NCG200363_COMPLETE FILE - HISTORICAL_20110311

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO. /V Cc,,quc) 3(0 3
DOC TYPE
DOC DATE
4=- 'HISTORICAL FILE
1-1 MONITORING REPORTS
YYYYMMDD

NCDENR
North Carolina Department of Environment and
Division of Water Quality
Beverly Eaves Perdue
Governor
Mr. Louis Gordon, Vice President
L. Gordon Iron & Metal Company
Post Office Drawer 1192
Statesville, NC 28687
Dear Mr. Gordon:
Coleen H. Sullins
Director
March 11, 2011
Natural Resources
Dee Freeman
Secretary
MAR 1 4 2011
Subject: Technical Site Visit
L. Gordon Iron & Metal Company
Certificate of Coverage No. NCG200363
Iredell County
On March 8, 2011, a site visit was conducted at the subject facility by representatives of the
Division of Water Quality's Mooresville Regional Office and Raleigh Central Office for the purpose of
evaluating existing site conditions and to offer suggestions that may improve the ability of L. Gordon
Iron & Metal (the Company) to comply with the benchmark levels established in the subject Certificate of
Coverage. Representing the Regional Office were Michael Parker and Rob Krebs, and representing the
Central Office were Michael Randall and Ken Pickle. Mr. Scott Powell with L. Gordon Iron & Metal
accompanied DWQ staff during the site visit.
As DWQ staff toured your facility, there were a number of observations made by both Regional
and Central Office staff that should be considered as you look to improve your stormwater (SW) runoff
quality. Some of these suggestions may require you to re-evaluate existing facility operations and others
may be as simple as re -locating potential contamination sources away from nearby stormwater
conveyances. As mention above, there were a number of areas identified during our visit where site
improvements may ultimately enhance your ability to contain and/or remove pollutants from your
stormwater. These suggested site improvements are listed below and are in no specific order:
First and foremost, it is important that you identify where the stormwater pipe located adjacent
to the railroad tracks and just west of the Warehouse outlets. This pipe appears to receive SW
from existing outfalls 004, 005, 006, and 007, which drain a substantial portion of the SW from
your site. If this pipe outlets into the junction box designated as outfall 009 on your site drawing,
then it may be possible to route a substantial portion of your site's SW through a redesigned BMP
that would be constructed behind the non-ferrous storage area. This BMP would also continue to
receive SW from facility operations associated with the storage bins. In reviewing recent SW
sampling data, high TSS values highlight the multiple benchmark exceedances, so some type of
pre -settling design such as fore bays, coarse or multiple settling chambers, or even dual train
configurations maybe necessary to achieve the desired results. Bear in mind any structural BMP
measure should focus first on the amount of TSS to be removed, however, consideration should
INooresville Regional Office One
-ovation: 610 East Center Avenue. Suite 301, Mooresville. NC 28115 OCarolina
Phone: [phone] \ Fax: [phone] \ Customer Service: 1-877-623-6748 rf Internet. http://portal,ncdenr.orgtwebfwq rally
An Equal opportunity \ Affirmative Action Employer - 50% Recycled/ 10% Post Consumer paper �/

Mr. Louis Gordon
March 11, 2011
Page Two
also be given to the frequency of cleaning and maintenance and access. Hopefully, the removal
of TSS will also affect a significant fraction of the metals, however, you wont really know until a
TSS removal plan is implemented. If you can contain/remove the TSS, you may see additional
benefits such as the lowering the concentrations of your other benchmark parameters.
As mentioned to you in our post tour discussion, of all the suggestions that came out of this visit,
the most important observation from an analytical testing standpoint is to try to bring your total
number of stormwater outfalls you are sampling down from the seven (7) you are currently
sampling to a more manageable two or three. If this can be accomplished, and you are able to
install some type of engineered Best Management Practice (BMP) on the remaining outfalls, a
significant reduction in the pollutants found in your stormwater may be possible. Based on
observations made during the site visit, the combining of outfalls 004, 005, 006, 007 (and possibly
008) into outfall 003 would bring you down to two outfalls.
Housekeeping is also problematic at this site. There were a number of areas where potential
contamination sources were noted at or near site boundaries that could be eliminated with some
general housekeeping. The area draining behind the bins adjacent to outfall 008 and 009 could be
cleaned up and the area stabilized with vegetation, which may improve SW quality. Stockpiled
materials along Salisbury Road near the Auto Storage area and down closer to the Office near the
storage trailers should be moved away from the site perimeter and a vegetated berm established
to prevent off -site SW migration. There were also a lot of barrels and containers located at
different points throughout the site that of themselves present potential SW risks. The barrels
and containers should be identified, characterized, and either recycled or consideration given to
locating them underneath roofs or in areas where SW contact is minimized. As required by your
permit, your Stormwater Pollution Prevention Plan (SPPP) should identify all potential pollutant
sources and describe any attempts to eliminate or minimize their exposure. If bottom access of
your ferrous and non-ferrous storage piles (as well as other stacked material piles) is not
necessary, spmething as simple as placing hay bales on the downstream (lower) side of the piles
may provide effective TSS containment. Wire mesh baskets placed in the inlet drains may
produce some TSS removal, however, this will not address the root source of the TSS and will
likely not prevent future TSS Benchmark exceedances. DWQ staff are of the opinion that
operational changes (ie. relocation of contaminant sources, moving some sources under roof,
berming or securing problematic materials from SW contact, etc.,) may go much further than
BMP construction in getting your SW back to below benchmark values. The Company should
al*D encourage their employees to look for ways to improve SW pollution awareness and
prevention You may find that your employees have suggestions on both operational and site
improvements that will improve SW quality.
• A site survey, complete with topographic constraintsiproperty lines, top of inlets, bottom of catch
basins, and gravity pipe inverts should be prepared. The survey should also follow the DOT
ditch line in the front of the property to its ultimate receiving water so the Company will know
where their SW goes once it leave the property line.

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

L> ;UEND
= DROP INLET
= DRAINAGE DIRECTION
002 = OUTFALLS 1
QS = SPILL RESPONSE EQUIPMENT
�7 r
= OIL/WATER SEPARATOR x `
ly
O
O=IMPERVIOUS SURFACES
j9
OFFSRE p'S
=DETENTION POND GASOLINE
STATION
""w =RAILROAD TRACK MUCKWASH
SANITARY SEWER
OA = OFFICE/ENTRANCE/SCALE eirfian c
® = MAINTENANCE.
© = FERROUS AREA A �.�'
= EASTERN BINS PAR
I CON T ER _
Q = NON-FERROUS AREA STOSTD E,AUTO ww
R '�" '•
® = WESTERN BINS Y
Q = SHIPPING
DSSi
FERROUS
STORAGE
® CRANE
e n fiance
j/
9 ,O
SCALES
o WELL
�•
.� RIPPING
OIL STORAGEA iSE. SAwzky DEPARTMENT
007
1)
00 SEWER SDMP :a. 005
500 GALLON GASOLINE AST 04p4 A+
2)
AT BASE OF
RAILROAD
1,000 GALLON DIESEL AST T-
3)
„��
500 GALLON USED OIL AST
APPRO};IMATE PERCENT IMPERVIOUS:
4)
55 GALLON OIL DRUMS
OUTFALL 001- 90%
5)
500 GALLON USED OIL AST
OUTFALL 003 - 95%
6)
SHREDDER WITH 3 RESERVOIRS (2-100 GALLON,
OUTFALL 004 - 20%
7)
1-150 GALLON)
THREE 55 GALLON OIL DRUMS
OUTFALL 005 - 80%
8)
500 GALLON DIESEL AST
OUTFALL 006 - 75%'
9)
BALER WITH 600 GALLON RESERVOIR
OUTFALL 007 - 90B/p
10)
TWO 55 GALLON DRUMS
OUTFALL 008 - 95%
11)
500 GALLON USED OIL AST
OUTFALL 009 -100%
12)
SHEAR WITH 1,500 GALLON RESERVOIR
13)
55 GALLON OIL DRUMS
SOURCE:
14)
BALER WITH 450 GALLON RESERVOIR
BASE MAP BY W.Z.
15)
55 GALLON OIL DRUM
BAUMGARTNER & ASSOCIATES,
V�
INC. DATED 09/1998
16)
BALER WITH 800 GALLON RESERVOIR
AND ECS FIELD NOTES
DATED 03/2010
OFFICE.
O
4 ® O NI NIONITORING
' q LOCATIO]
a
TO SANITARY
SFNER
NON-
OUS FERROUS
STORAGE
SCAr.E (IN FEET)
65 0 130
130 0
FIGURE 2
SITE PLAN
L. GORDON IRON & METAL COMPANY
1300 SALISBURY ROAD
STATESVILLE, NORTH CAROLINA
CATCH
BASIN
DUCH
ECS PROJECT NO. 09-18333

Pickle, Ken
From: Pickle, Ken
Sent: Thursday, March 10, 2011 8:48 AM
To: Randall, Mike; Parker, Michael
Cc: Krebs, Rob; Bennett, Bradley
Subject: RE: Pics from Gordon's site visit 3-9-2011
Thanks, Mike. As you say.
One other subtopic comes to mind today. Mike Parker first mentioned the ager of the facility and the possibility of
legacy soil contamination that might affect stormwater runoff. Good point. The good thing is that large areas of their
site are now under asphalt pavement. The pavement may operate to reduce the impact of contaminated soils. Scott
Powell made some comments that I'm unclear on concerning a UST and a monitor well. So, undoubtedly there is some
sort of suspicious history as far as potential for stormwater impacts, either via USTs or via past operational practices.
If we get to a point where we have addressed the obvious hot spots, and we still have a mystery about the sources,
that's when we need to remember the potential of legacy sources, it seems to me.
ken
From: Randall, Mike
Sent: Wednesday, March 09, 2011 2:37 PM
To: Pickle, Ken; Parker, Michael
Cc: Krebs, Rob; Bennett, Bradley
Subject: RE: Pics from Gordon's site visit 3-9-2011
I concur. Although I think they said it was 15 acres +/-
From: Pickle, Ken
Sent: Wednesday, March 09, 2011 1:09 PM
To: Parker, Michael; Randall, Mike
Cc: Krebs, Rob; Bennett, Bradley
Subject: RE: Pics from Gordon's site visit 3-9-2011
Thanks, Michael,
I really appreciate the invitation to see Gordon's. It's a pretty impressive site. Mike Randall and I chatted a good bit
about the Gordon site on the way home Tuesday. It occurs to me today that I might provide just a brain dump of
observations and opinions about this site. Whether they'll be useful for your next contact with Gordon's or not, I'm not
sure. But just in case, I'll make my comments.
Mike Randall, do you have anything to add?
Brain dump comments:
• Impression: Scott Powell may be experienced in H&S, but he needs some help/training/direction in
environmental. I may be wrong, but I'm not confident in the integrity of his sampling procedures, outfall
selection, hold times, etc. His lab contractor should provide training on how to sample. Mike Parker, I think you
indicated concerns along the same lines. I concur.
Opinion: As safety manager, Scott needs to provide secure access to his sampling points. Scrambling down wet
slopes to those sampling points is asking for a problem.

INFILTRATION TRENCH No.
5
Project: Piedmont Traid Ambulance & Rescue
Engineer: H. Mack Summey, Jr.
Impervious Area (la)=
0.0138
ac.
Da (contributing drainage area) =
0.019949
ac.
Volume of trench required (includes .4 Porosity) =
121.6
cu. ft.
Length of trench provided =
20.0
ft.
Width of trench provided =
2.5
ft.
Depth of trench provided =
2.5
ft.
Soil type =
sandy clay loam
Infiltration rate =
0.011
Volume of trench provided =
125
Time to dewater trench =
3.9
days
Infiltration Rate (field test) =
2.5
In/hour
Rd = Design Rainfall =
1
Inch
la = BUA/Da
0.690
Rv = .05+0.9 x la
0.671
Volume of Runoff to Treat = 3630 x Rd x Rv x Da
48.620
CF
INFILTRATION TRENCH No.
Project: Piedmont Traid Ambulance & Rescue
Engineer: H. Mack Summey, Jr.
Impervious Area (la)=
Da (contributing drainage area) _
Volume of trench required (includes .4 Porosity) _
Length of trench provided =
Width of trench provided =
Depth of trench provided =
Soil type =
Infiltration rate =
Volume of trench provided =
Time to dewater trench =
Infiltration Rate (field test) _
Rd = Design Rainfall =
la = BUA/Da
Rv = .05+0.9 x la
Volume of Runoff to Treat = 3630 x Rd x Rv x Da
0.0110
ac.
0.01669
ac.
97.0
cu. ft.
15.0
ft.
3.5
ft.
2
ft.
sandy clay loam
0.011
105
3.4
days
2.5 In/hour
1 Inch
0.656
0.640
38.803 CF

Scott mentioned missing a sampling period because rains occurred after hours. I think we should take a pretty
hard line on sampling obligations, and I use something like this to guide my thinking on it:
o Acceptable excuses: Complete drought (for example, 2007— 2008); night time rains only during the
sampling period; other dangerous conditions (over -bank flow at sampling point; hurricane conditions
were the only rains we had; high winds accompanied the only rains we had during the period; etc.);
o Unacceptable excuses: I forgot; I'm new at this job; I was on vacation when the rains came; The previous
environmental manager left; I thought we had a year to get the SPPP implemented; I didn't realize we
had to sample every outfall; it only rained on the weekends (TS, work it out); our lab won't take samples
after Thursday, and we only had Friday rains this period (TS, work it out);
o Remedy for missing: RO discretion to either fully excuse for good reason; or to advise permittee to just
catch up and sample two events in the next period; or to generate NOV for unacceptable excuses, or just
to be more lenient than my fairly strict outline above.
• Gordon's preparatory work: dye test to trace the main mystery culvert; ground survey (a physical features
survey, a topo survey, a property line survey, top of inlets, bottom of catch basins, gravity pipe inverts.) I doubt
that Scott has experience commissioning a survey. Get together with an experienced engineer as Mike Randall
advised. His engineer needs to understand the objective of the work, and needs to include all the elements
listed above as to survey information to be retrieved. Alternatively, we can advise him. I'm just concerned that
a surveyor may or may not understand the purposes of his work, and so may leave out some of these elements
unless specifically directed to include them. Further, in a side conversation I separately advised Scott that the
scope of the survey should be from property line to property line, PLUS a little. I mean, the survey needs to
follow the DOT ditch line to its ultimate receiving water. He needs to understand what happens for the next
`200' beyond his major outfall point on the front. He needs to get that one outfall across the tracks from the
scales in the back of the property. He needs to understand where the off -site drainage goes at the corner where
the rad waste box was located. Etc —follow the surface flow, notjust to the fence line, but enough beyond to be
sure that relevant off -site conditions are accounted for.
• 1 don't like the o/w separator outfall at the front gate. It's legal, but I don't like it. Scott will have to sample
there as one of the outfalls. My opinion is that the o/w separator should NOT be eligible for representative
outfall status. As per Mike Randall's input, these things are extremely susceptible to poor/none maintenance.
• 1 like Rob's observation that a little housekeeping along the margins of the site could go a long way. Re-establish
the berms along the street. I think Rob also mentioned the opportunity for vegetated strips along the margins
of the property. Obviously won't work on the drive areas, but a very good idea where they can be made to work
- - like perhaps on the short side of the property, and perhaps along the back fence, and perhaps along portions
of the front fence.
• It's good that they have a street sweeper. On a couple of occasions Scott responded that they sweep daily.
Really? Conforming to a daily schedule should be high priority because it's effective, and it's cheap. (Where are
they putting the sweepings?)
• Using my observation of the used oil tank as the exception that proves the rule: We just walked by without
comment lots and lots of barrels and containers that were obviously a stormwater risk. We didn't even walk
over to the shop and have a look around — you know there would be opportunities for improvement at that hot
spot. Scott and Gordon's need a comprehensive appreciation of their site vis-a-vis stormwater pollutant
sources. They don't have that now. Which is understandable when you consider that they have "26 acres of
sources. I think it's totally legitimate to feel some sympathy for the principle of, "It's hard to see the trees for
the forest."
• Scott asked about hay bales around the piles. I asked if they needed 360 degree access around the piles. If they
don't, then hay bales on the low -half side of each pile might be helpful.
• Opinion: This permittee needs to understand that a stormwater permit is not like a Building Permit — Jump
through the hoops one time, and you don't have to think about it for another 30 years, if you're lucky. This is a
change in the mindset of the permittee. A stormwater permit carries with it a continuing obligation to manage,
day -in and day -out, the site conditions to minimize stormwater impacts. Folks need to get past the Building
Permit mindset. My judgment is that heretofore Gordon's has not been acting in accordance with our vision of
what a stormwater permit is.

INFILTRATION TRENCH No.
7
Project: Piedmont Traid Ambulance & Rescue
Engineer: H. Mack Summey, Jr.
Impervious Area (la)=
0.0411
ac.
Da (contributing drainage area) =
0.056818
ac.
Volume of trench required (includes .4 Porosity) =
361.8
cu. ft.
Length of trench provided =
37.0
ft.
Width of trench provided =
4
ft.
Depth of trench provided =
2.5
ft.
Soil type =
sandy clay loam
Infiltration rate =
0.011
Volume of trench provided =
370
Time to dewater trench =
5.0
days
Infiltration Rate (field test) =
2.5
In/hour
Rd = Design Rainfall =
1
Inch
la = BUA/Da
0.724
Rv = .05+0.9 x la
0.702
Volume of Runoff to Treat = 3630 x Rd x Rv x Da
144.714
CF
INFILTRATION TRENCH No.
K
Project: Piedmont Traid Ambulance & Rescue
Engineer: H. Mack Summey, Jr.
Impervious Area (la)=
Da (contributing drainage area) _
Volume of trench required (includes .4 Porosity) _
Length of trench provided =
Width of trench provided =
Depth of trench provided =
Soil type =
Infiltration rate =
Volume of trench provided =
Time to dewater trench =
Infiltration Rate (field test) _
Rd = Design Rainfall =
la = BUA/Da
Rv = .05+0.9 x la
Volume of Runoff to Treat = 3630 x Rd x Rv x Da
0.0677
ac.
0.082553
ac.
590.2
cu. ft.
75.0
ft.
4
ft.
2
ft.
sandy clay loam
0.011
600
4.1
days
2.5 In/hour
1 Inch
0.820
0.788
236.084 CF

KBP concern: I'm a little concerned that Scott reported to Louis Gordon about the two areas we evaluated as
suitable for BMPs. There was a bit of flavor to his report, at least in my ears, of'DWQ told us to move the
trailers.' The benchmark exceedances are their problem, and the solutions attempted are their solutions not
ours. I don't want Gordon's to think that we share responsibility for the solution. Do we care? Of course. But
the problem belongs to them, not us. We may just want to keep our ears open in case we see Gordon going
further down this road.
• As Mike Randall pointed out, the wire mesh, or perforated plate, baskets that Scott proposes to fabricate for a
couple of the internal catch basins are ok. But they are not going to have a great effect on the discharge TSS.
Their main positive attribute is that they are cheap.
• The tiered approach in our stormwater permits lends itself to an incremental, step -wise approach to solving the
issues at a difficult site. This is a perfect fit with Gordon. They will not be able to do it all at once, regardless of
how deep their pockets. It's not the money, it's the knowledge and understanding necessary to implement
effective solutions that will take time to develop. I'm not sure there is anyone on site able to make that kind of
continuing commitment. They need an on -going relationship with some lucky consulting environmental
engineer.
• 1 think it was Mike Randall that indicated that operational changes (rather than structural BMPs) might be a
valuable part of the mix in getting this stormwater back under benchmark values. Can they increase
effectiveness of the sweeping? Can they move some operations indoors? Can they move the stockpiling of
especially problematic materials indoors? Can they curtail certain operations in anticipation of approaching
weather fronts? Can they employ new shed roofs or concrete containment areas for certain hot sources? These
are operational issues that only the permittee can evaluate.
• Can they train their employees in stormwater pollution awareness and prevention? They seem to be a fairly
employee oriented business. Can they set up an award for implemented ideas?
• As I suggested at the end of our day together, these guys are proud of their company. Once they see that
progress is not hopeless, would they be a candidate to voluntarily go above and beyond?
• KBP hope: More on the gigantic scope of their problems: I think these folks are just victims of the combination
of not knowing what to do, not understanding that they really can act to make a difference, and not being
familiar with an environmental problem solving mindset. To use Mike Parker's word, this site is a 'showcase' in
the making. If we can sell Scott and Gordon's on a before/after vision, I think it would be a great facility for the
industry to learn from.
• The high TSS content screams out for utilization of the pre -settling concept. Forebays, or coarse settling
chambers, or multiple chambers, or dual train configurations, or vegetated filter strips, or ditches with check
dams (not adjacent to the RR ballast however), etc. Any structural BMP measure should focus first on the great
amount of TSS, and the frequent cleaning and maintenance (i.e. Heavy equipment access, disposal of the solids,
ease of maintenance, warning provisions to signal when it's time for maintenance, etc.)
• Removal of TSS may take with it some significant fraction of the metals. We really won't know how much until
we try. This is the benefit of a stepped or incremental approach. Get the TSS first. See what's left. If it's still a
problem take the next step. Speed of improvement dependent upon willingness of the permittee, physical facts
of the site, and RO judgment on appropriate progress.
• Not just Scott Powell, but the Messrs. Gordon need to buy into the vision and the obligation for this site. They
need to be converted.
My brain is empty. Didn't take long, either.
Mike Randall, any comments for MRO?
Ken
From: Parker, Michael
Sent: Wednesday, March 09, 2011 8:18 AM
To: Randall, Mike; Pickle, Ken

Permit No.
(to be provided by DWO)
FvvllarFgoc
STORMWATER MANAGEMENT PERMIT APPLICATION FORM
NCDENR 401 CERTIFICATION APPLICATION FORM o
INFILTRATION TRENCH SUPPLEMENT
This form must be filled out, printed and submitted.
The Required Items Checklist (Part III) must be printed, filled out and submitted along with all of the required information,
vroleci name
Contact person
Phone number
Date
Drainage area number
Site Characteristics
Drainage area
Impervious area
Percent impervious
Design rainfall depth
Peak Flow Calculations
1-yr, 24-hr rainfall depth
1-yr, 24-hr intensity
Pre -development 1-yr, 24-hr discharge
Post -development 1-yr, 24-hr discharge
Pre/Post 1-yr, 24-hr peak Flow control
Storage Volume: Non -SA Waters
Minimum volume required
Volume provided
Storage Volume: SA Waters
1.5" runoff volume
Pre -development 1-yr, 24-hr runoff volume
Post -development 1-yr, 24-hr runoff volume
Minimum volume required
Volume provided
Soils Report Summary
Soil type
Infiltration rate
SHWT elevation
Trench Design Parameters
Drawdown time
Perforated pipe diameter
Perforated pipe length
Number of laterals
Stone type (if used)
Stone void ratio
Stone is free of fines?
Piedmont Triad Ambulance & Rescue
H. Mack Summey, Jr., PE
336-328-0902
1
10,142.00 ftz
9,237.00 ft2
91.1% %
1.00 in
2.79
in
0.12
in/hr
0.01
ft'Isec
0.02
ft3/sec
0.01
ft'/sec
735.02 ft3
1,837.60 ft3
ft3
ft3
ft3
ft3
ft3
Sandy Clay Loam
2.50 in/hr
96.20 fmsl
OK for non -SR waters
4.90
days OK
0.00
in
0.00
ft
0
57
0.4
y
(Y or N) OK
Form SW401-Infiltration Trench-Rev.4 Parts I. & II. Design Summary, Page 1 of 2

Cc: Krebs, Rob
Subject: Pics from Gordon's site visit 3-9-2011
Enjoy!
Michael Parker - [e-mail]
Environmental Engineer II
North Carolina Dept. of Environment & Natural Resources
Division of Water Quality
610 East Center Avenue
Suite 301
Mooresville, NC 28115
Ph: [phone] Fax: [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.

Permit No.
(to be provided by DWQ)
Trench Elevations
Bottom elevation
99.20
fmsl
OK
Storage/overflow elevation
102.20
fmsl
Top elevation
102.20
fmsl
Trench Dimensions
Length (long dimension)
125.00
It
Width (short dimension)
8.00
It
Height (depth)
2.00
It
OK
Additional Information
Maximum volume to each inlet into the trench?
0.04
ac-in
OK
Length of vegetative filter for overflow
30.00
ft
OK
Number of observation wells
1
OK
Distance to structure
15.00
ft
OK
Distance from surface waters
30.00
ft
OK for non -SA waters
Distance from water supply well(s)
1,000.00
ft
OK
Separation from impervious soil layer
6.00
it
OK
Depth of naturally occuring soil above SHWT
6.00
It
OK
Bottom covered with 4-in of clean sand?
y
(Y or N)
OK
Proposed drainage easement provided?
y
(Y or N)
OK
Capures all runoff at ultimate build -out?
y
(Y or N)
OK
Bypass provided for larger storms?
y
(Y or N)
OK
Trench wrapped with geotextile fabric?
y
(Y or N)
OK
Pretreatment device provided
grass strip prior to trench
Porm SW401-Infiltration Trench-Rev.4 Parts I. & II. Design Summary, Page 2 of 2

ISRI ®Iz.
THE GPIGINPL PECVGtfPS�
Gordon Recyclers, Inc.
dba L. Gordon Iron And Metal Co.
P.O. Drawer 1 192
Statesville, North Carolina - 28687
Tel [phone]
Fax [phone]
January 10, 2008
North Carolina Division of Water Quality
Water Quality Section
Storm water and General Permits Unit
1617 Main Service Center
Raleigh, NC 27699-1617
Subject: Representative Outfall Status
L. Gordon Iron & Metal Company
1300 Salisbury Road
PO Drawer 1192
Statesville, NC 28687
To Whom It May Concern:
"4N 14
L. Gordon Iron & Metal Company has recently added additional outfalls to more effectively manage storm
water at our facility. We request representative outfall status for Outfalls 003 and 005. Based on the
similarity of facility operations that have the potential to impact storm water, outfall 003 is representative
of the storm water quality expected to be discharged through Outfalls 001, 002, 003, 006, 007, and 008;
while outfall 005 is representative of storm water discharged from Outfalls 004 and 005.
Based on the granting of representative outfall status, we will conduct Annual Analytical Monitoring of
Outfalls OO and 005 but continue semi-annual qualitative monitoring of all outfalls (with the exception of
004). Please note that Outfall 004 is at the base of a steep railroad embankment and is not accessible.
Therefore, Outfall 004 will not be visually monitored for semiannual events. The site plan indicating the
outfall locations, the drainage patterns and the industrial activities is attached.
We appreciate your attention to this request. If you have any questions or require additional information,
please contact me at [phone].
Sincerely,
Mr. Louis Gordon
Vice President
Attachment: Site Plan
A Tradition of Conserving Natural Resources Since 1917

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/ CONQVEIE III4IN \ OY.fl1
OIL STORAGE/USE:
O 500—GAL GASOLINE AST
Q 1,000—GAL DIESEL AST
Q 500—GAL WASTE OIL AST
Q 500—CAL WASTE OIL AST
O] SHREDER WITH 3 RESERVOIRS ( 2-100 CAL., 1-150 GAL.)
O THREE 55—GAL DRUMS
O 500—GAL DIESEL AST
Q BALER WITH 600—GAL. RESERVOIR
O TWO 55—GAL. DRUMS
10 500—GAL WASTE OIL AST
11 SHEAR WITH 1.500 GAL RESERVOIR
12 BALER WITH 450-GAL RESERVOIR
1] BALER
ClD S UMURY ROAD
' BNS
\ ".2
CpICTETE � q
STAPLESS
STORAGE
NW-REt
STgtAGE
SCALE (IN FEET)
65 130
130 0
REFERENCE:
BASE MAP BY
W.Z.BAUMGARTNER &
ASSOCIATES, INC.
DATED 09/25/98
13 9
I
MP RAP mmH EcTILS
LEGEND:
❑ = DROP INLET
y = DRAINAGE
mx = OUTFALLS
® = OIL WATER SEPERATOR
• = RETENTION POND
= RAILROAD TRACK
OENTRACE/SCALE
ONON-FERROUS WAREHOUSE/STORAGE
© FERROUS AREAS
OMAINTENANCE
SITE FEATURES AND OIL STORAGE
UNIT(S) LOCATION(S) ARE
APPROXIMATE
CAROLINAS
FIGURE 2
SITE PLAN
L. GORDON IRON & METAL
COMPANY
1300 SALISBURY ROAD
STATESVILLE, NORTH CAROLINA
PROJECT NO. 09.15194
DRAWN BY/DATE
WIO-10/29/2007
1 CHECKED BY/DATE

Michael F. Fasley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
November 20, 2006
Louis Gordon
L Gordon Iron & Metal Co
PO Drawer 1192
Statesville NC, 28687
Subject: NPDES Stormwater Permit Coverage Renewal
L Gordon Iron & Metal Co
CDC # NCG200363
Iredell County
Dear Permittee:
In response to your renewal application for continued coverage under general permit NCG200000 the Division of
Water Quality (DWQ) is forwarding herewith the reissued stormwaler general permit. Due to resource constraints,
the Division has been unable to adequately consider appropriate modifications to the permit. Therefore, the permit
has been reissued without changes from the previous permit, so all conditions remain the same. The permit term for
the reissued permit is two years, expiring on September 30, 2008. The general permit may be modified and reissued
prior to its expiration. The permit is reissued pursuant to the requirements of North Carolina General Statute 143-
215.1 and the Memorandum of Agreement between the state of North Carolina and the U.S. Environmental
Protection Agency, dated December 6, 1983.
The following information is included with your permit package:
A new Certificate of Coverage
A copy of General Stormwater Permit NCG200000
Your coverage under this general permit is not transferable except after notice to DWQ. The Division may require
modification or revocation and reissuance of the Certificate of Coverage. This permit does not affect the legal
requirements to obtain other permits which may be required by DENR or relieve the permittee from responsibility for
compliance with any other applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or
decree.
If you have any questions regarding this permit package please contact Yadkin -Pee Dee of the Central Office
Stormwater Permitting Unit at [phone], ext. Bethany Georgoulias.
Sincerely,
Bradley Bennett, Supervisor
Stormwater and General Permits Unit
cc: Central Files
Stormwater & General Permits Unit Files
Mooresville Regional Office
Nor"
IhCarolina
Naturally
Wetlands and Stornnvater Branch 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone]
Internet: h2o.enrstaleoc.us 512 N. Salisbury St. Raleigh, NC 27604 FAX [phone]
An Equal OpportunitylAKrmadve Action Employer — 50% Recycled110% Post Consumer Paper

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG200000
CERTIFICATE OF COVERAGE No. NCG200363
STORMWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission,
and the Federal Water Pollution Control Act, as amended,
L GORDON IRON & METAL CO
is hereby authorized to discharge stormwater from a facility located at
L Gordon Iron & Metal Co
1300 Salisbury Rd
Statesville
Iredell County
to receiving waters designated as , a class Unnamed Tributary to Third Creek stream, in the C River
Basin in accordance with the effluent limitations, monitoring requirements, and other conditions set forth
in Parts I, II, III, IV, V, and VI of General Permit No. NCG200000 as attached.
This certificate of coverage shall become effective November 20, 2006.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day November 20, 2006
for Alan W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

Michael 17. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division or Water Quality
July 25, 2005
Louis Gordon
L Gordon Iron & Metal Co
PO Drawer 1192
Statesville, NC, 28687
Subject: NPDES Stormwater Permit Coverage Renewal
L Gordon Iron & Metal Co
COC Number NCG200363
Iredell County
Dear Permittee:
Your facility is currently covered for stormwater discharge under General Permit NCG200000. This permit expires on
October 31, 2005. The Division staff is currently in the process of renewing this permit. When a draft version is
available for notice and public comment, it will be posted on our website at http://h2o.enr.state.nc.us/su/. Once
the permit is reissued, your facility would be eligible for continued coverage under the reissued permit.
In order to assure your continued coverage under the general permit, you must apply to the Division of Water
Quality (DWQ) for renewal of your permit coverage. To make this renewal process easier, enclosed you will find a
Permit Coverage Renewal Application Form. The application must be completed and returned by August 19, 2005 in
order to assure continued coverage under the general permit. Letters confirming our receipt of the completed
application will not be sent.
Failure to request renewal within the time period specified may result in a civil assessment of at least $250.00.
Larger penalties may be assessed depending on the delinquency of the request. Discharge of stormwater from your
facility without coverage under a valid stormwater NPDES permit would constitute a violation of NCGS 143-215.1 and
could result in assessments of civil penalties of up to $10,000 per day.
Please note that "no exposure exclusion" is now available to all operators of industrial facilities in any of the
categories of "storm water discharges associated with industrial activity," (except construction activities). If you feel
your facility can certify a condition of "no exposure", i.e. the facility industrial materials and operations are not
exposed to stormwater, you can apply for the no exposure exclusion. For additional information contact the Central
Office Stormwater Staff member listed below or check the Stormwater Permitting Unit Web Site at
http://h2o.enr.state.nc.us/su/.
If the subject stormwater discharge to waters of the state has been terminated, please complete the enclosed
Rescission Request Form. Mailing instructions can be found on the bottom of the form. You will be notified when
the rescission process has been completed.
If you have any questions regarding the permit renewal procedures please contact Bethany Georgoulias of the
Central Office Stormwater Permitting Unit at [phone], ext. 529.
Sincerely,
Bradley Bennett
Supervisor, Stormwater & General Permit Unit
Cc: Central Files
Mooresville Regional Office
SWPU Files
Om
Nu�'thC;u'olina
Aatrrra/!y
Wetlands and Stormwater Branch 1617 Mail Service Center Raleigh, NC 27099-1617 Phone [phone]
Internet h2o.em.state.nc.us 512 N- Salisbury St. Raleigh, NC 27604 FAX [phone]
An Equal Opportunity/Affirmative Action Employer— 50 % Recycled/10% Post Consumer Paper

State of North Carolina
Department of Environment
and Natural ReSOUices
Division of Water Quality
Michael F. Easley, Governor
Sherri Evans -Stanton, Acting Secretary
Kerr T. Stevens, Director
LOUIS GORDON
L. GORDON IRON AND METAL CO.
P.O. DRAWER 1192
STATESVILLE, NC 28687
Dear Permittee:
January 16, 2001
A-
...
1
NCDENR
NORTH CAROUNA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: Reissue - NPDES Stormwater Permit
L. Gordon Iron and Metal Co.
COC Number NCG200363
Iredell County
In accordance with your application for a discharge permit received on July 31, 1995 we are forwarding herewith
the subject certificate of coverage to discharge under the subject state - NPDES general permit. This permit is
issued pursuant to the requirements of North Carolina General Statute 143-215 .I and the Memorandum of
Agreement between North Carolina and the US Environmental Protection agency dated December 6. 1983.
If any parts, measurement frequencies or sampling requirements contained in this permit are unacceptable to you,
you have the right to request an individual permit by submitting an individual permit application. Unless such
demand is made, this certificate of coverage shall be final and binding.
Please take notice that this certificate of coverage is not transferable except after notice to the Division of Water
Quality. The Division of Water Quality may require modification or revocation and rcissuance of the certificate of
coverage.
This permit does not affect the legal requirements to obtain other permits which may be required by the Division of
Water Quality or permits required by the Division of Land Resources, Coastal Area Management Act or any other
Federal or Local governmental permit that may be required.
Enclosed is a permit package which contains the following information:
* A copy of general Stormwater permit NCG200000
* Five copies of the Analytical Monitoring form and five copies of the Qualitative Monitoring form
* A copy of a Technical Bulletin for the general permit which outlines key requirements and addresses
frequently asked questions
* A Certificate of Coverage
If you have any questions concerning this permit, please contact Aisha Lau at telephone number [phone] est.
578.
Sincerely,
rml�lI�U11.SIGNr! � "
forSteCv�etTIS MILLS
cc: Central Files
Stormwater and General permits Unit Files
Mooresville Regional Office
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] Fax [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG200000
CERTIFICATE OF COVERAGE No. NCG200363
STORMWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the
Federal Water Pollution Control Act, as amended,
GORDON INDUSTRIES, INC.
is hereby authorized to discharge stormwater from a facility located at
L. GORDON IRON AND METAL CO.
IREDELL COUNTY
to receiving waters designated as an unnamed tributary to Third Creek, a class C stream, in the Yadkin - Pee Dee
River Basin in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in
Parts I, 11, III, IV, V, and VI of General Permit No. NCG200000 as attached.
This certificate of coverage shall become effective January 16, 2001,
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day January 16, 2001.
t7RIGlNIILSIGNE71 ^Y
WEI UAM C. M!Ls S
for Kerr T. Stevens, Director
Division of Water Quality
By Authority of the Environmental Management Commission

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W. Z. BAUMGARTNER & ASSOCIATES INC.
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BRENTWOOD, TENNESSEE 37024 A

FACILITY
COUNTY
NPDES i
'' AIC G cp D ' 3
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MAP #
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63
LATTITUDE
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RECEIVING STREAM
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EXPIRATION DATE
1-tMA/A-ME✓D-rAI3u7A-Iz� To ?-Hif9b CREUK
10 C-
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08-3/—q-7

State of North Carolina
Department of Er-vironment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
November 9, 2000
SAUL GORDON
L. GORDON IRON AND METAL CO.
P.O. DRAWER 1192
STATESVILLE, NC 28687
1
o ®
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: NPDES Stormwater Permit Renewal
L. Gordon Iron and Metal Co.
COC Number NCG030363
IredelI County
Dear Permittee:
The general stormwater permit for scrap metal recycling industries, NCG200000, was issued on
November 1, 2000. Since there has been a considerable time lag since your permit application was received on.
July 31, 1995 this letter is being sent to ensure that the contact information that we have is correct.
Enclosed with this letter you should find a contact information update form with the information that the
Division has on your facility. Please check to see whether or not this information is correct. If any of the
information has changed from what our records show, please make the appropriate corrections in the empty
blanks to the right of the information and mail the corrected form to us by December 8, 2000. Sign and mail the
information form regardless of whether or not any changes need to be made.
Upon receipt of your information form you will be mailed a Certificate of Coverage with a new number of the
format NCG200***. if you were one of the few facilities that received coverage under the NCG030000 general
permit prior to the issuance of this permit your existing NCG030000 permit coverage will be rescinded
concurrent with the issuance of your new Certificate of Coverage.
Thank you for your continued cooperation in complying with the Federal NPDES stormwater permitting
program. If you have any questions regarding this request please contact Ms. Valery Stephens at
[phone], ext. 520.
Sincerely,
Bradley Bennett, Supervisor
Stormwater and General Permits Unit
cc: Stormwater-and General Permits Uni-t D
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper