NC0089109_Permit Issuance_20111111

NPDES DOCUMENT SCANNING COVER SHEET
NPDES Permit:
NC0089109
Document Type: :,
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Meeting Notes
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
November 11, 2011
This document is printed on reuse paper - ignore any
eontexit on the reYersse side

AtccrA
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
November 11, 2011
Mr. Darin Cooper
Horsehead Corporation
4955 Steubenville Pike, Suite 405
Pittsburgh, PA 15205
Subject: Issuance of NPDES Permit NC0089109
Rutherford County Production Facility
Rutherford County
Facility Class WW-2
Dear Mr. Cooper:
Division personnel have reviewed and approved your application for a new NPDES permit.
Accordingly, we are forwarding the attached NPDES discharge permit. This permit is issued pursuant to
the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between
North Carolina and the U.S. Environmental Protection Agency dated October 15, 2007 (or as subsequently
amended).
This Final Permit contains no major changes from the Draft Permit sent to you on
September 14, 2011.
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty (30)
days following receipt of this letter. 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
(6714 Mail Service Center, Raleigh, North Carolina 27699-6714). Unless such demand is made, this
decision shall be final and binding.
Please note that this permit is not transferable except after notice to the Division. The Division may
require modification or revocation and reissuance of the permit. This permit does not affect the legal
requirements to obtain other permits which may be required by the Division of Water Quality or permits
required by the Division of Land Resources, the Coastal Area Management Act or any other Federal or Local
governmental permit that may be required. If you have any questions concerning this permit, please
contact Sergei Chernikov at telephone number [phone].
t
cc: Central Files NPDES Files Asheville Regional Office / Surface Water Protection
Aquatic Toxicology Unit (e-copy) David Honeycutt, McGill Engineers (e-copy: [e-mail])
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
512 North Salisbury Street, Raleigh, North Carolina 27604
Internet: http://portal.ncdenr.orglweb/wq
Phone: [phone] / FAX [phone]
[e-mail]
NorthCarolina
Naturally
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper

Permit NC0089109
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1,
other lawful standards and regulations promulgated and adopted by the North Carolina
Environmental Management Commission, and the Federal Water Pollution Control Act, as
amended,
Horsehead Corporation
is hereby authorized to discharge wastewater from a facility located at the
Rutherford County Production Facility
Hicks Grove Rd
Forest City
Rutherford County
to receiving waters designated as the Broad River in subbasin 03-08-02 of the Broad River Basin
in accordance with effluent limitations, monitoring requirements, and other conditions set forth
in Parts I, II, III and IV hereof.
This permit shall become effective December 1, 2011.
This permit and authorization to discharge shall expire at midnight on July 31, 2013.
Signed this day November 11, 2011.
efo•-
Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit NC0089109
SUPPLEMENT TO PERMIT COVER SHEET
Horsehead Corporation is hereby authorized to:
1. Construct and operate a zinc recycling facility, with a discharge of process
wastewater to be monitored / controlled by:
➢ Automatic sampler
➢ Instrumented flow measurement
➢ Diffuser
The facility will be located off Hicks Grove Rd near Forest City in Rutherford
County.
2. Discharge from said wastewater system at the location specified on the attached
map into the Broad River, currently classified C waters in hydrologic unit
03050105 of the Broad River Basin.

NC0089109 - Horsehead Corporation
Latitude: 35°12'03" Sub -Basin: 03-08-02
Longitude: 81°51'03" USGS Quad: F11SW
Receiving Stream: Broad River
Stream Class: C
Hydrologic Unit: 03050105
Facility
Location
Araidh
Map not to scale
Rutherford County

Permit NC0089109
A. (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee
is authorized to discharge from outfall 001. Such discharges shall be limited and monitored by the
Permittee as specified below:
PARAMETER
LIMITS
MONITORING REQUREMENTS
Monthly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample
Location1
Flow
0.62 MGD
Continuous
Recording
Effluent
Total Suspended Solids
Monthly
Composite
Effluent
NH3-N
Quarterly
Composite
Effluent
Total Aluminum
Quarterly
Composite
Effluent
Antimony
Quarterly
Composite
Effluent
Arsenic
Quarterly
Composite
Effluent
Total Cadmium
.350 pg/L
2,143 pg/L
Monthly
Composite
Effluent
Chlorides
Quarterly
Composite
Effluent
Total Chromium
Quarterly
Composite
Effluent
Total Cobalt
Quarterly
Composite
Effluent
Total Copper
Quarterly
Composite
Effluent
Fluoride
315.8 mg/L
315.8 mg/L
Monthly
Composite
Effluent
Total Iron
Quarterly
Composite
Effluent
Total Lead
4,386 pg/L
4,829 Ng/L
Monthly
Composite
Effluent
Total Nickel
Monthly
Composite
Effluent
Total Tin
Quarterly
Composite
Effluent
Total Zinc
Quarterly
Composite
Effluent.
pH
> 6.0 and < 9.0 standard units
Weekly
Grab
Effluent
Chronic Toxicity3
Quarterly
Composite
Effluent
Turbidity4
Monthly
Grab
Effluent
U,D•
NOTES;
1. U: at least 50 feet upstream from the outfall. D: at least 50 feet downstream from the
outfall.
3. Chronic Toxicity (Ceriodaphnia) P/F ® 0.57% with testing in January, April, July, and
October [see A. (2)].
4 The discharge from this facility shall not cause turbidity in the receiving stream to
exceed 50 NTU. If the instream turbidity exceeds 50 NTU due to natural background
conditions, the discharge cannot cause turbidity to increase in the receiving stream.
THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR FOAM VISIBLE IN OTHER THAN
TRACE AMOUNTS.

Permit NC0089109
A. (2) CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QUARTERLY)
The effluent discharge shall at no time exhibit chronic toxicity using test procedures outlined in the "North
Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised November 1995, or subsequent
versions.
The effluent concentration at which there may be no observable inhibition of reproduction or significant
mortality is 0.57% (defined as treatment two in the procedure document). The permit holder shall perform
quarterly monitoring using this procedure to establish compliance with the permit condition. The tests will
be performed during the months of January, April, July, and October. Effluent sampling for this testing
shall be performed at the NPDES permitted final effluent discharge below all treatment processes.
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 TGP3B.
Additionally, DWQ Form AT-1 (original) is to be sent to the following address:
Attention: North Carolina Division of Water Quality
Environmental Sciences Section
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
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 monitoring is
required, the permittee will complete the information 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 limits, 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 this monitoring requirement 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.
If the Permittee monitors any pollutant more frequently then required by this permit, the results of such
monitoring shall be included in the calculation & reporting of the data submitted on the DMR & all AT
Forms submitted.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control
organism survival, minimum control organism reproduction, 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.

NCDENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
Horsehead Corporation
NC0089109
Facility Information
(1.) Facility Name:
j Rutherford County Production facility
(2.) Permitted Flow (MGD):
j 0.62
(6.) County: . Rutherford
(3.) Facility Class:
II
A7.) Regional Office: Asheville
(4.) Pretreatment Program:
N/A_._._.....__.
—___.._....(8.) USGS Top-o Quad: _
(9.) USGS Quad Name:
F
F11SW
(5.) Permit Status:
New
Stream Characteristics
(1.) Receiving Stream:
i Broad River
(7.) Drainage Area (mi2): 1575
(2.) Sub -basin:
1 03-08-02
(8.) Summer 7Q10 (cfs):
' 167
(3.) Stream Index Number:
1 9-(36.5)
(9.) Winter 7Q10 (cfs):
334
544 Stream Classification:
C
(10.) 30Q2 (cfs)
403
(5.) 303(d) Status:
i Not listed
(11.) Average Flow (cfs):
914
(6.) 305(b) Status:
j
(12.) IWC %:
0.5
Summary
Horsehead Corporation proposes a construction of the industrial facility in the southern
portion of the Rutherford County. The facility will use the impure zinc oxide that is
generated from the recycled EAF dust in other Horsehead facilities. The EAF dust is a zinc
containing waste generated by the North American mini mills. The facility will produce
approximately 148,000 tons of high quality prime -Western grade Zinc metal. The process
will include zinc oxide leaching, extraction of zinc with an organic ligand and electrowinning.
The facility will achieve significant degree of recycling of the reagents that are used in the
process. This would be a first facility of this type in the USA, and there are no effluent
guidelines for Zinc recycling facilities.
The EAA was submitted by the McGill Associates on behalf of the Horsehead Corporation.
The EAA was approved on July 22 2011, it allows discharge of 0.62 MGD treated industrial
wastewater. The wastewater generated by the facility is essentially a clean brine solution that
has a high concentration of chlorides (19,680 mg/L). Potable water and sanitary sewer
service will be provided by the Forrest City.
RPA
The application identified the number of pollutants that might be present in the discharge.
The RPA (reasonable potential analysis) was conducted for these pollutants: iron, chlorides,
fluoride, tin, arsenic, zinc, nickel, cobalt, copper, cadmium, lead, aluminum, chromium, and
antimony (please see attached).
WET
The whole effluent toxicity testing was assigned in accordance with 15A NCAC 2B.0508

NPDES Permit Fact Sheet — 11 / 02 / 11 Horsehead Corporation
Page 2 NC0089109
Proposed Schedule for Permit Issuance
Draft Permit to Public Notice:
Permit Scheduled to Issue:
August 17, 2011 (est.)
October 10, 2011 (est.)
State Contact Information
If you have any questions on any of the above information or on the attached permit, please
contact Sergei Chernikov at [phone], or [e-mail].
Regional Office Comments:
Name: Date:

Horsehead Corporation REASONABLE POTENTIAL ANALYSIS
NC0089109
Qw (MGD) = 0.62
1 Q 10S (cfs) = 135.80
7Q 1 OS (cfs) = 167.00
7QIOW (cfs) = 334.00
30Q2 (cfs) = 403.00
Avg. Stream Flow, QA (cfs) = 914.00
Receiving Stream: Broad River
WWTP/WTP Class: Ill
IWC @ 1QiOS = 0.70%
IWC @ 7Q 10S = 0.57%
IWC @ 7Q1OW = 0.29%
IWC @ 30Q2 = 0.24%
IWC @ QA = 0.11%
Stream Class: C
Outfall 001
Qw=0.62MGD
PARAMETER
.
TYPE
STANDARDS & CRITERIA (2)
a
co
zII
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
NC WQS / Applied V2 FAV /
Chronic Standard Acute
# Det. Max Pred Cw Allowable Cw
Iron
NC
1000 HH(7Q10s)
ug/L
1 1
Note: n<12
Limited data set
17,450.40000
Default C.V.
Acute: NO WQS
._ ___ ___ _ _ ____________________________
Chronic: 175438.59649
No value > Allowable Cw
no limit
Page 1 of 1
89109 - RPA-2-2011.xism, rpa
8/10/2011

REASONABLE POTENTIAL ANALYSIS
Iron
Date Data BDL=1/2DL Results
1 1320 1320 Std Dev. N/A
2 Mean 1320.0000
3 C.V. (default) 0.6000
4 n 1
5
6 Mult Factor = 13.22
7 Max. Value 1320.000000 ug/L
8 Max. Pred Cw 17450.400000 ug/L
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
SPECIAL -Values" WITH
"COPY" COMMAND
-4-
89109 - RPA-2-2011.xlsm, data
8/10/2011

Horsehead Corporation REASONABLE POTENTIAL ANALYSIS
NC0089109
Qw (MOD) = 0.62
1Q10S (cfs) = 135.80
7Q1OS (cfs) = 167.00
7QIOW (cfs) = 334.00
30Q2 (cfs) = 403.00
Avg. Stream Flow, QA (cfs) = 914.00
Receiving Stream: Broad River
WWTP/WTP Class: Ill
IWC @ 1Q1OS = 0.70%
IWC @ 7Q10S = 0.57%
IWC @ 7Q1OW = 0.29%
IWC @ 30Q2 = 0.24%
IWC @ QA = 0.11%
Stream Class: C
Outfall 001
Qw=O.62MGD
PARAMETER
TYPE
(1)
STANDARDS & CRITERIA (2)
-i
a
cn
=
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
NC WQS /
Chronic
Applied
Standard
t/x FAV /
Acute
n # Det. Max Pred Cw Allowable Cw
Arsenic
Arsenic
C
C
50
10
FW(7Q10s)
HH/WS(Qavg)
ug/L
ug/L
1 1
Note: n<12
Limited data set
1 1
Note: n<12
3,490.1
Default C.V.
3,490.1
Default C.V.
Acute: NO WQS
__ _ _________________________________________
Chronic: 8,771.9
No value >>All_owa_ble Cw _______________________________
Chronic_9,090.9
No value > Allowable Cw
no limit
Cadmium
NC
2
FW(7Q10s)
15
ug/L
1 1
Note: n<12
Limited data set
1,745.0
Default C.V.
Acute: 2,142.9
__ _ _______ _ __-------------
Chronic: 350.9
No value > Allowable Cw
add limit
_^_______________
Chlorides(AL)
NC
230,000
FW(7Q10s)
ug/L
1 1
Note: n<12
Limited data set
286,186,560
Default C.V.
Acute: NO WQS
_________—__________________---
Chronic: 40,350,877
No value > Allowable Cw
no limit
Chromium
NC
50
FW(7Q10s)
1022
ug/L
1 1
Note: n<12
Limited data set
17,450.4
Default C.V.
Acute: 146,000.0
__ _ ___________----
Chronic: 8,771.9
No value > Allowable Cw
add limit
______
------ ______________
Copper(AL)
NC
7
FW(7Q10s)
7
ug/L
1 1
Note: n<12
Limited data set
1,745
Default C.V.
Acute: 1,042.9
__ _ _______ _________________________________
Chronic: 1,228.1
No value > Allowable Cw
no limit
Fluoride
NC
1800
FW(7Q1Os)
ug/L
I 1
Note: n<12
Limited data set
349,008.0
Default C.V.
Acute: NO WQS
_______________--_—________--____—
Chronic: 315,789.5
No value > Allowable Cw
add limit
Lead
NC
25
FW(7Q10s)
33.8
ug/L
1 1
Note: n<12
Limited data set
8,725.2
Default C.V.
Acute: 4,828.6
__ _ _______ ___—_____________________________
Chronic: 4,386.0
No value > Allowable Cw
add limit
Nickel
NC
88
FW(7Q10s)
261
ug/L
1 1
Note: n<12
Limited data set
8,725.2
Default C.V.
Acute: 37,285.7
__ _ _______ _________________________________
Chronic: 15,438.6
No value > Allowable Cw
no limit
Zinc (AL)
NC
50
FW(7Q10s)
67
ug/L
1 1
Note: n<12
Limited data set
17,450.4
Default C.V.
Acute: 9,571.4
__ _______ _________________________________
Chronic: 8,771.9
No value > Allowable Cw
no limit
Page 1 of 2
89109 - RPA-2011.xIsm, rpa
8/12/2011

Horsehead Corporation
REASONABLE POTENTIAL ANALYSIS
Outfall 001
Ow = 0.62 MGD
Cobalt
NC
270 HH(7Q10s)
ug/L
1 1
Note: n<12
Limited data set
1,745.04000
Default C.V.
Acute: NO WQS
__ _ __—__ _ _ _ __—_—_—_—_—_—___—_—_—_—_---_—_
Chronic: 47368.42105
No value > Allowable Cw
no limit
Aluminum
NC
87 FW(7Q10s)
ug/L
1 1
Note: n<12
Limited data set
34,900.80000
Default C.V.
Acute: NO WQS
__ _ __-__ _ _ _
Chronic: 15263.15789
No value > Allowable Cw
no limit
_-_-_-_-_-_-_-_____-_-_-_-_—_
Antimony
NC
640 HH(7Q10s)
ug/L
1 1
Note: n<12
Limited data set
3,490.08000
Default C.V.
Acute: NO WQS
__________________—______-_____—_____—.—
Chronic: 112280.70175
No value > Allowable Cw
no limit
Tin
NC
800 HH(7Q10s)
ug/L
1 1
Note: n<12
Limited data set
34,900.80000
Default C.V.
Acute: NO WQS
_- _ __—__ _ _ _ __—_—_—_—_—_—_—_—_—_—_—_---_—_
Chronic: 140350.87719
No value > Allowable Cw
no limit
89109 - RPA-2011.xism, rpa
Page 2 of 2 8/12/2011

REASONABLE POTENTIAL ANALYSIS
Arsenic - FW Standard
Date Data BDL=1/2DL Results
1 264 264 Std Dev.
2 Mean
3 C.V. (default)
4 n
5
6 Mull Factor =
7 Max. Value
8 Max. Pred Cw
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
SPECIAL -
Values" WITH
"COPY"
Arsenic - HHIWS Standards
N/A
264.0000
0.6000
1
13.22
264.0 ug/L
3490.1 ug/L
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
1/0/1900
Date Data
0
264 264
BDL=I/2DL Results
Std Dev.
Mean
C.V. (default)
n
Mult Factor =
Max. Value
Max. Pred Cw
THIS SECTION
N/A
264.0000
0.6000
1
13.22
264.0 ug/L
3490.1 ug/L
-1-
89109 - RPA-2011.xlsm, data
8/10/2011

REASONABLE POTENTIAL ANALYSIS
Cadmium
Date Data BDL=1/2DL Results
1 132 132 Std Dev.
2 Mean
3 C.V. (default)
4 n
5
6 Mult Factor =
7 Max. Value
8 Max. Pred Cw
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
SPECIAL -
Values" WITH
"COPY"
N/A
132.0000
0.6000
1
13.22
132.0 uglL
1745.0 ug/L
Chlorides (AL)
Date Data BDL=1/2DL Results
1 21648000 21648000 Std Dev. N/A
2 Mean 21,648,000.0
3 C.V. (default) 0.6000
4 n 1
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
Values" WI
"COPY"
A
•
Mult Factor = 13.2
Max. Value 21648000.0
Max. Pred Cw 286,186,560.0
-4-
89109 - RPA-2011.xlsm, data
8/10/2011

REASONABLE POTENTIAL ANALYSIS
Chromium
Date Data BDL=1l2DL Results
SPECIAL -
Values" WITH
"COPY" ...
1 1320 1320 Std Dev. N/A
2 Mean 1320.0000
3 C.V. (default) 0.6000
4 n 1
5
6 Mult Factor = 13.22
ug/L 7 Max. Value 1320.0 ug/L
ug/L 8 Max. Pred Cw 17450.4 ug/L
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
Copper (AL)
Date Data BDL=112DL Results
1 132 132 Std Dev. N/A
2 Mean 132.0000
3 C.V. (default) 0.6000
4 n 1
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
SPEC/A
Values"
Mult Factor = 13.22
Max. Value 132.0
Max. Pred Cw 1745.0
-7-
89109 - RPA-2011.xlsm, data
8/10/2011

REASONABLE POTENTIAL ANALYSIS
Fluoride
Date Data BDL=1/2DL Results
1 26400 26400 Std Dev. N/A
2 Mean 26400.0000
3 C.V. (default) 0.6000
4 n 1
5
6
SPECIAL -
Values" WITH
"COPY"
ug/L 7
ug/L 8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
Mull Factor =
Max. Value
Max. Pred Cw
13.22
26400.0 ug/L
349008.0 ug/L
Lead
Date Data BDL=1/2DL Results
1 660 660 Std Dev.
2 Mean
3 C.V. (default)
4 n
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
Mull Factor =
Max. Value
Max. Pred Cw
SPECIA
Values"
"COP
N/A
660.0000
0.6000
1
13.22
660.0
8725.2
-10-
89109 - RPA-2011.xlsm, data
8/10/2011

REASONABLE POTENTIAL ANALYSIS
ug/L
ug/L
Nickel
Date Data BDL=1/2DL Results
1 660 660 Std Dev. N/A
2 Mean 660.0000
3 C.V. (default) 0.6000
4 n 1
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
SPECIAL -
Values" WITH
"COPY"
Mutt Factor =
Max. Value
Max. Pred Cw
13.22
660.0 ug/L
8725.2 ug/L
Zinc (AL)
Date Data BDL=1/2DL Results
1 1320 1320 Std Dev. N/A
2 Mean 1320.0000
3 C.V. (default) 0.6000
4 n 1
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
Mutt Factor =
Max. Value
Max. Pred Cw
SPECIA
Values"
"COP
13.22
1320.0
17450.4
-13-
89109 - RPA-2011.xlsm. data
8/10/2011

REASONABLE POTENTIAL ANALYSIS
�I
Cobalt
Date Data BDL=1/2DL Results
1 132 132 Std Dev.
2 Mean
3 C.V. (default)
4 n
5
6
ug/L 7
ug/L 8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
SPECIAL
Values" WITH
"COPY"
Aluminum
N/A
132.0000
0.6000
1
MuIt Factor = 13.22
Max. Value 132.000000 ug/L
Max. Pred Cw ug/L
Date Data BDL=1/2DL Results
1 2640 2640 Std Dev.
2 Mean
3 C.V. (default)
4 n
5
6 Mult Factor =
7 Max. Value
8 Max. Pred Cw
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
89109 - RPA-2011.xlsm. data
- 16 - 8/10/2011

REASONABLE POTENTIAL ANALYSIS
- ' a ues
WITH "COPY"
COMMAND
N/A
2640.0000
0.6000
1
13.22
2640.000000 ug/L
34900.800000 ug/L
Antimony
Date Data BDL=1/2DL Results
1 264 264 Std Dev.
2 Mean
3 C.V. (default)
4 n
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
SPECIAL -
Values" WITH
"COPY"
N/A
264.0000
0.6000
1
Mutt Factor = 13.22
Max. Value 264.000000 ug/L
Max. Pred Cw ug/L
Tin
Date Data BDL=1/2DL
1 2640 2640
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
89109 - RPA-2011.xtsm, data
- 19 - 8/10/2011

TO: Complex Permitting Unit .
ATTENTION: Sergei Chernikov, Ph.D
DATE: August 9, 2011
NPDES STAFF REPORT AND RECOMMENDATION
RUTHERFORD COUNTY
PERMIT NUMBER NC0089109
PART I - GENERAL INFORMATION
1. Facility and Address:
2. Date of Investigation:
Hicks Grove Road
Forest City
Rutherford County, NC 28043
Mailing: Horsehead Holding Corporation
4955 Steubenville Pike, Suite 405
Pittsburgh, Pennsylvania 15205
August 27, 2011
3. Report Prepared By: Don Price, CET
4. Persons Contacted and Telephone Number Forrest Westall, P.E. 828-252-0575
5. Directions to Site: Hwy 221 S. to Hicks Grove Road on right, site is 0.55 miles on right.
6. Discharge Point(s), List for all discharge points:
Latitude: N 35° 12' 1.00" Longitude: W 81° 51' 10.00"
Attach a USGS map extract and indicate treatment facility site and discharge point on map.
U.S.G.S. Quad No. U.S.G.S. Quad Name 'Chesnee'
8. Topography (relationship to flood plain included): gentle slope toward Broad River, production mfg.
Site mostly flat with sight slope.
9. Location of nearest dwelling: 0.5 mile-
10. Receiving stream or affected surface waters: Broad River
a. Classification: C
b. River Basin and Subbasin No.: Broad
c. Describe receiving stream features and pertinent downstream uses: Secondary recreation
and fishing.
PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
1. Volume of wastewater to be permitted 620,000 gpd
2. What is the current permitted capacity of the Wastewater Treatment facility? N/A
3. Actual treatment capacity of the current facility N/A
4. Date(s) and construction activities allowed by previous A to C issued in the previous two
years: N/A
5. Please provide a description of existing or substantially constructed wastewater treatment
facilities: NONE
6. Please provide a description of proposed wastewater treatment facilities: The effluent from
the mfg. Process wastewater can be characterized as a clear brine solution. (see Part IV —
Evaluation and Recommendations).
7. Possible toxic impacts to surface waters: NONE
-1-

PART III - OTHER PERTINENT INFORMATION
1. Is this facility being constructed with Construction Grant Funds or are any public monies involved.
(municipals only)? N/A
2. Special monitoring or limitations (including toxicity) requests: None
3. Alternative Analysis Evaluation: Has the facility evaluated all of the non -discharge options available.
Please provide regional perspective for each option evaluated.
Spray Irrigation: Adjacent land is apparently not available
Connection to Regional Sewer System: Not possible
Subsurface: Soil not suitable
Other disposal options: According to soil study and engineering study the only reasonable alternative
is. direct discharge.
PART IV - EVALUATION AND RECOMMENDATIONS
This is a 'new process' technology involving the reclamation and recycling of zinc from the proposed facility.
The described process provides for a high degree of metals removal from the wastewater stream, resulting
in a discharge with low levels of contamination as compared to more traditional production facilities.
Because of the extensive efforts to remove all metals from the process flow stream, the process itself
provides a high degree of treatment. The ARO concurs with the Central Office finding that there is no other
viable option for Wastewater treatment at this time other than direct discharge. ARO recommends that the
facility employ 'post flow equalization' prior to discharge. Post flow equalization will help insure consistent in
stream concentration discharges below the discharge. The ARO has reviewed the company's request for
flexibility in setting effluent limitations for flow and other effluent characteristics. Based upon the prediction
calculations made the ARO agrees that this is a reasonable request. Dependent upon how Wastewater will
be discharged from the facility there could be peak flow levels could result in elevated pollutant levels
beyond those anticipated. Providing that the owner has met all submittal requirements with the application
and is able to meet any requirements of the Central Office, the regional office recommends the issuance of
the permit.
Signature of Report Preparer
/t' �zm
iriff4_
Water'Quality Regional Supervisor
Da
-2-

bENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
July 22, 2011
Mr. Darin Cooper
Project Manager
Horsehead Corporation
4955 Steubenville Pike, Suite 405
Pittsburgh, PA 15205
Subject: Engineering Alternative Analysis (EAA)
Permit NC0089109
Horsehead Corporation Rutherford County
Production Facility
:Rutherford County
Dear Mr. Cooper:
The Division of Water Quality (Division) has reviewed your Engineering Alternative Analysis (EAA) for the Horsehead
Corporation Rutherford County Production Facility. The Division concurs with the conclusions and recommendations of the
EAA. The EAA you have submitted is sufficient to meet the Alternative Analysis requirements for a new discharge.
The Division will now proceed to the permitting of the discharge. After the effluent limits are calculated, the new draft permit
will be publicly noticed in a regional newspaper. The entire permitting process may take between 60 and 120 days. If the draft
permit causes significant protests from local citizens, governmental organizations, and/or environmental groups a public
hearing may be scheduled and issuance of the final permit may be further delayed. In some cases the Division may modify or
deny the request for a new permit based on the public hearing results.
If you have any questions about the NPDES permit process, contact me at the following e-mail address -
§ergei.chernikov@ncdcnrgov, or telephone number 919-807-6393.
Sincerely,
Sergei Chernikov, Ph.D. •
Environmental Engineer II
• . Complex NPDES Permitting Unit .
cc: NPDES File
Asheville Regional Office/Surface Water Protection (via e-mail)
David Honeycutt, McGill Engineers([e-mail])
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury SL Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] Customer Service:1.877-623-6748
Internet www.ncwaterquallty.org
An Equal Opportunity 1 Affirmative Action Employer
O"eNorthCarohna
7V'aturaI4i

Chernikov, Sergei
From: Schimizzi, Nikki
Sent: Monday, July 25, 2011 10:29 AM
To: Brower, Connie; Chernikov, Sergei
Subject: RE: question
Morning Sergei,
We have internally calculated a water quality standard for tin. The standards are as follows:
Human health: 800 ug/L
Water Supply: 770 ug/L
Aquatic life: No data
Nikki
Please note new e-mail address: nikki.schimizzi(a).ncdenr.gov
Nikki Schimizzi
Environmental Senior Specialist
NC Department of Environment and Natural Resources
Division of Water Quality -Classification and Standards Unit
1617 Mail Service Center
Raleigh NC 27699
[phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
From: Brower, Connie
Sent: Monday, July 25, 2011 10:07 AM
To: Schimizzi, Nikki
Cc: Chernikov, Sergei
Subject: FW: question
Sergei — Nikki is going to check on the numbers for us to see if we have any updated information —she will get back with
you shortly —
Thanks —Nikki!
Connie
From: Chernikov, Sergei
Sent: Monday, July 25, 2011 9:20 AM
To: Brower, Connie
Subject: question
Connie,
Is there an EPA or NC standard for Tin?
Thank you!

Sergei
Sergei Chernikov, Ph.D.
Environmental Engineer II
Complex Permitting Unit
Phone: [phone], fax [phone]
1617 Mail Service Center
Raleigh, NC 27699-1617
Express mail: 512 North Salisbury St.
Raleigh, NC 27606
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
2

AFFIDAVIT OF PUBLICATION
STATE OF NORTH CAROLINA
RUTHERFORD COUNTY
Before the undersigned, a Notary Public of said County and State, duly
commissioned, qualified, and authorized by law to administer oaths, personally
appeared
Pam Curry
who being first duly sworn, deposes and says: that they are
Receptionist
(Owner, partner, publisher, or other officer or employee authorized to make this
affidavit) of THE DAILY COURIER, a newspaper published, issued and entered as
second class mail In the town of FOREST CITY, In said County and State; that they
are authorized to make this affidavit and sworn statement; that the notice or other
legal advertisement, a true copy of which is attached hereto, was published in THE
DAILY COURIER on the following date:
September 17, 2011
and that said newspaper in which such notice, paper, document, or legal
advertisement was published was, at the time of each and every such publication, a
newspaper meeting all of the requirements and qualifications of Section 1-597 of the
General Statutes of North Carolina and was a qualified newspaper within the meaning
of Section 1-597 of the General Statutes of North Carolina.
This the 19th day of September, 2011
) QZ4V eakl
Pam Curry, ReceptioUtst
Sworn to and subscribed before me this the 19th day of September, 2011
Cindy B. Whit;, 1 otary Public)
My commission expires: February 18, 2012.

PUBLIC NOTICE
North Carolina Environmental Management
Commission/NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Notice of Intent to Issue a NPDES Wastewater Permit
The North Carolina Environmental Management Commission
proposes to issue a NPDES wastewater discharge permit to
the person(s) listed below.
Written comments regarding the proposed permit will be
accepted until 30 days after the publish date of this notice.
The Director of the NC Division of Water Quality (DWQ) may
hold a public hearing should there be a significant degree of
public interest. Please mail comments and/or information
requests to DWQ at the above address. Interested persons
may visit the DWQ at 512 N. Salisbury Street, Raleigh, NC to
review information on file. Additional information on NPDES
permits and this .notice may be found on our website:
http://portal.ncdenr.org/web/wq/swp/ps/npdes/calendar, or by
calling [phone].
The Horsehead Corporation requested a new permit
NC0089109 for Rutherford County Production Facility in
Rutherford County; this facility discharge is treated industrial
wastewater to Broad River, Broad River Basin.

Chernikov, Sergei
From: David Honeycutt [[e-mail]]
Sent: Wednesday, August 10, 2011 10:42 AM
To: Chernikov, Sergei
Cc: [e-mail]
Subject: FW: Low -flow characteristics for Broad River near Harris (USGS Sta. 02150196)...RE: Initial
USGS response concerning...Re: FW: Broad River flows
Sergei,
See below information from USGS on low flow for the Broad River. Curtis Weaver with USGS has revised his previous
estimate for 7Q10 based on this review and provided a range in the estimates for all parameters. Although this estimate
shows a reduced low flow, the proposed effluent remains a very small percentage of the river flow. Please let me know
if you have any questions or need additional information based on these revisions. Thanks,
David L. Honeycutt, PE
Project Engineer
McGill Associates, P.A.
55 Broad Street I Asheville, NC 28801
Phone: [phone] I Fax: [phone]
Email: [e-mail] I Website: www.mcgillassociates.com
From: John C Weaver [mailto:[e-mail]]
Sent: Tuesday, August 09, 2011 5:38 PM
To: [e-mail]
Cc: [e-mail]; Curtis Weaver; Jeanne C Robbins; Rose D Pinnix; James C Finnerty
Subject: Low -flow characteristics for Broad River near Harris (USGS Sta. 02150196)...RE: Initial USGS response
concerning...Re: FW: Broad River flows
USGS
science for a changing world
U.S. Geological Survey North Carolina Water Science Center
3916 Sunset Ridge Road
Raleigh, North Carolina 27607
Date: August 09, 2011
To: Mr. David L. Honeycutt, PE, Project Engineer
McGill Associates, P.A.
55 Broad Street
Asheville, NC 28801
Mr. Honeycutt,
i

In response to your inquiry about the low -flow characteristics for the Broad River near Harris (station id 02150196,
drainage area 575 sqmi) in southern Rutherford County, the following information is provided:
A check of the low -flow and request files here at the USGS North Carolina Water Science Center indicates a number of
instances where preliminary estimates of 7Q10 discharge have been determined for the reach of Broad River very near
your point of interest. No USGS discharge records are known to exist for your point of interest on the Broad River
upstream from its confluence with Floyds Creek. In the most recent instances (2000, 2002, 2003), preliminary 7Q10 low -
flow yields were estimated to be in the range of 0.35 to 0.45 cfsm. However, the data has suggested that yield values
could most likely be closer to 0.35 cfsm.
Where no or insufficient data is available for a low -flow analysis, a determination of low -flow characteristics is based on
assessment of low -flow yields at nearby locations where such statistics have previously been determined. The low -flow
characteristics that are provided have been computed by correlating the runoff characteristics of nearby streams in vicinity
of the request site.
Previously published low -flow information for streams in your area of interest...
For streams in Rutherford County, the most recently published low -flow information is a statewide report completed in the
early 1990's. It is USGS Water -Supply Paper 2403, 'Low -flow characteristics of streams in North Carolina" (Giese and
Mason, 1993). An online version of the report is available through http://pubs.er.usas.gov/usgsoubs/wso/wsp2403. The
report provides the low -flow characteristics (based on data through 1988) via regional relations and at -site values for sites
with drainage basins between 1 and 400 sqmi and not considered or known to be affected by regulation and/or diversions.
If you access the report, please note the online report files are provided in the ".DJVU" format and require a particular
Lizardtech plug-in, also available through a link displayed on the page. Or you can click an adjacent link that will allow
you to view the report as a group of images without the need for a plug-in.
Considering the above information, please be aware of the following: The data provided in the above -referenced report
are based on periods of record ending in advance of the drought conditions that have occurred since publication of the
report. In some North Carolina basins, the low -flow conditions observed during the recent droughts (1998-2002, 2007-10)
have resulted in lower low -flow statistics. No formal statewide investigation has been completed to document the
changes in low -flow statistics since the droughts. However, where updated analyses have been completed for selected
stations, the changes in pre -drought versus updated 7Q10 discharges have shown varying percentage changes of
decline.
For instance, at the nearby long-term gaging station on Cove Creek near Lake Lure (station id 02149000, drainage area
79 sqmi, continuous records October 1950), the 7Q10 declined about 26 percent between the 1998 and 2010 climatic
years. Based on analysis of available period of record through the 2010 climatic year, the 7Q10 and 30Q2 low -flow
estimates have yield values of about 0.31 cfsm and 0.76 cfsm, respectively.
Note: The climatic year is the standard annual period used for low -flow analyses at continuous -record gaging stations. It
runs from April 1 through March 31 and is designated by the year in which the period begins. For example, the 2010
climatic year is from April 1, 2010, through March 31, 2011.
Sta. 02150196 Broad River near Harris, NC (drainage area 575 sqmi, at railroad crossing upstream from
confluence with Floyds Creek)
Updated provisional low -flow statistics at three nearby active streamgaging stations with long-term record were used to
determine the low -flow characteristics at your point of interest:
Cove Creek near Lake Lure (station id 02149000, drainage area 79 sqmi, period of record since October 1950, flows
unregulated)
Broad River near Boiling Springs (station id 02151500, drainage area 875 sqmi, period of record since June 1925, flows
regulated)
First Broad River near Casar (station id 02152100, drainage area 60.5 sqmi, period of record since March 1959, flow
unregulated)
Based on provisional updated low -flow analyses completed at the above three gaging stations, the respective low -flow
2

yields are as follows:
7Q10 low -flow yields estimated at 0.31, 0.33, and 0.24 cfsm (use average at 0.29 cfsm)
30Q2 low -flow yields estimated at 0.76, 0.76, and 0.59 cfsm (use average at 0.70 cfsm)
W7Q10 low -flow yields estimated at 0.50, 0.87, and 0.36 cfsm (use average at 0.58 cfsm)
7Q2 low -flow yields estimated at 0.67, 0.66, and 0.52 cfsm (use average at 0.62 cfsm)
Average annual discharge or mean annual runoff (MAR) estimated at 1.66, 1.66, and 1.44
cfsm)
Applying the above low -flow and mean annual runoff yields (in item #1) to a drainage area
following flow estimates:
w-flow estimated range is from 138 to 190 cfs (with an average o
ow -flow estimated range is from 339 to 437 cfs (with an average o
ow -flow estimated range is from 207 to 500 cfs (with an average of
7Q2 low -flow estimated range is from 300 to 385 cfs (with an average of 357 c s
cfsm (use average at 1.59
of 575 sqmi results in the
Average annual discharge or mean annual runoff estimated range is from 828 to 955 cfs (with an average o
Please be aware that a degree of uncertainty exists in the above low -flow estimates for this location because both
regulated and unregulated flows were used in the analyses. Streamflow data is limited in the Broad River basin, and the
Broad River itself is known or considered to be regulated by several impoundments and power plants located on the
Broad River and Green River (tributary to the Broad). There is only one active gaging station on the Broad River, located
downstream from your point of interest. As you make use of these low -flow estimates, please be aware of the issues
concerning the available data. Pending future data collection which could help further clarify the ranges in estimated
flows, the above estimates are deemed reasonable given the currently available data for this area of North Carolina.
Invoice information...
A charge of $250.00 for accessing and processing information has been assessed to partially offset these costs. An
invoice covering the processing costs for these data will be sent via regular mail from the U.S. Geological Survey to the
billing address shown below. Instructions for sending your payment will be shown on the invoice.
Mr. David L. Honeycutt, PE, Project Engineer
McGill Associates, P.A.
55 Broad Street
Asheville, NC 28801
This information is considered preliminary and subject to revision pending further analysis as further data were to become
available, and is made available through our cooperative program of water -resources investigations with the North
Carolina Department of Environment and Natural Resources.
Hope this information is helpful. If you have any questions regarding this information, please contact me at the phone
number or email address listed below.
Thank you.
Curtis Weaver
*************************************************************
J. Curtis Weaver, Hydrologist, PE
USGS North Carolina Water Science Center
3916 Sunset Ridge Road
Raleigh, NC 27607
Phone: [phone] // Fax: [phone]
Mobile: [phone]
E-mail address -- [e-mail]
3

Internet address -- htto://nc.water.usgs.gov/
*************************************************************
From: "David Honeycutt" <[e-mail]>
To: "'John C Weaver"' <[e-mail]>, <forrest [e-mail]>
Date: 07/29/2011 01:49 PM
Subject: RE: Initial USGS response conceming...Re: FW: Broad River flows
Curtis,
Per my phone call see below the correspondence we referred to below this email. The location we are interested in 30Q2 and
average flow at is the railroad bridge upstream of Floyds Creek Station ID 02150196.
David L. Honeycutt, PE
Project Engineer
McGill Associates, P.A.
55 Broad Street I Asheville, NC 28801
Phone: [phone] I Fax: [phone]
Email: [e-mail] I Website: www.mcgillassociates.com
From: John C Weaver [mailto:[e-mail]
Sent: Tuesday, August 29, 2006 2:20 PM
To: Mike Dowd
Cc: 'clement riddle'; keithwOmcgillengineers.com; 'Scott Hoyle'; John C Weaver
Subject: Low -flow characteristics for Broad River near Forest City (Rutherford County)...Re: Request for 7Q10 - Forest
City Intake Site
Mike,
In response to your inquiry about the 7Q10 discharge for a location on the Broad River in southern Rutherford County, the
following information is provided:
A check of the low -flow files here in the USGS North Carolina Water Science Center office does not reveal any previous
determinations of low -flow characteristics for your specific point of interest, and there are no known USGS records of
discharge for this location.
As I mentioned during our phone conversation the other day, this reach of the Broad River has been the subject of several
low -flow requests during the past few years. I am providing excerpts (shown in blue font) of the most recent response
made on October 23, 2005, to an engineering firm in Charlotte. This response was for a location downstream of Floyds
Creek, fairly close to your location.
While records of discharge have been collected in the past on both streams, the flows are known to have been affected by
regulation from upstream lakes used for power production. The occurrence of regulation in a stream always seems to
create some degree of uncertainty about what the appropriate 7Q10 discharge for these kinds of reaches.
Broad River at U.S. 221 (just downstream of confluence with Floyds Creek) - The drainage area at the bridge is estimated
to be 602 sqmi. Based on an assessment of low -flow characteristics at nearby locations, an appropriate 7Q10 low -flow
yield for this reach of the river appears to be about 0.35 cfs per sqmi. Applying this yield to the drainage area results in a
7Q10 flow estimate of approximately 210 cfs. The 7Q10 yield is considered to be reflective of "natural -flow" conditions.
Flows in the Broad River may be subject to regulation from Lake Lure, based on records of discharge that were collected
4

at a discontinued gaging station operated just downstream of Lake Lure during 1927-58 (Sta. 02148500, drainage area
97.0 sqmi). However, no information is known about the current regulation patterns, if any, caused by the lake. In
addition, given the difference between drainage areas from Lake Lure to the Hwy 221 bridge, the effects of any existing
regulation may not be significant.
The closest site to your point of interest where I have a drainage area value is at the railroad bridge (station id 021501.96,
drainage area 575 sqmi) approximately 0.5 mile upstream from mouth of Floyds Creek. Visual examination of the
topographical map suggests that a drainage area for your location will be in the range of 570 to 575 sqmi. Thus applying
the above -mentioned 7Q10 low -flow yield of 0.35 cfs per sqmi results in a 7Q10 discharge estimate of about 200 cfs,
again reflective of what is considered "natural -flow" conditions.
Hope this information is helpful.
Thank you.
Curtis Weaver
J. Curtis Weaver, Hydrologist, PE
USGS North Carolina Water Science Center
3916 Sunset Ridge Road
Raleigh, NC 27607
Telephone: [phone] // Fax: [phone]
E-mail address -- jcweaverausas.aov
Internet address — http:llnc.water.usgs.aov/
***********************************************************************
5

4955 STEUBENVILLE PIKE
SUITE 405
PITTSBURGH, PA 15205
July 8, 2011
W W W.HORSEHEAD.N ET
Dr. Sergei Chernikov, Ph.D.
North Carolina Department of Environment
& Natural Resources
Division of Water Quality
512 North Salisbury Street
9th Floor - Archdale Building
Raleigh, North Carolina 27604
Dear Dr. Chernikov:
HORSE':H:EAD
Leading She World in Zinc Recycling
Re: NPDES Permit Application
Horsehead Holding Corporation
Rutherford County, North Carolina
Please find enclosed three (3) copies of an Application for an NPDES Permit for
an industrial discharge to the Broad River south of Forest City, North Carolina. Also
enclosed are three (3) copies of the Engineering Alternatives Analysis, and a check for
the application fee of $860.00. Please note that all application information should be
considered Business Confidential. The flow and projected effluent values are based on
projections from engineering documents from the process design firm developing the
facility plans. There is no operational data available as no similar facilities exist. The
application provides a summary of expected effluent quality and a review of the
assimilative capacity of the receiving stream. Requested limits are based on the fact that
the projected effluent is based on a mass balance calculation and not on actual effluent
measurements. Due to the potential variability in the effluent, the Company is
requesting a wasteload allocation based on a limited portion of the Broad River's ability
to accept the discharge. Effluent guidelines for this type facility do not exist and based
on the characteristics of the receiving stream, the discharge of this wastewater at the
requested limits will provide protection of the River.
JUL 12 2011
CEN1Wri7R QUAI_t7Y
PUNT SOURCE BRANCH

Dr. Sergei Chernikov
July 8, 2011
Page 2
Thanks for your assistance on this important project. If you have any questions
please don't hesitate to contact me or our engineer David Honeycutt at 828-252-0575 or
email at [e-mail].
Sincerely,
Darin Cooper
Project Manager
HORSEHEAD CORPORATION
Encl .
cc: Tim Basilone, Horsehead Corporation
Tom Belnick, Division of Water Quality
David Honeycutt, PE, McGill Associates, P.A.
Forrest Westall, PE, McGill Associates, P.A.

Horsehead Corporation EAA (NC0089109)
Rutherford County
Purpose: New facility that recycles Zn using proprietary ligand based process.
Proposed Discharge: 0.62 MGD (industrial wastewater only, potable and domestic water will be
provided by Forrest City)
Proposed Receiving Stream: Broad River, Class C. 7Q10s=130 MGD
IWC=0.5 %
Significant issue - high concentration of chloride (' 19,680 mg/L).
State Action Level Standard for Chlorides — 230 mg/L.
Alternatives:
1) Construction of the new treatment facility - the lowest cost.'" $448,500.
2) Reuse. This option is not viable due to the high chloride concentrations.
3) Connection to the existing Forrest City WWTP, 10 miles away. High chloride concentration
would cause inhibition of the activated sludge. To prevent inhibition, concentration of the
chlorides has to be reduced by 97% to 425 mg/L. It would require RO, and the cost of the
pretreatment would be extremely high. —$15,600,000
4) Land application. Pretreatment with RO would be required to prevent injury to the crops and
soil damage, the cost is extremely high. The new storage lagoon and additional land acquisition
would be needed. ^' $20,300,000.

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Chernikov, Sergei
From: Belnick, Tom
Sent: Monday, April 04, 2011 4:53 PM
To: Chernikov, Sergei
Subject: FW: Project Chrysalis Wastewater NPDES Discharge
Sergei- fyi... my initial discussion with the zinc recycler.
Tom Belnick
Supervisor, Complex NPDES Permitting Unit
NC DENR/Division of Water Quality
1617 Mail Service Center, Raleigh, NC 27699-1617
[phone]; fax [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
From: Belnick, Tom
Sent: Thursday, February 03, 2011 12:35 PM
To: 'Belczyk Joshua'
Cc: Matthews, Matt; Poupart, Jeff; Edwards, Roger; Gore, Deborah
Subject: RE: Project Chrysalis Wastewater NPDES Discharge
Josh- I'll try to fill in some of the blanks regarding this proposed discharge.
1. The NC water quality standard for chlorides = 250 mg/I applies to Water Supply (WS) class waters only, for
protection of human health from ingesting surface water.
2. The NC Action Level for chlorides= 230 mg/I applies to all freshwaters for protection of aquatic life. We can set a
permit limit based on this action level.
3. The water quality standard for Total Dissolved Solids (TDS) = 500 mg/I applies to Water Supply (WS) class waters
only.
4. Based on your projected effluent concentration for chlorides =13,000 mg/I, you would require a receiving
waterbody with sufficient dilution to comply with the instream chloride action level of 230 mg/I (i.e.,
13,000/230= 56.5 dilution factor as a minimum).
5. First Location (near Riverside Industrial Park, NC0087084). At this location, the proposed direct discharge would
be to the Broad River in the Broad River Basin, Class C, with a summer 7Q10 streamflow = 195 cfs. Assuming a
direct discharge of 0.45 MGD, the Dilution Factor (DF) = 280. A permit would include a chronic toxicity test at
0.36% effluent concentration.
6. Second Location (former Alcoa Badin Works, NC0004308). At this location, the proposed direct discharge would
be to Badin Lake (Yadkin River) in the Yadkin River Basin, Class WS. There is no s7Q10 streamflow established
for a lake system. However, Alcoa has an existing outfall to the lake with a single port diffuser (Outfall 012),
which provides a dilution factor of 25:1 A permit would include a chronic toxicity test at 4% effluent
concentration.
7. Third Location (Shelby POTW, NC0024538). This proposal would be for an indirect discharge to the Shelby
POTW. The town is currently permitted for a 6 MGD discharge to First Broad River in the Broad River Basin,
Class C, with a summer 7Q10 streamflow = 44.3 cfs. At the town's full permitted flow of 6 MGD, the Dilution
Factor = 5.7. Thus, Shelby could discharge chlorides at 1326 mg/I and comply with the instream action level of
230 mg/I. You would need to figure out your dilution within the plant, combined with the 5.7 dilution factor
provided by the instream dilution, to determine if this is viable. Chloride concentrations for untreated
wastewater typically range from 30 to 100 mg/I, with 50 mg/I as a medium strength value. Shelby is already
subject to a chronic toxicity test.
1

8. You might also be subject to Federal Effluent Guidelines, which typically set permit limits based on production.
These could be more stringent than the water quality -based limits discussed above.
9. As a reminder, these are speculative calculations at this time. I have not checked our 303(d) list of impaired
waters, to see if any of these receiving waterbodies are currently impaired. If you need more in-depth
consideration for one of these locations, let me know.
10. As I mentioned yesterday, all new direct dischargers must complete an Engineering Alternatives Analysis (EAA)
which justifies the requested flow rate and evaluates alternatives to a new direct discharge to surface waters.
Tom Belnick
Supervisor, Complex NPDES Permitting Unit
NC DENR/Division of Water Quality
1617 Mail Service Center, Raleigh, NC 27699-1617
[phone]; fax [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
From: Belczyk Joshua [mailto:[e-mail]]
Sent: Wednesday, February 02, 2011 11:03 PM
To: Belnick, Tom
Subject: Project Chrysalis Wastewater NPDES Discharge
Hello, Tom
Thanks again for taking the time to discuss our potential new facility. As we discussed, this innovative application of
electrolytic zinc smelting technology to our 100% recycled feedstock will be a much more efficient and environmentally
sustainable process. It will, however, generate a continuous and consistent wastewater discharge of —450,000 gpd at 13
g/L Chloride and 26.8 g/L TDS.
The sites under consideration for the project in the State of North Carolina include the former Alcoa facility in Badin,
Riverstone Industrial Park in Forest City, and another site in Shelby. The Badin and Forest City sites would likely
discharge wastewater directly to the Yadkin and Broad rivers, respectively. The Shelby site would discharge to the First
Broad River, via the Shelby wastewater treatment plant.
One point of clarification is the applicability of a TDS water quality standard for C-class waterways, such as the Broad and
First Broad.
Another point of clarification is the difference between State Water Quality Standards and "Action Levels" (e.g. the State
Water Quality Standard for Chloride is 250mg/L, whereas the "Action Level" is 230mg/L).
For determining "end -of -pipe" discharge concentration limits, essentially, the assimilative capacity of the receiving stream
is compared to the proposed discharge (i.e. background concentration and 7Q10 flow of receiving stream versus
concentration and volume of effluent).
In the examples mentioned, discharge permits for all locations should be feasible, barring unusual circumstances.
Please advise on the above items.
Thanks again for the time and cooperation.
Sincerely,
- Josh
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NPDES PERMIT RATING WORK SHEET
NPDES NO. /00U l 101
Facility Name: Horsehead Corporation Production Facility/RiverStone Industrial Park
City: Forest City, North Carolina
Receiving Water: Broad River
Reach Number:
Fl Regular Addition
n DiscretionaryAddition
Fl Score change, but no status change
❑ Deletion
Is this facility a steam electric power plant (SlC=4911) with one or more of the following Is this permit for a municipal separate storm sewer serving a
characteristics? population greater than 100,000?
1. Power output 500 MW or greater (not using a cooling pond/lake)
2. A nuclear power plant ❑ YES; score is 700 (stop here)
3. Cooling water discharge greater than 25% of the receiving stream's 7010 flow rate X NO (continue)
i YES; score is 600 (stop here) X NO (continue)
FACTOR 1: Toxic Pollutant Potential
PCS SIC Code: Primary SIC Code: 3341 Other SIC Codes:
Industrial Subcategory Code: 000 (Code 000 if no subcategory)
Determine the Toxicity potential from Appendix A. Be sure to use the TOTAL toxicity potential column and check one)
Toxicity Group
❑ No Process
Waste stream
❑ 1.
❑ 2.
Code Points
0 0
1 5
2 10
Toxicity Group
❑ 3.
El 4.
❑ 5.
❑ 6.
Code Points
3 15
4 20
5 25
6 30
Toxicity Group
❑ 7.
X 8.
1-1 9.
11 10.
Code Points
7 35
8 40
9 45
10 50
Code Number Checked:
Total Points Factor 1:
FACTOR 2: Flow/Stream Flow Volume (Complete either Section A or Section B; check only one)
Section A Wastewater Flow Only Considered
Wastewater Type
(See Instructions)
Type I: Flow < 5 MGD
Flow 5 to 10 MGD
Flow > 10 to 50 MGD
Flow > 50 MGD
Type II: Flow < 1 MGD
Flow 1 to 5 MGD
Flow > 5 to 10 MGD
Flow> 10 MGD
Type III: Flow < 1 MGD
Flow 1 to 5 MGD
Flow > 5 to 10 MGD
Flow> 10 MGD
Code Points
rI 11 0
❑ 12 10
❑ 13 20
❑ 14 30
❑ 21 10
❑ 22 20
❑ 23 30
❑ 24 50
❑ 31 0
❑ 32 10
El 33 20
❑ 34 30
Section B X Wastewater and Stream Flow Considered
Wastewater Type
(See Instructions)
Type I/III:
Type II:
Percent of instream
Wastewater Concentration
at Receiving Stream Low Flow
<10%
10%to<50%
>50%
<10%
10%to<50%
>50%
08
40
Code Points
[1 41 0
❑ 42 10
❑ 43 20
X 51 0
❑ 52 20
❑ 53 30
Code Checked from Section A or B: 51
Total Points Factor 2: 0

r•
FACTOR 3: Conventional Pollutants NPDES NO:
(only when limited by the permit)
A. Oxygen Demanding Pollutant: (check one) 0 BOD ❑ COD 0 Other: N/A. Not present in WW
Code Points
Permit Limits: (check one) X < 100 lbs/day 1 0
❑ 100 to 1000 lbs/day 2 5
O > 1000 to 3000 lbs/day 3 15
O > 3000 lbs/day 4 20
B. Total Suspended Solids (TSS) N/A
Code Points
Permit Limits: (check one) X < 100 lbs/day 1 0
O 100 to 1000 lbs/day 2 5
O > 1000 to 5000 lbs/day 3 15
O > 5000 lbs/day 4 20
Code Checked: 3
Points Scored: 0
Code Checked: 1
Points Scored: 5
C. Nitrogen Pollutant: (check one) 0 Ammonia 0 Other: N/A
Nitrogen Equivalent Code Points
Permit Limits: (check one) X < 300 lbs/day 1 0
O 300 to 1000 lbs/day 2 5
❑ > 1000 to 3000 lbs/day 3 15
O > 3000 lbs/day 4 20
Code Checked:
Points Scored: 0
Total Points Factor 3: 0
FACTOR 4: Public Health Impact
Is there a public drinking water supply located within 50 miles downstream of the effluent discharge (this includes any body of water to which
the receiving water is a tributary)? A public drinking water supply may include infiltration galleries, or other methods of conveyance that
ultimately get water from the above referenced supply.
X YES (If yes, check toxicity potential number below)
0 NO (If no, go to Factor 5)
Determine the human health toxicity potential from Appendix A. Use the same SIC code and subcategory reference as in Factor 1. (Be sure to
use the human health toxicity group column 0 check one below)
Toxicity Group Code Points Toxicity Group Code Points Toxicity Group Code Points
O No Process 0 3. 3 0 0 7. 7 15
Waste stream 0 0 0 4. 4 0 X 8. 8 20
O 1. 1 0 05. 5 5 09. 9 25
O 2. 2 0 06. 6 10 0 10. 10 30
Code Number Checked: 8
Total Points Factor 4: 20

FACTOR 5: Water Quality Factors NPDES NO.
A. Is (or will) one or more of the effluent discharge limits based on water quality factors of the receiving stream (rather than technology -based
federal effluent guidelines, or technology -based state effluent guidelines), or has a wasteload allocation been assigned to the discharge:
Code
X Yes 1
❑ No 2
Points
10
0
B. Is the receiving water in compliance with applicable water quality standards for pollutants that are water quality limited in the permit?
Code
X Yes 1
❑ No 2
Points
0
5
C. Does the effluent discharged from this facility exhibit the reasonable potential to violate water quality standards due to whole effluent
toxicity?
Code
❑ Yes 1
X No 2
Points
10
0
Code Number Checked: A 1 B 1 C 2
Points Factor 5: A 10 + B 0 + C 0
= 10 TOTAL
FACTOR 6: Proximity to Near Coastal Waters
A. Base Score: Enter flow code here (from Factor 2): 51
Check appropriate facility HPRI Code (from PCS):
HPRI# Code HPRI Score
O 1 1 20
❑ 2 2 0
O 3 3 30
❑ 4 4 0
O 5 5 20
HPRI code checked:
Enter the multiplication factor that corresponds
to the flow code: 0.01
Flow Code
11, 31, or 41
12, 32, or 42
13, 33, or 43
14 or 34
21 or 51
22 or 52
23 or 53
24
Base Score: (HPRI Score) X (Multiplication Factor) = (TOTAL POINTS)
B. Additional Points 0 NEP Program
For a facility that has an HPRI code of 3,
does the facility discharge to one of the
estuaries enrolled in the National Estuary
Protection (NEP) program (see
instructions) or the Chesapeake Bay?
O Yes
O No
Code Points
1 10
2 0
Code Number Checked: A B C NA
Points Factor 6: A + B + C = TOTAL
Multiplication Factor
0.00
0.05
0.10
0.15
0.10
0.30
0.60
1.00
C. Additional Points 0 Great Lakes Area of Concern
For a facility that has an HPRI code of 5, does the
facility discharge any of the pollutants of concern into
one of the Great Lakes' 31 areas of concern (see
instructions)
Code Points
❑ Yes 1 10
D No 2 0

SCORE SUMMARY = NPDES NO.
Factor Description Total Points
1 Toxic Pollutant Potential 40
2 Flows/Streamflow Volume 0
3 Conventional Pollutants 0
4 Public Health Impacts 20
5 Water Quality Factors 10
6 Proximity to Near Coastal Waters 0
TOTAL (Factors 1 through 6) 70
S1. Is the total score equal to or greater than 80? ❑ Yes (Facility is a major) X No
S2. If the answer to the above questions is no, would you like this facility to be discretionary major?
0 No
0 Yes (Add 500 points to the above score and provide reason below:
Reason:
NEW SCORE:
OLD SCORE:
Permit Reviewer's Name
Phone Number
Date

III.Alternatives Analysis
AI(th9 6q/;Yf
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root, c
A total of five (5) alternatives were considered for disposal of the process
wastewater effluent. These include connection to an existing facility, land
application, reuse, discharge to surface waters, and a combination of
alternatives. The recommended alternative is direct discharge to surface waters.
Connection to existing facility and land application are considered feasible
however these approaches require significant additional capital investment,
operating costs, and are significantly more difficult to implement. The anticipated
effluent concentrations shown in Table III-1 below were used in evaluating
alternatives. These values were provided by Tecnicas Reunidas, a process
design firm in Spain that has developed this technological approach, as an
estimate based on a mass balance and theoretical data. Actual effluent values
are likely to vary from these estimates as this facility doesn't exist in this
configuration anywhere in the world. The values provided in Table III-1 represent
the baseline numbers that can be anticipated from the planned process steps. It
is unrealistic to base effluent limitations on the baseline process materials
balance. The actual facility's effluent will vary and must be assumed to be higher
than the baseline numbers to accomplish consistent compliance. Based on the
receiving waters at low flow conditions, the Broad River has significant capacity
to assimilate this discharge. Detailed cost estimates and operations costs are
included for the feasible alternatives.
Horsehead Holding Corporation Engineering Alternatives Analysis
Business Confidential Information pg. 7

A. Connection to an Existing Wastewater Treatment System
The nearest municipal wastewater facility with reasonable capacity to accept the
process wastewater is the Town of Forest City Second Broad River WWTP,
NPDES No. NC0025984, which is approximately 10 miles away. There are
several challenges associated with this alternative including the distance of the
facility from the site, and the characteristics of the wastewater. Average flow
between April 2010 and March 2011 to the Forest City WWTP is approximately
1,265,000 gpd and permitted capacity is 4,950,000 gpd. Therefore the
gpd of flow from the Horsehead facility would represent 33% of the wastewa er
flow when combined with the current influent and 12.5% of the permitted
capacity.
As noted, the Forest City WWTP is located approximately 10 miles away from
the proposed Horsehead site as shown in Figure III-1. Connection to the Forest
City VVWTP would require a pump station and force main to be constructed to
convey the wastewater to the Forest City WWTP. Pretreatment would also be
required to prevent inhibition of the Town's biological treatment process. It is
noted that although pretreatment could be accomplished, at a very high cost,
providing wastewater characteristics of the discharge that would prevent
inhibition, the flow from Horsehead is not typical of domestic wastewater or of
other carbon -based industrial wastewater that would be consistent with the
plant's design. Acceptance of the wastewater would also cause other treatment
complications due to dilution of the wastewater strength resulting in negative
impacts to the plant's biological treatment process. The Forest City facility was
designed to accept industrial wastewater that is consistent with carbon -based
biological treatment processes.
Based on the anticipated effluent parameters provided in Table III-1 above the
chloride concentration of the combined waste stream would be 6,500 mg/I
including Forest City's current flows and assuming the existing wastewater has a
typical chloride concentration of 50 mg/I. Inhibition levels for an activated sludge
Horsehead Holding Corporation Engineering Alternatives Analysis
Business Confidential Information pg. 9

Q:12011111.003061DesignlSewerlDrawingslOverall Map dwg 6/2912011 2:49 PM DAVID
sy. SPINDALE
POP. 4,415
'1106
•t 1221
1106 \`,
s
1106'
1125
.7:21
[1108
1109
FIGURE III-1
CONNECT TO FOREST CITY
WASTEWATER TREATMENT PLANT
HORSEHEAD CORPORATION
FQR€St
OP. 8,3
RUTHERFORD COUNTY, NORTH CAROLINA
ndymus
al„ t\
FOREST CITY
SECOND BROAD RIVER ELLEENBPOP. o2a
b WASTEWATER
CTREATMENT PLANT
Caroleen
Avondal
POTENTIAL FORCE
MAIN ROUTE
2112 211
wJ 2102
10 3
2105 .1
U
U UNE
1930�
iffside
SCALE: 1" = 7000'

waste treatment process with nitrification for chlorides are 180 mg/I per
"Comprehensive Guidance for North Carolina Pretreatment Programs" data
taken from the "Guidance Manual on the Development and Implementation of
Local Discharge Limitations Under the Pretreatment Program" published by the
Environmental Protection Agency in December 1987. The mixture of Horsehead
process wastewater with existing wastewater flow to the Town of Forest City
would cause inhibition without pretreatment. Chloride concentrations would be
required to be reduced by approximately 97% to less than 425 mg/I. This level of
treatment would bring the combined influent level under the 180 mg/I inhibition
level. Chloride removal to this level could be completed with Reverse Osmosis
(RO), electrodialysis (ED) or chemical precipitation. The most effective of these
treatment options for the high chloride concentrations in the process waste is
RO. The capital costs for this system will be high and recoveries are typically
limited to 80-90%. The reject flow of 62,000-124,000 gpd is concentrated brine
requiring additional treatment and disposal. RO technology has been applied to a
limited number of situations and is untested in this application. In other proposed
or existing RO systems the disposal of this reject stream is a huge problem.
Some facilities in the area of potable water treatment actually discharge the
wastewater to surface waters. This approach here would defeat the objective of
the treatment. Therefore, it is assumed that this water would have to be further
treated by a brine concentrator and crystallizer to remove the remaining liquid.
The resulting solid waste would have to be disposed of at a landfill that could
accept this material. The Town of Forest City has a schedule for new sewer
impact fees. If this option was pursued by Horsehead the Town may assess an
impact fee. Based on the fee table included in the appendix the fee is estimated
to be $92,710 for an outside customer of this size. A detailed cost estimate for
this alternative is included in Table III-2 below.
Horsehead Holding Corporation Engineering Alternatives Analysis
Business Confidential Information pg. 11

Table III-2: Cost Estimate - Connection to Existing
nt System
ITEM
NO.
'
DESCRIPTION
QUANTITY
UNIT
UNIT PRICE
EXTENSION
1
Mobilization (3%)
1
LS
$82,700
$82,700
2
Reverse Osmosis Treatment System
1
LS
$1,600,000
$1,600,000
3
Brine Concentrators and Crystallizers
1
LS
$4,500,000
$4,500,000
4
Pumps, Piping, Installation
1
LS
$2,000,000
$2,000,000
5
Treatment System Building
1
LS
$200,000
$200,000
6
Electrical
1
LS
$1,200,000
$1,200,000
7
Pump Station w/ Standby Generator
1
LS
$250,000
$250,000
8
10" PVC Force Main
53,000
LF
$40.00
$2,120,000
9
Air Release Valve
10
EA
$3,500.00
$35,000
10
Rock Excavation
2,500
CY
$75.00
$187,500
11
Select Backfill
2,500
CY
$15.00
$37,500
12
Erosion Control
1
LS
$125,000.00
$125,000
CONSTRUCTION SUBTOTAL
$12,337,700
Contingency (10%)
$1,233,800
$987,000
Design and Permitting
Construction Administration
$863,600
Town of Forest City Impact Fee
$92,710
Legal/Administrative
$75,000
Testing
$40,000
Project Total
$15,629,81.0
Horsehead Holding Corporation Engineering Alternatives Analysis
Business Confidential Information pg. 12

B. Land Application
This alternative considers the potential to spray or drip irrigate the process
wastewater. This alternative was discussed with Bill Yarborough, Regional
Agronomist with the North Carolina Department of Agriculture and Consumer
Services. Mr. Yarborough indicated that the high chloride concentration would be
problematic for most common field crops and forage crops. Irrigation of the water
without pretreatment for chlorides would likely result in injury to the plants and
require constant replanting or erosion the site would occur due to the inability to
maintain a consistent cover crop. In addition Mr. Yarborough indicated an
agronomic rate for irrigation in the area of '/4" per day which would require
approximately 92 acres of wetted area. Some additional land would inevitably be
required for buffers, maintenance area, water storage and pumping facilities.
Irrigation could not be permitted during wet periods and when temperatures are
below freezing. The proposed irrigation system is assumed to be operated as a
standalone system for disposal of the water. In this configuration referred to as a
non -conjunctive system a large storage pond would also be required to store
water when irrigation is not advisable and to account for seasonal variations in
irrigation rates. A complete water balance is required to determine the exact
amount of storage needed, however, typically no less than 30 days is practical.
Based on 30 days of storage approximately 19 million gallons of storage is
required. It is assume for purposes of this report that a pond could be
constructed to retain this volume on or near the irrigation site. Per Metcalf and
Eddy Wastewater Engineering Treatment and Reuse 4th edition pg. 1403
irrigation with chlorides above 350 mg/I should be severely restricted. For
sprinkler irrigation water greater than 100 mg/I of chloride should have slight to
moderate restriction. Therefore in order to maintain the irrigation site without
causing injury to the plants as indicated by Mr. Yarborough a reverse osmosis
treatment system similar to that described in Alternative A is recommended.
There is not sufficient property to utilize the water for irrigation on the industrial
facility site under consideration so it assumed that property would be acquired
within a mile of the site to be used for irrigation.
Horsehead Holding Corporation Engineering Alternatives Analysis
Business Confidential Information pg. 13

A
Table III-3: Cost Estimate - Land Aaalication
ITEM
NO.
DESCRIPTION
QTY.
UNIT
UNIT PRICE
EXTENSION •
1
Mobilization (3%)
1
LS
$402,800
$402,800
2
Reverse Osmosis Treatment System
1
LS
$1,600,000
$1,600,000
3
Brine Concentrators and Crystallizers
1
LS
$4,500,000
$4,500,000
4
Pumps, Piping, Installation
1
LS
$2,000,000
$2,000,000
5
Treatment System Building
1
LS
$200,000
$200,000
6
Electrical
1
LS
$1,200,000
$1,200,000
7
Site Work
1
LS
$150,000
$150,000
8
Yard Piping
1
LS
$100,000
$100,000
9
Erosion Control
1
LS
$75,000
$75,000
10
Effluent Pump Station to Irrigation
1
LS
$250,000
$250,000
11
Force Main to Pond at Irrigation Site
5,000
LF
$50
$250,000
12
Irrigation Pump Station
1
LS
$200,000
$200,000
13
Spray Irrigation System
1
LS
$2,000,000
$2,000,000
14
19-Million Gallon Storage Pond
1
LS
$2,500,000
$2,500,000
CONSTRUCTION SUBTOTAL
$15,427,800
Contingency (10%)
$1,542,800
Design and Permitting
$1,234,200
Construction Administration
$1,079,900
$1,040,000
$25,000
Land (130 acres @ $8,000/acre
Testing
Project Total
$ 20,349 700
Horsehead Holding Corporation Engineering Alternatives Analysis
Business Confidential Information pg. 14

C. Wastewater Reuse
This alternative considers the potential to reuse the wastewater for other
purposes onsite or nearby. The large quantity of water and the projected chloride
level are the largest hurdles for this alternative. There are no known needs for
this quantity of non -potable water in the Horsehead facility or any other areas
nearby. Utilizing the water for typical reuse applications such as toilet flushing are
not sufficient to reuse the quantity produced and will still result in the need to
dispose of the water at some point in the process. Use as a cooling water is not
feasible due to the chloride content. This alternative is not feasible and will not be
further considered.
Horsehead Holding Corporation Engineering Alternatives Analysis
Business Confidential Information pg. 15

D. Direct Discharge to Surface Waters
Background and Effluent Limitations
The proposed facility is located adjacent to the Broad River in southern
Rutherford County. Discharging 620,000 gpd of process wastewater directly to
the Broad River is considered in this alternative. The Broad River is classified as
C waters under Index No. 9-(36.5) at the facility site. The 7Q10 flow for the Broad
River is 130,000,000 gpd. Therefore the process water will be 0.5 % of the
instream flow at low flow conditions.
The highest expected effluent concentrations were used to calculate the
combined flow concentrations of the constituents. These concentrations and NC
water standards and action limits are shown in Table III-4 below. As Horsehead
Corporation described to DWQ on a number of occasions and at our meeting to
discuss the process wastewater discharge, the technology that will be
implemented at the Rutherford County facility is new and there are no
comparable facilities anywhere in the world. The company providing the process
design for this plant has predicted the effluent concentrations of several metals
that are likely to be present in the effluent. However, it is Horsehead's position
that they do not want to generate compliance issues based on preliminary
effluent data. While there is full confidence that the facility's effluent will not
result in any in -stream water quality standards for the parameters of concern in
this effluent, we respectfully request that DWQ base the effluent limitations on
50% of the available "assimilative capacity" of the Broad River. We have
provided a table showing the parameters expected in the effluent and the relative
discharge level in mass that the facility would be allowed to discharge using 50%
of the dilution capacity of the River. We believe that this approach is a realistic
consideration for the protection of water quality and would still leave a significant
component of capacity in the River for other discharges and variations in the
actual levels of these parameters in the receiving stream.
Horsehead Holding Corporation Engineering Alternatives Analysis
Business Confidential Information pg. 16

As indicated in the attached application form we have identified other effluent
characteristics. Included in this list are items related to temperature, and total
suspended solids. Based on the process that produces this effluent the numbers
provided for TSS are considered to be approximate and should be less than
those sighted. Since there is no water quality standard for TSS we would not
anticipate an effluent limit for this parameter. Based on the expected effluent
temperature and the instream waste concentration, we do not anticipate any
issues related to temperature impact from the discharge. pH will be managed in
the effluent to maintain a level between 6 and 9 standard units.
Most importantly, the Company requests that all other parameters limited in this
permit be based on mass loading rather than concentration. The discharge flow
is 0.5% of the instream flow and hence changes in discharge flow result in very
little impact to the instream concentrations with the same discharge mass. The
facility will have a relatively stable discharge and the flexibility of meeting a mass
limitation will help the company more effectively manage compliance and protect
water quality.
Horsehead Holding Corporation Engineering Alternatives Analysis
Business Confidential Information pg. 17

Table III-4: Water Quality Standards - Instream Concentrations
Constituent
Water Quality
Standard (mg/I)
WQS lbs/day
at 130,620,000
gpd instream
flow
Requested
Effluent
Limitation
(lbs/day)
Aquatic
Life
Action
Level
CI
230
250,555
125,278
K
SO4
Mg
Ca
Na
F
1.8
1,961
980
SiO2
Mn
Fe
1
1,089
545
Sn
As
0.05
54.47
27.23
Zn
0.05
54.47
27.23
Ni
0.088
95.86
47.93
Co
Cu
0.007
7.63
3.81
Cd
0.002
2.18
1.09
Pb
0.025
27.23
13.62
Al
0.087
94.78
47.39
Cr
0.050
54.47
27.23
Sb
0.0056
6.10
3.05
Project Description and Cost
Based on this information additional pretreatment for discharge to the Broad
River is not necessary to meet Water Standards or Action Levels. The process
will have a relatively consistent flow and flow equalization is not expected to be
required. In order to discharge the process waters to the Broad River the project
will include approximately 2,200 ft of gravity effluent piping, an instream diffuser,
and effluent flow monitoring and sampling equipment. A map of the discharge
location and preliminary site plan are included in Figures III-2 and III-3 A detailed
cost estimate is included in Table III-5 below.
Horsehead Holding Corporation Engineering Alternatives Analysis
Business Confidential Information pg. 18

Table III-5: Cost Estimate - Direct Discharge to Broad River
ITEM
No. •
DESCRIPTION
QUANTITY
UNIT
UNIT PRICE
EXTENSION
1
Mobilization (3%)
1
LS
$9,900
$9,900
2
Site Work
1
LS
$20,000
$20,000
3
Effluent Piping To Broad River
2,200
LF
$75
$165,000
4
Effluent Diffuser
1
LS
$30,000
$30,000
5
Effluent Flow Meter and Sampler
1
LS
$25,000
$25,000
6
Electrical
1
LS
$15,000
$15,000
7
Erosion Control
1
LS
$75,000
$75,000
CONSTRUCTION SUBTOTAL
$339,900
Contingency (10%)
$34,000
Design and Permitting
$37,400
Construction Administration
$27,200
Testing
$10,000
Project Total
$448,500
Horsehead Holding Corporation Engineering Alternatives Analysis
Business Confidential Information pg. 19

o s' � n .. 1 r /A r
1 PROPOSED WASTEWATER
b't rj�DISCHARGE LOCATION
, ,,(LATITUDE N 35 12' 1",
`LONGITUDE W 81 51' 10")
•
NORTH CAROLINA
SOUTH CAROLINA
Ph- 11,
_ &Mtk TAL
rams° welmitt_allimirm2it
i(01441 FIGURE III-2
PROPOSED DISCHARGE LOCATION MAP
11777t a HORSEHEAD CORPORATION
:�� RUTHERFORD COUNTY, NORTH CAROLINA

PROPOSED
DIFFUSER
POTENTIAL STREAM
IIMMIND POTENTIAL WETLANDS
•
- [ POTENTIAL PRODUCTION FACILITY
I
FIGURE III-3: PRELIMINARY SITE PLAN
HORSEHEAD CORPORATION
RUTHERFORD COUNTY, NORTH CAROLINA

E. Combination of Alternatives
A combination of alternatives refers to the possibility of using multiple options
from the above alternatives. Potential combinations that can be considered are
land application system with discharge for periods when irrigation is not required,
or reuse of a portion of the water with the remaining water being utilized for
irrigation or discharge. As described in the reuse alternative there is very limited
potential use for reuse water from the facility and reusing a small portion would
not be cost effective. Combining land application with a discharge would still
require RO treatment for the portion of water to be land applied and the
purchase/lease agreement for property to be irrigated. Although the requirement
for effluent storage may be able to be removed by utilizing a discharge as a
backup to irrigation the cost would still be significantly higher than alternative D.
Direct Discharge to Surface Waters. Based on this information a combination of
alternatives is not practical and will not be further considered.
Horsehead Holding Corporation Engineering Alternatives Analysis
Business Confidential Information pg. 22

IV. Economic Feasibility
As described in section III. The feasible alternatives are considered A.
Connection to Forest City WWTP, B. Land Application, and C. Direct Discharge
to the Broad River. The capital costs for these alternatives are included in section
III. In order to compare these alternatives as accurately as possible a present
worth calculation is required to account for the impact of salvage values and
operations and maintenance costs.
Connection to the Town of Forest City alternative's operation and
maintenance cost will include operation of the reverse osmosis treatment system
and sewer fees from the Town of Forest City. Typically RO operation cost are $1-
$3 per 1,000 gallons treated. Table IV-1 below gives a summary of typical
operation and maintenance associated with an RO system. Assuming a cost of
$2 per 1,000 gallons total yearly cost would be approximately $452,600.
Table IV-1: Reverse Osmosis Treatment
System Operation and Maintenance Cost
Item
Cost/1000 gallons
RO Electricity
$0.30-$0.50
Chemicals
$0.20-$0.40
RO Membrane
Replacement
$0.07-$0.12
Brine Concentrator
Electricity
$0.80-$1.20
Membrane Cleaning
$0.02-$0.05
Labor
$0.03-$0.05
Town of Forest City sewer bills are estimated based on the outside rates per the
rate sheets included in the appendix. The rates are $4,506 for the first 1,000,000
gallons and $3.01 foreach additional 1,000 gallons. Based on 24 hour per day, 7
day a week production on a typical 30 day month total water discharged will be
18,600,000 gallons. Therefore the estimated sewer bill per month is $57,482.20
or approximately $689,784 per year. The total estimated operation and
maintenance costs for this alternative are $1,142,384 per year.
Horsehead Holding Corporation Engineering Alternatives Analysis
Business Confidential Information
pg. 23

Land application will have similar operations costs for the RO system compared
to the connection to the Town of Forest City alternative. In addition to operation
of the RO treatment system the industry would also be required to operate the
irrigation system. Operation of the irrigation system would include, certified
operator, electricity, sampling/laboratory, and maintenance. These costs are
estimated to be $157,000 per year. Therefore the total estimated operation and
maintenance costs are for this alternative estimated as $609,600 per year.
Table IV-2: Land Application System Operation Costs
Item
Cost
Maintenance
$25,000
Laboratory/Samples
$12,000
Operator/Staff
$75,000
Utility Costs
$45,000
Total
$157,000
Alternative D. Direct Discharge to the Broad River operation and maintenance
costs will include laboratory/sampling, operator/staff, and maintenance of the flow
meter, and sample equipment. Flow will be conveyed by gravity to the Broad
River so electrical and maintenance cost will be minimal.
Table IV-3: Direct Discharge Operation Costs
Item
Cost
Maintenance
$5,000
Laboratory/Samples
$12,000
Operator/Staff
$10,000
Utility Costs
$2,000
Total
$29,000
Horsehead Holding Corporation
Business Confidential Information
Engineering Alternatives Analysis
pg. 24

Ly v
Table IV-4 below shows the summary of present worth costs for the feasible
alternatives. Detailed calculations are included in the appendix. Direct discharge
is the least costly alternative by a very large margin and is the recommended
alternative..
Table IV-4: Present Worth Analysis Summa
Alternative
Capital
Cost
Operations
and
Maintenance
(per Year)
Salvage
Value
Total
Present
Worth
Alternative A:
Connect to Forest
City WWTP
$15,629,810
$1,142,384
$409,135
$29,609,002
Alternative B: Land
Application
$20,349,700
$609,600
$627,211
$27,622,211
Alternative D:
Direct Discharge to
Broad River
$448,500
$29,000
$31,843
$781,912
Horsehead Holding Corporation Engineering Alternatives Analysis
Business Confidential Information pg. 25

i V
V. Conclusion
The process water effluent from the Horsehead facility is projected to be 620,000
gpd. Five (5) alternatives were considered for disposal of the process wastewater
however, the only reasonable alternative for disposal of the Horsehead process
wastewater is direct discharge to the Broad River. The flow will be high in
chlorides and cannot be used for irrigation or treated with typical domestic
wastewater without pretreatment. The most feasible treatment option for removal
of chlorides is RO which carries high capital and operation costs. The discharge
will not result in violation of any water quality standards in the Broad River and
will be approximately 0.5% of the instream flow rate at the 7Q10 low flow. The
present worth analysis shows that the direct discharge alternative is by far the
most cost effective alternative at 3% of the nearest alternative. Based on this
evaluation the proposed alternative is direct discharge to the Broad River.
Horsehead Holding Corporation Engineering Alternatives Analysis
Business Confidential Information pg. 26

Steven W. Troxier
Commissioner
Forrest Westall
McGill and Associates
O Box 2259
Asheville, NC 28802
North Carolina Department of Agriculture
and Consumer Services
Agronomic Division
Dr. Colleen Hudak -Wise
Director
Mr. Westall,
I am writing to you as per your request for an agronomist's opinion on the proposed new zinc facility in Rutherford County and
a land application waste water permit. Below are my observations and concerns.
{kccording to the information provided to me, 2 land application issues for the waste water are prominent.
I st is the chloride content of the waste water and 2nd (and the most agronomic concern) is the quantity of total water per day.
't Chlorides are problematic at the levels presented for most common field crops and forage crops. Over time, severe plant
injury can be expected at these levels. This could lead to constant replanting and possible erosion causing off site damage
unless erosion control best management practices are carefully planned, installed, and carefully maintained.
2nd Nearly 700,000 gallons of waste water per day will be the most agronomic concern for this operation. As you know, water
is a critical component of good plant growth. However, excessive water is one of the most limiting issues in any cropping
ystem. This quantity of water would require a minimum of over 100 acres of land for application. (27,000 gallons per day
quals one acre inch for a need for 26 acres of area for application. A good agronomic rate for waste water is 'A inch per day to
allow for normal precipitation and winter application where little to no evaporation can be expected. This would equate to an
Lpplication area of 104 acres for an application field). It is also a recommended practice to have a repair area of at least 50%
of the acreage to allow for failures or other unforeseen adversity. A minimum total land area of over 150 acres would be
necessary to adequately treat this quantity of waste water. Even with this calculation, careful planning of ground cover capable
df handling this quantity of water will be required. Considerations of slope, soil type, permeability, proximity to water courses,
c. could also impact this acreage and require additional land to achieve adequate land treatment of this waste water. This
1iould require a detailed site investigation to determine site limitations.
I additional information is required, please let me know.
est regards,
)fit 1�
ill Yarborough
egional Agronomist
1040 Mail Service Center, Raleigh, North Carolina 27699-1040
[phone] • Fax [phone]
TTY: 1-800-735-2962 Voice: 1-877-735-8200
An Equal Opportunity Affirmative Action Employer

• Lr
ALTERNATIVE A - Connect to Town of Forest City
Capital and
O&M
Description
I Cost (2012)
I
...',I ..._
l .:.. __.:._.
I Present Value
Total Capital Outlay
Annual O&M
$15,629,810
$1,142,384
-._ .
:!
.
- -
_. _ . _.
$15,629,810
$14,388,326
Subtotal
$16,772,194
- _--
_ _
; .- 3
_ ...
$30,018,136
r
a
Type 1 Life (YR)
Description
I Cost (2012) 1... . .
j
% Value at n (2032)
I Salvage at n (2032)1 Present Value
Structures
Collectors
50
40
Treatment System Building
10" PVC Force Main
$200,000
$2,120,000
._ . .....
....
..... .
60%
50%
$120,000
$1,060,000
$46,317
$409,135
:.,.
:. ...'
Subtotal
$2,120,000
--1:,--,-
=
''
$1,060,000
$409,135
ALTERNATIVES NET PRESENT VALUE I
;.$29,609,002
ALTERNATIVE B - Land Application
Capital and
O&M
Description
Cost (2012) ! _ _.
_'.__.. -.:
-.....: I .. _ _.. -
I .. _.:_._.. ,_ ..
Present Value
Total Capital Outlay
Annual 0&M
$20,349,700
627,211
-
:.-
-
. _ ...
_ . _:. i
" ."
, ...
- - -
_ ..:. _.. r
$20,349,700
$7,899,723
Subtotal
$20,976,911
).
:`.
._
. <
<. _ ._ .:, ...._
.�. _ _.
$28,249,423
i1
g
H
Type 1 Life (YR) I Description
Cost (2012)
I
; : ;
I % Value at n (2032) [Salvage at n (2032)
Present Value
Structures
Collectors
Structures
50
40
SO
Treatment System Building
Force Main to Pond at Irrigation Site
20-Million Gallon Storage Pond
$200,000
$250,000
$2,500,000
:_._
_.. _
.
: __.
60%
50%
6096
$120,000
$125,000
$1,500,000
$46,317
$48,247
$578,964
Subtotal
$2,950,000
_ ..
_ --
- :
...........
$1,625,000
$627,211
ALTERNATIVE 3 NET PRESENT VALUE
... ,. $27,622,21.1:
ALTERNATIVE D - Direct Discharge to Surface Waters
Capital and
O&M
Description
Cost (2012) I-�
- .. _:
.. _.__ - - ._ -._-_- Present Value
Total Capital Outlay
Annual O&M
$448,500
$29,000
:
_
..._ ..
-.-...._ . _
- - ." - . _
___ �__
$448,500
$365,255
Subtotal
$477,500
-__ ...
_
,
$813,755
y
gS
Type
Life (YR)
I Description
I Cost (2012) I .: -
—
,
__::.: ;I
% Value at n (2032)
I Salvage at n (2032)1 Present Value
Colllectors
40
Effluent Piping To Broad River
$165,000
-
::::
_";
' _; .
50%
$82,500
$31,843
•:
_ .
Subtotal
$165,000
_
-
_
- . :.
$82,500
$31,843
ALTERNATIVE 6 NET PRESENT VALUE
I ... ._1781,912.