DV-2020-0111 remission request

ASHEVILLE METAL FINISHING, INC.
A Leader in the Southeast for Commercial and Industrial Electroplating and Metal Finishing
February 2, 2021
Charles Weaver
NC Division of Water Resources
Water Quality Permitting Section-NPDES
1617 Mail Services Center
Raleigh NC 27699 1617
Asheville Metal Finishing, Inc. would like to formally submit a
penalty assessed to us on case number DV-2020-0111.
We refer to factors (b) and (d).
Regarding factor (b). once we were made aware of the situation. We immediately stopped our
production in the plant and moved all personnel to the spill area to begin our cleanup. The first thing
we would like to stress is, this spill was found to be an employee error. He took a tin bath rinse tank
outside the building to rinse it out causing the spill. In no way was Asheville Metal Finishing doing
anything willfully or intentionally in any manner. We were in the early stages of a reorganization of our
plating facility and were moving, condensing, and eliminating some of our plating processes from the
"downstairs". During this process we pumped our zinc bath and our tin bath into 55-gallon drums and
placed them outside the area, around the storm drain. We recognize our responsibility with this, but we
know for certain that the drums were in no way related to spill. After moving the drums to the
warehouse, we inspected the drums for labeling and leaking to prepare them for disposal. We
immediately removed all drums from the area and have continued to keep this area clear of any
chemicals.
Laser he
RECEIVED
FEB 0 4 2021
NCDEQ,DWR/NPDES
"Request for Remission" of the civil
We downsized our tin bath from a 300-gallon tank to a 90-gallon tank. The intention was to use the
other 210 gallons to replenish our bath as needed through our process. We made up a new zinc bath
for the move but had intended on reusing the 900 gallons as needed as well. The volume in our plating
baths will decrease over time due to drag out, evaporation, etc. At the recommendation of NCHWS, we
immediately began having analysis done to have these chemicals disposed of instead of keeping them
on site. The analysis was taken to Pace Analytical on 4/9/2020. This process took some time, but the
attachments show we disposed of 16 drums of zinc bath and 4 drums of tin bath on 6/8/2020. We also
disposed of 440 gallons of a chrome bath at the same time. These drums were disposed at a cost of
over $11,000.00.
P.O. Box 16237 Asheville, NC 28816 • 178 Clingman Ave., Asheville, NC 28801
Phone: [phone] Fax: [phone]

ASHEVILLE METAL FINISHING, INC.
A Leader in the Southeast for Commercial and Industrial Electroplating and Metal Finishing
As for preventing any future occurrences, we have retrained all personnel to keep all tanks, chemicals,
baths, and product within our containment perimeter.
Regarding factor (d): Asheville Metal Finishing, Inc, takes great pride in the fact that we have always
been very cooperative with all agencies and strive to maintain compliance in every measure. We have
not had a civil penalty in the 35+ years Tom Finger has owned this company. We have always been
quick to make all necessary changes that are recommended from all regulatory agencies that visit our
facility.
We would also like to respond to section G regarding the IANOV from the NCHWS. After on site visits
from Mr. Concepion and Mr. Menzel, it was determined that the waste was properly labeled as F006,
the waste was properly stored and handled. The waste was indeed on concrete and not bare ground as
first believed. We also determined that the 28 drums of usable chemistry, was not considered waste,
but we chose to dispose of them for the greater good.
Regards,
Thomas L. Finger
President
Asheville Metal Finishing, Inc
P.O. Box 16237 Asheville, NC 28816 • 178 Clingman Ave., Asheville, NC 28801
Phone: [phone] Fax: [phone]

DocuSign Envelope ID: 7CEF220E-8D06-40C8-A8FB-4C4EC231BE47
JUSTIFICATION FOR REMISSION REQUEST
DWR Case Number: DV-2020-0111
Assessed Party: Asheville Metal Finishing, Inc.
County: Buncombe
Amount Assessed: $11. 014.44
Please use this form when requesting remission of this civil penalty. You must also complete the
"Request For Remission, Waiver of Right to an Administrative Hearing, and Stipulation of Facts" form
to request remission of this civil penalty. You should attach any documents that you believe support
your request and are necessary for the Director to consider in evaluating your request for
remission. Please be aware that a request for remission is limited to consideration of the five
factors listed below as they may relate to the reasonableness of the amount of the civil penalty
assessed. Requesting remission is not the proper procedure for contesting whether the violation(s)
occurred or the accuracy of any of the factual statements contained in the civil penalty assessment
document. Pursuant to N.C.G.S. § 143B-282.1(c), remission of a civil penalty may be granted only
when one or more of the following five factors apply. Please check each factor that you believe
applies to your case and provide a detailed explanation, including copies of supporting documents,
as to why the factor applies (attach additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C.G.S. 143B-282.1(b)
were wrongfully applied to the detriment of the petitioner (the assessment factors
are listed in the civil penalty assessment document);
(b) the violator promptly abated continuing environmental damage resulting from
the violation (i.e., explain the steps that you took to correct the violation and
prevent future occurrences);
(c) the violation was inadvertent or a result of an accident (i.e., explain why the
violation was unavoidable or something you could not prevent or prepare for);
if-x (d) the violator had not been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary
remedial actions (i.e., explain how payment of the civil penalty will prevent you
from performing the activities necessary to achieve compliance).
EXPLANATION:

DocuSign Envelope ID: 7CEF220E-8D06-40C8-A8FB-4C4EC231 BE47
STATE OF NORTH CAROLINA
COUNTY OF BUNCOMBE
IN THE MATTER OF ASSESSMENT
OF CIVIL PENALTIES AGAINST
ASHEVILLE METAL FINISHING, INC.
DEPARTMENT OF ENVIRONMENTAL QUALITY
WAIVER OF RIGHT TO AN
ADMINSTRATIVE HEARING AND
STIPULATION OF FACTS
CASE NO. DV-2020-0111
Having been assessed civil penalties totaling $11,014.44 for violation(s) as set forth in the
assessment document of the Division of Water Resources dated December 30.2020, the
undersigned, desiring to seek remission of the civil penalty, does hereby waive the right to an
administrative hearing in the above -stated matter and does stipulate that the facts are as alleged in
the assessment document. The undersigned further understands that all evidence presented in
support of remission of this civil penalty must be submitted to the Director of the Division of Water
Resources within thirty (30) days of receipt of the notice of assessment. No new evidence in
support of a remission request will be allowed after (30) days from the receipt of the notice of
assessment.
This the day of r�--W /uto-1, 20 2-1
\
SIGNAT '
ADDRESS
A5LtAi; l 1 CVl L+11/ CS
PO6oX (l4237 (tL')(J
E (L 1V1 LZ V?? 0 I)
Ll.t NG.
TELEPHONE
RECEIVED
FEB 0 4 2021
NCDEQ/DWR/NPDES

Please complete and return copy of invoice with your payment.
INVOICE TOTAL $335.00
Amount Paid: $
Check No:
Customer No: 93-702347 Invoice No: 2092232735
Samples Received
Lab ID
92473112002
92473112003
92473112004
Qua
Sold To:
Ms. Monica Ledford
Asheville Metal Finishing
178 Clingman Ave.
Asheville, NC 28801
[phone]
Client Project- Plating Bath 4-9-2020
Pace Project No: 92473112
Report Sent To: Mr. Todd Israel, Asheville Metal Finishing
Comments:
Unit Description
2 Ea
2 Ea
2 Ea
1 Ea
2 Ea
200.71CP Metals
245.1 Mercury
4500CNE Cyanide, Total
EnvironmentalEnvironental Impact Fee
Metals Digestion Charge
92473112001
for analysis:
Client Sam le ID
MO ZINC
CN ZINC
MO TIN
CN TIN
INVOICE
Y
Pace Analytical Services, LLC
2225 Riverside Dr.
Asheville, NC 28804
Phone:[phone]
Invoice Number. 2092232735
Date: 04/29/2020
Total Amount Due: $335.00
Please Remit To:
Pace Analytical Services, LLC
P.O. Box 684056
Chicago, IL 60695-4056
Client Name: Asheville Metal Finishing
Sample Received: 4/9/2020
ANALYTICAL CHARGES
Method
Matrix
EPA 200.7 Rev 4.4 1994 Water
EPA 245.1 Rev 3.0 1994 Water
SM 4500-CN-E-2011 Water
Miscellaneous Charges Water
Miscellaneous Charges Water
Total Number of Charges 9
Received
4/9/2020 10:43:00
4/9/2020 10:43:00
4/9/2020 10:43:00
4/9/2020 10:43:00
if you have any questions, please contact Chris Derouen at Pace.
Phone: [phone] Email:: Christopherderouen@pace/abs.com
Price
$88.00
$35.00
$35.00
$9.00
$5.00
Analytical Subtotal
Total Invoice Amount
"1.5% MONTHLY FINANCE CHARGE ASSESSED AFTER 30 DAYS OR TERMS OF CONTRACT
PLEASE REFERENCE THE INVOICE NUMBER ON ALL REMITTANCE ADVICE.
AN EQUAL OPPORTUNITY EMPLOYER
Total
$176.00
$70.00
$70.00
$9.00
$10.00
$335.00
$335.00
Page 1 of 1

Please complete and retum copy of invoice with your payment.
INVOICE TOTAL
Amount Paid: $
Check No:
$90.00
Customer No: 93-702347 Invoice No: 2092233291
Sold To:
Ms. Monica Ledford
Asheville Metal Finishing
178 Clingman Ave.
Asheville, NC 28801
[phone]
93-702347 / 93-Ashe Meta
Client Project: MO CHROME 4-9-2020
Pace Project No: 92473217
Report Sent To: Mr. Todd Israel, Asheville Metal Finishing
Comments:
INVOICE
Purchase araiiiiib.
Pace Analytical Services, LLC
7275 Riverside Dr.
Asheville, NC 28804
Phone: [phone]
voice Number: 2092233291
Inv
oice
Date: 04/30/2020
1Total Amount Due: $90.00
Please Remit To:
Pace Analytical Services, LLC
P.O. Box 684056
Chicago, IL 60695-4056
Pace P}a�ect��
Chris Derouen
Net 30 Days
Client Name: Asheville Metal Finishing
Sample Received: 4/9/2020
1
ANALYTICAL CHARGES
Quantity Unit Description Method
Matrix
1 Ea 200.7 ICP Metals EPA 200.7 Rev 4.4 1994 Water
1 Ea 245.1 Mercury EPA 245.1 Rev 3.0 1994 Water
1 Ea Environmental Impact Fee Miscellaneous Charges Water
1 Ea Metals Digestion Charge Miscellaneous Charges Water
Price Total
$56.00 $56.00
$20.00 $20.00
$9.00 $9.00
$5.00 $5.00
Analytical Subtotal $90.00
Total Number of Charges 4
Samples Received for analysis:
Lab ID Client Sample ID Received
92473217001 MO CHROME 4/9/2020 4:07:00
If you have any questions, please contact Chris Derouen at Pace
Phone.- [phone] Email: [e-mail]
Total Invoice Amount $90.00
"1.5% MONTHLY FINANCE CHARGE ASSESSED AFTER 30 DAYS OR TERMS OF CONTRACT.
PLEASE REFERENCE THE INVOICE NUMBER ON ALL REMITTANCE ADVICE.
AN EQUAL OPPORTUNn'Y EMPLOYER
Page 1 of 1

L
Invoice
U.S_ WASTE INDUSTRIES, INC.
4420 Jefferies Hwy
PO Box 2326
Walterboro, SC, 29488-6488
US
Phone: [phone]
Fax: [phone]
Sold To:
ASHEVILLE METAL FINISHING/ ASHEVILLE NC
178 CLINGMAN AVE.
ASHEVII 1 F, NC 28801
Qty.
Ord
Order No.
ORD102205
Qty.
Shp,
8.000 8.000
4.000 4.000
16.000 16.00(
12.000 12.00(
1.000 1.000
0.120 0.120
1.000 1.000
Ship To:
ASHEVILLE METAL FINISHING
178 CLINGMAN AVE.
ASHEVILLE, NC 28801
Order Date Customer No.Salesperson
Jun 16, 2020, ASHEVILLE ME I CH
Item Number
E205075DET
E205141DET
E205142DET
STATE WASTE FEE
PICKUP FEE
FUEL SURCHARGE
EPAM MANIFEST
Due Date
Jul 16, 2020
Comments:
i
PO Number
5620
CHROME PLATING BATH
TIN PLATING BATH
ZINC PLATING BATH
THE STATE OF MI WASTE FEE
PICK UP FEE
FUEL SURCHARGE
EPA HAZ E-MANIFEST FEE
Amount Due Discount Date
11,166.52 Jun 16, 2020
Tax summary:
ASHEVILLE ME R0120760CH NC
6-8-2020 018623219JJK
invoices paid by credit card will be subject to a fee.
Charges for any wastes are based upon all waste materials
conforming to the waste profile. Any wastes that fall outside the
profile are subject to additional charges.
Unit Price
482.000000
482.000000
250.000000
2.20
145.00
9,926.00
20.00
Disc. Amount
0.00
Subtotal
Total sales tax
0.00
Total amount
Less payment
Less pmt disc
Ship Via Terms
I NET30
Extended Price
3,856.00
1,928.00
4,000.00
26.40
145.00
1,191.12
20.00
11,166.52
0.00
11,166.52
0.00
0.00
Amount due
11,166.52

Form Approved. OMB No. 2050-0039
9a.
HM
1
,rint or type. (Form desi ried'f r use on elite (12-pitch) typewriter.)
IIFORM HAZARDOUS
1. Generator ID Number
tNASTE MANIFEST A1C0i154262t 5
3enerator's Name and Mailing Address
ASHEt LLE METAL FINISHING. INC:.
178 CLINGMAN AVENUE
.A HEVILLE, NC 2$t301
nerator'sPhone: 62e-25 -1476
transporter 1f.remgnye `P
Frans orterr 2 Company Name
Designated Facility Name and Site Address
EC 0ETRO?T
19.23- FREDERICK;STREET
OETROIr , MI 413211
rdlity's Phone: [phone]
9b. U.S. DOT Description (including Proper Shipping Name, Hazard Class, ID Number,
and Packing Group (if any))
1.
RQ,UN17130,WASTE CORROSIVE LIQUID .N.O.S.(CHROMiC
AC!D)$,FGI ,ERG-154 #E2060750ET
2. RQ.UN/760,'WASTE CORROSIVE LIQUID N.O.S.I(SULFURIC
ACIDJ,S.,PGIt Ef G-154 #E2O5141 DET
3. 2iNC PLATING EIATiH NON HAZARDOUS.1NON REGLILA.TEO #
E205142DEC
2.Page 1of
3. Emergency Response Phone
26-253_1475
Generator's Site Address (rf different than mailing address)
4. Ma Traj�ki Nginf3r �13 J J K
U.S. EPA ID Number
. yfrc413'6y21'
10. Containers
No. Type
C
0M
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U.S. EPA ID Number
U.S. EPA ID Number
MI0 80991565
11. Total
Quantity
12. Unit
Wt.Nol.
13. Waste Codes
G 0002 0004
G 0002 0006
0006
0029L�
14. Special Handling Instructions and Additional Information 7c a;3f$0 rx�CH
R r a TODOISR.AEL $26-25314�.
NEEDS CO ;ENT TO US WASTE 24 t+.R EMERGENCY CONTACT
006
0007
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15. marked anOR'SIOdFEROdeCERTIFICATION: I hsrin roopdaco� t the lion forrttrans transport according ntents of this gnment are fully and to applicable international and nationalrately o ern menta regulations. If export shipment and I am the Primary
marked and labeled/placarded, thatla and are inall respects' proper
P
`Exporter,) certify that the contents of this consignment conforn to the terms of ml ame fia largeaEPA ua quantity
nt or of (if I am a small quantity generator) is true.
I certify that the waste minimization statement identified in 40 CFR 262.27(a) (ifq ty generator) �e
Sgnature r �= � ti
Generatoif Offerorfs FrntedlTyped Name j t
16IntemaGonal Shipments 0 Import to U.S.
r. Transporter signature (for exports only):
17. Transporter Acknowledgment of Receipt of Materials
u
r Tr orter 1 Printed/Typed Na
a. ' � tU"v �� f -
z Transporter 2 Prtnted/Typed Name
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18. Discrepancy
18a. Discrepancy Indication Space
18b. Alternate Facility (or Generator)
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W 18c. Signature of Alternate Facility (or Generator)
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2
• 19. Hazardous Waste Report Management Method Codes (i.e., codes for hazardous waste treatment, disposal, and recycling systems
)
CO
4.1 1' t� / �f , 2. 1 i 1 f
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1 20. Designated Facility Owner or Operator. Certification of receipt of hazardous materials covered by the msn�'rfes�eecept as noted in Item 1 f � �
Pr ntedlTyped Name (. . 1) ( r r o f ' —
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-�' ��� DESIGNATED FACILITY TO GENERATOR
❑ Export from U.S.
Port of entry/exit:
Date leaving U.S.:
Month Day._ Year
Quantity
EPA Form 8700-22 (Rev. 3-05) Previous editions are obsolete.
❑ Type
Sigre
❑ Residue
Manifest Reference Number:
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,
❑ Partial Rejection
U.S. EPA ID Number
4.
Month Day
6 o'7S
Month Day
❑ Full Rejection
Month Day Yea