NCS000562_NOV Response_20200921

Kobus de Wet
VP & General Manager —AZP
AZRZINCAMERICAN RECYCLING Mooresks Grove Road T828-919-3160 [e-mail]
Mooresboro, NC 28114 [e-mail]
Delivering a Sustainable Future
September 17, 2020
Stanley E. Aiken, PE
Regional Engineer —Land Quality Section
Asheville Regional Office
Division of Energy, Mineral and Land Resources, NCDEQ
2090 U.S. 7 Highway
Swannanoa, NC 28778
Received
RE: NOTICE OF VIOLATION [NOV-2020-PC-0369)
American Zinc Products, LLC SEP 2 1 2020
NPDES Individual Stormwater Permit NCS000562
Rutherford County, North Carolina Land Quality Section
Asheville
Mr. Aiken,
American Zinc Products LLC ("AZP") received your Notice of Violation ("NOV"),
dated August 18, 2020, including the Compliance Inspection Report (the "Inspection
Report") from Mr. Isaiah Reed's July 1, 2020 stormwater inspection ("the inspection") of
the AZP facility in Mooresboro, North Carolina (the "Facility"). This letter provides AZP's
written response to the alleged violations described in the NOV. Information in
response to each of the alleged violations and the required actions is provided below,
following each of the alleged violations and actions noted from the NOV and provided
in bold print.
1) Stormwater Pollution Plan (SWPPP)
The provided site plan was found to be incomplete and lacked requirements
found in Part II, Section A, 1(c) of the Permit.
An evaluation of the site plan from the SWPPP was performed to identify and include
areas of the property and related storm water facilities, as described in the Permit, that
were inaccurate or missing. As a result, several surface drains locations shown on the
map were added to the map. Although some drains were added to the map, which
were installed as a result of recent renovation work, the overall flow of stormwater
from the areas where drains were included remained the same. Attached is a revised
site plan which includes revisions that were made.

2) Analytical Monitoring
Analytical monitoring has not been conducted and recorded in accordance with
permit requirements found in Part II, Section,B, Tier 1, Tier 2, and Tier 3
response actions."
The effective date of the current permit is April 30, 2018. This permit was issued while
the plant was shut down and the zinc production process was idled. Section B, Table 2,
Footnote 1 of the permit reads "The date on which the plant begins zinc production, the
permittee shall maintain quarterly monitoring until either another permit is issued for
this facility or until this permit is revoked or rescinded". Furthermore, Footnote 2 of
Table 2 provides that "permittee need not sample for the listed monitoring period until
the facility comes into operation". Zinc production at the facility commenced on March
3, 2020.
The first quarter monitored after commencement of zinc production was the second
quarter 2020. Since the second quarter 2020, the permit requirements have been
maintained, and quarterly monitoring has been maintained in accordance with the
permit.
3) Secondary Containment
Secondary containment has not been provided and maintained in accordance
with Part II, Section A, 2(b) of the Permit
The Inspection Report references secondary containment in three areas. Each of the
areas are identified below, followed by AZP information.
• Secondary Containment was not provided for an above ground container
located next to the office building
This above ground container is a double walled polyethylene SAFE - tank
Assembly located within a curbed containment area. The inner tank capacity
is 2,500 gallons. The outer tank capacity, including the volume of the inner
tank, is 3,125 gallons. The capacity of the annular space surrounding the
inner tank, the inherent tank containment capacity, is 608 gallons.
By procedure, this tank is operated in a manner that precludes the liquid
volume from exceeding the containment capacity of the SAFE —tank
Assembly system. The procedure calls for the tank to be emptied daily. As
such, 250 to 400 gallons of liquid is recovered from the tank daily for use in
process. The facility has maintained liquid in the tank at volumes less than
the inherent capacity of the Safe —tank Assembly system.
An as built diagram of the tank is attached.

• Secondary Containment for hazardous waste storage was damaged and
cracked
Repairs to noted damaged and cracked areas of the hazardous waste storage
pad have been completed.
Secondary Containment for solids storage located at the basin one was
found to be incorrectly installed
The secondary containment system for the solids storage containers that
were temporarily staged at Basin 1 was immediately addressed.
Amendments to the secondary containment system for roll off containers
were completed on the day following the inspection, July 2, 2020.
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 dissipator. The
monitoring shall occur at a minimum of once every seven (7) calendar days to
begin on 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.
According to the permit, as provided in the Footnotes to Table 1, grab samples are to be
collected at each stormwater discharge outfall (SDO). SDO 01 is representative of the
contribution of existing stormwater flows from the site to the Broad River.
By definition in the permit the SDO is "the point of departure of stormwater from a
discernible, confined, or discrete conveyance, including but not limited to, storm sewer
pipes, drainage ditches, channels, spillways, or channelized collection areas, from which
stormwater flows directly or indirectly into waters of the State of North Carolina."
The permitted SDO, SDO 01, for the AZP site is, and always has been, located at the
discharge point where water from Basin 1 is discharged and enters the Broad River.
Basin 1 is operated as a sedimentation basin for management of stormwater from the
site for removal of sediment from stormwater before discharge to the Broad River.
Stormwater samples for discharge monitoring are collected at the permitted SDO 01
during measurable storm events that result in actual discharge to the Broad River, as
stated in the permit, and not from a point located at the inlet to Basin 1 as described in
the NOV.
As described in information provided under item 2) above, AZP commenced required
maintenance of quarterly monitoring in the second quarter of 2020. Based on the date
zinc production commenced, March 3, 2020, the facility would have had one monitored

quarter completed on July 1, 2020, with the third quarter 2020 being the second
consecutive quarter in which monitoring was required. As such, as of the date of the
inspection (July 1, 2020) and the NOV letter (August 18, 2020) the facility had not
completed monitoring for the second quarter following commencement of zinc
production. Therefore, according to Footnotes 1 and 2 for Table 2 of the permit, AZP
believes that as of August 18, 2020 the facility was required to perform monitoring
under Tier 1.
Nevertheless, sampling and analysis of water discharged to the Broad River, as
suggested in the NOV letter, has been performed. Samples were collected as
investigatory monitoring at the permitted SDO during dry periods, i.e. not during a
measurable storm event. This monitoring is separate from other stormwater discharge
monitoring required by the permit.
AZP will notify the Department and perform stormwater discharge monitoring as
required in the permit.
If you have any questions or would like to discuss these matters further, please contact
me or Tim Basilone, Vice President Environmental Affairs, at 724-773-2223.
Respectfully,
Ko Zet
cc T. Basilone, AZR
Enclosures

NON -CONTROLLED COPY
INFORMATION SUBJECT TO CHANGE WITHOUT NOTICE
VERIFY REV LEVEL OF PAPER COPY WITH REV LEVEL ON PPC WEB SITE
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