NCS000562_NOV with Inspection Report_20200818

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
BRIAN WRENN
Director
NORTH CAROLINA
Environmental Quality
August 18, 2020
CERTIFIED MAIL: 7019 0700 0000 8867 4575 CERTIFIED MAIL: 7019 0700 0000 8867 4742
RETURN RECEIPT REQUESTED RETURN RECEIPT REQUESTED
American Zinc Products, LLC American Zinc Products, LLC
Attn: Tim Basilone Attn: Kobus DeWet
4955 Steubenville Pike, Suite 405 484 Hicks Grove Road
Pittsburgh, Pennsylvania 15205 Mooresboro, North Carolina 28114
Subject: NOTICE OF VIOLATION (NOV-2020-PC-0369)
American Zinc Products, LLC
NPDES Individual Stormwater Permit NCS000562
Rutherford County, North Carolina
Dear Mr. DeWet and Mr. Basilone:
On July 1, 2020, Isaiah Reed from the Asheville Regional Office of the Division of Energy, Mineral
and Land Resources (DEMLR or Division), conducted a compliance inspection for the American Zinc
Products, LLC facility located at 484 Hicks Grove Road, in Rutherford County, North Carolina. A
copy of the Compliance Inspection Report is enclosed for your review. The subject facility is
covered by NPDES Individual Stormwater Permit NCS000562. Permit coverage authorizes the
discharge of stormwater from the facility to receiving waters designated as the Broad River, a Class
C waterbody in the Broad River Basin.
As a result of the compliance inspection, the following permit condition violations are noted:
1) Stormwater Pollution Prevention Plan (SPPP)
The provided site plan was found to be incomplete and lacked requirements found in Part 11,
Section A, 1(c) of the Permit.
2) Analytical Monitoring
Analytical monitoring has not been conducted and recorded in accordance with permit
requirements found in Part 11, Section B, Tier 1, Tier 2, and Tier 3 response actions.
3)Secondary Containment
Secondary containment has not been provided and maintained in accordance with Part II, Section A,
2(b) of the Permit.
North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
Asheville Regional Office 1 2090 U.S. Highway 70 1 Swannanoa, North Carolina 28778
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Tier 3 Required Actions
In accordance with Part II, Section B, Tier 3 requirements, the permittee is required to conduct
analytical monitoring, for all parameters, at the inlet to Basin 1 where the stormwater pipe
discharges to the energy dissipater. This monitoring shall occur at a minimum of once every seven
(7) calendar days to begin on the date of receipt of this Notice and to continue for a period not less
than three (3) months from the date of receipt of this Notice. Be advised that this monitoring shall
be done separately and in addition to the investigative monitoring conducted pursuant to Tier 2
response actions.
Requested Response:
You are asked to respond to this office, in writing, within 30 calendar days from receipt of this
Notice. Your written response should include a reasonable explanation as to why the
aforementioned violations have occurred as well as a Plan of Action to prevent these violations
from recurring.
Thank you for your attention to this matter. This office is considering sending a recommendation
for enforcement to the Division Director regarding these issues. Your above -mentioned response to
this correspondence will be considered in this process. This office requires that the violations, as
detailed above, be properly resolved. These violations and any future violations are subject
to a civil penalty assessment of up to $25,000 per day for each violation. Should you have any
questions regarding these matters, please contact Isaiah Reed or myself at [phone].
Sincerely,
Stanley E. Aik PEGA
Regional gineer
Land Quality Section
Enclosure:
Compliance Inspection Report
ec: Alaina Morman, Environmental Specialist [e-mail]
Jeff Menzel, Environmental Specialist ieffinenzelOncdenr.gov
Annette Lucas, Stormwater Program Manager annette.lucasoncdenr.gov
Toby Vinson, DEMLR Section Chief toby.vinsonCcDncdenr.gov
Stormwater Program File

Compliance Inspection Report
Permit: NCS000562 Effective: 04/30/18 Expiration: 03/31/23 Owner : American Zinc Products LLC
SOC: Effective: Expiration: Facility: American Zinc Products, LLC
County: Rutherford 484 Hicks Grove Rd
Region: Asheville
Mooresboro NC 28114
Contact Person: James D Harris Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 07/01/2020
Primary Inspector: Isaiah L Reed
Secondary Inspector(s):
Entry Time 09:OOAM
Alaina Morman
Reason for Inspection: Routine
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Certification:
Phone:
Exit Time: 02:30PM
Phone: [phone]
Inspection Type: Compliance Evaluation
Page 1 of 3

Permit: NCS000562 Owner- Facility: American Zinc Products LLC
Inspection Date: 07/0112020 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary
On July 1, 2020 this facility was inspected for complaince. I met with Charles Howell and Shannon Andrews on site. During
the inspection, the following items were noted:
1) Secondary containment was not provided for an above ground storage container located next to the office building the
permittee shall immediately begin efforts to provide adequate secondary containment for all bulk storage of liquid materials
on site as outlined in the NCS000562 Individual Stormwater Permit.
2) The secondary containment for hazardous waste storage was damaged and cracked. The permittee shall immediately
begin efforts to repair all containment structures on site to provide adequate secondary containment as outlined in the
NCS000562 Individual Stormwater Permit.
3) The site plan was found to be incomplete and did not meet the requirements of the permit. the permittee shall
immediately begin efforts to update, review and submit an accurate site plan as outlined in the NCS000562 Individual
Stormwater Permit, including all stormwater infrastructure.
4) The Containment around the Solids storage located at basin one was found to be incorrecty installed. the permittee shall
immediately begin efforts to address, inspect and repair all containment devices utilized on site to assure proper function
and operation as outlined in the NCS000562 Individual Stormwater Permit.
5) After reviewing the analytical data provided on site, it was determined that the permittee has failed to implement all
required actions in response to Tier 1, 2, and 3 requirements. The permittee id directed to immediately begin implementing
all responsive actions outlined in the Tier 1 and Tier 2 requirements as outlined in the NCS000562 Individual Stormwater
Permit. Be advised that this requirement includes Identifying and evaluating all possible causes of benchmark exceedances.
this includes but is not limited to: investigative monitoring to evaluate where the source of the exceedance may be coming
from. Please refer to the enclosed Notice of Violation for further requirements.
In accordance with Part Il, Section B, Tier 3 requirements, the permittee is required to conduct analytical monitoring, for all
parameters, at the inlet to Basin 1 where the stormwater pipe discharges to the energy dissipater. This monitoring shall
occur at a minimum of once every seven (7) calendar days to begin on the date of receipt of this Notice and to continue for a
period not less than three (3) months from the date of receipt of this Notice. Be advised that this monitoring shall be done
separately and in addition to the investigative monitoring conducted pursuant to Tier response actions.
If you have any questions, please contact this office at [phone]
Page 2of3

Permit: NCS000562 Owner- Facility: American Zinc Products LLC
Inspection Date: 07/0112020 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Stormwater Pollution Prevention Plan
Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan?
0
❑ ❑ ❑
# Does the Plan include a General Location (USGS) map?
0
❑ ❑ ❑
# Does the Plan include a "Narrative Description of Practices"?
0
❑ ❑ ❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
❑
0 ❑ ❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
0
❑ ❑ ❑
# Has the facility evaluated feasible alternatives to current practices?
0
❑ ❑ ❑
# Does the facility provide all necessary secondary containment?
❑
0 ❑ ❑
# Does the Plan include a BMP summary?
0
❑ ❑ ❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
0
❑ ❑ ❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
N
❑ ❑ ❑
# Does the facility provide and document Employee Training?
E
❑ ❑ ❑
# Does the Plan include a list of Responsible Party(s)?
N
❑ ❑ ❑
# Is the Plan reviewed and updated annually?
0
❑ ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
0
❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
❑
E ❑ ❑
Comment: See summary for more information.
Qualitative Monitoring
Yes
No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually?
0
❑ ❑ ❑
Comment
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? ❑ 0 ❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ 0❑
Comment: Analytical monitoring not conducted in accordance with Tier 2 requirements
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? 0 ❑ ❑ ❑
# Were all outfalls observed during the inspection? 0 ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ 0 ❑
# Has the facility evaluated all illicit (non Stormwater) discharges? N ❑ ❑ ❑
Comment:
Page 3 of 3