NC0089109_Application_20200611

TIMOTHY R. BASILONE
Vice President— Environmental Affairs
J"kAMERICAN
ZINC R E CYC S I N G 3000 GSK Drive T 724-773-2223 www.azr.com
Suite 201 F 412-7884526 [e-mail]
Delivering a Sustainable Future Moon Township, PA 15108
VIA EMAIL AND OVERNIGHT MAIL
October 16, 2019
Dr. Sergei Chernikov, Ph.D.
Environmental Engineer II
North Carolina Dept. of Environment
& Natural Resources
Division of Water Quality
9' Floor —Archdale Building
512 N Salisbury Street
Raleigh, NC 27604
RE: NPDES — Permit Modification Request
Revision to the Cadmium Compliance Schedule
American Zinc Products LLC (AZP)
American Zinc Recycling (AZR), Mooresboro Facility
Rutherford County, NC
PermitNCO089109
Dear Dr. Chernikov:
RECEIVED
OCT 18 2019
NCQEQ/DwR1NPDES
Pursuant to our recent discussion and exchange of information regarding the above referenced
American Zinc Products, LLC (AZP) facility located in Mooresboro, North Carolina, AZP is
providing this letter to formally request a modification to NPDES Permit NC0089109.
This request for modification to the existing NPDES Permit is necessary due to a catastrophic fire
that occurred at the facility on April 28, 2019, which severely damaged the cell house
operations. Consequently, the damage due to the fire has resulted in further delay in the
startup of the facility and zinc production operations. Under the current circumstances, work
necessary for completion of the Cadmium Compliance Schedule as described in the current
permit cannot reasonably be completed. Work identified on the attached schedule requires
that the cadmium content in effluent discharge water is accurately identified while the facility is
in operation and all processes for zinc production are running.
At present, the anticipated startup of the facility is estimated to occur sometime during the first
or second quarter in 2020. The current timeline for achieving full operational status is
estimated at around mid -year 2020. Based on this schedule, we are requesting that the timeline
for the Cadmium Compliance Schedule be revised to commence in June 2020. Specifically, we
are requesting that the Cadmium Compliance Schedule, as part of the NPDES Permit NCO069109
on page 8, A. (6.), be revised to reflect the dates provided on the attached timeline. Please note
that the attached schedule includes a revision to the year associated with activity 7, making the
date consistent with activity 6.

As you are aware, a detailed permit modification package for the restart of this operation was
submitted to DWR in 2018 and the permit was modified and renewed in April 2019 with an
effective date of June 1, 2019. Per your direction a permit application is not being submitted for
this modification request. Included herein is a check for $260.00, to cover the permit
modification fee, as provided on the Division's website and that you confirmed.
We appreciate your consideration of this request for modification.
revised permit with the requested changes as quickly as possible.
need any additional information, please contact me.
Sincerely,
Timothy R. Basilone
Enc.
We would like to secure the
If you have any questions or

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, 2020
2.
Ramp -up production to 75%.
December 1, 2020
3.
Stabilize plant operation and commence evaluation of permit
June 1, 2021
compliance.
4.
Complete evaluation period.
June 1, 2022
5.
Prepare a Preliminary Engineering Report (PER) of process
December 1, 2022
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, 2023
7.
Bench scale test work of process alternatives (start in parallel
April 1, 2023
with Activity 6).
8.
Evaluate business case and funding requirements for
April 1, 2023
technically suitable alternative(s).
(parallel with activity 7)
9•
Complete pilot test work for selected technology option(s) and
August 1, 2023
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, 2023
11.
Detailed engineering and design of selected option. Submit to
February 1, 2024
DWR for comment.
12•
Agency review and addressing comments
April 1, 2024
13.
Prepare capital project application and secure funding for
June 1, 2024
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, 2025
procurement and construction.
15.
Commission and ramp -up.
June 1, 2026
16.
Stabilize operation and evaluate performance.
December 1, 2026
17.
Make necessary final modifications to optimize and obtain full
August 1, 2027
operational status.
18.
Achieve full compliance.
December 1, 2027
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