NC0048712_Regional Office Historical File Pre 2018

03/16/2004 07:55 919733961
PAGE 02/02
ebruaxy 20, 2004
Mr. David Goodrich
NCDENR-DWQ-NpDES Unit
1617 Mail Service Center
Raleigh, North. Carolina 27699-1 6 17
Re- Request to Rescind Permit NC0048712
pLirlyti- ,Va yba Ai-
6555 CornmScope Road., Catawba, NC 2860'
Dean Mr.. Goodrich:
During July 2002, Alcoa E cusict Inc, (Alcoa) install k : ion change system that has
allowed the Catawba Operation to operate without disci .; ;. waste ater. ,connection t©
the discharge point has been removed and preventive procedures have been
developed to prevent the accidental release of process vv,' ''ecvater to storm sewers.
Ai this time, Alcoa requests that the DENR formally resc ''• the referenced NPDES permit.
If you have any questions or comments regarding this lett
385-8801 or email me at [e-mail]_
Alcoa tngmeered
PrediActt
53 Saville Straw
P© hog 187
Crerami, PA 17929-0187
Phone: [phone]
Fax [phone]
Sin
h
E
signs, I.mc. — Catawba Operation
kF
cc: Rex Gleason, WallerQuality Supervisor
NCDENR - Mooresville Regional Office
919 North Main Street
Mooresville, NC 28115
feel free to call me at 570-
FEB 25 004
fi

Mrcnaer r easaey, 1.20vem0r
William G. Ross Jr,,, Secretary
North Carolina Department of Environment and Natural Resources
Alan W, Klimek, P.E. Director ,..
Division of Water Quality
June 9 2003
George Chapman
Alcoa Extrusions Inc
PO Box 100
Catawba, NC 28609
SUBJECT: Payment Acknowledgrnent
Civil Penalty Assessment
Alcoa Extrusions Inc -Catawba
Catawba County
Permit No: NC0048712
TX-2002-0028
Dear Mr. Chapman:
This letter is to acknowledge receipt of check No. 15183 in the amount of $1,086.63 received from
you dated June 2., 2003. This payment satisfies in full the civil assessment levied against the
subject facility and this case has been closed. Payment of this penalty in no way precludes future
action by this Division for additional violations of the applicable Statutes, Regulations, or Permits,
If you have any questions, please call. Robert L Sledge at 919-733-5083 Ext.547.
Sincerely,
j#0., 7114 e4-4.411
For Coleen Sullins, Deputy Director
Division of Water Quality
cc: Enforcement File #: TX-2002-0028
Mooresville Regional Office Supervisor
Central Files
1617 Mail Service Center Raleigh, NC 27699-1617
9) 733-7015 Customer Service 1 800 82 7748

Michael F. Easley, Governor
VVilliam G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan VV, Klimek, P.'=., Director
Division of Water Quality
7001 2 al0 0005 0287 9313igust 28, 2002
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr, George Chapman
ALCOA Extrusions, Inc.
Post Office Box 100
Catawba, North Carolina 28609
SUBJECT:
Dear Mr. Chapman:
Notice of Violation and Assessment of Civil Penalty for Violations of NC
General Statute 143-215.1(a)(6) and NPDES Permit No. NC0048712
ALCOA Extrusions, Inc.
Catawba County
TX 02-028
This letter transmits a Notice of Violation and assessment of civil penalty against ALCOA
Extrusions in the amount of $1,086.63 ($1,000 civil penalty + $86.63 enforcement costs),
This assessment is based upon the following facts, A review of the facility's toxicity self -
monitoring data from June 2002 has been conducted. The review has shown ALCOA Extrusions to be in
violation of the 90©ia 24-hour pass/fail acute toxicity effluent discharge limitation found in NPDES
Permit No. NC0048712. ALCOA Extrusions' toxicity self -monitoring report for June 2002 revealed the
following violations.
June 2002 FAIL
Based upon the above fact(s), I conclude as a matter of law that ALCOA Extrusions violated the
terms, conditions or requirements of NPDES Permit No. NC0048712 and NCGS 143-215.1(a)(6) in the
manner and extent showed above, A civil penalty in accordance with the maximum established by
NCGS 143-215.6A(a)(2) may be assessed against a person who violates the terms, conditions or
requirements of a permit required by NCGS 143-215.1(a).
Based upon the above findings of fact and conclusions of law, and in accordance with authority
provided by the Secretary of the Department of Environment and Natural Resources and the Director of
the Division of Water Quality, I, D. Rex. Gleason, Water Quality Regional Supervisor for the .Mooresville
Region, hereby make the following civil penalty assessment against ALCOA Extrusions:
N=EN
N C. Division of Water Quality
919 North Main Street, Mooresville NC 25115 Phone (704) 663-'1699
FAX [phone]C

o
86.63
FOr / of the one (1) violation of NCGS 143-
215.1(a)(6) and NPDES Permit No, NC0048712, by
discharging waste into the waters of the State in violation of
the per-mit effluent limit for acute toxicity during the month
of June 2002.
TOTAL CIVIL PENALTY
Enforcement costs.
TOTAL AMOUNT DUE
Pursuant to NCGS 143-215.6A(c), in determining the amount of the penalty I have taken into
account the Findings of Fact and Conclusions of Law and the factors set forth at NCGS 143B-282.1(b),
which are:
(1)
(2)
(4)
(5)
(6)
(7)
(8)
The degree and extent ofharm to the natural resources of the State, to the public health, or to
private property resulting from the violation;
The duration and gravity of the violation;
The effect on ground or surface water quantity or quality or on air quality;
The cost of rectifying the damage;
The amount of money saved by noncompliance;
Whether the violation was committed willfully or intentionally;
The prior record of the violator in complying or failing to comply with programs over which the
Environmental Management Commission has regulatory authority; and
The cost to the State of the enforcement procedures.
Within thirty days receipt of this notice, you must do one of the following:
Submit payment of the penalty:
Payment should be made directly to the Department of Environment and Natural Resources (do
not include waiver form). Payment of the penalty will not foreclose enforcement action for any
continuing or new violation(s). Please submit payment to the attention of:
Point Source Complianee/Enforcement Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
OR
2. Submit a written request for remission or mitigation including a detailed justification for
such request.
A request for remission or mitigation is limited to consideration of the reasonableness of the
amount of the penalty and is not the proper procedure for contesting the accuracy of any of the

statements contained in the assessment letter. Because a remission request forecloses the option
of an administrative hearing, such a request must be accompanied by a waiver of your right to an
administrative hearing and a stipulation that there are no factual or legal issues in dispute, You
must execute and return to this office the attached waiver and stipulation form and a detailed
statement that you believe establishes whether:
(a)
(b)
(c)
(d)
(e)
one or more of the civil penalty assessment factors in NCGS 143B-282:1(b) was
wrongfully applied to the detriment of the petitioner;
the violator promptly abated continuing environmental damage resulting from the
violations;
the violation was inadvertent or a result of an accident;
the violator had been assessed civil penalties for any previous violations:
payment of the civil penalty will prevent payment for the remaining necessary remedial
actions.
Please submit this information to the attention of;
Ms. Coleen Sullins
Water Quality Section Chief
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Please note that all information presented in support of a request for remission must he submitted
in writing. The Director of the Division of Water Quality will review the information during a
bimonthly enforcement conference and inform you of his decision in the matter of the remission
request. His response will provide details regarding case status, directions for payment and
provision for further appeal of the penalty to the Environmental Management Commission's
Committee on Civil Penalty Remissions. Please be advised that the Committee cannot consider
information that was not art of the original remission request considered by the Director and,
therefore, it is very important that you prepare a complete and thorough statement in support of
your request for remission.
OR
Submit a written request for an administrative hearing:.
If you wish to contest any statement in this assessment letter,. you must request an administrative
hearing. This request must be in the form of a written petition to the Office of Administrative
Hearings and must conform to Chapter 150B of the North Carolina General Statutes,. You must:
File your original petition with the
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, North Carolina 27699-6714
and

a
or hand-deliv. er a copy of the petition t
.r. Dan Oakley, General Counsel
Department o`Environment and Natural Resou
1601 Mail Service Center
Raleigh, North Carolina 2 9 -1601
Failure to exercise one of the options above thirty days as evidenced by a date stamp (not
a postmark) indicating when we received your response, ill result in this matter being referred to the
Attorney GeneraPs Office with a request to initiate a civil action to collect the penalty
Please be advised that any continuing violationl:s) ay be the subject of new enforee ent
action, irseluding art additional penalty.: If you have any questions about this coal penalty assessment,
please contact the Water Quality Section staff of the Mooresville Regional Office at (704) 3-1 99.
Date
Regional Supervisor wiattaeh. cnt;
Point Source Compliance/Enforcement Unit File 'attaehmet
Aquatic Toxicology Unit File iv/attachments
CentralFiles wlattachments
D. Rex Gleason, P E
Water Quality Regional Superb isor
le Regional Office
on dfWater Quality,.

CIVIL PENALTY ASSESSMENT ADDENDUM
The Division of Water Quality (DWQ) issues/reissues NPDES permits with whole effluent toxicity
(WET) limits. The current. chronic toxicity test condition language requires perrnittees to conduct multiple
concentration testing upon a single quarterly failure to meet the chronic toxicity permit limit. Permittees with
NPDES permits which contain "old" chronic toxicity pass/fail testing language will have the OPTION to respond
to arty single quarterly toxicity test failure with follow-up multiple concentration toxicity testing (as contained in
the current language) or single concentration toxicity testing, thereby influencing the level of DWQ' s enforcement.
response.
NOTE: Choosing to respond to a chronic toxicity "fail" result with a pass/fail test instead of conducting multiple
concentration toxicity testing during the second and third months of the monitoring quarter (monitoring quarter
defined by your permit) will result in enforcement for single concentration test results that do not meet chronic
toxicity permit limitations.
Important WET Enforcement Policy items are:
1. CHRONIC TOXICITY TESTING
• The first test of the quarter can be conducted as either a pass/fail test or a chronic
value (ChV) test.
• If the :pass/fail test fails or if the ChV is lower than the limit, then a Notice of
Violation (NOV) is issued and at least two ChV tests (one per month) will be
conducted over the following two months. As many analyses as can be completed
will be accepted.
• A NOV will be issued for ANY test result failing to meet the permit limit.
• Any civil penalties assessed will be based on performance over a quarter. Facilities
may be assessed civil penalties for any month in which compliance with the WET
limit is not achieved. DWQ's enforcement response can be influenced by conducting
multiple concentration testing for the second and third months of the monitoring
quarter. Chronic values for all follow-up tests will be averaged arithmetically. If the
average is the chronic permit limit, then civil penalties will not be assessed for
monthly violations occurring during the quarter. If the average chronic value is < the
permit limit, the facility will be assessed civil penalties for each month during the
quarter in which compliance with WET was not achieved.
• NPDES Permits containing chronic toxicity pass/fail testing will be modified upon
permit renewal to include the new permit language.
11. ACUTE TOXICITY TESTING
• A NOV will be issued for each acute limit violation.
• A civil penalty will be assessed for any two consecutive acute limit violations,
If you are unable to consistently comply with your toxicity permit :limitation, you may notify your
respective Regional Office to discuss the possibility of entering into a Special Order by Consent (SOC), The SOC
provides conditional compliance for permit parameters with which the facility can not consistently comply and
may be issued in situations where facility operation and maintenance are not in question. If a SOC is signed by the
permittee/DWQ and contains toxicity as a noncompliant parameter, you will be required to: conduct a Toxicity
Reduction Evaluation (TRE), submit quarterly TRE progress reports and eliminate/reduce effluent toxicants so
that compliance with the whole effluent toxicity limit can be demonstrated,

STATE OF NORTH CAROLINA
CouNTY OF CATA
A
IN THE MATTER OF ASSESS
OF CIVIL; PENALTY AG X 1 ST
ALCOA EXTRUSIONS, INC.
PERMIT NO. NC0048712
DEP * T OF ENVIR {
NA E SOURCES
Having been assessed civil penalties totaling
violati n(s as set forth in the assessment document f the Division c f'w ater Quality dated
the undersigned, desiring to seek remission ,f lae civil penalties, does
hereby waive the right to a• 'nistrative 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 ofWater Quality within 30 days of receipt of the notice of assessment. No
new evidence in support ofa remission request will be allowed after 30 days from the receipt of the
notice of asessrg ent.
WAIVER OF RIGHT TO AN
ST TIVE HE G
STIPULATION OF FACTS
FILE N; T. 2-8
the
v
fo
ADDRESS
BY
TELEPHONE

Whole Effluent Toxicity Testing Seif-Monitoring Summary
1"IULHY kr,QUIRLM ENT
A Ugust 16, 2002
YEAR IAN FEB 01 01 1 MAY JON IIJL AUG S11 OCT' NOV DEE
AtsCosii Extrusions Penn 24lir tiff liar 90% ftlut
100004.8711001 i4egitrt1/1/1 995 Fiequosi y!Q ISF ,Marlw Srp Dec
County: Catawba Region: 43100 0 00 0 E12
P6i 0.611117 Svc, ad
7Q10, 0 IWCVASIDO
litonConip:Single
1.99F -- Pass Fast Pass Pass
1 WS . - -- Pass Pats Pass 83 01.
FOR Fail Fail Pats Pass Pass Fail' PassiPass Pass Pass Past
EOM --- — Pass Past Pass Faii,Fail
2.002 Pass l'ad 1ssil Fail FM FM )
V Prti t 990 Data Available
LEGENDi
PERM ti Ptinnit Erviiretnend liET 10da31ai8820 Target FitqW:gley trlitunsting iirquency: 4), Quimists34 MotUttlyi0301 B ins:sillily: SA- Sis atiannitally A- Annually, 1)0011,- Osily when tlistritsvings istscsusanst nioniststig reqtArtnie
Begia 4, First mouth requited SQ00 Rtiorisiat; tritium low flow 4131 88 3188.08) 4 a, quarterly usisisiring incrrstrt 10041114y upsii twists is NE 30ii1/11111S lhat terring 9,111a3 masts1 Art143 Ost Nisieniop Compliantir liaqUitaalala
P„F 9830144301 draw (MODI Mainsaits wage concsiitrarion ISP East/Fad ta.4I AC 'is. Arate CI IR clams,
Dabs Miamian' - radical Atiaassia- CeSsIdid 4.1. .s • Yu - aid4081, 10 Chid s Massa - xissikla:1 43 aiiiy at Eased saidenta it A ln0 4. at Palf..414844 h .DWQ 20 IrmL: riok link.- - Bad
Rritstrtinit Motown = Data itIME rciftmed, NS - Not .roported Facility Assisity So , I1n4.h 8400 Nosily ksorillis 4. 8812100,11- Arists but sci dististigiogs 0l102sla ssialablii 02r month in question; 11C .signattini netsted

Environmental Testing Solutions, LLC
PO Box 790
Pisgah Forest, NC 28768
Effluent Toxicity Report Form - Acute Pass/Fan
Phone, [phone]
Fax: [phone]
E-mail. JimSurnn Learn
Date: June 25, 2002
Facility: Alcoa En
oducrs NPDES #: NC 0048712 Pipe 001 County: Catawba
Laboratory Performing Test, Environmental Testing Solutions, LLC
Signature of Operator in Responsible Charge:
Signature of Laboratory" Supervisor:
Comments: .
Project 360
Sample: 020606.01
To: North Carolina Departrnent of Environment and Natural Resources
DWQI Environmental Sciences Branch
1621 Mail Service Center
Raleigh, NC 27699-1621
North Carolina Acute Pass/Fail Toxicity Test
Collection Date: 06-04-02
Collection Time, 0855
Test Start Date: 06-06-02
SarnpleTypeDuration
Comp
Duration
24-hour
Alkalinity (mg CaC01)
:Hardness (mg CaCO,./L)
Conductivity (umhosicm)
Total Residual Chlorine (nrig/L)
Sample Ternp, at Receipt (C)
30 34
49 34
165
203
a '4=
AUG
pH (—
D.O. (mg/L)
Control
Treatment
Control
Treatment
7.82
7,91
7.49
7.71
7.9
0
Mortality
Treatment 1 (Control)
Treatment 2 (Exposure
Concentration
Tested
Replicate
A B C
0%
A
100%
0%
1009/0
10%
100%
0%
80%
NOSC: if mean control mortality exceeds 10%, thetest is considered invalid.
Mean Morta
' 2,5$6
Calculate using Arc -Sine
Square Root transformed
data,
Calculated Student's t
Tabular Student's t
(ONE TAILED)
13:148
3.143
PASS
FAIL
if t.10:' ab:SOl'ave vaiut of the calculated less than or equal a the absolute value of the tabular t, check PASS.
If the absolute value of the calculated t gheater than the absolute value of the tabular.% chett.k. FAIL,
If all vessels within each Treatment have the Sam c response but the treatment meresponse is greater than the control, check fail
DWQ,finwi AT-2 (8/91)

Case Number.
LR
90
93
LV
TX
TX
TX
02
02
150
Yio
Alcoa Extrusions, Inc.
Alcoa Extrusions, Inc,
Alcoa Extrusions, Inc.
Alcoa Extrusions Inc-cata ba
Permit
NC0048712
NC004871 2
Alcoa Extrusions In
atawba
Alcoa Extrusions nc-catawba
Alcoa Extrusions lnc-catawba
NC0048712
CATAWBA
CATAWBA
CATAWBA
NC0048712
I NC0048712
Iat
Assessed
03/ /90 1
03/ 0/93
CATAWBA
NC0048712
NC0048712
atawba
0 22/97
05/26/00
Catawba
Catawba
04/04/02
05/29/02
07 6/02
* Database pull only. Complete information may he found through tile search. Cases with dale assessed greater
than 7/1/98 may be regional assessments. Some cases are still open for final agency decision, Cases labeled "LV"
or "LM are violations of permitted effluent limits and/or monitoring requirements. No violations <20% over the threshold
were assessed a civil penalty. Description of case types can be found on the next page.
Date Run: August 16, 2002
Total Amoont Pai(4,
a,5e Penalty todate case
$150.00
$500.00
$1,256.06
$2,097.77
$1,086.63
$1 086.63
2,086.63
50.00
$500.00
$
6.06
$2,097.77
$1,086,63
$8,263.72
sedSubba5In
04/05/90
02/27/97
06/23/00
05/06/02
$5,090.46
30832

Fast Track Worksheet
Case Number
Facility Name
Permit Number
Previous Case
in the Last
two years
02
128
NC0048712
Number of Assessments for previous 6 ©i Rs
tory Maximun
per violation
01 0 20 03© 40 0 6
1,00
Total Assessment Factor
Number Number
Violations Assessed Parameter
Acute Tox
6/02
Comments
Total
Penalty/ Assessment
Violation Violation Factor Total Penalty
Exceed whole
effluent toxicity
$1000
Grand. Total Penalty
Percent of the Maximum Penalty
Authorized by G.S. 143-215.6A.
$1000,00
$1000.0©
10.00
Acute Tox Vioi Lion for 6/02,

ftchael F, Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
6/19/03
George Chapman
Alcoa Extrusions Inc
PO Box 100
Catawba, NC 28609
SUBJECT: Payment Acknowledgment
Civil Penalty Assessment
Alcoa Extrusions Inc -Catawba
Catawba County
Permit No: NC0048712
TX-2002-0025
Dear Mr. Chapman:
JUN
This letter is to acknowledge receipt of check No. 15183 in the amount of $2,086.63 received from
you dated June 2, 2003. This payment satisfies in full the civil assessment levied against the
subject facility and this case has been closed. Payment of this penalty in no way precludes future
action by this Division for additional violations of the applicable Statutes, Regulations, or Permits.
If you have any questions, please call Robert L Sledge at 919-733-5083 Ext.547.
Sincerely,
277 (7
For Coleen Sullins, Deputy Director
Division of Water Quality
cc: Enforcement File #: TX-2002-0025
Mooresville Regional Office Supervisor
Central Files
1617 Mail Service Center Raleigh, NC 27699-1617 [phone]
Customer Service 1 800 623-7748

alLs(-
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. George Chapman.
ALCOA Extrusions, Inc.
Post Office Box 100
Catawba, North Carolina 28609
SUBJECT:
Dear Mr. Chapman:
Michael F. Easley, Governor
witarn G. Ross Jr.. Secretary
North Carolina Department of Environment an C Natural Resources
Atari VV RE., Dire:.lof
Division of Watet Quality
July 16, 200.2
7t-k:
Notice of Violation and Assessm.ent. of Civil Penalty for Violations of NC
General Statute 143-215.1(a)(6) and NPDES Permit No, NC0048712
ALCOA. Extrusions, Inc.
Catawba County
TX 0.2-025
This letter transmits a Notice of Violation and assessment of civil. penalty against ALCOA
Extrusions, Inc. (the Company) in the amount of $2„086.63 (S2,000 civil penalty + $86,63 enforcement
costs).
This assessment is based upon the following. facts. A review ofthe facility's toxicity self -
monitoring data from April through May 2002 has been conducted. The review has shown the Company
to be in violation of the 90n/0 24-hour pass/fail acute toxicity effluent discharge limitation found in
NPDES Permit No, NC0048712, The Company's toxicity self -monitoring reports for April through May
2002 revealedthe following violations.
April 2002 Fail
Ma3! 2002 Fail
Based upon the above fact(s), I conclude as a matter of law that the Company violated the terms,
conditions or requirements of NPDES Permit No. NC00487-12 and NCGS 143-215.1(a)(6) in the manner
and extent showed above. A civil penalty in accordance with the maximum established by NCGS 143-
21.5.6A(a)(2) may be assessed against a person who violates the terms, conditions or requirements of a
permit required by NCGS 143-215,1(a).
41K76,
4.0044
CiEirci
N. C. Division of Water Quality
91.9 Nortn Main Stree:, Mooresville, NO 28115
Pnone (704) 6a63-1.6©c
FAX [phone]

Based upon the above findings of fact and conclusions of law, and in accordance with authority
provided by the Secretary of the Department of Environment and Natural Resources and the Director of
the Division of Water Quality, I, D. Rex Gleason, Water Quality Regional Supervisor for the Mooresville
'Region, hereby make the 'following civil penalty assessment against ALCO.A Extrusions, Inc.:
For // of the one (I) violation of NCGS 143-
215.I.(a)(6) and NPDES Permit No, NC0048712, by
discharging waste into the waters of the State in violation of
the permit effluent limit for acute toxicity during the month
of April. 2002.
For / of the one (1) violation of NCGS 14.3-
215.1(a)(6) and NPDES Permit No. NC00487.12, bv
discharging waste into the waters of the State in violation. of
the permitted effluent limit for acute toxicity during the
month of May 2002.
TOTAL CIVIL PENALTY
86.63 Enforcement costs.
6 -7
27(7 TOTAL AMOUNT DUE
Pursuant to NCGS 1.43-215.6A(c), in determining the amount of the penalty 1 have taken into
account the Findings of Fa.ct and Conclusions of Law and the factors set forth at NCGS 143B-282.1 (b),
which are;
The degree and extent, of harm to the natural resources of the State, to the public health, or to
private property resulting from the violations;
(2) The duration and gravity of the violations;
(3) The effect on ground or surface, water quantity Or quality or on air quality:
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violations were committed willfully or intentionally;
(.7.) The prior record of the violator in complying or failing to comply with programs over which the
Environmental Management Commission has regulatory authority: and
(S). The cost to the State of the enforcement procedures.
Within thirty days receipt of this notice, you must do one of the following:
Submit payment of the penalty:
Payment should be made directly to the Department of Environment and Natural Resources (do
not include waiver _form). Payment of the penalty will not foreclose enforcement action for any
continuing or new violation(s). Please -submit payment to the attention of:

Point Source Compliance/Enforcement Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
OR
Submit a written request for remission or rttititgation including a detailed jostifacat'ian for
such request.
A. request for remission or mitigation is limited to consideration of the reasonableness of the
amount of the penalty and is not the proper procedure for contesting the accuracy of any of the
statements contained in the assessment letter. Because a remission request forecloses the option
of an administrative hearing, such a request must be accompanied by a waiver of your right to an
administrative hearing and a stipulation that there are no factual or legal issues in dispute. You
must execute and return to this office the attached waiver and stipulation form and a detailed
statement that you believe establishes whether:
one or more of the civil penalty assessment factors in NCGS 143B-282.1 1 Pas
wrongfully applied to the detriment of the petitioner;
the violator promptly abated continuing environmental damage resulting from the
violations;
tite violations were inadvertent or a result of an accident;
the violator had been assessed civil penalties for any previous violations,
payment of the civil penalty will prevent payment for the remaining, necessary rem.ediai
actions,
Please submit this information 'o the attention of:
Ms, Coleen Sullins
Water Quality Section Chief
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1.61.7
Please note that al] information presented in support of a request ission. must be submitted
in writing, The Director of the Division of Water Quality will review the information during a
bimonthly enforcement conference and inform you of his decision in the matter of the remission
request. Mis response will provide details regarding case status, directions for payment and
provision for further appeal of the penalty to the Environmental Management Commission's
Committee. on Civil Penalty Remissions, Please be advised that the 'Committee cannot consider
information that was not part of the original remission request considered by the Director and,
therefore, it is very important that you pre . are a ,co m lete and thorouh statement in su ort of
your request for remission.
OR
Submit a written request for an administrative hea'rin

If you wish to contest any statement to this assessment letter, you must request an adrninis
hearing. This request must be in the form of a written petition to the Office of Adof Achninistratry
Hearings and must conform to Chapter 150B of the North Carolina General Statutes. Youmust:
File your trri i al petition with the
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, North Carolina E99-6714
and
ail or hand -deliver a copy- of the petition to
Mr. Dan Oakley{, General Counsel
Department of Environment and Natural Resources
1601 Mail Service Center
Raleigh, North Carolina 276 9nl601
Failure to exercise one of the options above within thirty days as evidenced by a date stamp (not
a postmark) ark,.) Indicating when we received your response, will result in this matter being referred to the
Attorney General's Office with arequest to initiate a civil action to collect the penalty
.please be advised that any: continuing violat on(s may be the subject of a new nf"or•ce et t
action, including an additional penalty.. If you have any questions about this civil penalty assessment.
please eontact the Water Quality Section staff of the Mooresville Regional Office at (704) 6 -1699
Date
AITAC1HMENTS
x Gleason, P.E.
Water Quality Regional Supervisor
looresville Regional Office
liFision of Water +.ualty
cc: Regional Supervisor wianaehments
Point Source a:ornpliance/Enftlorcement Unit File iattachn3ents
Aquatic Toxicology Unit ,pile whattachments
Central Files wsFt"attae ents

CIVIL PENALTY ASSESSMENT ADDENDUM
The Division of Water Quality (DWQ) issues/reissues NPDES permits with whole effluent toxicity
(WET) limits. The current chronic toxicity test condition language requires perrnittees to conduct multiple,
concentration testing upon a single quarterly failure to meet the chronic toxicity permit limit. Permittees with
NPDES permits which contain "old" chronic toxicity pass/fail testing language will have the OPTION to respond
to any single quarterly toxicity test failure with follow-up multiple concentration toxicity testing (as contained in
the current language) or single concentration toxicity testing, thereby influencing the level of DWQs enforcement
response.
NOTE: Choosing to respond to a chronic toxicity "fair result with a pass/fail test instead of conducting multiple
concentration toxicity testing during the second and third months of the monitoring quarter (monitoring quarter
defined by your permit) will result in enforcement for single concentration test results that do not meet chronic
toxicity permit limitations.
Important WET Enforcement Policy items are:
1. CHRONIC TOXICITY TESTING
• The first test of the quarter can be conducted as either a pass/fail test or a chronic
value (ChV) test.
• If the pass/fail test fails or if the ChV is lower than the limit. then a Notice of
Violation (NOV) is issued and at least two ChV tests (one per month) will be
conducted over the following two months, As many analyses as can be completed
will be accepted.
• A NOV will be issued for ANY test result failing to meet the permit limit.
• Any civil penalties assessed will he based on performance over a quarter. Fadiliiies
may be assessed civil penalties for any month in which compliance with the WET
limit is not achieved. DWQ's enforcement response can be influenced by conducting
multiple concentration testing for the second and third months of the monitoring
quarter. Chronic values for foilow-up tests will be averaged arithmetically. If the
average is .:21: the chronic permit limit. then civil penalties will not be assessed for
monthly violations occurring during the quarter. If the average chronic value is < the
permit limit, the facility will be assessed civil penalties for each month during the
quarter in which compliance with WET was not achieved.
• NPDES Permits containing chronic toxicity pass/fail testing, will be modified, upon
permit renewal to include the new permit language,
ACUTE TOXICI I Y TESTING
j • A NOV will be issued for each acute limit violation.
• A civil penalty will be assessed for any two consecutive acute limit violations.
If you are unable to consistently comply with your toxicity' permit limitation, you may notify your
respective Regional Office to discuss the possibility of entering into a Special Order by Consent (SOC). The SOC
provides conditional compliance for permit parameters with which the facility can not consistently comply and.
may be issued in situations where facility operation and maintenance are not in question. If a SOC is signed by the
perrnittee/DWQ and contains toxicity as a noncompliant parameter, you will be required to: conduct a Toxicity
Reduction Evaluation (TRE),. submit quarterly TRE progress reports and eliminate/reduce effluent toxicants so
that compliance with the whole effluent toxicity limit can be demonstrated.

STATE OF NORTH CAROLINA
COUNTY F CATANATIA
IN THE MATTER OF ASSESS l T
OF CIVIL PENALTY T AGAINST
Al"OA EXTRUSIONS, INC
PE IT NO. NC0048712
L EP T T OF ENVIRO NT
Haying been assessed;ei it permit es rota
iralatien('s) as setforth in the sessrent document of the. Div ofater Quality dated
the undersigned, desiring to seek remission ofthe email penalties, does
hereby xa.i e 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 ofrernissn of this CiVilpenalty Hurst be submitted to the
Director of the Division of Water Quality within 30 days of receipt of the notice of assessment No
videnee in support of a renr.ission request will be allowed after 30 days from the receipt of the
e of assessment;
RESOURCES
WAIVER GHT T
ADMINISTRATIVE E HE
STIPULATION OF FATS
FIE
O. TX 02-025
the days cat0
or
BY
ADDRE
S
TELEPI-t a

EnvironmentalTesting Solutions, LLC
PO Box 790
Pisgah Forest, NC 28768
Effluent Toxicity Report Form - Acute Pass/Fail
Phone: 62- 1.93
Fax: [phone]
E-mail: JimSumner@zol..com
Date: April 1, 2002
Facility: Alcoa EngineerProducts NPDES 34: NC 0048712 Pipe 001 County: Catawba
Laboratory Performing Test: Environmental Testing Solutions, LLC
Signature of Operator in Responsible Charge:
Signature of Laboratory Supervisor,
Comments:
Project: 296
Sample: 020221,06
Mail Original To:
North Carolina Department of Environment and Natural Resources
DWQ:( Environmental Sciences Branch
1621 Mail Service Center
Raleigh, NC 27699-1621
North Carolina Acute Pass/Fail Toxicity Test
Collection Date.: 03-19-02
Collection Time: 0934
Test Star Date: 03-21-02
SarnpleiTypeiDuration
Grab
Comp Dura
X 24.5-hour
Hardness (mg
Conductivity (urnhosicm
Total Residual Chlorine (mg/1)
Sample Temp.. at Receipt ('C)
Organism Tested
PiiphaJes prmeIas
pH (S.U.)
Control
Treatment
Control
D.O. (mg/1)
Treatment
7.85
17.69
8.1
' 8.0
7,76
7.71
8.0
8.1
?1orta1it
Treatment 1 (Control)
Treatment 2 (Exposure)
Concentration
Tested
Note: If mean control mortality exceeds
90%
A
A
70%
Replicate
B C
0%
40%
%, the test is consider
90%
0%
90%.
valid.
Mean Mortaiity
0.0 %
72.5%
5
Calculate using Arc -Sine
Square Root transformed
data:
Calculated Student's t
Tabular Student's t
(ONE TAILED)
6.593
4.541
PASS
FAIL
If the absoluse value Df the calculated T iS less than or equal to the absolute value of the tabular t, check PASS,
If the aosoluic value. of Me calculated t is „greater than the absolute value of the 'tabular Lcheck. FAIL
If all vessels within each treatment have the same response but the treatment Two response is greater than the con.rrol, check fail.
m
0
r7-1
DWQ form AT-2 (8/91)

Environmental Testing Solutions, LLC •
PO Box 790
Pisgah Forest. NC 28768
Revie
by A TTP
Effluent Toxicity Report Form - Acute Pass/Fail
Phone: [phone]
Fax: [phone]
JimSurnnerLa Lcom
Date, April 22, 2002
Facility: Alcoa Engineered Products NPDES 0: NC 0048712
Laboratory Performing Test: Environmental Testing Solutions. LLC
Sinature of Operator in Responsible Charge:
Sip -azure of Laboratory Supervisor
Pipe 001 County: Catawba
COMMentS: .
Project 307
Sample: 020404,02
Mail Original To: North Carolina Department of Environment and Natural 'Re -sources
MVO,' Environmental Sciences Branch
1621 Mail Service Center
Raleigh, NC 27699-1621
North Carolina Acute Pass/Fail Toxicity, Test
Collection Date: 04-' 02-02
Collection Time.: 0900
Test Start Date: 04-04-02
SampleiTyperD
Grab Como.
X
Duration
24-hour
Hardness (rn 4,1)
Conductivity (urp.hosicrn)
Total Residual Chlorine (mg11)
Sample Temp. at Receipt (C)
46
42
161 196
< 0.10
0.5
RE
Etiv
RN 0 3 2002
Environmental Sciences Branch
Organism Tested
Pimephales promelas
pH (S.U.)
D.O. (mg/1)
Control.
Treatment
Control
Treatment
8.01
7.36
7,87
7.70
4I•
8.1
81.
8.1
Mortality
Note:
Treatment 1 (Control;
Treatment 2 (Exposure)
Concentration
Tested
n control mortality exce
90%
Replicate
A
014,
A
60%.
901,
60r
80°,),
10%, the Lest is considered invalid.
Mean Morality
72,5%
Calculate using Arc -Sint
Square Root transformed
da.ba,
Calculated Student's t
Tabular Student's t • 4.541
(ONE TAILED)
9,797
PASS
FAIL
If the absolute value of the calculated t less than or equal to the absolute value of the tabular L check PASS
If the absolute value of the calculated t is greater than the absolute value of the tabular t, check FAIL
If all vessels within each armament have the same resmnse but the trcaunent rwo ttsponse is greater than the conn-ol, check fail.
DWO form AT-2 (8/91)

Date Run: July 10, 2002
:eutnb
LR
90
93
LV
TX
96
00
TX
TX
02
02
TX
02
150
Alcoa Extrusions, Inc.
Alcoa Extrusions, Inc.
a Extrusions, Inc.
Alcoa Extrusions Inc-catawba
Alcoa Extrusions Inc-cala ba
Pecupit
NC0048712
NC0048712
NC0048712
NC0048712
NC0048712
NC0048712
cow
CATAWBA
CATAWBA
CATAWBA
CATAWBA
Catawba
Catawba
Total.
Assed Case Penalty
03/2f/90
03/30/93
01/22/97
05/26/00
' Databa.se pull only. Complete information may be found through tile search, Cases with date assessed greater
than 7/1/98 may be regional assessments. Sorne cases are, still open for final agency decision, Cases labeled "LV"
or "LM" are violations of permitted effluent limits and/or monitoring requirements. No violations <20% over the threshold
were assessed a civil penalty.. Description of case types can be -found on the next page.
$ 50.00
$500.00
$1,256.06
$2,0 7.77
$1,086.63
$1,086.63
Atnoit
'aid
19 date
$150,00
$500.00
$2,097,77
,086 63
$6,177.09
case Closed Nullilast
04 05/90
04/28/93
02/27/97
05/06/02
30832
30832,
$5,090.46

tytto,,,t tt,:tittity lestirig Sell -Monitoring Surnmory
l'Ar11,11 I KFAAIARAITTNIIINT
tTAT JAN T.11 re I AR AA'le Nt AY TNN JGA1, AtA srp (K 1 14,C
()A x11 ['vele AVe '901 Nei
NUI)441,A712,1)01 RegiA Rf 11'1,0 hewelter fer .$ Sq., the
Cata,,bc RogioTo MR() SciThokio; FB,
Pr: o.o.o,ty7
7Qin lwrcl rtol)
rNRI otn,,,n roeg Pass
19ete ,- rAN. rtyt R Pact MDT
2000 l',,,,,R Volt Pane reeg f'als f`CA PPIMF PASA
200T ,- re5s VV,S Ppot Falereri
2002 fAve5 fee! PAH rail FAR
V The 19q8 Data AcailabTe
LEGENIT,
FIAARP F'8211Tlit Itc.otimomoT LrAl" Adminictulvice 1 LarucA fActpcncy I
M
,c,TAci A, AT. (,),, QuArloily.; T IT,/onacH,; O, ii[AuTlabh. A Soneennuan; A AmeglAla nVIA k` %hen rcgi cp. EA, DiAcolcioord moltitcriog
C!iSee
• „ • .4
Brgin N1 1avrAit roptirod 7Q TO c Prcticinz, strcaTA1 th% Cf UN ion + q 1 1 1. 1.41 441.41TC.RAWN IIMOK16` Upon. 1 aA,er NR MORICIO OMR uAoing moo occur TrN N An, A TTI, (Xi NonCowty CAuvel 1 1. RogTACRoloont
c Permitted flow 0A1(11) IWO*. lostream Tcame emicenteAlela nasttntil teAt AC TAk 1. R TT, 0111,414;
DALA NoTA''i,To4 1.Mitta0. ' CeriodAplolia ; my - Mysid AtioAtITT CTIAT 1„luonic P 11.4 1. If Ttloti tVrerotag, At highest coneentrzoion: rit NAtormed4 AVQ, Acirewlit4 r, ht., Rod test
ccActing Noifgvol TT, 44AM WI' ttifklfed.;414 Nor wported41. 1.AcCOTicy 1. 1. 44 ATA1,,),, IcAuctIA WRIININN 11 4teer 1.tH h'et deehmeine, t iefine for 1.1 e+Olocc

Fast Track Worksheet
Case Number
Facility Name
Permit Number
Previous Case
in the Last
two years
TX
102
Alcoa Extrusions Inc -Catawba
NC0048712
Yes
Statutory Maximun
per violation
Number of Assessments for previous 6 DMRs
0 1 0 20 03 0 40 0
1.00
6
$25,000
Total Assessment Factor =
Exit
Number Number
Violations Assessed Parameter
acute tox - 4/02
acute tox - 5/02
1
Comments
Violation
Exceed whole
effluent. toxicity
Exceed whole
effluent toxicity,
Penalty/
Violation
$10 0
0
Total
Assessment
Factor Total Penalty
Grand Total Penalty
Percent of the Maximum Penalty
Authorized by G.S. 143-215.6A.
ION 8.
$1000.00
0.01
$2000.00
4.00 I
NOTE: The 4/02 and 5/02 violations are consecutive.

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Chairman
Water Pollution Control System Operators Certification Commission
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. George Chapman, General Manager
Alcoa Extrusions, Inc,
P.O. Box 100
Catawba, NC 28609
System: Alcoa Extrusions, Inc, WWTP
Classification: Grade 1 Physical Chemical System
Subject: Designation of ORC and Backup ORC for Physical / Chemical
Permit: .NC0048712
February 10, 2003
FEB 1 8 2003
Dear Mr. Chapman:
The Water Pollution Control System Operators Certification Commission adopted Rule 15A
NCAC 8G .0306, Classification of Physical / Chemical Systems, effective April 1, 1999, In
order to insure the proper operation and maintenance of these systems, this Rule requires that
all systems permitted for a physical / chemical process to treat wastewater be classified as
physical / chemical systems.
If the subject physical / chemical system consists of systems designed for (1) the remediat.ion
of contaminated groundwater, or (2) that utilizes a primarily physical process to treat
wastewaters, (with the exception of reverse osmosis, electrodialysis, and utrafiltration
systems), then that system shall be classified as a Grade I Physical / Chemical Water Pollution
Control System. Rule 15A. NCAC 8G .0306(a)
The Water Pollution Control System Operators Certification Commission hereby classifies
your system as a Grade 1 Physical Chemical System. This classification is based on
information submitted in your application for a NPDES permit and classification rating by the
Raleigh Regional Office.
As required by Rule 15A NCAC 8G .0202(2) and the subject permit, a certified grade one
physical chemical Operator in Responsible Charge (ORC) and back-up operator must
be designated for this system. In accordance with Rule 15A NCAC 8G .0406(b),
individuals presently working at physical / chemical water pollution control systems holding a
valid Grade I., II, III, or IV wastewater treatment plant operator certification, may apply for a
conditional operators physical / chemical certificate without examination. He or she may do
so if, he or she has one year experience and has successfully completed a training school
sponsored or co -sponsored by the Commission for Grade 1 or Grade 2 Physical / Chemical
Water Pollution Control System Operators. This conditional certification allows the
bearer to act as the OC or Backup ORC of that System only, This conditional
certification must be renewed annually per section .0700 of the rules. The Rules for this
certification as well as others is found on the DWQ/Technical Assistance and Certification
Unit web page (http://h20.enristateinciusitacu).
Aifis
NZ5ENR
Technical Assistance & Certification Unit
1618 Mail Service Center, Raleigh, NC 27699-1618
DENR Customer Service Center
An Equal Opportunity Action Employer
internet httpl/h2o,enr.nc.state.usitac
Telephone [phone] Fax [phone]
Telephone [phone]
50% recycled/10% post -consumer paper

N.C., , American Water "Forks , sucian (NC W lug a physical school that
meets the school re.quirernefts for operator's certification, Please contact NC ,A 5 \ l
1 9-9694 for r iat Lion information on and for dates o s hool during year 2003,
Once taour operators have obtain grade one physical chemical certification or grade pane
conditional certrficatic n, complete and return, the enclosed designation ftmin to this ft ce by
D c rtber 31, 2003 Failure to designate a properly certified ORC and hack -up operator is a
violation of the permit issued for this system
I f we can be o
contact Janes
c
Central Files
TA(". Facility Files
ncernrng this re uaply
t 1-7f-00.6, eat. 341 or e-mail: James.Puhnctlail,rret
arse or you have any quest
ape r alters, Superlsor
Technical Assistance and Certifiation Unit

December 20, 2 02
Mr. Clay Long
A.LC©A
53 Pottsville Street
Cressona, PA 17929
Michael F. Easley
Governor
William G, Ross, Jr., Secretary
Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
Subject: DWQ Copper and Zinc Action Level Policy - Final Report
Whole Effluent Toxicity
NPDES Permit No. NC0048712
ALCOA WWTP
Catawba County
Dear Mr. Long:
Our office has received your 12/2/02 correspondence transmitting information
you provided to support ALCOA's position that copper and zinc are not causative effluent
toxicants. We are in the process of evaluating this information and will notify you of our
decision after our review is complete.
2002
if you have any questions concerning this correspondence, please contact me or Mr.
Kevin Bowden at 919.733,2.126.
Sincerely,
Matt Matthews, Supervisor
Aquatic Toxicology Unit
cc: Rex Gleason -Mooresville Regional Office
Aquatic Toxicology Unit Files
Central Files
N'
Customer Service
1-800 623-7748
Environmental Sciences Branch 1621 Mail Service Center Raleigh, NC 27699-1621 [phone]

State of North Carolina
De ailment of Environment
andNatural Resources
Division of Water Quality
Michael F. Easley, Governor
Wiliam G. Ross Jr., Secretary
Alan. Klimek, P.E., Director
December 2, 2002
MR. GEORGE CHAPMAN
PO BOX 100
CATAWBA, NC 28609
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
SUBJECT: PAYMENT ACK.NOWI.EDGEMENT
CIVIL PENALTY ASSESSMENT
ALCOA EXTRUSIONS
CATAWBA COUNTY
PERMIT NO: NC0048712
TX 02-019
Dear Mr, Chapman
This letter is to acknowledge receipt of check No. 02198078 in the amount of $1,086.67 received from
you dated September 09, 2002. This payment satisfies in full the civil assessment levied against
the subject facility and this case has been closed. Payment of this penalty in no way precludes future
actioi by this Division for additional violations of the applicable Statutes, Regulations or Permits.
If you have any questions, please call Bob Sledge at 919) 733-5083.
Sincerely,
Coieen Sullins, Chief
ater Quality Section
Cc: Enforcement File #: TX 02-019
MRO Regional Office Supervisor
Central Files
1617 Mali 'Ser lice Center, Raleigh, NC 27699-1617 Telephone [phone]t13 Fax [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10% post -consumer paper

nael F. Easley
Governor
William G. Ross, Jr., Secretary
Department of Environment and Natural Resources
Gregory J. Thorpe, Ph.D., Acting Director
Division ofWater Quality
May 29, 2002
CERTIFIED MAIL CM # 7001 2510 0005 0287 7944
RETURN RECEIPT REQUESTED
Mr. George Chapman
ALCOA Extrusions, Inc.
Post Office Box 100
Catawba, North Carolina 28609
SUBJECT:
Dear Mr, Chapman:
Notice of Violation and Assessment of Civil Penalty for Violations of NC
General Statute 143-215.1(a)(6) and NPDES Permit No, NC0048712
ALCOA Extrusions, Inc. WWTP
Catawba County,
TX 02-019
This letter transmits a Notice of Violation and assessment of civil penalty against ALCOA
Extrusions, Inc. (ALCOA Extrusions) in the amount of $1,086.63 ($1,000 civil penalty + $86.63
enforcement costs).
This assessment is based upon the foliOwing facts, A review of the facility's toxicity self -
monitoring data from February through March 2002 has been conducted. The review has shown ALCOA
Extrusions to be in violation of the 90% 24-hour pass/fail acute toxicity effluent discharge limitation
found in -NPDES Permit No. NC0048712. ALCOA Extrusion's toxicity self -monitoring reports for
February through March 2002 revealed the following violations.
February 2002
March 2002
Fail
Fail
Based upon the above fact(s), 1 conclude as a matter of law that ALCOA Extrusions violated the
terms, conditions or requirements of NPDES Permit No. NC0048712 and NCGS 143-215.1(a)(6) in the
manner and extent showed above. A civil penalty in accordance with the maximum established by
NCGS 143-215,6A(a)(2) may be assessed against a person who violates the terms, conditions or
requirements of a permit required by NCGS 143-215.1(a).
Customer Service
600 623-7748
Division of VVater Quality 919 North Main Street Mooresville, N 28115 Phone [phone]
Fax [phone]

Based upon the above findings of fact and conclusions of law, and in accordance with authority provided
by the Secretary of the Department of Environment and Natural Resources and the Director of the
Division of Water Quality, I, D. Rex Gleason, Water Quality Regional Supervisor for the Mooresville
Region, hereby make the following civil penalty assessment against ALCOA Extrusions:
L2)
For / of the one (1) violation of NCGS 143-
215.1(a)(6) and NPDES Permit No, NC0048712, by
discharging waste into the waters of the State in violation of
the permit effluent limit for acute toxicity during the month
of February 2002.
For of the one (1) violation of NCGS 143-
21.5.1(a)(6) and NPDES Permit No. NC0048712, by
discharging waste .into the waters of the State in violation of
the permitted effluent limit for acute toxicity during the
month of March 2002.
5 L., ) ,
TOTAL CIVIL PENALTY
S 86.63 Enforcement costs.
TOTAL AMOUNT DUE
Pursuant to NCGS 143-215.6A(c in determining the amount of the penalty I have taken into
account the Findings of Fact and Conclusions of Law and the factors set forth at NCGS 14313-282.1(b),
which are:
(1) The degree and extent of harm to the natural resources of e State, to the public health. or to
private property resulting from the violations;
(2) The duration and gravity of the violations;
(3) The effect on ground or surface water quantity or quality or on air quali
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violations were committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs over which the
Environmental Management Commission has regulatory authority; and
(8) The cost to the State of the enforcement procedures,
ty;
Within thirty days receipt of this notice, you must do one of the following:
Submit payment of the penalty:
'Payment should be made directly to the Department of Environment and Natural Resources (do
not include waiver form). Payment of the penalty will not foreclose enforcement action for any
continuing or new violation(s). Please submit payment to the attention of:

Point Source Compliance/Enforcement Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1 6 17
OR.
2. Submit a written request for remission or mitigation including a detailed justification for
such request.
A request for remission or mitigation is limited to consideration of the reasonableness of the
amount of the penalty and is not the proper procedure for contesting the accuracy of any of the
statements contained in the assessment letter. Because a remission request .forecloses the option
of an administrative hearing, such a request must be accompanied by a waiver of your right to an
administrative hearing and a stipulation that there are no factual or legal issues in dispute. You
must execute and return to this office the attached waiver and stipulation form and a detailed
statement that you believe establishes whether:
(b)
(c)
(d)
(e)
one or more of the civil penalty assessment factors in NCGS 143B-282.1.(h) was
wrongfully applied to the detriment of the petitioner;
the violator promptly abated continuing environmental damage resulting from the
violations;
the violations were inadvertent or a result of an accident;
the violator had been assessed civil penalties for any previous violations;
payment of the civil penalty will prevent payment for the remaining necessary remedial
actions.
Please submit, this infonnat:on to the attention of:
1 Is, Coleen Sullins
Water Quality Section Chief
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Please note that all information presented in support of a request for remission must be submitted
in writing. The Director of the Division of Water Quality will review the information during a
bimonthly enforcement conference and inform you of his decision in the matter of the remission
request. His response will provide details regarding case status, directions for payment and
provision for further appeal of the penalty to the Environmental Management Commission's
Committee on Civil Penalty Remissions.. Please be advised that the_Committee cannot consider
information that was not part of the original remission request considered by the Director and,
therefore. it is very important that you prepare a. complete and thorough statement in support of
your request for remission.
OR
Submit a written request for an administrative hearing:

If you wish to contest any statement in this assessment letter, you must request an administrative
hearing. This request must be in the form of a written petition to the Office of Administrative
Hearings and must conform to Chapter 1.50B of the North Carolina General Statutes. You must:
File your original petition with the
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, North Carolina 27699-6714
and
Mail or hand -deliver a copy of the petition to
Mr. Dan Oakley, General Counsel
Department of Environment and Natural Resources
1601 Mail Service Center
Raleiah, North Carolina 27699-1601
Failure to exercise one of the options above within thirty days as evidenced by a date stamp (not
a postmark) indicating when we received your response, will result in this matter being referred to the
Attorney General's Office with a request to initiate a civil action to collect the penalty
Please be advised that any continuing violation(s) may be the subject of a new enforcement
action, including an additional penalty. If you have any questions about this civil penalty assessment,
please contact the Water Quality Section staff of the Mooresville Regional Office at (704) 663- 699:
c?(„10
Date
ATTACHMENTS
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
Mooresville Regional Office
Division of Water Quality
cc: Regional Supervisor w/attachments
Point Source Compliance/Enforcement Unit File w/attachments
Aquatic Toxicology Unit File w/attachments
Central Files wlattachments
JL

CIVIL PENALTY ASSESSMENT ADDENDUM
The Division ofWaLer Qualit:y (DWQ) issues/reissues NPDES 'permits with whole effluent toxicity
(WET) limits. The current chronic toxicity test condition language requires permittees to conduct multiple
concentration testing upon a single quarterly failure to meet the chronic toxicity permit limit. Permittees with
NPDES permits which contain "old" chronic toxicity pass/fail testing language will have the OPTION to respond
to any single quarterly toxicity test failure with follow-up multiple concentration toxicity testing (as contained in
the current language) or single concentrationtoxicity testing, thereby influencing the level of DWQ's enforcement
response*
NOTE: Choosing to respond to a chronic toxicity "fail" result with a pass/fail test instead of conducting multiple
concentration toxicity testing during the second and third months of the monitoring quarter (monitoring quarter
defined by your permit) will result in enforcement for single concentration test results that do not meet chronic
toxicity permit limitations,
Important WET Enforcement Policy items are:
I* CHRONIC TOXICITY TESTING
• The first test of the quarter can be conducted as either a pass/fall test or a chronic
value (ChV) test.
• If the pass/fail test fails or if the ChV is lower than the limit* then a Notice of
Violation (NOV) is issued and at least two ChV tests (one per month) will be
conducted over the following two months. As many analyses as can be completed
will be accepted.
• A NOV will be issued for ANY test result failing to meet the permit limit.
• Any civil penaltiesassessed will be based on performance over a quarter. Facilities
may be assessed civil penalties for any month in which compliance with the WET
limit is not achieved. DWQ's enforcement response can be influenced by conducting
multiple concentration testing for the second and third months of the monitoring
quarter. Chronic valu.es for all follow-up tests willbe averaged arithmetically* If the
average is the chronic permit limit, then civil penalties will not be assessed for
monthly violations occurring during the quarter. If the average chronic value is < the
permitlimit, the facility will be assessed civil. penalties for each -month during the
quarter in which compliance with. WET was not achieved.
•NPDES Permits containing chronic toxicity pass/fail testing will be modified upon
permit. renewal to include the new permit language.
ACUTE TOXICITY TESTING
• A NOV will be issued for each acute limit violation.
A civil penalty will be assessed for any two consecutive acute limit violations.
If you are unable to consistently comply with your toxicity permit limitation, you may notify your
respective Regional Office to discuss the possibility of entering into a Special Order by Consent (SOC). The SOC
provides conditional compliance for permit parameters with which the facility can not consistently comply and
may be issued in situations where facility operation and maintenance are not in question. If a SOC is signed by the
perrnittee/DWQ and contains toxicity as a noncompliant parameter, you will be required to: conduct a Toxicity
Reduction Evaluation (TRE), submit quarterly TRE progress reports and eliminate/reduce effluent toxicants so
that compliance with the whole effluent toxicity limit can be demonstrated.

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
COUNTY OF CA.TAWBA
IN THE MATTER OF ASSESSMENT
OF CIVIL PENALTY AGAINST
ALCOA EXTRUSIONS, INC. WWTP
PERMIT NO. NC0048712
WAIVER OF RIGHT TO AN
ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
FILE NO, TX 02-019
Having been assessed civil penalties totaling for
violation(s) as set forth in the assessment document of the Division of Water Quality dated
, the undersigned, desiring to seek remission of the civil penalties, 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 Quality within 30 days of receipt of thc 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 20
ADDRESS
TELEPHONE

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rt y R#'tp(F#RGa##3N#
Difedin
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PERM = Fe unit R q rnxnt #vE1" alrrsioai� dmtii L ttrr #Eder Te a#ur
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Uarmce Re+laaidment

Fast Track Worksheet
Case Number
Facility Name
Permit Number
Previous Case
in the Last
two years
TX
NC©048712
Statutory Maximun
per violation
Number of Assessments for previous 6 DMRs
0 20 03 0 40 0 6
.
00
$25,000
Total Assessment Factor
1.00
Exit
Total
Number Number Penalty/ Assessment
Violations Assessed Parameter Violation Violation Factor Total Penalty
acute tox 2/02
acute
Comments
x 3/02
Exceed whole
effluent toxicity
Exceed whole
effluent toxicity
$500
$500
Grand Total Penalty
Percent of the Maximum Penalty
Authorized by G.S. 143-215.6A.
$500.00
$500.00
$1000.00
2.00

Case N
LR
90
LV
96
TX
00
02
TX
02
ber
150
026
020
Alcoa Extrusions, Inc.
Alcoa Extrusions, Inc.
NC0048712
NC0048712
NC0048712
NC0048712
NC0048712
NC0048712
County
CATAWBA
CATAWBA
CATAWBA
CATAWBA I
Catawba
Catawba
xedw Ca
03/21 /90
[ 05/26/00
04/04/02
• Database pull only. Complete information may be found through file search, Cases with datemassessed greater
than 7/1/98 may be regional assessments, Some cases are still open for final agency decision. Cases labeled "LV"
or "LW are violations of permitted effluent limits and/or monitoring requirements, No violations <20% over the threshold
were assessed a civil penalty, Description of case types can be found on the next page.
$150.00
00.00
$2,097.77'
Date Run: May 23, 2002
Alt oust Paid
10 date
$150.00
$500.00
$1,256,06
086.63
$5,090.46
C
04/28/93
02127/'97
05/06/02
SubhasII1' •
30832
$5,090.46

Environmental Testing Solutions, LLC
PO Box 790
Pisgah Forest„ NC 28.768
Effluent Tox
Report Form - Acute Pass/Fail
Phone: [phone]
Fax: [phone]
E-mail: 3imSumner@c ,aol.com
Date: April 1, 2002
Facility: Alcoa En
red Products NPDES #: NC 0048712 Pipe*: 001 County: Catawba
Laboratory Performing Test: Environmental Testi
Signature of Operator in Responsible Charge:
Signature of Laboratory Supervisor.
Solutions, LLC
Con nlents:
Project: 296
20321.06
Mail ©rig%raaI To: North Carolina Department of Environment and Natural l escsu
DWQ/ Environmental Sciences Branch
1621 Mail Service Center
Raleigh, NC 27699-1621
North Carolina Acute Pass/Fail Toxicity Test
Collection. Date: 03-19-02
Collection Time:: 0934
Test Start Date: 113-21-02
S am p l e, T'ype:'D urati on
Grab
Comp,
Du
24.5-hour
Hardness (mg/
Conductivity (itmhos/cm
Total Residual Chlorine (mg.il
Sample 'Temp. at Receipt CC
37
Treatment 1 (Control)
Organitrt Tested
Pimephales promelas
pH (SIT.)
D.O. (mg./l)
Control
Treatment
Co+nts-o
Treatment
85
-7.76
7.69
8.1
8.0
7.71
Replicate
A B C
Treatment 2 (Exposure) A
Concentration
Tested
901/0
70%
40% 1 90%
90°,m
Note: If mean control mortality exceeds 10%, the test is considered invalid.
Mean Mortal
to using Arc -Sine
Root transformed.
data.
Calculated Student's t
Tabular Student's t
(ONE TAILED)
6.595
4,54 1
PASS
FAIL
If the absolute value of the calculated t is less than or equal to the absolute value of the tabular t. check PASS,
If the absolute value of the calculated t is grater than the absolute value of the tabula: t, check' FAIL.
If all vessels within each treatment have the same response hut the treacnent two itsponse is greater than the conu-61, check fail.
4
DIVTT form AT-2 (8/91)

Environmental Testing Solutions, LLC
0 Box 790
Pisgah Forest, NC 28768
Effluent Toxicity Report Form - Acute Pass!Fail
Phone: [phone]
Fax: [phone]
E-mail: JimS•umnertaol.corn
Date: February 2.2, 2002
Facility: ALCOA Engineered Products NPDES : NC 0
Laboratory Performing Test: Environmental Testirig Solutio
Signature of Operator in Responsible Charge:
Signature of Laboratory Supervisor,
Pipe #: 001 County: Catawba
• Comments:
Project: 252
Sample: 020207.05
Mail Original To: North Carolina Department. of Enviroturnent and Natural Resources
DWQ' Environmental Sciences Branch
1621 Mail Service Center
R.aleigh, NC 27699-1621
North Carolina Acute PassiF.ail Toxicity Test
Collection Date: 0.2,05-02
Collection Time: 0900
Test. Start Date: 02-07-02
SamplerTy-peiDuration
Grab Comp,
Duration
x
24-hour
Hardness (nig/1)
Conduerkity (mhos/cm)
Total Residual Chlorine (mall)
Sample Temp. at Receipt (C)
ririntigiiitZtZ
trtittairePtctitetv
n
R
AR 0 2 2002
ntai Scin
Organism Tested
Pimephales promelas
pH (S.U,)
Control
Treatment
Control
D.O. (mg/1)
Treannent
7.74
7,72
• 7.67
• 7.(4.
8,0 j 7.7
8.2
7,9
Mortality
Treatment 1 (Control)
Treatment 2 (Exposure)
Concentration
Tested
Note: If mean contro
90%
ortaliry exceeds 10%, th
A
A
c
Replicate
B C
0%
80%
100%
nsidered
0%
40%
Mean Mortality
70%
Calculate using, Arc -Sine
Square Root transformed
data.
Calculated Student's t
Tabular Student's t
(ONE TAILED)
41"
4.541
PASS
FALL
If the absolute value of the calculated ti or equal to the absolute value ©f the tabular chccIr ?ASS,
If thc absolute value of the calculated t is greater than the absolute value of the tabular t, cheek FAIL.
If all vessels within each treatment have the same response but the crearrnent two resbonse is rat-3r1IT than the commit, check fail.
X
crm AT-2

Michael E. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan. W. Klimek, P.E. Director
Division of Water Quality
9/16/2002
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
George R Chapman
Alcoa Extrusions inc
PO Box 100
Catawba NC 28609
SUBJECT: NOTICE OF VIOLATION AND REVOCATION FOR NON PAYMENT
PERMIT NUMBER NC0048712
Alcoa Extrusions Inc -Catawba
Catawba COUNTY
Dear Permittee:
Payment of the required annual administering and compliance monitoring fee of $715.00 for this year has not
been received for the subject permit. This fee is required by Title 15 North Carolina Administrative Code 2H.0105, under
the authority of North Carolina General Statutes 143-215.3(a)(1), (1a) and (1b). Because this fee was not fully paid within
30 days after being billed, this letter initiates action to revoke the subject permit, pursuant to 15 ncac 2H.0195(b) (2) (k)
(4), and G.S. 143-215,1 (b) (3).
Effective 60 days from receipt of this notice, subject permit is hereby revoked unless the required Annual
Administering and Compliance Monitoring Fee is received within that time. Discharges without a permit are subject to the
enforcement authority of the Division of Water Quality. Your payment should be sent to:
N.C, Department of Environment and Natural Resources
Division of Water Quality
Budget Office
1617 Mail Service Center
Raleigh, NC 27699-1617
If you are dissatisfied with this decision, you have the right to request an administrative hearing within Thirty (30)
days following recipt of this notice, identifying the specific issues to be contended. This request must be in the form of a
written petition conforming to Chapter 150B of the North Carolina General Statutes, and filed with the Office of Administrative
Hearings, Post Office Drawer 27447, Raleigh, North Carolina, 27611-7447. Unless such request for hearing is made or
payments received, revocation shall be final and binding. If you have any questions, please contact:
Mr. Rex Gleason, Mooresville Water Quality Regional Supervisor, [phone].
Sincerely,
Alan W, Klimek, P.E.
cc: Supevisor, Water Quality Pe and Engineering Unit
Mooresville Regional Office
County Health Department
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled / 10n/0 post -consumer paper

4
Stati of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
Wiliam G. Ross Jr., Secretary
Gregory J. Thorpe, PhD., Acting Director
May 6, 2 2
MR. GEORGE CHAPMAN
'PO BOX 100
CATAWBA NC 28609
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
SUBJECT: PAYMENT ACKNOWLEDGEMENT
CIVIL PENALTY ASSESSMENT
ALCOA EXTRUSIONS
CATAWBA COUNTY
PERMIT NO: NC0048712
TX 02-010
Dear Mr. Chapman:
This letter is to acknowledge receipt of check No. 02083242, in the amount of $1,086.63 received from
you dated April 30, 2002. This payment satisfies in full the civil assessment levied against
the subject facility and this case has been closed, Payment of this penalty in no way precludes future
action by this Division for additional violations of the applicable Statutes, Regulations or Permits.
If you have any questions, please callBob Sledge at [phone].
Sincerely, MAY 2 4 2002
Coleen Sullins, Chief
Water Quality Section
Cc: Enforcement File #: TX 02-010
MRORegion4
Central Files
1617 Mail Service Center, Raleigh, NC 27699-1617 Telephone [phone] Fax [phone]
An Equal Opportunity Affirmative Action Employer 50 t7c recycled/10% post -consumer paper

(:‘ .2".),f3; 1;1Ck-15
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. George Chapman
ALCOA Extrusions, Inc.
Post Office Box 100
Catawba, North Carolina 28609
SUBJECT:
Dear Mr, Chapman:
Michael F. Easley
Governor
William G. Ross, Jr., Secretary
Department of Environment and Natural Resources
Gregory J. Thorpe, Ph,D., Acting Director
Division of Water Quality
April 4, 2002
Notice of 'Violation, and Assessment of Civil Penalty. for Violations of NC
General Statute 143-215...1(a)(6) and NPDES Permit No. NC0048712
ALCO,A. Extrusions, Inc.
Catawba County
TX 02-010
This letter transmits a Notice of Violation and assessment of civil penalty against ALCOA
Extursions, Inc. (the Company) in the amount of $1,086,63 (S1,000 civil penalty 586.63 enforcement
costs).
This assessment is based upon the following facts. A review of the facility's toxicity self -
monitoring data for December 2001 has been conducted. The review has shown the, Company to be in
violation of the 90% 24-hour pass/fail acute toxicity effluent discharge limitation found in NPDES
Permit No, NC0048712. The Company's toxicity self -monitoring reports for December 2001 revealed the
following violations,
December 2001
December 2001
Fail
Fail
Based upon the above fact(s), I. conclude as a matter of law that the Company violated the terms,
conditions or requirements of NPDES Permit No. NC0048712 and NCGS 143-215,1(a)(6) in the manner
and extent shown above. A civil penalty in accordance with the maximum established by NCGS 143-
215,6A(a)(2), may be assessed against a person who violates the terms, conditions or requirements of a
permit required by NCGS 143-215.1(a).
Custo
1 800 623-
Division of Water Quality 919 North Main Street Mooresville, NC 28115 Phone [phone]
Fax [phone]

Based upon the above findings of fact and conclusions °flaw, and in accordance with authority
provided by the Secretary of the Department of Environment and Natural Resources and the Director of
the Division of Water Quality, I, D. Rex Gleason, Water Quality Regional Supervisor for the Mooresville
Region, hereby make the following civil penalty assessment against ALCOA Extrusions, Inc.:
.0 C.)
For of the two (2) violations of NCGS
(a)(6) and NPDES Permit No, NC0.048712„ by
discharging waste into the waters of the State in violation of
the permit effluent limit for acute toxicity during the month.
of December 2001..
0 ---
TOTAL CIVIL PENALTY
86 63 Enforcement costs.
S TOTAL AMOUNT DUE
Pursuant to NCGS 143-215.6A(O in determining the amount of the penalty I have taken into
.account the Findings of Fact and Conclusions of Law and the factors set forth at NCGS 143B-282,1(b),
which are:
(1) The degree and extent of harm to the natural resources of th.e State, to the public health, er to
private property resulting from the violations;
(2) The duration and gravity of the violations;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of -rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violations were committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs over which the
Environmental Management Commission has regulatory authority; and
(8) The cost to the State of the enforcement procedures.
Within thirty days receipt of this notice, you must do one of the -following:
Submit payment of the penalty:
Payment should be made directly to the Department of Environment and Natural Resources (do
not includewaiver form), Payment of the penalty. will not foreclose enforcement action for any
continuing or new violation(s). Please submit payment to the attention of:
Point Source CompliancelEnforcement 'Unit
Division of Water Quality
161.7 Mail Service Center
Raleigh, North Carolina 27699-1617
OR

Submit a writtenyequest for remission or mitigation including a detailed justification for
such request.
A request for remission or mitigation is limited to consideration of the reasonableness of the
amount of the penalty and is not the proper procedure for contesting the accuracy of any of the
statements contained in the assessment letter, Because a remission request forecloses the option
of an administrative hearing, such a request must be accompanied by a waiver of your right to an
administrative hearing and a stipulation that there are no factual or legal issues in dispute. You
must execute and return to this office the attached waiver and stipulation form and a detailed
statement that you believe establishes whether:
(a) one or more of the civil penalty assessment factors in NCGS 143B-282.1(b) was
wrongfully applied to the detriment of the petitioner;
(b) the violator promptly abated continuing environmental damage resulting from the
violations;
(c) the violations were inadvertent or a result of an accident;
(d) the violator had been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary remedial
actions.
Please submit this information to the attention of:
Ms. .Coleen Sullins
Water Quality Section Chief
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Please note that all inforrnation presented in support of a request for remission must be submitted
in writing. The Director of the Division of Water Quality will review the information during a
bimonthly enforcement conference and inform you of his decision in the matter of the remission
request. His response will provide details regarding case status, directions for payment and
provision for further appeal of the penalty to the Environmental Management Commission's
Committee on Civil Penalty Remissions. Please be advised that the Committee cannot consider
information that was not art of original remission request considered by the Director and,
therefore. it is very important that you prepare a complete and thorough statement in support of
Your request: for remission.,
3 Submit a written request for an administrative hearing:
If you wish to contest any statement in this assessment letter, you must request an administrative
hearing. This request must be in the form of a written petition to the Office of Administrative
Hearings and must conform to Chapter 1.50B of the North Carolina General Statutes, You must:

File your on i a petition ith the
Office of Administrative H arirtgs
6714 Mail Service Center
Raleigh, North Carolina 2'7699-6'714
and
Mail or hand -deli er a copy of the petition to
Mr. Dan Oakley, General Counsel
Department of Environment and Natural Resources
1601 Mail Service Center
Raleigh, North Carolina. 27699-1601
FailFailur o exercise one of the options above within thlrtV days a evidenced by a date stamp (not
a post ark) indicating when We received your response, will result in thin;matter being referred to the
Attorney General's Office with a request to initiate a civil action to collect the penalty
Please be advised that any continuing violation(s) may he the subject of new enforce en
acion, including an additional penalty. If you have any questions about this civil penalty assess enu.
e contact the Water Quality Section staff of the Moores °i lle Regional Office. at (704) lib 3-1 9 ,
Date
ATTACHMENTS
son, P.1 ;.
r Quality Regional Supervisor
orvest=ille Regional Office
Division of Water Quality
Regional Supervisor wfattachments
Point Source Compliance/Enforcement Unit File tv'attach arts
Aquatic Toxicology Unit pile w:'attach.. ents
Central Files tr,la chnwnt

CIVIL PENALTY ASSESSMENT ADDENDUM
The Division of Water Quality (DWQ) issues/reissues NPDES permits with whole effluent toxicity
(WET) limits. The current chronic toxicity test condition language requires permittees to conduct multiple
concentration testing upon a single quarterly failure to meet the chronic toxicity perrnit limit. Permittees with
NPDES permits which contain "old" chronic toxicity pass/fail testing language will have the OPTION to respond
to any single quarterly toxicity test failure with follow-up multiple concentration toxicity testing (as contained in
the current language) or single concentration toxicity testing, thereby influencing the level of DWQ's enforcement
response.
NOTE: Choosing to respond to a chronic toxicity —fail" result with a pass/fail test instead of conducting multiple
concentration toxicity testing during the second and third months of the monitoring quarter (monitoring quarter
defined. by your permit) will result in enforcement for single concentration test results that do not meet chronic
toxicity perrnit limitations.
Important WET Enforcement Policy items are:
I. CHRONIC TOXICITY TESTING
The first test of the quarter can be conducted as either a .pass/fail test or a chronic
value (ChV) test.
If the pass/fail test fails or if the ChV is lower than the limit. then a Notice of
Violation (NOV) is issued and at least two ChV tests (one per month) will be
conducted over the following two months. As many analyses as can he complet.ed.
will be accepted.
A NOV will he issued for ANY test result failing to meet the permit limit.
Any civil penalties assessed will be based on performance over a quarter. Facilities
may be assessed civil penalties for any month in which compliance with the WET
limit is not achieved...DWQ' s enforcement response can be influenced by conducting
multiple concentration testing for the second and third months of the monitoring
quarter. Chronic values for all follow-up tests will be averaged arithmetically. If the
average is the chronic permit limit, then civil penalties will not be assessed for
monthly violations occurring during the quarter. If the average chronic value is < the
permit limit, the facility will be assessed civil penalties for each month during the
quarter in which compliance, with WET was not achieved.
NPDES Permits containing chronic toxicity pass/fail testing will be modified upon
perrnit renewal to include the new perrnit language.
ACUTE TOXICITY TESTING
• A NOV will be issued for each acute limit violation,
• A civil penalty will be assessed for any two consecutive acute
If you are unable to consistently comply with your toxicity permit limitation, you may notify your
respective Regional Office to discuss the possibility of entering into a Special Order by Consent (SOC). The SOC
provides conditional compliance for permit parameters with which the facility can not consistently comply and
may he issued in situations where facility operation and maintenance are not in question. If a SOC is signed by the
pennittee/DWQ and contains toxicity as a noncompliant parameter, you will be required to: conduct a Toxicity
Reduction Evaluation (TRE), submit quarterly TRE progress reports and eliminate/reduce effluent toxicants so
that compliance with the whole effluent toxicity limit can be demonstrated.

STATE OF NORTH CAROLINA
COUNTY OF CATA A
IN THE MATTER OF ASSESSMENT
OF CIVIL PENALTY ST
ALCOA EX E RL SI l S,
PERMIT N, NC0048712
DEP T NT OF ENVIRONMENT
RESOURCES
ER OF RIGHT TO AN
1IllISTRATIVE HE IG
STIPULATION OF FACTS
FILE NO, TX 0 -0I
Havmg been assessed civil penalties totaling for
al ionIsl as set forth in the assessment daaurnent ofthe Division of#ater Quality dated
the undersigned, desiring to seek remission of the civil penalties, does
right to an administrative hearin,g in the above -stated matter and does stipulate
that the bets are as alleged in the assessment document. The undersigned further understands that
all evidence presented in support ofremission of this civil penalty must be submitted to the
Director ofthe Division ofWater Quality within 30 days ofreceipt ofthe notice of assessment, No
new evidence in support of a remission request will be allowed after 30 days from the receipt ofthe
notice of assessment.
This tI
day of
ADDRESS
B
'TELEPHONE

Environmental Testing Solutions, LLC
P© Box 790
Pisgah Forest, NC 28768
Effluent Toxicity ReportForm - Acute Pass/Fail
8f2-8193
Fax: [phone]
ail': J[rnStunner(aaol.com
Date:
Dec
ber 21, 2001
Facility: A.1.,COA Engineered Products NPDES 4: NC 0048712 Pipe #: 001 County; Catawba
Laboratory Perfonrtirfg Test: Environmental Testing Solutions,
Signature of Operator in Responsible Charge:
Signature of Laboratory Supervisor
Comments: .
Project. 209
0 t t207,0
Mail Original To:
North Carolina Department of Environment and Natural Resources
DWQ/ Environmental Sciences Branch
1621 Mail Service Center
Raleigh, NC 27699-1621
North Caro :iiata acute Pass/Fail Toxicity Test
Collection Date: 12-05-01.
Collection Time: 0900
Test Start Date:
7-01
Hardness (mei)
Conductivity (prithos/cm)
Total Residual. Chlorine (mg/1)
Sample Temp. at Receipt (°C)
FEB 0 2
SCI`
Organism Tested
Pimephales promelas
pH (S,U.)
D.O. (mg,
Control.
Treatment
Control
Treatment
7.70
8,0
8.©
7,67
7.67
7.9
Treatment 1 (Control)
Treatment 2 (Exposure)
Concentration
Tested
Note: if mean control mortality exceeds 10%, the test is considered invalid.
Reviicate
A B C
A
90%
1©0°/a
70%
90°A
0
Calculate using Arc -Sine
Square Root transformed
data.
Calculated Student's t
Tabular Student's t
(ONE TAILED)
4..541
PASS
FAIL
lithe absolute value of the calculated I. is less than or equal to the absolute value r f the tabular t, check PASS.
If the absolute value orate calculated s is greater than the ab,oiute value of the tabular t, check FAIL.
If all vrssels within each treatment have the same response but the treatment two response is greater than the control, check fail.

7
Environmental Testing Solutions, LLC
PO Box 790
Pisgah Forest, NC 28768
Effluent Toxicity Report Form - Acute Pass/Fail
Phone: [phone]
Fax: [phone]
E-mail: [e-mail]
Date: December 21, 2001
Facility: ALCOA Engineered Products NPDES #: NC 0048712 Pipe #: 001 County: Catawba
Laboratory Performing Test: Environmental TestingSolutions, LLC
Signature of Operator in Responsible Charge:
Signature of Laboratory Supervisor.
Comments:
RS=10.0, 'Tailed Critical=90
Project 219
Sample: 011213,03
Mail Original To:
North Carolina Department of Environment and Natural Resources
DWQ/ Environmental Sciences Branch
1621 Mail Service Center
Raleigh, NC 27699-1621
North Carolina Acute Pass/Fail Toxicity Test.
Collection Date: 12-11-01
Collection 'Time: 0900
Test Start Date: 12-13-01
Hardness (mg/1)
Conductivity (qmhos/crn)
Total Residual Chlorine (mg/1)
Sample Temp. at Receipt (°C)
Organism Tested
Fimephales promelas
pH (S.U.)
D.O. (mg(1)
Control
Treatment
Control
Treatment
7.73
7.55
7.70'
7.67
7 9
8.0
•-q
LT21
7A
73
Mortali
Treatment 1 (Control)
Treatment 2 (Exposure)
Concentration
Tested
Note: If mean control mortality exceeds 10%, the test is considered invalid,
Replicate
A B C
0%
0%
0%
90%
A
80%
100%
100%
100%
Mean Mortality
95%
CalculateCalcuFate using Arc -Sine
Square Root transformed
data,
Calculated Student's t
Tabular Student's t
(ONE TAILED)
NA
NA
PASS
FAIL
If the absolute value of Me calculated t is less thaii or equal to the absolute value of the tabular L. cheek PASS,
If the absolute value of the calculated I is greater than the absolute value of the tabular t, check FAIL.
If all vessels within each treatment have the same response but the treatment two response is greater than the control, check fail,

Fast Track Worksheet
Case Number
Facility Name
Permit Number
Previous Case
in the Last
two years
TX
02
010
coa Extrusions inc-Catawba
NC0048712
Yes
Statutory Maximun
per violation
Number of Assessments for previous 6 DMRs
02 0 0 4 0 5© 6
.00
$25,000
Total Assessment Factor =
1.00
Exit
Number Number
Violations Assessed
2
Comments
Parameter
acute tox - 12/01
acute tox.-12/01
Viola
Total
Penalty/ Assessment
on Violation Factor Total Penalty
$500
$500
Grand Total Penalty
Percent of the Maximum Penalty
Authorized by Q.S. 143-215.6A.
$500.00
$5
$.
00
00.00
2.00

Case Number
L,Ft 9Q —
LR
LV
TX
TX
150
Violator
Alcoa Extrusions, Inc.
Alcoa Extrusions, Inc.
Alcoa Extrusions Inc-catawba
Permit # County
NC0048712
NCQQ48712
NCQQ48712
NC0048712
NC0048712
CATAWBA
CATAWBA
CATAWBA
CATAWBA
Catawba
Date Total.
Assessed Case Penalty
Q3/21 /90
03/30/93
Q 1 /22/97
Q5/26/QQ 1
Database pull only. Complete information may be found through file search. Cases with date assessed greater
than 7/1/98 may be regional assessments_ Some cases are still open for final agency decision. Cases labeled "LV*
or "LM°" are violations of permitted effluent limits and/or monitoring requirements. No violations *z20% over the thresho9d
were assessed a civil penalty. Description of case types can be found on the next page.
$500.00
$1,256.06
$2,097.77
Date Run: March 25, 2002
Amount Paid
to date Case Closed 5ubbasiR
$150.00
$500.00
$1,256.06
$2,097,77
$4,003.83
04/Q5/90
04/28/93
02/27/97
06/23/00
$4,003.83
3Q832

l Etflui
PActFS
4L
rY
it „OA Etirfats
c004871kl 11
tkGisty Catawba.
PERM a P
®tvca = i`rrsc anal
rr t�ra,t,ital a
Data !Vaataatiaate t - P
RepontatNtraaare+tt'r'
y Testing Selfenit rin Summer
REQUIREMFN"k'
iy
Region
bit
P1na 41
aty. Q P/F
i Bola astt'
Ntaue Atm),
LET = Adt tiniaetataa,•s t cxtur- Tuuut. Pc tinuncy « Mon
?DIP-R i+ingsiw'usuaa..inawahwtrt;ntit ,rrtc1's> +aquar"teri
WC's: mm [natatiunt r�vastit G^W,na:unra stietst . PI(= Pala att ki.
eaW; * - �'a`ntineYs..i+Rvssi a 133 any • Ltvsit[ slamaip; ctal' ciu"Faxaic vuiur.; P
next;: 1ii - Pai Fi'toI Activity Status: T - Ina ae:,
YEAR AN
Fail
g frequency Q Q
�,ta ttrruag. ttu`teases ur
AC at Acute..
aced percentage et P`
y isau riat caenatntutS 14 , Attu
MAR APR
Pass
Pace
Ps64
PASS
taihip, BMe. or
8a
1Cbi) failurtt
fIIR=CI
tai krustton teat
MAY. JU.N
Pass
Pees
Fee
Fens
t�kL
U
Pass
Pa
March 25, 2;
NOV DEi
r't- sstaslzrul9 'I - 0 h who alasckrcar ,su ., 4-1:1i ,.artatinueci trxxnaCcnvap; P
ttx;cur pr,Iut,''rct Ia3casC."r,satpaCurrent tcuksptiau:. 10
'Q A*p uic "i sx i u'rt, k a » I3 tcsi
y;
y SA- San tenuuully;
AScnatha that teati
il k}R.P: eiRtaatutra«tci�:

State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
919 North Main Street Mooresville, North Carolina 28115
CERTIFIED MAIL f
RETURN RECEIPT REQUESTED
Mr. George R. Chapman
ALCOA Extrusions, inc.
PO Box 100
Catawba, North Carolina 28609
SUBJECT:
Dear Mr. Chapman:
July 19, 2002
NOTICE OF VIOLATION
Whole Effluent Toxicity (WET) Testing
NPDES Permit No. NC0048712/001
ALCOA Extrusions, Inc. WWTP
Catawba County
This is to inform. you that a review of your toxicity self -monitoring report form for the month of
May 2002 indicates a violation of the toxicity limitation specified in your NPDES Permit.
You should take whatever remedial actions are necessary to eliminate the conditions causing the
effluent toxicity violation(s). Your efforts may include conducting a Toxicity Reduction Evaluation
(T. RE) which is a site -specific study designed to identify the causative agents of effluent toxicity, isolate
the sources of toxicity, evaluate the effectiveness of toxicity control options, and then confirm reductions
in effluent toxicity. Please be aware that North Carolina General Statutes provide for assessment of civil
penalties for violations of NPDES permit limitations and requirements.
The reverse side of this Notice contains important information concerning your Whole Effluent
Toxicity Monitoring and. Reporting Requirements. Please note updated mailing addressesforsubmitting
your Discharge Monitoring Reports (DMRs) and Aquatic Toxicity (AT) Test Forms. We encourage. you
to review this information and if it would be helpful to discuss this situation or possible solutions to
resolve effluent toxicity noncompliance, please contact Mr. John Lesley with this office at (704) 663-
1.699.
Since
D. Rex Gleason, P.E.
Regional Water Quality Supervisor
cc: Aquatic Toxicology Unit
Central Files

WHOLE EFFLUENT TOXICITY MONITORING AND REPORTING INFORMATION
The following items are provided in an effort to assist you with identifying critical and sometimes overlooked
toxicitytesting and reporting information. Please take time to review this information. The itrins. below donot
address or include all the testing and reporting requirements cQntainedJp ur P Spgrjjjt„, It
you should have any questions about your toxicity testing requirement, please contact Mr, Kevin Bowden with
the Aquatic Toxicology Unit at (91.9) 733-2136 or another Unit representative at the same number.
The permittee is responsible for ensuring that toxicity testing is conducted according to the permit requirement
and that toxicity report forms are appropriately filed,
The reporting of whole effluent toxicity testing data is a dual requirement. All Loxtest results must be
entered (with the appropriate parameter code) an your monthly Discharge Monitoring Report which is
submitted to:
North Carolina Division of Water Qua
Central Files
1617 Mail Service Center
Raleigh, NC 27699-1617
IN ADDITION
Toxicity test data (original "AT" form) must be submitted to the ,following address:
North Carolina. Division of Water Quality
Environmental Sciences Branch
16.21 Mail Service Center
Raleigh, North Carolina 27699-1.621
Toxicity test results shall be filed with the Environmental Sciences Branch no later than 30 days after the end
of_the reporting_period (eg, January test result is due by the end of February).
Toxicity test condition language contained in your NPDES permit may require use of multiple concentration
toxicity testing upon failure of any single quarterly toxicity test. If the initial pass/fail test fails or if the chronic
value is lower than the permit limit, then at least two multiple concentration toxicity tests (one per .month) will
be conducted over the following two months, As many analyses as can be completed will be accepted. If your
NPDES 'permit does not require use of multiple concentration toxicity testing upon failure of any single
quarterly test, you may choose to conduct either single concentration toxicity testi.ng or multiple concentration
toxicity testing per the Division's. WET enforcement initiatives effective ILO 1, 1999. Follow-up multiple
concentration toxicity testing will influence the Division's enforcement response
Toxicity .testing months are specified by the NPDES Permit, except for NPDES Permits which contain episodic
toxicity monitoring requirements (eg, if the testing months specified in your NPDES permit are March, June,
September, and December, then toxicity testing must be conducted during these months).
If your NPDES Permit specifies episodic monitoring and your facility does not have a discharge from January 1-
ne 30, then You must provide written notification to the Environmental Sciences Branch by June 30 that a
discharge did not occur during the first six months of the calendar year.
If you receive notification from your contract laboratory that a test was invalidated, vou should immediately
notify the Environmental Sciences Branch at [phone] and provide written documentation indicating why
the test was invalidated and the date when follow-up testing will occur.
If your facility is required to conduct toxicity testing during a month in which no discharge occurs, you should
complete the information block located at the top of the AT form indicating the facility name, permit number,
pipe number, county and the month„(year of the subject report, You should also write "No Flow" on the AT
form., sign the form and submit following normal procedures,
The Aquatic Toxicity Test forms shall be signed by the facility's Operator in Responsible Charge (ORC) except
for facilities which have not received a facility classification. In these cases, a duly authorized facility
representative must sign the AT form, The AT form must also be signed by the performing lab supervisor.
To determine if your AT test forms were received on time by the Division of Water Quality, you may consider
stibmittin., your t x' v test . es s certified mail, return receipt requested to the Environmental Sciences
Branch,

A
iehael E, Easley
Governor
William G. Ross, Jr., Secretary
Department of Environment and Natural Resources
Alan W. Klimek, P.E.„ Director
Division of Water Quality
November 26, 2002
CERTIFIEQ MAIL
RETURN RECEIPT REQUESTED
Mr, George R. Chapman
ALCOAExtrusions Incorporated
PO Box 100
Catawba, North Carolina 28609
SUBJECT. Effluent Toxicity Testing
NPDES Permit. No, NC0048712
ALCOA Extrusions Incorporated WWTP
Catawba County
E 0 3 2002
Dear Mr, Chapman .
This is to inform you that the Division has not received your quarterly toxicity self monitoring report
form. for the month of September 2002. Your September 2002isgeonaoring Report (R)) indicated
"NO OW"; however, our office did not receive a toxicity self-monitoringreprt labeled"NO LOW
Please be reminded that the reporting of toxicity testing data is a dual requirement and that Aquatic
Toxicity (AT) Report Forms and DMRS are due no later than thirty (30) days after the end of the reporting
period for which the report is made. AT report forms shall be submitted to the following address:
North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621.
Attached is a copy of the new toxicity condition test language contained in your NPDES Permit,
Please note the requirement to report to our office in the event there is no discharge from the facility during a
month in which toxicity testing is required.
The reverse side of this Notice contains a summary of important toxicity monitoring and reporting
requirements. Please read this one page summary page and if you have any questions concerning this Notice
or any aspect of your toxicity testing requirement, please contact Mr. Kevin Bowden with the Aquatic
Toxicology Unit at [phone],
cc: Rex Gleason -Mooresville Regional Office
John Lesley -Mooresville Regional Office
Aquatic Toxicology Unit Files
Central File
Sincer
Overton
Assistant Water Quality Section. Chief
for Environmental Sciences
Customer S ice Environmental Sciences Branch
1621 Mail Service Center
Raleigh, NC 27699-1621 [phone]

WHOLE EFFLUENT TOXICITY MONITORING AND REPORTING INFORMATION
The following items are provided in an effort to assist you with identifying critical and sometimes overlooked toxicity
testing and reporting information, Please take time to 'review this inform.ation. The items below do not address or include
all the toxicitv testing and reporting requirements contained in.vour_NPDES ermit. If you should have any questions
about your toxicity testing requirement, please contact Mr. Kevin Bowden with the Aquatic Toxicology Unit at (91.9) '733-
2136 or another Unit representative at the same number..
> The permittee is responsible for ensuring that toxicity testing is conducted according to the .permit requirement and that
toxicity report forms are appropriately filed,
The reporting of whole effluent toxicity testing data is a dual requirement. All toxicity test results must be entered (with the
appropriate parameter code) on your monthly Discharge Monitoring Report which is submitted to:
North Carolina Division of Water Quality
Central Files
1.617 Mail Service Center
Raleigh, NC 27699-1,617
IN ADDITION
Toxicity test data (original "AT" form) must. he submitted to .the following address:
North Carolina Division of Water Quality
^ Environmental. Sciences Branch
1621, Mail Service Center
Raleigh, North Carolina 27699-1621
Toxicity test results shall be Bled with the Environmental Sciences Branch no later than 30 days after the end of the
reporting period (eg, January test result is due by the end of February).
Toxicity test condition language contained in your NPDES permit may require use of multipleconcentration toxicity testing
upon failure of any single quarterly toxicity test. If the initial pass/fail test fails or if the chronic value is lower than the
permit limit, then. at least two multiple concentration toxicity tests (one per month) will be conducted over the following two
months. As many analyses as can be completed will be accepted, If your NPDES permit does not require use of multiple
concentration toxicity testing upon failure of, any single quarterly test, you may choose to conduct either. single
concentration toxicity testing or multiple concentration toxicity testing per the Division's WET enforcement initiatives
effective July 1, 1999, Follow-up multiple concentration toxicity testing will influence the Division's enforcement response,
> 'Toxicity testing months are specified by the NPDES Permit, except for NPDES Permits which contain episodic toxicity
monitoring requirements (eg, if the testing months specified in your NPDES permit are March, June, September, and
December, then toxicity testing must he conducted during these months).
• If your NPDES Permit specifies episodic monitoring and your facility does not have a discharge from January 1-June 3.0,
then you must provide written notification to the Environmental Sciences Branch by June 3.0 that a discharge did not occur
during the first six months of the calendar year.
.> If you receive notification from your contract laboratory that a test was invalidated, you should immediatelynotify the
Environmental Sciences Branch at [phone] and provide written documentation indicating why, the test was
invalidated and the date when follow-up testing will occur„
If your facility is required to conduct toxicity testing during a .month in which no discharge occurs, you should complete the
information. block located at the top of the AT form indicating the facility name, permit number, pipe number, county and
the month/year of the subject report. You should also write No Flow" on the AT form, sign the form and submit following
normal procedures.
> The Aquatic Toxicity Test forms shall he signed by the facility's Operator in Responsible Charge (ORC) except for facilities
which have not received a facility classification. In these cases, a duly authorized facility representative must sign the AT
form. The ATIOTM must also be signed by (he performing lab supervisor.
> To determine if your AT test forms sere received on time by the Division of Water Quality, you may consider submitting
your toxicity test results certified mail. return receipt requested to the 'Environmental Sciences Branch.

A. (2.) ACUTE TOXICITY PASS/FAIL PERMIT LIMIT
The Permittee shall conduct acute toxicity tests on a quarterly basis using protocols defined in the
North Carolina Procedure Document entitled "Pass/Fail Methodology For Determining Acute Toxicity
In A Single Effluent Concentration" (Revised -July, 1992 or subsequent versions). The monitoring
shall be performedas a Fathead Minnow (Pimephales promeias) 24 hour static test. The effluent
concentration at which there may be at no time significant acute mortality is 900/0 (defined as
treatment two in the procedure document). Effluent samples for self -,monitoring purposes must be
obtained during representative effluent discharge below all waste treatment. The tests will be
performed during the months of March, Jurie, September and December.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the month in which it was performed, using the parameter
code TGE6C, Additionally, DWQ Foi in AT-2 (original) is to be sent to the following address:
Attention: North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Foi ins shall be filed with the Environmental Sciences Branch no
later than 30 days after the end of the reporting period for which the report is made.
Test data shall be complete and accurate and include all supporting chemical/physical
measurements performed in association with the toxicity tests, as well as all dose/response data,
Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is
employed for disinfection of the waste stream`.
Should there be no discharge of flow from the facility during a month in which toxicity inonitoring is
required, the Permittee will complete the infoiniation located at the top of the aquatic toxicity (AT)
test form indicating the facility name, permit number, pipe number, county, and the month/year of
the report with the notation of "No Flow" in the comment area of the form. The report shall be
submitted to the Environmental Sciences Branch at the address cited above.
Should any single quarterly monitoring indicate a failure to meet specified lirn:its, then monthly
monitoring will begin immediately until such time that a single test is passed. Upon passing, this
monthly test requirement will revert to quarterly in the months specified above.
Should the Permittee fail to monitor during a month in which toxicity monitoring is required, then
monthly monitoring will begin immediately until such time that a single test is passed. Upon passing„
this monthly test requirement will revert to quarterly in the months specified above..
Should any test data from either these monitoring requirements or tests performed by the North
Carolina Division of Water Quality indicate potential impacts to the receiving stream, this permit. may
be re -opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum
control"organisrn survival and appropriate environmental controls, shall constitute an invalid test
and will require immediate follow-up testing to be completed no later than the last day of the ,month
following the month of the initial monitoring.

State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
Mooresville, North Carolina 28110
b1
?(1O' indicates violation of the
919 North Main Street
CERTIFIED MAIL
RETURN RECEIPT RECIiESTtD
Mr. George R. Chapman
ALCOA Extrusions, Inc.
PO Box. 100
C North Carolina 2
Catawba.
SUBJECT:
August 21. 20(E
NOTICE OF VIOLATION
Whole Effluent Toxicity (WET) Tes
NPDES Permit No. NC004S712/001
ALCOA. Extrusions, Inc. WWTP
Catawba County
This is ro inrornl V011 tttat a review of your to icita' SeIf-monitoring report form Ior the montht o
d in vour NPDES Permit.
itv
You should take whatever refrtedia,l actions are necessary to eliminate the conditions causing the
eft tuent toxicity vioiationr s;. Your efforts may include conducting a Toxicity Reduction Evaluation
(TRE) which is a site -specific study designed to identify the causative agents of effluent toxicity, isolate
the sources of toxicity. evaluate the effectiveness of toxicity control options, and then confirm reductions
in effluent toxicity. Please be aware that North Carolina General'Statutes provide for assessment of civil
penalties for violations of NPDES permit limitations and requirements.
The reverse side of this Notice contains important information concerning) your Whole Effluent
To ;icit ' Monitoring and Reporting Requirements. Please note updated mailing addresses far submitting
your Discharge Monitoring Reports (DIM1Rs) and Aquatic Toxicity (AT) Test Forms. We encourage you
to review this information and if it would be helpful to discuss this situation or possible solutions to
resolve effluent toxicity noncompliance, please contact Mr. Sohn Lesley with this office at (704) 66
16p9.
D. Rex Gleason, P.E.
Regional Water Quality Supervisor
Aquatic Toxic�lta�?x I�nii
`.entrai -ae.

WHOLE EFFLUEN1 TOxJCITY MON FO
W
ORa1M.AT�I ON
The following items are provided in an effort to assist you va>itz identiat en. and
toxicity testing and reporting information. Please take time to review this information. hem
address rar iticrde �Il rite te7yritcs t� ... a _ t_.
you should have any questio
the Aquatic Toxicology Unit at
The rnittee ]
and that toxicity r
about your toxic
`t19i ,-37-2136 or a.
veriooked
sterns b low do not
PDES permit. If
estmg requirement, please contact Mr. Kevir, Bowder „itl rerr�sratr;F a
at the same number,
responsible for ensuring that toxicity testing is conducted according
eport forms are appropriately filed,
The reporting of whole effluent toxi.citl testing data
entered (with the appropriate parameter code) on.
submitted to:
Toxicity test da
Toxidit test resu
otftthe reporfing_period (eg
'Fa, city test conchal)
toxicity testing upon failure o
value is lower than the perrru
be conducted over the .followi
hope
q
ireznen,.
dual requirement. All toxicity test results must be
monthly Discharge Monitoring Report which is
North Carolina Division of Water Quality
Central Files
161'7 Mali Service Center
Raleigh, NC 27699-1617
IN ADDITION
"AT"" form) must be submitted to the following address:
North Carolina Divisicm of Water Quality
m
Environental. Sciences Branch
1621' Mail Service Center
l aleigh, North Carolina27699-1621
n
•led with the Env frpnrraen
result is due by the end of
ND REP
e contained in vour NPDES permit may° require use of multiplc4 concentration
sny single quarterly toxicity" test, if the. it itial pass/fail test fails or if the chronic
nit. ttaer t least ttivo multiple concentration toxicity tests (one per months
wall
tics .. .
on �'1s many
analyses as can be completed will be accepted. If vour
.NPDES permit does not require use of multiple concentration toxicity testing upon failure of any .sinui.e
quarterly test,, you may choose to conduct either singie concentration toxicity testing ar multiple concentration
toxicity testing per the Division's WET enforcement initiatives effective July..m
, 10F9. Fallorv-up erl.ti ie
concentration toxicity testing will influence the Divisions enforcement response.
Toxicity testing months are specified by the NPDES Permit, except for NPDES Pemuts which contain episodic
toxicity monitoring requirements (eg, if the testing months specified in your NPDES permit are March Jurie,
September, and December, then toxicity" testing must be conducted during these months),
If vour NPDES 'Permit specifies episodic monitoring and vour facility does not have a discharge from. January 1
June 30, then you must provide written notification to the Environmental Sciences Branch by June 30. that a
discharge did not occur during the first six months of the calendar year.
If you receive notification from your contract laboratory that a test was in -a
notify the Environmental Sciences Branch at (919) 7333_2136 and provide writtc
the test was. invalidated and the date when follow-up testing will occur.,
if ya�ur i `fifty, is required to conduct toxicity testing during a month sho
in
To deter
submittint vou,
Branch,
complete the information block located at the top of the AT form. indicating titectgilstername `permits number,
pipe number, county and the month/year of the subject report. You should also write 'No Flow" on the AT
form, sign the form and submit following normal procedures.
The Aquatic Toxicity Test forrrs shall be sigmed .by the facility's C erator in Respon_si,ble Charge (ORC) except
roar ttacilities which have not received a facility classification, in these cases, a duly authorized facility
representative must sign the AT ton.-�
g. The fain must also be signed by the performing lab supervisor,
AT test forms were received on time by the Division cat Water Qualit}` y`tnu m t tt te.. t results �r
ated, you should immediately
documentation indicating wh
etilted
i s ta
l
led mail, return receipt requested to the nvironm�entall

AUG-1 g-2O02 MON 08 : 06 AM
FAX NO
P, 01
Apiil 9, 2002
CGRTIFI
RETURN RE ° l l'.1 pUE T ©
Environ
North Carolina Division of Water Quality
Environmental Sciences Branch
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
R.L.: Notice of Violation
Whole Effluent Toxicity (WET) Testing
Copper acid Zinc Action Level Policy
NPDES Permit No. NC0048712/001
-Alcoa Extrusions, Inc.
Catawba County
Dear Sir or Madam.
122002
Br
6535 CrnmiScgre Rood
P.n.MxtW
camwba, NC 213609
P1ur . N211)241 3301
Pax: (82!!j 241-4044
We are in receipt of the above referenced Notice of Violation dated #"arch 11, 2002. This NOV
provides several options for this facility to pursue in order to come into compliance with its
WET testing requirement. Please be advised that Alcoa Extrusions, Inc. (Alcoa) is actively
investigating technologies that will allow us to cease all surface water discharge described in our
NPDES permit. This matter was discussed with Mr. Matt Matthews of the Aquatic Toxicology
Unit. Mr. Matthews suggested that this strategy would be covered under Option 4 in the
DENR's NOV, "Demonstration by an alternative method approved by the Division and EPA that
copper and/or zinc is not the cause oft©xicity,"
Alcoa understands that corrective actions necessary to ensure compliane r1,ust be completed
within nine months and that a report of our compliance status must au(1rnitted to the
Department by December 11, 2002.
Please direct any questions or comments that you might have tot
Environmental Services — Alcoa Engineered Products at 570-385-8$01.
Sincerely,
a rrge R. Chapman
Operations Manager
Alcoa Engineered Products
( C.`. ToN N .-C's
Clay Long, Manager of

State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
919 North Main Street -Mooresville, North Carolina 28115
CERTIFIED, MAIL
RETURN RECEIPT REQUESTED
Mr. George R. Chapman
ALCOA Extrusions, Inc.
PO Box 100
Catawba, North Carolina 28609
SUBJECT
Dear Mr. Chapman:
June 20, 2002.
NOTICE OF VIOLATION
Whole Effluent Toxicity (WET) Testing
NPDES Permit No, NC0048712/001
ALCOA Extrusions, Inc, WWTP
Catawba County
This is to inform you that a review of your toxicity self -monitoring report forms for the month of
April 2002 indicates a violation of the toxicity limitation specified in your NPDES Pertnit.
You should take whatever remedial actions are necessary to eliminate the conditions causing the
effluent toxicity violation(s). Your efforts may include conducting a Toxicity Reduction Evaluation
(TRE) which is a site -specific study designed to identify the causative agents of effluent toxicity, isolate
the sources of toxicity, evaluate the effectiveness of toxicity control, options, and then confirm reductions
in effluent toxicity. Please be aware .that North Carolina General Statutes provide for.assessment of civil
penalties for violations of NPDES permit limitations and requirements.
The reverse side of this Notice contains important information concerning your Whole Effluent
Toxicity Monitoring and Reporting Requirements. Please note updated mailing addresses for submitting
your Discharge Monitoring Reports (DMRs) and Aquatic Toxicity (AT) Test Forms, We encourage you
to review this information and if it would be helpfui to discuss this situation or possible solutions to
resolve effluent toxicity noncompliance, please contact Mr. John Lesley with this office at (704) 663-
1699.
cc: Aquatic Toxicology Unit
Central Files
Sincerely,
6-)
D. Rex Gleason, P.E.
Regional Water Quality Supervisor

WHOLE EFFLUENT TOXICITY MONITORING AND REPORTING INFORMATION
The following items are provided in an effort to assist you with identifying critical and sometimes overlooked
toxicity testing arid reporting irtforrnation. Please take time to review this information. The items below do pot
address rjha4Lj1 the tr xi tsjjjgndje din r quirern n ojndjfQ$ermit. If
you should have any questions about your toxicity testing requirement, please contact Mr. Kevin Bowden with
the Aquatic Toxicology Unit at [phone] or another Unit representative at the same number.
The permittee is responsible for ensuring that toxicity testing is conducted according to the permit requirement
and that toxicity report forms are appropriately filed.
The reporting of whole effluent toxicity testing data is a dual. requirement, Ali toxicity test results must. he
.entered (with the appropriate parameter code) on your monthly Discharge Monitoring Report which is
submitted to:
North Carolina Division of Water Qua .*
Central Files
1.617 Mail Service Center
Raleigh, NC 27699-161.7
IN ADDITION
Toxicjty test data (original"AT" form) must be submitted to the following address:
North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Toxicity test results shall he filed with the Environmental Sciences Branch
of the reporting period (eg, January test result is due by the end of February).
hartjQdays after e end
Toxicity test condition language contained in your NPDES permit may require use of multiple concentration
toxicity testing upon failure of any single quarterly toxicity test,. If the initial pass/fail test fails or if the chronic
value is lower than the permit limit, then at least two multiple concentration toxicity tests (one per month) will
be conducted over the following two months. As many analyses as can be completed will be accepted. If your
NPDES permit does not require use of multiple concentration toxicity testing upon failure of any single
quarterly test, you m.ay choose to conduct either single concentration toxicitytesting or multiple concentration
toxicity testing per the Division's WET enforcement initiatives effective July 1, 1999. Follow-up multiple
concentration toxicity: testing willinfluence the Division's enforcement response.
Toxicity testing months are specified by the NPDES Permit except for NPDES Permits which contain episodic
toxicity monitoring requirements (e.g„ if the testing months specified in your NTDES perrnit are March, June,
September, and December, then toxicity testing must be conducted during these months)..
If your NPDES Permit specifies episodic monitoring and your facility does not have a discharge from January 1-
June 30, then you must provide writte.nnotification to the Environmental Sciences Branch by June 30 that a
discharge did not occur during the first six months of the calendar year.
If you receive notification from your contract laboratory that a test was invalidated, you should immediately
notify the Environmental Sciences Branch at (919) 733-2.136 and provide written documentation indicating why
thetest was invalidated and the date when follow-up testing will occur.
If your facility is required to conduct toxicity testing during a month in which no discharge occurs, you ,should
complete the inforrnatio.n block located at the top of the AT form. indicating the facility name, permit number,
pipe number, county and the month/year of the subject' report. You should also write "No Flow" on the AT
form, sign the formand submit following normal procedures.
The Aquatic Toxicity Test forms shall be signed by tbe facility's Operator in Responsible Charge (ORC) except
for facilities which have not received a facility cias.sification. In these cases, a duly authorized facility
representative must sign the AT form. The AT form must also be signed by the performing lab supervisor.
To determine if your AT test forms were received on time by the Division of Water Qualitv. you may consider
submitting your toxicity_ test results certified mail, return receipt requested to the Environmental Sciences
Branch.

91.9 North Main Street
,c1E to Cc P`-;
RT D MAIL
RETURN RECEIPT REOUES 1ED
Mr. George R. Chapman
ALCOA Extrusions, Inc.
PO Box 100
Catawba, North Carolina 28609
SUBJECT:
Dear Mr. Chapman:
State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
Mooresville, North Carolina 28115
ay 24, 2002
NOTICE OF VIOLATION
Whole Effluent Toxicity (WET) Testing
NPDES Permit No. NC0048712/001
ALCOA Extrusions, Inc. WWTP
Catawba County
This is to inform you that a review of your toxicity self -monitoring report forrns for the month of
March 2002 indicates a violation of the toxicity limitation specified in your NPDES Permit,
You should take whatever remedial actions are necessary to eliminate the conditions causing the
effluent toxicity violation(s). Your efforts may include conducting a Toxicity Reduction Evaluation
(TRE) which is a site -specific study designed to identify the causative agents of effluent toxicity, isolate
the sources of toxicity, evaluate the effectiveness of toxicity control options, and then confirm reductions
in effluent toxicity. Please be aware that North Carolina General Statutes provide for assessment of civil
penalties for violations of NPDES permit limitations and requirements.
The reverse side of this Notice contains important information concerning your Whole Effluent
Toxicity Monitoring and Reporting Requirements, Please note updated mailing addresses for submitting
your Discharge Monitoring Reports (DMRs) and Aquatic Toxicity (AT) Test Forms. We encourage you
to review this information and if it would be helpful to discuss this situation or possible solutions to
resolve effluent toxicity noncompliance, please contact Mr. John Lesley with this office at (704) 663-
1699.
Sincerely,
D. Rex Gleason, P.E.
Regional Water Quality Supervisor
cc: Aquatic Toxicology Unit
Central Files

WHOLE EFFLUENT TOXICITY MONITORING AND REPORTING INFORMATION
The following items are provided in an effort to assist you with identifying critical and sometimes overlooked
toxicity testing and reporting information. Please take time to review this information. Tht items below do n_g_t
addre or I all t 'n d o uirements contained in your NPDES permit If
you should have any questions about your toxicity testing requirement, please contact Mr. Kevin Bowden with
the Aquatic Toxicology Unit at [phone] or another Unit representative at the same number.
The perrnittee is responsible for ensuring that toxicity testing is conducted according to the permit requirement
and that toxicity report forms are appropriately filed.
);'• The reporting of whole effluent toxicity testing data i.s a dual requirement- All toxicity test results must be
entered (with the appropriate parameter code) on your monthly Discharge Monitoring Report which is
submitted to:
North Carolina Division of Water Quality
Central Files
1617 Mail Service Center
Raleigh, NC 27699-1.617
IN ADDITION
Toxicity test data (original "AT" form) must be submitted to the following address;
North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center.
Raleigh, North Carolina 27699-1621
• Toxicity test results shall be filed with the Environmental Sciences Branch no laterthn 30 days after the end
of the reportinperi0 (eg, January test result is due by the end of February)
• Toxicity test condition language contained, in your NPDES permit may require use of multiple concentration
toxicity testing upon failure of any single quarterly toxicity test. If the initial pass/fail test fails or if the chronic
value is lower than the permit limit, then at least two multiple concentration toxicity tests (one per month) will
be conducted over the following two months. As many analyses as can be completed will be accepted. If your
NPDES permit does not require use of multiple concentration .toxicity testing uponfailure of any single
quarterly test, you may choose to conduct either single concentration toxicity testing or multiple concentration
toxicity testing per the Division's WET enforcement initiatives effective julv 1., 1999..Follow-up multiple
concentration toxicity testing will influence the Division's enforcement response.
17oxicity testing months are specified by the NPDES Permit, except for NPDES Permits which contain episodic
toxicity- monitoring requirements (eg, if the testing months specified i.n your NPDES permit are March, June,
September, and December, then toxicity testing must be conducted during these months).
If your NPDES Permit specifies episodic monitoring arid your facility does not have a discharge from January, 1.-
lune 30, then you must provide written notification to the Environmental Sciences Branch by June 30 that a
discharge did not occur duringthe first six months of the calendar year,
• If you receive notification from your contract laboratory that a test was invalidated, you, should immediately
notify the Environmental Sciences Branch at (919) 733-.2136 and provide written documentation indicating why
the test was invalidated and the date when follow-up testing will occur.
If your facility is required to conduct toxicity testing during a month in which no discharge occurs, you should
complete the information block located at the top of the AT form indicating the facility name, permit number,.
pipe .number„ county and the month/year of the subject report. You should also write "No Flow." on the AT
form, sign the form and submit following normal procedures.
▪ The Aquatic Toxicity Test forms shall be signed by the .facility's Operator in Responsible Charge (ORC) except
for facilities which have not received a facility classification. In these cases, a duly authorized facility
representative must sign the AT form. The AT form must also be signed by the performing lab supervisor.
• To determine if your AT test forms were received on tirne by the Division of Water Quality, you may consider
submitting your toxicitytest results certified mail, return receipt requested to the Environmental Sciences
Branch.

919 North Main Street
cx,
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. George R Chapman
ALCOA„Extrusions, Inc.
PO Box 100
Catawba, North Carolina 28609
SUBJECT:
Dear Mr. Chapman:
State of North Carolina
Depart ent of Environment and Natural Resources
Division of Water Quality
Mooresville, North Carolina 28115
March 11, 2002
NOTICE OF VIOLATION
Whole Effluent Toxicity (WET) Testing
Copper and Zinc Action Level Policy
NPDES Permit No, NC00487.12/001
ALCOA Extrusions. Inc, WWTP
Catawba County
This is to inform you that a review of your toxicity self -monitoring report forms for the month of
December 2001 indicates violations of the toxicity limitation specified in your NPDES Permit. You
should undertake necessary actions to eliminate or reduce effluent toxicity to acceptable levels..
A separate Notice of Violation with the same date as above accompanied this Notice and
addressed implementation of the, Division's Copper and Zinc Action Level Policy. The correspondence
included prospective permit limits for copper and/or zinc and stated that the trigger for implementing the
policy would be two or more WET limit violations which occur during a toxicity testing calendar
quarter. Please note that the second WET limit violation has occurred and you must provide:
a) Written notification indicating acceptance of the prospective copper and/or
zinc permit limit. Notification is due by April 11, 2002.
OR
b) Written notification indicating your choice of opiion(s) 1-4 below. Notification is due by
April 11, 2002. DWQ approval of options 1-3 below is not necessary as the Division
expects work to rule out copper and/or zinc as causative effluent, toxicants to begin.
immediately upon the second WET permit limit violation that occurred during December
2001.
1. nstream measurements of dissolved metal during low flow conditions that demonstrate
compliance with the Action Level standard,
2. A revision of the prospective permit limit using improved inputs that in concert with
existing or additional monitoring data demonstrates compliance with the Action Level
standard
3. Toxicity Identification Evaluation (TIE) results that definitively rule out copper and/or
zinc as causes of effluent toxicity

7).
4. Demonstration by an alternative method approved by the Division and EPA that copper
1 and/or zinc is not the cause of toxicity
Written notification (a or b above) shall be sent to:
North Carolina Division of Water Quality
Environmental Sciences Branch
Aquatic Toxicology Unit
1.621 Mail Service Center
R.a.leicih, North Carolina 27699-1621
Please note that if you choose item b) above, you will be given nine months to submit
documentation that eliminates copper and/or zinc as causative effluent toxicants. Your .final report
should be comprehensive and include all data used to support your conclusion. The report is due by
December 11, 2002,
Three copies of the final report shall be submitted to:
North Carolina Division of Water Quality
Environmental Sciences Branch
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh. North Carolina 27699-1621
Failure to notify DWQ of your acceptance of a copper and/or zinc limit, failure to notify DWQ
of your option selection or failure to make acceptable demonstration to DWQ that copper and/or zinc are
not causative effluent toxicants within the stated time frames will result in reopening of the NPDES
Permit to include copper and/or zinc numeric limitations. as appropriate.
If the effluent is toxic, then we expect work to commence immediately with toxic effluent
samples. Failure to initiate work with toxic effluent samples during the study period is unacceptable and
will be considered a failure to make acceptable demonstration as cited above. We recommend a
minimum of three separate sampling events during the nine month period to definitively rule out copper
and/or zinc as causative effluent toxicants.
Additional information regarding the Division's copper and/or zinc action level policy can be
found at the following web site - httpe/ /www.esb,enr.statestc.usi. Click on the Aquatic Toxicology
Unit and go to the prompt "AT Downloadable Files" located at the bottom of the page..
If you have any questions concerning this correspondence, please contact me at (7. 4) 663-1699
or Mr. Matt Matthews. Supervisor of the Aquatic Toxicology Unit at (9'19) 733-2136.
Sincerely,
Rex GleasOn
Water Quality Regional Supervisor
cc: Mooresville Regional Office
Susan Wilson-NPDES Unit
Tom Poe -Pretreatment
Lydia Mayo-USEPA Region IV, Atlanta Federal Center. 61 Forsyth Si., SW, Atlanta, GA 30303
Aquatic Toxicology Unit Files
Central Files

State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
9 9 North Main Street Mooresville, North Carolina 28115
April 26, 2002
5to mob 64,)6. 4,514
CERTIFIED MAIL
RETURN RECEIPT REQUES IED
Mr. George R. Chapman
ALCOA Extrusions, Inc,
PO Box 1.00
Catawba, North Carolina 28609
SUBJECT:
Dear Mr, Chapman:
NOTICE OF VIOLATION
Whole Effluent Toxicity (WET) Testin
NPDES Permit No. NC0048712/00 I
ALCOA Extrusions, Inc. WWTP
Catawba County
This is to inform you that a review of your toxicity self -monitoring report forms for the month of
February 2002 indicates a violation of the toxicity limitation specified in your NPDES Permit.
You should take whatever remedial actions are necessary to eliminate the conditions causing the
effluent toxicity violation(s). Your efforts may include conducting a Toxicity Reduction Evaluation
(TRE) which is a site -specific study designed to identify the causative agents of effluent toxicity, isolate.
the sources of toxicity, evaluate the effectiveness of toxicity control options, and then confirm reductions
in effluent toxicity. Please be aware that North Carolina General Statutes provide for assessment of civil.
penalties for violations of NPDES permit limitations and requirements.
The reverse side of this Notice contains important information concerning your Whole Effluent
Toxicity Monitoring and Reporting Requirements. Please note updated mailing addresses for submitting
your Discharge Monitoring Reports (DMRs) and Aquatic Toxicity (AT) Test Forms. We encourage you
to review this information and if it would be helpful to discuss this situation or possible solutions to
resolve effluent toxicity noncompliance, please contact Mr, John Lesley with this office at (704) 663-
1699,
Sincerely,
D. Rex Gleason, P.E.
Regional Water Quality Supervisor
cc: Aquatic Toxicology Unit
Central Files

WHOLE EFFLUENT TOXICITY MONITORING AND REPORTING INFORMATION
The following items are provided in an effort to assist you with identifying critical and sometimes overlooked
toxicity testing and reporting information. Please take time to review this information. The items below do not
address or include all the oxi i t st'n nd din re ir m nts contai d 'n our NP S ermit. If
you should have any questions about your toxicity testing requirement, please contact Mr. Kevin Bowden with
the Aquatic Toxicology Unit at [phone] or another Unit representative at the same number.
The permittee is responsible for ensuring that toxicity testing is conducted according to the permit requirement
and that toxicity report forms are appropriately filed,
The reporting of whole effluent toxicity testing data is a dual requirement. All toxicity test results rnust be
entered (with the appropriate parameter code) on your monthly Discharge Monitoring Report which is
submitted to:
North Carolina Division of Water Quality
Central Files
1617 Mail Service Center
Raleigh, NC 276994617'
IN ADDITION
Toxicity test data (original "AT" form) must be submitted to the following address:
North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Toxicity test results shall be filed with the Environmental Sciences Branch no later than 30 days after the end
nf.the reporting period (eg, January test result is due by the end of February).
Toxicity test condition language contained in your NPDES permit may require use of multiple concentration.
toxicity testing upon failure of any single quarterly toxicity test. If the initial pass/fail test fails or if the chronic
value is lower than the permit Iirrdt, then at least two multiple concentration toxicity tests (one per month) will
be conducted over the following two months. As many analyses as can be completed will be accepted. If your
NPDES permit does not require use of multiple concentration toxicity testing upon failure of any single
quarterly test, you may choose to conduct either single concentration toxicity testing or multiple concentration
toxicity testing per the Division's WET enforcement initiatives effective july 1, 1999, Follow-up multiple
concentration toxicity, testing will influence the Division's enforcement response„
Toxicity testing months are specified by the NPDES Permit, except for NPDES Permits which contain episodic
toxicity monitoring requirements (eg, if the testing months specified in your NPDES permit are March, lune,
September, and December, then toxicity testing must be conducted during these months).
If your NPDES Permit specifies episodic monitoring and your facility does not have a discharge from January '1-
June 30, then you must provide written notification to the Environmental Sciences Branch by June 30 that a
discharge did not occur during the first six months of the calendar year.
If you receive notification from your contract laboratory that a test was invalidated, you should immediately
notify the Environmental Sciences Branch at [phone] and provide written documentation indicating why
the test was invalidated and the date when follow-up testing will occur.
If your facility is required to conduct toxicity testing during a month in which no discharge occurs, you should
complete the information block located at the top of the AT form indicating the facility name, permit number,
pipe number, county and the month/year of the subject report. You should also write "No Flow" on the AT
form, sign the form and submit following normal procedures.
The Aquatic Toxicity Test forms shall. be signed by the facility's Operator in Responsible Charge (ORC) except
for facilities which have not received a facility classification. In these cases, a duly authorized facility
representative must sign the AT form, The AT form must also he signed by the performing lab supervisor.
To determine if your AT test forms were received on time by the Division of Water Quality, you may consider
submittin lour `ci test results certified miL return receipt requested to the Environmental Sciences
Branch.

State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
919 North Main Street Mooresvilie„ North Carolina 28115
March 11, 2002
7ef.,,t; 7 6 005 (..)->"-? 7
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr, George R. Chapman
ALCOA Extrusions, Inc.
PO Box 100
Catawba, North Carolina 28609
SUBJECT:
Dear Mr. Chapman:
NOTICE OF VIOLATION
Whole Effluent Toxicity (WET) Testing
Copper and Zinc Action Level Policy
NPDES Permit No. NC0048712/001
ALCOA Extrusions, Inc. WWTP
Catawba County
This is to inform you that a review of your toxicity self -monitoring report forms for the month of
December 200.1 indicates violations of the toxicity limitation specified in your NPDES Permit. You
should undertake necessary actions to eliminate or reduce effluent toxicity to acceptable levels,
In addition, this. correspondence contains important information on the Division's Copper and
Zinc Action Level Policy which is triggered by two or more 'toxicity limit violations that occur during
the toxicity testing calendar quarter specified by the toxicity testing special condition of your NPDES
Permit, Attachments addressing policy implementation and a copy of the Division's Toxicity Reduction
Guidance have been included with this Notice of Violation.
You should initiate follow-up toxicity testing upon a single WET test failure which occurs
during the toxicity testing calendar quarter.
Your facility is currently monitoring for copper and/or zinc and is exceeding the action level for
these parameters. The policy states that whenever a facility experiences two or more toxicity limit
violations during a toxicity testing calendar quarter, the NPDES Permit will be modified to include
numeric limits for copper and/or zinc UNLESS the permittee provides one or more of the following:
1. Instream measurements of dissolved metal during o • conditions that demonstrate
compliance with the Action Level standard
2. A revision of the prospective permit lirn.it. using improved inputs that in concert with
existing or additional monitoring data demonstrates compliance with the Action Level
standard
3 Toxicity Identification Evaluation (TIE) results that definitively rule out copper and/or zinc
as causes of effluent toxicity
4. Demonstration. by an alternative method approved by the Division and EPA .thatcopper
and/or zinc is not the cause of toxicity.

The Division has evaluated your copper and/or zinc monitoring data, The Division has also
developed a prospective NPDES permit limit based on your facility's instream waste concentration, the
copper and/or zinc action level criterion and a translator procedure. Based on this data your prospective
copper 'permit limit is 1..4 AWL and your prospective zinc permit limit is 111. pg/L,
The permittee, upon experiencing two or more toxicity limit violations during a toxicity
testing calendar quarter must either provide DWQ with:
a) Written notification indicating acceptance of the prospective copper
and/or zinc pern-lit limit. Notification is due within 30 days after the date of
the second WET Notice of Violation:
OR,
b) Written notification indicating your choke of option(s) , noted on page
one of this correspondence. Notification is due within 30 days after the date.
of the second WET Notice of 'Violation.. DWQ approval of options 1-3
(previous page) is not necessary as the Division expects work to rule out
copper and/or zinc as causative effluent toxicants to begin immediately upon
the second WET permit limit violation,
Written notification (a or b above) shall be sent to:
North Carolina Division of Water Quality
Environmental Sciences Branch
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, North Carolina 276994621.
Please note that if you choose item b) above, you will be given nine, months to submit
documentation that eliminates copper and/or zinc as causative effluent toxicants. Your final report.
should be comprehensive and include all data used to support your conclusion(s). Should the data
indicate copper and/or zinc as the source of effluent toxicity or if the data are inconclusive as to copper
and/or zinc's role as a toxicity source, then the NPDES Permit will he reopened and the 'metal limits
specified above will be applied to the permit. The report is due nine months after the date of the second
WET Notice of Violation,
Three copies of the final report shall be submitted. to.
North Carolina Division of Water Qualitv
Environmental Sciences Branch
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
You should consider subraittin;tg the above correspondence certified mail.
Failure to notify DWQ of your acceptance of a copper and/or zinc limit, failure to notify
DWQ of your option selection or failure to make acceptable demonstration to DWQ that copper
and/or zinc are not causative effluent toxicants within the stated time frames will result in
reopening of the NPDES Permit to include copper and/or zinc numeric limitations, as appropriate.
Please note that your actions to notify DWQ of prospective limit acceptance or to notify DWQ
of plan option(s) and subsequent submission of a 'plan are contingent upon two or more toxicity .NPDES
permit limit violations occurring during a toxicity testing calendar quarter.

If the effluent is toxic, then we expect work to commence immediately^ with toxic effluent
samples. Failure to initiate work with toxic effluent samples during the study period is unacceptable and
will be considered a failure to make acceptable demonstration as cited above, We recommend a
minimum of three separate sampling events during the nine month period to definitively rule out copper
and/or zinc as causative effluent toxicants.
Also note that the WET limit will remain in your NPDES permit regardless of whether metals
are the source of effluent toxicity. The data resulting from your actions to disprove copper and/or zinc as
sources of effluent toxicity will determine whether NPDES Permit limits will be assigned for these
parameters. You are responsible for initiating actions to address these issues.
You rnay consider entering into a Special Order by Consent (SOC) with DVVQ. A SOC provides
regulatory relief for specific NPDES permit limit violations and, if signed, will contain a requirement to
conduct a Toxicity Reduction Evaluation. The SOC will contain a compliance schedule, stipulated
penalties for failing to meet milestone activity dates and may contain upfront penalties to settle past
permit limit violations.
Additional information regarding the Division's copper and/or zinc action level policy can be
found at the following web site http//www.esb.enr.statenc.us. Click on the "Aquatic
Toxicology" 'Unit and go to the prompt "DOWNLOADS" located at the bottom of the page. This web
site also contains EPA's "Toxicity Reduction Evaluation Guidance for Municipal Wastewater Treatment
Plants." Section 4 of this documentcontains pertinent information on Toxicity Identification
Evaluations.
If you have any questions concerning this correspondence, please contact me at (7)4) 663-1699
or Mr. Matt Matthews, Supervisor of the Aquatic Toxicology Unit at (9.19) 733.-2136.
Sincerely,
,r)
D. Rex Gleason, P.E.
Regional Water Quality Supervisor
ATTACHMENTS
cc: Mooresville Regional Office (no attachments)
Susan Wilson-NPDES Unit (no attaehrnents)
Tom Poe -Pretreatment (no attachments)
Lydia Mayo-USEPA Region IV, Atlanta Federal Center, 61 Forsyth St., SW, Atlanta, GA 30303
(no attachments)
Central Files (no attachments)
Aquatic Toxicology Unit Files (no attachments)