NC0089109_Permit Modification_20151120

NPDES DOCUMENT SCANNING COVER SHEET
Aift
oft
MIR
41.11.
INN
NPDES Permit:
NC0089109
Document Type:‘
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
-
-Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Meeting Notes
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
November 20, 2015 .
This document is printed on reuse paper - ignore any
content on the reYerse side

North Carolina Department of Environmental Quality
Pat McCrory
Governor
Mr. Anthony Staley, Plant Manager
Horsehead Metal Products Inc.
484 Hicks Grove Road
Mooresboro, North Carolina 28114
Dear Mr. Staley:
Division of Water Resources
Donald R. Van der Vaart
Secretary
November 20, 2015
Subject: Issuance of NPDES Major Modification
Permit NC0089109
Rutherford County Production Facility
Rutherford County
Facility Class II
Division personnel have reviewed and approved your application for a major modification of
the subject permit. Accordingly, we are forwarding the attached NPDES discharge permit. This
permit is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the
Memorandum of Agreement between North Carolina and the U.S. Environmental Protection Agency
dated October 15, 2007 (or as subsequently amended).
The following changes have been incorporated into this major modification:
• Increase in flow limit from 0.62 MGD to 0.8 MGD.
• The limits for Total Cadmium, Total Fluoride, and Total Lead were recalculated based on the
new flow estimate.
• The limits for Total Chromium were added based on the results of the Reasonable Potential
Analysis.
• Proposed federal regulations require electronic submittal of all discharge monitoring reports
(DMRs) and specify that, if a state does not establish a system to receive such submittals, then
permittees must submit DMRs electronically to the Environmental Protection Agency (EPA).
The Division anticipates that these regulations will be adopted and is beginning
implementation.
The requirement to begin reporting discharge monitoring data electronically using the NC
DWR's Electronic Discharge Monitoring Report (eDMR) internet application has been added
to your final NPDES permit. [See Special Condition A. (3.)] For information on eDMR,
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone]
Internet: www.ncwaterqualitv.orq
NOne Cat'011111
7Vatunil4,'
An Equal opportunity 1 Affirmative Action Employer

registering for eDMR and obtaining an eDMR user account, please visit the following web
page:
http://portal.ncdenr.org/web/wq/admin/bog/ipu/edmr.
For information on EPA's proposed NPDES Electronic Reporting Rule, please visit the
following web site:
http: //www2.epa.gov/compliance/proposed-npdes-electronic-reporting-rule.
• The monitoring frequency for pH was increased to daily.
• The monitoring frequency for Total Cadmium, Total Chromium, Total Lead, Total Zinc, and
TSS were increased to 2/Month.
If any parts, measurement frequencies or sampling requirements contained in this permit
modification 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 permits required by the Division of Land Resources, the Coastal Area Management Act
or any other Federal or Local governmental permit that may be required. If you have any questions
concerning this permit, please contact Sergei Chernikov at telephone number [phone].
dS. Jay Zimmerman P.G.
tti Director, Division of Water Resources
cc: Cenral Files
NPDES Files
Asheville Regional Office / Water Quality
WSS/Aquatic Toxicology Unit (e-copy)

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,
Horsehead Metal Products Inc.
is hereby authorized to discharge wastewater from a facility located at
Rutherford County Production Facility
Forest City
Rutherford County
to receiving waters designated as -the Broad River- in the Broad River Basin inaccordancewith effluent
limitations, monitoring requirements, and other applicable conditions set forth in Parts I, II, III and IV
hereof.
This permit modification shall become effective January 1, 2016.
This permit and authorization to discharge shall expire at midnight on July 31, 2018.
Signed this day November 20, 2015.
0144
6.0/, S. Jay Zimmerman P.G., Director
Division of Water Resources
By Authority of the Environmental Management Commission
Page 1 of 6

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.
Horsehead Metal Products Inc. is hereby authorized to:
1. After constructing the wastewater treatment facility, operate it in accordance with the
existing wastewater treatment system consisting of the following components:
➢ Automatic sampler
➢ Instrumented flow measurement, and
➢ Diffuser
The facility is located near Forest City, Rutherford County; and
2. Discharge from said treatment works at the location specified on the attached map into
the Broad River which is classified C waters in the Broad River Basin.
Page 2 of 6

Permit NC0089109
Part I
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 '
CHARACTER STICS
LIMITS'
-MONITORING REQUREMENTS:
Monthly
Average
Daily`
Maximum
Measurement,
. Frequency '
Sample
.Tye .
Sle_
ampLocation1
Flow (MGD)
0.80
Continuous
Recording
I or E
Total Suspended Solids
2/Month
Composite
E
NIA-N
QuarterIy
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
Composite
E
Chlorides
Quarterly
Composite
E
Total Chromium
6.75 mg/L
113.6 mg/L
2/Month
Composite
E
Total Cobalt
Quarterly
Composite
E
Total Copper
Quarterly
Composite
E
Total Fluoride
243.2 mg/L
243.2 mg/L
Monthly
Composite
E
Total Iron
Quarterly
Composite
E
Total Lead
3.37 mg/L
3.75 mg/L
2/Month
Composite
E
_Total Nickel
Monthly
Composite
—E
Total Tin
Quarterly
Composite
E
Total Zinc
2/Month
Composite
E
pH2
Daily
Grab
E
Chronic Toxicity3
Quarterly
Composite
E
Turbidity4
Monthly
Grab
E, U, D
1VV1i7:
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 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. 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

Permit NC0089109
A. (2.) CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QUARTERLY)
The effluent discharge shall at no time exhibit chronic toxicity using test procedures outlined in the "North Carolina
Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised November 1995, or subsequent versions.
The effluent concentration at which there may be no observable inhibition of reproduction or significant mortality is
0.74% (defined as treatment two in the procedure document). The permit holder shall perform quarterly monitoring
using this procedure to establish compliance with the permit condition. The tests will be performed during the
months of January, April, July and October. Effluent sampling for this testing shall be performed at the NPDES
permitted final effluent discharge below all treatment processes.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form (MR-1) for the month in which it was performed, using the parameter code TGP3B. Additionally,
DWR Form AT-1 (original) is to be sent to the following address:
Attention: North Carolina Division of Water Resources
Water Sciences Section
1623 Mail Service Center
Raleigh, North Carolina 27699-1623
Test data shall be complete and accurate and include all supporting chemical/physical measurements performed in
association with the toxicity tests, as well as all dose/response data. Total residual chlorine of the effluent toxicity
sample must be measured and reported if chlorine is employed for disinfection of the waste stream.
Should there be no discharge of flow.from the facility during a month in which toxicity monitoring is required, the
permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the
facility name, permit number, pipe number, county, and the month/year of the report with the notation of "No
Flow" in the comment area of the form. The report shall be submitted to the Water Sciences Section at the address
cited above. Should any single quarterly monitoring indicate a failure to meet specified limits, then' monthly
monitoring will begin immediately until such time that a single test is passed. Upon passing, this monthly test
requirement will revert to quarterly in the months specified above. Should the permittee fail to monitor during a
month in which toxicity monitoring is required, then monthly monitoring will begin immediately until such time
that a single test is passed. Upon passing, this monthly test requirement will revert to quarterly in the months
specified above.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water
Resources indicate potential impacts to the receiving stream, this permit may be re -opened and modified to include
alternate monitoring requirements or limits.
If the-Permittee monitors any pollutant more frequently then required by this permit, the results of such
monitoring shall be included in the calculation & reporting of the data submitted on the DMR & all AT
Forms submitted.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control
organism survival, minimum control organism reproduction, and appropriate environmental controls, shall
constitute an invalid test and will require immediate follow-up testing to be completed no later than the last
day of the month following the month of the initial monitoring.
Page 4 of 6

Permit NC0089109
A. (3.) ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS
Proposed federal regulations require electronic submittal of all discharge monitoring reports
(DMRs) and specify that, if a state does not establish a system to receive such submittals, then
permittees must submit DMRs electronically to the Environmental Protection Agency (EPA). The
Division anticipates that these regulations will be adopted and is beginning implementation in late
2013.
NOTE: This special condition supplements or supersedes the following sections within Part II of
this permit (Standard Conditions for NPDES Permits):
• Section B. (11.)
• Section D. (2.)
• Section D. (6.)
• Section E. (5.) •
Signatory Requirements
Reporting
Records Retention
Monitoring Reports
1. Reporting [Supersedes Section D. (2.) and Section E. (5.) (a)1
Beginning no later than 270 days from the effective date of this permit, the permittee shall
begin reporting 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 DENR / DWR / Information Processing Unit
ATTENTION: Central Files / eDMR
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
submitted to the mailing address above.
Requests for temporary waivers from the NPDES electronic reporting requirements 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 using eDMR. Temporary
waivers shall be valid for twelve (12) months and shall thereupon expire. At such time, DMRs
shall be submitted electronically to the Division unless the permittee re -applies for and is
granted a new temporary waiver by the Division.
Page 5 of 6

Permit NC0089109
Information on eDMR and application for a temporary waiver from the NPDES electronic
reporting requirements is found on the following web page:
http:/ /portal.ncdenr.org/web/wq/admin/bog/ipu/edmr
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.
2. Signatory Requirements [Supplements Section B. (11.) (b) and supersedes Section B. (11.)
(d)1
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: / /portal.ncdenr.org/ web/wq/ admin./bog/ ipu/ 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 certtfij, 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 nay knowledge and belief true, accurate, and complete. I am aware that there
are significant penalties for submitting false information, including the possibility of fines and
imprisonment for knowing violations."
-3. . ecor s Retention [Supplements Section D. (6.)1
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].
Page 6 of 6

NoWN CAROLINK-')
SOUTH CAtiOLINA
Latitude: 35°12'3" Sub -Basin: 03-08-02
Longitude: 81°51'3"
Quad #: F11SW
Stream Class: C
Receiving Stream: Broad River
Permitted Flow: 0.8 MGD
Facility 441111,
Location
North
Horsehead Corporation
NC0089109
Rutherford County Production Facility

NCDEQ/DWR
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
MAJOR MODIFICATION
Horsehead Metal Products Inc.
NC0089109
Facility Information
(1.) Facility Name:
Rutherford County Production Facility
(2.) Permitted Flow (MGD):
0.8
(6.) County:
Rutherford
(3.) Facility Class:
II
(7.) Regional Office:
'Asheville
(4.) Pretreatment Program:
N/A
(8.) USGS To . o Quad:
F11SW
(5.) Permit Status:
Major Modification
(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:
9'136.5)
(9.) Winter 7Q10 (cfs):
334
(4.) Stream Classification:
C
(10.) 30Q2 (cfs):
403
(5.) 303(d) Status:
Not listed
(11.) Aver ge Flow (cfs):
914
(6.) 305(b) Status:
(12.) IWC %:
0.74
Summary
This is a Major Modification for the permit for Horsehead Metal Products Inc. The facility
is located in the southern portion of the Rutherford County. The facility uses the impure
zinc oxide that is generated from the recycled EAF dust in other Horsehead facilities. The
EAF dust is a zinc containing waste generated by the North American mini mills. The
facility will produce approximately 148,000 tons of high quality prime -Western grade Zinc
metal. The process will include zinc oxide leaching, extraction of zinc with an organic ligand
and electrowinning. The facility will achieve significant degree of recycling of the reagents
that are used in the process. This would be a first facility of this type in the USA, and there
are no effluent guidelines for Zinc recycling facilities.
The original estimates for the wastewater flow were incorrect, the new flow is estimated to
be 0.8 MGD. The Major Modification is conducted to accommodate the flow increase in the
permit. The updated EAA was submitted by the McGill Associates on behalf of the
Horsehead Corporation on December 27, 2013. The EAA was approved on January 2,
2014, it allows discharge of 0.8 MGD treated industrial wastewater. The wastewater
generated by the facility is essentially a clean brine solution that has a high concentration of
chlorides (19,680 mg/L). Potable water and sanitary sewer service will be provided by the
Forrest City.
RPA
The RPA (reasonable potential analysis) was updated to incorporate a new flow limit of 0.8
MGD. The original application identified the number of pollutants that might be present in
the discharge. The RPA was conducted for these pollutants: iron, chlorides, fluoride, tin,
arsenic, zinc, nickel, cobalt, copper, cadmium, lead, aluminum, chromium, and antimony.
The RPA indicated that the limit is necessary for cadmium, lead, fluoride, and chromium
Page 1 of 3

NPDES Permit Fact Sheet — 11 /23/ 15 Horsehead Metal Products Inc.
Page 2 NC0089109
WET
The whole effluent toxicity testing was assigned in accordance with 15A NCAC 2B.0508
PERMIT LIMITS
• The limits for Total Cadmium, Total Chromium, Total Fluoride, and Total Lead
were established as a result of the Reasonable Potential Analysis of the effluent data.
These limits are necessary to prevent contravention of the state water quality
standards and the EPA criteria in the receiving water body.
• The pH limits and turbidity limits are based on the state water quality standards.
• The whole effluent toxicity testing was assigned in accordance with 15A NCAC
2B.0508
PROPOSED CHANGES
• The limits for Total Cadmium, Total Fluoride, and Total Lead were recalculated
based on the new flow estimate.
• The limits for Total Chromium were added based on the results of the Reasonable
Potential Analysis.
• Proposed federal regulations require electronic submittal of all discharge monitoring
reports (DMRs) and specify that, if a state does not establish a system to receive such
submittals, then permittees must submit DMRs electronically to the Environmental
Protection Agency (EPA). The Division anticipates that these regulations will be
adopted and is beginning implementation.
The requirement to begin reporting discharge monitoring data electronically using
the NC DWR's Electronic Discharge Monitoring Report (eDMR) internet
application has been added to the permit. [See Special Condition A. (3.)]
Proposed Schedule for Permit Issuance
Draft Permit to Public Notice:
Permit Scheduled to Issue:
January 14, 2014 (est.)
March 10, 2014 (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 Modification:
The facility has experienced numerous issues with compliance, including:
1. Facility compliance history including permit DMR violations and violations/CPAs
related to spills to date.
2. Spills and releases, including the April 25 and May 19 "depleted solution" pipe
failures, and the September 5th storm sewer/ storm water basin contamination event
resulting from the "cellhouse" containment failure.
3. Discharges of gypsum material via the WW outfall which have accumulated on the
riverbed adjacent to the outfall.
Page 2 of 3

NPDES Permit Fact Sheet — 11/23/ 15 Horsehead Metal Products Inc.
Page 3 NC0089109
4. The potential for events (including those described above) at the facility to enter the
storm sewer and industrial discharge conveyance system.
5. Continued failed effluent toxicity at the Riverstone WWTP (facility that accepts
domestic wastewater from Horsehead plant) due to zinc from March 2014 to date.
6. Other related events in the area which may have been influenced by the Horsehead
facility.
Therefore, the following changes have been incorporated into the Final Major Modification:
1. The monitoring frequency for pH was increased to daily.
2. The monitoring frequency for Total Cadmium, Total Chromium, Total Lead,
Total Zinc, and TSS were increased to 2/Month.
Page 3 of 3

Whole Effluent Toxicity Testing and Self Monitoring Summary
Holly Springs WWTP-Utley Crk NC0063096/001
Ceri7dPF Begin: 11/1/2011 chr lim: 90%
County: Wake
NonComp: Single
Region: RRO Basin: CPF07 Feb May Aug Nov SOC JOC:
7010: 0.11 PF: 2.4 IWC: 95 Freq: Q
J F M A M J J A S 0 N D
2010 * Pass * >100(P) Pass * * Pass * * Pass *
2011 * Pass * * Pass * * Pass * * Pass *
2012 * Pass * * Pass * * Pass * * Pass *
2013 * Pass * * Pass * * Pass * * Pass *
2014 * Pass * * Pass * * Pass * * Pass *
2014 * * * * H * * H * * H *
2015 * Pass * * Pass * * * * * * *
2015 * * * * H * * * * * * *
Horsehead Metals -Rutherford Cnty Pro NC0089109/001 County: Rutherford Region: ARO Basin: BRD02 Jan AprJul Oct SOC JOC:
Ceri7dPF Begin: 1/1/2014 Chr Lim: 0.57% NonComp: 7Q10: PF: 0.62 IWC: Freq: Q
J F M A M J J A S 0 N D
2012 * * * * * * * * * H * *
2014 * * * H * * Pass * * Pass * *
2015 Pass * * Pass * * Pass * * * * *
Hospira, Inc. NC0001589/003 County: Nash Region: RRO Basin: TAR02 MarJun Sep Dec SOCJOC:
Fthd24PF Begin: 5/1/2010 Ac P/F Monit: 90% Ft NonComp: 7Q10: PF: IWC: Freq: Q
J F M A M J J A S 0 N D
2010 * * * * * Pass * * Pass * * Pass
2011 * * Pass * * Pass * * H * * H
2012 * * H * * H * * H * * H
2013 * * H * * H * * H * * H
2014 * * H * H * * H * * H
2015 * * H * * H * * * * * *
House of Raeford - Wallace Division NC0003344/001 County: Duplin Region: WIRO Basin: CPF22 MarJun Sep Dec SOC JOC:
Ceri7dPF Begin: 7/1/2007 chr lim: 57% NonComp: Single 7Q10: 1.77 PF: 1.5 IWC: 57 Freq: Q
J F M A M J J A S 0 N D
2010 * * Pass * Pass * * Pass * * Pass
2011 * * Pass * Pass * * Pass * * Pass
2012 * * Pass * * Pass * * Pass * * Pass
2013 * * Pass * * Pass * * Pass * * Pass
2014 * * Pass * * Pass * * Pass * * Pass
2015 * * Pass * * Pass * * * * * *
Page 66 of 148

Horsehead Corporation REASONABLE POTENTIAL ANALYSIS
NC0089109
Outfall 001
Qw=0.8MGD
Qw (MOD) = 0.80
IQIOS(cfs)- 135.80
7Q10S(cfs)= 167.00
7Q1OW (cfs) - 334.00
30Q2 (cfs) - 403.00
Avg. Stream Flow. QA (cfs) = 914.00
Receiving Steam: Broad River
WWTP/WTP Class: Ill
IWC Q IQIOS = 0.90%
iWC Ca 7Q10S= 0.74%
IWC§7QIOW = 0.37%
IWC30Q2= 0.31%
IWCQA 0.14%
Stream Class: C
PARAMETER
TYPE
(1)
STANDARDS a CRITERIA (2)
=
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
NC WQS / Applied IAFAv /
Chronic Standard Acme
n 8 Dot Max Prcd Cw Allowable Cw
Arsenic
Arsante
C
C
50 FW(7Q10s)
10 HH/WS(Qavg)
ug/L
ug/1.
1 1
Note: n<12
Limited data set
1 1
Note: u<12
I 3,490.1
Default C.V.
3,490.1
Default C.V.
Acute: NO WQS
_ —
Chroaic:---- 6,756.8
No value >Allowable Cw
Chronic: -
No value > Allowable Cw
miimit
—•—•—•---•---•—•—•—•—._ _..
- ---- --------.--.-.-.-..
Cadmium
NC
2 FW(7Q10s) 15
ug/L
1 1
Note: 0<l2
Unshed data set
1,745.0-------------•-•-•-•-•--
Default C.V.
Acme: 1,666.7
Ch:otuic: - 270.3
No value > Allowable Cw
add fsaa
NC
230,000 FW(7Q1Os)
ug/L
1 1
Note: n<12
Note:
Umited data set
286,186,560
Default C.V.
Acme: NO WQS
- _ _ _ -----------
Ch:onic: 31,081,081
No value> Allowable Cw
n''''''
----- -•-•--- ---
Ctvontum
NC
50 FW(7Q10a) 1022
ug/L
1
Note: n<12
Unshed data set
I 17,450.4
Default C.V.
Acute: 113,555.6
^.-.-.-.-.-_-.-._.-.-•-.-.-..
Chrmic: - - 6,756.8
No value> Allowable Cw
add We1
Coppar(AL)
NC
7 FW(7QI03) 7
ug/L
1 I
Note: tt<12
Limited data set
I l,745
Default C.V.
Acme: 811.1
-.^.-_-_-.-.-.-.-._.-.-_-.-._..
Chrmic: - - 945.9
No value> Allowable Cw
ro Ertel
action level standard
Fluoride
NC
1800 FW(7Q10s)
ug/L
1 1
Note: n<12
Limited data set
349,008.0
Default C.V.
Acute: NO WQS
•hra Ctic: • 243,243.2 -
No value> Allowable Cw
add 'ma
_.-._._.-._._._._.-.-..
Lead
NC
25 FW(7Q10s) 33.8
ug/l.
1 1
Note: n<12
United data set
8,725.2
Default C.V.
Acute: 3,755.6
_ _ —
Chronic:-----3,378.4
No value> Allowable Cw
add rank
—•—•--- •------- •—•—•—•—•—•-
rectal
NC
88 FW(7Q10s) 261
ug/L
1 1
Note: o<12
limited data set
I 8,725.2
Default C.V.
Acme: 29,000A
Chronic: - --
11891.9
No value> Allowable Cw
raEinst ---•- --- - • -.
- -•---
Zinc (AL)
NC
50 FW(7Q10s) 67
ug/L
1 1
Note: n<12
Limited data set
17,450.4
Default C.V.
Acme: 7,444.4
___ _ _ ___ ___
Chronic: 6,756.8
No value> Allowable Cw
ro &nit
—_—___—_—_—_—___—_—_— —
action WM standard
Horsehead Corporation
NC0089109
Page 1 of 2
REASONABLE POTENTIAL ANALYSIS
89109 • RPA.2014, rya
1I812014
Outfall 001
Qw = 0.8 MGD
Cobalt
NC
270 1111(7Q103)
ug/1.
1 1
Note: n<12
Limited data set
1,745.04000
Default C.V.
Acute: NO WQS
-----•—
Chronic: 36486.48649
No value> Allowable Cw
roEEmN
—-------•_•—•—•-
Atutdnum
NC
8000 FW(7Q10s)
ug/L
1 1
Note: n<12
Limited data set
I 34,900.80000
Default C.V.
Acute: NO WQS
Chronic: 1081081.08108
No value> Allowable Cw
roEtrmlt.----------- ----- — —•-
Antimony
NC
640 HH(7Q10s)
ug/L
1 1
Note: n<12
Limited data set
I 3,490.08000
Default C.V.
Acute: NO WQS
_ _ —
Chronic: 86486A8649
No value> Allowable Cw
ro Emit
---•---•-------•---•— —._.
Tin
NC
800 HH(7Q10s)
ug/L
1 1
Note: n<12
Limited data set
34,900.80000
Default C.V.
Acute: NO WQS
__ Chronic _ _ _•_•_•_•-•-•-•-•-•_•_•_•_•_••
:__ - 108108.10811
No value> Allowable Cw
ro C re
Pape 2 of 2
89109 - RPA•2014.:pa
119t2014

Horsehead Corporation REASONABLE POTENTIAL ANALYSIS
NC0089109
Qw (MGD) = 0.80
1Q1OS (cfs) = 135.80
7Q I OS (cfs) = 167.00
7Q1 OW (cfs) = 334.00
30Q2 (cfs) = 403.00
Avg. Stream Flow, QA (cfs) = 914.00
Receiving Stream: Broad River
WWTP/WTP Class: III
IWC @ 1Q1OS = 0.90%
IWC @ 7Q1OS = 0.74%
IWC @ 7QIOW = 0.37%
IWC @ 30Q2 = 0.31%
IWC@QA= 0.14%
Stream Class: C
Outfall 001
Qw=0.8 MGD
PARAMETER
TYPE
(1)
STANDARDS & CRITERIA (2)
-i
a
co
1-
Z
D
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
NC WQS /
Chronic
Applied
Standard
1/2 FAV /
Acute
n # Det. Max Pred Cw Allowable Cw
Iron
NC
1000
HH(7Q10s)
ug/L
1 1
Note: n<12
Limited data set
17,450.40000
Default C.V.
Acute: NO WQS
___ _ _______ _ _ _ __
Chronic: 135135.13514
No value > Allowable Cw
no limit
__ ___
____________________
•
Page 1 of 1
89109 - RPA-2-2011, rpa
1/9/2014

HORSEHEAD METAL PRODUCTS. INC.
484 HICKS GROVE ROAD
MOORESBORO, NORTH CAROLINA 28114
February 12, 2014
HORSEHEAD
METAL PRODUCTS, INC.
Sergei Chernikov Ph.D.
Environmental Engineer II
Complex NPDES Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699
Subject: Comments on Draft Process Water Discharge NPDES Permit - NC0089109
Dear Mr. Chernikov:
We appreciate your timely response to our request for modification of Horsehead's process
wastewater discharge NPDES Permit. As requested, the Draft reflects an increase in our flow
limit from 0.62 MGD to 0.80 MGD. We have reviewed the additional proposed revisions
associated with this flow increase and would like to request consideration for 1) the use of mass
limits as an alternative to the effluent limits expressed as a concentration, and 2) a Chronic
Toxicity requirement tied to actual facility effluent flow. In support of these requested changes
we offer the following comments:
1) The effluent limitations for Total Cadmium, Total Chromium, Fluoride, and Total Lead
are expressed as monthly average and daily maximum concentration levels. While we
understand through our review of the supplemental information you provided that these
limits were established using NC's Water Quality Standards which are expressed as
concentrations, we believe mass limitations provide effective protection of -the reference
standards. The 7Q10 of the Broad River at our outfall is approximately 107 MGD.
Under design low flow conditions our discharge will have a dilution ratio > 133 to 1.
The flow of our effluent within the ranges expected during normal operation is an
insignificant factor in determining the concentration below our outfall. Revision of our
concentration limit to mass (lbs/day, e.g.) secures protection of the Water Quality
Standards.
Mass based limits are more appropriate considering the operational parameters of this
facility. The zinc recycling process used by Horsehead is a continuous process and the
mass of each feedstock component during operation will be relatively constant,
depending on the production level. As a result the components of the wastewater from
our operation in mass terms are relative constant as well. However, the concentrations of
these components within our process and in the plant effluent will vary based on the
water balance during any production cycle. Process water balance at our facility is
affected not only by normal use of water for the process, but also due to careful
management of stormwater under the Divison's NPDES Stormwater Permit. The
availability of stormwater to replace finished water for process use supplied by the Town

HORSEI-IEAD METAL PRODUCTS, INC.
484 HICKS GROVE ROAD
MOORESBORO, NORTH CAROLINA 28114
METAL PRODUCTS, INC.
of Forest City is dependent upon weather conditions, and by definition will be variable
over any specific discharge period. Consequently, the application of concentration
effluent limits is an unnecessary constraint on our ability to effectively minimize finished
water consumption for process use at the facility.
Related to the importance of water balance at this facility are the company's ongoing
efforts to reduce water use. We continue to evaluate ways to effectively reduce water
usage on this site, factoring in production demands, use of finished water from the Town
of Forest City and stormwater management. Facility operation will begin in the near
future. As we develop a stable and consistent operational cycle, we will be able to more
accurately determine the full potential for water management and conservation on site,
which would include periods with less storm water availability and a higher demand for
finished water supply, resulting in tighter management to reduce consumption and lower
discharge flows. Under these conditions, mass based limits provide incentive for reduced
water usage, as opposed to concentration based limits.
2) Horsehead requests reconsideration of the approach to Chronic Toxicity limits described
in the Draft. We realize that the increase in effluent flow raises the instream wastewater
concentration (IWC) from 0.57% to 0.74% at 7Q10. However, as currently written, this
static approach does not encourage Horsehead to pursue its water conservation
objectives. If we are successful in reducing our water usage and resulting effluent flow,
we are potentially penalized if we are required to generate toxicity results using our
maximum flow limit at 7Q10.
We believe there is an acceptable alternate approach to protecting the receiving waters
from potential toxicity. We have noted the variation in effluent flow from this facility
and the associated reasons for this. We also maintain that the flow requested is necessary
to accommodate the real world factors affecting water balance at our site. Nevertheless,
it is likely that for much of the year the actual monthly average effluent flows from our
process will be below the 0.8 MGD permitted level. We believe that the WET test
requirement should be tied to actual flow during the time the sample is collected. We
therefore request that the Chronic Toxicity Limit and testing requirement be modified to
use an IWC calculated using the average effluent flow from the previous 30 days prior to
date of the beginning of sample collection. This approach would effectively predict the
potential for instream toxicity based on the true flow from the facility and would promote
efforts to to conserve water usage at the plant.
As noted, we are now and will continue into the future assessing various process improvements
related to water usage that may be introduced once we have secured operational consistency for
this facility. Reducing water usage has many potential benefits. We believe that our requested
changes offered here will provide effective protection of water quality and encourage efforts to
conserve water.
Business Confidential information

HORSEHEAD METAL PRODUCTS. INC.
484 HICKS GROVE ROAD
MOORESBORO, NORTH CAROLINA 28114
METAL PRODUCTS, INC
We appreciate your consideration of this additional information and look forward to the
opportunity to discuss these requested changes prior to finalizing the revised permit. Should you
need any additional information, please contact me at 828-919-3134 or Jim Harris at 828-748-
5283.
Anthony Staley
General Manager
Business Confidential Information 2

PUBLIC NOTICE
North Carolina Environmental Management
Commission/NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Notice of Intent to Issue a NPDES Wastewater Permit
The North Carolina Environmental Management Commission
proposes to issue a NPDES wastewater discharge permit to
the person(s) listed below. Written comments regarding the
proposed permit will be accepted until 30 days after the
publish date of this notice. The Director of the NC Division of
Water Resources (DWR) may hold a public hearing should
there be a significant degree of public interest. 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 permits and
this notice may be found on our website:
http://portal.nedenr.org/web/wq/swp/ps/npdes/calendar, or by
calling [phone]. The Horsehead Metal Products, Inc.
requested a major modification (expansion to 0.8 MGD) of
permit NC0089109 for Rutherford County Production Facility
in Rutherford Cni,nty: this facility discharge is treated
industrial wad
_ publisher, or other officer or employee authorized to make this
wensind /�7'Adel
AFFIDAVIT OF PUBLICATION
STATE OF NORTH CAROLINA
RUTHERFORD COUNTY
ersigned, a Notary Public of said County and State, duly
qualified, and authorized by law to administer oaths, personally
Pam Dixon
duly sworn, deposes and says: that they are
Sales Representative
a o c E DAILY COURIER, a newspaper published, issued and entered as
second class mail In the town of FOREST CITY, In said County and State; that they
are authorized to make this affidavit and sworn statement; that the notice or other
legal advertisement, a true copy of which is attached hereto, was published in THE
DAILY COURIER on the following dates:
January 17, 2013
and that said newspaper in which such notice, paper, document, or legal
advertisement was published was, at the time of each and every such publication, a
newspaper meeting all of the requirements and qualifications of Section 1-597 of the
General Statutes of North Carolina and was a qualified newspaper within the meaning
of Section 1-597 of the General Statutes of North Carolina.
's the 17th day of January, 2014.
Pam Dixon, Sales Representative
Sworn to and subscribed before me this the 17th day of January, 2014
Cindy D. Branc (Notary Public)
My commission expires: February 18, 2017.