NCG030265_2021 DMR_20210323 (2)

DS
GAVE STEEL COMPANY
A WALTERS GROUP COMPANY
March 26, 2021
NCDEQ - Asheville Regional Office
Division of Energy, Mineral, and Land Resources
2090 U.S. 70 Highway
Swannanoa, NC 28778-8211
Re: Dave Steel Company, Inc.
40 Meadows Road
Asheville, NC 28802
Certificate of Coverage No. NCG030265
Dear Sir or Madam:
Attached is the First Semiannual Stormwater Discharge Monitoring Report for 2021 for Dave Steel
Company, Inc. (DSCO).
Methods
Samples were collected on March 16, 2021, during a "measurable storm event" from the facility
stormwater outfalls labeled SDO 001 and SDO 002 (see Figure 1). SDO 001 and SDO 002 are the
locations where previous samples have been collected. Samples were collected from the approximate
center of the discharge streams and transferred to laboratory -supplied containers. Samples were
collected using good sampling practices in pre -cleaned (and preserved when appropriate) containers
supplied by Pace Analytical Laboratories (Pace). The containers were placed in a cooler on ice and
delivered to Pace in Asheville, North Carolina, for laboratory analyses. pH was measured in the field by
placing a probe within the flow of the respective outfall, and the pH was recorded following stabilization.
The pH meter was calibrated before testing with two buffer solutions that bracketed the expected pH
range. The pH measurement was taken within 15 minutes of collection as required by the North
Carolina Department of Environmental Quality (NCDEQ).
A Dave Steel staff representative also conducted a Stormwater Discharge Outfall (SDO) Qualitative
Monitoring event for SDO 001 and SDO 002 during the stormwater analytical sampling event. This
monitoring report is attached for reference.
The total precipitation was 0.74 inches for the storm event that resulted in an actual discharge from the
permitted site outfalls. The previous measurable storm event with actual discharge was at least 72
hours prior to the sampling. Samples were collected by 9:20 am on the sampling day. Precipitation
amounts are based on a local rain gauge. Calculations of the maximum total flow through the outfalls
on March 16, 2021, are included as Attachment I.
Steel Construction Since 1929
Asheville, NC ■ Cincinnati, OH ■ Chesnee, SC
P.O. Box 2630 Asheville, NC 28802� CERTIFIED
T 828 252 2771 , •s FABRICATOR
www.davesteel.com

DS
GAVE STEEL COMPANY
A WALTERS GROUP COMPANY
Findings
Analytical Results
The laboratory analytical results are summarized in the Discharge Monitoring Report (Attachment II)
and discussed below.
SDO 001
The results for SDO 001 indicate that the samples contained concentrations less than or within the
range of the specified benchmark value concentrations for the following parameters measured on -site
or at the laboratory: Non -Polar Oil & Grease/Total Petroleum Hydrocarbons (Oil & Grease), Total
Suspended Solids (TSS), pH, copper, lead, and zinc. There were no exceedances at SDO 001 during
this monitoring event.
SDO 002
The results for SDO 002 indicate that the samples contained concentrations less than or within the
range of the specified benchmark value concentrations for the following parameters measured on -site
or at the laboratory: Oil & Grease, pH, copper, and lead. However, there was a slight exceedance of
zinc at this outfall with a zinc concentration of 0.137 milligrams per liter (mg/L) vs. the benchmark of
0.126 mg/L. In addition, there was an exceedance of TSS at this outfall with a TSS concentration of
435 mg/L vs. the benchmark of 100 mg/L.
Monitoring relief was granted at DSCO in 2014 for zinc exceedances, so zinc exceedances by
themselves do not trigger Tiered responses. However, as this is the second consecutive TSS
exceedance for SDO 002, DSCO will implement a Tier Two response for TSS for this outfall as
described in the Conclusions section below.
The laboratory analytical report and chain -of -custody form are included as Attachment III to this
document.
Qualitative Results
The SDO Qualitative Monitoring Report did not warrant further investigation regarding stormwater
outfall SDO 001. No foam, oil sheen, or erosion/deposition was observed at this outfall. The SDO 001
discharge did not have many floating solids, clarity was good, and suspended solids were low.
The SDO Qualitative Monitoring Report did warrant further investigation regarding stormwater outfall
SDO 002. No foam, oil sheen, or erosion/deposition was observed at this outfall. However, the SDO
002 discharge had moderate clarity with low and moderate levels of floating and suspended solids,
respectively.
No other deficiencies were observed at SDO 001 and SDO 002 during the Qualitative Monitoring event,
and no other obvious indicators of stormwater pollution were observed. The system appeared to be
operating as designed and was in good order. Please see the qualitative report included as Attachment
IV for more information.
Conclusions
There were no exceedances of benchmark values or obvious indicators of stormwater pollution at SDO
001 during this monitoring event. However, SDO 002 had two exceedances: one for zinc and one for
TSS. Because this is the second consecutive TSS exceedance, SDO 002 will now have Tier Two
status. DSCO will implement the following Tier Two response for SDO 002:
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DS
GAVE STEEL COMPANY
A WALTERS GROUP COMPANY
Tier Two
1. Repeat all the required actions outlined in the stormwater permit for Tier One.
2. Immediately institute monthly monitoring and reporting for all parameters. The permittee shall
conduct monthly monitoring at every outfall where a sampling result exceeded the benchmark
value for two consecutive samples. Monthly (analytical and qualitative) monitoring shall continue
until three consecutive sample results are below the benchmark values or within benchmark
range.
3. If no discharge occurs during the sampling period, the permittee is required to submit a monthly
monitoring report indicating "No Flow" to comply with reporting requirements.
4. Alternatively, in lieu of steps 2 and 3, the permittee may, after two consecutive exceedances,
exercise the option of contacting the DEMLR Regional Engineer as provided below in Tier
Three. The Regional Engineer may direct the response actions on the part of the permittee as
provided in Tier Three, including reduced or additional sampling parameters or frequency.
5. Maintain a record of the Tier Two response in the Stormwater Pollution Prevention Plan (SPPP).
6. Continue Tier Two response obligations throughout the permit renewal process.
DSCO will conduct the next semiannual monitoring event for SDO 001 sometime between July 1 and
December 31, 2021. SDO 002 will be monitored again in April 2021. Please contact me with
operational or compliance issues.
Sincerely,
Dave Steel Company, Inc.
�oj
Allan Clontz
Environmental Health & Safety Director
828-252-2771
Attachments: Figure 1 — Stormwater Pollution Prevention Plan Figure
Attachment I — Stormwater Flow Calculations
Attachment 11 — Discharge Monitoring Report for SDO 001 and SDO 002
Attachment III — Laboratory Analytical Report and Chain -of -Custody
Attachment IV — Qualitative Monitoring Report for SDO 001 and SDO 002
cc: Uploaded to the NPDES Stormwater Permit Data Monitoring Report (DMR) Upload site at
https://edocs.deg.nc.gov/Forms/SW-DMR
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