NC0089109_Plan of Action_20200416

TIMOTHY R. BASILONE
Vice President — Environmental Affairs
ZK AMERICAN
ZINC RECYCLING 3000 GSK Drive T 724-773-2223 www.azr.com
Suite 201 F 412-788-4526 [e-mail]
Delivering a Sustainable Future Moon Township, PA 15108
April 16, 2020
Division of Water Resources
WQ Permitting Section - NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
(Electronic Version Only (pdf and CD))
Division of Water Resources
Water Sciences Section
1621 Mail Service Center
Raleigh, NC 27699-1621
(Electronic Version (pdf and CD) and Hard Copy)
Re: Revised Fish Tissue Monitoring Plan
NPDES Permit NCO089109
American Zinc Products
Condition Part I, A. (4.)
In accordance with NPDES Permit NCO089109 issued to American Zinc Products (AZP) in Rutherford County,
NC, enclosed is a Revised Fish Tissue Monitoring Plan (Revised Plan) developed for the collection,
preparation and chemical analysis of fish samples collected from the Broad River upstream and downstream
of AZP's permitted discharge outfall. The Revised Plan was edited to address comments provided to AZP by
DWR in a letter dated December 20, 2019, and according to permit condition Part I, A. (4). A responsiveness
summary is included to facilitate the Department's review of the Revised Plan.
The Revised Plan identifies certified labs that may be used for the analytical evaluation of samples that are
collected. A list of potential contractors for field work, including the collection of fish and sample
preservation is also provided. This information does not represent a commitment by AZP to use any of the
listed contractors or laboratories. AZP will select appropriate and qualified service providers to perform
monitoring activities in accordance with the approved monitoring plan.
Following agency approval of the monitoring plan, AZP will follow the revised plan to perform monitoring
within the current permit cycle. Results from monitoring activities will be included with the Company's
application for renewal of the NPDES Permit that is submitted to the Department.
Please advise me if you have any questions. Thank you for your attention to this matter.
Sincerely,
zxj�
Timothy R. Basilone
Encl.

Responsiveness Summary AZR Fish Tissue Revised Monitoring Plan and DWR Review Comments (12/20/2019)
• Note addition of CZR Inc. Environmental Consultants Wilmington NC to contractor list.
• Duplicate samples of two duplicates per site for a total of four duplicates
Comment: As stated in the permit, fish tissue monitoring of arsenic (As), cadmium (Cd), and zinc (Zn) must be
performed once during the 5-year AZR NPDES permit cycle. For clarity please include these terms in the beginning of
the AZR fish tissue monitoring plan, as well as in the final report.
Response: Page one of the AZR revised Fish Sampling Plan incorporates the exact requirements of the NPDES Fish
Tissue Monitoring requirement and is reproduced in the plan and labeled as Permit Item A. (4).
2. Comment: Please omit the last two paragraphs on page 2 through page 4 (including Figure 1 and Table 1). The referenced
2019 NCDWR fish tissue monitoring activities were conducted via internal agency request, and not specifically intended
to serve as a model for NPDES fish tissue contaminant monitoring of the Broad River. However, it would be reasonableto
list those species collected by DWR in 2019, and to specify which of those species are being targeted for the required
AZR fish tissue monitoring.
Response: The requested deletions have been made as requested. Target species have been identified based on the
DWR suggestions and the 2019 collections.
Comment: The plan should outline AZR's proposal to compare arsenic (As), cadmium (Cd), and zinc (Zn) fish fillet
concentrations from two separate locations in the vicinity of the AZR waste water discharge (upstream control, and
downstream). Site boundaries should be separated by a reasonable distance (— 1 mile) to characterize the potential impact
of AZR's waste water discharge on As, Cd, and Zn concentrations in fish. All of the current NPDES fish tissue monitoring
plans in the state of North Carolina share this paradigm of upstream -downstream comparisons for the purpose of
determining a facility's potential impact on fish contaminant levels.
Response: The AZR revised Fish Sampling Plan incorporates two monitoring locations, one upstream and one
downstream of the AZR facility.
4. Comment: The boundaries of the proposed downstream fish collection reach are reasonable and therefore will be
accepted as is.
Response: No changes necessary related to this comment.
5. Comment: We suggest placement of the upstream sample reach (control) to be above the Jack McKinney Road bridge
(approximately 3 river miles above the AZR waste water discharge), to create considerable distance between the two
reaches and provide similar habitat types and species assemblages for contaminant comparisons.
Response: The AZR revised Fish Sampling Plan incorporates the addition of a Broad River sampling reach from the Jack
McKinney Road Bridge to one mile downstream.
6. Comment: The plan should outline an attempt to collect 10 individuals of 3 targeted species from both sample reaches
(total of 30 fish from each sample reach), with a minimum of 6 individuals per species meeting the permit requirement
(total of 18 fish from each sample reach).
Response: The revised Fish Sampling Plan now targets a goal of 3 species composed of 10 individual fish at each location
with a minimum objective goal of 18 fish from each location.
7. Comment: Based on the NCDWR's 2019 fish collections, the most likely target species in this section of the Broad River
include Largemouth Bass (top predator), Redbreast Sunfish (mid-trophic insectivore), and Notchlip Redhorse (mid-
trophic omnivore). Other suitable species of bass, sunfish, suckers, catfish, or carp should also be retained during
collection efforts. These fish samples may be submitted for analysis if target species are absent or low in numbers, or as
supplemental observations.
Response: The AZR revised Fish Sampling Plan has incorporated the suggested primary target species and the secondary
target species as identified in the DWR comments.
8. Comment: In the final monitoring report, please provide data comparisons to fish consumption screening levels set by the
North Carolina Department of Health and Human Services (NCDHHS) and the Environmental Protection Agency.
Response: AZR is aware that EPA and NCDHHS fish tissue screening levels may be established based on different
assumptions at different times and for different purposes. AZR will reference established standards and criteria and other
such information available at the time the monitoring report is submitted. AZR will submit a final fish monitoring report
with the NPDES permit renewal application as required in our NPDES permit Item A.(4.).

Revised Fish Tissue Sampling Plan
American Zinc Recycling, LLC NPDES Permit Condition
Permit Item A. (4.)
Revised March, 2020
11Page
Fish Tissue Sampling Plan American Zinc Recycling NPDES NCO089109

Introduction
This Sampling Plan is designed to assist with the planning and responses necessary for the
successful compliance of the Fish Tissue Monitoring Condition included in the American Zinc
Recycling (AZR), LLC Forest City, Rutherford County NPDES Permit NC0089109. The Permit
as modified is scheduled with an effective date of June 1, 2019. This Study Plan was revised
based on NCDWR Comments dated December 20, 2019. The NPDES Fish Tissue Monitoring
requirement is included as Permit Item A. (4.) as follows (taken directly from the permit):
A. (4.) FISH TISSUE MONITORING
[G. S. 143-215.1(b)]
The facility shall conduct fish tissue monitoring once during the permit cycle and submit the
results with the NPDES permit renewal application. The objective of this monitoring is to
evaluate potential uptake of pollutants by fish tissue near the facility's discharge. The
parameters analyzed in fish tissue shall be arsenic, cadmium, and zinc. The monitoring shall
be conducted in accordance with the sampling plan approved by the Division. The plan should
be submitted to the Division within 180 days from the effective date of the permit modification.
Upon approval, the plan becomes an enforceable part of the permit.
Copies of all the study plans, study results, and any other applicable materials should be
submitted to:
1) Electronic Version Only (pdf and CD) 2) Electronic Version (pdf and CD) and Hard Copy
Division of Water Resources Division of Water Resources
WQ Permitting Section - NPDES Water Sciences Section
1617 Mail Service Center 1621 Mail Service Center
Raleigh, NC 27699-1617 Raleigh, NC 27699-1621
Objectives
All fish tissue sampling performed by American Zinc Recycling (AZR) will be conducted based
on an approved sampling plan (this plan) according to the NPDES permit condition. Any
exceptions to this approved Sampling Plan either due to unforeseen logistical challenges,
difficulty in obtaining target species, safety concerns or other issues will be specifically detailed
in writing and communicated to the NCDWR either during or after field sample collections are
performed.
The purpose of this Sampling Plan is to document sample collection and analytical procedures to
be followed by AZR contractors for the collection and processing of fish samples for analysis of
Arsenic, Cadmium, and Zinc as may be found in the edible portion (fillet) of target species in the
vicinity of the AZR waste water discharge. After obtaining the appropriate fish samples, fillet
portions will be processed and delivered to a North Carolina certified laboratory for total arsenic,
total cadmium, and total zinc. Results from this sampling and laboratory analysis will be
reported to the NCDWR with the next AZR NPDES permit renewal application as specified in
the current NPDES permit under: A. (4.) FISH TISSUE MONITORING.
It is the goal of this Sampling Plan to obtain ten individual fish for each of three different target
species at two different locations. One location will be geographically upstream of the AZR
facility and another location will be located geographically downstream of the facility. All fish
submitted for chemical analysis will be representative of edible sizes. This goal, if attainable,
2[Page
Fish Tissue Sampling Plan American Zinc Recycling NPDFS NCO089109

will represent a total of 60 individual fish fillet samples for total arsenic, total cadmium, and total
zinc. Sample duplicates will also be submitted for laboratory analysis on four samples.
Sampling Target Species
The resident fish species of the Broad River near the American Zinc Recycling (AZR) facility
are expected to include a number of different fish species based on North Carolina Division of
Water Resources (NCDWR) fish sampling conducted on March 13, 2019. NCDWR Water
Sciences Staff collected fish samples from the Broad River both upstream and downstream of the
AZR facility's discharge. The following eight species were collected for metals analysis by
NCDWR in March of 2019:
Bluegill Sunfish Notchlip Redhorse (Sucker)
Brassy Jumprock (Sucker) Redbreast Sunfish
Flat Bullhead Smallmouth Bass
Largemouth Bass White Sucker
Based on the results of NCDWR fish collection sampling efforts in March 2019, this AZR
Sampling Plan represents a lofty goal. At a minimum, this AZR Sampling Plan will strive for
representation at each location with at least three edible species and a minimum of at least six
individuals from each species selected from the target species list. Thus, a minimum total of 18
fish samples will be selected for laboratory analysis from each location. Because ten individual
representatives of each species may not be attainable at each location, the sampling effort will be
well documented by the selected AZR contractor.
Based on NCDWR's 2019 fish collections and recommendations, the three species chosen as
primary targets for collection in this study include: Largemouth Bass, Redbreast Sunfish, and
Notchlip Redhorse. Each of these three species represent different trophic levels — top predator,
mid-trophic insectivore, and mid trophic omnivore, respectively. If these three primary target
species are absent from each location or a minimum of six individuals from each species are not
attainable then secondary target species may be substituted. Secondary target species may
include: Bluegill Sunfish, Brassy Jumprock, Flat Bullhead, Smallmouth Bass, White Sucker,
catfish, carp or other species.
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Fish Tissue Sampling Plan American Zinc Recycling NPDFS NCO089109

Broad River Sampling Reach Locations
The Broad River in the vicinity of the AZR facility can be a challenge for many fish collection
approaches including gill nets, hook and line, electrofishing, and other practices. Fish samples
will be obtained from two locations on the Broad River. The Broad River is a rocky, flashy, and
swift waterbody capable of rapid changes in water depth.
The first sampling reach location on the Broad River will start at the Jack McKinney Road
Bridge (approximately three river miles above the AZR facility). The downstream extent of this
sampling reach will be located no further than one mile downstream of the Jack McKinney Road
Bridge.
The second fish sampling reach will obtain fish from the Broad River below the AZP discharge.
The second river sampling reach will start below the AZP discharge in the vicinity of the
Highway 221 bridge over the Broad River (GPS location approximately Latitude 35.20585
Longitude-81.83773). The downstream extent of the sampling reach will be located
approximately one mile downstream of the Highway 221 bridge over the Broad River (GPS
location approximately Latitude 35.205356 Longitude-81.821633).
In any case, depending on the availability of fish, the extent of each actual sampling reach will
be measured and reported using reliable GPS positioning equipment. The agent or contractor
selected for fish sample collections will provide copies of any figures, maps, and photographs
needed to document the location of the sampling reach. Photographs documenting sampling
collection activities will also be provided.
Sampling Technique Methods
It is anticipated that the AZR fish collection contractor will employ boat mounted powered
electrofishing as the primary means of fish collection. Depending on the selection of a suitable
fish collection contractor, collections may also be accomplished using back pack electrofishing
techniques, hook and line, trot lines, traps, or gillnets. In any case, the collection contractor will
implement measures necessary to ensure that samples are collected and handled properly with
minimal contamination and that each sampling reach is GPS verified. Field sampling efforts will
continue at each location until either the primary or secondary target fish samples have been
collected with a sufficient number of individuals. A minimum of three different species with six
individuals will be collected from each location. Thus, fish collections are expected to result in a
minimum of 36 laboratory samples for individual fish analysis (plus 4 duplicates) for arsenic,
cadmium, and zinc. Regardless of collection method, the successful contractor will have
knowledge, skills, and experience with all sampling techniques used to obtain fish samples. All
personnel involved with electrofishing or other methods employed will be familiar with
operational and safety procedures. At least two fish tissue samples will be duplicated for
laboratory analysis at each location regardless of the total number of individual fish collected at
each location.
If field sampling approaches for fish collections are not successful in obtaining sufficient
individuals (18 per site) for laboratory analysis NCDWR will be consulted to determine
appropriate modifications.
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Fish Tissue Sampling Plan American Zinc Recycling NPDFS NCO089109

Field Data Sheet #1 and Field Data Sheet #2 will document Fish Tissue Collection Results on
the day(s) of Field sampling. One set of Data Sheets (2) will be completed for each location for
each day sampling is conducted.
Field Data Sheet #1
Fish Tissue Collections: Broad River downstream American Zinc Products Discharge.
Collection Date:
Location:
Study Reach Start From: Latitude: Longitude:
Study Reach Finish at: Latitude: Longitude:
Nearest Landmark at Start of Reach: Highway 221 bridge over the Broad River Rutherford Co.
Duration of Daily Collection Activities: Hours: Minutes:
Collection Staff. (list name and affiliation: example John Doe, Agency Blue Inc.
Describe Collection Methods: (ex. Electrofishing Boat, Back Pack electrofishing, hook and line,
trot lines, traps, or gillnets).
Describe:
Comment and Describe Access to River: ( example boat ramp, bank, bridge etc.)
Each day of sampling personnel must fill out the following table ((Field Data Sheet #2)
completing information for all individual fish. Any deviation from this Sampling Plan must be
noted and described on daily records.
Exceptions to Sampling Plan if any:
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Fish Tissue Sampling Plan American Zinc Recycling NPDFS NC0089109

Field Data Sheet #2
Fish #
Sample Location
Species
ID
Total Length
in cm
Weight
in grams
Comments
1
Date of collection:
2
3
Lat/Long Site Coordinates
The upstream extent was:
Latitude:
Longitude:
The Downstream extent was:
Latitude:
Longitude:
Reach Length in miles (include decimals)
4
5
6
7
8
9
10
11
12
13
Fish Collection Goal per location
3 Target Species
Ten fish per Species: 30 fish total
14
15
16
17
Primary Target Species Include
largemouth bass
redbreast sunfish
notchlip redhorse sucker
18
19
20
21
22
23
24
Secondary Target Species Include
bluegill sunfish
brassy jumprock
white sucker
flat bullhead
catfish
carp
others
25
26
27
28
29
30
31
Dup #1 of Fish Sample #
32
Dup#2 of Fish Sample #
Additional Comments:
61 age
Fish Tissue Sampling Plan American Zinc Recycling NPDFS NCO089109

Analytical Requirements —
Fish Tissue Samples will be analyzed by a North Carolina Laboratory certified by the Division
of Water Resources. All fish tissue samples will be analyzed for total arsenic, cadmium, and
zinc. Laboratory analytical capabilities will be evaluated and compared to the DWR PQL
reporting limits for arsenic, cadmium, and zinc prior to contractor selection. At least two fish
tissue samples will be duplicated for laboratory analysis at each location regardless of the total
number of individual fish collected at each location.
Sample Handling and Delivery/Shipment
Fish tissue samples collected for analyses must be processed and delivered/shipped to the
selected certified laboratory in order to prevent decomposition or contamination. In all activities
the selected contractor will avoid potential sources of arsenic, cadmium, and zinc contamination
— i.e. no use of galvanized buckets, no cigarette smoking, powderless nitrile gloves will be worn
in all fish handling activities. Fish will be removed from plastic live wells, holding tanks, or
buckets, and rinsed with ambient water to remove foreign matter, and placed on a clean or new
protective surface (i.e. aluminum foil) for sorting, weighing, length measurements, and
wrapping. All samples will be processed individually. No fish will be composited into
composite samples.
• An individual whole fish wet weight will be determined for each fish to the nearest gram
and recorded on Field Data Sheet #2. All individual samples will be weighed on
scalesibalances that are properly calibrated and of adequate accuracy and precision to
weigh samples to the nearest gram. Scales and or balances will be checked for calibration
at the beginning of each weighing session.
• A total length will be determined for each fish to the nearest centimeter using a length
board such as the Wildco® Model 118 and recorded on Field Data Sheet #2). Individual
fish will be identified to species under the supervision of an experienced staff familiar
with North Carolina fish. Fish will be identified using current, identification manuals and
other appropriate taxonomic literature (i.e.: Menhinick, E. F. 1991).
• Skins on fish selected for analysis will be examined for breaks or lacerations from
sampling gear as a possible source of contamination. Fish samples will be identified by
species and sorted by species before any packaging or processing for delivery/shipment
to the certified laboratory.
• Fish selected for metals analysis will be weighed and measured for length. Fish will be
individually wrapped and labeled with sample number, species name, weight, and length
in appropriate arsenic, cadmium, and zinc free wrap (i.e. new aluminum foil) and placed
by species in polyethylene bags. After removing as much air as possible, the bags will be
closed and tagged with the date, time, station name, species, and collector(s).
• All fish (in bags) will be placed on wet ice and chilled to 4 degrees C for transport to
either the certified laboratory or other suitable tissue processing location for preparation
of fillet samples within 48 hours.
• All fish will be processed as fillet samples. No fish samples for whole body metals
analysis will be sent to the certified laboratory for whole body metals analysis.
• All bass and sunfish species will be processed as fish fillet samples with skin -on intact.
• All Suckers, Catfish, and Bullheads, and Carp will be processed as fillet samples with
skin -off (no skin included).
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Fish Tissue Sampling Plan American Zinc Recycling NPDFS NCO089109

Fish Tissue Sample Processing Procedures
• Individual fish selected for filleting will be unwrapped and inspected carefully to ensure that
they have not been compromised in any way (i.e., not properly preserved during shipment).
Any specimen deemed unsuitable for further processing and analysis should be discarded and
identified on the sample processing record.
• Equipment used in processing fish samples for metals analysis will be free from arsenic,
cadmium, and zinc contamination. As such, glass and plastic use will be prioritized. Only
when necessary (i.e. knives) stainless steel will be used. Prior to preparing fish samples, all
hard surfaces used in the processing will be washed with a detergent and rinsed with verified
metal free water (treated by reverse osmosis — R.O.). Any necessary utensils and containers
will be thoroughly cleaned and rinsed with tap water, soaked in 50 percent HNO3 (at least
reagent grade) for 12 to 24 hours, and then rinsed with metal -free water.
• All processing will be performed on surfaces covered with heavy duty aluminum foil.
Aluminum foil will be rinsed with R.O. water between fish or new foil will be used. Filleting
will be performed using talc free disposable gloves. Gloves will be rinsed between samples to
prevent cross contamination. Fillets will be resected using high grade stainless steel knives.
Knives are rinsed with R.O. water between fish species from the same station.
• Fillets will be removed from the lateral area of the fish behind the head and pectoral fin and
will include the belly flap. Extreme care will be taken not to cut into the gut cavity as it may
contaminate the fillet tissue.
• Filleting will be done on cutting boards covered with heavy duty aluminum foil that is
changed after each filleting. Fillet tissues will be removed from whole fish with clean, high
quality, corrosion -resistant stainless steel or with titanium blade knives and polypropylene
handles.
• Skin -on fillets will be processed by removing scales from the intact fish. Fish will be scaled
prior to filleting using an automatic rotary scaler or hand scaler. Fish will then be rinsed with
R.O. water to remove slime and foreign matter. Any scaling instruments will also be rinsed
between fish to prevent contamination. The scale free fish fillet will be finely minced using
the same knives to prepare individual fillet homogenates to ensure equal distribution of
contaminants throughout the sample. These individual fillet tissue homogenates will be
stored in heavy duty aluminum foil and appropriately labeled for delivery to the certified
laboratory for chemical analysis. Where possible the final individual homogenized sample
should be composed of approximately 100 g of tissue to ensure an adequate amount of
material for analysis. Since samples will be composed of individual fish fillets it may not be
possible to achieve 100g of sample in every case.
• Fish fillet for skin -off analysis will be separated from the skin using knives. Fish will be
skinned prior to filleting for all catfish and bullheads. Sucker and Carp fillets will be
separated from the fish body and subsequently separated from the skin using knives. The skin
free fish fillet will be finely minced using the same knives to prepare individual fillet
homogenates to ensure equal distribution of contaminants throughout the sample. These
individual fillet tissue homogenates will be stored in heavy duty aluminum foil and
appropriately labeled for delivery to the certified laboratory for chemical analysis. Where
possible the final individual homogenized sample should be composed of approximately 100
g of tissue to ensure an adequate amount of material for analysis.
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Fish Tissue Sampling Plan American Zinc Recycling NPDFS NC0089109

Commercial Certified laboratories in North Carolina, South Carolina and Tennessee
Cert # I Lab Name
Lab Contact
Lab Addressl
Lab City
State
Zip
Phone I E-mail Address
1 Beacham Labs- Division of Environmental Chemists
Ray Porter
6602 Windmill Way
Wilmington
NC
28405-
910-392-0223 [e-mail]
10 Environment 1 Inc.
Mark Oliveira
P.O. Box7085
Greenville
NC
27835-
[e-mail]
11 Microbac Laboratories Inc.
James Williams
2592 Hope Mills Road
Fayetteville
NC
28306-
910-864-1920 [e-mail]
12 Pace Analytical Services LLC - Huntersville NC
Cheryl Johnson
_
9800 Kincey Avenue, Suite 100
Huntersville
NC
28078-
704-875-9092 [e-mail]
20 PAR Laboratories Inc.
Russell Everett
Box 411483
Charlotte
NC
28273-
704-588-8333 [e-mail]
22 Vann Laboratories
James W. Vann
P.O. Box 668
Wallace
NC
28466-
910-285-3966 [e-mail]
34 Research &Analytical Laboratories
Sidney L. Champion
P.O. Box473
Kernersville
NC
27285-
336-996-2841 info(randalabs.com
37 TBL Environmental Laboratory Inc.
Pamela S. Hester
P.O. Box 589
Lumberton
NC
28359-
910-738-6190 [e-mail]
40 Pace Analytical Services LLC - Asheville NC
Barry Johnson
2225 Riverside Drive
Asheville
NC
28804-
828-254-7176 [e-mail]
50 Water Tech Labs Inc.
La Fayette A. Gragg
P.O. Box 1056
Granite Falls
NC
28630-
828-396-4444 [e-mail]
57 Environmental Inc.
AnthonyTirona
P.O. Box954
Cullowhee
NC
28723-
828-586-5588 [e-mail]
67 Pace Analytical Services LLC - Raleigh NC
Barry Johnson
4915 Waters Edge Drive Suite 125
Raleigh
NC
27606-
919-834-4984 [e-mail]
94 Environmental Chemists Inc. (Envirochem)
Ray Porter
6602 Windmill Way
Wilmington
NC
28405-
910-392-0223 [e-mail]
165 Meritech Inc.
David Merritt
P.O. Box 27
Reidsville
NC
27323-
336-342-4748 [e-mail]
177 Water& Sewer Authority of Cabarrus County
Cayce Atkinson
6400 Breezy Lane
Concord
NC
28025-
704-788-4164 [e-mail]
192 Charlotte Water- Environmental Laboratory Services
Rhonda Hutson
4222 Westmont Drive
Charlotte
NC
28217-
704-336-3690 [e-mail]
210 City of Gastonia - Crow_ders Creek Laboratory
Annette McMurray
P.O. Box 1748
Gastonia
NC
28054-
704-854-6658 [e-mail]
235 Cherokee WWTP Laboratory
Michael Bolt
P.O. Box 547
Cherokee
NC
28719-
828-359-6772 [e-mail]
245 Perdue Incorporated
Tina B. Rawls
P.O. Box460
Lewiston Woodville
NC
27849-
252-348-4400 [e-mail]
275 Blue Ridge Labs
David Wessinger
P.O. Box 2940
Lenoir
NC
28645-
828-728-0149 [e-mail]
352 Earth Environmental Services
Mark Bentley
75 Bison Lane
Murphy
NC
28906-
828-837-9543 ceaderwvnn(vahoo.com
402 Prism Laboratories Inc.
Paul Fitzgerald
P.O. Box 240543
Charlotte
NC
28224-
704-529-6364 [e-mail]
440 Statesville Analytical Holdings LLC
Dena Myers
P.O. Box 228
Statesville
NC
28687-
704-872-4697 [e-mail]
481 SGS North America Inc. - Wilmington
Jeannie Milholland
5500 Business Drive
Wilmington
NC
28405-
910-350-1903 [e-mail]
482 James & James Environmental Management Inc.
Juanita James
P.O. Box 519
Mountain Home
NC
28758-
828-697-0063 [e-mail]
544 Water Quality Labs Inc.
Paul Isenhour
P.O. Box1167
Banner Elk
NC
28604-
828-898-6277 [e-mail]
559 K& W Laboratories
Gosia Kraska
1121 Hwy. 24/27 W
Midland
NC
28107-
704-888-1211 [e-mail]
572 Agronomic Division Laboratory- NCDA
Colleen Hudak -Wise
1040 Mail Service Center
Raleigh
NC
27699-
919-733-2655 Colleen. [e-mail]
591 Environmental Conservation Laboratories Inc.
Dale Mori
102 Woodwinds Industrial Ct. Ste. A Cary
NC
27511-
919-467-3090 [e-mail]
600 Environmental Testing Solutions Inc.
Kelley E. Keenan
P.O. Box 7565
Asheville
NC
28802-
828-350-9364 [e-mail]
602 Statesville Analytical Holdings, LLC
Dena Myers
4350 Sea Pines Drive
Southport
NC
28461-
910-617-1353 [e-mail]
604 Element One Inc.
Ken Smith
6319-D Carolina Beach Rd
Wilmington
NC
28412-
910-793-0128 [e-mail]
628 Environmental Chemists Inc./Outer Banks Div.
Ray Porter
P.O Box 2228
Manteo
NC
27954-
252-473-5702 [e-mail]
633 Pace Analytical Services LLC - Eden NC
Barry Johnson
205 East Meadow Road - Suite A
Eden
NC
27288-
828-254-7176I [e-mail]
638 Aquatic Ecology Lab- UNCW Center for Marine Science
Matthew McIver
5600 Marvin Moss Lane
Wilmington
NC
28409-
910-962-2357'[e-mail]
654 Cameron Testing Services Inc.
Chris Cameron
219 S. Steele Street
Sanford
NC
27330-
919-208-4240 [e-mail]
677 First Analytical Laboratories NC, LLC
Matt Loftis
4620-B Industry Lane
Durham
NC
27713-
919-942-8607 [e-mail]
687 RTI International
Andrea McWilliams
3040 E. Cornwallis Road
RTP
NC
27709-
919-485-5520 [e-mail]
27 Rogers & Callcott Engineers Inc. M
ieliel sa Ramey
P.O. Box 5655
Greenville
SC
29606-
864-232-1556 [e-mail]
233 GEL Laboratories LLC
Nancy Mattern
P.O. Box 30712
Charleston
SC
29417-
843-556-8171 [e-mail]
329 Shealy Environmental Services Inc.
Stephanie Atkins
106 Vantage Point Dr.
West Columbia
SC
29172-
803-227-3167 [e-mail]
686 ETT Environmental Inc.
Robert W. Kelley
P.O. Box 16414
Greenville
SC
29606-
864-877-6942 [e-mail]
64 TestAmerica Knoxville
Kevin McGee
5815 Middlebrook Pike
Knoxville
TN
37921-
865-291-3000 [e-mail]
375 Pace Analytical
Shari Pfalmer
12065 Lebanon Road
Mt. Juliet
TN
37122-
615-773-9755 [e-mail]
387 TestAmerica Nashville
Glenn Baun
2960 Foster Creighton Drive
Nashville
TN
37204-
615-301-5739 [e-mail]
415 Waypoint Analytical LLC
Richard Medina
2790 Whitten Road
Memphis
TN
38133-
901-213-2447 [e-mail]
9 1 0 a g e
Fish Tissue Sampling Plan American Zinc Recycling NPDES NC0089109

Examples of Some Potential Electrofishing Contractors
CZR Inc. Environmental Consultants
hLtp:Hczr-inc.com/index.]2hp?go=home.main
4709 College Acres Drive
Suite 2
Wilmington, NC 28403-1725
[phone]
Foster Lake & Pond Management
https://fosterlake.com/fisheries-mgmt/
9020 White Oak Road
P.O. Box 1294
Garner, NC 27529
Raleigh, NC [phone]
Charlotte, NC [phone]
Aquatic Environmental Services, INC.
http://Iakework.com/
2050 Howell Bridge Road
Ball Ground, GA 30107
United States
Phone: [phone]
Platinum Ponds and Lake Management
htti)s://www. DlatinumlakemanaL,ement. com/solutions/fisheries/electrofishin
Greenville, SC Charlotte, NC
1361 W. Hampton Blvd, Suite F 3611 Mt Holly-Huntersville Rd, Ste. 204
Greer, SC 29650 Charlotte, NC 28216
864-381-7663 704-816-0526
Solitude Lake Management
https://www.solitudelakemanaizement.com/
Charlotte: 980.248.2979
Raleigh: 984.444.2548
101 .-1ag(.
Fish Tissue Sampling Plan American Zinc Recycling NPDFS NCO089109

Taxonomic References for Fish Identification
Boschung, H. T. and R. L., Mayden. 2004.
Fishes of Alabama. Smithsonian Books, Birmingham,AL.
Marcy, B. C., D. E. Fletcher, F. D. Martin, M. H. Paller, M. J. M. Reichert. 2005.
Fishes of the Middle Savannah River Basin with Emphasis on the Savannah River
Site. University of Georgia Press. Athens, GA.
Menhinick, E. F. 1991. The Freshwater Fishes of North Carolina. North Carolina
Wildlife Resources Commission, Raleigh, N.C.
Murphy, B. R. and D. W. Willis. 1996.
Fisheries Techniques. American Fisheries Society. Bethesda, MD.
Jenkins, R. E. and N. M. Burkhead. 1993.
Freshwater Fishes of Virginia. American Fisheries. Society, Bethesda, MD.
Page, L. M. and B. M. Burr. 1991. A Field Guide to Freshwater Fishes. Houghton
Mifflin Co., Boston, MA.
111 ,-1ag(.
Fish Tissue Sampling Plan American Zinc Recycling NPDFS NCO089109

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Dlrectar
Mr. Robert Williamson, Plant Manager
American Zinc Products, LLC
484 Hicks Grove Road
Mooresboro, North Carolina 28114
Dear Mr. Williamson:
NORTH CAROLINA
Environmental Quality
April 18, 2019
Subject: Final NPDES Permit
Permit NCO089109
American Zinc Products, LLC
Rutherford County
Grade II PCWPCS
Division personnel have reviewed and approved your application for a renewal of the subject permit.
Accordingly, we are forwarding the attached NPDES permit. This permit is issued pursuant to the
requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement
between North Carolina and the U.S. Environmental Protection Agency dated October 15, 2007 (or
as subsequently amended).
No major changes were made to the draft permit sent to you on January 29, 2019.
The final permit maintains the following significant changes identified in the letter sent on
January 29, 2019:
• The flow limit was increased to 0.98 MGD
• The requirement for fish tissue monitoring was added to the permit to address a comment
from the Regional Office.
• The requirement for pollutant scan was added to the permit to address a comment from the
Regional Office.
• The limits for Total Cadmium were recalculated (reduced) based on the new flow estimate
and the recent update to the North Carolina water quality standards. A cadmium limit
compliance schedule was added to the permit.
• The limits for Total Chromium, Total Lead, and Total Fluoride were removed from the
permit based on the results of the Reasonable Potential Analysis.
• Quarterly monitoring for Hexavalent Chromium was added to the permit based on the
review of the effluent data.
ef 5-'fDUE Q5
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512 46,7hMrAb.ty W*V 11617MI 50YtWd C.rrlW I Mek*NtJiN Cafaria2N09-1611
419.747.3681

Permit NCO089109
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
PF.RMIT
TO DISCHARGE WASTEWATER UNDER THE
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,
American Zinc Products, LLC
is hereby authorized to discharge wastewater from a facility located at
American Zinc Products, LLC
Forest City
Rutherford County
to receiving waters designated as the Broad River in the Broad River Basin in accordance with
effluent limitations, monitoring requirements, and other applicable conditions set forth in
Parts I, II, III and IV hereof.
This permit modification shall become effective June 1, 2019.
This permit and authorization to discharge shall expire at midnight on July 31, 2023.
Signed this day April 18, 2019.
hard copy signed by Julie Grzyb
Linda Culpepper, Director
Division of Water Resources
By Authority of the Environmental Management Commission
Page 1 of 9

Permit NCO089109
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked. As of this permit issuance, any previously issued permit bearing this number is no longer
effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the
permit conditions, requirements, terms, and provisions included herein.
American Zinc Products, LLC is hereby authorized to:
1. Operate the process effluent discharge system including the following
components:
➢ Automatic sampler
➢ Instrumented flow measurement, and
➢ Diffuser
The facility is located near Forest City, Rutherford County; and
2. Discharge effluent from this location as specified on the attached map into the
Broad River which is classified WS-IV waters in the Broad River Basin.
Page 2 of 9

Permit NCO089109
Part I
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee
is authorized to discharge from outfall(s) serial number 001. Such discharges shall be limited and
monitored5 by the Permittee as specified below:
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQUREMENTS
Monthly
Average
Daily
Maximum
Measureme
nt
Frequency
Sample
Type
Sample
Locationl
Flow (MGD)
0.98
Continuous
Recording
I or E
Total Suspended Solids,
m L
2/Month
Composite
E
NH3-N, mg/L
Quarterly
Composite
E
Total Aluminum, µg/L
Quarterly
Composite
E
Total Antimony, µg/L
Quarterly
Composite
E
Total Arsenic, µg/L
Quarterly
Composite
E
Total Cadmium
90.4 µg/L6
454.4 µg/L6
2/Month
Composite
E
Chlorides, mg/ L
Quarterly
Composite
E
Chromium (VI), µg/L
Quarterly
Composite
E
Total Cobalt, µg/L
Quarterly
Composite
E
Total Copper, µg/L
Quarterly
Composite
E
Total Fluoride, mg/L
Quarterly
Composite
E
Total Iron, mg/L
Quarterly
Composite
E
Total Lead, µg/L
2/Month
Composite
E
Total Nickel, µg/ L
Monthly
Composite
E
Total Tin, µg/L
Quarterly
Composite
E
Total Zinc, µg/L
2/Month
Composite
E
pH2
6.0 < pH
< 9.0
Daily
Grab
E
Chronic Toxicity3
Quarterly
Composite
E
Turbidityy4
j Monthly
j Grab
NOTES:
1. Sample Locations: I - Influent, E - Effluent, U - upstream (50 ft. upstream of the
discharge), D - downstream (50 ft. downstream of the discharge).
2. The pH shall not be less than 6.0 standard units or greater than 9.0 standard units.
3. Chronic Toxicity (Ceriodaphnia) P/F @ 0.9%; Jan., April, July, and October; See
condition A. (2.) of the Supplement to Effluent Limitations and Monitoring Section of
this permit.
4. The discharge from this facility shall not cause turbidity in the receiving stream to exceed 50
NTU. If the instream turbidity exceeds 50 NTU due to natural background conditions, the
discharge cannot cause turbidity to increase in the receiving stream. Therefore, if the effluent
measurement exceeds 50 NTU, the Permittee shall sample upstream and downstream
turbidity in the receiving waterbody, within 24 hours, to demonstrate the existing turbidity
level in the receiving waterbody was not increased. All data shall be reported on the DMRs.
(See 15A NCAC 2B .0211 (21)).
NTU - Nephelometric Turbidity Unit.
Page 3 of 9

Permit NCO089109
5. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's
eDMR application system. See Special Condition A. (3.).
6. The limit becomes effective 90 months from the effective date of the permit. Please see A.
(6.) for Compliance Schedule.
THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR FOAM VISIBLE IN OTHER THAN
TRACE AMOUNTS.
A. (2.) CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QUARTERLY)
[ I SA NCAC 02B .0200 et seq.]
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant
mortality to Ceriodaphnia dubia at an effluent concentration of 0.9%.
The permit holder shall perform at a minimum, puarterlu monitoring using test procedures
outlined in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised
December 2010, or subsequent versions or "North Carolina Phase II Chronic Whole Effluent
Toxicity Test Procedure" (Revised- December 2010) or subsequent versions. The tests will be
performed during the months of January, April, July and October. These months signify the
first month of each three-month toxicity testing quarter assigned to the facility. Effluent
sampling for this testing must be obtained during representative effluent discharge and shall be
performed at the NPDES permitted final effluent discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or
ChV below the permit limit, then multiple -concentration testing shall be performed at a
minimum, in each of the two following months as described in "North Carolina Phase II
Chronic Whole Effluent Toxicity Test Procedure" (Revised -December 2010) or subsequent
versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the months in which tests were performed, using the
parameter code TGP3B for the pass/fail results and THP3B for the Chronic Value. Additionally,
DWR Form AT-3 (original) is to be sent to the following address:
Attention: North Carolina Division of Water Resources
Water Sciences Section/Aquatic Toxicology Branch
1621 Mail Service Center
Raleigh, NC 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section no later
than 30 days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements
and all concentration/response data, and be certified by laboratory supervisor and ORC or
approved designate signature. Total residual chlorine of the effluent toxicity sample must be
measured and reported if chlorine is employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring
is required, the permittee will complete the information located at the top of the aquatic toxicity
(AT) test form indicating the facility name, permit number, pipe number, county, and the
month/year of the report with the notation of "No Flow" in the comment area of the form. The
report shall be submitted to the Water Sciences Section at the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required,
monitoring will be required during the following month. Assessment of toxicity compliance is
Page 4 of 9

Permit NCO089109
based on the toxicity testing quarter, which is the three month time interval that begins on the
first day of the month in which toxicity testing is required by this permit and continues until the
final day of the third month.
Should any test data from this monitoring requirement or tests performed by the North Carolina
Division of Water Resources indicate potential impacts to the receiving stream, this permit may be
re -opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum
control organism survival, minimum control organism reproduction, and appropriate
environmental controls, shall constitute an invalid test and will require immediate follow-up
testing to be completed no later than the last day of the month following the month of the initial
monitoring.
A. (3.) ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS
[G.S. 143-215.1(b)]
Federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and
program reports. The final NPDES Electronic Reporting Rule was adopted and became effective on
December 21, 2015.
NOTE: This special condition supplements or supersedes the following sections within Part Il of
this permit (Standard Conditions for NPDES Permits):
• Section B. (11.) Signatory Requirements
• Section D. (2.)
• Section D. (6.)
• Section E. (5.)
Reporting
Records Retention
Monitoring Reports
1. Reporting Requirements [Supersedes Section D. (2.) and Section E. (5.) (a)]
The permittee shall report discharge monitoring data electronically using the NC DWR's
Electronic Discharge Monitoring Report (eDMR) internet application.
Monitoring results obtained during the previous month(s) shall be summarized for each
month and submitted electronically using eDMR. The eDMR system allows permitted facilities
to enter monitoring data and submit DMRs electronically using the internet. Until such time
that the state's eDMR application is compliant with EPA's Cross -Media Electronic Reporting
Regulation (CROMERR), permittees will be required to submit all discharge monitoring data to
the state electronically using eDMR and will be required to complete the eDMR submission by
printing, signing, and submitting one signed original and a copy of the computer printed
eDMR to the following address:
NC DEQ / Division of Water Resources / Water Quality Permitting Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the
facility being physically located in an area where less than 10 percent of the households have
broadband access, then a temporary waiver from the NPDES electronic reporting requirements
may be granted and discharge monitoring data may be submitted on paper DMR forms (MR 1,
1. 1, 2, 3) or alternative forms approved by the Director. Duplicate signed copies shall be
Page 5 of 9

Permit NC0089109
submitted to the mailing address above. See "How to Request a Waiver from Electronic
Reporting" section below.
Regardless of the submission method, the first DMR is due on the last day of the month
following the issuance of the permit or in the case of a new facility, on the last day of the
month following the commencement of discharge.
Starting on December 21, 2020, the permittee must electronically report the following
compliance monitoring data and reports, when applicable:
• Sewer Overflow/Bypass Event Reports;
• Pretreatment Program Annual Reports; and
• Clean Water Act (CWA) Section 316(b) Annual Reports.
The permittee may seek an electronic reporting waiver from the Division (see "How to Request
a Waiver from Electronic Reporting" section below).
2. Electronic Submissions
In accordance with 40 CFR 122.41(1)(9), the permittee must identify the initial recipient at the
time of each electronic submission. The permittee should use the EPA's website resources to
identify the initial recipient for the electronic submission.
Initial recipient of electronic NPDES information from NPDES-regulated facilities means the
entity (EPA or the state authorized by EPA to implement the NPDES program) that is the
designated entity for receiving electronic NPDES data [see 40 CFR 127.2(b)].
EPA plans to establish a website that will also link to the appropriate electronic reporting tool
for each type of electronic submission and for each state. Instructions on how to access and
use the appropriate electronic reporting tool will be available as well. Information on EPA's
NPDES Electronic Reporting Rule is found at:
https://www.federalre ig ster.gov/documents/2015/10/22/2015-24954/national-pollutant-
discharge-elimination-system-npdes-electronic-reporting-rule
Electronic submissions must start by the dates listed in the "Reporting Requirements" section
above.
3. How to Request a Waiver from Electronic Reporting
The permittee may seek a temporary electronic reporting waiver from the Division. To obtain
an electronic reporting waiver, a permittee must first submit an electronic reporting waiver
request to the Division. Requests for temporary electronic reporting waivers must be
submitted in writing to the Division for written approval at least sixty (60) days prior to the
date the facility would be required under this permit to begin submitting monitoring data and
reports. The duration of a temporary waiver shall not exceed 5 years and shall thereupon
expire. At such time, monitoring data and reports shall be submitted electronically to the
Division unless the permittee re -applies for and is granted a new temporary electronic
reporting waiver by the Division. Approved electronic reporting waivers are not transferrable.
Only permittees with an approved reporting waiver request may submit monitoring data and
reports on paper to the Division for the period that the approved reporting waiver request is
effective.
Information on eDMR and the application for a temporary electronic reporting waiver are
found on the following web page:
http: / /deg.nc.gov/about/divisions/water-resources/edmr
Page 6 of 9

Permit NCO089109
4. Signatory Requirements [Supplements Section B. (11.) (b) and Supersedes Section B.
11. d
All eDMRs submitted to the permit issuing authority shall be signed by a person described in
Part II, Section B. (11.)(a) or by a duly authorized representative of that person as described in
Part II, Section B. (11.)(b). A person, and not a position, must be delegated signatory
authority for eDMR reporting purposes.
For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR
user account and login credentials to access the eDMR system. For more information on
North Carolina's eDMR system, registering for eDMR and obtaining an eDMR user account,
please visit the following web page:
http://deq.nc.gov/about/divisions/water-resources/edmr
Certification. Any person submitting an electronic DMR using the state's eDMR system shall
make the following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF
CERTIFICATION WILL BE ACCEPTED:
"I certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate,
and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fines and imprisonment for knowing violations. "
5. Records Retention [Supplements Section D. (6.11
The permittee shall retain records of all Discharge Monitoring Reports, including eDMR
submissions. These records or copies shall be maintained for a period of at least 3 years from
the date of the report. This period may be extended by request of the Director at any time [40
CFR 122.411.
A. (4.) FISH TISSUE MONITORING
[G.S. 143-215.1(b)]
The facility shall conduct fish tissue monitoring once during the permit cycle and submit the results
with the NPDES permit renewal application. The objective of this monitoring is to evaluate potential
uptake of pollutants by fish tissue near the facility's discharge. The parameters analyzed in fish
tissue shall be arsenic, cadmium, and zinc. The monitoring shall be conducted in accordance with
the sampling plan approved by the Division. The plan should be submitted to the Division within
180 days from the effective date of the permit modification. Upon approval, the plan becomes an
enforceable part of the permit.
Copies of all the study plans, study results, and any other applicable materials should be
submitted to:
1) Electronic Version Only (pdf and CD)
Division of Water Resources
WQ Permitting Section - NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
2) Electronic Version (pdf and CD) and Hard Copy
Division of Water Resources
Water Sciences Section
1621 Mail Service Center
Raleigh, NC 27699-1621
Page 7 of 9

Permit NCO089109
A. (5.) PRIORITY POLLUTANT ANALYSIS
[G.S. 143-215.1(b)]
The Permittee shall perform one Effluent Pollutant Scan for all parameters listed below. The analytical
methods shall be in accordance with 40 CFR Part 136 and shall be sufficiently sensitive to determine
whether parameters are present in concentrations greater than applicable standards and criteria.
Unless otherwise indicated, metals shall be analyzed as "total recoverable."
Ammonia (as N)
Trans-1,2-dichloroethylene
Bis (2-chloroethyl) ether
Chlorine (total residual, TRC)
1, 1 -dichloroethylene
Bis (2-chloroisopropyl) ether
Dissolved oxygen
1,2-dichloropropane
Bis (2-ethylhexyl) phthalate
Nitrate/Nitrite
1,3-dichloropropylene
4-bromophenyl phenyl ether
Kjeldahl nitrogen
Ethylbenzene
Butyl benzyl phthalate
Oil and grease
Methyl bromide
2-chloronaphthalene
Phosphorus
Methyl chloride
4-chlorophenyl phenyl ether
Total dissolved solids
Methylene chloride
Chrysene
Hardness
1,1,2,2-tetrachloroethane
Di-n-butyl phthalate
Antimony
Tetrachloroethylene
Di-n-octyl phthalate
Arsenic
Toluene
Dibenzo(a,h)anthraccnc
Beryllium
1, 1, 1 -trichloroethane
1,2-dichlorobenzene
Cadmium
1,1,2-trichloroethane
1,3-dichlorobenzene
Chromium
Trichloroethylene
1, 4-dichlorobenzene
Copper
Vinyl chloride
3,3-dichlorobenzidine
Lead
Acid -extractable compounds:
Diethyl phthalate
Mercury (EPA Method 1631E)
P-chloro-m-cresol
Dimethyl phthalate
Nickel
2-chlorophenol
2,4-dinitrotoluene
Selenium
2, 4-dichlorophenol
2, 6-dinitrotoluene
Silver
2,4-dimethylphenol
1,2-diphenylhydrazine
Thallium
4,6-dinitro-o-cresol
Fluoranthene
Zinc
2,4-dinitrophenol
Fluorene
Cyanide
2-nitrophenol
Hexachlorobenzene
Total phenolic compounds
4-nitrophenol
Hexachlorobutadiene
Volatile organic compounds:
Pentachlorophenol
Hexachlorocyclo-pentadiene
Acrolein
Phenol
Hexachloroethane
Acrylonitrile
2, 4, 6-trichlorophenol
Indeno (1, 2, 3-cd) pyrene
Benzene
Base -neutral compounds:
Isophorone
Bromoform
Acenaphthene
Naphthalene
Carbon tetrachloride
Acenaphthylene
Nitrobenzene
Chlorobenzene
Anthracene
N-nitrosodi-n-propylamine
Chlorodibromomethane
Benzidine
N-nitrosodimethylamine
Chloroethane
Benzo(a)anthracene
N-nitrosodiphenylamine
2-chloroethylvinyl ether
Benzo(a)pyrene
Phenanthrene
Chloroform
3,4 benzofluoranthene
Pyrene
Dichlorobromomethane
Benzo(ghi)perylene
1,2,4-trichlorobcnzene
1,1-dichloroethane
Benzo(k)fluoranthene
1,2-dichloroethane
Bis (2-chloroethoxy)
methane
Reporting. The effluent pollutant scan shall be performed once during the permit cycle and test
results shall be submitted to the Division within 270 days of the sampling.
Page 8 of 9

Permit NCO089109
A. (6.) CADMIUM COMPLIANCE SCHEDULE
[G.S. 143-215.1(b)]
Activity
Description
Deadline
1 •
Commence production of Zinc at Mooresboro Facility.
June 1, 2019
2.
Ramp -up production to 75%.
December 1, 2019
3•
Stabilize plant operation and commence evaluation of permit
June 1, 2020
compliance.
4.
Complete evaluation period.
June 1, 2021
5•
Prepare a Preliminary Engineering Report (PER) of process
December 1, 2021
alternatives and/or pollution prevention/waste minimization
(parallel with activity 4)
alternatives designed to achieve compliance. This report would
include the results of the compliance evaluation. Submit to DWR
for review and comment.
6.
Agency review and addressing comments
February 1, 2022
7.
Bench scale test work of process alternatives (start in parallel
April 1, 2020
with Activity 6).
8.
Evaluate business case and funding requirements for
April 1, 2022
technically suitable alternative(s).
(parallel with activity 7)
9•
Complete pilot test work for selected technology option(s) and
August 1, 2022
final technology selection. Develop a summary of the results of
this evaluation. Submit summary to DWR for review.
10.
Agency review and addressing comments
October 1, 2022
11.
Detailed engineering and design of selected option. Submit to
February 1, 2023
DWR for comment.
12.
Agency review and addressing comments
April 1, 2023
13.
Prepare capital project application and secure funding for
June 1, 2023
selected option, obtain building permits and all needed
(much of this work will be done in
approvals for implementation.
parallel with activities 11,12)
14.
Project implementation, including design completion,
June 1, 2024
procurement and construction.
15.
Commission and ramp -up.
June 1, 2025
16.
Stabilize operation and evaluate performance.
December 1, 2025
17.
Make necessary final modifications to optimize and obtain full
August 1, 2026
operational status.
18•
Achieve full compliance.
December 1, 2026
Page 9 of 9

The Division is unable to grant your request for changing the Fish Tissue Monitoring Special
Condition, the Division used the standard language that applies to all the facilities required to monitor
fish tissue.
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty
(30) days following receipt of this letter. This request must be in the form of a written petition,
conforming to Chapter 150B of the North Carolina General Statutes, and filed with the Office of
Administrative Hearings (6714 Mail Service Center, Raleigh, North Carolina 27699-6714). Unless
such demand is made, this decision shall be final and binding.
Please note that this permit is not transferable except after notice to the Division. The Division may
require modification or revocation and reissuance of the permit. This permit does not affect the legal
requirements to obtain other permits which may be required by the Division of Water Resources or
any other Federal, State, or Local governmental regulations.
If you have any questions concerning this permit, please contact Sergei Chernikov at [phone]
or via email at [e-mail].
Sincerely,
Linda Culpepper, Director
Division of Water Resources, NCDEQ
Hardcopy: NPDES Files
Central Files
E-copy: DWR/Asheville Regional Office/Water Quality
DWR/Aquatic Toxicology Branch
Page 2 of 2