NCS000562_Renewal application_20221101

25 October 2022
North Carolina Dept. of Energy, Mineral & Land Resources
SW Individual Permit Coverage Renewal
Stormwater Permitting Program
1612 Mall Service Center
Raleigh, North Carolina 27699-1612
Subject: NPDES Stormwater Permit Renewal Application
Befesa Zinc Metal, LLC
NPDES Individual Permit No. NCS000562
Rutherford County
Dear Sir/Madam:
RECEIVED
110V 012022
DENR-LAND QUALITY
STORMWATER PERMITTING
Enclosed are two (2) copies of the NPDES Stormwater Permit Renewal Application and required supplemental
information for the Befesa Zinc Metal, LLC (Befesa) facility located in Mooresboro, Rutherford County, North
Carolina. The facility was previously known as American Zinc Products Mooresboro, NC but underwent a name
and ownership change in September and October of 2022.This timely submittal of the permit application is for
renewal of the current NPDES Individual Permit No. NCS000562, which expires on April 30, 2023.
Please contact me if you have any questions or require additional information.
Sincerely,
Befesa Zinc Metal, LLC
Kobus de Wet
General Manager
Attachments
cc: Dan Curry (TRC)
Scott Menniti (TRC)
Chris Valdez (TRC)
Joey Cashwell (Befesa)
Jan Nedbal(Befesa)

SUPPLEMENTAL INFORMATION REQUIRED FOR RENEWAL OF INDIVIDUAL
NPDES STORMWATER PERMIT
Two copies of each of the following shall accompany this submittal in order for the application
to be considered complete:
(Do not submit the site Stormwater Pollution Prevention Plan)
Initials
/ 1. A current Site Map from the Stormwater Pollution Prevention Plan. The location of
1] J� industrial activities (including storage of materials, disposal areas, process areas and
loading and unloading areas), drainage structures, drainage areas for each outfall,
building locations and impervious surfaces should be clearly noted.
2. A summary of Analytical Monitoring results during the term of the existing permit
(if your permit required analytical sampling). Do not submit individual lab reports.
The summary can consist of a table including such items as outfall number,
parameters sampled, lab results, date sampled, and storm event data.
3. A summary of the Visual Monitoring results. Do not submit individual monitoring
reports. The summary can consist of a table including such items as outfall number,
parameters surveyed, observations, and date monitoring conducted.
kj` - 4. A summary of the Best Management Practices utilized at the permitted facility.
U Summary should consist of a short narrative description of each BMP's in place at
the facility. If the implementation of any BMP's is planned, please include
information on these BMP's.
5. A short narrative describing any significant changes in industrial activities at the
permitted facility. Significant changes could include the addition or deletion of
work processes, changes in material handling practices, changes in material storage
practices, and/or changes in the raw materials used by the facility.
�( 6. Certification of the development and implementation of a Stormwater Pollution
(vim Prevention Plan for the permitted facility (Sign and return attached form).
If the final year analytical monitoring of the existing permit term has not been completed
prior to filing the renewal submittal, then the last years monitoring results should be submitted
within 30 days of receipt of the laboratory reports. (i.e. do not withhold renewal submittal
waiting on lab results)

Narrative: Supplemental Information
Befesa Zinc Metal, LLC Mooresboro, NC Stormwater Permit Renewal Application
Permit NCS000562
This renewal application is submitted timely for renewal of the stormwater discharge permit (Permit
NCS000562) for the Befesa Zinc Metal, LLC Mooresboro, NC facility ("Befesa" or "the facility"). The facility was
previously known as American Zinc Products Mooresboro, NC but underwent a name and ownership change in
September and October of 2022.
Information provided in this permit renewal application includes stormwater discharge monitoring data
collected since June 2018. Monitoring was performed in accordance with permit requirements for analytical and
visual monitoring of discharged water. In addition, included is a summary of Best Management Practices utilized
at the facility, a summary of significant changes in industrial activities, a current site map depicting methods the
stormwater is managed at the facility, and a topographic map identifying the location of Outfall 001. The
Stormwater Pollution Prevention Plan Certification Form can be found in Appendix A at the end of this.
application.
Permit History
NPDES Stormwater Permit No. NCS000562 was issued to Befesa for the discharge of stormwater on May 2,
2018.
In addition to this permit the plant has two additional NPDES Permits:
■ NCG500677 issued by NC DEQ on January 6, 2021- Certificate of coverage for discharge of non -contact
cooling water, cooling tower and boiler blowdown, condensate, exempt stormwater, cooling water
associated with hydroelectric operations, and similar wastewaters under the DEQ's General Permit
NCG50000.
■ NCO089109 Issued by NC DEQ April 19, 2019, for the discharge of process wastewater
On two separate occasions in the life of the stormwater permit Befesa requested and obtained e-mail approval
to reroute discharge associated with the NCG500677 through the stormwater discharge point.
■ On November 20, 2018, Befesa requested discharge from 5 new air compressor units to the stormwater
system. An e-mail approval was received from DEQ on December 13, 2018
■ On March 22, 2019, Befesa requested rerouting of non -contact cooling water be rerouted to the
stormwater system. An e-mail approval was received from DEQ on March 25, 2019
On both occasions internal monitoring points were established to monitor discharge from the NCG500000 units.

Currently this plant continues to route these discharges through the stormwater outlet. Befesa has plans to
reroute this water back into the process where it can be reused. This modification is planned for calendar year
2023.
Stormwater Management Approach
Stormwater at the facility is managed at the facility in several ways, including:
■ Discharge directly to the stormwater sedimentation basin (Basin 1) equipped with an energy dissipator
forebay, which promotes sediment settling, before discharging at Outfall 001 to the Broad River;
■ Use for process operations; a nd
■ Management in a pond ortank for analysis and then discharge or use for process operations.
The figure attached to Form 2F identifies how stormwater from various areas on the operating area of the
property is managed. The location of the discharge outfall is provided on the attached topographic map also
included in Form 2F.
Monitoring Results
Form 2F (with attachments summarizes) analytical and visual monitoring results for storm water discharged to
the Broad River. The range and average values of sample analytical results are provided In Tables A, B, and C of
the form.
Onaoin4 and Planned Improvements
■ Befesa has installed approximately forty-six (46) Safe Drain Inlets, a proprietary device that is installed at
catch basins and/or inlet to allow valved control of discharge through the inlet instead of typical free flow.
These have improved stormwater discharge control at the Energy Dissipator Area as well as at the
stormwater discharge outfall. Befesa is developing plans to install additional Safe Drain Inlets at inlets
throughout the plant.
■ Non-stormwater discharge waters currently permitted under the NCG500677 permit are proposed to be
routed back in the plant process.

NPDES Form
General Information
NPDES FORM 1: GENERAL INFORMATION
DISCHARGE LOCATION MAP

EPA Identification Number
NPDES Permit Number
Facility Name
Form Approved 03/05/19
NCR000159038
NCS000562
Befesa Zinc Metal, LLC
OMB No. 2040-0004
Form
U.S. Environmental Protection Agency
1
ZVEPA
Application for NPDES Permit to Discharge Wastewater
NPDES
GENERAL INFORMATION
SECTION•
• r
1.1
Applicants Not Required to Submit Form 1
1.1.1
Is the facility a new or existing publicly owned
1.1.2
Is the facility a new or existing treatment works
treatmentworks?
treating domestic sewage?
If yes, STOP. Do NOT complete ❑✓ No
If yes, STOP. Do NOT 0✓ No
Form 1. Complete Form 2A.
complete Form 1. Complete
Form 2S.
1.2
Applicants Required to Submit Form 1
1.2.1
Is the facility a concentrated animal feeding
1.2.2
Is the facility an existing manufacturing,
operation or a concentrated aquatic animal
commercial, mining, or silvicultural facility that is
n
production facility?
currently discharging process wastewater?
oYes
4 Complete Form 1 No
0✓ Yes 4 Complete Form E] No
z
and Form 2B.
1 and Form 2C.
1.2.3
Is the facility a new manufacturing, commercial,
1.2.4
Is the facility a new or existing manufacturing,
mining, or silvicultural facility that has not yet
commercial, mining, or silvicultural facility that
—
commenced to discharge?
discharges only nonprocess wastewater?
❑ Yes 4 Complete Form 1 2 No
Ej Yes 4 Complete Form �✓ No
N
and Form 2D.
1 and Form 2E,
°—
1.2.5
Is the facility a new or existing facility whose
'—
discharge is composed entirely of stormwater
a
associated with industrial activity or whose
discharge is composed of both stormwater and
non-stormwater?
Yes 4 Complete Form 1 F(I No
and Form 2F
unless exempted by
40 CFR
122.26(b)(14)(x) or
b 15.
SECTIOND•
2.1
• • r
Facili Name
Befesa Zinc Metal, LLC
0
2.2
EPA Identification Number
U
0
NCR000159038
9
m
2.3
Facility Contact
N'
Name (first and last)
Title
Phone number
Jan Nedbal
Environmental Manager
[phone]
Email address
[e-mail]
2.4
Facility Mailing Address
E
Street or P.O. box
z
484 Hicks Grove Road
City or town
State
ZIP code
Mooresboro
North Carolina
28114
EPA Form 3510-1 (revised 3-19) Page 1

EPA Identification Number
NPDES Permit Number
Facility Name
Form Approved 03/05119
NCR000159038
NC5000562
Befesa Zinc Metal, LLC
OMB No. 2040-0004
y
2.5
Facility Location
4 `
Street, route number, or other specific identifier
a
484 Hicks Grove Road
rn
c
County name
County code (if known)
Rutherford County
161
E
City or town
State ZIP code
z ,tee
Mooresboro
North Carolina 28114
SECTION•
NAICS CODES1
3.1
SIC Code(s)
Description (optional)
3341
Secondary Nonferrous Metals
N
N
B
O
U
ft)
U
z
3.2
NAICS Code(s)
Description (optional)
v
U
to
SECTIONOPERATOR
INFORMATION (40
4A
Name of 0 erator
Befesa Zinc Metal, LLC
0
4.2
Is the name you listed in Item 4.1 also the owner?
E
`o
❑✓ Yes ❑ No
=
`o
4.3
0 eratorStatus
❑ Public —federal ❑ Public —state ❑ Other public (specify)
o
❑✓ Private ElOther
(specify)
4.4
Phone Number of Operator
[phone]
4.5
0 eratorAddress
Street or P.O. Box
E w
484 Hicks Grove Road
5
City or town
State
ZIP code
o 0
Mooresboro
North Carolina
28114
m
o
Email address of operator
O
[phone]
SECTION•
• •1
5.1
Is the facility located on Indian Land?
JR
5❑Yess
❑✓ No
EPA Form 3510.1 (revised 3-19) - Page 2

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NCR000159038 NCS000562 Befesa Zinc Metal, LLC OMB No. 2040-0004
SECTION• 1
—m 6.1 Existing Environmental Permits (check all that apply and print or type the corresponding permit number for each)
B❑
NPDES (discharges to surface
❑ RCRA (hazardous wastes)
❑ UIC (underground injection of
o
water)
fluids)
«
•—
E
NC5000562
w E
❑✓ PSD (air emissions)
❑ Nonattainment program (CAA)
❑ NESHAPs (CAA)
C
10MR09
Ul
❑ Ocean dumping (MPRSA) ❑ Dredge or fill (CWA Section 404) ❑✓ Other (specify)
NCG500000 (NC Cooling)
SECTION7.MAP(40
Have you attached a topographic map containing all required information to this application? (See instructions for
7.1
specific requirements.)
❑✓ Yes ❑ No ❑ CAFO—Not Applicable (See requirements in Form 2B.)
SECTIONOF
t
8.1
Describe the nature of your business.
This facility processes Waelz Oxide (a.k.a. Crude Zinc Oxide) as its principal raw material to produce Special
High -Grade (SHG) zinc metal and other metals as it's principal product. The manufacturing process consists of an
integrated system of leaching, extraction, stripping, and electrowinning processes. Feed, including metal bearing
c
oxides (e.g. Walez Oxide) and other raw materials, are managed in solution throughout the process. Metal products
are removed as precipitates, concentrates, SHG zinc metal and CGG alloy. Metal -bearing Waelz Oxide feed is
m
delivered to the subject facility from local and international sources. The specific technologies and configuration of
a
the operation are confidential business information.
io
z
SECTION••
I
Does your facility use cooling water?
9.1
❑✓ Yes ❑ No 4 SKIP to Item 10.1.
w
9.2
Identify the source of cooling water. (Note that facilities that use a cooling water intake structure as described at
o -
40 CFR 125, Subparts I and J may have additional application requirements at 40 CFR 122.21(r). Consult with your
o v
NPDES permitting authority to determine what specific information needs to be submitted and when.)
0
c
Forest City, NC Water Supply
SECTION
1
! I 1
10.1
Do you intend to request or renew one or more of the variances authorized at 40 CFR 122.21(m)? (Check all that
y
apply. Consult with your NPDES permitting authority to determine what information needs to be submitted and
m
when.)
❑ Fundamentally different factors (CWA ❑ Water quality related effluent limitations (CWA Section
z
Section301(n)) 302(b)(2))
❑ Non -conventional pollutants (CWA ❑ Thermal discharges (CWA Section 316(a))
Section 301(c) and (g))
❑✓ Not applicable
EPA Form 3510-1 (revised 3-19) Page 3

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03l05119
NCR000159038 NCS000562 Befesa Zinc Metal, LLC OMB No. 2040-0004
SECTION•
I
In Column 1 below, mark the sections of Form 1 that you have completed and are submitting with your application.
For each section, specify in Column 2 any attachments that you are enclosing to alert the permitting authority. Note
that not all applicants are required to provide attachments.
711.1
Column 1
Column 2
❑� Section 1: Activities Requiring an NPDES Permit
s
❑ wl attachments
❑✓ Section 2: Name, Mailing Address, and Location
❑ w/ attachments
❑✓ Section 3: SIC Codes
❑ w/ attachments
❑✓ Section 4: Operator Information
❑ w/ attachments
❑✓ Section 5: Indian Land
❑ w/ attachments
❑✓ Section 6: Existing Environmental Permits
❑ wl attachments
m
v
❑✓ Section 7: Map
wltopographic
❑� ❑ wl additional attachments
ma
in
c
❑✓ Section 8: Nature of Business
❑ wl attachments
R
❑✓ Section 9: Cooling Water Intake Structures
❑ w/ attachments
e
d
�'
❑� Section 10: Variance Requests
❑ w( attachments
a
c
Section 11: Checklist and Certification Statement
❑ w/ attachments
Y
d
11.2
Certification Statement
1 certify under penaltyof 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. I am aware that there are significant penalties for submitting false information,
including the possibility of fine and imprisonment for knowing violations.
Name (print or type first and last name)
Official title
Jan Nedbal
Environmental Manager
Signature
Date signed
b .2,z
EPA Form 3510-1 (revised 3-19) Page 4

On
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DISCHARGE LOCATION MAP
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M11111111-9-o-'aN 4% BEFESA ZINC METAL LLC
RUTHERFORD COUNTY, NORTH CAROLINA

NPDES Form 2F
Stormwater Discharges
Associated with Industrial Activity

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NCR000159038 NC5000562 Befesa Zinc Metal, LLC OMB No. 2040-0004
Form U.S Environmental Protection Agency
2F \�/EPA Application for NPDES Permit to Discharge Wastewater
NPDES STORMWATER DISCHARGES ASSOCIATED WITH INDUSTRIAL ACTIVITY
SECTIONOUTFALL LOCATION••
1.1 Provide information on each of the facifit Is outfalls in the table below
Outfall Receiving Water Name Latitude Longitude
Number
001 Broad River 35° 12 2.6" N 81° 51' 3.2" W
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0
ea
0
SECTION" • 1
2.1 Are you presently required by any federal, state, or local authority to meet an implementation schedule for constructing,
upgrading, or operating wastewater treatment equipment or practices or any other environmental programs that could
affect the discharges described in this application?
❑ Yes ❑✓ No 4 SKIP to Section 3.
2.2 Briefly identify each applicable project in the table below.
Brief Identification and Affected Outfalls Source(s) of Discharge Final Compliance Dates
Description of Project (list outfall numbers)
Required Projected
N
C
E
m
0
E
E
2.3 Have you attached sheets describing any additional water pollution control programs (or other environmental projects
that may affect your discharges) that you now have underway or planned? (Optional Item)
❑ Yes ❑ No
EPA Form 3510.2F (Revised 3-19) Page 1

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NCR000159038 NCS000562 Befesa Zinc Metal, U-C OMB No. 2040-0004
SECTIOND•, r
o� 3.1 Have you attached a site drainage map containing all required information to this application? (See instructions for
specific guidance.)
N m �
o ® Yes ❑ No
SECTION• • t
4.1 Provide information on the facility's pollutant sources in the table below.
Outfall
Impervious Surface Area
Total Surface Area Drained
Number
(within a mile radius of the facility)
(within a mile radius of the facility)
specify units
specify units
001
1,611,789
SF
2,231,711
SF
specify units
specify units
specifyunits
spedy units
specify units
speciy units
specify units
specify units
spacify units
specify units
4.2
Provide a narrative description of the facility's significant material in the space below. (See instructions for content
requirements.)
Waelz Oxide (a.k.a. Crude Zinc Oxide), a powder, is the main feedstock material for the plant. Unloading of this
material as it arrives at the facility is performed in a manner which prevent contact of stormwater with the material.
Waelz Oxide, as well as Gypsum, a powder, are handled elsewhere in plant under roof and within structures. However,
'o
there are potential pathways that the materials can migrate out of buildings. Please see the attached BMP summary
table referred to in Section 4.3 for descriptions and locations of the BMP's utilized to prevent and address the
m
exposure of Waelz Oxide and Gypsum to stormwater at the facility, including but not limited to street sweeping,
containments, and Safe Drain proprietary storm drain inlet valves.
0
a
4.3
Provide the location and a description of existing structural and non-structural control measures to reduce pollutants in
stormwater runoff. See instructions forspecificguidance.)
Stormwater Treatment
Codes
Outfall
from
Number
Control Measures and Treatment
Exhibit
2F-1
(list)
001
See attached for Stormwater Management BMP's employed at facility
N/A
EPA Form 3510-2F (Revised 3-19) Page 2

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03105li9
NCR000159038 NCS000562 Befesa Zinc Metal, LLC OMB No. 2040-0004
SECTION• • r
5.1 1 certify under penalty of law that the outfall(s) covered by this application have been tested or evaluated for the
presence of non-stormwater discharges. Moreover, I certify that the outfalls identified as having non-stormwater
discharges are described in either an accompanying NPDES Form 2C, 2D, or 2E application.
Name (print or type first and last name)
Official title
Signature
Date signed i
2
N
.2Z
rn
5.2
Provi e t e testing Informationqm,,;tdin the table below.
Outfall
Onsite Drainage Points
o
Number
Description of T Method Used
Date(s) of Testing
Directly Observed
`m
During Test
m
3
0
N
C
0
2
SECTIONOR
1
6.1
Describe any significant leaks or spills of toxic or hazardous pollutants in the last three years.
See attached Significant Spill Record
rn
`o
Y
N
J
C
U
C
D_1
SECTION•
• .r
See the
instructions to determine the pollutants and parameters you are required to monitor and, in turn, the tables you must
`o
complete.
Not all applicants need to complete each table.
E7.1
Is this a new source or new discharge?
0
❑ Yes 4 See instructions regarding submission of ❑ No 4 See instructions regarding submission of
d
estimated data. actual data.
Tables A, B, C, and D
y
7.2
Have you completed Table A for each outfall?
❑✓ Yes ❑ No
EPA Form 3510-21' (Revised 3-19) Page 3

EPA Identification Number
NPDES Permit Number
Facility Name
Form Approved 03/05/19
NCR000159038
NCS000562
Befesa Zinc Metal, LLC
OMB No. 2040-0004
7.3
Is the facility subject to an effluent limitation guideline (ELG) or effluent limitations in an NPDES permit for its process
wastewater?
❑ Yes ❑✓ No 4 SKIP to Item 7.5.
7.4
Have you completed Table B by providing quantitative data for those pollutants that are (1) limited either directly or
indirectly in an ELG and/or (2) subject to effluent limitations in an NPDES permit for the facility's process wastewater?
❑ Yes ❑ No
7.5
Do you know or have reason to believe any pollutants in Exhibit 2F-2 are present in the discharge?
❑✓ Yes ❑ No 4 SKIP to Item 7.7.
7.6
Have you listed all pollutants in Exhibit 217-2 that you know or have reason to believe are present in the discharge and
provided quantitative data or an explanation for those pollutants in Table C?
❑✓ Yes ❑ No
7.7
Do you qualify for a small business exemption under the criteria specified in the Instructions?
❑ Yes 4SKIP to Item 7.18. ❑✓ No
7.8
Do you know or have reason to believe any pollutants in Exhibit 2F-3 are present in the discharge?
❑✓ Yes ❑ No 4 SKIP to Item 7.10.
7.9
Have you listed all pollutants in Exhibit 2F-3 that you know or have reason to believe are present in the discharge in
Table C?
:r
0
❑✓ Yes ❑ No
0
7.10
Do you expect any of the pollutants in Exhibit 2F-3 to be discharged in concentrations of 10 ppb or greater?
E
❑ Yes ElNo 4 SKIP to Item 7.12.
0
C
7.11
Have you provided quantitative data in Table C for those pollutants in Exhibit 2F-3 that you expect to be discharged in
concentrations of 10 ppb or greater?
❑✓ Yes ❑ No
7.12
Do you expect acrolein, acrylonitrile, 2,4-dinitrophenol, or 2-methyl-4,6-dinitrophenol to be discharged in concentrations
of 100 ppb or greater?
❑ Yes ❑✓ No 4 SKIP to Item 7.14.
7.13
Have you provided quantitative data in Table C for the pollutants identified in Item 7.12 that you expect to be
discharged in concentrations of 100 ppb or greater?
❑ Yes ❑ No
7.14
Have you provided quantitative data or an explanation in Table C for pollutants you expect to be present in the
discharge at concentrations less than 10 ppb (or less than 100 ppb for the pollutants identified in Item 7.12)?
❑ Yes ❑ No
7.15
Do you know or have reason to believe any pollutants in Exhibit 2F-4 are present in the discharge?
❑ Yes ❑✓ No 4 SKIP to Item 7.17.
7.16
Have you listed pollutants in Exhibit 2F-4 that you know or believe to be present in the discharge and provided an
explanation in Table C?
❑ Yes ❑ No
7.17
Have you provided information for the storm event(s) sampled in Table D?
❑ Yes ❑✓ No
EPA Form 3510-2F (Revised 3-19) Page 4

EPA Identification Number
NPDES Permit Number
Facility Name
Form Approved 03/05/19
NCR000159038 INCS000562
Befesa Zinc Metal, LLC
OMB No. 2040-0004
o
Used or Manufactured Toxics
7.18
Is any pollutant listed on Exhibits 2F-2 through 2F-4 a substance or a component of a substance used or
omanufactured
as an intermediate or final product or byproduct?
0 Yes ❑ No 4 SKIP to Section 8.
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0
'M
7.19
List the pollutants below, including TCDD if applicable.
c
1. Cadmium 4. 7.
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r
2. Lead 5. 8.
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N
'0
3• Zinc 6. 9,
SECTIONBIOLOGICAL
T• DATA r
Do you have any knowledge or reason to believe that any biological test for acute or chronic toxicity has been made on
8.1
any of your discharges or on a receiving water in relation to your discharge within the last three years?
0
❑✓ Yes ❑ No 4 SKIP to Section 9.
8.2
Identify the tests and their purposes below.
'
•x
Testis)
Purpose of Test(s)
Submitted to NPDES
Permitting Authority?
Date Submitted
Fish Tissue Sampling
Biological, Under NPDES Perm
❑✓ Yes ❑ No
�
to
o
❑ Yes ❑ No
0
m
❑ Yes ❑ No
SECTION•
• • ••
Were any of the analyses reported in Section 7 (on Tables A through C) performed by a contract laboratory or
9.1
consulting firm?
❑✓ Yes ❑ No 4 SKIP to Section 10.
9.2
Provide information for each contract laboratory or consulting firm below.
Laboratory Number 1
Laboratory Number 2
Laboratory Number 3
Name of laboratory/firm
Pace Analytical Services, LLC
c
0
.q
0
N
•�
Laboratory address
98001(incey Ave. suite 100
T
Huntersville, NC 28078
A
C
Q
U
N
oPhone
number
1704) 875-9092
Pollutant(s) analyzed
All pollutants lists in Tables A,
B, and C.
EPA Form 3510-2F (Revised 3-19) Page 5

EPA Idenfificafion Number NPDES Permit Number Facility Name Form Approved 03105119
NCR000159038 NCS000562 Befesa Zinc Metal, LLC OMB No. 2040-0004
SECTION•
CERTIFICATION
10.1
In Column 1 below, mark the sections of Form 2F that you have completed and are submitting with your application. For
each section, specify in Column 2 any attachments that you are enclosing to alert the permitting authority. Note that not
all applicants are required to complete all sections or provide attachments.
Column 1
Column 2
❑✓ Section 1
❑ w/ attachments (e.g., responses for additional outfalls)
❑✓ Section 2
❑ w/ attachments
El Section 3
❑✓ w/ site drainage map
✓❑ Section 4
❑✓ w/ attachments
0 Section 5
❑ w/ attachments
Section 6
❑✓ w/ attachments
�❑
IE
❑✓ Section 7
❑✓ Table A ❑ w/ small business exemption request
J9
0
❑✓ Table B ✓❑ w/ analytical results as an attachment
19
❑✓ Table C ❑ Table D
r
❑✓ Section 8
❑ w/attachments
c
❑✓ Section 9
❑ w/attachments (e.g., responses for additional contact laboratories or firms)
x
t
❑ Section 10
❑
10.2
Certification Statement
1 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 qualffied personnel properly gather and evaluate the information
submitted. Based on my inquiryof the person orpersons 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. I am aware that there are significant penalties for submitting false information, including the possibility of fine
and imprisonment for knowing violations.
Name (print or type first and last name)
Official title
Jan Nedbal
Environmental Manager
Signature
Date signed
Ib 1�L1o, 2Z
�r
EPA Form 3510-21F (Revised 3-19) Page 6

Identification Number NPDES Permit Number Facility Name Outlet Number Form Approved 03N5/f 9
NCR000159038 NCS000562 Befesa Zinc Metal, LLC 001 (SDO) OMB No. 2040-0004
TABLE A. • • AND NON CONVENTIONAL1
You must provide the results of at least one anal sis for every pollutant in this table. Complete one table for each outfall. See instructions for additional details and re uirements.
Pollutant or Parameter
Maximum Daily Discharge
(specify units)
Average Daily Discharge
(specify units)
Number of Storm
Events Sampled
Source of
Information
(new souroalnew
dischargers only; use
codes in instructions)
Grab Sample Taken
During First
30 Minutes
Flow -Weighted
Composite
Grab Sample Taken
During First
30 Minutes
Flow•Weighted
Composite
1.
Oil and grease
5.1 mg/L
<5.0 rn
44
2.
Biochemical oxygen demand (BOD5)
N/A
N/A
N/A
N/A
N/A
3.
Chemical oxygen demand (COD)
N/A
N/A
N/A
N/A
N/A
4.
Total suspended solids (TSS)
237 mg/L
N/A
17.83 mg/L ©
N/A
46
5.
Total phosphorus
0.57 mg/L ©
N/A
0.13 mg/L ©
N/A
44
6.
Total Kjeldahl nitrogen (TKN)
N/A
N/A
N/A
N/A
N/A
7.
Total nitrogen (as N)
3.0 mg/L
N/A
0.5 mg/L
N/A
44
8.
pH (minimum)
5.7 sU
8.2 SU
46
pH (maximum)
9.6 SU
S.z SU
46
r Sampling shall be conducted according to sufficiently sensitive test procedures (i.e., methods) approved under 4u u-K in for the anaiysls or ponutanfs or poimranr parameters or
required under 40 CFR chapter I, subchapter N or 0. See instructions and 40 CFR 122.21(e)(3).
EPA Form 3570-21' (Revised 3-19)
Page 7

4 Identificafion Number NPDES Permit Number Facility Name Outfall Number
NCR000159038 NCS000562 Befesa Zinc Metal, LLC 001 (5DO)
Form Approved 03rD5119
OMB No. 2040-0004
List each pollutant that is limited in an effluent limitation guideline (ELG) that the facility is subject to or any pollutant listed in the facility's NPDES permit for its process wastewater (if the
facility is operating under an existing NPDES permit). Complete one table for each cutfall. See the instructions for additional details and requirements.
Pollutant and CAS Number (if available)
Maximum Daily Discharge
(sped units)
Average Daily Discharge
(spedly (spedunits
Number of Storm
Events Sampled
Source of
Information
(new source/new
dischargers only; use
mdesininstructions)
Grab Sample Taken
During First
30Minutes
Flow -Weighted
composite
Grab Sample Taken
During First
30Minutes
Flow -Weighted
Composite
Chlorides
1080 mg/L
N/A
40.0 mg/L
N/A
46
r Sampling shall be conducted according to sufficiently sensitive test procedures (i.e., methods) approved under 40 Ut-K 136 for the analysis of pollutants or pollutant parameters of
required under 40 CFR chapter I, subchapter N or 0. See instructions and 40 CFR 122.21(e)(3).
EPA Form 3510-2F (Revised 3-19)
Page 9

4ldentification Number NNutti F8=1 Number raun y naina waan nu„.
NCR000159038 I NCS000562 Befesa Zinc Metal, LLC 001(SDO)
Form Approved 03105/19
OMB No. 2040-0004
TABLE C. TOXIC POLLUTANTS, CERTAIN HAZARDOUS SUBSTANCES, AND ASBESTOS (40 CFR 122.26(c)(1)(i)(E)(4) and 40 CFR 122.21(g)(7)(vi)(B) and (vii))'
List each pollutant shown in Exhibits 2F-2, 2F-3, and 2F-4 that you know or have reason to believe is present. Complete one table for each oulfall. See the instructions for additional
details and requirements.
Pollutant and CAS Number (if available)
Maximum Daily Discharge
s eci units
Average Daily Discharge
(specify units
Number of Storm
Events Sampled
Source of
Information
(new sourcelnew
dischargers only; use
codes in instructions)
Grab Sample Taken
During First
30 Minutes
Flow -Weighted
Composite
Grab Sample Taken
During First
30 Minutes
Flow -Weighted
Composite
Cadmium (7440-43-9)
0.86 mg/L
N/A
0.15 mg/L
N/A
45
Lead (7439-92-1)
0.79 mg/L
N/A
0.09 mg/L
N/A
46
Zinc (7440-66-6)
96.9 mg/L
N/A
9.2 mg/L
N/A
46
Oil and Grease
5.1 mg/L
N/A
<5.0 mg/L
N/A
44
Total Nitrogen (as N)
3.0 mg/L
N/A
0.5 mg/L
N/A
44
1 Sampling shall be conducted according to sufficiently sensitive test procedures (i.e., methods) approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or
required under 40 CFR chapter I, subchapter N or 0. See instructions and 40 CFR 122.21(e)(3).
EPA Form 3510-21' (Revised 3-19) Page 11

EPA Iden0ficali n Number NPDES Permit Number Facility name Outfall Number Form Approved 03/05/19
NCRoo0159038 NC5000562 Befesa Zinc Metal, LLC 001(SDO) 0108 No. 2040-0004
TABLE D. STORM EVENT INFORMATIONr
Provide data for the storm event(s) that resulted in the maximum daily discharges for the flow -weighted composite sample.
Number of Hours Between
Duration of Storm Event Total Rainfall During Beginning of Storm Measured and Maximum flow Rate Total Flow from Rain Event
Date of Storm Event Storm Event During Rain Event in s ec
(in hours) (in inches) End of Previous Measurable Rain (in gpm or specify units) ( gallons or p h units)
Event
N/A N/A N/A N/A N/A
Provide a description of the method of flow measurement or estimate.
N/A. Grab samples only.
EPA Form 3510-21' (Revised 3-19) Page 13

FORM 2F: SECTION 3 ATTACHMENTS
OUTFALL LOCATION MAP WITH TOPO (SEE FORM 1)
SITE DRAINAGE MAP

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_
E-0000-6-IW6 I

FORM 2F: SECTION 4 ATTACHMENTS
FACILTY BUILDING AND AREA MAP
BEST MANAGEMENT PRACTICES (BMP) SUMMARY

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BMP Assessment
BMP Summary Table
Area
A
`o
`o
V p
6
o
V w
c
m
c a
c
c
Best Management Practice (BMP)
BMP Description
0 o 'o
o 'o o 'o o a s
Oa°
'o
Compliance obligations are met and items are reviewed for improvement.
Compliance Obligations
Improvement plans are developed.
SWPPP Requirements
SWPPP Requirements are met and improvement plans are developed.
Permit Limits
Permit Limits are met and Imrovement plans are developed, as needed.
Benchmark Assessments are completed and Tiered responses have an
Benchmark Assessment
improvement plans developed.
Trenches are maintained free of debris and cracks. If issues are found upon
Containment -Trenches
visual inspection, a repair plan is developed to remedy the issue. These are
monitored under a regular inspection program.
Pumps/Sumps/Hoses are maintained are monitored under a regular
inspection program. In case of a leak from a pipe or vessel in the process
Containment - Pumps/Sumps/Hoses
area, the secondary containments will hold the materila until site personnel
can take the necessary action to remove the material.
Floors/Liners are maintained, free of debris and cracks. If issues are found
4
Containment- Floors/Liners
upon visual inspection, a repair plan is developed to remedy the issue.
These are monitored under a regular inspection program.
-
Walls are kept free of debris on outside. These are monitored under
Containment - Walls
regular inspection program.
_
Roofs are maintained to prevent leaking. The roof is monitored under a
Containment - Roofs
regular inspection program.
Containment Reviews
Regular reviews are completed by area under an inppection program
High Level Alarm on Tanks High level alarms on tanks are in place and tested periodically.
Roadways are kept free of debris accumulations, issues are found through
Roadways
inspections and corrective actions are tracked through Velocity. Good
housekeeping and proper material storage/handling practices are in place.
Sweeper vacuum Truck for roadways
Vacuum truck is used on routine schedule to maintain roadways.
BMPAssessment

BMP A,se...M
Area
C °
«
N
a
v p
6
a
C°
o
y m
W
Best Management Practice (BMP) BMP Description
o
0
0
0 0
0
0 0
E
¢ '-
^'
m
x
a
p
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a a
a
+%
'^
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w
When vehicles need to enter the process containment, the tires are cleaned
Truck Wash Stations to prevent tracking of materials on the roadways This is monitored under a
regular inspection program.
Pond is operational and appropriate. Liner is inspected per PM schedule
Storm pond - East
and is maintained
Pond is operational and appropriate. Liner is inspected per PM schedule
Storm pond- West
and is maintained
Pond is no longer operational and now serves as a secondary containment.
Maintenance Pond -West
Liner is inspected per PM schedule and is maintained
Pond is operational and appropriate. Liner is inspected per PM schedule
Effluent Pond
and is maintained
Pond is no longer operational and now serves as a secondary containment.
Depleted Solutions Pond
Liner is inspected per PM schedule and is maintained
Pond is no longer operational and now serves as a secondary containment.
Rafffnate Pond
Liner is inspected per PM schedule and is maintained
Water from west storm pond is no longer released to Basin 1. This would
j
Operator Inspection before Discharge
only be implemented in the event of an emergency.
-% _ x
x
Inlet inspections Regular inspections are completed, issues have a repair plan
_,X,<I-<
'
Safe Drain Inlets are a proprietary device that is installed at catch basins
Safe Drain Inlet protection devices and/or inlet to allow valved control of discharge through the inlet instead of
typical free flow.
Waste storage areas are inspected and documentation maintained per
Waste storage areas requirements, issues have a plan and are corrected.
Boot washes areto precent tracking of debris in buildings or site caused by
Boot wash stations
footwear. The wash water from the boot wash is returned to the process.
Chemical Storage Practices Chemicals are stored per regulatory requirements
Emergency Plan is kept up-to-date and is tested. Drills are performed.
-
Emergency Response Plan
Further training is in process of implementation
Bmpms ume@

smpA ssMent
Area
c
m
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Best Management Practice (BMP)
BMP Description
o 0 0 0 0 0 0 0
o 0 0 0 0 0 0 0
3
c
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3
ao
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Regular audits are completed for housekeeping under an in-house
EHS Audits for Housekeeping
documentation program.
Regular inspections are completed and documented under an in-house
Environmental Inspection
documentation program. Action plans for issues are developed based on
inspection findings.
_
PM Program PM Program is effective and appropriate
24/7 Monitoring of Process
Operation and Security personnel monito.r the areas within the facility to
ensure that conditions remain safe for personnel and the environment. _
Spills kits containing materials to respond to minor material spills are
Spill Response kits
located near potential spill areas. Third party vendor inspects and stocks
weekly.
Training Regulatory training of facility personell is completed initially and annually.
aMPA nment

FORM 2F: SECTION 6 ATTACHMENTS
SIGNIFICANT SPILL RECORD

AZP Significant Spill Record
Date
incident
Actions
1/3/2019
Gypsum Pad -Truck Wash leak to
stormwater drain
Documentation on file. Material did not reach Broad River. NRC and DEQ notified. No RQ released. Velocity
Report IN-20190104-001, NRC Report# 1234535
4/28/2019
Fire at Electrowinning
Documentation on file. Fire caused low pH/High metals electrolyte to be collected in Basin 1. Due to significant
rainfall in the following weeks, a voluntary release of water was discharged to protect integrity of dam (-20K
Documentation on file. Spill resulted in low pH liquid to enter storm drains and collected in Basin 1. This
6/3/2020
Spent Electrolyte Spill
material did not contact any air, water, or soil, but was reported due to the fact that it entered our storm water
system.
Documentation on file. Spill resulted in low pH liquid to enter storm drains and collected in Basin 1. This
1/1/2021
Electrolyte Spill
material did not contact any air, water, or soil, but was reported due to the fact that it entered our storm water
system.
7/28/2021
Raffinate pond release.
Documentation on file. This incident was reported to the NRC out of caution. NRC Report # 1312115. Tank list
was updated after ponds were removed from service.
Documentation on file. This incident was reported to the NRC and NC DEQ due to oil sheen on surface waters of
1/20/2022
Oil Sheen on Basin 1 / AZP SDO / Broad River
the State. NRC Report # 1326980. Discharge to Broad River was stopped immediately. AZP crews boomed and
skimmed surface of Basin 1 to clean sheen from retention basin.
Documentation on file. This incident was reported to the NRC, EPA OSC (Ken Rhame), and NC DEQ due to a
release of WOX and a calculated RQ of zinc, lead, and cadmium. NRC Report # 1337300VARRATI. Release
5/29/2022
WOX release from pneumatic offloading
piping system.
occurred when a pipe failed during a pneumatic offloading operation. The release was reported out of an
abundance of caution with the knowledge available during the time limit of reporting requirments. Upon further
investigation, very little of this material, likely in the form of unseen transient emissions, actually hit bare soil.
Most of this material landed on impervious surfaces and was recovered and placed back into process.

FORM 2F: SECTION 7 ATTACHMENTS
ANALYTICAL MONITORING DATA SUMMARY
(MAXIMUM DISCHARGE VALUE HIGHLIGHTED)
VISUAL MONITORING DATA SUMMARY

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Visual Monintoring Data Summary
Sample date
7/19/2018
Color
Clear
Odor
None
Clarity
(1-5)
2
Floating
Solids
1
Suspended
Solids
2
Any Foam?
No
Oil Sheen?
No
Erosion?
No
Obvious indicators?
9/28/2018
Reddish Brown,
Medium
none
2
1
2
No
No
No
12/1/2018
Red/Brown, Light
None
2
2
2
No
No
No
2/12/2019
Red/Brown, Light
None
2
2
2
No
No
No
8/20/2019
Red/Brown, Light
None
3
1
3
No
No
Yes
10/8/2019
Red/Brown, Light
None
1
1
1
No
No
No
2/5/2020
Red/Brown, Light
None
1
1
3
No
No
No
6/29/2020
Clear
None
1
1
1
No
No
No
9/24/2020
Clear
None
1
1
1
No
No
No
10/28/2020
Clear
None
1
1
1
No
No
No
11/2512020
NA
NA
NA
NA
NA
NA
NA
NA
Report completed 21:30
12/14/2020
Light Brown
None
3
1
2
No
No
No
1/25/2021
Clear
None
1
1
1
No
No
No
2/11/2D21
Clear
None
1
1
1
No
No
No
3/16/2021
Clear
None
1
1
1
No
No
No
4/24/2021
Clear
None
1
1
1
No
No
No
5/10/2021
Light Brown
None
2
1
2
No
No
No
6/29/2021
Light Brown
None
1
1
1
No
No
No
7/20/2021
Light Brown
None
1
1
1
No
No
No
8/16/2021
Clear
None
1
1
1
No
No
No
9/20/2021
Clear
None
1
1
1
No
No
No
10/5/2021
Clear
None
1
1
1
No
No
No
11/11/2021
Clear
None
1
1
1
No
No
No
12/29/2021
Clear
None
1
1
1
No
No
No
1/20/2022
Clear
None
1
1
1
No
Yes
No
2/23/2022
Clear
None
1
1
1
No
No
No
3/8/2022
Clear
None
1
1
1
No
No
No
4/5/2022
Clear
None
1
1
1
No
No
No
5/23/2022
Clear
None
1
1
1
No
No
No
6/16/2022
Clear
None
1
1
1
No
No
No
7/8/2022
Clear
None
1
1
1
No
No
No
8/17/2022
Clear
None
1
1
1
No
No
No

Appendix A
SPPP Certification Form

STORMWATER POLLUTION PREVENTION PLAN
DEVELOPMENT AND IMPLEMENTATION
CERTIFICATION
North Carolina Division of Energy, Mineral, and Land Resources — Stormwater Program
Facility Name:
Permit Number:
Location Address:
Balsa Vl M.K=
NCSW002
4MK�
County: ftftd c
"I certify, under penalty of law, that the Stormwater Pollution Prevention Plan (SPPP) document and all
attachments were developed and implemented under my direction or supervision in accordance with a system
designed to assure that qualified personnel properly gather and evaluate the information required by the SPPP.
Based on my inquiry of the person or persons who manage the system, or those persons directly responsible
for gathering the information, the information gathered is, to the best of my knowledge and belief, true,
accurate and complete."
And
I certify that the SPPP has been developed, signed and retained at the named facility location, and the SPPP
has been fully implemented at this facility location in accordance with the terms and conditions of the
stormwater discharge permit."
And
" I am aware that there are significant penalties for falsifying information, including the possibility of fines and
imprisonment for knowing violations."
Sign (according to permit signatory requirements) and return this Certification. DO NOT
SEND STORMWATER POLLUTION PREVENTION PLAN WITH THIS CERTIFICATION.
Signature Date ���• r `"'ll
Ib2b•zz
Print or type name of person signing above Title
SPPP Certification 10/13