NC0089109_NOV-2022-LV-0419 Response_20220712

Charles Howell
Environmental Manager
AZP
AMERICAN
ZINC PRODUCTS
July 12, 2022
484 Hicks Grove Road T 828-919-3139 www.americanzincproducts.com
Mooresboro, NC 28114 C 828-748-5636 [e-mail]
Mr. G. Landon Davidson, P.G.
Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
NCDEQ— Division of Water Resources
2090 U.S. 7 Highway
Swannanoa, NC 28778
RE: Notice of Violation & Intent to Assess Civil Penalty
NOV-2022-LV-0419
Permit No. NC0089109
American Zinc Products, LLC
Rutherford County
Dear Mr. Davidson,
American Zinc Products, LLC (AZP) appreciates the opportunity to provide additional information
regarding the Notice of Violation (NOV) dated June 23rd, 2022. The NOV was issued for a reported
exceedance of the pH discharge limit for a sample collected on April 4, 2022. This letter also provides
information to advise you of actions taken to mitigate the potential for compromised sampling results in
the future.
As previously discussed with Mr. Heim, we believe that the container used for our pH sample collection
had leftover solution in it that adversely affected the results of this pH analysis. We believe the sample
was not representative of effluent water being discharged at the time the sample was collected, as all
upstream pH probes at the time the sample was collected were within the limit range. Additionally, a
resample conducted within the hour showed a pH of 8.2 S.U.
To prevent a recurrence of sampling results which might be compromised in a similar manner, the facility
operations and laboratory departments have updated the effluent sampling SOP and the sample bottle
cleaning and storage procedures.
AZP appreciates the agency's consideration of this additional information when evaluating the April 2022
Discharge Monitoring Report, and the reported result indicated pH of 9.6 S.U. If you have questions or
require additional information, please contact me.
Respectfully,
Charles G. Howell
Environmental Manager