to the civil engineer to determine
how the data is trending and will be helpful in determining what BMPs and measures taken onsite
are working to control the contaminated runoff.
Raleigh Metal Recycling,i„„ December 23, 2013
9 MCADAMS 6

USTORMWATER MANAGEMENT PLAN —PHASE lI
This phase of stormwater management is intended to serve as an ultimate/final remediation plan.
Once additional drainage area and testing data are received as part of the Phase I plan and approval
of the RAP is received, modification or additions to the stormwater management plan will be
evaluated. We anticipate this might include expansion/addition of larger traditional stormwater
facilities (i.e. dry detention basins or wet ponds). The extent of Phase 11 cannot be clearly defined
until the drainage boundaries to each of the outfalls are determined and installation of measures
proposed in the RAP are complete,_ since the stormwater treatment facilities will be designed
specifically -for -each -drainage area.
Raleigh Metal Recycling
1111 MCADAMS
December 23, 2013
7

© STORMWATER MANAGEMENT PLAN SCHEDULE
The suggested plan of action by the client is as follows:
• Installation of perimeter silt fence, check dams, inlet protection, and Floc Logs as detailed on the
provided Phase I plan. Upon receipt of the draft of this document on December 10, 2013, the
client began installation of several of these measures.
Estimated completion — 21112014
t�
• Determination of onsite drainage systems/boundaries by survey, smoke testing, video camera, or
other means.
Estimated completion — 21112014
• Continued monitoring at each outfall to determine whether further modifications to the proposed
stormwater management plan is required. If the site is not reaching compliance as required in the
NPDES General Permit, additional measures may need to be taken.
Estimated completion — Ongoing
• Installation of protective barrier and sto` rmwater_management.pond as outlined in the RAP.
Estimated completion — 12 months after final approvals by U.SEPA and NCDENR
• Evaluation of effectiveness of protective barrier and stormwater management pond.
Estimated completion — 6 months after completion of installation
Raleigh Metal Recycling 'December 23, 2013
TIMCADAMS 8

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EFFECTIVE: 01/31
TOP ELEVATION OF STORMWATER
- - - - - - - - - - - - - - - - - -
#5 WASHED
EXISTING SLOPE
EXISTING SLOPES
KEYED RIP RAP
#5 WASHED STONE
FRONT VIEW
NOTE: REMOVE SEDIMENT ACCUMULATION FROM BEHIND
CHECK DAMS TO PREVENT DAMAGE TO CHANNEL VEGETATION.
FLOW SHOULD BE MAINTAINED THROUGH THE DAM.
STANDARD CHECK DAM
0.5'-1'
MAX. y
1 A
a N
#1
SIDE VIEW
CONSTRUCTION NOTES:
HEIGHT & WIDTH DETERMINED BY
EXISTING TOPOGRAPHY AND
SEDIMENT STORAGE REQUIRED.
KEY RIP RAP INTO THE DAM
FOR STABILIZATION.
EXISTING -
GROUNO
STEP SEQUENCE

STANDARD METAL POSTS 7-0" IN GROUND
GALVANIZED HARDWARE WIRE
EXTENDS TO TOP OF BOX
0
-\
NOTE:
1. INSPECT INLET PROTECTION AND REMOVE SEDIMENT AFTER EACH RAIN EVENT. GRAVEL SHOULD BE REPLACED� V # 57 WASHED STONE PLACED TO A HEIGHT OF 12"-18` MINIMUM ABOVE TOP OF BOX
AND REPAIRS MADE AS NEEDED.
STANDARD GRAVEL YARD INLET PROTECTION
i

MINIMUM 10
LINE WIRES
8'-0" MAXIMUM
IMUM 12-1/2 GAUGE
RMEDIATE WIRES
GRADE
NOTE:
1. USE SILT FENCE ONLY WHEN DRAINAGE AREA
DOES NOT EXCEED 1/4 ACRE AND NEVER IN
AREAS OF CONCENTRATED FLOW.
2. REMOVE SEDIMENT DEPOSITED AS NEEDED TO
PROVIDE STORAGE VOLUME FOR THE NEXT RAIN
AND TO REMOVE PRESSURE ON THE SILT
FENCE.
FRONT VIEW
STEEL POST
WOVEN WIRE FABRIC
�3 SILT FENCE FABRIC
0
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FILL SLOPE
io
`�~•�GRADE
6NIMUM COVER
oTO'VERSKIRT
`,HOR SKIRT AS DIRECTED
ENGINEER '
SIDE VIEW
STANDARD TEMPORARY SILT FENCE

TOP OF
MUST BE
ABOVE T
THE WAS
STEEL FENCE
WIRE FENCE
HARDWARE CLOTH
BURY WERE FENCE AND HARDWARE CLOTH
0I /3
U CLOTH IN TRENCH
SIFIl FENCE POST I
SET LIA% Y' APART
MIN. 18' WTO SOU
GROUND
J' FILTER FABRIC
ON GROUND .
NOTES:
1. REMOVE SEDIMENT WHEN HALF OF STONE OUTLET IS COVERED.
2. REPLACE STONE AS NEEDED TO ENSURE DEWATERING.
8' OF UPPER EDGE OF
FABRIC IN TRENCH
SECTION VIEW
STANDARD SILT FENCE OUTLET

Applied Polymer
519 Industrial Drive, Woodstock, GA 30189
WWW.siltstoo.com
Phone: [phone]
Toll -free: 866-200-9868
Fax:[phone]
Systems
APS 700 Series Floc Logs°
Polyacrylamide Sediment and Turbidity Control Applicator Logs
APS 700 Series Floc Logs are a group of soil -specific tailored log -blocks that contain blends
of water treatment components and polyacrylamide co -polymer for water clarification. They reduce and
prevent fine particles and colloidal clays from suspension in stormwater. There are several types of Floc
Logs designed to treat most water and soil types. Contact Applied Polymer Systems, Inc. or your local
distributor for free testing and site -specific application information.
Primary Applications
• Mine tailings and waste pile ditches
• Stormwater drainage from construction and building sites
• Road and highway construction runoff ditches
• Ditch and treatment system placement for all forms of highly turbid waters (less than 4% solids)
• Dredging operations as a flocculent
Features and Benefits
• Removes solubilized soils and clay from water
• Prevents colloidal solutions in water within ditch systems
• Binds cationic metals within water, reducing solubilization
• Binds pesticides and fertilizers within runoff water
• Reduces operational and cleanup costs
• Reduces environmental risks and helps meet compliance
Specifications / Compliances
• ANSI/NSF Standard 60 Drinking water treatment chemical additives
• 48h or 96h Acute Toxicity Tests (D. magna or 0. mykiss)
• 7 Day Chronic Toxicity Tests (P. promealas or C. dubia
Packaging
APS 700 Series Floc Logs are packaged in boxes of four (4)
Technical Information
Appearance - semi -solid block
Biodegradable internal coconut skeleton
Percent Moisture - 40% maximum
pH 0.5% Solution - 6-8
Shelf Life — up to 5 years when stored out of UV rays

Placement
Applied Polymer Systems
519 Industrial Drive, Woodstock, GA 30189
www.siltstop.com
Phone: [phone]
Toll -free: 866-200-9868
Fax:[phone]
Floc Logs are designed for placement within ditches averaging three feet wide by two feet deep. Floc log
placement is based on gallon per minute flow rates. Note: actual GPM or dosage will vary based on site
criteria and soil/water testing.
Directions for Use
(Water and Floc Log Mixing is Very Important!)
APS 700 Series Floc Logs should be placed within the upper quarter to half of a stabilized ditch system or
as close as possible to active earth moving activities. Floc Logs have built in ropes with attachment loops
which can be looped over stakes to ensure they remain where placed. Mixing is key! If the flow rate is
too slow, adding sand bags, cinder blocks, etc., can create the turbulence required for proper mixing.
Floc Logs are designed to treat dirty water, not liquid mud; when the water contains heavy solids
(exceeding 4%), it will be necessary to create a sediment or grit pit to let the heavy solids settle before
treating the water.
Floc Logs must not be placed in areas where heavy erosion would result in the Floc Logs becoming
buried. Where there is heavy sedimentation, maintenance will be required.
APS 700 Series Floc Logs can easily be moved to different locations as site conditions change. Water
quality will be improved with the addition of a dispersion field or soft armor covered ditch checks below
the Floc Log(s) to collect flocculated particulate. Construction of mixing weirs may be required in areas
where short ditch lines, swelling clays, heavy particle concentrations, or steep slopes may be
encountered.
Cleanup:
Latex or rubber gloves are recommended for handling during usage. Use soap and water to wash hands
after handling.
Precautions / Limitations
• APS 700 Series Floc Logs are extremely slippery when wet.
• Clean up spills quickly. Do not use water unless necessary as extremely slippery conditions will
result and if water is necessary, use pressure washer.
• APS Floc Log will remain viable for up to 5 years when stored out of UV rays.
• APS 700 Series Floc Logs have been specifically tailored to specific water and soil types and
samples must be tested. Testing is necessary and is free.
• For product information, treatment system design assistance, or performance issues, contact Applied
Polymer Systems.

t,
Environmental Conservation Laboratories, Inc.
102-A Woodwind, Industrial Court
Cary NC, 27511
Phone: [phone] FAX: [phone]
Friday, June 21, 2013
Goldsboro Iron & Metals Recycling (G0014)
Attn: Dennis Gehle
801 N. John Street
Goldsboro, NC 27530
RE: Laboratory Results for
Project Number: [none], Project Name/Desc: Raleigh Metal Recycling Storm Water
ENCO Workorder(s): C305031
Dear Dennis Gehle,
Enclosed is a copy of your laboratory report for test samples received by our laboratory on
Friday, June 7, 2013,
Unless otherwise noted in an attached project narrative, all samples were received in
acceptable condition and processed in accordance with the referenced methods/procedures.
Results for these procedures apply only to the samples as submitted.
The analytical results contained in this report are in compliance with NELAC standards, except
as noted in the project narrative. This report shall not be reproduced except in full, without
the written approval of the Laboratory.
This report contains only those analyses performed by Environmental Conservation
Laboratories. Unless otherwise noted, all analyses were performed at ENCO Cary. Data from
outside organizations will be reported under separate cover.
If you have any questions or require further information, please do not hesitate to contact me.
Sincerely,
�n
Stephanie Franz By
Project Manager
Enclosure(s)
"C
0 �'i
AUG 26 2M
Page 1 0f30

www.encolabs.com
PROJECTPRpIECT-nVE
Date:
21 June 2013
Client:
Goldsboro Iron & Metals Recycling (GO014)
Project:
Raleigh Metal Recycling Storm Water
Lab ID:
C305031
Overview
Environmental Conservation Laboratories, Inc. (ENCO) analyzed all submitted samples in accordance with the methods
referenced in the laboratory report. Any particular difficulties encountered during sample handling by ENCO are discussed in
the QC Remarks section below.
Quality Control Samples
No Comments
Quality Control Remarks
The determination of pH is considered a field parameter, and as such, has a holding time of approximately 15 minutes. As
this time passed prior to receipt by ENCO, the analysis was conducted outside of hold time, and the results are appropriately
qualified (Q-Flagged).
Other Comments
The analytical data presented in this report are consistent with the methods as referenced in the analytical report. Any
exceptions or deviations are noted in the QC remarks section of this narrative or in the Flags/Notes and Definitions section of
the report.
Released By:
Environmental Conservation Laboratories, Inc.
Stephanie Franz
Project Manager
FINAL To's report reldtAS only to me sample as reoeivm
M roe laboratory, and meV oMv Le ieyropucey m roll.
Page 2 of 30

SAMPLE SUMMARY/LABORATORY CHRONICLE
Parameter
-
Hold Date/T1me(s)
-. p
-
EPA 1660A
Prep Date/Time(s)
Analysis Date/Time(s)
07/05/13
06/13/13 11:00
4 2 1' ... .......................
6/14/2013 09:44
EPA 200.7
12/04113
06/10/13 09:57
6/12/2013 12:22
SM 2540D-1997
D6/14/13
06/11/13 10:10
6/11/2013 10:10
SM 4500H+B-2000
06/07/13 14:59
06/10/13 14:24
SM 5220D-1997
D7/05/13
6/10/2013 14:24
06/17/13 14:21
6/17/2013 17:56
Parameter
Hold Date/Time(:
EPA 1664A--
07/OS/13
EPA 2DO.7
12/04/13
SM 2540D-1997
06/14/13
SM 4500H+B-2000
06/07/13 15: 14
SM 5220D-1997
07/05/13
..:.................. Prep Dat
06/13/13
06/10/13
06/11/13
06/10/13
O6/17/13
11:00
6/14/2013
09:44
09:57
6/12/2013
12:25
10:10
6/11/2013
10:10
14:24
6/10/2013
14:24
14:21
6/17/2013
17:56
Parameter.
-� � � -
- � Hold Dale/Time(s)
-._ (s
Pre p Date/Time(s)
ueeetveo:-P6/07/13.16:36,a;..
EPA 1664A
07/OS/13
/1
Analysis Dale/7me(s)
EPA 200.7
06/13/13 I1:00
6/14/2013 09:44
12/04/13
06/10/13 09:57
6/12/2013 12:34
SM 2540D-1997
06/14/13
06/11/13 10:10
6/11/2013 10:10
SM 4500H+e-2000
06/07/13 14:29
06/10/13 14:24
SM 5220D-1997
07/05/13
6/10/2013 14:24
06/17/13 14:21
6/17/2013 17:56
Parimeter Hold
d Dale/Time(s) Prepe Date/Time(s) _ Analysis Date/Times)
EPA 1664A 07/O5/13 06/13/13 11:00
6/14/2013 09:94
EPA 200.7 12/04/13 06/10/13 09:57 6/12/2013 12:37
SM 2510D-1997 06/11/13 06/11/13 10:10 6/11/2013 10:10
SM 45DOH+9-2000 06/07/13 14:29 06/10/13 14:24 6/10/2013 14:24
SM 5220D-1997 07/05/13 06/17/13 14:21 6/17/2013 17:56
Parameter
— ..... ........ --
Hold Dal
EPA 1664A
07/05/13
EPA 200.7
12/04/13
SM 2540D-1997
06/14/13
SM 4500H+B-2000
06/07/13
SM 5220D-1997
07/05/13
rmets) Prep Do
06/13/13
06/10/13
06/11/13
13:59 06/10/13
06/12/13
Imets)
Analysis Date/Tin
11:00
6/14/2013
09:44
09:57
6/12/2D13
12:39
10:10
6/11/2013
10:10
14:24
6/10/N13
14:24
12:06
6/12/2013
16:23
FINAL t his report r dates only to the sample as receme0 try the IaM1oram,,, xnrl may only W raprw]ucea in full. N.3 of 30

1
70
Parameter
- ..........
-.-_. --___
Hold DateI Ime(s)
.,--a ,,. a;,l, nampled'D6
/07/13'1435 ..._.. Rece vedi 06/07/13, 16:261 ni
EPA 1669A
....... ... ... - .........
OJ/OS/13
Pre D
P rate/rme(s)
� � -
..... Anal '
- Ysls Dale/T'ime(s)
EPA 20p.J
12/09/13
06/13/13 11:00
_ ..
-"--"----..
6/14/2013 09:44 '
SM 254OD-1997
06/
06/10/13 09:57
6/12/2013 12:42
SM 9500H+8-2000
06/07/13 /13 Iq:99
06/11/13 10:10
6/11/2013 10:10
SM 5220D-1997
07/OS/13
06/10/13 14:24
6/10/2013 14:24
06/12113 12:06
6/12/2013 16:23 -
FINAL This report helatea oFl
Y mthe sample a; reccven by the le WmWry, ana may only pe reprpaucetl In lull.
Page 4 0130

SAMPLE DETECTION SUMMARY
Analyte
..._.-.o-'
,Ux I.. N.t� ss,,
L.3u1 :..a'$..5'a�si:lxC'6'i.F''`"tr ..-
���-�-�
Cadmium - Total "-'-"
Results
Fla 9 MDL
"�-xxS, "T?'-t 3^;
Chemical Oxygen Demand
3.03
0,360
PQL
Units
- "
... - Method Notes
Copper -Total
130
10
1.00
o L
EPA 200.7
Leon - Total
269
1.60
30
mg/L
SM 5220D-1997
Lead - 7obl
1780800
22
10.0
ug/L
EPA 200.7
Oil & Grease HEM-5
( GT) Nan
147
2 1
50
ug/L
EPA 200.7
-Polar Material
PH
8.10
10.0
ug/L
EPA 200.7
Total Suspended Solids
75
2.49
1.0
7.79
mg/L
EPA 1664A
Zinc - Total
9
1.0
1.0
pH
SM 4500H+B-2000 Q
948
1.0
m
mg/L
SM 2540D-1997
lent ID vfr`pp -
9' /
3.8
100
ug/L
EPA 200,7
.-. C
4 •'k '. 1 .t'r
Lab
Analyte
Im-C305031-02
Results
u,P11
.L.. ., 1`i3 ,,.;;V, k�L �.:...
Cadmlum Total _
qa g MDL
..
PQL
vx_.�x•r
Chemical 0
Oxygen Demand
0.693
.-.-.
J 0360 -
_ .....Units
Method Notes
Copper - total
S2
.
10
1.00
.. .. ..... .. ...
EPA 200.7
Iron - Total
66.8
1.60
10
mg/L
SM 5220D-1997
Lead - Total
3010
22
10.0
ug/L
EPA 200.7
Oil &Grease HEM-S
( � Non
76.5
2.1
50
ug/L
EPA 200.7
-Polar Material
4.09
10.0
ug/L
EPA 200.7
PH
Total Suspended Solids
77
J 1.92
1.01.0.0
6.01
mg/PH
EPA 1664A
Zinc -Total
53
1.0
PH
SM 4500H+B-2000 Q
293
1.0
mg/L
SM 254OD-1997
lient ID 3�30utfall 003 ' "`+'9 a -
3.8
10.0
ug/L
EPA 200.7
�(V.A YC''L N 'r
Analyte- ,rs'v Loh ID
...
Cadmum iobl
Results
,"{�0503103`�
Fla '. ..t'.$
0 MDL
..a n�.;�:, '_;;vy>;j
x :. ..t^ r t, ,'
'
Chemical Oxygen Demand
. - .
1.99
- - 0,3
0.360 -
PQL
-'1.- -
Units
- � � .......
- - ._�,�
_ Method Notes
Copper - Total
130
10
ug/L
EPA 2D0.7 -'-"-
Iron -Total
62.7
1.60
10
mg/L
SM 5220D-1997
Lead - Total
1680
22
10.0
ug/L
EPA 200.7
Oil & Grease HEM-S
( G1) Nan
lfi.l
2 1
50
10.0
ug/L
EPA 2007.
-Polar Material
3.95
J
ug/L
EPA 200.7
PH
Total Suspended Solids
7.6
2.11
10
6.58
my/L
EPA 1664A
Zinc -Total
13
1.0
1.0
OM
SM 4500H+B-2000 Q
681
1.0
mg/L
SM 2540D-1997
,.r
3.8
10.0
ug/L
EPA 200.7
Analyte
Cadmium - TPtal........... ...... .. ............
Chemical Oxygen Demand
Copper - Total
Iron -Total
Lead - Total
Oil & Grease (HEM -SG) Non -Polar Material
PH
Total Suspended Solids
Zinc - Total
Results Fla 9
MDL
.,
.::..
._.
2.32
-'
0.360
.60
Units
" '
M ethod
Notes
100
ug/L
EPA 200.7
32.9
10
3.
mg/L
SM 5220D.1997
1120
1.60
oD
u0/L
EPA 200.7
6.3
22
50
ug/L
EPA 200.7
3.2B J
2.1
10.0
ug/L
EPA 200.7
7.8
1.81
5.
mg/
EPA 1664A
1.0
1.0.00
PH
PH
SM 4500H+B-2000
Q
893
0
mg/L
SM 2540D-1997
3_8
10.0
ug/L
EPA 200.7
Analyte
....'.. . .........-
Cadmium Total
.... Results Fla 9
MDL
.,. '..
Chemical
Chemical Oxygen Demand
_
2.05
PQL
.......
0.360
Units
� -'
Method
�
Notes
Copper -Total
43
1.00
10
u0i,
� �
EPA2D07
-'
Iron -Total
65.1
10
1.60
mg/L
SM 0
FINAL
436
10.0
ug/L
EPAPA 2200.7.7
This "'Pnn relates only to the Sample+' receivud by the lalui
al22 SD
ory,
EPA 200.7
and may only be reproduced
in full.
1.
POBo 5 0130

Ij
Analyte
-
Lead .. - .
Lead - Total ........ . ....
Results
............ ... ....
Fla fl
.....
MDL
PQL
Units
Method
es
PH
7.1
3
2.1
10.D
...... .......
ug/L
...Notof
EPA 200.7
Total Suspended Solids8.0
1.0
1.0
PH
SM 4500H+B-2000
Q
Zinc - Total
3 2
1.0
1.0
m9/L
SM 2540D-1997
18
3.8
10.0
u9/L
EPA 200.7
Client .Outiall 006
ID - '�
A lyt
¢Lab
C305031
O6
tti fiY"t 9r g
i
Results
Hag
MDL
t � k F
Cadmium - Total .. ....
....... ...-...-..
..
.. . pQL
Units
Method
Notes
Chemical l Oxygen Demand
1.60
ug/L
..0. .......
EPA 200.7
........
Copper - Total
200
10
ID
mg/L
SM 5220D-1997
Iron - Total
93
1.60
10.0
ug/L
EPA 200.7
Lead - Total
39800
22
50
ug/L
EPA 200.7
Oil & Grease (HEM-SCTr) Non -Polar Material
571
2.1
10.0
ug/L
EPA 2D0.7
PH
8.74
2.15
6.72
m9/L
EPA 1664A
Total Suspended Solids
8.2
1.0
1.0
PH
SM 4500H+B-2000
Q
Zinc - Total
680
680
1.0
1.0
mg/L
SM 2540D-1997
3.8
10.0
ug/L
EPA 200.7
FINAL This report lel.tu, only to the sample as receivac by Ire ladorato and may Y only tat reproduced in lull. Fapo 6 of a0

ANALYTICAL RESULTS
Description: Outfall 001 Lab Sample ID: C305031-01
- Received: 06/07/13 16:26
Matrix: Surface Water Sampled: 06/07/13 14:45
Project: Raleigh Metal Recycling Storm Water Work Order: C305031
Sampled By; CLIENT
Metals by EPA 200 Series Methods
^ - ENCO Cary certifiedana/yfe(NC 591]
Analyte rCAS Numb,,I ResYlC4 F[aq Unru PE MDL MRRL Balch
cadmium [744043-9] ^ 3.03 Methotl Analwe -BY25
copper [)440-50.8]RO1
U9/L 1 0.360 l.W 3F10p16 EPA 200.7 D6/12/1312:22 JDH
^ 269 ug/L 1 1.60 1D.0 3FLOO16 EPA 2DOJ IronO6/12/1312:22 3DH 1)439-89-6]^ 17800 Ug/L 1 22 so 3F10016 EPA 2DO.7 06/12/1312:22 3DH
Lead [7439-92-11 ^ 147 ug/L 1
2.1 10.0 3F1o016 EPA 200.) 06/12/1312:22 3DH
Zinc [)440-66-61 " 948 u9/L 1 3.8 10.0 3F10016 EPA 2DO.7 06/1211312:22 Jon
FINAL This report rdalm unly to the sample as recaved by the IaOoralory, and mdy only M rnprMnttd In full.
Pnyn) of 30

r
Description: Outfall 001 www.encolabs.com
Lab Sample ID: C305031-01
Matrix: Surface Water Received: 06/07/13 16:26
Project: Raleigh Metal Recycling Storm Water Sampled: 06/07/13 1q:g5
Sampled By: CLIENT Work Order: C305031
Classical ChemistryParameters
_................- - - - -
ENCU -. - _. _............._._.
^ . �ry rediliedawtyre (NC 591J - . -
............... ........... ........... ....
Anallo- [ CAS NumbNumberl -
Chemialo Results �R nits DF MDL MRL
^ rygen oemana [ECL-0035] 130
mOh 1 10 10 Itch Mna -By Note,
PH [Ett-0062] ^ 3F12022 SM 5R01>106199) 06/ll/ll D:56
7.5 lapN 1
Total Suspended Solias [ECL-0169]^ 990 1.0 1.0 3FIM21 SM
06/10/13 14:29 Cly Q
m9/L 1 1.0 LD 9500Ha&2000
3F11009 SM 25oc,1992 05/11/1310:10
CV
FINAL
This reppn relates only to me lamplc m fe d'W by me OWratry, anp may only he regotlu[e0 in run.
FaOe 8 of 30

' w .encolabs.com
Received: 06/07/ 13 16:76
Work Order: C305031
Classical Chemistry Parameters
Analvte 1 A N b l
Oil & Grease (HEM-&GT) Non -Polar
Material
Description: Outfa II 001
Matrix: Surface Water
Project: Raleigh Metal Recycling Storm Water
Lab Sample ID: C305031-01
Sampled: 06/07/ 13 14:45
Sampled By CLIENT
R8.10 esults 19 Units m9/L UE MDL MRL Batch Meth
od
2.49 7.79 3F12018 EPA 1664A
Ana_lwed 1Y Natu
06/14/13 09:44 MlF
FINAL
IDis,port relates only to the eamnlr as rxeivM 6y Ne klvrmory and may only pe reFnWUC 0 in full.
Page 9 0f 30

Description: Outfall 002 w .encolabs.com
Lab Sample ID: C305031-02
Matrix: Surface Water Received: 06/07/13 16:26
Sampled: 06/07/13 15:00 Work Order: C305031
Project: Raleigh Metal Recycling Storm Water
Sampled BY: CLIENT
Metals by EPA 200 Series Methods
.............
E_._..........._..__.._......._._._......_.... _....... _.. ......
^ - NCO (try certifiedana/yfe(NC 591J
.. .. ........ .........
AnalYte fCAS Numberl
Cadmium [2H0-43-9] ^
Result FJa_9
0.693
Units
DF
MDL
MR1,
Batch
Method
Analyzed
Copper [2H0-50.81 ^
]
u9/L
1
IAO
3FIM16
EPA 200.7
_13
6610
u9/L
t
L60
LAO
06/12/13 12:25
12:
]d1
Iron [7039-89-6] ^
3010
Iso
3FJW16
EPA 200J
06/12/1312:25
JEH
Leaa[743"2-1]^
765
u9/L
1
50
3FI0016
EPA 200.7
06112/1312:25
Jw
Zinc [7H0-fib-6] n
293
u9/L
1
.1
10.0
3FIN16
EPA 200.7
JDH
u9/L
1
3.1
3.a
30.0
3F10016
EPA 200.7
06112/1312:25
06/12/138:25
]py
FINAL Thla repnn relates only tp th, sample ea ia,,al 0y me NOcratpry, and may only ba reprnr0irrq in NII.
Poge lu o130

ly.......�........��.�`r. "eJ
Description: Outtall 002
wwW.encolabs.com
Lab Sample ID: C305031-02
Matrix: Surface Water
Received: O6/07/13 16:26
Project: Raleigh Metal Recycling Storm Water
Sampled: 06/07/13 15:00
Work Order: C305031
Sampled By: CLIENT
Classical Chemistry Parameters
^ - ENCO Carycerr/{/eyarolyre [NC 591]
. ........ .. .....
A naIK [CASNumberl Result, Had
Chemical Oxygen Demand [ECL-0035]
Units
DI. I—I'D—S FRS Batch
Method
Anal
.. 52
m9/L
1 10 10 3F17022
SM 5220c-1997
Notes
06/17/13 17:56 30C
PH [ECL-00631 ^ 7.7
Topl suspended holies [ECL-0169] ^ 53
pM
1 1.0 1.0 3F10021
SM
4S00.Ya&2000
06/10/13 14:24 C1V Q
m0A
1 L0 1.0 3F110U9
SM 254UD-1997
06/11/13 10:10 N
FINAL This report rdau, only to fl,e sample es r..W by the laborat ory, and mdY only M raprMoree In full. page 11 0l aU

Description: Outfall 002
Lab Sample ID: C305031-02 d: 06 07/13 -com
Matrix; Surface Water Received: 06/07/13 16:26
Project: Raleigh Metal Recycling Storm Water Sampled: 06/07/13 15:00
Work Order: C305031
Sampled By; CLIENT
Classical Chemistry parameters
An IK I M mb 1
Oil a Grease (HEM-SGr) Nan -Polar
Material [ECL-01041
Results Flag Units DF MDL MRL BatCb Method
ethod
1 1.92 6.01
3F12018 EPA 1664A
Ana_ lyg By NSF
06/11/13111:, M]F
FINAL
3M5 report F6auc onlv In ffi✓ sample a: rttelvdl by Ine laoorau,, and may only b reproduced in full.
Page 12 of 30

Description:
Outfa II 003
Matrix: Surface Water
Lab Sample ID: C305031-03
16�.encolabs.com
Project; Raleigh Metal Recycling
Sampled: 06/07 /13
14:15
Received: 06/07/13 16:26
Storm Wa[er
Sampled By: CLIENT
Work Order: C305031
Metals by EPA 200 Series
Methods
^-ENCO CaY (NC 59lJ ....
Fmtified anaNre
..... .. ...............
......... .
AnaA� 1CA5 Nlmbl
... .......... .........
Caamlum [)ga013-91 ^
Results ag
nits
DF MOL
Met.
c^ooe. [)a40.50.9J ^
c' [7
1.99
uyL
MRL
1
Batch
Method
An I M
��-
iron - 9-6 1 ^
62'7
ug/L
2.00
1 1.60
3FIM16
EPA 200J
BY Notes
06/12113 12:34
Lead [7439-92-1) ^
1"D
ug/L
10.0
1 22
3F10016
EPA 200J
IDH
06/12/13 12:39
Zinc I)+90-fib-6 1 ^
16.1
ug/L
60
1
3FI0016
EPA 2DD.7
]OH
O6/II/1312:34
691
ug/L
.1 l0A
I 3.8 10.0
3F10016
EPA 2pOJ
3DH
O6/12 13 12:39
/
3F10016
EPA 2DDJ
IDH
06/II/13 12:34 IDH
FINAL
This report related only t0 the semolg as rpreivad by the tllW'1tory, and may only De reproduced in lull.
Page 13 of 30

Description: Outfall 003
WMM-encolabs.com
Lab Sample ID: C305031-03
Matrix: Surface Water
Received: 06/07/13 16:26
Project: Raleigh Metal Recycling Storm Water
Sampled: 13 14:15
Work Order: C305031
Sampled By: C
CLIEN
LIEN T
Classical Chemistry Parameters
^ - fNCO Gry cedifiedawly/e (NC 59fJ
A IMA !�,rl ResultsF�
units OF
Chemical Oxygen Demand [ECL-00351
MDI, MRL Batch
Method d 0 _
pM [ECL-0063] ^
mgn' 1 ID 30 3Fll011
5M 92106199J
-nnn�-lyze� 61' Nate
06/17/13 17:56 30C
� 6
Total Spspentled Solitls [ECL-0169 ] ^
PH 1 1.0 1.0 3F10011
5M
06/10/1319:14 �1y Q
13
fpg/L 1 1.0 1.0 3F110p9
a500H1
5M 1540&pD1997997
06/11/13
10:10 CV
FINAL This romp rWates only to the sample ae ImOved by On laboratory, and may only M r✓produc9d in full.
Pape 14 o130

Description: Outfa II 003
Lab Sample ID: C305031-03 �w.encolabs.com
Matrix: Surface Water Received: 06/07/1316:26
Project: Raleigh Metal Recycling Storm Water Sampled: 06/07/13 14:15
Sam led e Work Order: C305031
Classical Chemistry parameters P y. CLIENT
Analvre frill N Berl
Oil B Grease (HEM-SGn Non -Polar
Material [E4-0100]
Result, Bag units DF MDL MRL Batch Method
M90. 1 2.11 6.56 3FI2018 EPA 1664A
Ana_yld BY Notes
06/14/130a:44 MY
FINAL
T AS report relates only in the sample a feceil J W Me lapnee , and may only ,reproduced in lull.
Pogo 15 o130

Description: Outfall 004
Matrix: Surface Water Lab Sample ID: C305031-04 11w'encolabs.com
Project: Raleigh Metal 'RI
ecyding Storm Wa[er Received: 06/07/13 16:26
Sampled: 06/07/13 I9:15
Sampled B Wark Order: C305031
Metals by EPA 200 Series Methods Y: CLIEFIT
A - ENCO Ca
tl'�etr6edana/y(e INC
59IJ -
.............
nal�_FCAS Numberl ...... . ............ .
Catlmium [)ggpy3-91 ^ Result, Bag Un_irs -
C9pper [7"0-50-B] • 2.32 u9/L OF MDL MRL Batch Me
Iron od
[)439-89-6] ^ 32.9 u9/L I 0.360 1.00 3FI0016 EPA 00) Ana[vZ d S—
I 92- 1120 22 1p,0 3F10016 06/B/13 B:3) 10H
Leatl )939- 11 ^ u0/L 1 EPA 200.) 06/12113 12:3I Zinc [)440.66-6] ^ 6'3 J 22 Sp 3F10016 EPA 200.7 JDH
943 u9/L 1 2.1 10.0 06/12/1312:3)
3F10016 Jp1
ug/L 1 3.8 MCI EPA 2pp,) 0611211312:37 Jay
3F10016 EPA 200.7
06/12/1312:37 JDH
FINAL
r% rewq tdJ trS chly t, [he 5anlple d5 tetelvetl by the abOlalety, dntl r ay Only be lep,M...
d In rnli.
Page 16 of 30

Description: Outfa11004
Matrix: Surface Water
Lab Sample ID: C305031-04
'" .encolabs.com
project: Raleigh Metal Reryding Storm Water
Sampled: O6/07/13 1 4;15
Received: 06/07/13 16:26
Classical Chemistry parameters
Sampled By: CLIENT
W ork Order: C305031
^ -ENCO !aryce?i/&dana .N.........
A"alVIA ICAS N
—mob 1
...............
^hemiwl Ozy9en Demand [EC1-00351 Result, F[_ag
Units DF MDL
pM [ECL.0062]+ 100
mg/L 1 30 MOL Batch
3F17022
Method
SM
Anal
PA N
7.e
Torol Suspended Solids[Ea-01691•
1
ON 1.0
5220619W
06/17/—�g6 a
26
I.0 3F10021
S^1
06/10/1314.24
m90. 1 1.0 1.045Wrya&2000
3F11009
SM 25 oo-1997
CiV Q
06/11/13 10:10 CV
FINAL
This Iepon Idw, oily y the ssoiple aS reccyved by the Wp IatM, and may only by reooduced in fuff
Pege 17 o130

Description: Outfa II 004
Matrix: Surface Water Lab Sample ID: C305031-04 "FAr .encolabs.com
Project; Raleigh Metal Recycling Storm Water Received: 06/07/13 16:26
Sampled: 06/07/13 14:15
Work Ord
Sampled By; CLIENT er• C305031
Classical Chemistry parameters
Analyte fCA_ g_-6 rl .
oil & Grease (HEM-5GT) Hon Polar
Material [EC1--03UGI
Re ul Flag mUnits DF MDL MRL B, ch3.28 Method
9A 1.61 e
5.66 3F12018 EPA 1664A
Ana�ed B
uy Nolte
06/14/1300:44 MY
FINAL
This report relates mly la tnc MMPle ds receive] by are and "Y only he reprwp ec in lull.
Page 19 0130

Description: Outfa II 005
Matrix: Surface Water
Project: Raleigh Metal Recycling Storm Water
Lab Sample ID: C305031-05
Sampled: 06/07/13 13:45
Sampled By: CLIENT
WW Nencolabs.com
Received: 06/07/13 16:26
Work order: C305031
- - _-- -. -• -• -�� ��r m5 mecnods
^ - ENCO Cary redirkd 8Wryre (NC 5911 .....
. . . . . ....... .
Arlalyte FCAS Number]
Cadmium [7440-43-9] ^
R su is FI
SJ_ �9
Uni
DF
NUI
NR�I
Batch
Copper I7440-50-e] ^
2.05
1
0.360
1.00
Method
An z
Notes
lme [7439-89-6] ^
65.1
p9/L
1
1.60
10.0
3F10016
EPA 200.7
06/12/1 g.39
3DN
Lead [7439-92-1] ^
436
A/L
1
22
50
3FI0016
EPA 200,7
06/12/1312:39
1P4
Zinc [7"0-66-6] ^
7.1 3
u9/L
1
2A
10.0
3F10016
EPA 20pJ
06112/13 12:39
Jon
189
u9/1
1
3FIN16
EPA 200.]
06/12/13 12:39
3DM
3.6
1D.0
3F10016
EPA 2pOJ
06/12/13
8:39
]pry
FINAL Thic report relate; only W the -niple 35 rOOOyed b the la Y bpratnry, anq may only be rcprodueN iu roll.
Pa90 19 of 30

Description:
Ou[fall 005
Matrix: Surface Water
Lab Sample ID: C305031-05
yyvr ✓-encolabs.c°m
Project; Raleigh Metal Recycling
Sampled: 06/07/ 13 13: q 5
Received: 06/07/13 16:26
Storm Water
Sampled 6 Y: CLIENT
Work Order: C305031
Classical a
Chemistry Parmeters
......................................
^-61VW Cary mrtil�yanayte (NC 59t/ .......
-
AmalYte I[A N
--""'
Chemical oxygen Derv, IECL-0036 Result' Flag
]
ni DF MDL M3L
<3
pH IECL-0062]+
Batch
m9/L 1 10 10 3F12020
thod
SM MSg0 9J
Ana> fyi� MY Notes
1
06/12/13 16:23 Xc
Tobl6uspentled 6glitls IECL-0169] +
1'0 1.0 3F10021
yt
3.2
mg/L 1 1.0 1.0
15004'a-20M
06/10/1314.21 C1V Q
3F11009
SM 2590P1992
06/11/13 10:10 CV
FINAL
I his report no," m1Y [g me ampe of r"C w by the WOmatow. end maY only 6e relxwuceo in Full.
Po9e 20 of 30

Description: Ou[fall 005
Matrix: Surface Water Lab Sample ID: C305031-05
Sampled: 06/07/13 13: q5
Project: Raleigh Metal Recycling Storm Water
Sa I
W`A"vencolabs.com
Received: 06/07/13 16:26
Work Order: C305031
Classical Chemistry Parameters PIP ed By: CLIENT
Analvt !` r��
OY & Grease (HEM-SGT) Non -Polar Malenal
[ECL-01M]
Result,
Units
2.03- MMDL MRL Bat b Method
m9/L I2.03 6.35 ��
3FBDIa EPA 1669A
Analn,d @Y Not,,
06/14/13 D9:44 M3F
FINAL.
This lelgn "`ItQ d'1y [O the Llmltle a6 feCCivGI by nle dbdUPP11, and mdy only bQ IQOIptl�Cetl In full.
Page 21 of 30

Description: 011tfall 006
W Ww.encolabs.com
Lab Sample ID: C305031-06
Matrix: Surface Water
Received: 06/07/13 16:26
Project: Raleigh Metal Recycling Storm Water
Sampled: 06/07/13 14:35
Work Order: C305031
Sampled By: CLIENT
Metals by EPA 200 Series Methods
^ - ENCO Cary re?ified ana/y(e (NC 5911
A alyte fCAS Number]
Reesu_IL FLaq
Units
DF MD MRL
Cadmium [7440-43-9] A
S.9fi
_5
Method
A I 8 No
copper [7440-50-8] ^
93=
u9/L
1 0.360 1.00 3FI0016
FI 01
EPA 200.7
—�
06/12/13 12:42
Iron [7439.89.61 A
39800
1.60 nex 3F10016
EPA 200.7
JpH
06/12/13 12:12 Jd1
Lead [)d39-92-1]^
9-92-]
511
71
09/L
1 22 50 3FIN16
EPA 200.7
06/12/1312:42
Lint [(74
^
i
ug/L
1 2.1 10.0 3FI0016
EPA 200.7
JnH
06/12/13 12:42
og/L
1 3.8 10.0 3FI0016
EPA 20D.7
JOH
O6/12/13 II:42 JDN
FINAL This rcmq n6aWb unly to the sample as received bV the abpratery, and may only be reproduced in lull.
Page 22 of 30

Description: Outfall 006
Matrix: Surface Water
Project; Raleigh Metal Recycling Storm Water
Lab Sample ID: C305031-06
Sampled: 06/07/13 14:35
Sampled By: CLIENT
wwtv.encolabs.com
Received: 06/07/ 13 16:26
Work Order: C305031
... ..... _.._._. - _......«c,a
^ - ENCO bry cad/fiedanaly(e /NC 59y
Analyte IrAS Nlmb,l
Chemical Pgpen Demand IECL-00351
Results2_9
unitsOF
MDL MR Batch
PH [ECL-0062] ^
m9/L
_S
1 10 10 3F12020
Method
5M 52 6g9)
A —nalnd Y NotCf
9.2
1
06/12/13 16:23 3DC
Total 15uspended Solids [ECL-0169]^
660
1.0 1'0 3FI0021
5M
06/10/1319:24
mg4
0 1.0 3F110m
9600H+e-2000
C1V Q
SM 259pP1997
06/11/1310y0 cy
FINAL
This rePon relate, only 1P the Sample as FMMW by pie Wboratwy, and may only be raooduced in full.
Page 23 of 30

Description: Outfall 006 �®
Lab Sample ID: C305031-06 �1vvr•encolabs.com
Matrix: Surface Water Received: 06/07/13 16:26
Project: Raleigh Metal Recycling Storm Water Sampled led BY: : CLIENT O6/07/13 1q:35
Work Order: C305031
Classical Chemistry Parameters
....................................
AnalVt f AS N b l
Oil & Grease (HEM-IGT) Non -Polar
Material (EQ-01041
Results.m9/L Units DF MOIL MRL Bpsb Method
t 2.15 6.72 3F12018
EPA t66aA
Anahozed BY Not
06/11/13 W,;A FUF
FINAL
This teri wlate5 only to the >eIrryle a5 received b, the laboratory, and may only ber,producedinfull.
Page 24 of 30

Meals by EPA 200 Series
Batch 3FIO016 - EPA 3OO5A
Blank (3FLDD36-BLKI)
LC
• Y•`,r,l j f i....,., �O, :.a.°J
QUALITY CONTROL
Prepared: 06/10/2013 09:57 Analyzed: 06/12/2013 12:02
Caemium
"c'-`5aS\ m :.. F,?a LeveJ ^s,�i.J ResulLp--,, NREC.,. 1 i _F-
Li mits'(e
a360 :e':RPD z.yl.(.Limi[} t41 `F.
Copper
Iron
,No[e3
1.60 U 10.0 Ug/L
Lea!
2 U 50 ogA
Zinc
2.1 U 10.0 ug/L
3.8 U 10.0 o9A
LCS (31`10016-11SI)
... ..........
eta '.-is1 0130957 Analyzed 06/12/201312:05a Rd
Anals 1e J na ?
r .�,.
c Y Results "Flag /MRL / � U t 't SP,_ So � y hIV / REC 1 IRPD
Catl
z04 t 00 Level )
R ult /REC LI t dyRV
�gPpe
9/L 20.0 102 85-115
01
Iron
0.0 u9A 200 101 65-115
977
Led0
50 u9/L I000 98 BS116
02
zinc
10.0 uga zoo 101
207 BSlls
10.0 ug/L zoo
Matrix Spike (3F10016-MS1)
Source: C211747-01
Prepared: 06/10/2013 09:57 Analyzed: 06/12/2013 12:11
Analy[e1 rp,r�,ttF4 li yr t S.i � 4 1! , t......9S
rr.141 ly
',Result k y �45 y� (�0 P ket t ,, Sources( c'Y' t t s;,i hREC ° -
Calmrum,.Level
., t. Result, ':'�' tI �S tia: RPDxi§`�S,
23.9 u94 20.0 aNa REC;;�Llmlts ,,,,L`! RPD, _r Limit i' S Notes
1.00
3.6] -
319 99 70130
Imn
10.0 u9e1 200 22.2 99
6600 70-130
Lead
50 ug/L I000 SNO 76 70-130
13
Zinc
10.0
1490 °g/L 200 10.6 101 70-130
..
10.0 ug/L 200 1330 89 70-13D
Matrix Spike Dup (3F10036-MSD1)
......
Source: C211747-01
Prepared: 06/10/2013 09:57 Analyzed: 06/12/2013 12:13
� r
Spike ark„ry Source
Analyteu�^6k�Result ry.. i? S rs�7M )6 1F' - *+a -r
a.rn'I ..ikr t eery r ,tyr
Calm �" Flay +.:MRL1 qx',.)-Units (Result,";` o nl / RECk 1 3ty i RPD`,r,,*, r r rj
um
,yLevelib wr/oREC.,n i{tj Limits Y.,ORPD y, Limltt;;
23.8 100 Notes
Copper
Ug/l 20.0 k'.+.r e_..:..
229 3.67 101 70�130 2 30
Iron
ug/L 200 22.2
6120 10.0 IN 70-130 4 30
Lead
213 50 ug/L I" 5090 IN 70-130 5 30
Zinc
10.0
IS50 u9/L 20p 10.6 101 ]0.130 0.1 30
t0.0 ug/L 200 1330
30
............................................................
Post Spike (3F10016-PSI)
...... . ... -- ...................
Source: C211747-01
Prepared: 06/10/2013 09:57 Analyzed: 06/12/2013 12:15
�.. I
„T
4r rt; •...3
r
GCYte,A
LVIdM 5 e
Result' Flag MRL v, kREC RPD 2
Result
W REC, LI k
0 @9 0 D01 RPD Ll t N t
C PC
9/L 0 0200 0.004 IDI 80.B0
0.23
Iron
01
0.m9/L 0.200 0.02 103 80-120
6
Lead
0.05 mg/L LW 5 90 86120
0.2
Zinc
0.01 m9/L 0.200 0.01 1W 80-120
1.5
0.01 mg/L 0.200
Batch 3FIOO21 - NO PREP
LCS (3F10D21-BSl)
Prepared & Analyzed: 06/10/2013 11:23
FINAL This report nste, only to the..enrple as receive! by the laborat IXy, And may only pe repmducc! In lull. Page 25 0130

Classical Chemistry parameters -
Batch 3F10021 - NO PREP
LCS (3F30021-BSI) Continued
QUALITY CONTROL
Prepared & Analyzed: 06/10/2013 11:23
1 nro J""9,
_-._._.,,,.,,av .mnL'aal._`+.Umtr'ei'-, Leveh ,_.._• .+.,er -e.a RPu
PH J0 Ei .d.: Result a -_%REC: rUmrtr �y�u_RPD .. n „�"
LO PH ]Ol Im 99-101-sLimi[ �i-Notesp,_,�
Duplicate (31`10021-DUPI)
Source: C304753-01 Prepared & Analyzed: 06/10/2013 14:24
Batch 3F11009 - NO PREP
Blank (3F11009-BLK1)
Prepared & Analyzed 06/11/2013 10:10
Tpblunl[s"•i.(
omen SPlitls
VUeve1 *,,'a'.Re p, ,, RFC,,.k ,t Limltr ry; RPD w uT" 1
-sult '�'- y °"Limltdt`Notes'rrl.
U
t.0 mg/L
LCS (3F13009-BS1)
Prepared & Analyzed 06/11/2013 10:10
m
Analyte y ^�imy
r, 2
�' a4 r a
"Spike 0' Source ij r
°-
T ta15 ceeee Sole
9 t MRL U ts'�
/REC
L e11 Res It /REC L
P- F
PRPD tUmitr
90
0 9/L
is
100
N
..............................................................
90 60.1]0
Duplicate (3F13009-DUPI)
...............................
...... ... ..
..
Source: C211747-01
Prepared & Analyzed: 06/11/2013 10:10
.. _.._..__._...._._. a 10
(3F11009-DUP2)
......................................................................................... .................
Duplicate
SOUR¢: C211747-02 Prepared & Analyzed: 06/11/2013 10:10
Batch 3F11010 -Same
Blank(3F12020-BLKl)
Prepared: 06/12/2013 12:06 Analyzed: 06/12/2013 16:23
Cheml-1 Oavgen O mane - .�I"'^ l'¢evel VI f Result ryVS %RECp t'...`
10 U 10 mg/l ..Limits l .;,RPI).. ,„� ❑mrt1 ,, Notesk�i°
LCS (3F12020-BS1) ..
1 Prepared 06/12/2013 12:06 Analyzed: 06/12/2013 16:23
a..':i.._s:. .. ° M,g ;a' ,..'.,.:r *u .a...a,.., y ,R. e:. .....t .,.,. ,I
...<.> _in.. o���u ., wq .Level "_}`' .Result=.^ill 2. Chemical Oggen oemane 520 10 /REC .,y; Liinitr RPD xnt LImR .jy Notes'4'
m9/L 500 90.110
Maui: Spike (3F12020-MS1)
Source: C305031-05 Prepared: 06/12/2013 12:06 Analyaed: 06/12/2013 15:23
CM1emical Orygm
.: e's. Result �,�Fla9al .v ..MRL Units'.
Y
Level nt w l /REC l
Result ':,?/
I.zr RPD °% 7• {, .
�s �a
Demane
550 10
,:
.u„'�tx REC a iaLlmitr K ..
RPD° iY r Q
'i' 4mlt I NotesIx
mB/L
S00 43 02 90.110
•. •
FINAL
ThIs rPPort relates _ly W Ili¢ Sample as recerval6r
me W6ara1 nry, are may only 4
reproeucee'n full.
POBe 26 of 30

QUALITY CONTROL
Batch 3F12020 - Same
® 211-
=-
r
Matrix Spike Dup (3F12020-MSD3)
Source: C305031-05 Prepared: 06/12/2013 12:06 Analyzed: 06/12/2DI3 16:23
Geml[al Orygeo Oemand 550 10 mg/L S00 43 DREG Limits RPD gLlmit Notes
101 90.110 0.0 10
Batch 3F17072 -Same
Blank (3F37022-BLKi)
Prepared: 06/17/2013 14:21 Analyzed: 06/17/2013 17:56
__-„r..,o ,.�arxren.eve: ffi4�ResulL %'RECr`t _ .•• k Chemlral Orygen Demand t0 U mg/L aLimits RPD, , Lfin(t 'Notes
LCS(3F17022-BS1)
Prepared: 06/17/2013 14:21 Analyzed: 06/17/2013 17:56
..--�+-��=.0rtevainesm[La1kL%REC^ limits _ --""'
emieal Orygen Demand 520 10 m9/L 500 RBU Limit Notes,:
106 95110
Matrix Spike (3F17022 -MS 1) Source: C305703-02
Prepared: 06/17/2013 14:21 Analyzed: 06/17/2013 17:56
Chemical Oxygen Demand 560 " "eJava®I!nesurz,L, v/o REC LimitrRPD Limi`9allotes �!..
m9/L 500 96 109 90.1ID
Matrix Spike Dup (3FD022-MSD1) � � � � ' ' "' - "' ' ' ' ' ' ' Source: C305703-02 -
Prepared: 06/17/2013 14:21 Analyzed: 06/17/2013 17:56
Ge iral Orygen 4mand 560 10 mg4 SW 46 Omifs RPD_, Limit Notes
109 90.110 0 10
QUALITY CONTROL
Classical Chemistry parameters - Quality Control
Batch 3FI2018 - EPA 1664A
Blank (3F12018-BLKi) Prepared: 06/13/2013 11:00 Analyzed: 06/14/2013 09:33
.... 0f ,. '_. :`!?.'•tlKcm.lro r..w+�ivo-rrcew.�::�...._.�..—_._..
Oil a Grease(HEM-SGT) Non -Polar --- ---- "" •r''nesm[ %RECijmits`31RPD limit Notes ram„(
Material 1.60 U 5.00 mg/L
LCS (31F12018-851)
.mLuaeevmm �_wa _-._ Prepared: 06/13/2013 11:00 Analyzed: 06/14/2013 09:33
Ojl &Grease (HEM-SGi) NoroPolar Material
:w&iR En:Reaun;;{jNyj,YalteC "Limits. RV0 limit N es 30.1 5.00 mg/L 20.3
.............. 99 64132
Matrix Spike (3F12018-M53)
Source: B30254402 Prepared: 06/13/2013 11:00 Analyzed: 06/14/2013 09:33
1.60U -,- {1tg;36+132 RPD :;Llmi[ air:"
Oil &Grease (HEM-SGT) Non-Pdar Material 19.6 600 mg/L 20.4 L60 U a96 6413]
.......... ..........
Matrix Spike Dup (3F12018-MSD1) Prepared: 06/13/2013 11:00 Analyzed: 06/14/2013 09:33
FINAL This report relates only b the sample as rectived 6/ Me laboratory, and may only M roproduecd in full. Page [I pt 30

. _ a
O)UALrrY CONTROL
Batch 3FI2018- EPA 1664A
Matrix Spike Dup (3F12018-MSDI) Continued Source: 0302544-02 Prepared: 06/13/2013 11:00 Analyzed; 06/14/2013 09:33
wr
a>
Analyte fr_n a��r�`S"?M ,�= m _ yResul-4rFla9k \rMRL,.,� .d+« Units �"�Ss��ke r Source s'�F"' n /REC ^'! 7 : �' S. RPD s I A t t -
01 &Grease (HEM sC� Nan Polar Meterlal 20 5 5.00 m L F a §Level!{s: ResNt > ?, / R E C E"3y�`Limllsijtl RPD xNOtes"`
9/ 20.5 1.60. t00 6 132 '1 34
FINAL This report relates mly W Na ample as mceivW by llm 1,1xi atory, ane may only be rexxjX,,, in fu".
Page 28 a130

i
www.encolabs.com
FLAGSINOTES AND DEFINITIONS
B The analyte was detected in the associated method blank.
D The sample was analyzed at dilution. _
I The reported value is between the laboratory method detection limit (MDL) and the laboratory method
reporting limit (MRL), adjusted for actual sample preparation data and moisture content, where applicable.
D The analyte was analyzed for but not detected to the level shown, adjusted for actual sample preparation
data and moisture content, where applicable.
E The concentration indicated for this analyte is an estimated value above the calibration range of the
instrument. This value is considered an estimate.
MRL Method Reporting Limit. The MRL is roughly equivalent to the practical quantitation limit (PQL) and is
based on the low point of the calibration curve, when applicable, sample preparation factor, dilution
factor, and, in the case of soil samples, moisture content.
2 Analysis performed outside of method - specified holding time.
FINAL IDis IaPalt Idatee only to me samole as rxry ,
M the labors[ ary, and may only4 reµ Wu«J In luLL Page 29 of 30

24Hour No46f , ion of Discharge Forme
For Mon -UST This form should be completed and submitted to the UST Section's regional office following a known or suspected release of
Relensae of petroleum from a source other than an underground storage tank This form is required to be submitted within 24 hours of
Petroleum In NC discovery of a known or suspected petroleum release
(DWM USE ONLY)
Suspected Contamination? (Y/N) Y
Release discovered
incident if Priority Rank (H,LL,U) _
Confirmed GW Contamination? (YIN) w
(tima/date):
Received (sms/date)
Confirmed Soil Contamination ?(YIN) r
841-2013 Rt 1200 hours
Received by Reglon
Samples taken?(Y/N) N Free product? (YIN) N
Reported by (circle one): Phone. Fax or Report
If Yes(free product), state greatest thickness: _feet
INCIDENT DESCRIPTION
Incident Name: Oil -Water MICH Discharge
Address (street numberhrama):;231 Gamer Road
County: Wake
ciryrtown: Raleigh
zip Code: 27610
R tonal Office (circle one): Asheville, Mooresville, Fayetteville,
le' ashin ton VVI]mlnc cn,Winston-Salem
Latitude (d mmi d.rr.N.): 35.749844 Longitude (d.dma dw ) :-78.632680
Obtained by:
0 GPS
Describe suspected or confirmed release (nature of release, time/date of release, quantity of release, amount of free
product):
O Electronic; topographic map
0 GIS Address matching
0 Other
Illicit discharge of oil and water. Discovered @ 1200 hours. Unknown quantity, Unknown prod. volume
Describe initial response/abatement (timalidate release stopped, cleanup begurdcomp/etod, quentay of product
soe removed confirmation sampling):
0 Unknown
Describe location:
Outlets plugged. Impacted water on ground surface recovered. Sorbent booms installed.
Describe impacted receptors:
Soil. No known surface waters Impacted. Stormiwater Inlets Impacted and water/oil recovered.
HOW RELEASE WAS DISCOVERED (Release code)
(Chock one)
0 Observation of Release at Occurrence 0 Water Supply Well Contamination
0 Visual or Olfactory Evidence ❑ Surface Water Contamination
0 Soli Contamination ❑ Other (specify)
❑ Groundwater Contamination
SOURCE OF CONTAMINATION
Source of Release Cause of Release Type of Release Product Type Released
(Check one Indicate primary (Check one to Indicate prmary (Check one) (Check one to Indicate primary petroleum product
type released)
0 AST (tank) 0 Spill (Accidental) 0 Petroleum 0 Gasoline/ Dleselt ❑ DlsseWeg. Oil
0 AST Pipagl Dispenser ❑ Spill (Intentional) 0 Both Petroleum Kerosene Blend
0 AST Delivery Problem 0 Corrosion & Non -Petroleum 0 El I - E20 ❑ Vegetable Oil 100%
0 OTR Vehicle Tank ❑ Physical or Mechanical ❑ E21 - E94 0 Heating Oil
0 OTR Bulk Transport Tank Damage Locatlon ❑ E85-E99 ❑ waste oil
0 RR Bulk Transport Tank 0 Equipment Failure (Check one) ❑ Ethanol 100% ❑ Mineral Oil -no
0 Traraknner 0 AST Overfill I] Facility PCSS
❑
'0 Unknown 0 AST Installation Problem Mineral OlI-PCBs
0 Residence
❑ Unknown
0 Other 0 Highway/Road +❑ Other Petroleum
0Other w.Maaan.�.... Products �w
0 Railway .
Definitions presented on revsrss DegMUons presented on reverse
0 Other
Ownership
1. Municipal 2. Military 3. Unknown 4. Private 5. Federal 6. County 7. State
Operation Tvpe
1. Public Service 2. Agrlcukurel 3. Residential 4. EducationR2elg. 5. Industrial 4cCommerda 7. Mining
Guidance presented on reverse
UST Form 62 (5rn u) Page t of 2

IMPACT ON DRINKING WATER SUPPLIES
Water Supply Wells Affected? 1. Yes 2. No . Unknown Number of Water Supply Wells Affected
Ust of Water Supply Wells Contaminated: (Include Users Names, Addresses and Phorre Numbers. Attach addlllonal sheet If necessary)
1.
2.
3.
PARTY RESPONSIBLE FOR RELEASE
('tithe source of the release is not an AST system or ff It Is an AST system and there is a responsible party other Man fire AST sysfam owneN operator)
Name of PersonlCompeny
Address
Raleigh Metals Re clin
2310 Gamer Road
C
State
Zip Code
Telephone Number
Raleigh
NC
27610
919-828-5426
AST SYSTEM OWNER (if the source of Me release is an AST system)
AST Owner/Company
Address
na
City
Sfafe
Zip Code
Telephone Number
AST SYSTEM OPERATOR (if the source of the release is an AST system)
UST Operator/Company
-Address
na
city
State
Zip Code
Telephone Number
LANDOWNER AT LOCATION OF INCIDENT
Landowner
Address —
Seymour Brown Investment Co., Inc.
P.O. Box 10809
City
Goldsboro
State
NC
23 Code
27532-0609
Telephone Number
To Be Determined
Draw Sketch of Area or Provide Map (showing incident site, iocatlon of release, two mq)orroad Intersections, potential
receptors)
Attach sketch a map to form.
Give Directions to Incident Site Attach directions to form ffnecessary.
See Attached
Person Reporting InctdwtjOe Be Co ny Highlands Environmental Solutions, Inc.
Telephone Numbergl9-848-3155
Title principal Geologist dress 8410-0 Falls of Neuse Road: Raleigh, NC 27615
Date 8-21-2013
UST Form 62 (uvr iu) Page 2 of 2
Definition, of Sourm
AST (Tank): means the tank is used to store product
AST Piping: means the piping and connectors running from the tank to the dispenser or other end -use equipment
AST Dispenser. inchades the dispenser and the equipment used to connect the dispense to the piping
AST Delivery Problem: identifies releases that occurred during product delivery to the mak.
OTR Vehicle Tank: means the tank is used to store product to fuel an over the road vehicle
OTR Bulk Transport Tank: means a tank that is used m transport product in bulk over the road (by truck)
RR :bulk Transport Tank: mesas a tank that is used to transport product in bulk by train
Tmnsformcr. means electrical transformer
Other: serves as the option to use when the release source is known but does not fit into one of the preceding categories
Unknown: identifies releases for which the source has not been determined
De6nldons of Cause
Spill (Accidental): use this raise when a spill occurs accidentally(e.g., when the delivery host is disconnected from a fill pipe)
Spill (Intentional): use this cause when a spill occurs intentionally (e.g., intentional dumping or breakage)
Corrosion; use when a metal tank, piping or other component has a release due to corrosion
Physical or Mechanical Damage: use for all types ofphysical or ravehanical damage, except corrosion
Equipment failure: use when a release occurs due to equipment failure other data conosion or physical or mechanical damage
AST Overfill: use when an overfill occurs (e.g, overfills may occur from the fill pipe at the tank or when the nozzle fails to shut offer the dispenser)
AST Installation Problem: use when the problem is determined to have occurred specifically because the AST system was not installed properly
Other: use this option when the cause is known but does not fit into one of the preceding categories
Unknown: use when the cause has not been determined
Guidance: Ownership and Operator Type
Ownership select the category which d.-bes owner of the AST system, bulk transport tank, or other release source
Opcmtor Type select the category which desenbes the operation in which ow ea uses the AST system, bulk nanspon tank, or other release sours

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RALEIGH, NORTH CAROLINA
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Parnell, David
From: Bennett, Bradley
Sent: Monday, September 30, 2013 11:24 AM
To: Parnell, David; Pullinger, Robert C
Subject: FW: Old Garner Road Metal Recycling
Attachments: ATT00002.c; ATT00005.htm
FYI
Bradley Bennett
Stormwater Permitting Program Phone: [phone]
NC Division of Energy, Mineral and Land Resources Fax: [phone]
1617 Mail Service Center Email: bradlev.bennettcDncdenr.gov
Raleigh, NC 27699-1617 Web: httpalportal.ncdenr.org/web/Irlstormwater
Email correspondence to and from this address may be subject to public records laws
From: Senior, Mark [mailto:[e-mail]]
Sent: Monday, September 30, 2013 11:20 AM
To: Holley, John; Bennett, Bradley; Smith, Danny
Cc: Duffy, Peter; Rall, Todd; Boyer, Kevin
Subject: Old Garner Road Metal Recycling
Hey guys, thanks much for meeting with us last week. I think that was very worthwhile in terms of everyone better
understanding the different parties involved and their roles. City staff are discussing the issues we are having with this
site with our attorneys and could really use a copy of their signed permit (or permit application) if you have it. We could
also use any monitoring data associated with this site including any self monitoring data they may have supplied. Our
plan is to collect and analyze samples from the site and we will forward that data to you when we have it. Our Fire
Marshal is also looking into the site based on the kinds of material stored there. They are very concerned that this site
could be hazardous to their responders.
Thanks, Mark Sr.
Mark T. Senior, PE, Senior Project Engineer
Stormwater Utility Division
City of Raleigh Public Works Department
PO Box 590
Raleigh NC 27602
Work Phone [phone]
Fax [phone]
Email mark. seniorCcDraleiohnc.00v
www.raleighnc.00v

Name
Greg Brown
William Toole
Jay Butler
Dan Nielsen
Mark Senior
Pete Duffy
Todd Rall
Nicolette Fulton
Phil Orozco
Kim Caulk
John Walch
Chris Pullinger
Matt Auffman
Bradley Bennett
Danny Smith
David Parnell
Eric Green
Organization/Role
Raleigh Scrap Metal Recycling
Attorney for RSMR
Representative for SBIC (Owner)
Mid -Atlantic Associates (Engineer)
City of Raleigh (Stormwater)
City of Raleigh (Stormwater)
City of Raleigh (Stormwater)
City of Raleigh (Attorney)
NCDENR (Hazardous Waste)
NCDENR (REC Program)
NCDENR
NCDENR
NCDENR (REC Program)
NCDENR
NCDENR
NCDENR (Stormwater)
Wake County
E-mail
Rbrown@raleighscrapmeta Irecycli ng.com
[e-mail]
laybutler@pa rkerpoe.com
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
phil.orozco @ncden r.gov
[e-mail]
[e-mail]
[e-mail]
[e-mail]
brad ley. [e-mail]
[e-mail]
[e-mail]
[e-mail]

Telephone
[phone]
[phone]
[phone]
[phone]
[phone]
[phone]
[phone]
[phone]
[phone]
[phone]
[phone]
[phone]
[phone]
[phone]
[phone]
[phone]
[phone]

Fli
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Waste Management
Pat McCrory Dexter R. Matthews John E. Skvarla, III
Governor Director Secretary
October 4, 2013
Mr. Daniel Nielsen, P.E.
Mid -Atlantic Associates, Inc.
409 Rogers View Court
Raleigh, NC 27610
Re: Project Meeting and Proposed Containment Remedy Status
Raleigh Metal Processors
Raleigh, Wake County, NC
Site ID No.: NCD45615568
Dear Mr. Nielsen:
As you are aware, the Inactive Hazardous Sites Branch (Branch) held a meeting on September 26, 2013 to
discuss concems regarding surface water discharge issues at the Raleigh Metal Processors Site (Site).
The proposed containment remedy that is part of the long -.term cleanup for the historical soil contamination
was also discussed. Representatives of the City of Raleigh, Wake County, the United States
Environmental Protection Agency (USEPA), the Division of Water Resources (DWR), and the Division of
Energy, Minerals, and Land Resources (DEMLR) were present in addition to staff from the Division of
Waste Management.
Based on our meeting it is my understanding that in August 2013, DEMLR staff conducted inspections of
the surface water discharge practices at the facility, with DEMLR issuing a Notice of Deficiency on August
271 2013. On September 20, 2013, local, state, and federal representatives performed a follow-up
inspection at the facility, and the inspection results indicated surface water run-off continues to be a
concern. At the conclusion of our meeting, the representatives agreed that City of Raleigh staff will work
with the DWR/DEMLR to address any surface water discharge issues caused by current site operations.
We also discussed the proposed containment remedy for the long-term remedy and its effect on surface
water discharge issues from the current site operations. We explained that concurrence on the proposed
containment remedy is tentative pending additional review and public comment. The meeting resulted in
the following important issues associated with the proposed containment remedy that will need to be
addressed:
1) Concern was expressed over the durability and thickness of the proposed barrier. Several
representatives have conducted site inspections and are concerned that heavy machinery
operations will regularly damage the barrier. They also noted that the area on the southern portion
of the site that was covered with the barrier material in 2010 is not in a high traffic area (area with
significant active operations). Therefore, just as the Branch has expressed concerns regarding the
barrier thickness, many of the representatives are concerned about the long term durability of a
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone: [phone]Internet: ht1p://podal.ncdenr.orglweblwm
An Equal Oppotluniry 1 AKrmatve Action Employer— 50 % Recycled 110%Post Consumer Paper

Project Meeting and Proposed Containment Remedy Status
Raleigh Metal Processors
October 4, 2013
Page 2
one -foot thick cover material for adequately protecting public health. The barrier thickness design
needs further evaluation.
2) Just as the Branch has expressed reservations regarding the ability to effectively monitor the
proposed barrier location within "Area A" of the proposed containment remedy, the representatives
were also concerned. Additionally, the survey plat shows two separate areas where contaminated
soils must be covered. It is the Branch's understanding that the contaminated soil will be
consolidated into one larger area and covered by the barrier for monitoring. Additional evaluation
and clarification of the cover location and monitoring is needed.
3) As indicated above, recent inspections have revealed current site operations are contributing to
surface water discharge to neighboring properties. The proposed remedy will need to address the
long-term surface water flow and discharge at the site. The remedy must also address surface
water flow issues that may affect the integrity of the proposed barrier.
The above items will need to be addressed by the proposed containment remedy. Please be aware that
any actions required by federal, state, and local agencies to abate the on -going surface water issues are
not barred by actions of the REC Program. The property owner/operator must comply with those
requirements. If you would like to schedule a meeting to discuss these items or have additional questions
regarding the ongoing project activities, feel free to contact me at [phone] or
matt.aufmanaa ncdenr.00v.
Sincerely,
Matthew S. Aufman
REC Program
Superfund Section, Inactive Hazardous Sites Branch
cc: Ms. Jo Brown, Seymour Brown Investment Company, Inc.

lp V
2 o a -�

13

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Energy, Mineral and Land Resources
Land Quality Section Pat McCrory, Governor
Tracy E. Davis, PE, CPM John E. Skvarla, III, Secretary
Director
September 12, 2013
CERTIFIED MAIL 47012 1640 0001 9605 7874
Mr. Paul Perrotti
Raleigh Metal Recycling
2310 Garner Road
Raleigh, NC 27610
Subject: Notice of Deficiency
NOD-2013-PC-0361
Raleigh Metal Recycling
NPDES Stormwater Permit NCG200335
Wake County
Dear Mr Perrotti:
On August 27, 2013, Dave Parnell and Chris Pullinger, from the Raleigh Regional Office of the North
Carolina Division of Energy, Mineral and Land Resources (DEMLR) conducted a compliance evaluation
inspection (CEI) at your facility, located at 2310 Garner Road in Raleigh, North Carolina. The facility lies
in the watershed of an unnamed tributary (UT) to Walnut Creek, Class C NSW waters, in the Neuse River
Basin.
The following observations were noted during the DEMLR inspection and file review:
This facility is a scrap metal processing company, which has on -site tanks utilized for used oil and
petroleum derived from junked vehicles. Andy Sanderson and you were on site during the inspection
and provided valuable assistance to DEMLR staff.
1628 Mail Service Center, Ralegh, North Carolina 27699-1628
Location: 3800 Barrett Drive, Ralegh, North Carolina 27609 One
Phone: [phone] FAX: [phone] NorthCarolina
Internet: http:pnitytAcdmative Action
rl Naturallr� An Equal Opportunity 1 Affirmative Action Employer

Stormwater run-off generated at such facilities is regulated by general NPDES stormwater permit
NCG200000. The DEMLR Stormwater Program has issued certificate of coverage (COC) NCG200335.
The permit was on site and current. The Stormwater Pollution Prevention Plan (SPPP) was reviewed by
DEMLR staff. The SPPP was developed during the first half of 2013 and satisfied most of the
requirements of the permit. The plan lacked the following: documented employee training records and a
list of significant spills - for the last three years.
The monitoring reports were reviewed during the inspection. Prior to the last sampling period, only
three of the six Stormwater Discharge Outfalls (SDO) noted in the SPPP were being monitored. During
the last monitoring period, six SDO were monitored, qualitatively and analytically. Results from the last
analytical monitoring indicated exceedences of benchmarks at one or more of the SDO, which were for
Cadmium, COD, Copper, Iron, Lead, Oil and Grease, TSS and Zinc.
The stormwater collection system location and the drainage area flowing to each SDO were reviewed
during the inspection. Unfortunately, we were not able to determine the originating location of the
stormwater, as it flowed to each SDO and then offsite. This will make the reduction of benchmark
exceedences difficult to address, as you advance through the Tier system of your permit.
Containment and storage of oils, fuels and other liquids were adequate, with respect to secondary
containment. General housekeeping, within the shop, appeared to be adequate, as well.
DEMLR Staff and Raleigh Metal Recycling staff discussed the cause and effect of an illicit discharge that
was reported to DEMLR staff on August 23, 2013. The facility reports that measures have.been taken to
assure that no further spill such as the one noted, will reoccur.
Requested response. You are directed to respond to this letter in writing to DEMLR at the address
provided below within 30 days of receipt. Please address the following items noted in bold:
Please fully develop the Stormwater Pollution Prevention Plan by placing a list of
significant spills during the last three years, as well as documenting employee training
annually.
The latest analytical monitoring indicated benchmark exceedences. Please adhere to the
requirements of the NPDES permit with respect to the Tier program.
Please provide a final account of the illicit discharge which was reported to DENR on August
23, 2013. (It may be helpful if your consultant provides the report on your behalf).
1628 Mail Service Center, Ralegh, North Carolina 27699-1628
Location: 3800 Barrett Drive, Raleigh, North Carolina 27609 One
Phone: 919-791A2001 FAX: 919-571 A718 NorthCarolina
Internee httorporty LAffi mJve coon rl a�ryturallff
An Equal Opponunityl A�rma6ve Action Employer J�/K a

Please respond to:
Dave Parnell
NCDENR/DEMLR
Raleigh Regional Office
1628 Mail Service Center
Raleigh, NC 27699-162
Should you have questions regarding these matters, please contact Dave Parnell at [phone].
Sincerely,
John L. Holley, Jr., PE, CPESC
Regional Engineer
Raleigh Regional Office
cc: Stormwater Permitting Program Files - with attachment
DEMLR Raleigh Regional Office Files - with attachment
DWR Raleigh Regional Office Files -with attachment
City of Raleigh Stormwater Utility Division- with attachment
1628 Mail service Center, Raleigh, North Carolina 27699-1628
Location, 3800 Barrett Drive, Raleigh, North Carolina 27609.,i One
Phone: [phone] FAX: 919-571 A718 ��i.:��.1 ��' ~' NorthCarolina
Internet http:portal.ncdenr.orgANeb/ir/ t/�y�
An Equal Opportunity1ARrmative Action Employer ;Vat LQLL//
%ff

Parnell, David
From: Smith, Danny -
Sent: Friday, August 23, 2013 3:28 PM �� 1,
To: Hayes, Mitch; Parnell, David l/ JJJ
Subject: FW: Incident report (UST-62)
Lets all discuss this so we can ensure we are providing Raleigh the support that is appropriate.
Danny
Danny Smith
Regional Supervisor
Raleigh Regional Office
NCDENR-Division of Water Resources
3800 Barrett Drive
Raleigh, NC 27609
[phone]
[e-mail]
Email correspondence to and from this address may be 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.
12012
From: Sullivan, Shelton
Sent: Friday, August 23, 2013 2:12 PM
To: Randall, Mike; Smith, Danny; Pickle, Ken
Subject: RE: Incident report (UST-62)
The RRO, which you have copied should follow up. DEMLR or DWR? Maybe both
Shelton Sullivan
NCDENR I Division of Water Resources - Water Quality Programs
Wetlands, Buffers, Streams - Compliance and Permitting (Webscape) Unit
1650 Mail Service Center, Raleigh, NC 27699-1650
Phone [phone] Fax:[phone]
Email: shelton.sullivan@nedcnegov
Website: http://Vortal.ncdenr.org/web/wq/swp/ws/webscape
U S C S • ���
Lit S%sltLim_
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BAP V
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Pre M4,'r)_ C-/k
�M /%� l �,1- /LF-;-V-
rR- CE SI-'- J v .�
L�13 J Js `�J�
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to
third parties
�A Please consider the environment before printing this email.
From: Randall, Mike
Sent: Friday, August 23, 2013 1:47 PM
To: Smith, Danny; Ken Pickle; Sullivan, Shelton
Subject: FW: Incident report (UST-62)
Apparently, Raleigh Metals Recycling on 2310 Garner Road in Raleigh needs to be inspired to bring their facility into
compliance.

Any suggestions? Not really my area but I would love to help anyway I can.
Mike
From: Duffy, Peter[mailto:Peter. Duffv(a)raleighnc.gov]
Sent: Friday, August 23, 2013 1:41 PM
To: Randall, Mike
Cc: Senior, Mark; Bowden, Danny
Subject: FW: Incident report (UST-62)
Mike,
Per our conversation, here is the UST spill report for the discharge at 2310 Garner Rd.
Pete Duffy
Water Quality Technician
www.raleighnc.a,,ov/waterpollution
City of Raleigh
Public Works Department
Stormwater Utility Division
[phone] office
[phone] cell
From: Joe Beaman [mailto:JBeaman(-Ohesnc.com]
Sent: Wednesday, August 21, 2013 6:49 PM
To: Powers, Mark; danny.smith(@ncdenr.gov; Brenda. hafshe]ani(0)ncdenr.gov; Duffy, Peter
Cc: asanderson(algoldsboroscraometalrecvcling com
Subject: Incident report (UST-62)
Greetings.
Attached, please find a UST-62 for a release of oil and water from the subject facility. Initial response activities included
the recovery of oil -impacted water (surface water puddles), construction of a containment dam, plugging of stormwater
outfall piping, and installation of hydrocarbon sorbent boom downgradient of the stormwater outfall. We will be
visiting the site again tomorrow, and developing a workplan for remediation of impacted soils at the site.
Please contact me with questions or concern.
Joe
Please visit our website at www.HESfast.com
Hlghhuxls
'� Emrironrnerrtal
Sokirdons, hx -
Joe Beaman, P.G, RSM
President/Principal Geologist
Highlands Environmental Solutions, Inc.
8410-D Falls of Neuse Road; Raleigh, NC 27615
p: 919-848-3155 f: 919-848-4265

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Parnell, David
From: Bennett, Bradley
Sent: Wednesday, September 25, 2013 12:22 PM
To: Smith, Danny, Holley, John; Parnell, David
Subject: FW: Raleigh Metal Processors Meeting Scheduled for Thursday
Attachments: RMP—Site Map.pdf
FYI
More on meeting tomorrow.
L*-
Bradley Bennett
Stormwater Permitting Program Phone: [phone]
NC Division of Energy, Mineral and Land Resources Fax: [phone]
1617 Mail Service Center Email: bradley.bennett(d)ncdenr.gov
Raleigh, NC 27699-1617 Web: http://portal.ncdenr.org/webllr/stormwater
Email correspondence to and from this address may be subject to public records laws
From: Caulk, Kim
Sent: Wednesday, September 25, 2013 10:14 AM
To: '[e-mail]'; '[e-mail]'; Bennett, Bradley; '[e-mail]';
'Rhame. Ken [e-mail]'; '[e-mail]'; Holley, John; Parnell, David; Orozco, Phil; Smith, Danny;
[e-mail]; [e-mail]
Cc: Jesneck, Charlotte; Aufman, Matt
Subject: Raleigh Metal Processors Meeting Scheduled for Thursday
In case it is not clear after my Outlook glitch yesterday, the meeting is still scheduled for tomorrow (Thursday) at 1:30 in
the video Conference Room at DENR- Green Square. If you need additional information/directions, please let me know.
Prior to our meeting on Thursday, I would like to provide everyone with the attached map of the Raleigh Metal
Processors Site. It was taken from one of the consultant's documents in our files regarding the planned remedial action.
If anyone would like to review more information, the files are available to the public electronically. The instructions for
reviewing the files can be found on the Branch's web site at http://portal.ncdenr.org/web/wm/sf/ihshome.
So we can all understand the concerns and observations of each other's program area regarding the Site, the following is
a brief agenda that I thought might help:
Explanation of the REC Program & status of the long-term remedial action program (DENR-DWM, Inactive
Hazardous Sites Branch)
• Recent Site Inspections/Field Observations
o City of Raleigh
o Wake County
o DENR — Division of Water Resources
o DENR—DWM, Hazardous Waste Section

o EPA —Emergency Response
• Status of EPA TSCA review of PCB remediation
• Discussion/Conclusions
Hopefully after the meeting everyone's concerns will be clear, so we all understand the remedial path forward for
everyone's program.
Regards,
Kim
Kim T. Caulk, P.G.
Inactive Hazardous Sites Branch - REC Program
NCDENR - Division of Waste Management
217 West Jones Street
Raleigh, North Carolina 27603
Phone: [phone]
e-mail: Kim.Caulkancdenr.gov
hftp://Portal.ncdenr.org/web/wm/sf/ihs/recprogram
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to
third parties.

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Parnell, David
From:
Caulk, Kim
Sent:
Wednesday, October 02, 2013 1:04 PM
To:
Parnell, David
Subject:
RE: Raleigh Metal Processors Meeting 9/26/13
Thanks for clarifying. It will take awhile to get adjusted to the changes.
Kim T. Caulk, P.G.
Phone: [phone]
hftp://portal,ncdenr.org/web/wm/sf/ihs/recprogram
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to
third parties.
From: Parnell, David
Sent: Wednesday, October 02, 2013 10:10 AM
To: Caulk, Kim; '[e-mail]'; 'amy.ikerd@wakegov radley; '[e-mail]';
'[e-mail]'; '[e-mail]'; Holley, Joh ; rozco, Phil- ith, Danny; [e-mail];
[e-mail]; [e-mail]; gbrig h't@ gov.com; [e-mail];
timothy. [e-mail]
Cc: Jesneck, Charlotte; Aufman, Matt; Pullinger, Robert C
Subject: RE: Raleigh Metal Processors Meeting 9/26/13
Kim,
Thank you for the summary. As a result of the recent reorganization of some sections of DENR, there may have been
some confusion concerning the Notice of Deficiency (NOD) that was issued. You are correct that DWR (Division of
Water Resources) responded to the discharge, but the NOD resulted from an NPDES Stormwater inspection by
Stormwater Staff of DEMLR — Land Quality Section, on August 27, 2013. The facility is currently within their 30 day
response time to our office.
Thank you,
Dave Parnell
Environmental Senior Specialist
North Carolina Department of Environment & Natural Resources
Division of Energy, Minerals, and Land Resources
Raleigh Regional Office
3800 Barrett Drive
Raleigh, NC 27609
0: [phone]
F: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law
and may be disclosed to third parties.
From: Caulk, Kim
Sent: Tuesday, October 01, 2013 3:15 PM
To: '[e-mail]'; '[e-mail]'; Bennett, Bradley; '[e-mail]';
'[e-mail]'; '[e-mail]'; Holley, John; Parnell, David; Orozco, Phil; Smith, Danny;

feelv.kenOepa.gov; todd.rallCalraleighnc.gov; andrew.potterCalwakegov.com; gbright@)wakegov.com;
mark.senior0raleighnc.gov; timothy. henshaw(alraleighnc.gov
Cc: )esneck, Charlotte; Aufman, Matt
Subject: RE: Raleigh Metal Processors Meeting 9/26/13
Everyone:
Thank you all for participating in the meeting last Thursday. I believe it was beneficial in that everyone was able to gain
a better understanding of each program's perspective of the situation. The following is a brief summary of our
discussions:
The Inactive Hazardous Sites Branch (Branch) is within the Superfund Section of the DENR-Division of Waste
Management. The Branch has limited staff resources available to work on high priority sites (typically those
sites with threatened or impacted water supply wells). The Branch's Registered Environmental Consultant (REC)
Program is a privatized voluntary remedial action program available for the cleanup of sites determined by the
Branch to be lower priority compared to other sites across the state. The Raleigh Metal Processors Site is not
considered a higher priority site for the Branch.
• For the long-term remedial action Site, the REC Program executed an REC-Administrative Agreement (REC-AA)
with Seymour Brown Investment Company (the remediator) for a voluntary remedial action on 11/28/07. The
REC overseeing and approving the remediation under the REC Rules is Mid -Atlantic Associates. A remedial
investigation (RI) has been completed by Mid -Atlantic and a final certified RI Report (Site Assessment Report)
dated 8/20/10 is in the state's files.
In accordance with the REC Rules, the remediator and REC have submitted a proposed containment remedy that
has been given tentative concurrence by the Branch, however, details regarding a surface barrier that is to be
placed over contaminated soil and perpetual land use restrictions for the property owner have not been
finalized (see state files). The remedial design has been delayed while awaiting a permit from EPA under the
Toxic Substance Control Act (TSCA) authority for PCBs that are present at the Site. EPA Region IV has resource
limitations, but they will try to re -assign staff so review of the permit for PCB remedial action can move forward.
If final concurrence is given by the Branch, the containment remedy will become part of the overall long-term
remedy for any contaminated media (soil, groundwater, sediment, surface water, vapor intrusion) for the entire
Site and will be included in a REC-certified Proposed Remedial Action Plan (RAP), which will go through a
required 30-day public notice as required by the REC Rules. Depending on the public comments, the proposed
containment remedy and RAP may have to be revised by the REC before the RSM's certification and approval of
the remedy can be made.
• Representatives from the City of Raleigh and Wake County have performed inspections and responded to public
complaints regarding operations at the Site on several occasions. In late August, they, along with the Division of
Water Resources (DWR), responded to a surface water discharge from the Site onto neighboring properties.
Subsequently, the DWR issued a Notice of Deficiency on 8/27/13 for the surface water discharge.
• City of Raleigh and Wake County officials along with representatives of the Hazardous Waste Section of the
DENR-Division of Waste Management and EPA performed an inspection of the operation on September 20,
2013. Based on the inspection findings, surface water run-off is a continued concern at the facility.
City of Raleigh representatives will work with the DENR-Division of Water Resources to address the surface
water issues from the current facility operations. Interim remedial measures of the contamination can take
place to correct any current short-term surface water issues caused by the operations, but the measures need to
be coordinated appropriately with the Branch and comply with the REC Rule requirements. The REC Program
staff will continue to review the proposed containment remedy as part of the cleanup at the Site, including

additional concerns from other representative regarding the planned barrier. Also, the REC will be informed
that surface water issues for the facility operations need to be addressed in the long-term remedy as well.
Attached is a scanned image of the meeting attendees. As I mentioned near the end of the meeting, after the proposed
RAP is completed and public noticed by the REC, I encourage each interested party to review it and provide any
comments. Matt Aufman is the Branch's main point of contact for the project, so please contact him if you want to be
on the public notice mailing list.
In the meantime, please contact Matt or me if any information is needed or there are questions regarding the Site.
Regards,
Kim
Kim T. Caulk, P.G.
Phone: [phone]
http://portal.ncdenr.org/web/wm/sf/ihs/recprog ram
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to
third parties.
From: Caulk, Kim
Sent: Wednesday, September 25, 2013 10:14 AM
To: '[e-mail]'; '[e-mail]'; Bennett, Bradley; '[e-mail]';
'[e-mail]'; '[e-mail]'; Holley, John; Parnell, David; Orozco, Phil; Smith, Danny;
feely.kenCoepa.clov; todd.rall(a)raleighnc.gov
Cc: Jesneck, Charlotte; Aufman, Matt
Subject: Raleigh Metal Processors Meeting Scheduled for Thursday
In case it is not clear after my Outlook glitch yesterday, the meeting is still scheduled for tomorrow (Thursday) at 1:30 in
the video Conference Room at DENR- Green Square. If you need additional information/directions, please let me know.
Prior to our meeting on Thursday, I would like to provide everyone with the attached map of the Raleigh Metal
Processors Site. It was taken from one of the consultant's documents in our files regarding the planned remedial action.
If anyone would like to review more information, the files are available to the public electronically. The instructions for
reviewing the files can be found on the Branch's web site at http://portal.ncdenr.org/web/wm/sf/ihshome.
So we can all understand the concerns and observations of each other's program area regarding the Site, the following is
a brief agenda that I thought might help:
Explanation of the REC Program & status of the long-term remedial action program (DENR-DWM, Inactive
Hazardous Sites Branch)
• Recent Site Inspections/Field Observations
o City of Raleigh
o Wake County
o DENR — Division of Water Resources
o DENR—DWM, Hazardous Waste Section
o EPA —Emergency Response

• Status of EPA TSCA review of PCB remediation
• Discussion/Conclusions
Hopefully after the meeting everyone's concerns will be clear, so we all understand the remedial path forward for
everyone's program.
Regards,
Kim
Kim T. Caulk, P.G.
Inactive Hazardous Sites Branch - REC Program
NCDENR - Division of Waste Management
217 West Jones Street
Raleigh, North Carolina 27603
Phone: [phone]
e-mail: KIm.Caulk(aAncdenr.gov
hftp://Portal.ncdenr.org/web/wm/sf/ihs/recprogram
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to
third parties.

For Non-11,187 This form should he completed and submitted to the UST Section's regional office following a known or suspected release of
Releases of petroleu i from a source other than an underground storage tank This form is required to be submitted within 24 hours of
Petroleum In NC discovery of a known w suspected petroleum release
I
(DWM USE ONLY)-
Suspected Contamination? (Y/N) Y
Release discovered
btcklentfl Priority Re(H,I,L,U) _,
Confirmed GW Contamination? (YM) "
(11 alo):
Receved (tlmddats) -
Confirmed Soil Contamination ?(YIN) r
&21-2013 fe 1200 hours
Received by -Region
Samples taken?(Y/N) N Free product?(YIN)
Reported by. (circle one): Phone. Faxllor Report '
If Yes(free product), state greatest thickness: _feet
INCIDENT DESCRIPTION
?rodent Name: Oil -Water Illicit DI are
Address (street number/name): 2310 Gamer
Road
County: Wake
CltyRown: Raleigh
ZIP Code:27610
R tonal Office (circle one): Asheville, Mooresville, Fayetteville,
ta ashi ton Wllmin n Winston-Salem
Latitude (deamn dnlram): 35.749W
Longitude (d.mm,d dm�) :-78.832680
Obtained by.
® GPS
Describe suspected or confirmed release
(,ature ofrefease, time/date of release, quantify of release, amount offrse
vox: I
0 Electronic topographic map
0 GISAddressmatthng
0 Other
Illicit discharge of oil and water. Discovered
Q 1200 hours. Unknown quantity. Unknown prod. volume
Describe initial response/abateme It
OkWdate release stopped, dearule begw/aorripleted, quantify dWoduct
so# removed confirmation i
0 Unknown
location:
Outlets plugged. Impacted
water on ground surface recovered. Sorbent booms installed.
Describe impacted receptors: IDescribe
Soil. No known surface water
impacted. Storrnwater Inlets impacted and water/oil recovered.
NOW RELEASE WAS DISCOVERED (Releeee code)
(Check one)
0 Observation of Release at Occurrence
❑ Water Supply Well Contamination
0 Visual or OHactory Evidence
0 Surface Water Contamination
O Soil Contamination
\ ❑ Other (specify)
0 Groundwater Contamination
SOURCE OF CONTAMINATION
Source of Release
Cause of Release Type of Release Product Type Released
(Check one to lndlcets pnmery (Check
one to Indicate primary (Check we) (Check one to Indicate primary petroleum product
sauce)
I cause) / type released)
0 AST (tank)
Spill (Accidental) 0 Petroleum 13 Gasoline/ Dlesw 0 DlesalfVeg. Oil
❑ AST Piping? Dispenser ❑
Spill (imerdonal) 0 Both Petroleum Kerosene Bland
0 AST Delivery Problem ❑
Corrosion 8 Non -Petroleum 0 Ell - F20 ❑ Vegetable Oil 100%
0 OTR Vehicle Tank ❑
Physical or Mechanical 0 E21- E64 ❑ Heating Oil
0 OTR Bulk Transport Tank
Damage L lon ❑ E85- E99 ❑ Waste Oil
0 RR Sulk Transport Tank 0
Equipment Failure (Check one) ❑ Ethanol 100% ❑ Mineral Oil -no
• err 0
AST PCBS
El Facility ❑
(3
0 Unknown
AST Installation Problem Minarsl Oil -PCBs
0 Residence (]
0 Other ❑
Unknown Other Petroleum
0 Highway/Road
0
Other ewas.a d a .r Products —W
RWmy
DeflMLons presented on reverse Derarkins
presented on reverse O
Other
chimemblis
1. Municipal 2. Military 3. Unknown
4. Pmrete S. Federal 6. County 7. State
Oneredm Tvoe
1. Public Service 2. Agricultural 3. Residential
4. Edumfion/Re%. 5. Industrial Canmenia 7. Mining
Guidance presented an reverse
us I i-orm to (uanu) 1Page 1 of 2

IMPACT ON DRINKING WATER SUPPLIES
t Water Supply Wells Affected? 1i
Yes 2. No . Unknown Number of Water Supply Wells Affected_
List of Water Supply Wells Contaminated:
(Include Users Name, Addresses and Phone Numbers. Affach addlilonal sheet Ifnecessary)
1.
2.
3.
PARTY RESPONSIBLE FOR RELEASE
(ff the source of ffte release la not an
AST system orffIt Is an AST system and there Is a responsible party other than dre AST system owner/ operator)
Name of PetsonlCompeny
Address
Ralei h Metals R li
2310 Gamer Road
CNNyy
State
Zip Code
Teleepphone Number
Rate' h
NC
27610
919826-5426
AST
SYSTEM OWNER (if are source of the release Is an AST system)
AST Owner/Company .I
Address
na
Clry
State
Zip Code
Telephone Number
AST
SYSTEM OPERATOR Cif the source of the release Is an ASTsystem)
UST OperamdCompany
Address
nor
City
State
Zip Code
Telephone Number
LANDOWNER AT LOCATION OF INCIDENT
Landowner
Address
Seymour Brown Investment Co., Inc.
P.O. Box 10809
I
State
ZI Code
Telephone Number
Go taro
NC
27g32-0609
To Be Determined
Draw Sketch of Area or
Provide Map (showing incident site, location ofralease, t m mglor rowtatorsacffons, potential
ors)
ACach sketch ormep to form.
Give
Directions to Incident Site Affachdtredlonstormmnnacessary.
See Attached
Person Reporting Incident Joe Ba
Gom y H' hlands Environmental Solutions, Inc.
Telephone Number 919-848-3155
Title Pdncliml Geologist
rear 8410-D Falls of Neuse Road; Raleigh, NC 27615
Data 8-21-2013
UST Form 62 (04110) Page 2 of 2
Definitions of Sources
AST (Tank): meaty the tank is used to store product
AST Piping: means the piping and comcctom mmung from the tank to the dispenser an other end,use equipment
AST Dispenser. inchdes the dispenser and the equipment used to coma t the dispenser to the piping
AST Delivery Problem: identifies releases that occurred timing product delivery to the bank:
OTR Vchicle Tank: means the tank is unction more product to mrel an over the mad vehicle
OTR Dugs Transport Tank: means a tact that is used to transport product in bulk over the road (by truck)
RR :bulls Tnm.pwt Tank: means a tank that is wed to transport product in bulk by tram
ltnnafomer. meaty electrical transformer
Other: serves as the option to use when the release source is known but does not fit into one of the preceding categories
Unkmown: identifies releases for I hick the source has not been determined
De6m ni6oof Causes
Spill (Accidental): use this cause when a spill occurs accidemally(e.g., when the delivery hose is disconnected from a fill pipe)
Spill (intentional): use fills cause when a soil] occurs intentionally (c.g., intentional dumping or breakage)
Corrosion: use when a metal tanI
ng, or other component has a release clue to corrosion
Physical w Mechanical Damage: or all types of physical or mechanical damage, except corrosion
Equiprtreat failure: use when a release oue to equipment failure other than corrosion wpbysical w mechanical damage
AST Overfill: use when an overfill (e.g., overfills may occur from the fill pipe at the tank or when the nozzle fails to shut off at the dispenser)
AST Installation Problem: use when the problem is determined to have occurred specifically because the AST system was not installed properly
Other: use this opfionwhea the cause is Item own but does not fit into one of the preceding categories
Unknown: use when the cause has not been determined
Guidance: Ownership and Operator Type 1
Ownership select the category which descnbcs owner of the AST system, bulk transport ink, or other release source
Operator Type select the category which deseribe the operation in which owner wes the AST system, bulk transport tank, or other mime somce

Parnell, David
From:
Parnell, David
Sent:
Wednesday, October 16, 2013 2:43 PM
To:
Holley, John
Cc:
Pullinger, Robert C
Subject:
Raleigh Metal Recycling Requested Response - NCG200335
John,
Chris Pullinger and I reviewed the response from Raleigh Metal Recycling, thoroughly. Their response was
required by October 16, 2013. We received the response electronically on October 14, 2013, and by UPS
Overnight on October 15, 2013. The response was written by Mr. Gregory Brown. It adequately addressed all
of the items in the Notice of Deficiency. There was a small discrepancy concerning the list of spills required in
the SPPP, but this can be corrected during the next site visit. One thing of note is that Mr. Brown states that
they are currently on Tier 11 of their NPDES Permit.
Let me know if you have questions.
Dave Parnell
Environmental Senior Specialist
North Carolina Department of Environment & Natural Resources
Division of Energy, Minerals, and Land Resources
Raleigh Regional Office
3800 Barrett Drive
Raleigh, NC 27609
0: [phone]
F: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law
and may be disclosed to third parties.

Greg Brown
From: Greg Brown
Sent: Monday, October 14, 2013 2:24 PM
To: [e-mail]
Cc: David Gibb
Subject: Follow Up
Attachments: storm10.14.13rl.pdf, storm.10.14.13.pdf
Note, the below is also coming via Overnight UPS pack
Subject: NOD 2013-PC-0361
Mr. Parnell
NCDENR/DEMLR
Raleigh Regional Center
1628 Mail Service Center
Raleigh, NC 27699-162,
ova
This is to respond to the letter of September 12, 2013 and signed for on the 16th that
asked to address the items in bold.
1) Please fully develop the Storm water pollution Prevention Plan by placing a
list of significant spills during the past three years, as well as documenting
employee training. Address: A log form to record significant spills is now in the
plan book. Related. this email is serve to document that there have been zero
significant spills during the past three years -see attached. Also, the documentation
of "recent" training was in a different file and was not shown when asked to Andy
Sanderson, whom you met with on 8/27/13. He was not working there in April, nor
was the General Manager Paul Perrotti, so they were not aware that training had
been done by Dennis Gehle, the General Manager of our Goldsboro Operation on
April 12, 2013. Documentation of that training is now in the book. See attached.
2) The latest monitoring indicated benchmark exceedence. Please adhere to the
requirements of the NPDES permit with respect to the Tier Program. Address
We are adherina to the reauirements and are now treatina the site as a Tier 2. We
are hirina a comoanv to do monthlv testina. (thev will take samples) because we
want to ensure we are testing correctl
3) Please provide a final account of the illicit discharge which was reported to
DENR on August 23, 2013. (It may be helpful if your consultant provided the report
on your behalf). Address: See below email from the consultant with the 'final'
account of what Hiahland did that day. A complete analvtical report can also be
sent if requested. Related significant remediation work was done since the event,

which was witness by you and others during the tour of 10/6/13. More has been
done since then and more continues to be done. Note the discharge was due to the
pipe that went from our small storm water pond to the North that was blocked. The
storm water pond filled and was overflowing, causing water to go over ground to the
North. The onsite team, wanted to stop or slow this, so they engaged a pump to
take the water to the SOUTH, away from the property to the North. Note in a
published article it was said "Workers had apparently been pumping the liquid onto a neighbor's
property", Which is not true. Also, we did not send, let alone we were never planing on
sending more hazardous waste into the city's storm water pipes, which the article said the city was
concerned about. Laslty, what we believe to be the causes of the petroleum have
been addressed.
From: Joe Beaman [mailto:[e-mail]]
Sent: Friday, September 06, 2013 4:21 PM
To:'[e-mail]'; pperrottiCalraleighscrapmetalrecycling.com
Subject: Analytical data
Good afternoon. We finally received all of the analytical data for the soil sample that we collected during our initial
response activities. Only petroleum compounds were detected in the sample. Metals concentrations were very low,
and well below hazardous waste standards. The hydrocarbons detected consisted of diesel range organics (at a
concentration of 3400 ppm), and total oil and grease (at a concentration of 2320 ppm). Both diesel and oil and grease
were well above their state action limits.
Please contact me with questions or concerns.
Joe
"atal
Inc-
Please visit our website at www.HESfast.com
Joe Beaman, P.G., RSM
Highlands Environmental Solutions, Inc.
8410-D Falls ofNeuse Road
Raleigh, NC 27615
P — 919-848-3155
F — 919-848-4265
C — 919-414-7081
24-Hour Emergency Response: 1-855-HES-FAST (855-437-3278)
Submitted by. -
Gregory Brown

Raleigh Metal Recycling
Goldsboro Metal Recycling
"Excellence in Recycling and Services"
"We Pay Cash for Your Metal Trash"
Tel: [phone]
Cell: 734-740-9514
Email: gbrown(a)raleighscrapmetalrecycling.com
Web Addresses:
www.raleighscrapmetairecycling.com
www.goldsboroscrapmetalrecycling.com

1
+ O E e G. F
For NaM/8T This form should
be completed and submitted to the UST Section's regional office following a known or suspected release of
Ralwsas of petrolour from
a source other than an underground storage tank This form is required to be submitted within 24 hours of
Petroleum In INC
discovery of a known or suspected petroleum release
(DWM USE ONLY)
Suspected Contamination? (Y/N) r
Release discovered
Incident ft Prlortty Ra
(H,I,L,U)_.
Confirmed GW Contarnmation7(YIN)N
(time/date):
Reoelved (time/dste) .
�gion
Confirmed Soil Contamination 7(Y/N) r
8-21-2013 ma 1200 hours
RoceNed by R
Samples taken7(Y/N) N Free product? (Y/N) x
Reported by. (circle one): Phone, Faxior
Report-
If Yes(free product), state greatest thickness: _feet
incident Name: Oil -Water Illldt DI I
INCIDENT DESCRIPTION
charge
Address (street numbedname): 2310 Gamer
Road
I County: Wake
CltylTawn: Raleigh
Zlp Code:27610
Re lonal Office (clro/e one): Asheville, Mooresville, Fayetteville,
lei ashi ton Wilmin on Winston-Salem
Latitude (morel dopwo): 35.749844
Longitude (down dear..,) :-78.632680
Obtained by:
GPS
Describe suspected or confirmed release
(nature of release, timardefe of release, quantity of release, amount of free
producjt:
O Electronic topographic map
0 GIS Address matching
O Other
Illicit discharge of oil and water. Discovered
@ 1200 hours. Unknown quantity. Unknown prod. volume
Describe initial response/abatemedt
(firnWdefe release stopped, cleanup beguNcomplefed, quent ly of product
soil romoved confirmation so l : 1
l] Unknown
Describe location:
Outlets plugged. Impactedl
water on ground surface recovered. Sorbent booms installed.
Describe impacted receptors:
Soil. No known surface waters
Impacted. Storrnwater inlets impacted and waterloil recovered.
�iOW RELEASE WAS DISCOVERED (Release code)
(Check one)
m Observation of Release at Occurrence
❑ Water Supply Well Contamination
0 Visual or Olfactory Evidence
❑ Surface Water Contamination
• Soil Contamination
❑ Other (specify)
(] Groundwater contamination
SOURCE OF CONTAMINATION
Source of Release
Cause of Release Tyne of Release Product Type Released
(Check one to�� to primary (Check
one to Inca primary (Check orre) (Check one to indicate primarypefrleurn product
s
edke
type released)
0 AST (tank) ❑
Spill (Accidental) '❑ Petroleum 0 Gasoline/ DleseU 0 DleselNeg. Oil
❑ AST Plping/ Diapenser ❑
Spill (Intentional) 0 Both Petroleum Kerosene Blend
0 AST Delivery Problem ❑
Corrosion d Non -Petroleum ❑ Et 1 - E20 ❑ Vegetable Oil T00%
❑ OTR Vehicle Tank ❑
Physical or Mechanical ❑ E21 - E84 ❑ Heating Oil
❑ OTR Bulk Transport Tank
Damage Location ❑ Ea5-Egg ❑ Waste Oil
❑ RR Bulk Transport Tank ❑
Equipment Failure (Chock one) ❑ Ethanol 100% ❑ Mineral Oil -no
❑ (]
Transfa ner
AST Overfill PCBS
0 Facility [3Mineral
0 Unknown ❑
AST Installation Problem Oil -PCBs
0 Residence 0 Other Petroleum
❑ Other ❑
Unknown ❑Highway/Road Products —w
IZI
Other w asw...^wu,.
0 Railway
Definitions prosented fir reverse Dell
Idons presented on reverse
❑ Other
Ownership
1. Municipal 2. Military 3. Unknown
4. Private 5. Federal 6. County 7. Slate
Operation Type
1. Public Service 2. Agricultural 3. Re
Idential 4. Education/Relig. 5. Industrial Commends 7. Mining
Guidance presented on reverse
LIST Form 62 (04/10) 1 Pago 1 of 2

IMPACT ON DRINKING WATER SUPPLIES
Water Supply Wells Affected? 1
Yea 2. No . Unknown Number of Water Supply Wells Affected
List of Water Supply Wells Contemin
ad: (Include Users Names, Addresses and Phone Numbers. Attach additional sheet Hnecessery)
1.
2.
3.
PARTY RESPONSIBLE FOR RELEASE
(if the source of Me release la not an
qST system or if it Is an AST system and there la a responsible parry other Aran th ASTsystem owned operator)
Name of PersordCompeny
Address
Raleigh Metals Re clin
2310 Gamer Road
CIry
State
Zip Code
Telephone Number
Rate' h
NC
27610
919-8285428
AST
SYSTEM OWNER (tithe source of the release is an AST system)
AST Owner/Company I
Address
na
City
State
Zip Code
Telephone Number
AST
SYSTEM OPERATOR (If the source of the release Is an AST system)
UST OperatodGnmpany
Address
na
cityState
Zlp Code
Telephone Number
LANDOWNER AT LOCATION OF INCIDENT
Landowner
Address
Se ur Brown Investment Co., In
.
I P.O. Box 10809
C''
State
ZI Code
Telephone Number
Goldsboro
NC
27A32.0809
To Be Determined
Draw Sketch of Area Oi
Provide Map (showfnglncldon ire, location ofralease, two mq(orroadintersecdons, potential
receptors)
Attach sketch or map to form.
Give
to Incident Site Attach directions to form Ifnacessary.
See Attached
directions
Person Reporting Inddentj0e Be
Cum _ y Highlands Environmental Solutions, Inc.
Telephone Number919-848-3155
'Me Pdndpel Geologist
dress 641" Fails of Nauss Road: Raleigh, NC 27615
Data 6-21-2013
UST Form 62 (04110) Page 2 of 2
Definitions orsoarces
AST (Tank): means the tank is used to store product
AST Piping: means the piping and tors running from the tank to the dispenser o other cad -we equipment
AST Dispenser includes thq disponser and the equipment used to connect the dispenses to the piping
AST Delivery Problem: identifies releases that occurred timing product delivery to the tank.
OTR Vehicle Tank: means the tank is us sires product to fuel an over the read vehicle
OTR Hulk Transport Tank: means a the is used to transport product in bulk over the road (by took)
RR :bulk Transport Tank: means a that is used to transport product in bulls by Cain
Transformer. means electrical bans£ rmer
Other: serves as the option to use when rite mime source is known but does not fit into one of the preceding categories
Unknown: identifies releases for hick the source has not been determined
Definitions of Clam
Spill (A"fi enrol): use this came when a spill occurs accidentally(e.g., when the delivery hose is disconnected from a fill pipe)
Spill (Intentional): use this cruse when e M occurs intentionally (e.g., intentional dumping or breakage)
Corrosion: use when a metal tank, ipk& or other wmponmt has a release due to wrrosion
Physical or Mechanical Damage: for all typos of physical or mechanical damage, except corrosion
Equipment failure: use when a release occurs due to equipment failure other then corrosion or physical or mechanical damage
AST Overfill: use when an overfill rs (e.g., overfills may occur from the fill pipe at the tank or when the nozzle fails to shut off at the dispenser)
AST Installation Problem: use when th problem is determined to have occurred specifically because the AST system was not installed properly
Other: use this option when the cause is known but does not fit into one of the preceding categories
Unknowns uu when the cause has pot been detmmined
Guidance: Ownenhlp and Operator Type
Ownership select the category which describes owner of the AST system, bulk transport tank, or other release source
Operator Type select the category which describes the operation in which owner uses the AST system, bulk transport tank, or other release source

SPCC Training - Sign In Sheetpoi t 3
1
1
l
1
L
31
32
33

Greg Brown
From: Greg Brown
Sent: Monday, October 14, 2013 2:24 PM
To: [e-mail]
Cc: David Gibb
Subject: Follow Up
Attachments: storml0.14.13rl.pdf, storm.10.14.13.pdf
Note, the below is also coming via Overnight UPS pack n03
Subject: NOD 2013-PC-0361
Mr. Parnell Oct
NCDENR/DEMLR
Raleigh Regional Center
1628 Mail Service Center
Raleigh, NC 27699-162, \.
This is to respond to the letter of September 12, 2013 and signed for on the 16th that
asked to address the items in bold.
1) Please fully develop the Storm water pollution Prevention Plan by placing a
list of significant spills during the past three years, as well as documenting
employee training. Address: A log form to record significant spills is now-i+�-t
plan book. Related, this email is serve to document that there have been zero
significant spills during the past three years -see attached. Also, the doclimentatior
of "recent" training was in a different file and was not shown when asked to Andy
Sanderson, whom you met with on 8/27/13. He was not working there in April nor
was the General Manager Paul Perrotti, so they were not aware that training had
been done by Dennis Gehle, the General Manager of our Goldsboro Operation on
April 12, 2013. Documentation of that traininq is now in the book. See attached.
2) The latest monitoring indicated benchmark exceedence. Please adhere to the
requirements of the NPDES permit with respect to the Tier Program. Address
We are adherinq to the requirements and are now treating the site as a Tier 2. We
are hiring a company to do monthly testing, (then will take samples) because we
want to ensure we are testing correctl
3) Please provide a final account of the illicit discharge which was reported to
DENR on August 23, 2013. (It may be helpful if your consultant provided the report
on your behalf). Address: See below email from the consultant with the 'final'
account of what Hiqhland did that day. A complete analvtical report can also be
sent if requested. Related significant remediation work was done since the event
I

Permit: NCG200335 Owner -Facility: Gimco Acquisition LLC
Inspection Date: 08/27/2013 Inspection Type: compliance Evaluation Reason for Visit:
Routine
Stormwater Pollution Prevention Plan
Yes No
NA
NE
Does the site have a Stormwater Pollution Prevention Plan?
■
❑
❑
❑
# Does the Plan include a General Location (USGS) map?
■
❑
❑
❑
# Does the Plan include a "Narrative Description of Practices'?
■
❑
❑
❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
■
❑
❑
❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
❑
■
❑
❑
# Has the facility evaluated feasible alternatives to current practices?
■
❑
❑
❑
# Does the facility provide all necessary secondary containment?
■
❑
❑
❑
# Does the Plan include a BMP summary?
■
❑
❑
❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
■
❑
❑
❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
■
❑
❑
❑
At 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: The facility has a SP3 that was developed in the spring of 2013. A list of
spills for the previous three years and documented records of employee training is not
included in the plan but is required.
Qualitative Monitoring
Yes No
NA
NE
Has the facility conducted its Qualitative Monitoring semi-annually?
■ ❑
❑
❑
Comment: For previous monitoring periods the facility was not sampling all six of the
outfalls. The monitoring period for the last six months of 2013 was conducted properly.
Analytical Monitoring
Yes No
NA
NE
Has the facility conducted its Analytical monitoring?
■ ❑
❑
❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
■ ❑
❑
❑
Comment: For the previous sample periods the facility was not sampling all six of the
outfalls. It conducted the required outfall sampling in on June 2013. However the
sample results were beyond benchmarks for many of the parameters at the outfalls.
Above benchmarks at one or more of the outfalls included Cadmium, COD, Copper,
Iron, Lead, Oil and Grease, TSS and Zinc. Please adhere to the requirements of the
permit with respect to the Tier program.
Permit and Outfalls Yes . No NA NE
Page: 3

Permit: NCG200335
Inspection Date: 08/27/2013
Owner • Facility: Gimco Acquisition LLC
Inspection Type: Compliance Evaluation
Reason for Visit: Routine
# Is a copy of the Permit and the Certificate of Coverage available at the site?
# Were all outfalls observed during the inspection?
# If the facility has representative oulfall status, is it properly documented by the Division?
# Has the facility evaluated all illicit (non stormwater) discharges?
Comment: An illicit discharge of oil/water was reported to DLR RRO on 8/21/2013.
Highlands Environmental Solutions, Inc. handled the cleanup. The discharge was
discussed during the inspection and prevention actions were suggested.
■00Q
■0D0
n0■0
n■❑O
Page:4

A
1
2 Date
D t
8
LRaleigh Metal Recycling Spill Tracking
Area Amount of Spill Action Taken Manager on Duty
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32

SPCC Training - Sign In Sheet
21
2E
2 c.
3C
31
32
33
,70/3

Parnell, David
From:
Senior, Mark [[e-mail]]
Sent:
Wednesday, October 16, 2013 10:50 AM
To:
Bennett, Bradley; Holley, John; Smith, Danny
Cc:
Duffy, Peter; Rall, Todd; Boyer, Kevin; Parnell,
Nicolette
Subject:
RE: Old Garner Road Metal Recycling
Attachments:
ATT00002.c; ATTOOOO5.htm
David; '[e-mail]'; Fulton,
Hi folks. Just want to keep everyone up to date on this site. The operator has enlisted the local engineering firm
McAdams to help them develop an appropriate stormwater management plan. Raleigh staff met with their representative,
Amos Clark, yesterday to discuss our concerns with the site. I told him that there were other regulators involved at the
state and county level and that any plan developed would have to be -coordinated -among the different agencies. It
appears they will be proposing a plan with several large sediment type basins along with diversion features to direct all
runoff from the site .to..the,basins. They mmay also incorporate some kind of inverted outlet structure'to contain'petrdle'um
products`Mlyintent is to follow up with the operator to insure that a plan is developed and implemented in a timely
manner. We may need to get together to discuss what kind of timetable is acceptable.
We have collected one runoff sample from one outfall at the site and intend to collect at least one more from another
outfall to verify what's in the stormwater leaving the site. I will provide that data when we receive it.
As I noted in our meetings. I would highly recommend that this site be considered for an individual NPDES Industrial
Stormwater Permit based on the amount of disturbed soil, the quantity and types of exposed materials, and the fact that it
is a PCB and metals hazardous waste site with noted offsite contamination.
Thanks and please let me know if you have any questions.
Mark Sr.
Mark T. Senior, PE, Senior Project Engineer
Stormwater Utility Division
City of Raleigh Public Works Department
PO Box 590
Raleigh NC 27602
Work Phone [phone]
Fax [phone]
Email mark.senior(a)raleighnc.gov
www.raleighnc.gov
From: Bennett, Bradley [mailto:[e-mail]]
Sent: Tuesday, October 01, 2013 4:38 PM
To: Senior; Mark; Holley, John; Smith, Danny
Cc: Duffy, Peter; Rall, Todd; Boyer, Kevin; Parnell, David
Subject: RE: Old Garner Road Metal Recycling
Mark
Here is the most recent permit issued in 2010. Two files are fttached, their cover
permit is in the second file. The permit was first issued in 200.
11-
Bradley Bennett
Stormwater Permitting Program Phone: [phone]
NC Division of Energy, Mineral and Land Resources Fax: [phone]
1617 Mail Service Center Email: bradlev.benneft a&cdenr.gov
and CDC are in one and the

Parnell, David
From: Holley, John
Sent: Wednesday, March 12, 2014 5:10 PM
To: Bennett, Bradley; Smith, Danny; Zimmerman, Jay
Cc: Parnell, David; Dupree, Joe; Vinson, Toby
Subject: FW: Raleigh Metals Draft RAP
Attachments: 2013-12-23 SWMP to G. Brown.pdf
As I mentioned to some folks earlier, EPA and DWM facilitated a telephone conference call today regarding the Raleigh
Metals site that we all have been working on for some time. The primary agenda was to ensure DENR concurrence with
a proposed EPA approval of the remedy for past PCB contamination at the property where this facility exists. This
remedy involves a pervious cap for contaminated areas to prevent exposure of contaminated soils and direct human
contact with PCB's and other toxins. This remedy is a component of a broader remedial action plan (RAP) that addresses
the PCB contamination, but does not address stormwater and surface water contamination that has been monitored
recently by DWR and the City of Raleigh (the data indicates significant violations of stream standards). A consultant for
the operator has recently submitted a temporary stormwater plan to the city in response to their concerns, and the city
staff have found it to be inadequate, largely because it does not provide designed stormwater basins sufficient to abate
sediment loss and subsequent discharge of pollutants to waters of the state. After much discussion, the city (Mark
Senior and an Assist. Attorney) made it clear that they are ready to take an enforcement posture if something is not
done quickly (within 30-60 days) to begin abatement of the offsite pollution. I noted that DWR is currently considering
the most appropriate and effective legal steps to ensure that the site is addressed. I noted that we are working in
support of their actions and encourage a comprehensive plan addressing all pollutants affecting waters below this site. I
recommended that they not move forward with approvals, etc. until this matter is discussed with staff representing Jay
Zimmerman and Bradley Bennett to ensure that a comprehensive plan is being developed that will be satisfactory to
DWR/DEMLR SW. It was encouraging to hear that EPA is willing to allow flexibility with incorporating SW BMP's with the
RAP, allowing onsite SW measures to be taken concurrent with implementation of their approved PCB remedy. Note
the access information below for the current RAP. EPA has asked all to review/consider this plan in any actions being
considered, and to provide any feedback regarding portions that we do not believe will work to improve water quality
and overall operation. Although I believe we still need to take an aggressive stance in this case, I would suggest that we
facilitate a discussion with the EPA and DWM representatives before moving forward, if possible. If there are any
questions, please advise. Attached is a copy of the SWPlan submitted to the city back in December.
From: Dan Nielsen [mailto:[e-mail]]
Sent: Wednesday, March 12, 2014 3:07 PM
To: [e-mail]; [e-mail]; Holley, John; Fulton, Nicolette;
[e-mail]
Cc: Feely, Ken; Crosby -Vega, Terri; 'Butler, Jay'
Subject: Raleigh Metals Draft RAP
f:UE
The draft of the Remedial Action Plan for the Raleigh Metals site which is dated June 21, 2012 is available. However, the
file size is too large to efficiently e-mail, so we have posted it to our FTP site. You can access the Plan by clicking on this
link ftp://remote.maaonline.com/ . Follow the instructions there and use these access codes:
Username: Raleigh Metals
Password: Raleigh
Please pass this link on to appropriate parties (Jay Zimmerman, Bradley Bennett, etc). If you have problems accessing
the documents, please call Beverly Oglesby at 919-250-9918 to ask for assistance.

Thanks,
Dan
UMM Mid Atlantic
Enllnauin! f F�6LdnFheAGC ia�aliani
Daniel H. Nielsen, PE, RSM, LEED-AP ...
Vice -President, Principal Engineer
MID -ATLANTIC ASSOCIATES, INC.
409 Rogers View Court I Raleigh, NC 27610
919-250-9918 1 919-250-9950 (Facsimile) 1 919-614-3988 (Mobile)
www.MAAONLINE.com 120-Years of service 1993 - 2013
Confidentiality Notice: The information contained in this e-mail is intended only for the individual or entity to whom it is
addressed.lts contents (including any attachments) may contain confidential and/or privileged information. If you are
not an intended recipient you must not use, disclose, disseminate, copy or print its contents. If you receive this e-mail in
error, please notify the sender by reply e-mail and delete and destroy the message.

Raleigh, NC 27699-1617 1 Web: hftp://portal.ncdenr.org/web/Ir/stormwater
Email correspondence to and from this address may be subject to public records laws
From: Senior, Mark [mailto:[e-mail]]
Sent: Monday, September 30, 2013 11:20 AM
To: Holley, John; Bennett, Bradley; Smith, Danny
Cc: Duffy, Peter; Rail, Todd; Boyer, Kevin
Subject: Old Garner Road Metal Recycling
Hey guys, thanks much for meeting with us last week. I think that was very worthwhile in terms of everyone better
understanding the different parties involved and their roles. City staff are discussing the issues we are having with this
site with our attorneys and could really use a copy of their signed permit (or permit application) if you have it. We could
also use any monitoring data associated with this site including any self monitoring data they may have supplied. Our
plan is to collect and analyze samples from the site and we will forward that data to you when we have it. Our Fire
Marshal is also looking into the site based on the kinds of material stored there. They are very concerned that this site
could be hazardous to their responders.
Thanks, Mark Sr.
Mark T. Senior, PE, Senior Project Engineer
Stormwater Utility Division
City of Raleigh Public Works Department
PO Box 590
Raleigh NC 27602
Work Phone [phone]
Fax [phone]
Email mark. senior(3raleiohnc.00v
www.raleighnc.c�ov

Parnell, David
From:
Smith, Danny
Sent:
Saturday, January 04, 2014 1:25 PM
To:
Subject:
Parnell, David 7
FRaleigh Metals Recyclin Wg f
Attachments:
2013:12-23-SWMP to-GGBrown.pdf; ATT00001.c
fyi
Danny Smith
Regional Supervisor
Raleigh Regional Office
NCDENR-Division of Water Resources
3800 Barrett Drive
Raleigh, NC 27609
[phone]
[e-mail]
Email correspondence to and from this address may be 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: Senior, Mark [mailto:[e-mail]]
Sent: Tuesday, December 31, 2013 11:38 AM
To: [e-mail]; Bennett, Bradley; Smith, Danny; Holley, John
Subject: FW: Raleigh Metals Recycling
Hi folks, I received the attached stormwater management plan for Raleigh Metals Recycling from the operator's
consulting engineer. Personally I am concerned that it lacks an accurate map of the site's storm drainage system and
inlets, the drainage area to those inlets, and calculations or designs for devices capable of capturing and removing the
high concentrations of sediment, metals, and PCB's identified in both their sampling and ours. I simply don't see how
what is proposed will provide any meaningful reduction in pollutant loads leaving the site. I would welcome your
thoughts regarding the adequacy of this plan and where we should go from here.
Thanks, Mark Sr.
Mark T. Senior, PE, Senior Project Engineer
Stormwater Utility Division
City of Raleigh Public Works Department
PO Box 590
Raleigh NC 27602
Work Phone [phone]
Fax [phone]
Email mark. senior(o)raleighnc.gov
www.raleighnc.gov
From: Aldridge, Jon [mailto:[e-mail]]
Sent: Thursday, December 26, 2013 11:29 AM
To: Senior, Mark
Cc: Clark, Amos; [e-mail]; Toole, William ([e-mail])
Subject: Raleigh Metals Recycling

Mark,
Attached is the stormwater management plan for the Raleigh Metals site for your review and approval. I will be sending
you a hard copy as well.
Please let Amos or myself know if you need anything further. Thank you.
Jon Aldridge, PE
Project Manager
Water Resources & Infrastructure
Office: 919-361-5000
Direct: 919-287-0889
Mobile: [phone]
McAdamsCo.com
2 MCADAMS
Designing Tomorrow's Infrastructure & Communities

Parnell, David
From: Senior, Mark [[e-mail]]
Sent: Tuesday, January 28, 2014 11:56 AM
To: Holley, John
Cc: Vinson, Toby; Bennett, Bradley; Smith, Danny; Parnell, David; Boyer, Kevin; Rall, Todd; Duffy,
Peter
Subject: RE: Old Garner Road Metal Recycling stormwater pollution
Attachments: ATT00001.c; ATT00004.htm
Hi John, I was not sure what you have been copied on so I wanted to take a moment to provide a brief update on the
status of our efforts with this site. We received the results from our second round of sampling and the results were
similar to the first round with a number of the NPDES permit thresholds exceeded (including sediment and metals) and
extremely high PCB levels`(I'II"follow up this email with a copy of those results) -Based -on -our results, a unit of runoff
from that site would have to be diluted 53,000 times in order to meet NC in stream standards for PCBs.
We received a draft-stormwater management plan prepared by McAdams on December 26`h which we shared with your
folks and Wake County. I received comments from the County and am hoping to get.some comments from the State
before we formally respond, hopefully by next week. Unfortunately, the plan was less than 1 expected and I don't see
anything in it that would lead me to expect its implementation will provide a significant reduction in pollutants leaving
the site.
On January 2, 1 received a call from Dan Nielson with Mid -Atlantic who is working for the owners (not the operator Mr.
Brown) on the PCB remediation plan which involves covering the site with a.barrier' He is trying to speed things along
with EPA by greaas g the wheels of the local communities that may comment on plan when EPA sends it out for
comment. He had also contacted Eric Green with Wake County. We concluded that getting some kind of cap on this site
is a step in the right direction and agreed we would support approval of the plan in order to expedite its G'
implementation. This is with the understanding that the plan requires monitoring by Mid -Atlantic and any deficiencies
would have to be remediated.
In discussions with our attorney, Nicolette Fulton, we have a continuing concern that we may have difficulty with any
enforcement action taken by the City because the site has a valid State permit for their stormwater_discharge. Since the
permit includes only thresholds and not specific concentration -limits, -the City ymay 'have difficulty demonstrating that
their discharges violate the conditions of their permit. With that in mind, the City may require your assistance in pursing
enforcement based on either the permit conditions or violation of surface water quality -standards. -Other options for
getting this site to adequately control'the pollstan in theidischarge might include placing additional conditions in the
permit based on exceeding the thresholds or by requiring anlirsd ivi d� or the site based on the fact that a
general permit is inappropriate for a site which has been revealed"to Be a federal remediation site contaminated with
PRaleigh would certainly support the need for an indiv� I permit.Have you given any thought to potential ways
the State might address surface water contamination from this site?
I am also curious as to whether your staff has had an opportunity to conduct any in -stream sampling to confirm any
State standard violations.
Thanks for your help with this John.
Mark Sr
Mark T. Senior, PE, Senior Project Engineer
Stormwater Utility Division

City of Raleigh Public Works Department
PO Box 590
Raleigh NC 27602
Work Phone [phone]
Fax [phone]
Email mark.senior(o)raleiohnc.gov
www.raleighnc.gov
From: Holley, John [mailto:[e-mail]]
Sent: Wednesday, November 27, 2013 5;Q3..PM
To: Bennett, Bradley; Smith, Danny; Parnell; David
Cc: Vinson, Toby; Senior, Mark
Subject: Old Garner Road Metal Recycling
As I have discussed with Toby and Danny today, this is a heads -up about sampling reported bythe city regarding this
site. Mark Senior indicated that while the expected presence of sediment and metals was not extraordinary, the
concentration of PCB's was. He indicated that the concentration beyond acceptable levels was extreme, and he
suggested that we look specifically for PCB's in any sampling the state may perform downstream from the site. He also
noted that the city will be taking an additional sample to confirm the current results. I asked him to,;share,the specific
readings as soon as practical. You may want to discuss this further with him directly. Have a great Thanksgiving
everyone!
i MI

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Parnell, David
From: Holley, John
Sent: Wednesday, November 27, 2013 5:03 PM
To: Bennett, Bradley; Smith, Danny; Parnell, David
Cc: Vinson, Toby; [e-mail]
Subject: Old Garner Road Metal Recycling
As I have discussed with Toby and Danny today, this is a heads -up about sampling reported by the city regarding this
site. Mark Senior indicated that while the expected presence of sediment and metals was not extraordinary, the
concentration of PCB's was. He indicated that the concentration beyond acceptable levels was extreme, and he
suggested that we look specifically for PCB's in any sampling the state may perform downstream from the site. He also
noted that the city will be taking an additional sample to confirm the current results. I asked him to share the specific
readings as soon as practical. You may want to discuss this further with him directly. Have a great Thanksgiving
everyone!
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