NC0089109_Permit Issuance_20190419

NPDES DOCUMENT SCANNING COVER SHEET
NPDES Permit:
NC0089109
Document Type: w
xb.
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:
April 19, 2019
This document is printed on reuse paper - ignore any
cozztezzt on the reirerse side

RQY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
Mr. Robert Williamson, Plant Manager
American Zinc Products, LLC
484 Hicks Grove Road
Mooresboro, North Carolina 28114
Dear Mr. Williamson:
NORTH CAROLINA
Environmental Quality
April 18, 2019
Subject: Final NPDES Permit
Permit NC0089109
American Zinc Products, LLC
Rutherford County
Grade II PCWPCS
Division personnel have reviewed and approved your application for a renewal of the subject permit.
Accordingly, we are forwarding the attached NPDES 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).
No major changes were made to the draft permit sent to you on January 29, 2019.
The final permit maintains the following significant changes identified in the letter sent on
January 29, 2019:
• The flow limit was increased to 0.98 MGD
• The requirement for fish tissue monitoring was added to the permit to address a comment
from the Regional Office.
• The requirement for pollutant scan was added to the permit to address a comment from the
Regional Office.
• The limits for Total Cadmium were recalculated (reduced) based on the new flow estimate
• and the recent update to the North Carolina water quality standards. A cadmium limit
compliance schedule was added to the permit.
• The .imits for Total Chromium, Total Lead, and Total Fluoride were removed from the
permit based on the results of the Reasonable Potential Analysis.
• Quarterly monitoring for Hexavalent Chromium was added to the permit based on the
review of the effluent data.
DECV4
North Caroiea Department of Environmental Quality 1 DMslon of Water Resources
512 North Salsbury Street I ib1TMafl Service Center I RaStigA. North Carolina Z1699.1611

The Division is unable to grant your request for changing the Fish Tissue Monitoring Special
Condition, the Division used the standard language that applies to all the facilities required to monitor
fish tissue.
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 Resources or
any other Federal, State, or Local governmental regulations.
If you have any questions concerning this permit, please contact Sergei Chernikov at [phone]
or via email at [e-mail].
Sincerely,
a Culpe.�.:, , .Iii ector
ivision of Water Resources, NCDEQ
Hardcopy: NPDES Files
Central Files
E-copy: DWR/Asheville Regional Office/Water Quality
DWR/Aquatic Toxicology Branch
Page 2 of 2

Permit NC0089109
.-
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
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,
American Zinc Products, LLC
is hereby authorized to discharge wastewater from a facility located at
American Zinc Products, LLC
Forest City
Rutherford County
to receiving waters designated as the Broad River in the Broad River Basin in accordance with
effluent limitations, monitoring requirements, and other applicable conditions set forth in
Parts I, II, III and IV hereof.
This permit modification shall become effective June 1, 2019.
This permit and authorization to discharge shall expire at midnight on July 31, 2023.
Signed this day April 18, 2019.
Al-, a" .9
a Culpepp or
ision of Water Resources
By Authority of the Environmental Management Commission
Page 1 of 9

Permit NC0089109
SUPPLEMENT TO PERMIT COVER SHEET •
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked. As of this permit issuance, any previously issued permit bearing this number is no longer
effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the
permit conditions, requirements, terms, and provisions included herein.
American Zinc Products, LLC is hereby authorized to:
1. Operate the process effluent discharge system including the following
components:
➢ Automatic sampler
➢ Instrumented flow measurement, and
➢ Diffuser
The facility is located near Forest City, Rutherford County; and
2. Discharge effluent from this location as specified on the attached map into the
Broad River which is classified WS-IV waters in the Broad River Basin.
Page 2 of 9

Permit NC0089109
Part I
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee
is authorized to discharge from outfall(s) serial number 001. Such discharges shall be limited and
monitored5 by the Permittee as svecified below:
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQUREMENTS
Monthly
Average
Daily
Maximum
Measureme
nt
Frequency
Sample
Type
Sample
Location'.
Flow (MGD)
0.98
Continuous
Recording
I or E
Total Suspended Solids,
mg/L
2/Month
Composite
E
NH3-N, mg/L
Quarterly
Composite
E
Total Aluminum, µg/ L
Quarterly
Composite
E
Total Antimony, µg/ L
Quarterly
Composite
E
Total Arsenic, µg/ L
Quarterly
Composite
E
Total Cadmium
90.4 µg/ L6
454.4 µg/ L6
2/Month
Composite
E
Chlorides, mg/L
Quarterly
Composite
E
Chromium (VI), µg/ L
Quarterly
Composite
E
Total Cobalt, µg/ L
Quarterly
Composite
E
Total Copper, µg/L
Quarterly
Composite
E
Total Fluoride, mg/L
Quarterly
Composite
E
Total Iron, mg/L
Quarterly
Composite
E
Total Lead, µg/ L
, 2/Month
Composite
E
Total Nickel, µg/ L
Monthly
Composite
E
Total Tin, µg/ L
Quarterly
Composite
E
Total Zinc, µg/ L
2/Month
Composite
E
pH2
6.0 s pH s 9.0
Daily
Grab
E
Chronic Toxicity3
Quarterly
Composite
E
Turbidity4
Monthly
Grab
E, U, D
NOTES:
1.
Sample Locations: I - Influent, E - Effluent, U - upstream (50 ft. upstream of the
discharge), D - downstream (50 ft. downstream of the discharge).
2. The pH shall not be less than 6.0 standard units or greater than 9.0 standard units.
3. Chronic Toxicity (Ceriodaphnia) P/F @ 0.9%; Jan., April, July, and October; See
condition A. (2.) of the Supplement to Effluent Limitations and Monitoring Section of
this permit.
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. Therefore, if the effluent
measurement exceeds 50 NTU, the Permittee shall sample upstream and downstream
turbidity in the receiving waterbody, within 24 hours, to demonstrate the existing turbidity
level in the receiving waterbody was not increased. All data shall be reported on the DMRs.
(See 15A NCAC 2B .0211 (21)).
NTU - Nephelometric Turbidity Unit.
Page 3 of 9

Permit NC0089109
5. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's
eDMR application system. See Special Condition A. (3.).
6. The limit becomes effective 90 months from the effective date of the permit. Please see A.
(6.) for Compliance Schedule.
THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR FOAM VISIBLE IN OTHER THAN
TRACE AMOUNTS.
A. (2.) CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QUARTERLY)
[15A NCAC 02B .0200 et seq.]
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant
mortality to Ceriodaphnia dubia at an effluent concentration of 0.9%.
The permit holder shall perform at a minimum, auarterlu monitoring using test procedures
outlined in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised
December 2010, or subsequent versions or "North Carolina Phase II Chronic Whole Effluent
Toxicity Test Procedure" (Revised- December 2010) or subsequent versions. The tests will be
performed during the months of January, April, July and October. These months signify the
first month of each three-month toxicity testing quarter assigned to the facility. Effluent
sampling for this testing must be obtained during representative effluent discharge and shall be
performed at the NPDES permitted final effluent discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or
ChV below the permit limit, then multiple -concentration testing shall be performed at a
minimum, in each of the two following months as described in "North Carolina Phase H
Chronic Whole Effluent Toxicity Test Procedure" (Revised -December 2010) or subsequent
versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the months in which tests were performed, using the
parameter code TGP3B for the pass/fail results and THP3B for the Chronic Value. Additionally,
DWR Form AT-3 (original) is to be sent to the following address:
Attention: North Carolina Division of Water Resources
Water Sciences Section/Aquatic Toxicology Branch
1621 Mail Service Center
Raleigh, NC 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section no later
than 30 days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements
and all concentration/response data, and be certified by laboratory supervisor and ORC or
approved designate signature. 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 Water Sciences Section at the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required,
monitoring will be required during the following month. Assessment of toxicity compliance is
Page 4 of 9

Permit NC0089 109
based on the toxicity testing quarter, which is the three month time interval that begins on the
first day of the month in which toxicity testing is required by this permit and continues until the
final day of the third month.
Should any test data from this monitoring requirement or tests performed by the North Carolina
Division of Water Resources 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 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.
A. (3.) ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS
[G.S. 143-215.1(b)]
Federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and
program reports. The final NPDES Electronic Reporting Rule was adopted and became effective on
December 21, 2015.
NOTE: This special condition supplements or supersedes the following sections within Part II of
this permit (Standard Conditions for NPDES Permits):
• Section B. (11.) Signatory Requirements
• Section D. (2.) Reporting
• Section D. (6.) Records Retention
• Section E. (5.) Monitoring Reports
1. Reporting Requirements [Supersedes Section D. (2.1 and Section E. (5.1 (all
The permittee shall report discharge monitoring data electronically using the NC DWR's
Electronic Discharge Monitoring Report (eDMR) internet application.
Monitoring results obtained during the previous month(s) shall be summarized for each
month and submitted electronically using eDMR. The eDMR system allows permitted facilities
to enter monitoring data and submit DMRs electronically using the internet. Until such time
that the state's eDMR application is compliant with EPA's Cross -Media Electronic Reporting
Regulation (CROMERR), permittees will be required to submit all discharge monitoring data to
the state electronically using eDMR and will be required to complete the eDMR submission by
printing, signing, and submitting one signed original and a copy of the computer printed
eDMR to the following address:
NC DEQ / Division of Water Resources / Water Quality Permitting Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the
facility being physically located in an area where less than 10 percent of the households have
broadband access, then a temporary waiver from the NPDES electronic reporting requirements
may be granted and discharge monitoring data may be submitted on paper DMR forms (MR 1,
1.1, 2, 3) or alternative forms approved by the Director. Duplicate signed copies shall be
Page 5 of 9

Permit NC0089 109
submitted to the mailing address above. See "How to Request a Waiver from Electronic
Reporting" section below.
Regardless of the submission method, the first DMR is due on the last day of the month
following the issuance of the permit or in the case of a new facility, on the last day of the
month following the commencement of discharge.
Starting on December 21, 2020, the permittee must electronically report the following
compliance monitoring data and reports, when applicable:
• Sewer Overflow/Bypass Event Reports;
• Pretreatment Program Annual Reports; and
• Clean Water Act (CWA) Section 316(b) Annual Reports.
The permittee may seek an electronic reporting waiver from the Division (see "How to Request
a Waiver from Electronic Reporting" section below).
2. Electronic Submissions
In accordance with 40 CFR 122.41(1)(9), the permittee must identify the initial recipient at the
time of each electronic submission. The permittee should use the EPA's website resources to
identify the initial recipient for the electronic submission.
Initial recipient of electronic NPDES information from NPDES-regulated facilities means the
entity (EPA or the state authorized by EPA to implement the NPDES program) that is the
designated entity for receiving electronic NPDES data [see 40 CFR 127.2(b)].
EPA plans to establish a website that will also link to the appropriate electronic reporting tool
for each type of electronic submission and for each state. Instructions on how to access and
use the appropriate electronic reporting tool will be available as well. Information on EPA's
NPDES Electronic Reporting Rule is found at:
https://www.federalregister.gov/documents/2015/ 10/22/2015-24954/national-pollutant-
discharge-elimination-system-npdes-electronic-reporting-rule
Electronic submissions must start by the dates listed in the "Reporting Requirements" section
above.
3. How to Request a Waiver from Electronic Reporting
The permittee may seek a temporary electronic reporting waiver from the Division. To obtain
an electronic reporting waiver, a permittee must first submit an electronic reporting waiver
request to the Division. Requests for temporary electronic reporting waivers must be
submitted in writing to the Division for written approval at least sixty (60) days prior to the
date the facility would be required under this permit to begin submitting monitoring data and
reports. The duration of a temporary waiver shall not exceed 5 years and shall thereupon
expire. At such time, monitoring data and reports shall be submitted electronically to the
Division unless the permittee re -applies for and is granted a new temporary electronic
reporting waiver by the Division. Approved electronic reporting waivers are not transferrable.
Only permittees with an approved reporting waiver request may submit monitoring data and
reports on paper to the Division for the period that the approved reporting waiver request is
effective.
Information on eDMR and the application for a temporary electronic reporting waiver are
found on the following web page:
http: / /deq.nc.gov/about/divisions/water-resources/edmr
Page 6 of 9

Permit NC0089109
I-
4. Signatory Requirements [Supplements Section B. (11.1 (bj and Supersedes Section B.
(11.1(d1l
All eDMRs submitted to the permit issuing authority shall be signed by a person described in
Part II, Section B. (11.)(a) or by a duly authorized representative of that person as described in
Part II, Section B. (11.)(b). A person, and not a position, must be delegated signatory
authority for eDMR reporting purposes.
For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR
user account and login credentials to access the eDMR system. For more information on
North Carolina's eDMR system, registering for eDMR and obtaining an eDMR user account,
please visit the following web page:
http: / /deci.nc.gov/about/divisions/water-resources/edmr
Certification. Any person submitting an electronic DMR using the state's eDMR system shall
make the following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF
CERTIFICATION WILL BE ACCEPTED:
"I certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate,
and complete. 1 am aware that there are significant penalties for submitting false information,
including the possibility of fines and imprisonment for knowing violations."
5. Records Retention [Supplements Section D. (6.11
The permittee shall retain records of all Discharge Monitoring Reports, including eDMR
submissions. These records or copies shall be maintained for a period of at least 3 years from
the date of the report. This period may be extended by request of the Director at any time [40
CFR 122.41].
A. (4.) FISH TISSUE MONITORING
[G.S. 143-215.1(b)]
The facility shall conduct fish tissue monitoring once during the permit cycle and submit the results
with the NPDES permit renewal application. The objective of this monitoring is to evaluate potential
uptake of pollutants by fish tissue near the facility's discharge. The parameters analyzed in fish
tissue shall be arsenic, cadmium, and zinc. The monitoring shall be conducted in accordance with
the sampling plan approved by the Division. The plan should be submitted to the Division within
180 days from the effective date of the permit modification. Upon approval, the plan becomes an
enforceable part of the permit.
Copies of all the study plans, study results, and any other applicable materials should be
submitted to:
1) Electronic Version Only (pdf and CD)
Division of Water Resources
WQ Permitting Section - NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
2) Electronic Version (pdf and CD) and Hard Copy
Division of Water Resources
Water Sciences Section
1621 Mail Service Center
Raleigh, NC 27699-1621
Page 7 of 9

Permit NC0089 109
A. (5.) PRIORITY POLLUTANT ANALYSIS
[G.S. 143-215.1(b)]
The Permittee shall perform one Effluent Pollutant Scan for all parameters listed below. The analytical
methods shall be in accordance with 40 CFR Part 136 and shall be sufficiently sensitive to determine
whether parameters are present in concentrations greater than applicable standards and criteria.
Unless otherwise indicated, metals shall be analyzed as "total recoverable."
Ammonia (as N)
Chlorine (total residual, TRC)
Dissolved oxygen
Nitrate/ Nitrite
Kjeldahl nitrogen
Oil and grease
Phosphorus
Total dissolved solids
Hardness
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury (EPA Method 1631 E)
Nickel
Selenium
Silver
Thallium
Zinc
Cyanide
Total phenolic compounds
Volatile organic compounds:
Acrolein
Acrylonitrile
Benzene
Bromoform
Carbon tetrachloride
Chlorobenzene
Chlorodibromomethane
Chloroethane
2-chloroethylvinyl ether
Chloroform
Dichlorobromomethane
1,1-dichloroethane
1,2-dichloroethane
Trans-1,2-dichloroethylene
1,1-dichloroethylene
1,2-dichloropropane
1,3-dichloropropylene
Ethylbenzene
Methyl bromide
Methyl chloride
Methylene chloride
1,1,2,2-tetrachloroethane
Tetrachloroethylene
Toluene
1,1,1-trichloroethane
1,1,2-trichloroethane
Trichloroethylene
Vinyl chloride
Acid -extractable compounds:
P-chloro-m-cresol
2-chlorophenol
2,4-dichlorophenol
2,4-dimethylphenol
4,6-dinitro-o-cresol
2,4-dinitrophenol
2-nitrophenol
4-nitrophenol
Pentachlorophenol
Phenol
2,4,6-trichlorophenol
Base -neutral compounds:
Acenaphthene
Acenaphthylene
Anthracene
Benzidine
Benzo(a)anthracene
Benzo(a)pyrene
3,4 benzofluoranthene
Benzo(ghi)perylene
Benzo(k)fluoranthene
Bis (2-chloroethoxy)
methane
Bis (2-chloroethyl) ether
Bis (2-chloroisopropyl) ether
Bis (2-ethylhexyl) phthalate
4-bromophenyl phenyl ether
Butyl benzyl phthalate
2-chloronaphthalene
4-chlorophenyl phenyl ether
Chrysene
Di-n-butyl phthalate
Di-n-octyl phthalate
Dibenzo(a,h)anthracene
1,2-dichlorobenzene
1,3-dichlorobenzene
1,4-dichlorobenzene
3,3-dichlorobenzidine
Diethyl phthalate
Dimethyl phthalate
2,4-dinitrotoluene
2,6-dinitrotoluene
1, 2-diphenylhydrazine
Fluoranthene
Fluorene
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclo-pentadiene
Hexachloroethane
Indeno(1,2,3-cd)pyrene
Isophorone
Naphthalene
Nitrobenzene
N-nitrosodi-n-propylamine
N-nitrosodimethylamine
N-nitrosodiphenylamine
Phenanthrene
Pyrene
1,2,4-trichlorobenzene
Reporting. The effluent pollutant scan shall be performed once during the permit cycle and test
results shall be submitted to the Division within 270 days of the sampling.
Page 8 of 9

Permit NC0089109
•
A. (6.) CADMIUM COMPLIANCE SCHEDULE
[G.S. 143-215.1(b)]
Activity
Description
Deadline
1.
Commence production of Zinc at Mooresboro Facility.
June 1, 2019
2.
Ramp -up production to 75%.
December 1, 2019
3.
Stabilize plant operation and commence evaluation of permit
compliance.
June 1, 2020
4.
Complete evaluation period.
June 1, 2021
5.
Prepare a Preliminary Engineering Report (PER) of process
alternatives and/or pollution prevention/waste minimization
alternatives designed to achieve compliance. This report would
include the results of the compliance evaluation. Submit to DWR
for review and comment.
December 1, 2021
(parallel with activity 4)
6.
Agency review and addressing comments
February 1, 2022
7.
Bench scale test work of process alternatives (start in parallel
with Activity 6).
April 1, 2020
8.
Evaluate business case and funding requirements for
technically suitable alternative(s).
April 1, 2022
(parallel with activity 7)
9.
Complete pilot test work for selected technology option(s) and
final technology selection. Develop a summary of the results of
this evaluation. Submit summary to DWR for review.
August 1, 2022
10.
Agency review and addressing comments
October 1, 2022
11.
Detailed engineering and design of selected option. Submit to
DWR for comment.
February 1, 2023
12.
Agency review and addressing comments
April 1, 2023
13.
Prepare capital project application and secure funding for
selected option, obtain building permits and all needed
approvals for implementation.
June 1, 2023
(much of this work will be done in
parallel with activities 11,12)
14.
Project implementation, including design completion,
procurement and construction.
June 1, 2024
15.
Commission and ramp -up.
June 1, 2025
16.
Stabilize operation and evaluate performance.
December 1, 2025
17.
Make necessary final modifications to optimize and obtain full
operational status.
August 1, 2026
18.
Achieve full compliance.
December 1, 2026
Page 9 of 9

Latitude: 35°12'3" Sub -Basin: 03-08-02
Longitude: 81 °51'3"
Quad #: F11SW
Stream Class: S.
Receiving Stream: Broad River
Facility
Location
American Zmc Recycling
NC0089109
Mooresboro Facility

NCDEQ/DWR
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
MAJOR MODIFICATION/RENEWAL
American Zinc Products, LLC
NC0089109
Facility Information
(1.) Facility Name:
American Zinc Products, LLC
(2.) Permitted Flow (MGD):
0.98
(6.) County:
Rutherford
(3.) Facility Class:
II
(7.) Regional Office:
Asheville
(4.) Pretreatment Program:
N/A
(8.) USGS Topo Quad:
F11SW
(5.) Permit Status:
Major Modification and
Renewal
(9.) USGS Quad Name:
Stream Characteristics
(1.) Receiving Stream:
Broad River
(7.) Drainage Area (mi2):
575
(2.) Sub -basin:
03-08-02
(8.) Summer 7Q10 (cfs):
167
(3.) Stream Index Number:
9-(36.5)
(9.) Winter 7Q10 (cfs):
334
(4.) Stream Classification:
WS-IV
(10.) 30Q2 (cfs):
403
(5.) 303(d) Status:
Not listed
(11.) Average Flow (cfs):
914
(6.) 305(b) Status:
I (12.) IWC %:
0.9
Summary
This is a Major Modification and a Renewal for the permit for American Zinc Products,
LLC. The Major Modification and Renewal is conducted to accommodate the flow increase
in the permit. The facility is located in the southern portion of the Rutherford County. The
facility uses the impure zinc oxide that is generated from the parent company's (AZR)
recycle plants, which recycle Electric Arc Furnace (EAF) dust. The EAF dust is a zinc
containing waste generated by the North American steel mini mills. The facility will produce
approximately 55,000 tons of Special High grade Zinc metal. The process will include zinc
oxide leaching, extraction of zinc with an organic ligand electrowinning, and casting. The
facility will achieve significant degree of recycling of the reagents that are used in the
process. This will be a first facility of this type in the USA, and there are no effluent
guidelines for Zinc recycling facilities.
The facility went through a bankruptcy in 2016 and has not produced any zinc since that
time. It is currently undergoing substantial changes and improvements to the production and
wastewater facilities. It is scheduled to re -open in the Spring of 2019.
Potable water and sanitary sewer service for the facility is provided by the Forrest City.
Antidegradation review
Per NC antidegradation policy (15A NCAC 2B.0201, each applicant for an NPDES permit
expansion must document an effort to consider non -discharge alternatives pursuant to 15A
NCAC 2H.0105(c)(2). The original estimates for the wastewater flow submitted by the
Page 1 of 9

NPDES Permit Fact Sheet — 04/ 16/ 19 American Zinc Products, LLC
Page 2 NC0089109
facility prior to the beginning of the production were incorrect. The facility employs a new
technology that has not been used for Zinc production in this country. Therefore, it was
difficult to correctly calculate a flow limit for the new facility, the re -calculated flow estimate
is 0.98 MGD. The updated EAA was submitted by the facility on September 6, 2017. The
EAA was approved on September 29, 2017, it allows discharge of 0.98 MGD treated
industrial wastewater. The wastewater generated by the facility is essentially a clean brine
solution that has a very high concentration of chlorides (17,000 mg/L). Hence, the non -
discharge options are not viable. If this wastewater is discharged to the soil surface or into
the infiltration galleries, it will contaminate the soil and the aquafer. The Forrest City POTW
is also unable to treat this discharge since it will cause a major toxicity problem and likely
destroy the microbial biomass in the treatment system, which will result in a complete failure
of the POTW.
Therefore, DWR staff concurred with the EAA conclusion that expansion at the current
location was the most environmentally sound alternative from the reasonably cost-effective
options (per 15A NCAC 2H.0105).
Compliance Schedule
Due to the recent changes in the state water quality standards, the new dissolved state
standard for Cadmium has become more stringent. Review of the effluent data indicated that
the facility will not be able to comply with the new permit limit for Cadmium. The facility
conducted a bench -scale testing with the effluent to evaluate various treatment options.
Based on the results of the test the facility proposed a 10-year compliance schedule. The
Division discussed the schedule with the applicant and negotiated a reduced compliance
schedule of 7.5 years, it will be added to the permit.
Compliance History
The facility has experienced numerous production and compliance issues since the start-up,
which led to the bankruptcy in February of 2016. The facility has been purchased by a new
owner and completed several improvement projects.
RPA
The RPA (reasonable potential analysis) was updated to incorporate a new flow limit of 0.98
MGD. The modification application identified the number of pollutants that might be
present in the discharge. The RPA was conducted for these pollutants: arsenic, cadmium,
chlorides, chromium, copper, fluoride, lead, nickel, zinc, tin, and antimony.
The RPA indicated that the limits are necessary for total cadmium. Due to the recent
updates to the state standard, the cadmium standard has been significantly reduced. The
facility requested a compliance schedule to design a treatment system for cadmium removal.
The compliance schedule was added to the permit.
Page 2 of 9

NPDES Permit Fact Sheet — 04/ 16/ 19
Page 3
Summary of Permittine Actions
American Zinc Products, LLC
NC0089109
Parameter
Current Permit
Proposed
Change
Basis for Condition/Change
Flow
0.8 MGD
0.98 MGD
15A NCAC 2H.0105
NH3-N
Quarterly monitoring
No change
Parameter of concern
TSS
Monitoring - 2/Month
No change
Parameter of concern
Total Aluminum
Quarterly monitoring
No change
Parameter of concern
Total Antimony
Quarterly monitoring
No change
Parameter of concern
Total Arsenic
Quarterly monitoring
No change
Parameter of concern
Total Cadmium
MA 0.27 mg/L
DM 1.66 mg/L
MA 90.4 µg/L
DM 454.4 µg
WQBEL. State WQ standard, 15A
NCAC 2B .0200. New limits are based
on the new dissolved standard
Chlorides
Quarterly monitoring
No change
Parameter of concern
Total Chromium
MA 6.75 mg/L
DM 113.6 mg/L
Limit and
Based on the results of the Reasonable
Potential Analysis. Total Chromium is
no longer has a state standards.
monitoring
removed
Chromium (VI)
No requirement
Quarterly
monitoring
Parameter of concern, monitoring
added because the valence of the
chromium present in the discharge is
unknown
Total Cobalt
Quarterly monitoring
No change
Parameter of concern
Total Copper
Quarterly monitoring
No change
Parameter of concern
Total Fluoride
MA 243.2 mg/L
DM 243.2 mg/L
Limit removed,
Based on the results of the Reasonable
Potential Analysis.
Quarterly
monitoring
Total Iron
Quarterly monitoring
No change
Parameter of concern
Total Lead
' MA 3.37 mg/L
DM 3.75 mg/L
Limit removed,
Based on the results of the Reasonable
Potential Analysis.
Monitoring -
2/Month
Total Nickel
Monthly monitoring
No change
Parameter of concern
Total Tin
Quarterly monitoring
No change
Parameter of concern
Total Zinc
Monitoring - 2/Month
No change
Parameter of concern
pH
6.0 — 9.0 SU
No change
WQBEL. State WQ standard, 15A
NCAC 2B .0200
Toxicity Test
Chronic limit, 0.74%
effluent.
Chronic limit,
0.9% effluent.
WQBEL. No toxics in toxic amounts.
15A NCAC 2B.0200 and 15A NCAC
2B.0500
Turbidity
Monitoring in the
effluent, upstream and
downstream
No change
Parameter of concern
Fish tissue
monitoring
No requirement
Sampling one
time during the
permit cycle
Added to address a comment from the
regional office
Priority Pollutant
Scan
No requirement
Sampling one
time during the
permit cycle
Added to address a comment from the
regional office
Page 3 of 9

NPDES Permit Fact Sheet - 04/ 16/ 19 American Zinc Products, LLC
Page 4 NC0089109
MA- monthly average
DM -Daily Maximum
Antibacksliding Review
Sections 402(o)(2) and 303(d)(4) of the CWA and federal regulations at 40 CFR 122.44(1)
prohibit backsliding of effluent limitations in NPDES permits. These provisions require
effluent limitations in a reissued permit to be as stringent as those in the previous permit,
with some exceptions where limitations may be relaxed (e.g., based on new information,
increases in production may warrant less stringent TBEL limits, or WQBELs may be less
stringent based on updated RPA or dilution).
Are any effluent limitations less stringent than previous permit (YES/NO): NO
If YES, confirm that antibacksliding provisions are not violated: N/A
Proposed Schedule for Permit Issuance
Per 15A NCAC 2H .0109 & .0111, The Division will receive comments for a period of 30
days following the publication date of the public notice. Any request for a public hearing
shall be submitted to the Director within the 30-day comment period indicating the interest
of the party filing such request and the reasons why a hearing is warranted.
Draft Permit to Public Notice: January 29, 2019 (est.)
Permit Scheduled to Issue: March 20, 2019 (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].
Changes in the Final Permit
The Final Permit contains no significant changes from the Draft Permit.
Fact Sheet Attachments
• RPA Spreadsheet Summary
• Dissolved Metals Implementation/Freshwater or Saltwater
Page 4 of 9

Page 5
NPDES Permit Fact Sheet - 04/ 16/ 19 American Zinc Products, LLC
NC0089109
NPDES Implementation of Instream Dissolved Metals Standards - Freshwater
Standards
The NC 2007-2015 Water Quality Standard (WQS) Triennial Review was approved by the NC Environmental
Management Commission (EMC) on November 13, 2014. The US EPA subsequently approved the WQS
revisions on April 6, 2016, with some exceptions. Therefore, metal limits in draft permits out to public notice
after April 6, 2016 must be calculated to protect the new standards - as approved.
Table 1. NC Dissolved Metals Water Quality Standards/Aquatic Life Protection
Parameter
Acute FW, µg/1
(Dissolved)
Chronic FW, µg/1
(Dissolved)
Acute SW, µg/1
(Dissolved)
Chronic SW, pg/1
(Dissolved)
Arsenic
340
150
69
36
Beryllium
65
6.5
---
---
Cadmium;
Calculation
Calculation
40
8.8
Chromium •III
Calculation
Calculation
---
---
Chromium VI
16
11
1100
50
Copper
Calculation
Calculation
4.8
3.1
Lead
Calculation
Calculation
210
8.1
Nickel
Calculation
Calculation
74
8.2
Silver
Calculation
0.06
1.9
0.1
Zinc
Calculation
Calculation
90
81
Table 1 Notes:
1. FW= Freshwater, SW= Saltwater
2. Calculation = Hardness dependent standard
3. Only the aquatic life standards listed above are expressed in dissolved form. Aquatic
life standards for Mercury and selenium are still expressed as Total Recoverable
Metals due to bioaccumulative concerns (as are all human health standards for all
metals). It is still necessary to evaluate total recoverable aquatic life and human
health standards listed in 15A NCAC 2B.0200 (e.g., arsenic at 10 µg/1 for human
health protection; cyanide at 5 µg/L and fluoride at 1.8 mg/L for aquatic life
protection).
Table 2. Dissolved Freshwater Standards for Hardness -Dependent Metals
The Water Effects Ratio (WER) is equal to one unless determined otherwise
under 15A NCAC 02B .0211 Subparagraph (11)(d)
Metal
NC Dissolved Standard, µg/1
Cadmium, Acute
WER* { 1.136672-[In hardness] (0.041838) } • e^ {0.9151 [In hardness]-
3.1485)
Cadmium, Acute Trout
waters
WER* { 1.136672-[In hardness] (0.041838) } • e^ {0.9151 [In hardness] -
3.6236)
Cadmium, Chronic
WER*{1.101672-[ln hardness](0.041838)} • e^{0.7998[ln hardness]-
4.4451)
Chromium III, Acute
WER*0.316 • e^ {0.8190[ln hardness]+3.7256}
Chromium III, Chronic
WER*0.860 • e^ {0.8190[ln hardness]+0.6848}
Page 5 of 9

NPDES Permit Fact Sheet — 04/ 16/ 19
Page 6
American Zinc Products, LLC
NC0089109
Copper, Acute
WER*0.960 • e^ {0.9422[ln hardness]-1.700}
Copper, Chronic
WER*0.960 • e^ {0.8545[ln hardness]-1.702)
Lead, Acute
WER* { 1.46203-[ln hardness] (0.145712) } •
1.460}
e^ { 1.273 [ln hardness]-
Lead, Chronic
WER* { 1.46203-[ln hardness] (0.145712) } •
4.705 }
e^ { 1.273 [ln hardness]-
Nickel, Acute
WER*0.998 • e^ {0.8460[ln hardness]+2.255)
Nickel, Chronic
WER*0.997 • e^ {0.8460[ln hardness]+0.0584}
Silver, Acute
WER*0.85 • e^{1.72[ln hardness]-6.59}
Silver, Chronic
Not applicable
Zinc, Acute
WER*0.978 • e^ {0.8473[ln hardness]+0.884}
Zinc, Chronic
WER*0.986 • e^ {0.8473[ln hardness]+0.884}
. General Information on the Reasonable Potential Analysis (RPA)
The RPA process itself did not change as the result of the new metals standards. However,
application of the dissolved and hardness -dependent standards requires additional
consideration in order to establish the numeric standard for each metal of concern of each
individual discharge.
The hardness -based standards require some knowledge of the effluent and instream
(upstream) hardness and so must be calculated case -by -case for each discharge.
Metals limits must be expressed as `total recoverable' metals in accordance with 40 CFR
122.45(c). The discharge -specific standards must be converted to the equivalent total values
for use in the RPA calculations. We will generally rely on default translator values developed
for each metal (more on that below), but it is also possible to consider case -specific
translators developed in accordance with established methodology.
RPA Permitting Guidance/WOBELs for Hardness -Dependent Metals - Freshwater
The RPA is designed to predict the maximum likely effluent concentrations for each metal of concern, based
on recent effluent data, and calculate the allowable effluent concentrations, based on applicable standards and
the critical low -flow values for the receiving stream.
If the maximum predicted value is greater than the maximum allowed value (chronic or
acute), the discharge has reasonable potential to exceed the standard, which warrants a
permit limit in most cases. If monitoring for a particular pollutant indicates that the pollutant
is not present (i.e. consistently below detection level), then the Division may remove the
monitoring requirement in the reissued permit.
1. To perform a RPA on the Freshwater hardness -dependent metals the Permit Writer
compiles the following information:
Page 6 of 9

NPDES Permit Fact Sheet — 04/ 16/ 19 American Zinc Products, LLC
Page 7 NC0089109
• Critical low flow of the receiving stream, 7Q10 (the spreadsheet
automatically calculates the 1Q10 using the formula 1Q10 = 0.843 (s7Q10,
cfs) 0.993
• Effluent hardness and upstream hardness, site -specific data is preferred
• Permitted flow
• Receiving stream classification
2. In order to establish the numeric standard for each hardness -dependent metal of
concern and for each individual discharge, the Permit Writer must first determine
what effluent and instream (upstream) hardness values to use in the equations.
The permit writer reviews DMR's, Effluent Pollutant Scans, and Toxicity Test results
for any hardness data and contacts the Permittee to see if any additional data is
available for instream hardness values, upstream of the discharge.
If no hardness data is available, the permit writer may choose to do an initial
evaluation using a default hardness of 25 mg/L (CaCO3 or (Ca + Mg)). Minimum
and maximum limits on the hardness value used for water quality calculations are 25
mg/L and 400 mg/L, respectively.
If the use of a default hardness value results in a hardness -dependent metal showing
reasonable potential, the permit writer contacts the Permittee and requests 5 site -
specific effluent and upstream hardness samples over a period of one week. The
RPA is rerun using the new data.
The overall hardness value used in the water quality calculations is calculated as follows:
Combined Hardness (chronic)
= (Permitted Flow, cfs *Avg. Effluent Hardness. mg/L) + (s7Q10. cfs *Avg. Upstream Hardness, mg/L)
(Permitted Flow, cfs + s7Q10, cfs)
The Combined Hardness for acute is the same but the calculation uses the 1Q10 flow.
3. The permit writer converts the numeric standard for each metal of concern to a total
recoverable metal, using the EPA Default Partition Coefficients (DPCs) or site -
specific translators, if any have been developed using federally approved
methodology.
Page 7 of 9

NPDES Permit Fact Sheet — 04/ 16/ 19
Page 8
4. The
American Zinc Products, LLC •
NC0089109
EPA default partition coefficients or the "Fraction Dissolved" converts the value for
dissolved metal at laboratory conditions to total recoverable metal at in -stream ambient
conditions. This factor is calculated using the linear partition coefficients found in The
Metals Translator: Guidance for Calculating a Total Recoverable Permit Limit from a
Dissolved Criterion (EPA 823-B-96-007, June 1996) and the equation:
Cdis4
Ctotal
1
1 + { [K1,0] [ss(l'al [1e] }
Where:
ss = in -stream suspended solids concentration [mg/1], minimum of 10 mg/L used, and
Kpo and a = constants that express the equilibrium relationship between dissolved and
adsorbed forms of metals. A list of constants used for each hardness -dependent metal can
also be found in the RPA program under a sheet labeled DPCs.
numeric standard for each metal of concern is divided by the default partition
coefficient (or site -specific translator) to obtain a Total Recoverable Metal at ambient
conditions.
In some cases, where an EPA default partition coefficient translator does not exist
(ie. silver), the dissolved numeric standard for each metal of concern is divided by
the EPA conversion factor to obtain a Total Recoverable Metal at ambient
conditions. This method presumes that the metal is dissolved to the same extent as it
was during EPA's criteria development for metals. For more information on
conversion factors see the June, 1996 EPA Translator Guidance Document.
5. The RPA spreadsheet uses a mass balance equation to determine the total allowable
concentration (permit limits) for each pollutant using the following equation:
Ca = (s7Q10 + Qw) (Cwqs) — (s7Q10) (Cb)
Qw
Where: Ca = allowable effluent concentration (µg/L or mg/L)
Cwqs = NC Water Quality Standard or federal criteria (µg/L or mg/L)
Cb = background concentration: assume zero for all toxicants except NH3* (µg/L or mg/L)
Qw = permitted effluent flow (cfs, match s7Q10)
s7Q10 = summer low flow used to protect aquatic life from chronic toxicity and human health
through the consumption of water, fish, and shellfish from noncarcinogens (cfs)
* Discussions are on -going with EPA on how best to address background concentrations
Flows other than s7Q10 may be incorporated as applicable:
1Q10 = used in the equation to protect aquatic life from acute toxicity
QA = used in the equation to protect human health through the consumption of water, fish,
and shellfish from carcinogens
30Q2 = used in the equation to protect aesthetic quality
Page 8 of 9

NPDES Permit Fact Sheet — 04/ 16/ 19 American Zinc Products, LLC
Page 9 NC0089109
6. The permit writer enters the most recent 2-3 years of effluent data for each pollutant
of concern. Data entered must have been taken within four and one-half years prior
to the date of the permit application (40 CFR 122.21). The RPA spreadsheet
estimates the 95th percentile upper concentration of each pollutant. The Predicted
Max concentrations are compared to the Total allowable concentrations to
determine if a permit limit is necessary. If the predicted max exceeds the acute or
chronic Total allowable concentrations, the discharge is considered to show
reasonable potential to violate the water quality standard, and a permit limit (Total
allowable concentration) is included in the permit in accordance with the U.S.
EPA Technical Support Document for Water Quality -Based Toxics Control
published in 1991.
7. When appropriate, permit writers develop facility specific compliance schedules in
accordance with the EPA Headquarters Memo dated May 10, 2007 from James
Hanlon to Alexis Strauss on 40 CFR 122.47 Compliance Schedule Requirements.
8. The Total Chromium NC WQS was removed and replaced with trivalent chromium
and hexavalent chromium Water Quality Standards. As a cost savings measure, total
chromium data results may be used as a conservative surrogate in cases where there
are no analytical results based on chromium III or VI. In these cases, the projected
maximum concentration (95th %) for total chromium will be compared against water
quality standards for chromium III and chromium VI.
9. Effluent hardness sampling and instream hardness sampling, upstream of the
discharge, are inserted into all permits with facilities monitoring for hardness -
dependent metals to ensure the accuracy of the permit limits and to build a more
robust hardness dataset.
10. Hardness and flow values used in the Reasonable Potential Analysis for this permit
included:
Parameter
Value
Comments (Data Source)
Average Effluent Hardness
(mg/L)
[Total as, CaCO3 or (Ca+Mg)]
25.0
Default value
Average Upstream Hardness
(mg/L)
[Total as, CaCO3 or (Ca+Mg)]
25.0
Default value
7Q10 summer (cfs)
0
Lake or Tidal
1Q10 (cfs)
0
Lake or Tidal
Permitted Flow (MGD)
2.1
For dewatering
Page 9 of 9

AFFP
Public Notice North Carolina E
Affidavit of Publication
STATE OF NORTH
CAROLINA }
COUNTY OF RUTHERFORD
SS
Erika Meyer, being duly sworn, says:
That she is Advertising Manager of the The Daily Courier,
a daily newspaper of general circulation, printed and
published in Forest City, Rutherford County, North
Carolina; that the publication, evidenced hereto, was
published in the said newspaper on the following dates:
February 08, 2019
That said newspaper was regularly issued and circulated
on those dates.
SIGNED;
Advertising Manager
Subscribed to and sworn to me this 8th cl,Aot;O'l bry�ry
2019. ���O\AA ......i.i
Public Notice
North Carolina Environmental
Management Commission/
NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Notice of Intent to Issue a NP-
DES Wastewater Permit
The North Carolina Environ-
mental Management Commis-
sion proposes to issue a NP-
DES wastewater discharge
permit to the person(s) listed
below. Written comments re-
garding the proposed permit
will be accepted until 30 days
after the publish date of this
notice. The Director of the NC
Division of Water Resources
(DWR) may hold a public
hearing should there be a sig-
nificant degree of public in-
terest. Please mail comments
and/or information requests to
DWR at the above address.
Interested persons may visit
the DWR at 512 N. Salisbury
Street, Raleigh, NC to review
information on file. Additional
information on NPDES per-
mits and this notice may be
found on our website:
= c: Z _ http:/!deq. nc.gov/about/divi-
= y . ''UBi.\c, /. signs/water-resources/water-
Donna Petty, Notary, Rutherfor Co �0, Sor1h l a�� resources-permitS,wastewa-
'1.,,PRDcoo.•` ter-branchInpdes-
My commission expires: October 26, 2022�'f'���i���� wastewater/public-notices,or
30086891 30851668 919-807-6495
WREN THEDFORD (FC)
DEQ-DIVISION OF WATER RESOURCES (FC)
1617 MAIL SERVICE CENTER
RALEIGH, NC 27699-1617
by calling [phone]
Basin. The American Zinc
Products, LLC requested a re-
newal of permit NC0089109
for Rutherford County Produc-
tion Facility in Rutherford
County; this facility discharge
is treated industrial wastewa-
ter to Broad River, Broad
River Basin.
February 8. 2019

.5efv3e4
(' ,

B —The Daily Courier, Friday, February 8, 2019 • www.thedigitalcourier.com
0955 Legals
0955 Legals
0955 Legals
0955 Legals
0955 Le
said JEWELL B
AGE TT, to pesent them to
undersgned cn or before
8th day of May, 2019 or
same will be pleaded in
of their recovery All
sons indebted to said
ate will please make
nediate payment.
s is the 8th day of
bruary, 2019
neon Keith Campbef
ninistrat-CTA
Cam pgroLnd Rd.
nbcro, NC 28040
,2f15,2122,endVn201I
III Your Purse Through
%%tlr a Classifieds Oe491
NORTH CAROLINA
RUTHERFORD COUNTY
NOTICE TO CRE DITORS
THE UNDERSIGNED. having
qualified as EXECUTOR of
the Estate cf RUTH AMOS
PEACE, deceased late of
RUTHERFORD County, this is
to notty all persons, trims, and
corporatons ha••ing claims
CALL THE
DAILY COURIER TO
SUBSCRIBE TODAY!
828-202-7794
aganst sad Estate to pesent
them to the unde's geed on or
tefcre the 18th day of, APRIL.
2019 or this Notce wl! be
pleaded in tar of their recov-
ery All persons indebted to
said estate pease ma-e im-
m ed ate rem eat to the under-
signed.
This the 18th day of JANU-
ARY, 2019
Detra F Peace
65 Long B-anch Rove
Forest Oty, NC 24. 043
January13, 25, February 1,8,
2019
Pubic Notice
North CarotnaEnvironmental
Management Commission/
NPDES Unit
16'. 7 Mail Ser 4ce Center
Rae:ah, NC27699-1617
NOIce of 'ntent to Issue a NP-
DES Wastewater Permit
The North Carolina Environ-
mental Management Commis -
sort proposes to issue a NP-
AWAY WITH A BARGAIN
II It C�I$$ITIEEE
DES wastewater discharge
permit tc the persons) listed
below Written comments re-
garding the proposed permit
witl be accepted untl 30 days
attar the puliisn date of this
Hotta Tne Director of the NC
Division of Water Resources
(DWR) may hold a public
hearing shou d there to a sig-
nificant degree of public in-
terest. Please mail comments
and/or .nformaton requests to
DWR at the above adcress.
Interested persons may vsit
the DWR at 512 N. lsllisbury
Street, Raleigh, NC to review
information on file. Add tonal
information on NPDES per -
trite and frs notice mad
found on our weos
http./hreq.nc.gov/aboutr
s on s Awster -re scurcestwe
resources-permits/waste
ter-branch/npde
waste taster /pu b is -no Ice
by calling (919.) 707-6
Basin. The American
Products, LLCrequested i
newal of permit N00089
for Rutherford C ountyPr or
ton Facility in Ruined
County, this fad[ ty
is treated industrial waste
ter to Eroad R. ver. Br
River Basin.
Februxy8, 2019
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2 Your Specs

TIMOTHY R. BASILONE
Vice President — Environmental Affairs
AMERICAN
ZINC RECYCLING
Delivering a Sustainable Future
3000 GSK Drive T 724-773-2223
Suite 201 F 412-788-4526
Moon Township, PA 15108
www.azr.com
[e-mail]
March 4, 2019
Dr. Sergei Chernikov
Complex NPDES Permitting Unit
North Carolina Division of Water Resources
Department of Environmental Quality
1617 Mail Service Center
Raleigh, NC 27699-1611
Dear Dr. Chernikov:
RECEtVED/DNR/DWR
MAR 062019
1N�f RQsources
Permitting Section
R.E. Draft NPDES Process Discharge Permit
Permit Number NC 0089109
American Zinc Products, LLC
Rutherford County
North Carolina
Thank you for the opportunity to provide comments on the draft NPDES process discharge
permit for the Mooresboro, NC facility. It is our understanding that this draft permit was
provided to coincide with issuance of the formal public notice, as required by NC regulations.
American Zinc Products (AZP) is providing comments herein in advance of the permit being
finalized. We request that information provided in this letter is addressed before the final
permit is issued.
In general, the permit reflects conditions that AZP reviewed and discussed with you previously.
Our comments are primarily related to certain conditions in the draft permit that were not
previously reviewed or discussed with you, in addition to several editorial changes.
Our primary comment relates to the added condition requiring fish tissue monitoring for
arsenic, cadmium and zinc. Our understanding as to the reason for this addition, as cited in your
cover letter, is that the Regional Office indicated concern regarding the potential for
bioaccumulation of these metals in fish, and potential associated ecological impacts.
Based on our preliminary review of this matter, it appears there is limited information available
for monitoring arsenic, cadmium and zinc in fish. In addition, published information regarding
the ecological impact from the presence of these metals in fish is apparently not well
established.
Before proposing a specific monitoring program, we believe it would be best to first understand
the potential for bioaccumulation of the subject metals in fish. Once the potential for

bioaccumulation is understood, the potential ecological effect can be evaluated. Information
gathered as part of this initial step can be used to develop an appropriate monitoring program,
if it is determined to be necessary. The attached Word file provides suggested revisions to this
condition.
The draft permit also includes a priority pollutant analysis monitoring requirement. This
condition is not included in the current permit for the facility. The reason cited for inclusion is
that the Regional Office requested the condition be added. We do not anticipate the presence
of any parameters beyond those already reflected in our application.
There are several suggested editorial revisions provided in the attached electronic Word
document. These are offered only as clarifications or to more accurately reflect the operational
aspects of this facility.
In addition to the draft permit, we have also reviewed the permit Fact Sheet and have offered
some minor edits. These changes are reflected in the attached electronic Word document.
If there are any questions concerning our comments and proposed revisions, please let me
know. We would be glad to discuss our comments with you.
Sincerely,
•
Timothy R. Basilone
Encls.

American Zinc Products, LLC
NC0089109
Freshwater RPA -
Qw (MGD) _
1Q1OS (cfs) _
7QIOS (cfs) =
7Q10W (cfs) =
30Q2 (cfs) =
Avg. Stream Flow, QA (cfs) _
Receiving Stream
0.98
135.83
167.00
334.00
403.00
914.00
: NO HUC NUMBER
95% Probability/95% Confidence Using Metal Translators
MAXIMUM DATA POINTS = 58
WWTP/WTP Class: II
IWC% ® 1QIOS = 1.104825754
IWC% @ 7Q10S = 0.900470545
IWC%©7QIOW = 0.452271558
IWC% Q 30Q2 = 0.375125968
IW%C@QA= 0.165747797
Stream Class: WS
Outfall 001
Qw = 0.979 MGD
COMBINED HARDNESS (ma/LZ
Acute = 41.3 mg/L
Chronic = 38.28 mg/L
PARAMETER
TYPE
(1)
NC STANDARDS OR EPA CRITERIA
J
a
a
F
z
=
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
Chronic
Applied
Standard
AciiI
I1 ;; 1)cl M:ix Tied Ctc Allowable Cw
Arsenic
Arsenic
C
C
150
10
FW(7Q10s)
HH/WS(Qavg)
340
ug/L
ug/L
I I
Note: n < 9
Limited data act
250.0
I>elault C.V.
Acute (FW): 30,774.1
__ -
Chronic (FW): 16,658.0
No value >Allowa_bleC_w__
Ch ronic (HH): 6,033.3
No value > Allowable Cw
no limit
—------------
___________________________
Beryllium
NC
6.5
FW(7Q10s)
65
ug/L
0 0
N/A
Acute: 5'883.28
--Chronic---- 721.84 --
N/A
---------------------------•
Cadmium
NC
08141
FW(7Q10s)
5.0206
ug/L
1 1
Note: n < 9
Limited data set
100.000
Default C.V.
Acute: 454.428
- _ _ _--__ _ __—_—_—_—_—_—_—_—_—
Chronic 90.410
I value(s)> Allowable Cw
add limit
——_—_—_—_.
Chlorides
NC
230
FW(7Q10s)
mgt.
I 1
Note: n < 9
Limited data set
17,000.0
Default C.V
Acute: NO WQS
-_ _ _ _--__ _ _
Chronic 25,542.2
No value > Allowable Cw
no limit
— — — — — — — — — — — —
Chlorinated Phenolic Compounds
NC
I
A(30Q2)
ug/L
0 0
N/A
Acute: NO WQS
Chronic: 266.E
N/A
Total Phenolic Compounds
NC
300
A(30Q2)
ug/L
0 fI
N/A
Acute: NO WQS
_ Ch_ — — _ _ _ -
ronic: 79,973. I
N/A
— — — — — — — — — —
Chromium 111
NC
1(6.8998
F11'(7Q1Os)
1 305 2270
ug/L
0 II
N A
Acute: 123,569.5
_ _ — _8,53__
Chronic: 14.7
N/A
— — — — — — — — — — — — —
Chromium VI
NC
II
FW(7Q10s)
Ih
ug/L
0 0
NA
Acute: 1,448.2
Chronic: 1 221.6
N/A
Chromium, Total
NC
nil_
Tot Cr value
I 1
Note: n<9
I.intited data se'
50 and < Cr VI
4.0
Default C.V.
Allowable Cw
Max reported value = 4
no limit
Page 1 of 3
89109-RPA-2019, rpa
1/14/2019

American Zinc Products, LLC
NC0089109
Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators
Outfail 001
Qw = 0.979 MGD
Copper
NC
11.3420 FW(7Q10s) 16.8035
ug/L
1 I
Note: n < 9
Limited data set
160.00
Default C.V
Acute: 1,520.92
__ _ _ _____ _ ___
Chronic: 1,259.56
No value > Allowable Cw
no limit
________---- ______________,
Cyanide
NC
5 FW(7Q10s) 22
10
mil.,
0 0
N'A
Acute: 1,991.3
Chronic: 555.3
N/A
Fluoride
NC
1500 FW(7Q10s)
ug/L
1 I
Note: n<''
Limited data set
20,000.0
Default C.V.
. Acute: NO WQS
-_ _ _ _-___ _ _ _
Chronic: 199,895.5
No value > Allowable Cw
no limit
— _ _ — _ _ _ _ ___ _ ____
Lead
NC
4 7437 FW(7Q10s) 132.4722
ug/L
1 1
Note: n 5 9
Limited data se
500.000
Default C.V.
Acute: 11,990.324
_ _ _ __ _ ___
Chronic: 526.806
No value > Allowable Cw
no limit
__________ _________________ .
Mercury
NC
12 FW(7Q10s)
0.5
nt1_
0 0
N A
Acute: NO WQS
_ _ ro_ — _ _ _-
Chnic: 1,332.E
N/A
— — — — — — — — — — — — —
Molybdenum
NC
2000 HH(7Q10s)
uvl.
0 0
N'A
Acute: NO WQS
—Chronic: 222.106. t
N/A
Nickel
Nickel
NC
NC
53.3905 FW(7Q10s) 512.5282
25.0000 WS(7QIOs)
pg-L
µg/L
1 I
Note: n < /
Limited data set
150.0
Default C.V.
Acute (FW): 46,390.0
__ _ _ _ ___ _ ___
Chronic (FW): 5,929.2
No value> Allowable Cw _
Chronic(WS): 2,776.3 --
No value > Allowable Cw
no limit
___________________________,
— — — — — — — — — — — — —
Selenium
NC
•
5 FW(7Q10s) 56
00,
0 0
N/A
Acute: 5,068.7
—_ _ --_ _ --
Chronic: 555.3
N/A
_---------------------__--- •
Silver
NC
0.06 FW(7Q10s) 0.7027
ug/L
0 0
N/A
Acute: 63.605
Chronic: 6.663
N/A
Zinc
NC
ICI 8392 FW(7Q10s) 192.3265
ug/L
I 1
Note: n<9
Limited data set
4,000.0
Default C.V.
Acute: 17,407.9
__ _-_-_-_ _ ___
Chronic: 20,193.8
No value > Allowable Cw
no limit
___________________________1
I
Tin
NC
S00 HH(7Q10s)
µg/L
I 1
Note: n << 9
Limited data set
1 1.00000
Default C. V
Acute: NO WQS
______ __
Chronic: 88842.43962
No value > Allowable Cw
no limit
__________ _ ____.
Antimony
NC
640 HH(7Q10s)
µg/L
I I
Note: n < 9
limited data set
250.00000
Default C.V.
Acute: NO WQS
__ __ _ _ _
Chronic: 71073.95170
No value> Allowable Cw
no limit
____________ _ _ _ ________
I
Acute:
Page 2 of 3
89109-RPA-2019, ma
1 /14/2019

REASONABLE POTENTIAL ANALYSIS
H1
Effluent Hardness
Date Data BDL=112DL Results
1 1500 1500 Std Dev.
2 Mean
3 C.V.
4 n
5 10th Per value
6 Average Value
7 Max. Value
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
Use "PASTE SPECIAL.
Values" then "COPY"
. Maximum data
points = 58
H2
Upstream Hardness
N/A
1500.0000
0.0000
1
1500.00 mg/L
1500.00 mg/L
1500.00 mg/L
Use"PASTE SPECIAL,
Values" then "COPY"
. Maximum data
points = 58
Date Data BDL=112DL Results
1 25 25 Std Dev. N/A
2 Mean 25.0000
3 C.V. 0.0000
4 n 1
5 10th Per value 25.00 mg/L
6 Average Value 25.00 mg/L
7 Max. Value 25.00 mg/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
89109-RPA-2019, data
- 1 - 1/14/2019

REASONABLE POTENTIAL ANALYSIS
Par01 & Par02
Arsenic
Date Data BDL=112DL Results
1 250 250 Std Dev.
2 Mean
3 C.V.
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
Use "PASTE SPECIAL.
Values" then "COPY"
. Maximum data
points = 58
N/A
250.0000
0.0000
1
1.00
250.0 ug/L
250.0 ug/L
89109-RPA-2019, data
- 2 - 1/14/2019

REASONABLE POTENTIAL ANALYSIS
Par03
Beryllium
Date Data BDL=1/2DL Results
Std Dev.
Mean
C.V.
n
MuIt Factor =
Max. Value
Max. Pred Cw
Use "PASTE SPECIAL.
Values" then "COPY"
. Maximum data
points = 58
Par04
Cadmium
NO DATA
NO DATA
NO DATA
0
N/A
N/A ug/L
N/A uglL
Date Data BDL=1/2DL Results
100 Std Dev.
Mean
C.V.
n
Mult Factor =
Max. Value
Max. Pred Cw
100
Use "PASTE SPECIAL.
Values" then "COPY"
Maximum data
points = 58
N/A
100.0000
0.0000
1
1.00
100.000 ug/L
100.000 ug/L
89109-RPA-2019, data
- 3 - 1/14/2019

REASONABLE POTENTIAL ANALYSIS
Par05
Chlorides
Date Data
17000
BDL=1/2DL Results
17000 Std Dev.
Mean
C.V.
n
Mutt Factor =
Max. Value
Max. Pred Cw
Use "PASTE SPECIAL -
Values" then "COPY" .
Maximum data points =
58
N/A
17,000.0
0.0000
1
1.0
17000.0 mg/L
17,000.0 mg/L
Par06
Use"PASTE SF
Values- then "I
Maximum c
points = 5
Date Data BDL=1l2DL Results
1 Std Dev. NO DATA
2 Mean NO DATA
3 C.V. NO DATA
4 n 0
5
6 Mutt Factor = N/A
7 Max. Value N/A
8 Max. Pred Cw N/A
9
Chlorinated Phenolic Compounds
-4-
89109-RPA-2019, data
1/14/2019

REASONABLE POTENTIAL ANALYSIS
Par07
Total Phenolic Compounds
Date Data BDL=1!2DL Results
1 Std Dev.
2 Mean
3 C.V.
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
Use "PASTE SPECIAL.
Values" then "COPY"
. Maximum data
points = 58
Par08
Chromium Ill
NO DATA
NO DATA
NO DATA
0
Mult Factor = N/A
Max. Value N/A ug/L
Max. Pred Cw N/A ug/L
Use "PASTE SF
Values" then "I
. Maximum <
points = 5
Date Data BDL=1/2DL Results
1 Std Dev. NO DATA
2 Mean NO DATA
3 C.V. NO DATA
4 n 0
5
6 Mult Factor = N/A
7 Max. Value N/A
8 Max. Pred Cw N/A
58
89109-RPA-2019, data
- 5 - 1/14/2019

REASONABLE POTENTIAL ANALYSIS
'ECIAL
COPY"
iata
;g
Par09
Chromium VI
pg/L
pg/L
Date Data BDL=1/2DL Results
1 Std Dev.
2 Mean
3 C.V.
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
Use "PASTE SPECIAL.
Values" then "COPY"
. Maximum data
points = 58
Par10
Chromium, Total
NO DATA
NO DATA
NO DATA
0
N/A
N/A pg/L
N/A pg/L
Date Data BDL=1/2DL Results
1 4 4 Std Dev.
2 Mean
3 C.V.
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
Use"PASTE SF
Values" then "I
.Maximum[
points = 5
N/A
4.0000
0.0000
1
1.00
4.0
4.0
89109-RPA-2019, data
- 6 - 1/14/2019

REASONABLE POTENTIAL ANALYSIS
'ECIAL.
:OPY"
tuta
8
Pal
Copper
1
2
3
4
5
6
pg/L 7
pg/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
nata nat.
160
BDL=1/2DL Results
160 Std Dev.
Mean
C.V.
n
Mult Factor =
Max. Value
Max. Pred Cw
Use "PASTE SPECIAL.
Values" then "COPY"
. Maximum data
points = 58
Par12
Cyanide
N/A
160.0000
0.0000
1
1.00
160.00 ug/L
160.00 ug/L
Use "PASTE SF
Values" then "I
. Maximum c
points = 5
Date Data BDL=1/2DL Results
1 Std Dev. NO DATA
2 Mean NO DATA
3 C.V. NO DATA
4 n 0
5
6 Mult Factor = N/A
7 Max. Value N/A
8 Max. Pred Cw N/A
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
89109-RPA-2019, data
- 7 - 1/14/2019

REASONABLE POTENTIAL ANALYSIS
Par13
Fluoride
ug/L
ug/L
Date Data BDL=1/2DL Results
1 20000 20000 Std Dev.
2 Mean
3 C.V.
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
Use "PASTE SPECIAL
Values" then "COPY"
. Maximum data
points = 58
NIA
20000.0000
0.0000
1
1.00
20000.0 ug/L
20000.0 ug/L
Par14
Use"PASTE SF
Values" then "I
. Maximum
points = 5
Date BDL=112DL Results
1 500 500 Std Dev. N/A
2 Mean 500.0000
3 C.V. 0.0000
4 n 1
5
6 Mult Factor = 1.00
7 Max. Value 500.000
8 Max. Pred Cw 500.000
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
Lead
89109-RPA-2019, data
-8- 1/14/2019

REASONABLE POTENTIAL ANALYSIS
!ECIAL'
SOPY"
tab
Par15
Mercury
ug/L
ug/L
Date Data BDL=1/2DL Results
1 Std Dev.
2 Mean
3 C.V.
4 n
5
6 Mutt 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
Use "PASTE SPECIAL.
Values" then "COPY"
. Maximum data
points = 58
NO DATA
NO DATA
NO DATA
0
N/A
N/A ng/L
N/A ng/L
Par16
Use"PASTE SF
Values" then "I
. Maximum
points = 5
Date Data BDL=1/2DL Results
1 Std Dev. NO DATA
2 Mean NO DATA
3 C.V. NO DATA
4 n 0
5
6 Mutt Factor = N/A
7 Max. Value N/A
8 Max. Pred Cw N/A
9
Molybdenum
89109-RPA-2019, data
- 9 - 1/14/2019

REASONABLE POTENTIAL ANALYSIS
Par17 & Par18
ECW.
OPY"
m
Date Data BDL=1/2DL Results
1 150 150 Std Dev.
2 Mean
3 C.V.
4 n
5
6 Mult Factor =
ug/L 7 Max. Value
ug/L 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
Nickel
Use"PASTE SPECIAL.
Values" then "COPY"
. Maximum data
points = 58
Par19
Selenium
N/A
150.0000
0.0000
1
1.00
150.0 pg/L
150.0 pg/L
Date Data BDL=1/2DL Results
Std Dev.
Mean
C.V.
n
Mull Factor =
Max. Value
Max. Pred Cw
-10-
89109-RPA-2019, data
1/14/2019

REASONABLE POTENTIAL ANALYSIS
Use "PASTE SPECIAL.
Values" then "COPY"
. Maximum data
points = 58
Par20
Silver
NO DATA
NO DATA
NO DATA
0
N/A
N/A ug/L
N/A ug/L
Date Data BDL=1/2DL Results
Std Dev.
Mean
C.V.
n
Mull Factor =
Max. Value
Max. Pred Cw
Use "PASTE SPECIAL.
Values" then "COPY"
. Maximum data
points = 58
Par21
Zinc
NO DATA
NO DATA
NO DATA
0
N/A
N/A ug/L
N/A ug/L
1
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
Date Data BDL=1/2DL Results
4000 Std Dev.
Mean
C.V.
n
Mull Factor =
Max. Value
Max. Pred Cw
4000
89109-RPA-2019, data
- 11 - 1/14/2019

REASONABLE POTENTIAL ANALYSIS
Use "PASTE SPECIAL
Values" then "COPY"
. Maximum data
points = 58
Par22
Tin
N/A
4000.0000
0.0000
1
1.00
4000.0 ug/L
4000.0 ug/L
Date Data BDL=1/2DL Results
1 Std Dev.
Mean
C.V.
n
Mult Factor =
Max. Value
Max. Pred Cw
Use "PASTE SPECIAL.
Values" then "COPY"
. Maximum data
points = 58
Par23
Antimony
N/A
1.0000
0.0000
1
1.00
1.000000 pg/L
1.000000 Ng/L
1
2
3
4
5
6
7
a
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
Date Data BDL=II2DL
250
250
-12-
89109-RPA-2019, data
1 /14/2019

REASONABLE POTENTIAL ANALYSIS
Results
Std Dev.
Mean
C.V.
n
Use "PASTE SPECIAL
Values.' then "COPY"
. Maximum data
points = 58
Par24
0
N'A
250.0000
0.0000
1
Mull Factor = 1.00
Max. Value 250.000000 pg/L
Max. Pred Cw 250.000000 pg/L
Date Data
BDL=1/2DL Results
Std Dev.
Mean
C.V.
n
Mull Factor =
Max. Value
Max. Pred Cw
Use "PASTE SPECIAL
Values" then "COPY"
. Maximum data
points = 58
Par25
0
NO DATA
NO DATA
NO DATA
0
N/A
N/A
N/A
1
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
Date Data BDL=1/2DL
89109-RPA-2019, data
- 13 - 1/14/2019

REASONABLE POTENTIAL ANALYSIS
Results
Std Dev.
Mean
C.V.
n
Use "PASTE SPECIAL.
Values' then "COPY"
. Maximum data
points = 58
NO DATA
NO DATA
NO DATA
0
Mult Factor = N/A
Max. Value N/A
Max. Pred Cw N/A
-14-
89109-RPA-2019, data
1/14/2019

moELf
FLAMERICAN
ZINC RECYCLING
Delivering a Sustainable Future
Timothy R. Basilone
Vice President — Environmental Affairs
4955 Steubenville Pike T 724-773-2223
Suite 405 F 412-788-4526
Pittsburgh, PA 15205 C 412-287-9871
www.azr.com
[e-mail]
VIA EMAIL AND OVERNIGHT MAIL
December 14, 2018
Dr. Sergei Chernikov, Ph.D.
Environmental Engineer II
North Carolina Dept. of Environment
& Natural Resources
Division of Water Quality
9th Floor — Archdale Building
512 N Salisbury Street
Raleigh, NC 27604
RE: NPDES— Permit Flow Modification Application
Cadmium Compliance Schedule
American Zinc Products LLC
American Zinc Recycling, Mooresboro Facility
Rutherford County, NC
Permit NC0089109
Dear Dr. Chernikov:
RECEIVED/DENR/DWR
DEC 21 2018
Water Resources
Permitting Section
Please find enclosed three copies of the application and supporting information requesting
modification of the NPDES Permit for American Zinc Products LLC (AZP), American Zinc
Recycling's Mooresboro facility in Rutherford County, North Carolina. This application provides
information sup P's re uest for the monthly average flow in the current permit be
increased from 0.8 MGD to 0.98 MGD. In addition, as we discussed on several occasions, AZP is
requesting a permit schedule comply with the anticipated cadmium (Cd) limit in the modified
permit. The attached information will provide details on the need for the requested flow
increase and the Cd compliance schedule. The described revisions are critically important to the
operation of this facility.
Please note that all application information should be considered Confidential Business
Information. Information contained in the application is provided based on the permit
application requirements, consultation with DWR on the information needed to support the
subject requests, and previous discharge information from the facility.
As we have discussed, the AZP Mooresboro facility is undergoing a Restart Project that will
improve the flexibility of the operation, allowing for a successfully restart of the facility and
commencement of commercial zinc production. The requested increase in the flow limit is
necessary to operate the reconfigured facility and to comply with the flow permitted limit.
Because the core production processes and procedures have not been changed, this flow
increase will not change production capacity or significantly affect process materials balances
within the plant. The flow increase reflects improvements made for water management on the
site and comply with all regulatory requirements.

DWR has informed AZP that the NC Water Quality Standards have been revised as a result of
recent changes made to the rules and that the current Cd limit for the facility will be revised to a
lower level. We have discussed with you the effect of this anticipated change, and the fact that
the more stringent limit will likely result in AZP having to significantly modify its process to
reduce the Cd in the process water discharge. DWR advised AZP to include an assessment of the
effect the revised limit would have on operations, and to provide a recommended compliance
schedule to be included into modified the Mooresboro NPDES permit. This permit modification
package includes the results of AZR's assessment.
To facilitate the review of this modification request, we have prepared a Permit Application
Summary that provides an overview of the request and summarizes the supporting application
information.
We appreciate your consideration of this application. As we move toward completion of the
Restart Project early in 2019, we are anxious to complete this permit modification as quickly as
possible. If you have any questions or need any additional information, please contact me. If a
meeting at your office would be helpful to expedite your review of this application, we would be
glad to meet with you.
Sincerely,
rs
Timothy
Enc.
4
. Basilone

PROPRIETARY AND CONFIDENTIAL - Do Not Disclose
contains Confidential Business Information
Permit Application Summary
Guide to Attachments
Mooresboro NPDES Process Effluent Permit Modification Application
Permit NC0089109
Requested Flow Increase
This permit application and the support information requests modification of the existing NPDES
Permit authorizing discharge from the AZR Mooresboro, NC facility (Permit Number
NC0089109), Rutherford County, North Carolina. American Zinc Products (AZP) is the parent
company for this facility. AZP is requesting that the monthly average process discharge flow
limit for the AZR Mooresboro facility be revised to 0.98 MGD. The current monthly average
flow is limited to 0.8 MGD.
The Mooresboro AZR facility is undergoing a significant facilities improvements process
referred to as the Restart Project. This project is summarized in the attached information. An
application for the renewal of the current permit is pending. However, the requested monthly
average flow modification to 0.98 MGD reflects the flow that will be necessary to effectively
operate the facility as configured upon completion of the Restart Project.
As documented in several sections of the reports and materials attached, the Mooresboro
facility's basic process and steps for production of high quality zinc remain the same as those
described in the initial and subsequent applications made previously for this facility. The
requested flow increase to 0.98 MGD is not being requested to change zinc production capacity,
alter materials balances in the process, or revise the basic processes being used to produce zinc.
However, the Restart Project will result in a better and more flexible production facility, more
effective water balance on the site, better by-products management and improved process
management of the facility. The flow increase is essential to accomplishing the goals of the
i Restart Project.
The stormwater footprint of the Mooresboro facility site is being modified by the Restart Project.
By-product temporary storage areas are being covered by roof structures that will prevent any
loss of material from the by-product areas. The overall stormwater management system on the
site is being modified to limit the amount of rainwater that will have to be incorporated into the
process side. Better management of stormwater will help to reduce overall process flow but the
expected amount of stormwater incorporation will still add significant amounts of water to the
process side. This flow adds little in the way of materials or potential pollutants but will add
flow that must be managed. These efforts are aimed at minimizing the potential discharge of
contaminants from the site. The previous water management systems did not effectively account
for these additional flows and past operational efforts demonstrated that the current flow limit
during full plant operational production would be an issue. As a result, the monthly average
permitted flow is expected to exceed the current 0.8 MGD permit limit. A careful evaluation of
the water balance on the site, considering the variability of rainfall/stormwater impacts and
previous experience at the facility, demonstrates that the current flow limit of 0.8 MGD is
inadequate to manage the resultant process flow under all conditions. A monthly average flow

PROPRIETARY AND CONFIDENTIAL - Do Not Disclose
contains Confidential Business Information
limit of 0.98 MGD is essential for effective water balance management on the site. The permit
application attached reflects the needed flow limit.
Attachment 1, NPDES Permit Application —Short Form C
Previous Facility Operations
The historic effluent quality information provided in this package reflects the facility as it was
prior to the initiation of the Restart Project. These data provide a general point of reference on
facility discharge values generated in the last 24 months. The Restart Project facility
improvements under construction will result in better management and control of the process
materials and the byproducts produced at the facility. The historic effluent data is being
provided as requested in the permit application form.
In January 2016, the facility curtailed zinc production, and the associated effluent discharge rate
over the past 24 months has fluctuated, averaging 192,842 gallons on a daily average basis,
which is approximately 2.34 million gallons/month total discharge. Obviously, these flows do
not reflect operations of the production facility at full capacity.
Intermittent flow has occurred at an average of around 12 days per month over the past 24
months. It is anticipated that operations at the current level will continue while the Restart
Project proceeds. Restart of production is expected to begin in Spring 2019. As the facility
ramps up production and begins the process of producing product, flows will increase. As noted,
our evaluation of the site and the operational demands of the facility will generate flows up to the
requested permit limit, 0.98 MGD.
Summary tables of the previous 24 months effluent monitoring are attached for general
reference.
Attachment 3: Table 1, Summary of Effluent Monitoring Results; Table 2, Monthly
Maximum Concentrations; Table 3, Other Monitored Parameters
Compliance Schedule
In 2017 AZP submitted a permit modification request that asked for an increase in flow to 0.98
MGD, monthly average. This request was made following the determination that the Restart
Project would be needed to improve the management of water and materials on the site. DWR
began reviewing this application but communicated with AZP that due to changes in some of the
State's metals water quality standards that cadmium (Cd) limits would become significantly
more stringent than the limits in the current permit. As a result, AZP withdrew this application
so that a careful review of the impact of the lower Cd requirement could be performed. As a
result of this evaluation, AZP has determined that Cd capture in the process may not be sufficient
to reduce the trace concentration of Cd sufficiently in the process discharge to allow the
company to comply with the expected Cd limits. Design, installation and operation of additional
process technologies will most likely be necessary to capture additional Cd and achieve the
2

PROPRIETARY AND CONFIDENTIAL - Do Not Disclose
contains Confidential Business Information
expected Cd limits. Based on discussing this issue with DWR, AZP was advised that the needed
permit flow modification request, when resubmitted, should include a requested compliance
schedule that would allow AZP to meet the anticipated Cd limits that would come with a
modified NPDES Permit.
AZP staff and consultants looked at the logistics of modifying production steps to include
additional removal capability. This represents a significant undertaking and will require
sufficient time to evaluate how the Restart Project facility will operate and measure the actual Cd
content in the process water as it moves through the steps of zinc production. On the basis of
this evaluation, the initial report evaluating and developing a compliance schedule was drafted
and provided to DWR for a preliminary review. The comments received resulted in AZP
revising the prospective schedule to shorten the timeline to achieve compliance. These revisions
resulted in a significant reduction in the schedule. However, it should be noted that the steps in
the proposed compliance schedule that allow for the development of accurate process water Cd
levels are the most critical. AZP has made every effort to consolidate and parallel actions
involving the evaluation of data, development of preliminary design information and to develop
final engineering plans. The demonstration periods involving the achievement of stable
operations must be maintained in order to develop appropriate technologies and actions to
achieve the reduction goals needed to comply with final limitations. This report, "NPDES
Process Discharge Compliance Schedule — Revised Stream Standards," is included in this permit
application package.
The compliance evaluation report notes the change in Cd limit expected in a modified permit
with monthly average flow limit of 0.98 MGD. A copy of the limits page for the current permit
and the limits page from the permit drafted in response to the 2017 application are attached. The
compliance evaluation report includes, in support of the compliance schedule, a discussion of the
facility and the Restart Project along with a summary of the basis for the timeline requested.
AZP's application for renewal of the current permit was filed to meet renewal request
requirements for the current permit. This application included information about mass limits
verses concentration limits. That information points out that due to the significantly larger flow
of the Broad River (even at 7-day, ten-year low flow levels) dominates the determination of
concentration of discharged parameters downstream of the diffused process water discharge.
Because overall mass materials balances from the process will not be affected by the process
discharge flow limit, the mass of each listed potential pollutant, including Cd will not
significantly increase. This is a mitigating factor in considering the compliance schedule
timeline for the modification of the facility's process steps to further reduce Cd in the process
discharge.
Attachment 3, NPDES Process Discharge Compliance Schedule —Revised Stream
Standards
Attachment 4, NPDES Permit Pages for the Current Permit and the Draft 2017 Permit for
a Monthly Average Flow Limit of 0.98 MGD
3

PROPRIETARY AND CONFIDENTIAL - Do Not Disclose
contains Confidential Business Information
Alternatives Analysis
Our meeting and discussions with DWR indicate that the conclusion reached with the initial
permit issuance and subsequent modified permits that direct discharge of the Mooresboro facility
is the most appropriate and really the only feasible option available for management of this
discharge has been established. As a result, the pervious decision on engineering alternatives is
well supported by previous alternatives analysis and DWR's review.
Summary
AZP presents this permit modification package with its commitment to restarting the
Mooresboro facility using a series of improved process management systems that will result in a
more stable, flexible and sustainable zinc refining plant. The improvements made address
environmental water management issues that the company acknowledges presented problems
during the initial efforts to bring this facility up to its zinc production capability. This experience
has informed the Restart Project and resulted in a careful accounting of materials and water
balances on the site. Receiving a permit modification with a 0.98 MGD average monthly flow
limit is extremely important to our operation and really is essential to being able to comply with
the permit.
The requested compliance schedule for meeting the expected Cd limit represents actions
requiring the allocation of significant financial resources and effort. We believe we must
carefully determine with a reasonable level of certainty the amount of Cd reduction necessary to
comply. The potential scope of process revisions necessary and the installation and operation of
any additional equipment is crucial. The time needed to evaluate the several levels of stable
operation required to achieve acceptable product production quality is the most critical input to
the process to make these decisions. The times requested for these steps give us a reasonable
opportunity to take into consideration the factors that will materially impact the concentration of
Cd in our process water within the process and that will be discharged under our NPDES permit.
We have coordinated the development of our Cd compliance report with DWR and believe it
represents a tight schedule that can be met thorough diligent attention to the steps needed to
complete the process.
4

PROPRIETARY AND CONFIDENTIAL - Do Not Disclose
contains Confidential Business Information
Attachment 1
NPDES Permit Application

PROPRIETARY AND CONFIDENTIAL - Do Not Disclose
contains Confidential Business Information
NPDES PERMIT APPLICATION - SHORT FORM C - Minor Industrial
Minor industrial, manufacturing and commercial facilities.
Mail the complete application to:
N. C. Department of Environment and Natural Resources
Division of Water Quality / NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
NPDES Permit Number
1. Contact Information:
Owner Name
Facility Name
Mailing Address
City
State / Zip Code
Telephone Number
Fax Number
e-mail Address
NC0089109
J
Please print or type.
American Zinc Products LLC (Parent Company)
American Zinc Recycling (AZR)
Mooresboro Zinc Refinery
484 Hicks Grove Road
Mooresboro
North Carolina, 28114
724-773-2223
412-788-4526
[e-mail]
2. Location of facility producing discharge:
Check here if same as above
Street Address or State Road
City
State / Zip Code
County
3. Operator Information:
Name of the fin-n, consultant or other entity that operates the facility. (Note that this is not referring to the
Operator in Responsible Charge or ORC)
Name N/A
Mailing Address
City
State / Zip Code
Telephone Number
Fax Number
Page 1 of 5 C-MI 10/08

PROPRIETARY AND CONFIDENTIAL - Do Not Disclose
contains Confidential Business Information
NPDES PERMIT APPLICATION - SHORT FORM C - Minor Industrial
Minor industrial, manufacturing and commercial facilities.
4. Ownership Status:
Federal ❑ State 0
Private ® Public 0
5. Standard Industrial Classification (SIC) code(s): 3341
6. Number of employees: 160 currently; approximately 300 when fully staffed
7. Describe the treatment system List all installed waste treatment components with capacities,
describe the processes that generate wastewaters. if the space provided is not sufficient attach a
separate sheet of paper with the system description.
There is no wastewater treatment system. Removal of metals and other constituents as by-
products is inherent to the metal production process, as described in Section 9 below.
Process water discharged is the resultant water remaining following all production steps.
8. Is facility covered under federal effluent limitation guidelines? No ® Yes ❑
If yes, specify the category?
9. Principal product(s) produced: Special High -Grade ("SHG") Zinc Metal and other metal
commodities.
Principal raw material(s) consumed: Waelz Oxide (a/k/a Crude Zinc Oxide)
Briefly describe the manufacturing process(es):
The manufacturing process consists of an integrated system of leaching, extraction,
stripping, and electrowinning processes. Feed, including metal bearing oxides and other raw
materials, are managed in solution throughout the process, and metal products are removed
as precipitates, concentrates, and SHG Zinc Metal. Metal bearing Waelz Oxide feed is
produced at parent company -owned facilities. The basic process approach is unchanged
from those described and provided in earlier applications. The specific technologies and
configuration of the operation are confidential business information.
In January 2016, the facility ceased commercial zinc production. The facility is currently
not in production and is in the process of implementing significant design and operational
changes at the facility (Restart Project) that will allow the facility to achieve commercial zinc
production and improve process water and stormwater management capability, improve
storage and management of by-products produced in the process, more carefully isolate
domestic wastewaters, and implement improved operational procedures. Completion of
these actions is expected in early spring 2019. Please see attached report that addresses the
Restart Project and the need for a compliance schedule. This report provides details on the
status of the facility and the modifications to the production site and operational capability
of the plant.
Historic information provided in this permit modification application reflects effluent
discharge monitoring data provided in monthly discharge monitoring reports (DMR's)
submitted to the Department over the past 24 months. This information reflects the volume
and nature of constituents occurring in the plant discharge water under the previous plant
configuration. These data reflect operations at that time and will not accurately reflect
discharge water quality following full implementation of the improvements underway at the
facility.
Page 2 of 5 C-MI 10/08

PROPRIETARY AND CONFIDENTIAL - Do Not Disclose
contains Confidential Business Information
NPDES PERMIT APPLICATION - SHORT FORM C - Minor Industrial
Minor industrial, manufacturing and commercial facilities.
10. Amount of principal product produced or raw material consumed
List specific amounts consumed and/or units of production over the last three gears
Product Produced or Raw Material
Consumed
(AVERAGE)
Product Produced or Raw Material
Consumed
(PEAK)
per Day
See Section 9 above and attached
documentation that provided production
and raw materials (Business Confidential
Information) —Plant is currently not
operating in a commercial zinc production
mode.
per Month
per Year
11. Frequency of discharge: Continuous ® Intermittent ❑
This application is for a modification of the existing permit to increase the discharge flow of the
facility. Current discharge is intermittent during the facility improvements project and this flow
is covered under the existing permit. Discharge will be continuous during normal production
operation.
If intermittent:
Days per week discharge occurs: Duration:
12. Types of wastewater discharged to surface waters only
Discharge
Flow
(GALLONS PER DAY)
Sanitary -monthly average
Sanitary WW is discharged to the Town of Forest City
satellite WWTP for RiverStone Commercial Park
Utility water, etc. - monthly average
Process water -
monthly average
980,000 gpd
Stormwater -monthly
average
Stormwater discharge managed under a separate
NPDES SW Individual Permit
Other - monthly
Explain:
average
Facility holds an NPDES General Permit for Boiler
Blowdown, Condensate and Non -Contact Cooling
Tower Blowdown.
Monthly Average
total discharge (all types)
980,000 gpd
13. Number of separate discharge points: 1 Outfall Identification number(s): 001
14. Name of receiving stream(s) (Provide a map showing the exact location of each outfall, including
latitude and longitude):
Broad River
Page 3 of 5
C-M 110/08

PROPRIETARY AND CONFIDENTIAL - Do Not Disclose
contains Confidential Business Information
NPDES PERMIT APPLICATION - SHORT FORM C - Minor Industrial
Minor industrial, manufacturing and commercial facilities.
15. Effluent Data [for new or proposed discharges]
Provide data for the parameters listed. Temperature and pH shall be grab samples, for all other parameters 24-hour
composite sampling shall be used. If more than one analysis is reported, report daily maximum and monthly average.
If only one analysis is reported, report as daily maximum.
NOTE: Permittees requesting renewal should complete the table ONLY for the parameters
currentlu monitored. Summarize the past 3 nears of effluent data.
Parameter
Daily
Maximum
Monthly
Average
Units of
Measurement
Biochemical Oxygen Demand (BOD5)
N/A
Chemical Oxygen
Demand (COD)
N/A
Total Organic Carbon
N/A
Total Suspended
Solids*
SEE ATTACHED
NARRATIVE,
TABLES, AND
FIGURES
Ammonia as N
N/A
Temperature (Summer)
N/A
Temperature (Winter)
N/A
pH*
Fecal Coliform (If
present)
sanitary waste is
N/A
Total Residual Chlorine
used)
(if chlorine is
N/A
16. List all permits, construction approvals and/or applications (check all that apply and provide permit
numbers or check none if not applicable):
Type
Permit Number Type
Hazardous Waste (RCRA) NESHAPS (CAA)
UIC (SDWA) Ocean Dumping (MPRSA)
NPDES X Dredge or fill (Section 404 or CWA)
PSD (CAA) Other
Non -attainment program (CAA)
Permit Number
17. List any chemicals that may be discharged (Please list and explain source and potential
amounts.)
See attached information describing the anticipated constituents and average
concentrations in effluent water discharged from the facility.
18. Is this facility located on Indian country? (check one)
Yes D No
Page 4 of 5
C-M 110/08

PROPRIETARY AND CONFIDENTIAL - Do Not Disclose
contains Confidential Business Information
NPDES PERMIT APPLICATION - SHORT FORM C - Minor Industrial
Minor industrial, manufacturing and commercial facilities.
19. Applicant Certification
I certify that I am familiar with the information contained in the application and that to the
best of my knowledge and belief such information is true, complete, and accurate.
Rob Williamson General Manager
Printed name of Person Signing
Signature of Applican
Title
Date
North Carolina General Statute 143-215.6 (b)(2) provides that: Any person who knowingly makes any false
statement representation, or certification in any application, record, report, plan, or other document files or
required to be maintained under Article 21 or regulations of the Environmental Management Commission
implementing that Article, or who falsifies, tampers with, or knowingly renders inaccurate any recording or
monitoring device or method required to be operated or maintained under Article 21 or regulations of the
Environmental Management Commission implementing that Article, shall be guilty of a misdemeanor punishable
by a fine not to exceed $25,000, or by imprisonment not to exceed six months, or by both. (18 U.S.C. Section
1001 provides a punishment by a fine of not more than $25,000 or imprisonment not more than 5 years, or both,
for a similar offense.)
Page 5 of 5 C-MI 10/08

PROPRIETARY AND CONFIDENTIAL - Do Not Disclose
contains Confidential Business Information
Attachment 2
Table 1, Process Discharge
Summary
Table 2, Monthly Maximum
Concentrations
Table 3, Other Monitored
Parameters

PROPRIETARY AND CONFIDENTIAL - Do Not Disclose
contains Confidential Business Information
TABLE 1
MONTHLY DISCHARGE INFORMATION - EFFLUENT FLOW, CONSTITUENT CONCENTRATION AND MONTHLY MASS DISCHARGE AMOUNT,
COMPARISON WITH CURRENT PERMIT AND CALCULATED CHRONIC EFFLUENT LIMITS (NEW RULE)
YEAR
MONTH
TOTAL DISCHARGE
FOR THE MONTH
(GALLONS)
NUMBER OF
DAYS FLOW
OCCURRED IN
MONTH
MONTHLY
AVERAGE FLOW
PER DAY
Monthly Average Concentrations (Mg/L)
Monthly Mass Discharged (Total Pounds)
Cd
Pb
Zn
F
TSS
Cd
Cr
Pb
Zn
F
TSS
1D
N
January
14,260,000
29
491,724
0.0816
0.005,
0
0.94
c31.5 1
6
9.70
0.65
0.00
111.9
3748.5
714
February
2,929,000
14
209,214
0.1230
0.00285
0.00275
5.36
12.9
10
3,01
0.07
0.07
131.0
315.3
244
March
4,092,000
18
227,333
0.1425
0
4i44,2
1.07
0
7.25
4.87
0.00
4.87
36.5
0.0
248
April
2,460,000
13
189,231
0.0610
0
0
0.945
6.8
9.8
1.25
0.00
0.00
19.4
139.6
201
May
2,325,000
13
178,846
0.0340
0
0.0026
057
6.6
10.5
0.66
0.00
0.05
11.1
128.1
204
June
3,360,000
18
186,667
0.0560
0
0
1.35
9.2
10.5
1.57
0.00
0.00
37.9
258.0
294
July
1,705,000
10
170.500
0.0945
0
0
1.3
9.1
5.55
1.34
0.00
0.00
18.5
129.5
79
August
2,418,000
10
241,800
(1.174.)
0
0.003
2.85
10.3
8,3
3.51
0.00
0.06
57.5
207.8
167
September
540,000
4
135,000
0,1050
0
0.00275
4.46
7.7
4.65
0.47
0.00
0.01
20.1
34.7
21
October
1,271,000
8
158,875
0.0615
0
0
3.56
6
0
0.65
0.00
0.00
37,8
63.6
0
November
290,000
3
96,667
0,068D
0
0
3.7
4.7
0
0.16
0.00
0.00
9.0
11.4
0
December
651,000
6
108,500
0.0940
0
0
4,43
5.2
0
0.51
0.00
0.00
24.1
28.2
0
r^I
N
MONTHLY
AVERAGE
January
1,364,000
10
136,400
0.0885
0
0
6.46
5.3
0
1.01
0.00
0.00
73.5
60.3
0
February
1,540,000
11
140,000
0,0465
0
0.0033
5.39
5.2
1.5
0.60
0.00
0.04
69.3
66.8
19
March
963,000
9
107,000
0.0555
0
0
3.9
8.2
2.15
0.45
0.00
0.00
31.3
65.9
17
April
2,265,000
15
151,000
0.0550
0
0
4.12
7.1
1.9
1.04
0.00
0.00
77.9
134.2
36
May
3,114,000
18
173,000
0.0360
0
0.0055
1.71
4.6
0
0.94
0.00
0.14
44.4
1195
0
June
2,235,000
15
149,000
0.0490
0.005
0
2.65
5.7
1.5
0.91
0.09
0.00
49.4
106.3
28
July
2,338,000
14
167,000
0.0615
0.0028
0.005
L9
6.8
7.6
1.20
0.05
0.10
37.1
132.7
148
August
1,582,000
14
113,000
0.0945
0
0
6.27
6.7
2.7
1.25
0.00
0.00
82.8
88.5
36
September
1,370,000
10
137,000
0.1675
0
0.0027
29
5.2
2
1.91
0.00
0.03
33.2
59.4
23
October
1,632,000
16
102,000
0.0975
0
0.00255
6.58
5
L25
1.33
0.00
0.03
89.6
68.1
17
November
1,110,000
10
111,000
0.0360
0.038
0
18.9.8_„,)
7.5
0
0.33
0.35
0.00
175.8
69.5
0
December
TOTAL
303,000
56,117,000
2,338,208
3
291
12.13
101,000
192,842
0.0420
0.0802
0
0.0023
0
0.0072
2.52
3.91
7.39
0
3.88
0.11
1.62
0.00
0.05
0.00
0.23
6.4
53.6
0.0
251.5
0
104
Total Monthly Flow - Limit (gals)
24,333,333
Flow /Day (gals)
800,0
Current Permit (Chronic Limit Monthly Average Concentration - M L)
F TSS
00 243.2 No Limit
Cd
(
Cr I Pb
0.27 6.75 337
Zn
No Limit
Calculated Max Effluent Concentration Limit - Chronic Toxicity Limits (Mo. Avg - Mg/L)-
Flow /Da Is)
Cd
Pb
TSS
• Calculated using hardness of 2,500 for effluent water, and 25 for upstream hardness.
"0" value means not detected.
Parameter with Permit Limit
Cd
54.83
Cd
Permitted Monthly Mass (Total Pounds)
Cr Pb
1,371 684.32
Zn
No Limit
F TSS
49,385 I No Limit
Calculated Allowable Max Monthly Mass (Total Pounds)
n
T55

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TABLE 2
MONTHLY DISCHARGE INFORMATION - MAXIMUM CONSTITUENT CONCENTRATION
COMPARISON WITH CURRENT PERMIT LIMITS
AND CALCULATED MAXIMUM DAILY (ACUTE) EFFLUENT LIMITS
YEAR
MONTH
Monthly Maximum Concentrations (Mg/L)
Cd
Cr
Pb
Zn
F
TSS
o
January
0.114
0.011
0
1.44
31.5
12
February
0.128
0.0057
0.0055
5.56
12.9
11.2
March
0.174
0
0.174
1.21
0
7.6
April
0.075
0
0
1
6.8
16.2
May
0.035
0
0.0052
0.64
6.6
12.2
June
0.099
0
0
1.6
9.2
15.5
July
0.1
0
0
1.5
9.1
6.5
August
0.228
0
0.006
4.4
10.3
11.8
September
0.14
0
0.0055
4.66
7.7
5.7
October
0.069
0
0
3.74
6
0
November
0.068
0
0
3.7
4.7
0
December
0.094
0
0
4.43
5.2
0
s
a
January
0.12
0
0
6.56
5.3
0
February
0.083
0
0.0066
9
5.2
3
March
0.057
0
0
4.2
8.2
4.3
April
0.08
0
0
4.53
7.1
3.8
May
0.038
0
0.011
2.23
4.6
0
June
0.057
5
0
2.8
5.7
3
July
0.078
0.0055
0.005
2,28
6.8
9.6
August
0.13
0
0
10.5
6.7
5.4
September
0.26
0
0.0054
3.9
5.2
6
October
0.12
0
0.0051
7.24
5
2.5
November
0.7
0.076
0
CLI,7
7.5
0
December
0.42
0
0
2.52
0
MONTHLY
AVERAGE
0.1453
0.2124
0.0096
5.17
7.39
5.68
Current Permit
(Acute
Limit (Daily
Maximum Concentration
- Mg/L)
Cd
Cr
Pb
Zn
F
TSS
1.66
113.6
3.75
No Limit
243,2
No Limit
Calculated (Acute) Limit (Daily Maximum Concentration - Mg/L)
Cd
Cr
Pb
Zn
F TSS
0.63
1$ l..t .
17.07
` , 4
* Calculated using hardness of 2,500 for effluent water, and 25 for upstream
hardness, and at 800,000 gallons / day average flow.
"0" value means not detected.
Parameter with Permit Limit

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TABLE 3
MONTHLY DISCHARGE INFORMATION - OTHER MONITORED CONSTITUENTS
DAILY MAXIMUM AND AVERAGE MONTHLY CONSTITUENT CONCENTRATION
Constituent
Units
Maximum
Average
NH3-N
Mg/L
0.12
0.017
Total Aluminum
Mg/L
0.151
0.0713
Total Antimony
Mg/L
0.0445
0.0125
Total Arsenic
Mg/L
Not Detected
Not Detected
Chlorides
Mg/L
4700
1440
Total Cobalt
Mg/L
0.0072
0.001
Total Copper
Mg/L
0.0238
0.0034
Total Fluoride
Mg/L
31.5
25.3
Total Iron
Mg/L
110
15.7
Total Nickel
Mg/L
0.0071
0.0028
Total Tin
Mg/L
0.0068
0.001
pH
standard units
6.6 - 8.3
6.5 - 7.3
Chronic Toxicity
Pass / Fail
Failed 1 Time in 8 Monitored Periods
Effluent Turbidity
NTU
13.8
3
Upstream Turbidity
NTU
83.4
17
Downstream Turbidity
NTU
87.3
17

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Attachment 3
NPDES Process Discharge
Compliance Schedule —Revised
Stream Standards

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American Zinc Recycling (AZR)
Mooresboro Zinc Refinery
Rutherford County, NC
NPDES Process Discharge Compliance Schedule — Revised Stream Standards
December 2018

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Contents
1. Background 1
1.1. Objectives of this document 1
1.2. The Mooresboro Zinc Production Facility 1
1.3. Restart Project 2
1.3.1. Metals removal technology selection 2
1.3.2. Key performance indicators 3
1.4. Environmental Standards 3
1.4.1. Evolution of water quality standards 3
1.4.2. Compliance risk 3
2. Compliance program 4
3. Implementation philosophy 4
4. Compliance schedule 5
5. Schedule Review and Justification 6
6. Requested Interim Limits 9

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1. Background
1.1.Objectives of this document
The objective of this narrative is twofold: 1) to provide to the Department of Environmental
Quality (DEQ) the basis for the company's request for an increase in the permitted discharge
volume, and 2) provide an outline of a program consisting of necessary tasks and process
equipment/modifications to achieve compliance with the anticipated more restrictive cadmium
(Cd) limit (due to recent rule changes). AZR has previously discussed the need for a flow
increase in its process effluent discharge with DEQ. DEQ has provided AZR with information
indicating that due to a change in regulations the Cd discharge limit will become more stringent.
It is important to note that the requested flow increase is not the result of a production change.
Zinc production capacity at this facility remains the same as that identified in the initial
application for an NPDES permit. The total water balance for this operation and the physical
means of managing process water and stormwater effectively requires that the permitted flow
be increased. There has been no significant change in the materials balance for this facility.
Therefore, the expected mass of metals and other materials within the process essentially
remains unchanged from the mass balance provided previously. However, overall water
management necessary to effectively operate the plant on this site will actually result in lower
expected discharge concentrations. AZR recognizes that changes to the NC water quality
standards will likely require AZR to take actions to reduce process flow discharge
concentrations for Cd.
This document is included with the AZR's application for a revised discharge flow to describe
to DWR the efforts required to achieve consistent compliance with the anticipated effluent Cd
limit. Please be aware that the water balance for this site is dependent on rainfall/stormwater
and as a result will have some variation over time due to actual precipitation events
experienced at the site.
1.2.The Mooresboro Zinc Production Facility
The AZR Corp. Zinc Production Facility, located in Mooresboro NC, was designed to produce
155,000 tons of Special High Grade (SHG) zinc per annum. Numerous technical difficulties,
experienced since the start-up of the facility in May 2014, led to the eventual shut down of the
facility in January 2016 by Horsehead Inc, who subsequently filed for Chapter 11 bankruptcy.
Pursuant to an extensive investigation into the technical problems, the current owners of the
facility, American Zinc Recycling LLC, the parent company of American Zinc Products (AZP),
approved a project to address the technical difficulties, with the assistance of an experienced
technical team, augmented by Asturiana de Zinc, a leading supplier of zinc production
1

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technology and an owner of several zinc production facilities globally. The restart project, with
a capital budget of $156 million was approved in December 2017 and is planned to be
completed in March 2019, with eventual ramp -up to 155,000 tons of SHG zinc production by
July 2020. The planned eventual production capacity has remained at 155,000 tons per year
and the scope of the Mooresboro Restart Project is limited to the resolution of technical
difficulties and does not include any planned increase in production capacity.
1.3. Restart Project
1.3.1. Metals removal technology selection
Although the key technology blocks for zinc production have been retained, the process
water system, designed to recover valuable metals and other by-products prior to
discharge in the effluent stream, is being expanded and modified to address the
following shortcomings of the original design:
• Constrained capacity to deal with fluctuating flow rates, primarily resulting from
environmental factors, such as significant rainfall and the need to direct potentially
contaminated stormwater into the process.
• Limited solid/liquid separation capacity to remove precipitated metal hydroxides
and sulphides (recoverable by-products).
• Ability to deal with upset conditions due to process equipment failures (e.g. filter
cloth tears, etc.).
During the initial operating phase from May 2014 to January 2016 the above constraints
were addressed through temporary measures, such as the installation of a lamella
thickener, and installation of a temporary metals removal unit to augment capacity.
Evaluation of these technologies during the initial operating phase and subsequent
design reviews, led to the development of the following permanent process changes,
which are included in the restart project scope:
• Procurement and installation of two Veolia Actiflo units, to provide excess capacity
for removal of solid metal hydroxides and sulphides, with 100% redundancy.
• A 40% capacity increase of the process water system.
• Installation of proprietary pH control units, which have been proven to be reliable
in Asturiana de Zinc facilities, to provide increased process stability and more
consistent operation.
2

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In addition to the improvements to the process system, mentioned above, the capital
investment also includes the following upgrades, which will reduce the volume of metal -
containing solutions, resulting from the incorporation of stormwater into the process:
• Construction of covered storage facilities for all major by-products and reagents.
• Installation of sump pumps and piping systems to more readily collect metal -
containing solutions from around the facility.
1.3.2. Key performance indicators
The design parameters of the collection and process water system were based on
achieving the following key performance indicators:
• Limit water consumption and treated effluent discharge as far as possible. Based
on careful consideration of all of the actions necessary to effectively manage water
on the site, the new design is based on limiting the average daily discharge flow
rate to 0.98 Million Gallons Per Day (MGD).
• Limit the Cd concentration in the discharge stream to achieve the same Cd
discharge on a mass flow basis, as stipulated by the current NPDES permit
(NC0089109).
1.4. Environmental Standards
1.4.1. Evolution of water quality standards
The NC 2007-2015 Water Quality Standard (WQS) was revised in April 2016 and
although the process used to determine metals standards, namely the Reasonable
Potential Analysis (RPA) did not change, the application of dissolved and hardness -
dependent calculations in the RPA represent a significant change. The evaluation of
hardness -based standards requires knowledge of the effluent and upstream hardness
which is used in calculating certain metals concentration limits, including cadmium, for
effluent discharge that will comply with the NC standards.
1.4.2. Compliance risk
The design improvements, included in the scope of the Mooresboro Restart Project,
will improve the consistency of effluent water quality at the facility. Nevertheless,
compliance with the amended NC WQS cannot be confirmed without operating
experience. The changes to the standard are significant and it is possible that further
refinements of the water process system may be required to ultimately achieve
compliance with effluent discharge limits. Without actual operational data, it will be
impossible to determine what, if any, modifications to our process will be necessary.
3

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2. Compliance program
The scope of the compliance programme is highly dependent on determining potential causes of
non-compliance and will therefore be confirmed during the initial operating phase. However, based
on the nature of the Mooresboro facility and the composition of the various process streams to be
managed by the water process system, it is possible to identify the more likely areas requiring
improvement during the initial operating phase, particularly processes for metals precipitation and
solid/liquid separation of precipitated metals. The scope of work will therefore comprise the
following key aspects:
Pursuant to plant commissioning and stabilization, the efficiency of metal hydroxide and metal
sulphide precipitation will be assessed through comparison with bench scale test work and
industry best practice. This phase will feature optimization of pH and Redox Potential of the
plant operation.
The separation of metal hydroxides and precipitates through settling and filtration, using
conventional high rate clarifiers as well as the planned Veolia Actiflo lamella clarifier, will be
assessed through in -plant sampling.
Based on the assessment above, enhanced chemical removal and/or solid/liquid separation
technologies will be evaluated to address potential areas for improvement of trace metal
removal. The evaluation will comprise a literature survey, as well as bench scale test work in
collaboration with potential technology suppliers.
• The initial technology selection process will yield short-listed technologies which may be
evaluated further through pilot test work at the Mooresboro facility.
• The final selected technologies will be incorporated into the overall facility design, followed by
procurement and construction.
• Commissioning and evaluation of the selected technologies will comprise the final steps in the
program.
3. Implementation philosophy
The project will be implemented in accordance with the Project Management Institute (PMI®)
project life cycle process, as contained in the Project Management Body of Knowledge (PMBOK).
The key steps are as follows:
• Initiation. Subsequent to commissioning of the Mooresboro facility.
• Planning. Detailed planning, based on the outcome of the initial evaluation of the
Mooresboro process water system performance.
• Implementation. Technology selection, detailed design, procurement and construction.
• Control. Project management to achieve target dates.
• Close-out. Final evaluation of the selected technology in operation and confirmation of
compliance, followed by project close-out.
4

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4. Compliance schedule
The schedule presented in Table 1, commences with the start-up of the Mooresboro Zinc
Production facility. The schedule is therefore linked to the start date, to be no later than June 1,
2019 (month 0).
Table 1. High level draft compliance schedule
Activities
Deadline for Completion
1.
Commence production of Zinc at Mooresboro Facility.
Month 0
2.
Ramp -up production to 75%.
Month 6
3.
Stabilize plant operation and commence evaluation of permit compliance.
Month 12
4.
Complete evaluation period.
Month 24
5.
Prepare a Preliminary Engineering Report (PER) of process alternatives and/or
pollution prevention/waste minimization alternatives designed to achieve
compliance. This report would include the results of the compliance evaluation.
Submit to DWR for review and comment.
Month 30
(parallel with activity 4)
6.
Agency review and addressing comments
Month 32
7.
Bench scale test work of process alternatives (start following completion of
Activity 5).
Month 34
8.
Evaluate business case and funding requirements for technically suitable
altemative(s).
Month 34
(parallel with activity 7)
9.
Complete pilot test work for selected technology option(s) and final technology
selection. Develop a summary of the results of this evaluation. Submit
summary to DWR for review.
Month 38
10.
Agency review and addressing comments
Month 40
11.
Detailed engineering and design of selected option. Submit to DWR for
comment. (in order to meet this schedule, work on this component will begin
following Step 9)
Month 44
12.
Agency review and addressing comments
Month 46
13.
Prepare capital project application and secure funding for selected option,
obtain building permits and all needed approvals for implementation.
Month 48
(much of this work will be
done in parallel with
activities 11,12)
5

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14.
Project implementation, including design completion, procurement and
construction.
Month 60
15.
Commission and ramp -up.
Month 72
16.
Stabilize operation and evaluate performance.
Month 78
17.
Make necessary final modifications to optimize and obtain full operational
status.
Month 86
18.
Achieve full compliance.
Month 90
5. Schedule Review and Justification
Table 1 provides the necessary timeframe for the logical and effective development of required process
modification, if necessary, to increase the capability for Cd capture and reduce concentrations in the
process discharge water in order to comply with the final permit limit. The most critical steps in this
process involve achieving stable operation of the process before assessing resultant discharged water
quality. The time necessary to achieve stable operation is essential to providing accurate information
that will serve as the basis for employing the technologies that will be used to assure compliance. The
schedule reflects the Company's efforts to streamline actions involving the evaluation and reporting of
data and for making important design decisions, A summary of the schedule and the basis for the
assigned time segments for identified actions is provided below:
A. Providing sufficient time to achieving operational sustainability of the facility.
Steps 1 and 2 accounts for the essential time that facility operators must have to achieve a
sustained zinc production level and acceptable product quality. The facility operation involves the
interaction of a series of chemical and physical production steps. Based on experience with
similar production facilities, management believes the Mooresboro facility will require 6 months to
ramp up production and then an additional 6 months to achieve stable operation. The length of
this time period also accounts for a full year of climate conditions and precipitation, and
associated effects on the process water discharge. As part of its NPDES Stormwater Permit plan,
stormwater that may contain some level of constituents from raw materials and production by-
products must be managed with process water. Seasonal weather conditions will likely have
some effect on effluent water discharge. A full year is required at a minimum to understand the
potential variability in flow and quality over four seasons, and the potential effect on process water
quality. In addition, over the first year of operation variations in the discharge water quality from
the plant process operations will be eliminated.
6

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B. Evaluate process discharge to determine variation in Cd within the production sequence
and in the resultant process wastewater.
Similar to the rationale provided for Steps 1 and 2 above, seasonal impacts on process water will
need to be assessed. At least one full year is required to evaluate Cd levels within the production
steps and in the effluent discharge water after a consistent operation is achieved. Steps 3 and 4
allow for this evaluation period to be completed. The timeframe allocated, after the evaluation
period, for preparation of the PER is 6 months (Step 5). This time is necessary to fully evaluate
the results of the Cd monitoring from the evaluation period, operational variability during this time,
and other related information. This is the critical analysis needed to develop an approach to
reducing Cd and to evaluate process and pollution prevention alternatives and prepare a final
report.
C. Submittal of reports and information to DWR for review and comment.
The schedule includes steps for submission of evaluation reports and supporting information to
DWR for review and comment. This begins with Step 5. The schedule proposes 2 months for
this review and comment and includes provisions to address comments provided by the agency.
Since the review and comment time segment is not within the company's control, DWR should
note that any schedule impact due to agency review and comment should not be considered in
determining our compliance with the schedule. If DWR believes that the allocated time for review
and comment is not adequate, the schedule will need to be adjusted.
D. Developing real world information for evaluation of specific process technologies and
actions that will result in Cd compliance.
Steps 7,8 and 9 are essential in order to ensure that certain technologies and actions identified to
achieve compliance will be effective in this facility. The process used for production at this facility
is complex and involved. There are no 'off the shelf' specific technologies or techniques for
addressing issues with elevated Cd. The potential solutions will require evaluation on a site -
specific basis. The only way to do this with some assurance that the recommended solutions
work at this plant is through bench scale testing. Based on our experience and the processes
involved, this requires a minimum of 12 months to develop appropriate data on the options
identified in the PER, test them, identify the most appropriate actions to achieve the objective, to
evaluate the business case for the actions identified and prepare a report to support the
recommendations. Please note that Step 7, bench scale evaluation, will be started in parallel with
7

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Step 5 in order to provide enough time for bench testing and to reduce the overall schedule
timeline.
E. Detailed engineering and design of the selected alternative actions.
Step 11 includes the preparation of plans and specifications for the actions selected to address Cd
within the process. This step, in order to allow reasonable time for engineering will have to begin
with preliminary work following the completion of the bench scale testing. Agency review comments
will be incorporated based on the information provided in step 10. This is a tight schedule for the
development of engineered solutions with sufficient detail for final evaluation. This also includes
the necessary evaluation of appropriate technologies from various vendors and ensuring the
equipment is available, and that it can be acquired and installed in a timely fashion to meet the
established schedule in the permit.
F. Moving forward with the actions to install, construct and place into operation the
necessary technologies and actions.
Steps 14, and 15 represent the on -the -ground installation of selected technologies. This
includes necessary time for capital project approvals in the company, obtaining all construction
approvals necessary to allow the project to proceed with installation of equipment. Approvals
will be obtained in advance of the development of detailed plans and specifications. This is an
aggressive approach which will require extensive coordination with Step 11. A 12-month period
is provided for finalizing design, procurement and construction. Considering that at the time of
development of this schedule that the scope of actions needed is not known, this could be a
very difficult objective. However, the company believes it is possible to achieve these
objectives during the time requested. Commissioning and ramp up of the installed equipment
and associated systems requires 6 months.
G. Placing the installation and systems into operation and working through initial
operational issues, establishing stable and effective protocols, and making sure that the
system can in fact comply with the limits.
Certainly, the final efforts needed to achieve the ultimate objective of compliance are
identified in Steps 16, 17 and 18. The total time allocated to these critical efforts is 12
months. The effective date of the final discharge limits is extremely important. The time
allowed for these steps need to be sufficient to prevent any circumstances that would
jeopardize final compliance. We see this as a two-step process, achieving stable operation
(16) and a final 6 months to optimize the systems and reach full operational status (17). Once
8

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compliance with final limits is achieved, the system will be optimized to ensure consistent and
reliable performance.
6. Requested Interim Limits.
The facility is currently undergoing a relatively large upgrade process (Restart Project) to improve the
process operation and overall management of process and storm water on this site. As noted, the
project will not materially impact the general materials balance for the production sequence that was
provided with the initial permit application for this facility. From a mass balance of materials
throughout the process, it is estimated that the effluent discharge will contain Cd levels in excess of
the anticipated concentration limit at the increased 0.98 MGD discharge rate. This projection is, of
course, the basis for this request and the described program for evaluating, selecting, and
implementing measures to reduce Cd in the process water discharge.
This report provides general information on the improvements that are under construction on the site
and the specific facility modifications that could affect resultant process water discharge
concentrations. The production sequences and technologies applied will not be fully tested or proven
until full production and a stable operation is achieved. As the previous operation trials were not
successful, data gathered during the former operating period cannot be used for estimating metal
concentrations in discharge effluent water.
AZR believes that the estimated level of Cd in effluent discharge water while the plant operates at full
production will be similar to the calculated concentration determined from the material balance. We
believe that the most appropriate approach to an interim limit is to establish a monitor -only provision
during the compliance period. As the facility moves toward full production and stable operation in
accordance with the requested compliance schedule, the actual process discharge Cd levels will be
definitively identified.
9

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Attachment 4
NPDES Permit Limits Pages
Current Permit at 0.8 MGD and
Anticipated Limits Page for 0.98
MGD

Current 2015 Permit Effluent Limits Page
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Part I
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(s)serial number 001. Such discharges shall be limited and monitored5 by the
Permittee as specified below:
EFFLUENT
CHARACTERISTIC$
LIMITS
MONITORINGREQUREMENTS
Monthly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample
Locationl
Flow (MGD)
0. 80
Continuous
Recording
I or E
Total Suspended Solids
2/Month ;gig
Composite
E
NH3-N
Quarterly
Composite
E
Total Aluminum
-
Quarterly
'Composite
E
Total Antimony
Quarterly
Composite
E
Total Arsenic
Quarterly
Composite
E
Total Cadmium
0.27 mg/L
1.66 mg/L
2/Month 1
Composite
E
Chlorides
Quarterly
Composite
E
Total Chromium
6.75 mg/L
113.6 mg/L
2/Month t
Composite
E
Total Cobalt
Quarterly.
Composite
E
Total Copper
Quarterly
Composite
E
Total Fluoride
243.2 mg/ L
243.2 mg/L
K ' `Sli ly -:4'
Composite
E
Total Iron
Quarterly
Composite
E
Total Lead
3.37 mg/L
3.75 mg/L
2/Month
Composite
E
Total Nickel
„onthiY
�.�.__.
Composite
E
Total Tin
Quarterly
Composite
E
Total Zinc
2/Month '`
Composite
E
pH2
Daily
Grab
E
Chronic Toxicity3
Quarterly
Composite
E
Turbidity4
: ,-':Mont y<,_'
Grab
E, U, D
NOTES:
1.
Sample Locations: I - Influent, E - Effluent, U - upstream (50 ft. upstream of the discharge), D -
downstream (50 ft. downstream of the discharge).
2. The pH shall not be less than 6.0 standard units or greater than 9.0 standard units.
3. Chronic Toxicity (Ceriodaphnia) P/F 0.74%; Jan., April, July andOctober; See condition A. (2.)
of the Supplement to Effluent Limitations and Monitoring Section of this permit.
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.
5. No later than 270 days from the effective date of this permit, begin submitting discharge
monitoring reports electronically using NC DWR's eDMR application system. See Special
Condition A. (3.).
THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR FOAM VISIBLE IN OTHER THAN TRACE
AMOUNTS.
Page 3 of 6

PROPRIETARY AND CONFIDENTIAL - Do Not Disclose
contains Confidential Business Information
Proposed Limits Page from 2017 Draft 0.98 MGD Permit
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge from outfall(s) serial number 001. Such discharges shall be
limited and monitored5 by the Permittee as specified below:
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQUREMENTS
Monthly
Average
Daily
Maximum
Measureme
nt
Frequency
Sample
Type
Sample
Locationl
Flow (MGD)
0.98
Continuous
Recording
I or E
Total Suspended Solids,
mg/ L
2/Month
Composite
E
NH3-N, mg/L
Quarterly
Composite
E
Total Aluminum, µg/L
Quarterly
Composite
E
Total Antimony, µg/ L
Quarterly
Composite
E
Total Arsenic, µg/L
Quarterly
Composite
E
Total Cadmium
65.5 µg/L
293.2 µg/L
2/Month
Composite
E
Chlorides, mg/L
Quarterly
Composite
E
Chromium (VI), µg/L
Quarterly
Composite
E
Total Cobalt, µg/L
Quarterly
Composite
E
Total Copper, µg/ L
Quarterly
Composite
E
Total Fluoride, mg/L
Quarterly
Composite
E
Total Iron, mg/L
Quarterly
Composite
E
Total Lead
326.0 µg/L
6,832 µg/L
2/Month
Composite
E
Total Nickel, µg/ L
Monthly
Composite
E
Total Tin, µg/L
Quarterly
Composite
E
Total Zinc, pg/L
2/Month
Composite
E
pH2
Daily
Grab
E
Chronic Toxicity3
Quarterly
Composite
E
Turbidity-,
Monthly
Grab
E, U, D
NOTES:
1.
Sample Locations: I — Influent, E — Effluent, U - upstream (50 ft. upstream of the
discharge), D — downstream (50 ft. downstream of the discharge).
2. The pH shall not be less than 6.0 standard units or greater than 9.0 standard units.
3. Chronic Toxicity (Ceriodaphnia) P/F @ 0.9%; Jan., April, July and October; See
condition A. (2.) of the Supplement to Effluent Limitations and Monitoring Section of
this permit.
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.
5. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's
eDMR application system. See Special Condition A. (3.).
THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR FOAM VISIBLE IN OTHER THAN
TRACE AMOUNTS.

1
eve,aE-s
c,3p 3_
AMERICAN
ZINC RECYCLING
Delivering a Sustainable Future
TIMOTHY R. BASILONE
Vice President - Environmental Affairs
4955 Steubenville Pike
Suite 405
Pittsburgh, PA 15205
T 724-773-2223 www.azr.com
F 412-788-4526 tbasilonefdazr.com
VIA EMAIL AND OVERNIGHT MAIL
January 30, 2018
Dr. Sergei Chernikov, Ph.D.
Environmental Engineer II
North Carolina Dept. of Environment
& Natural Resources
Division of Water Quality
9th Floor — Archdale Building
512 N Salisbury Street
Raleigh, NC 27604
RE: NPDES — Effluent Permit Renewal Application
American Zinc Products LLC
Permit NC0089109
Dear Dr. Chernikov:
Please find enclosed three copies of the application and supporting information for timely renewal of
the above referenced NPDES Permit for the American Zinc Products LLC ("AZP", f/k/a Horsehead Metal
Products LLC) facility in Mooresboro, North Carolina.
Please note that all application information should be considered Confidential Business Information.
Information contained in the application is based on recent monthly effluent discharge monitoring
information submitted over the past 24 months.
AZP would like to meet with you to discuss the permit application and anticipated activities at the
facility during the next 12 -18 months. I will call you within the next week to schedule a mutually
convenient time to meet at your office. If you have any questions, please contact me.
Sincerely,
Timothy ' Basilone
Enc.

NPDES PERMIT APPLICATION - SHORT FORM C - Minor Industrial
Minor industrial, manufacturing and commercial facilities.
Mail the complete application to:
N. C. Department of Environment and Natural Resources
Division of Water Quality / NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
NPDES Permit Number
1. Contact Information:
NC0089109
Please print or type.
Owner Name American Zinc Products LLC
Facility Name American Zinc Products LLC
Mailing Address 484 Hicks Grove Road
City Mooresboro
State / Zip Code North Carolina, 28114
Telephone Number 724-773-2223
Fax Number 412-788-4526
e-mail Address [e-mail]
2. Location of facility producing discharge:
Check here if same as above El
Street Address or State Road
City
State / Zip Code
County
3. Operator Information:
Name of the firm, consultant or other entity that operates the facility. (Note that this is not referring to the
Operator in Responsible Charge or ORC)
Name N/A
Mailing Address
City
State / Zip Code
Telephone Number
Fax Number
Page 1 of 5 C-MI 10/08

NPDES PERMIT APPLICATION - SHORT FORM C - Minor Industrial
Minor industrial, manufacturing and commercial facilities.
4. Ownership Status:
Federal ❑ State ❑ Private ® Public 0
5. Standard Industrial Classification (SIC) code(s): 3341
6. Number of employees: 35; approximately 300 when fully staffed
7. Describe the treatment system List all installed waste treatment components with capacities,
describe the processes that generate wastewaters. If the space provided is not sufficient attach a
separate sheet of paper with the system description.
There is no wastewater treatment system. Removal of metals and other constituents
from effluent water is inherent to the metal production process, as described in
Section 9 below.
8. Is facility covered under federal effluent limitation guidelines? No Z Yes ❑
If yes, specify the category?
9. Principal product(s) produced: Special High -Grade ("SHG") Zinc Metal and other metal
commodities.
Principal raw material(s) consumed: Waelz Oxide (a/k/a Crude Zinc Oxide)
Briefly describe the manufacturing process(es):
The manufacturing process consists of an integrated system of leaching, extraction,
stripping, and electrowinning processes. Feed, including metal bearing oxides and other raw
materials, are managed in solution throughout the process, and metal products are removed
as precipitates, concentrates, and SHG Zinc Metal. Metal bearing Waelz Oxide feed is
produced at parent company -owned facilities. The specific technologies and configuration of
the operation are confidential business information.
In January 2016, the facility curtailed zinc production. Process design and operational
changes will be under consideration over the forthcoming 12 - 18 months.
Information provided in this permit renewal application reflects effluent discharge
monitoring data provided in monthly discharge monitoring reports (DMR's) submitted to the
Department over the past 24 months. This historic information reflects the volume and
nature of constituents anticipated in discharge under current operations.
Page 2 of 5 C-MI 10/08

NPDES PERMIT APPLICATION - SHORT FORM C - Minor Industrial
• Minor industrial, manufacturing and commercial facilities.
10. Amount of principal product produced or raw material consumed
List specific amounts consumed and/or units of production over the last three years
Product Produced or Raw Material
Consumed
(AVERAGE)
Product Produced or Raw Material
Consumed
(PEAK)
per Day
per Month
per Year
11. Frequency of discharge: Continuous ❑ Intermittent El
If intermittent:
Days per week discharge occurs: Average 12 days/month Duration: 24 hours/day
12. Types of wastewater discharged to surface waters only
Discharge
Flow
(GALLONS PER DAY)
Sanitary - monthly average
Utility water, etc. - monthly average
Process water - monthly average
192,842 gallons / day (12 days / month average)
Stormwater - monthly average
Other - monthly average
Explain:
Monthly Average
total discharge (all types)
192,842 gallons / day (12 days / month average)
13. Number of separate discharge points: 1 Outfall Identification number(s): 001
14. Name of receiving stream(s) (Provide a map showing the exact location of each outfall, including
latitude and longitude):
Broad River
Page 3 of 5
C-MI 10/08

NPDES PERMIT APPLICATION - SHORT FORM C - Minor Industrial
• Minor industrial, manufacturing and commercial facilities.
15. Effluent Data [for new or proposed discharges]
Provide data for the parameters listed. Temperature and pH shall be grab samples, for all other parameters 24-hour
composite sampling shall be used. If more than one analysis is reported, report daily maximum and monthly average.
If only one analysis is reported, report as daily maximum.
NOTE: Permittees requesting renewal should complete the table ONLY for the parameters
current! u monitored. Summarize the vast 3 nears of effluent data.
Parameter
Daily
Maximum
Monthly
Average
Units of
Measurement
Biochemical Oxygen Demand (BOD5)
N/A
Chemical Oxygen Demand (COD)
N/A
Total Organic Carbon
N/A
Total Suspended Solids*
SEE ATTACHED
NARRATIVE,
TABLES, AND
FIGURES
Ammonia as N
N/A
Temperature (Summer)
N/A
Temperature (Winter)
N/A
pH*
Fecal Coliform (If sanitary waste is
present)
N/A
Total Residual Chlorine (if chlorine is
used)
N/A
16. List all permits, construction approvals and/or applications (check all that apply and provide permit
numbers or check none if not applicable):
Type Permit Number Type
Hazardous Waste (RCRA) NESHAPS (CAA)
UIC (SDWA) Ocean Dumping (MPRSA)
NPDES X Dredge or fill (Section 404 or CWA)
PSD (CAA) Other
Non -attainment program (CAA)
Permit Number
17. List any chemicals that may be discharged (Please list and explain source and potential
amounts.)
Attached is information describing the anticipated constituents and average
concentrations in effluent water discharged from the facility.
SEE TABLE 4, FIGURES 1 AND 2, AND THE NARRATIVE, ATTACHED
Page 4 of 5
C-MI 10108

NPDES PERMIT APPLICATION - SHORT FORM C - Minor Industrial
Minor industrial, manufacturing and commercial facilities.
18. Is this facility located on Indian country? (check one)
Yes ❑ No
19. Applicant Certification
I certify that I am familiar with the information contained in the application and that to the
best of my knowledge and belief such information is true, complete, and accurate.
Rob Williamson General Manager
Printed name of Per on igning Title
i - t%2 q /lee
Signature of App scant Date
North Carolina General Statute 143-215.6 (b)(2) provides that: Any person who knowingly makes any false
statement representation, or certification in any application, record, report, plan, or other document files or
required to be maintained under Article 21 or regulations of the Environmental Management Commission
implementing that Article, or who falsifies, tampers with, or knowingly renders inaccurate any recording or
monitoring device or method required to be operated or maintained under Article 21 or regulations of the
Environmental Management Commission implementing that Article, shall be guilty of a misdemeanor punishable
by a fine not to exceed $25,000, or by imprisonment not to exceed six months, or by both. (18 U.S.C. Section
1001 provides a punishment by a fine of not more than $25,000 or imprisonment not more than 5 years, or both,
for a similar offense.)
Page 6 of 5 C-MI 10108

Supplemental Information
Mooresboro Effluent Permit Renewal Application
Permit NC0089109
This renewal permit application is submitted timely for renewal of the effluent discharge permit
for the AZR Mooresboro, NC facility (Permit Number NC0089109).
Information provided in this permit renewal application reflects effluent discharge monitoring
data provided in monthly discharge monitoring reports (DMRs) submitted to the Department
over the past 24 months. This information reflects the nature of effluent discharge water based
on current operations.
A summary of historic effluent information is provided below, and data from Monthly DMR's
for the past 24 months is provided on the attached Tables and Figures.
Discharge Volume
In January 2016, the facility curtailed zinc production, and the associated effluent discharge rate
over the past 24 months has fluctuated, averaging 192,842 gallons on a daily average basis,
which is approximately 2.34 million gallons/month total discharge (Table 1). The current
permitted average discharge volume is 800,000 gallons / day.
Intermittent flow has occurred at an average of around 12 days per month over the past 24
months. It is anticipated that operations at the current level will continue while process design
and operation changes are considered over the forthcoming 12 —18 months. The average daily
effluent flow of 800,000 gallons should be maintained in the renewed permit.
Constituent Discharge Concentration and Mass
Information on DMR's submitted to the Department over the past 24 months indicates that
permit limits were not exceeded for any parameters. There was one chronic toxicity test,
occurring in January 2016, which failed. A test was conducted the following month which was
shown to pass. All other tests passed for chronic toxicity.
Information from DMR's, including monthly average concentrations for constituents having
chronic discharge limits, and monthly effluent flow information is provided on Table 1.
Constituents noted on Table 1 have a sampling frequency of 2 / Month.
Information from DMR's, including daily maximum concentrations for constituents with acute
discharge limits is provided on Table 2.
Table 3 includes monthly average and daily maximum concentrations for constituents without
limits and that were monitored on a quarterly or monthly frequency, except for pH which is
monitored daily and has a limit of 6 — 9 standard units, chronic toxicity which is pass/fail, and
turbidity having a contribution limit to the stream of 50 NTU.

Table 4 provides information on various constituents as to the anticipated average concentration
in effluent discharge water.
Cadmium
Cadmium discharge is limited in the current permit to 0.270 Mg/L (ppm). At an average
discharge rate of 800,000 gallons / day, based on this concentration limit 54.83 pounds / month
of cadmium can be discharged within limits to the Broad River in effluent water, provided the
daily average concentration for the month does not exceed 0.270 ppm, and the maximum daily
concentration does not exceed 1.66 ppm (Table 1).
Over the past 24 months, the average monthly cadmium concentration was 0.0802 ppm. This
concentration is well below the permit limit for cadmium at 0.270 ppm. At the current average
daily effluent discharge rate of 192,842 gallons / day, an average of 1.62 pounds / month of
cadmium was discharged over the past 24 months. This amount of cadmium is well below the
mass at the chronic permit limit described above, at 54.83 pounds / month.
The Maximum Effluent Concentration Limit was calculated using the Departments Reasonable
Potential Analysis (RPA) worksheet. Based on stream characteristics for the Broad River, an
average of 800,000 gallons / day discharge rate, a water hardness of 2,500 ppm, and using 0.100
ppm for the anticipated cadmium concentration, the calculated maximum effluent concentration
for chronic toxicity is 0.121 ppm. This limit is conservative considering it is based on the
permitted discharge rate (800,000 gallons / day average) as opposed to the actual discharge rate
(192,000 gallons / day average), which is much lower. Additionally, a higher anticipated
cadmium concentration of 0.100 ppm was used in the calculation, which is 25% higher than the
average cadmium concentration in effluent water over the past 24 months of 0.0802 ppm.
Finally, flow is intermittent, averaging 12 days / month, which consequently reduces the
likelihood of the calculated limit for the average monthly concentration being exceeded.
Based on the calculated Maximum Effluent Concentration Limit, at an average of 800,000
gallons / day discharge volume the mass of cadmium that could be discharged within the
calculated limit is 25 pounds / month. The current monthly average discharge rate of 1.62
pounds / month is well below the calculated limit on a mass basis.
Table 2 provides information on maximum cadmium concentrations in effluent flow over the
past 24 months, the current acute toxicity permit limit, and the calculated maximum acute
toxicity permit limit using the RPA. Using the maximum discharge concentrations over the past
24 months, the average of maximum monthly cadmium concentrations was 0.1453 ppm, and the
maximum of all daily cadmium concentrations recorded is 0.260 ppm. These concentrations are
both well below the 1.66 ppm limit in the current permit, and is below the daily maximum
(acute) limit of 0.63 ppm for cadmium calculated using the RPA.
2

Lead
Lead discharge is limited in the current permit to 3.37 ppm. At an average discharge rate of
800,000 gallons / day, based on this concentration limit 684.32 pounds / month of lead can be
discharged within limits to the Broad River in effluent water, provided the daily average
concentration for the month does not exceed 3.37 ppm, and the maximum daily concentration
does not exceed 3.75 ppm (Table 1).
Over the past 24 months, the average monthly lead concentration was 0.0072 ppm. This
concentration is well below the permit limit for lead at 3.37 ppm. At the current average daily
effluent discharge rate of 192,842 gallons / day, an average of 0.23 pounds / month of lead was
discharged over the past 24 months. This amount of lead is well below the mass at the chronic
permit limit described above, at 684.32 pounds / month.
The Maximum Effluent Concentration Limit was calculated using the Departments RPA
worksheet. Based on stream characteristics for the Broad River, an average of 800,000 gallons /
day discharge rate, a water hardness of 2,500 ppm, and using 0.500 ppm for the anticipated lead
concentration, the calculated maximum effluent concentration for chronic toxicity is 0.737 ppm.
This limit is conservative considering it is based on the permitted discharge rate (800,000 gallons
/ day average) as opposed to the actual discharge rate (192,000 gallons / day average), which is
much lower. Additionally, a higher anticipated lead concentration of 0.500 ppm was used in the
calculation, which is significantly higher than the average lead concentration in effluent water
over the past 24 months of 0.0072 ppm. Finally, flow is intermittent, averaging 12 days / month,
which reduces the likelihood of the calculated limit for the average monthly concentration being
exceeded.
Based on the calculated Maximum Effluent Concentration Limit, at an average of 800,000
gallons / day discharge volume the mass of lead that could be discharged within the calculated
limit is 150 pounds / month. The current monthly average discharge rate of 0.23 pounds / month
is well below the calculated limit on a mass basis.
Table 2 provides information on maximum lead concentrations in effluent flow over the past 24
months, the current acute toxicity permit limit, and the calculated maximum acute toxicity permit
limit using the RPA. Using the maximum discharge concentrations over the past 24 months, the
average of maximum monthly lead concentrations was 0.0096 ppm, and the maximum of all
daily lead concentrations recorded is 0.174 ppm. These concentrations are both well below the
3.75 ppm limit in the current permit, and is below the daily maximum (acute) limit of 17.07 ppm
for lead calculated using the RPA.
Summary
Figure 1 and Figure 2 summarize recent mass discharge levels for cadmium and lead, including
the mass discharge on an average monthly basis over the past 24 months, and mass limits for the
current permit limit and the anticipated limit based on the RPA, respectively. As shown on these
figures, under the current operating conditions and based on information over the past 24
3

months, cadmium and lead discharges on a monthly mass basis are well below the calculated
RPA maximum chronic and acute toxicity limit values for effluent discharge to the Broad River.
AZR is submitting this renewal application for renewal of the effluent discharge permit based on
effluent information contained in the DMR's submitted over the past 24 months. Anticipated
constituents and concentrations are provided in Table 4. Effluent water hardness determined
over the past 24 months of approximately 2,500 should be used for RPA calculations. The
current permit discharge volume should be maintained on an average daily discharge of 800,000
gallons / day.
4

TABLE 1
MONTHLY DISCHARGE INFORMATION - EFFLUENT FLOW, CONSTITUENT CONCENTRATION AND MONTHLY MASS DISCHARGE AMOUNT,
COMPARISON WITH CURRENT PERMIT AND CALCULATED CHRONIC EFFLUENT LIMITS (NEW RULE)
YEAR
MONTH
TOTAL DISCHARGE
FOR THE MONTH
(GALLONS)
NUMBER OF
DAYS FLOW
OCCURRED IN
MONTH
MONTHLY
AVERAGE FLOW
PER DAY
Monthly Average Concentrations (Mg/L)
Monthly Mass Discharged (Total Pounds)
Cd
Cr
Pb
Zn
F
TSS
Cd
Cr
Pb
Zn
F
TSS
.-1
N
January
14,260,000
29
491,724
0.0816
0.0055
0
0.94
31.5
6
9.70
0.65
0.00
111.9
3748.5
714
February
2,929,000
14
209,214
0.1230
0.00285
0.00275
5.36
12.9
10
3.01
0.07
0.07
131.0
315.3
244
March
4,092,000
18
227,333
0.1425
0
0.1425
1.07
0
7.25
4.87
0.00
4.87
36.5
0.0
248
April
2,460,000
13
189,231
0.0610
0
0
0.945
6.8
9.8
1.25
0.00
0.00
19.4
139.6
201
May
2,325,000
13
178,846
0.0340
0
0.0026
0.57
6.6
10.5
0.66
0.00
0.05
11.1
128.1
204
June
3,360,000
18
186,667
0.0560
0
0
1.35
9.2
10.5
1.57
0.00
0.00
37.9
258.0
294
July
1,705,000
10
170,500
0.0945
0
0
1.3
9.1
5.55
1.34
0.00
0.00
18.5
129.5
79
August
2,418,000
10
241,800
0.1740
0
0.003
2.85
10.3
8.3
3.51
0.00
0.06
57.5
207.8
167
September
540,000
4
135,000
0.1050
0
0.00275
4.46
7.7
4.65
0.47
0.00
0.01
20.1
34.7
21
October
1,271,000
8
158,875
0.0615
0
0
3.56
6
0
0.65
0.00
0.00
37.8
63.6
0
November
290,000
3
96,667
0.0680
0
0
3.7
4.7
0
0.16
0.00
0.00
9.0
11.4
0
December
651,000
6
108,500
0.0940
0
0
4.43
5.2
0
0.51
0.00
0.00
24.1
28.2
0
,^.,
N
MONTHLY
AVERAGE
January
1,364,000
10
136,400
0.0885
0
0
6.46
5.3
0
1.01
0.00
0.00
73.5
60.3
0
February
1,540,000
11
140,000
0.0465
0
0.0033
5.39
5.2
1.5
0.60
0.00
0.04
69.3
66.8
19
March
963,000
9
107,000
0.0555
0
0
3.9
8.2
2.15
0.45
0.00
0.00
31.3
65.9
17
April
2,265,000
15
151,000
0.0550
0
0
4.12
7.1
1.9
1.04
0.00
0.00
77.9
134.2
36
May
3,114,000
18
173,000
0.0360
0
0.0055
1.71
4.6
0
0.94
0.00
0.14
44.4
119.5
0
June
2,235,000
15
149,000
0.0490
0.005
0
2.65
5.7
1.5
0.91
0.09
0.00
49.4
106.3
28
July
2,338,000
14
167,000
0.0615
0.0028
0.005
1.9
6.8
7.6
1.20
0.05
0.10
37.1
132.7
148
August
1,582,000
14
113,000
0.0945
0
0
6.27
6.7
2.7
1.25
0.00
0.00
82.8
88.5
36
September
1,370,000
10
137,000
0.1675
0
0.0027
2.9
5.2
2
1.91
0.00
0.03
33.2
59.4
23
October
1,632,000
16
102,000
0.0975
0
0.00255
6.58
5
1.25
1.33
0.00
0.03
89.6
68.1
17
November
1,110,000
10
111,000
0.0360
0.038
0
18.98
7.5
0
0.33
0.35
0.00
175.8
69.5
0
December
TOTAL
303,000
56,117,000
2,338,208
3
291
12.13
101,000
0.0420
0
0
2.52
0
0.11
0.00
0.00
6.4
0.0
0
192,842
0.0802
0.0023
0.0072
3.91
7.39
3.88
1.62
0.05
0.23
53.6
251.5
104
Total Monthly Flow - Limit (gals)
24,333,333
Current Permit (Chronic) Limit (Monthly Average Concentration - Mg/L)
Permitted Monthly Mass (Total Pounds)
Flow /Day (gals)
Cd
Cr
Pb
Zn
F
TSS
Cd
Cr
Pb
Zn
F
TSS
800,000
0.27
6.75
3.37
No Limit
243.2
No Limit
54.83
1,371
684.32
No Limit
49,385
No Limit
Calculated Max Effluent Concentration Limit - Chronic Toxicity Limits (Mo. Avg - Mg/L)*
Calculated Allowable Max Monthly Mass (Total Pounds)
Flow /Day (gals)
Pb
TSS Cd
* Calculated using hardness of 2,500 for effluent water, and 25 for upstream hardness.
"0" value means not detected.
Parameter with Permit Limit
Pb
TSS

TABLE 2
MONTHLY DISCHARGE INFORMATION - MAXIMUM CONSTITUENT CONCENTRATION
COMPARISON WITH CURRENT PERMIT LIMITS
AND CALCULATED MAXIMUM DAILY (ACUTE) EFFLUENT LIMITS
YEAR
MONTH
Monthly Maximum Concentrations (Mg/L)
Cd
Cr
Pb
Zn
F
TSS
N
January
0.114
0.011
0
1.44
31.5
12
February
0.128
0.0057
0.0055
5.56
12.9
11.2
March
0.174
0
0.174
1.21
0
7.6
April
0.075
0
0
1
6.8
16.2
May
0.035
0
0.0052
0.64
6.6
12.2
June
0.099
0
0
1.6
9.2
15.5
July
0.1
0
0
1.5
9.1
6.5
August
0.228
0
0.006
4.4
10.3
11.8
September
0.14
0
0.0055
4.66
7.7
5.7
October
0.069
0
0
3.74
6
0
November
0.068
0
0
3.7
4.7
0
December
0.094
0
0
4.43
5.2
0
n�i
January
0.12
0
0
6.56
5.3
0
February
0.083
0
0.0066
9
5.2
3
March
0.057
0
0
4.2
8.2
4.3
April
0.08
0
0
4.53
7.1
3.8
May
0.038
0
0.011
2.23
4.6
0
June
0.057
5
0
2.8
5.7
3
July
0.078
0.0055
0.005
2.28
6.8
9.6
August
0.13
0
0
10.5
6.7
5.4
September
0.26
0
0.0054
3.9
5.2
6
October
0.12
0
0.0051
7.24
5
2.5
November
0.72
0.076
0
34.5
7.5
0
December
0.42
0
0
2.52
0
MONTHLY
AVERAGE
0.1453
0.2124
0.0096
5.17
7.39
5.68
Current Permit (Acute) Limit (Daily Maximum Concentration - Mg/L)
Cd
Cr
Pb
Zn
F
TSS
1.66
113.6
3.75
No Limit
243.2
No Limit
Calculated (Acute) Limit (Daily Maximum Concentration - Mg/L)
Cd
Pb
0.63 17.07
* Calculated using hardness of 2,500 for effluent water, and 25 for upstream
hardness, and at 800,000 gallons / day average flow.
F
TSS
"0" value means not detected.
Parameter with Permit Limit

TABLE 3
MONTHLY DISCHARGE INFORMATION - OTHER MONITORED CONSTITUENTS
DAILY MAXIMUM AND AVERAGE MONTHLY CONSTITUENT CONCENTRATION
L_ Cpn tituen '
— uni - --
.Maximum- --- -----Tir11-----
_ _-Average ----- __
_
NH3-N
Mg/L
0.12
0.017
Total Aluminum
Mg/L
0.151
0.0713
Total Antimony
Mg/L
0.0445
0.0125
Total Arsenic
Mg/L
Not Detected
Not Detected
Chlorides
Mg/L
4700
1440
Total Cobalt
Mg/L
0.0072
0.001
Total Copper
Mg/L
0.0238
0.0034
Total Fluoride
Mg/L
31.5
25.3
Total Iron
Mg/L
110
15.7
Total Nickel
Mg/L
0.0071
0.0028
Total Tin
Mg/L
0.0068
0.001
pH
standard units
6.6 - 8.3
6.5 - 7.3
Chronic Toxicity
Pass / Fail
Failed 1 Time in 8 Monitored Periods
Effluent Turbidity
NTU
13.8
3
Upstream Turbidity
NTU
83.4
17
Downstream Turbidity
NTU
87.3
17

TABLE 4
ANTICIPATED CONSTITUENTS - AVERAGE CONCENTRATION
Constituent
Mg/L
Chlorides
17,000
Fluoride
20
Iron
0.0157
Tin
0.001
Arsenic
0.25
Zinc
4.00
Nickel
0.150
Cobalt
0.001
Copper
0.160
Cadmium
0.100
Lead
0.500
Aluminum
0.151
Chromium
0.004
Antimony
0.250

Figure 1
Cadmium Mass Discharge
60
O O O O • • • • • • • ♦ • • • • • • • • • •
50
40
o_ 30
• • • 0 •
20
10
0
• • • • • • • • a • • • • O
1 • +
�0 0 ro 0 6 �o �o �o �0 6 �o �0 1 1 1 1 1 1 1 1 1 1 1 1
O>' 01' O>' Off' O,' O>' 01' O>' Oh' 6ti` O Off' 6s' Off' O 01' O,' Off'
c�ti c,ti rti i�� aa1ceti J▪ 1 awry e�� e�ti e��•
e�1 r�ry c�� r �aa ceti >�� Jti e�1e�ti e�ti eC• ti
at pQ `3 >° > �� �`o .0 �co �'° OJa 01a� pQ �S >s > 01P �o .° F0 Fo
>a <cer p Q�e 0L� o4e e(e Qua 06 owe eye
0O C O
--1-Monthly Mass Discharged --*—Permitted Monthly Mass —S—RPA Calculated Allowable Max Monthly Mass

800
700
600
500
a° 400
TD
0
F-
300
200
100
Figure 2
Lead Mass Discharge
— n a • • •
0 • • • • • • • • • • • • • • • • • • • • • • •
Co 0 Co �0 0 Co Co 0 6 0 0 Co 1 1 1 1 1 1 1 1 1 1 1 1
0, O,' O 01' O, O,' O, 01' O,' O,' O, O,' O,' O,' 6, O,' O, O,' O,' O, O,' O, O, O,
Dck1 ak1 `rti `�1 a�� c¢1- JNA 0` '1' Z�� il' il. 61' t ry tam rry Q�`� aa, Jo¢. >J�a"95-1°Qc - b¢`1" oil
°eta
>ac, (to,
J C\a PQ $ s
PJ� Qte‘� O°� °,a�� y`a�o >aJa cIeOCJaa` P > QJ� Q�ycc 01c° oaf yca�
5e a O 4 , O
tMonthly Mass Discharged tPermitted Monthly Mass—•--RPA Calculated Allowable Max Monthly Mass

AMERICAN
ZINC PRODUCTS
An AZR Company
October 20, 2017
Sergei Chernikov, Ph.D.
Environmental Engineer II
Complex NPDES Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
Express Mail: 512 N. Salisbury St., Raleigh, NC 27604
Re: NPDES Application for a Permit Modification, Permit NC0089109
Dear Dr. Chernikov:
484 Hicks Grove Road
Mooresboro, NC 28114
www.azr.com
RECEIVEDINCDEQIDWR
OCT 302017
Water �ivaliiy
Permitting Section
On August 31, 2017, American Zinc Products LLC ("AZP") submitted to the
North Carolina Department of Environmental Quality (the "Department") an application
for a modification to its existing NPDES Permit #NC0089109. Based on a continuing
review of planning for future restart of the facility, AZP hereby withdraws the application
submitted to the Department on August 31, 2017, which consequently vitiates the draft
modified permit you issued on October 16, 2017.
AZP appreciates the Department's assistance in this matter. If you have any
questions, please do not hesitate to contact Jim Harris at 828-919-3139.
(-
Rob Williamson
General Manager
cc: Ali Alavi

828 296 4680 office
$28 230 4057 mobile
Landon.Davidsonncdenr.qov
2090 U.S. Hwy. 70
Swannanoa, N.C. 28711
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Davidson, Landon
Sent: Tuesday, June 27, 2017 2:08 PM
To: Heim, Tim <[e-mail]>; Chernikov, Sergei <sergei.chernikovWncdenr.gov>
Subject: FW: Horsehead storm water/ waste water permit renewal
fyi _ (�
G. Landon Davidson, P.G. 1 i -:—. SAAN'
Regional Supervisor - Asheville Regional Office 0 �� �(
Water Quality Regional Operations Section 1; ,�`
NCDEQ - Division of Water Resources �L f v_ Njj‘d-
Landon.Davidsonncdenr.qov
t v-' 828 296 4680 office `-' �828 230 4057 mobilet`�(7‘
2090 U.S. Hwy. 70
Swannanoa, N.C. 28711
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
:/
From: Burch, Brent
Sent: Tuesday, June 27, 2017 2:03 PM
To: Davidson, Landon <[e-mail]>; Randall, Mike <[e-mail]>
Cc: Woosley, Julie <[e-mail]>; Aiken, Stan E <[e-mail]>; Morris, Sean
<[e-mail]>; Menzel, Jeff <[e-mail]>
Subject: FW: Horsehead storm water/ waste water permit renewal
Hi Landon and Mike,
The Hazardous Waste Section is requesting that DEMLR and DWR put all stormwater and NPDES permit modifications related
to Horsehead on hold until we can determine what impact, if any, those modifications may have on our regulatory jurisdiction
related to a joint HWS/EPA January sampling event. As both of you may be aware, 9 of 15 sample results came back exceeding
hazardous waste limits for one or more constituents including lead, cadmium, chromium or silver. All 9 areas are, or could be,
related to stormwater management or regulated discharges.
HWS will be having a conference call this Thursday with Horsehead and EPA to discuss the sampling results. Additionally, HWS
continues to work with EPA to establish a plan of action to address both our concerns at the site. I know all of our programs
have responsibilities to respond to our customers in a timely manner, so if we need to reach out to DEMLR or DWR staff at the
Division level we would be happy to do so.
Please let me know if you have any questions, concerns or thoughts on moving forward. I would be happy to set up a
conference call where we can all discuss this in more detail internally if that is preferred.
Thanks...Brent
2

Grzyb, Julie
From: Grzyb, Julie
Sent: Tuesday, June 27, 2017 5:41 PM
To: Davidson, Landon
Subject: RE: Horsehead storm water/ waste water permit renewal
Landon,
Thanks for the update, I'll put a copy of this email in the file.
So you know - NC0089109 was issued to Horsehead Holding Corporation on 11/20/2015. It doesn't expire until 7/31/2018.
Charles Weaver said —"They sent in a name & ownership change request for one of their General Permit CoCs, but not for
NC0089109. I think that may have been processed but that kind of modification has no impact on limits or monitoring
requirements."
Hope that was okay,
Julie
Julie A Grzyb
Supervisor
NPDES Complex Permitting
NC DEQ I Division of Water Resources I Water Quality Permitting
919 807 6390 office
919 707 9000 main office
julie.grzyb(a ncdenr.gov
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617
'7> Nothing Compares
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Davidson, Landon
Sent: Tuesday, June 27, 2017 2:08 PM
To: Grzyb, Julie <[e-mail]>
Subject: FW: Horsehead storm water/ waste water permit renewal
fyi
G. Landon Davidson, P.G.
Regional Supervisor — Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
1

Brent G. Burch
Compliance Branch Head
Hazardous Waste Section
Division of Waste Management
828 321 9585 office
919 270 2049 mobile
Brent.Burch(a�ncdenr.gov
PO Box 1427
Andrews, NC 28901
!''Nothing Compares
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Menzel, Jeff
Sent: Friday, June 23, 2017 3:58 PM
To: Burch, Brent <[e-mail]>; Morris, Sean <[e-mail]>
Subject: Horsehead storm water/ waste water permit renewal
Sean and Brent,
After reviewing the current draft of Storm Water permit NCS000562 for American Zinc Products LLC (former Horsehead
Metals), I would like to request that this draft and any other NPDES permit be placed on hold.
The current storm water permit does not expire until March 2018 and I feel that any analytical data available along with
observations made by HWS during site visits staff be conveyed to DEMLR/DWR before any subsequent permits are issued.
This facility, in its shorts life span, has had numerous spills of hazardous material with the primary conveyance being the storm
water/wastewater systems. There are NPDES permits issued for both.
The facility has asked for DEQ's input during their current engineering phase prior to starting operations again in 2018. To
facilitate a beneficial response to the facility I think it is prudent that the various Division's share information or concerns
regarding permit requirements or applicable regulations.
If you need any additional information or supporting documentation for this request I will be happy to provide that.
Thanks,
Jeff
Jeff Menzel
3

Western Region Environmental Specialist
Hazardous Waste Section
Division of Waste Management
828 419 5034 office
919 270 1967 cell
[e-mail]
PO Box 117
Black Mountain, NC 28711
-:5,'Nothing Compares
Email correspondence to and from this address is subject to the
Notch Carolina Public Records Law and may be disclosed to third parties.
4