NCS000562_Fact sheet binder_20231214

DEQ / DEMLR
FACT SHEET FOR NPDES INDUSTRIAL INDIVIDUAL
STORMWATER PERMIT DEVELOPMENT
Basic Information for Permit Issuance and Renewals:
Permit Writer/Date Brianna Young 12/13/2023
Permit Number NCS000562
Owner/Facility Name Befesa Zinc Metal,LLC/Befesa Zinc Metal,LLC
SIC AICS Code/Category 3341 /Secondary nonferrous metals
Basin Name/Sub-basin number Broad/03-08-02
Receiving Stream/HUC Broad River/030501050503
Stream Classification/Stream Segment C/9- 36.5
Is the stream impaired on 303 d list]? No
Any TMDLs? No
Any threatened and/or endangered species? See Section 2 below
Any compliance concerns? See Section 2 below
Any perinit mods since lastpermit? No
New expiration date 12/31/2028
Comments on Draft Permit? See Section 6(below)
Section 1. Facility Activities and Process:
Befesa Zinc Metal, LLC facility processes waelz oxide (crude zinc oxide)powder to produce special
high-grade (SHG) zinc metal and other metals as its principal product. Unloading of this material as it
arrives at the facility is performed in a manner which prevents contact of stormwater with the material.
Waelz oxide, as well as gypsum powder, are handled in the plant under roof and within structures, but
there are potential pathways that the materials can migrate out of buildings. The manufacturing process
consists of an integrated system of leaching, extraction, stripping, and electrowinning processes. Feed,
including metal bearing 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 delivered to the subject facility from local and
international sources. Based on information in the permit file history, the facility first started production
in 2014, shut down between 2016 and 2018, and restarted production in 2018.
Per the permit renewal application, stormwater at the facility is managed by:
• 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; and
• Management in a pond or tank for analysis and then discharge or use for process operations.
Information in the permit file history indicates several ponds onsite. Per a DEQ email dated 2/19/2016:
• Storm Pond: Collects stormwater from the roadways on the western half of the property.
Collected stormwater can be introduced into the process as needed or if there is a surplus after a
storm event the water is routed through bleed treatment and discharged as wastewater.
o Per 2/26/2016 email, The "Storm Pond" should never discharge directly to surface waters
based on our understanding of its use and contents. Discharge of fluids in basin is not
authorized under NCS000562.
Page 1 of 10

o Per email dated 10/18/2023 from Befesa: No discharge; water is pumped back into our
process.
• West Maintenance Pond: Designed to collect stormwater and process materials within secondary
containment units on the west side of the property. This water can be introduced back into the
process to recover process materials.
o Per email dated 10/18/2023 from Befesa: No discharge; it is connected to the West
Stormwater Pond for overflow protection
• Raffinate Pond: Collects water from the 200 Area Raffinate secondary containment. Can be
introduced back into process.
o Per email dated 10/18/2023 from Befesa: No discharge; water is pumped back into our
process
• Depleted Solution Pond: Spent electrolyte solution can be introduced back into process to be
combined with organic solvent to hold the purified zinc in solution or can be routed through
bleed treatment to remove built up impurities or contaminants.
o Per email dated 10/18/2023 from Befesa: No discharge; water is pumped back into our
process
• Per an email dated 10/18/2023 from Befesa, additional ponds include:
o East Effluent Pond: Discharged under wastewater permit.
o East Stormwater Pond: No discharge; water is pumped back into the process.
o Basin 1: Stormwater Sedimentation Pond, discharges to the Broad River(SDO #1).
Area 100—Leaching/Neutralization
WOX undergoes a washing process before being introduced into the leaching unit with zinc skimmings.
This results in the dissolution of zinc and other metals in a solution containing sulfuric acid, recycled
hydrochloric acid, and zinc raffinate. The following activities occur in this area: loading and unloading,
outdoor storage, outdoor processing, dust or particulate generating processes and waste generation.
Area 200—Solvent Extraction
The Solvent Extraction(SX)process is utilized to create an ultra-pure zinc sulfate electrolyte. The
following activities occur in this area: outdoor storage, waste generation.
Area 300—Bleed Treatment
Treatment of aqueous raffinate to impede the accumulation of soluble impurities in the leaching circuit
while also retrieving valuable metals and residues from effluent solutions. The following activities occur
in this area: loading and unloading, outdoor storage, outdoor processing, dust or particulate generating
processes and waste generation.
Area 400—Electrowinning(Cell House)
Produce zinc metal by electrochemical plating of the zinc from the electrolyte solution onto aluminum
cathode sheets. Once the plating process is complete, each cathode is removed and washed, after which
the zinc is mechanically stripped from the surfaces. The following activities occur in this area: waste
generation.
Area 500— Casting
Stripped zinc is melted and cast into ingots of various sizes and zinc alloys are manufactured. The
following activities occur in this area: loading and unloading, outdoor storage, outdoor processing, dust
or particulate generating processes and waste generation.
Page 2 of 10

Area 600—PLINT
Recover lead and silver from residues produced during the leaching process, resulting in the production
of a lead concentrate. The following activities occur in this area: loading and unloading, outdoor storage,
outdoor processing, and waste generation.
Area 700—Reagents Preparation and Distribution
Preparation and distribution of reagents throughout the facility and storage of oils, solvents,paints,
chemical reagents, cleaning agents, antifreeze, and other materials. The following activities occur in this
area: waste generation.
Outfall SW001:
Drainage area consists of loading and unloading activities, outdoor storage, outdoor process activities,
dust/particulate generating processes, illicit connections and non-stormwater discharges, and waste
management.
Why Industrial Sites with Stormwater are Subject to a Permit: Federal NPDES regulations define
stormwater discharge associated with industrial activity in 40 CFR §122.26 (b)(14) as: "the discharge
from any conveyance that is used for collecting and conveying storm water and that is directly related to
manufacturing,processing or raw materials storage areas at an industrial plant. The term does not
include discharges from facilities or activities excluded from the NPDES program under this part 122.
For the categories of industries identified in this section, the term includes, but is not limited to, storm
water [sic] discharges from industrial plant yards; immediate access roads and rail lines used or traveled
by carriers of raw materials, manufactured products, waste material, or byproducts used or created by
the facility; material handling sites; refuse sites; sites used for the application or disposal of process
waste waters (as defined at part 401 of this chapter); sites used for the storage and maintenance of
material handling equipment; sites used for residual treatment, storage, or disposal; shipping and
receiving areas; manufacturing buildings; storage areas (including tank farms) for raw materials, and
intermediate and final products; and areas where industrial activity has taken place in the past and
significant materials remain and are exposed to storm water. For the purposes of this paragraph, material
handling activities include storage, loading and unloading, transportation, or conveyance of any raw
material, intermediate product, final product, byproduct or waste product. The term excludes areas
located on plant lands separate from the plant's industrial activities, such as office buildings and
accompanying parking lots as long as the drainage from the excluded areas is not mixed with storm
water [sic] drained from the above described areas."
Section 2. Monitoring Information and Compliance History:
• April 2018 to August 2023, benchmarks exceeded for:
o TSS: 2x
o pH: min not reached lx, max exceeded I
o Chlorides: Ix
o Cadmium: 55x
o Lead: 4lx
o Zinc: 56x
• Per letter dated 12/1/2020, SW001 was in Tier 3 status for cadmium, lead, and zinc
• NOV-2019-PC-0405 issued for an authorized non-stormwater discharge to the Broad River
Page 3 of 10

o The facility caught fire and had a fire and suppression water entered the stormwater
retention basin
o Monitoring was required for TSS, TN, zinc, lead, cadmium, chloride, O&G, pH, arsenic,
barium, beryllium, calcium, chromium, cobalt, copper, iron, magnesium, manganese,
nickel,potassium, selenium, silver, sodium, thallium, and vanadium (per 5/3/2019 email
in NOV doc)
• NOV-2020-PC-0369 issued for violations found during a DEMLR inspection
o Tier 2 and Tier 3 response actions not taken, secondary containment not present, and
SPPP incomplete
• Per information provided with the renewal application, there have been seven(7) significant
spills onsite between January 2019 and May 2022
o Per email dated 6/23/2017 from Hazardous Waste Section, the facility has had numerous
spills of hazardous material with the primary conveyance being the
stormwater/wastewater systems.
o DEMLR inspection conducted June 2020, February 2020, May 2019 for spill issues
• Per the August 2022 inspection, the facility was operating in Tier 3 response, and DEMLR was
deliberating additional Tier 3 response requirements
• Per an email dated 6/27/2017 from the DEQ Hazardous Waste Section: 9 of 15 sample results
came back exceeding hazardous waste limits for one or more constituents including lead,
cadmium, chromium or silver.
Per information provided with the permit renewal application, on November 20, 2018, Befesa requested
discharge from 5 new air compressor units to the stormwater system through wastewater permit
NCG500667 (DEQ e-mailed approval 12/13/2018). On March 22, 2019, Befesa requested non-contact
cooling water be rerouted to the stormwater system(per permittee, DEQ emailed approval on
3/25/2019) (permit writer could not find a record of this approval). On both occasions internal
monitoring points were established to monitor discharge from the NCG500000 units. The 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 during calendar year 2023. Per an email dated 10/5/2023,
Befesa is still assessing the feasibility of redirecting all discharges from the sedimentation pond back
into the manufacturing process, with a goal of transitioning to a zero-discharge facility. Per additional
correspondence dated 10/24/2023, the permittee stated: "Taking representative stormwater samples
before boiler blow down comingling occurs is not feasible. We adhere to the requirements set forth in
parts 122 and 136 of 40 CFR- Samples are collected from Basin 1, which is the state regulated
discharge point and the designated area where flow leaves our property and enters the Broad River. As
you pointed out, our non-contact cooling water discharge also drains into our sedimentation pond [...]
we have implemented BMPs to address potential concerns related to Total Suspended Solids (TSS) and
heavy metals. As part of our BMPs, we conduct additional sampling from individual drains to identify
specific areas that may contribute to these pollutants."
Information in the permit file history identified following additional potential pollutants: NH3-N, Total
Aluminum, Antimony, Arsenic, Total Chromium, Total Cobalt, Total Copper, Fluoride, Total Iron,
Total Nickel, Total Tin, Turbidity, Total Silver, and Chronic Toxicity.
• Per 10/18/2023 email: Excluding Chronic Toxicity, these constituents could potentially be
present in stormwater due to runoff and overland flow throughout the site. However, it is
important to note that most, if not all, of these constituents are likely below detection limits in
our stormwater discharges.
Page 4 of 10

Threatened/Endangered Species:
There are threatened species in the vicinity of the facility, including Dwarf-flowered Heartleaf
(Hexastylis naniflora; NC status: T; Federal status: T), Santee Chub (Cyprinella zanema; NC status: T),
and Thicklip Chub (Cyprinella labrosa; NC status: T). An additional species of concern in the vicinity is
the Seagreen Darter(Etheostoma thalassinum; NC status: SC).
Section 3. Proposed Monitoring for Stormwater Discharges:
The Division considered potential pollutants from past and present industrial activities and data was
submitted for April 2018 to August 2023. Quantitative sampling included pH, TSS, cadmium, lead, zinc,
chlorides, total nitrogen, total phosphorus, and O&G.
Parameters are based on potential pollutants in the drainage area, sampling results, and in some cases,
dependent upon future activities (e.g., ash removal through the drainage area). Below is a table of the
proposed monitoring for each outfall at the Befesa Zinc Metal, LLC site.
Outfall SWO01
Quarterly monitoring
Total Suspended Solids BASIS: Potential pollutant from drainage area and BMP effectiveness
(TSS) indicator.
Quarterly monitoring
H BASIS: Pollutant indicator and important to interpreting toxicity potential
p of metals.
Quarterly monitoring
Total Rainfall BASIS: Discharge potential indicator
Quarterly monitoring
Non-Polar Oil &Grease BASIS: Potential pollutant from lubricants; Method 1664 SGT-HEM
targets petroleum-based O&G
Quarterly monitoring
Monthly Oil Usage BASIS: Potential pollutant from drainage area
Quarterly monitoring
COD BASIS: Discharge potential indicator
Quarterly monitoring
Total Nitrogen BASIS: Potential pollutant from drainage area
Quarterly monitoring
Total Phosphorus BASIS: Potential pollutant from drainage area
Quarterly monitoring
Total Chlorides BASIS: Potential pollutant from drainage area
Page 5 of 10

Quarterly monitoring
Total Cadmium BASIS: Potential pollutant from drainage area
Quarterly monitoring
Total Lead BASIS: Potential pollutant from drainage area
Quarterly monitoring
Total Zinc BASIS: Potential pollutant from drainage area
Ammonia Nitrogen Quarterly monitoring
(Winter) BASIS: Potential pollutant from drainage area
Quarterly monitoring
Aluminum (Total) BASIS: Potential pollutant from drainage area
Quarterly monitoring
Antimony(Total) BASIS: Potential pollutant from drainage area
Quarterly monitoring
Arsenic BASIS: Potential pollutant from drainage area
Quarterly monitoring
Chromium(Total) BASIS: Potential pollutant from drainage area
Quarterly monitoring
Cobalt (Total) BASIS: Potential pollutant from drainage area
Quarterly monitoring
Copper(Total) BASIS: Potential pollutant from drainage area
Quarterly monitoring
Fluoride (Total) BASIS: Potential pollutant from drainage area
Quarterly monitoring
Nickel (Total) BASIS: Potential pollutant from drainage area
Quarterly monitoring
Silver(Total) BASIS: Potential pollutant from drainage area
Quarterly monitoring
Total Hardness BASIS: Monitoring for hardness dependent metals required
Stormwater Benchmarks and Tiered Response: Rather than limits,North Carolina NPDES
Stormwater permits contain benchmark concentrations. Stormwater benchmarks are numerical action
levels for stormwater monitoring. Benchmarks are not effluent limits, and benchmark exceedances are
not permit violations. Benchmarks provide facilities a tool for assessing the significance of pollutants in
stormwater discharges and the effectiveness of best management practices (BMPs). Benchmark
Page 6 of 10

concentrations are intended as guidelines for the facility's development and implementation of the
Stormwater Pollution Prevention Plan(SWPPP).
Benchmark exceedances require the permittee to increase monitoring, increase management actions,
increase record keeping, and/or install stormwater BMPs in a tiered program. The permit establishes a
tiered approach to specify actions the permittee must take in response to analytical results above
benchmark concentrations. The tiered structure of the permit provides the permittee and DEMLR wide
flexibility to address issues that may arise with one or more parameters and/or outfalls.
Metals benchmarks are calculated to mimic acute water quality standards and with the guidance of
DWR. NC DWR follows established federal procedures for calculating acute standards when developing
the benchmarks. Just like the acute standards, metals benchmarks normally reflect one half of the
calculated Final Acute Value (the "1/2 FAV"). In most cases, translation into total recoverable values is
based on an assumed hardness of 25 mg/L and a total suspended solids (TSS) concentration of 10 mg/L.
Acute standards protect aquatic life from negative impacts of short-term exposure to higher levels of
chemicals where the discharge enters a waterbody. The Stormwater Permitting Program applies this
approach because of the ephemeral nature of rainfall events.
The Division may evaluate results to determine if a smaller suite of parameters for some outfalls is
adequate to characterize potential pollution or BMP effectiveness. For example, one or more metals or
other parameters may serve as an adequate tracer for the presence of ash pollution during disturbance or
ash removal in specific drainage areas at this site. For parameters that do not have a stormwater
benchmark, the Division may develop a benchmark value if appropriate toxicity data become available
or if rising trends in concentrations suggest a persistent source.
A summary of the benchmarks in the draft permit, and their basis, is below:
Page 7 of 10

Parameter Benchmark Basis
Total Suspended 100 mg/L National Urban Runoff Program(NURP) Study, 1983
Solids TSS
H 6 s.u. —9 s.u. NC Water Quality Standard(Range)
Non-Polar Oil & Review of other state's daily maximum benchmark
Grease 15 mg/L concentration for this more targeted O&G;NC WQS that
EPA Method 1664 does not allow oil sheen in waters
SGT-HEM
COD 120 mg/L BPJ; Generally found at levels 4x BOD5 in domestic
wastewaters
Total Nitrogen 30 mg/L TKN+Nitrate+Nitrite Benchmarks (Expressed in mg/L of
N
Total Phosphorus 2 mg/L BPJ; Based on wastewater permit limits for NSW waters
Chlorides 860 mg/L EPA's National Recommended Water Quality Criteria, 2006
Cadmium Total 3 /L Acute Aquatic Criterion, 1/2 FAV
Lead Total 75 /L Acute Aquatic Criterion, 1/2 FAV
Zinc Total 126 /L Acute Aquatic Criterion, 1/2 FAV
Ammonia Nitrogen At 7.5 s.u. pH and summer(26°C) temperature from
(Summer) 5.6 mg/L Wasteload Allocation document for the coastal plain region
worst-case scenario
Ammonia Nitrogen At 7.5 s.u. pH and summer(26°C) temperature from
(Winter) 15 mg/L Wasteload Allocation document for the coastal plain region
worst-case scenario
Aluminum Total 750 /L Acute Aquatic Criterion, 1/2 FAV
Antimony Total 340 /L '/2 FAV
Arsenic 340 /L 1/2 FAV
1/2 FAV; Based on (Cr III+Cr VI) acute thresholds and
Chromium(Total) 905 µg/L assumption that industrial activities here are not a source of
hexavalent chromium
Copper Total 10 /L Acute Aquatic Criterion, 1/2 FAV
Fluoride Total 170 mg/L
Nickel Total 335 /L 1/2 FAV
Silver Total 0.3 /L I 1/2 FAV
Stormwater Pollution Prevention Plan: The proposed permit conditions reflect the EPA and NC's
pollution prevention approach to stormwater permitting. The Division's maintains that implementation
of Best Management Practices (BMPs) and traditional stormwater management practices that control the
source of pollutants meets the definition of Best Available Technology (BAT) and Best Conventional
Pollutant Control Technology(BCT). The permit conditions are not numeric effluent limitations but are
designed to be flexible requirements for implementing site-specific plans to minimize and control
pollutants in stormwater discharges associated with the industrial activity. Title 40 Code of Federal
Regulations (CFR) §122.44(k)(2) authorizes the use of BMPs in lieu of numeric effluent limitations in
NPDES permits when the agency finds numeric effluent limitations to be infeasible. The agency may
also impose BMP requirements which are "reasonably necessary" to carry out the purposes of the Act
under the authority of 40 CFR 122.44(k)(3). The conditions proposed in this draft permit are included
under the authority of both of these regulatory provisions. In essence, the pollution prevention and BMP
requirements operate as limitations on effluent discharges that reflect the application of BAT/BCT.
Page 8 of 10

Flexibility in Tier Responses: Tier Two actions provide an opportunity for the permittee to propose an
alternative monitoring plan for approval by the Region:
• Alternatively, in lieu of steps 2 and 3, the permittee may, after two consecutive exceedances,
exercise the option of contacting the DEMLR Regional Engineer as provided below in Tier
Three. The Regional Engineer may direct the response actions on the part of the permittee as
provided in Tier Three, including reduced or additional sampling parameters or frequency.
• If pursuing the alternative above after two consecutive exceedances, the permittee may propose
an alternative monitoring plan for approval by the Regional Engineer.
The permit therefore allows the permittee to petition the Regional Office for monitoring changes sooner
than Tier Three (upon any four benchmark exceedances) and gives guidance on one option to take. For
example, the permittee may request that mercury only be monitored semi-annually under the tiers, or
that only parameters over the benchmark be monitored more frequently. In this way, changes to the
monitoring scheme for any outfall could be handled outside of a permit modification.
Other Proposed Requirements:
• It is standard for Stormwater Pollution Prevention Plan(SWPPP)requirements to include an
annual certification that stormwater outfalls have been evaluated for the presence of non-
stormwater discharges, and if any are identified, how those discharges are permitted or otherwise
authorized.
• Requirement to submit a request for permit modification if the facility identifies or creates any
new outfalls, removes outfalls, or alters any drainage area that changes potential pollutants.
• The Division expects the permittee to apply best professional judgment and consider the safety
of its personnel in fulfilling sampling obligations under the permit.
• Federal regulations require electronic submittal of all discharge monitoring reports (DMRs). If a
state does not establish a system to receive such submittals, then permittees must submit DMRs
electronically to the EPA.
• Quarterly QualitativeNisual Monitoring to assure regular observation of outfalls throughout
year.
Section 4. Changes from previous permit to draft:
• Regulatory citations added
• "No discharge" clarifications made
• Feasibility study requirement removed per updated stormwater program requirements
• eDMR requirement added
• Boilerplate language moved into body of the permit; boilerplate no longer attached
• Outfall-specific monitoring been implemented to reflect industrial activity and potential
pollutants specific to each discharge area
• Monitoring for COD added for all outfalls due to type of industrial activity occurring onsite and
materials stored onsite
• Monitoring added for Ammonia Nitrogen, Total Aluminum, Antimony, Arsenic, Total
Chromium, Total Cobalt, Total Copper, Fluoride, Total Nickel, and Total Silver as these have
been identified as potential pollutants at the facility
o Footnote added that monitoring can cease after 4 consecutive sampling event showing
results below benchmarks
Page 9 of 10

• Monitoring for total hardness added for outfalls where monitoring for hardness dependent metals
is required
• Benchmarks updated for parameters per guidance from DWR Standards group on stormwater
benchmarks
Section 5. Changes from draft to final:
• None
Section 6. Discussions with the Facility and Regional Office:
• Initial contact with facility: 10/3/2023
• Initial contact with Regional Office: 9/27/2023
• Draft sent to CO peer review: N/A
• Draft sent to Regional Office: l l/l/2023
• Final permit sent for supervisor signature: 12/14/2023
Section 7. Comments received on draft permit:
• None
Page 10 of 10

* LocaliQ
Georgia/North Carolina PO Box 631697 Cincinnati, OH 45263-1697
South Carolina
GANNETT
NORTH CAROLINA ENVIRONMENTAL
PROOF OF PUBLICATION MANAGEMENT COMMISSION INTENT TO ISSUE
NPDES STORMWATER DISCHARGE PERMITS
Brianna Young The North Carolina Environmental Management Commis-
Deq Div Of Water Resources sion proposes to issue NPDES stormwater discharge
1617 Mail Service Ctr permit(s) to the person(s) listed below. Public comment or
obiection to the draft permits is invited. Written comments
Raleigh NC 27699-1617 regarding the proposed permit will be accepted until 30 days
after the publish date of this notice and considered in the
final determination regarding permit issuance and permit
provisions. The Director of the NC Division of Energy,
STATE OF WISCONSIN, COUNTY OF BROWN Mineral, and Land Resources (DEMLR) may hold a public
hearing should there be a significant degree of public inter-
est. Please mail comments and/or information requests to
Before the undersigned, a Notary Public, duly DEM LR at 1612 Mail Service Center, Raleigh, NC 27699-
commissioned, qualified and authorized by law to . Befesa Zinc Metal, LLC [484 Hicks Grove Road, Moores-
administer oaths, personally appeared said legal clerk, who, boro, NC 281141 has requested renewal of permit NCS000562
for the Befesa Zinc Metal, LLC in Rutherford County. This
being first duly sworn,deposes and says: that he/she is the facility discharges to the Broad River in the Broad River
legal clerk of The Asheville Citizen-Times,engaged in Basin.
publication of a newspaper known as The Asheville Citizen- Interested persons may visit DEMLR at 512 N. Salisbury
pStreet, Raleigh, NC 27604 to review information on file.
Times, published, issued and entered as first class mail in Additional information on NPDES permits and this notice
may be found on our website:
the city of Asheville, in Buncombe County, State of North https://deq.nc.gov/about/divisions/energy-mineral-and-Iand-
resources/stormwater/stormwater-program/stormwater-
Carolina;that he/she is authorized to make this affidavit public-notices, or by contacting Brianna Young at
and sworn statement; that the notice or other legal Nove bee 8,2023 nc.gov or 919-707-3647.
g November 8,2023 9492902
advertisement, a true copy of which is attached here to,
was published in said newspaper in the issues dated:
11/08/2023
That said newspaper in which said notice, paper, document
or legal advertisement was published was, at the time of
each and every publication, a newspaper meeting all 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.
Sworn to and subscribed before on 11/08/2023
Legal Clerk
Notary,ghftrafWl,Coun[y 13'a
My commision expires
Publication Cost: $167.48
Order No: 9492902 #of Copies:
Customer No: 948986 2
PO#: NCS000562
THIS IS NOT AN INVOICE!
Please do not use this form.1br payment remittance.
VICKY FELTY
C Notary Public Page 1 of 1
State of Wisconsin

Young, Brianna A
From: William N.White <[e-mail]>
Sent: Tuesday, October 24, 2023 3:26 PM
To: Young, Brianna A
Cc: Kaitlyn Sampson
Subject: RE: [External] RE: Befesa Zinc Metal, LLC facility stormwater permit NCS000562
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Brianna,
Taking representative stormwater samples before boiler blow down comingling occurs is not feasible. We adhere to the
requirements set forth in parts 122 and 136 of 40 CFR--Samples are collected from Basin 1, which is the state regulated
discharge point and the designated area where flow leaves our property and enters the Broad River. As you pointed out,
our non-contact cooling water discharge also drains into our sedimentation pond—however, as you know, non-contact
cooling water does not come into contact with raw material, products, or byproducts—which is why I assume many
years ago NCDEQ approved our NCG permit.
That being said, we have implemented BMPs to address potential concerns related to Total Suspended Solids (TSS) and
heavy metals. As part of our BMPs,we conduct additional sampling from individual drains to identify specific areas that
may contribute to these pollutants.
Respectfully,
BEFESA
William White I EHS Manager—Befesa Zinc Metal
484 Hicks Grove Road,Mooresboro,North Carolina 28114
Work: [phone] I Cell: [phone]
William.whitegbefesa.com
------------------------------------------------
Do you have environmental concerns from the plant?
Want to give feedback to your BZM Environmental Department?
Use the below QR and take our survey!
J. 4�
�
From:Young, Brianna A<[e-mail]>
Sent:Tuesday, October 24, 2023 2:32 PM
To: William N. White<[e-mail]>
Cc: Kaitlyn Sampson <[e-mail]>
Subject: RE: [External] RE: Befesa Zinc Metal, LLC facility stormwater permit NCS000562
Thank you for the clarification. Based on this information, it does appear stormwater (discharges permitted under
NCS000562)and wastewater (discharges permitted under NCG500000) are being comingled before stormwater samples
1

are taken. As stated previously,wastewater discharges through stormwater outfalls are not typically allowed in
stormwater permits, and the Stormwater Program should be notified immediately about any changes to site activities
that would affect permitted stormwater outfalls.
Is it possible to take samples of stormwater before the comingling occurs?
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
From:William N. White<[e-mail]>
Sent:Thursday, October 19, 2023 1:10 PM
To:Young, Brianna A<[e-mail]>
Cc: Kaitlyn Sampson <[e-mail]>
Subject: RE: [External] RE: Befesa Zinc Metal, LLC facility stormwater permit NCS000562
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Brianna,
That makes much more sense—The discharges allowed under NCG500000 are currently being overseen within Basin 1.
Regular monthly samples are taken from the SDO after this water is integrated into the system.
It's important to note that we possess the ability to redirect the water from our sedimentation basin back into the
processing system if any complications arise, ensuring our operations remain compliant.
*Note—I removed a few individuals from this email chain to mitigate the large email traffic. I will back brief Kobus, and
Katie will back brief her Environmental Team.*
Respectfully,
BEFESA
William White I EHS Manager—Befesa Zinc Metal
484 Hicks Grove Road,Mooresboro,North Carolina 28114
Work: [phone] I Cell: [phone]
William.whiteL&befesa.com
------------------------------------------------
Do you have environmental concerns from the plant?
Want to give feedback to your BZM Environmental Department?
2

Use the below QR and take our survey!
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d. }
0.
From:Young, Brianna A<[e-mail]>
Sent:Thursday, October 19, 2023 12:59 PM
To:William N. White<[e-mail]>
Cc: Kobus de Wet<[e-mail]>;Angelica Martinez-Valdes<[e-mail]>; Kaitlyn
Sampson<[e-mail]>; Kaley R. Stanley<[e-mail]>
Subject: RE: [External] RE: Befesa Zinc Metal, LLC facility stormwater permit NCS000562
William,
I apologize for the confusion. Per information previously provided, Befesa requested discharge from 5 air compressor
units and non-contact cooling water to the stormwater system through wastewater permit NCG500667, and that the
plant continues to route these discharges through the stormwater outlet. Any discharges permitted under an
NCG500000 permit are considered wastewater discharges. Based on the information in the permit application, these
wastewaters are still being discharged through stormwater outfalls. Can you confirm if wastewater from air compressor
units and non-contact cooling water are still being discharged through the stormwater system? If so, are you sampling
stormwater before or after the introduction of these wastestreams?
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
From:William N. White<[e-mail]>
Sent:Thursday, October 19, 2023 12:32 PM
To:Young, Brianna A<[e-mail]>
Cc: Kobus de Wet<[e-mail]>;Angelica Martinez-Valdes<[e-mail]>; Kaitlyn
Sampson<[e-mail]>; Kaley R. Stanley<[e-mail]>
Subject: RE: [External] RE: Befesa Zinc Metal, LLC facility stormwater permit NCS000562
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
3

Brianna,
Thank you for getting back to me. I want to reiterate that there is no commingling of wastewater and stormwater at our
facility. Our systems are designed to keep these streams entirely separate. Specifically,the east effluent pond is
transferred via a dedicated pipeline to our effluent flow discharge point in the Broad River.This system runs
independently of our stormwater conveyance system.
For your reference, I have attached the map I shared earlier, illustrating the distinct stormwater conveyance pathways.
Our stormwater is directed to a sedimentation basin (Basin 1) where settling occurs, preventing Total Suspended Solids
(TSS) and turbidity in our outflow. It's important to note that all conveyance on the North side of the plant leads to the
West/East stormwater ponds, not the East Effluent Pond, where it is redirected back into the process.
Please feel free to reach out if you require any additional information or if there are further questions.Thanks Brianna!
Respectfully,
BEFESA
William White I EHS Manager—Befesa Zinc Metal
484 Hicks Grove Road,Mooresboro,North Carolina 28114
Work: [phone] I Cell: [phone]
William.Whitc(Dbcfesa.com
------------------------------------------------
Do you have environmental concerns from the plant?
Want to give feedback to your BZM Environmental Department?
Use the below QR and take our survey!
0 0
o-
d. }
0.
From:Young, Brianna A<[e-mail]>
Sent:Thursday, October 19, 2023 12:19 PM
To:William N. White <[e-mail]>
Cc: Kobus de Wet<[e-mail]>;Angelica Martinez-Valdes<[e-mail]>; Kaitlyn
Sampson<[e-mail]>; Kaley R. Stanley<[e-mail]>
Subject: RE: [External] RE: Befesa Zinc Metal, LLC facility stormwater permit NCS000562
Good morning,
Thank you for providing this information. Files for NPDES COC NCG500667 can be found online here. I was able to find a
DEQ email dated 12/13/2018 but was unable to find any documentation dated 3/25/2019. As it appears wastewater and
stormwater are being comingled in the stormwater outfall, can you confirm if stormwater samples are being taken
before or after the wastewater is comingled?Wastewater discharges through stormwater outfalls are not typically
allowed in stormwater permits, and the Stormwater Program should be notified immediately about any changes to site
activities that would affect permitted stormwater outfalls.
Thank you,
Brianna Young, MS(she/her)
4

Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
Brian na.Young@d eq.nc.goy(e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
From: William N. White<[e-mail]>
Sent: Wednesday, October 18, 2023 7:36 AM
To:Young, Brianna A<[e-mail]>
Cc: Kobus de Wet<[e-mail]>;Angelica Martinez-Valdes<[e-mail]>; Kaitlyn
Sampson<[e-mail]>; Kaley R. Stanley<[e-mail]>
Subject: RE: [External] RE: Befesa Zinc Metal, LLC facility stormwater permit NCS000562
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Good morning Brianna,
I appreciate you taking the time to review our records and for reaching out to us regarding these questions. Below are
my responses to your inquiries as outlined in your email.
Documentation of DEQ Approvals:
I acknowledge your request for copies of the emails dated 12/13/2018 and 3/25/2019, as referenced in our NPDES
package. However,these specific emails are not currently in our records. I want to emphasize that the issuance of the
NCG permit does signify the approval of these discharges. Could you kindly confirm whether DEQ has these approval
emails on file? If so,we would greatly appreciate it if you could share them with us for proper filing. If not, please let me
know, and I will re-submit the request to your team.
Sampling Data Accuracy:
I understand your concern regarding the presentation of sampling data.The headers indicating "sum of xxx" in the
provided information do represent the individual sampling events, not aggregated values(excel automatically does this
when creating a pivot table). I apologize for any confusion caused and can assist you further if you require additional
clarification or specific data.
Pond Discharge Locations:
• West Stormwater Pond: No discharge;water is pumped back into our process.
• West Maintenance Pond: No discharge; it is connected to the West Stormwater Pond for overflow protection.
• West Raffinate Pond: No discharge; water is pumped back into our process.
• West Depleted Solution Pond: No discharge; water is pumped back into our process.
• East Effluent Pond: Discharged under wastewater permit.
• East Stormwater Pond: No discharge; water is pumped back into the process.
• Basin 1: Stormwater Sedimentation Pond, discharges to the Broad River(SDO#1).
5

Potential Pollutants in Stormwater Discharges:
Excluding Chronic Toxicity,these constituents could potentially be present in stormwater due to runoff and overland
flow throughout the site. However, it is important to note that most, if not all, of these constituents are likely below
detection limits in our stormwater discharges. We would be happy to confirm if necessary.
Please feel free to reach out if you require any additional information or if there are further questions.Thanks Brianna!
Respectfully,
BEFESA
William White I EHS Manager—Befesa Zinc Metal
484 Hicks Grove Road,Mooresboro,North Carolina 28114
Work: [phone] I Cell: [phone]
William.whiteL&befesa.com
------------------------------------------------
Do you have environmental concerns from the plant?
Want to give feedback to your BZM Environmental Department?
Use the below QR and take our survey!
0 FEI
r• r
From:Young, Brianna A<[e-mail]>
Sent:Tuesday, October 17, 2023 2:58 PM
To: William N. White<[e-mail]>
Cc: Kobus de Wet<[e-mail]>;Angelica Martinez-Valdes<[e-mail]>; Kaitlyn
Sampson<[e-mail]>; Kaley R. Stanley<[e-mail]>
Subject: RE: [External] RE: Befesa Zinc Metal, LLC facility stormwater permit NCS000562
Good afternoon,
After reviewing all the submitted information, I have a few follow-up questions.
1. My previous information request asked that documentation be provided of DEQ approving discharge of non-
contact cooling water and air compressor condensate through stormwater outfalls. The response to the
information request included COC NCG500667. Per the permit renewal application,there are emails from
12/13/2018 and 3/25/2019 allowing these discharges. Please provide copies of these emails.
2. Your response to the information request included sampling data, however,the data appears to have summed
values of each parameter for each month, rather than results from each sampling event. Please provide the
results for individual sampling points (not the sum for each month)for August 2022 to the most recent sampling
event.
3. Information in the permit file history indicates there are 4 ponds onsite: Storm Pond, West Maintenance Pond,
Raffinate Pond, and Depleted Solution Pond.The information indicates discharges from the maintenance,
raffinate, and solution ponds go back into the process, and water from the storm pond is discharged with a
wastewater permit. Can you confirm the location of discharge for each pond?
6

4. Information in the permit file history indicates there are additional potential pollutants onsite related to
industrial processes. Please confirm if any of these pollutants are or could be present in stormwater discharges:
NH3-N,Total Aluminum,Antimony, Arsenic,Total Chromium,Total Cobalt,Total Copper, Fluoride,Total Iron,
Total Nickel,Total Tin,Total Silver, Chronic Toxicity, and Turbidity.
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
From:Young, Brianna A
Sent:Thursday, October S, 2023 11:4S AM
To: William N. White<[e-mail]>
Cc: Kobus de Wet<[e-mail]>;Angelica Martinez-Valdez<[e-mail]>; Kaitlyn
Sampson<[e-mail]>; Kaley R. Stanley<[e-mail]>
Subject: RE: [External] RE: Befesa Zinc Metal, LLC facility stormwater permit NCSOOOS62
Good morning,
Thank you for providing this information. I will reach out with any additional questions once I've had a chance to review
everything.
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
7

The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
From: William N. White<[e-mail]>
Sent:Thursday, October 5, 2023 9:42 AM
To:Young, Brianna A<[e-mail]>
Cc: Kobus de Wet<[e-mail]>;Angelica Martinez-Valdez<[e-mail]>; Kaitlyn
Sampson<[e-mail]>; Kaley R. Stanley<[e-mail]>
Subject: [External] RE: Befesa Zinc Metal, LLC facility stormwater permit NCS000562
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Good morning Brianna,
I appreciate your prompt communication and the detailed list of requirements for the renewal of our stormwater
permit. Attached you will find following/requested documents for your review and verification:
File 1: NPDES NCG500000(NCG500667, Non-Contact Cooling Water, Boiler Blowdown, etc.)
File 2: BZM Site Map/Drain Configuration
File 3: List of Chemicals (Tier 11)
File 4: Industrial Activity (Per Area)— Refer to page 13, hyperlinked in the table of contents on page 3.
File 5: Stormwater Database (PDF)
File 6: Stormwater Database (Excel)
In response to your specific requests:
Response 1: Regarding the status of rerouting discharges, our team is actively exploring the feasibility of redirecting all
discharges from our sedimentation pond back into the manufacturing process.The aim is to transition towards
becoming a zero-discharge facility.
Response 2: 1 have noted an administrative change that needs to be addressed. Specifically, on EPA Form 3510-1,the
personnel information may need a change.Jan, who was previously designated, is no longer with the company. I have
assumed the role of the appropriate facility contact.All technical details in the application remain accurate.
Response 3:There have been notable operational enhancements. We have utilized GIS mapping to enhance our
understanding of site characteristics.Additionally, our BMP processes have been refined to target key areas contributing
to Tier 3 status.
Furthermore, I can confirm that all information in the stormwater summary report has been reviewed and updated to
reflect our current operational status. Should you require any further clarification or additional details, please do not
hesitate to contact me. We look forward to your feedback and appreciate your efforts in facilitating this permit renewal
process.
Respectfully,
BEFESA
William White I EHS Manager—Befesa Zinc Metal
484 Hicks Grove Road,Mooresboro,North Carolina 28114
Work: [phone] 1 Cell: [phone]
William.whitc(bbefesa.com
------------------------------------------------
8

Do you have environmental concerns from the plant?
Want to give feedback to your BZM Environmental Department?
Use the below QR and take our survey!
}
a. .
From: Young, Brianna A<[e-mail]>
Sent:Tuesday, October 3, 2023 2:31 PM
To: Kobus de Wet<[e-mail]>
Cc:Jan Nedbal <[e-mail]>; William N. White <[e-mail]>
Subject: Befesa Zinc Metal, LLC facility stormwater permit NCS000562
Good afternoon,
I am working on renewing the individual stormwater permit for the Befesa Zinc Metal, LLC facility
(NCS000562). I need additional information in order to 1) confirm that the information I have is correct and 2)
make sure the permit adequately serves the needs of the facility. Please provide the following:
• Provide documentation of DEQ approval to discharge non-contact cooling water and air compressor
condensate through stormwater outfalls;
• Provide an update on the status of rerouting the above discharges back into the process;
• Provide an updated site map (the one provided with the application is not clear to read);
• Description of chemicals stored onsite;
• Description of industrial activity in each drainage area;
• An electronic spreadsheet summarizing all of the monitoring data that has been collected since the
effective date of the current permit;
• Verification that the information in the renewal application is still complete and correct; and
• An explanation of any operational changes since the renewal application was submitted.
Enter your stormwater permit number into the Stormwater Permit Summary Report and you will see a form that
includes the address of the facility, contact information for the permit, and the regulated stormwater outfall(s)
for the facility. Please review the facility information to make sure it is correct. Information can be updated
using the links provided below, where applicable:
• Facility/Company name or ownership: Name/Ownership Change. Form
• Owner Affiliation (Legally responsible person; i.e., someone with the company who is designated to
represent the company per signatory requirements or another authorized representative): Permit Contact
Update Request Form
• Delegation of Signature Authority (DOSA): Permit Contact Update Request Form
• Billing contact: Permit Contact Update Request Form
• Permit contact: Permit Contact Update Request Form
• Facility contact: Permit Contact Update Request Form
• Facility address only: Email Bethany og ulias
• Stormwater outfall information: Email Bethany Geor_og ulias
• Visit the eDMR Six Steps website and complete Steps 1 and 2
• Pay outstanding permit fees: Stormwater ePayment website
9

Once I have the above listed information, I can continue my review. You will receive a draft permit for a 30-day
comment period. During this time we will be able to address any comments or concerns you have. During the
same 30-day period, the draft will be sent to a Regional Office staff member for review as well as out to public
notice. Once all comments and concerns are addressed, you may be issued a final permit.
Please contact me if you have any questions.
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred) PLEASE NOTE NEW EMAIL ADDRESS
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.
Befesa complies with the regulations on personal data protection.Please,check our Privacy Policy
*******Internet Email Confidentiality footer*****
This email and any files transmitted with it are confidential and intended solely for the use of the organization or individual to whom they are addressed.It is expressly forbidden to retransmit or copy email
and/or this attached files without our permission.If you are not the addressee indicated in this message(or responsible for delivery of the message to such person),you may not copy or deliver this
message to anyone.In such case,you should destroy this message and kindly notify the sender by reply email.Please advise immediately if you or your employer does not consent to Internet email for
messages of this kind.Opinions,conclusions and other information in this message that do not relate to the official business of my firm shall be understood as neither given nor endorsed by it.
Befesa complies with the regulations on personal data protection.Please,check our Privacy Policy
*******Internet Email Confidentiality footer*****
This email and any files transmitted with it are confidential and intended solely for the use of the organization or individual to whom they are addressed.It is expressly forbidden to retransmit or copy email
and/or this attached files without our permission.If you are not the addressee indicated in this message(or responsible for delivery of the message to such person),you may not copy or deliver this
message to anyone.In such case,you should destroy this message and kindly notify the sender by reply email.Please advise immediately if you or your employer does not consent to Internet email for
messages of this kind.Opinions,conclusions and other information in this message that do not relate to the official business of my firm shall be understood as neither given nor endorsed by it.
Befesa complies with the regulations on personal data protection.Please,check our Privacy Policy
10

*******Internet Email Confidentiality footer*****
This email and any files transmitted with it are confidential and intended solely for the use of the organization or individual to whom they are addressed.It is expressly forbidden to retransmit or copy email
and/or this attached files without our permission.If you are not the addressee indicated in this message(or responsible for delivery of the message to such person),you may not copy or deliver this
message to anyone.In such rase,you should destroy this message and kindly notify the sender by reply email.Please advise immediately if you or your employer does not consent to Internet email for
messages of this kind.Opinions,conclusions and other information in this message that do not relate to the official business of my firm shall be understood as neither given nor endorsed by it.
Befesa complies with the regulations on personal data protection.Please,check our Privacy Policy
*******Internet Email Confidentiality footer*****
This email and any files transmitted with it are confidential and intended solely for the use of the organization or individual to whom they are addressed.It is expressly forbidden to retransmit or copy email
and/or this attached files without our permission.If you are not the addressee indicated in this message(or responsible for delivery of the message to such person),you may not copy or deliver this
message to anyone.In such rase,you should destroy this message and kindly notify the sender by reply email.Please advise immediately if you or your employer does not consent to Internet email for
messages of this kind.Opinions,conclusions and other information in this message that do not relate to the official business of my firm shall be understood as neither given nor endorsed by it.
Befesa complies with the regulations on personal data protection.Please,check our Privacy Policy
*******Internet Email Confidentiality footer*****
This email and any files transmitted with it are confidential and intended solely for the use of the organization or individual to whom they are addressed.It is expressly forbidden to retransmit or copy email
and/or this attached files without our permission.If you are not the addressee indicated in this message(or responsible for delivery of the message to such person),you may not copy or deliver this
message to anyone.In such rase,you should destroy this message and kindly notify the sender by reply email.Please advise immediately if you or your employer does not consent to Internet email for
messages of this kind.Opinions,conclusions and other information in this message that do not relate to the official business of my firm shall be understood as neither given nor endorsed by it.
11

Young, Brianna A
From: William N.White <[e-mail]>
Sent: Thursday, October 19, 2023 1:10 PM
To: Young, Brianna A
Cc: Kaitlyn Sampson
Subject: RE: [External] RE: Befesa Zinc Metal, LLC facility stormwater permit NCS000562
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Brianna,
That makes much more sense—The discharges allowed under NCG500000 are currently being overseen within Basin 1.
Regular monthly samples are taken from the SDO after this water is integrated into the system.
It's important to note that we possess the ability to redirect the water from our sedimentation basin back into the
processing system if any complications arise, ensuring our operations remain compliant.
*Note—I removed a few individuals from this email chain to mitigate the large email traffic. I will back brief Kobus, and
Katie will back brief her Environmental Team.*
Respectfully,
BEFESA
William White I EHS Manager—Befesa Zinc Metal
484 Hicks Grove Road,Mooresboro,North Carolina 28114
Work: [phone] I Cell: [phone]
William.whitegbefesa.com
------------------------------------------------
Do you have environmental concerns from the plant?
Want to give feedback to your BZM Environmental Department?
Use the below QR and take our survey!
RP 0
r• r
From:Young, Brianna A<[e-mail]>
Sent:Thursday, October 19, 2023 12:59 PM
To: William N. White<[e-mail]>
Cc: Kobus de Wet<[e-mail]>; Angelica Martinez-Valdes<[e-mail]>; Kaitlyn
Sampson<[e-mail]>; Kaley R. Stanley<[e-mail]>
Subject: RE: [External] RE: Befesa Zinc Metal, LLC facility stormwater permit NCS000562
William,
i

I apologize for the confusion. Per information previously provided, Befesa requested discharge from 5 air compressor
units and non-contact cooling water to the stormwater system through wastewater permit NCG500667, and that the
plant continues to route these discharges through the stormwater outlet. Any discharges permitted under an
NCG500000 permit are considered wastewater discharges. Based on the information in the permit application, these
wastewaters are still being discharged through stormwater outfalls. Can you confirm if wastewater from air compressor
units and non-contact cooling water are still being discharged through the stormwater system? If so, are you sampling
stormwater before or after the introduction of these wastestreams?
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
From:William N. White<[e-mail]>
Sent:Thursday, October 19, 2023 12:32 PM
To:Young, Brianna A<[e-mail]>
Cc: Kobus de Wet<[e-mail]>;Angelica Martinez-Valdes<[e-mail]>; Kaitlyn
Sampson<[e-mail]>; Kaley R. Stanley<[e-mail]>
Subject: RE: [External] RE: Befesa Zinc Metal, LLC facility stormwater permit NCS000562
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Brianna,
Thank you for getting back to me. I want to reiterate that there is no commingling of wastewater and stormwater at our
facility. Our systems are designed to keep these streams entirely separate. Specifically,the east effluent pond is
transferred via a dedicated pipeline to our effluent flow discharge point in the Broad River.This system runs
independently of our stormwater conveyance system.
For your reference, I have attached the map I shared earlier, illustrating the distinct stormwater conveyance pathways.
Our stormwater is directed to a sedimentation basin (Basin 1) where settling occurs, preventing Total Suspended Solids
(TSS) and turbidity in our outflow. It's important to note that all conveyance on the North side of the plant leads to the
West/East stormwater ponds, not the East Effluent Pond, where it is redirected back into the process.
Please feel free to reach out if you require any additional information or if there are further questions.Thanks Brianna!
Respectfully,
2

BEFESA
William White I EHS Manager—Befesa Zinc Metal
484 Hicks Grove Road,Mooresboro,North Carolina 28114
Work: [phone] 1 Cell: [phone]
W illiam.whiteg.befesa.corn
------------------------------------------------
Do you have environmental concerns from the plant?
Want to give feedback to your BZM Environmental Department?
Use the below QR and take our survey!
0I' .
d.
li
From:Young, Brianna A<[e-mail]>
Sent:Thursday, October 19, 2023 12:19 PM
To:William N. White<[e-mail]>
Cc: Kobus de Wet<[e-mail]>;Angelica Martinez-Valdes<[e-mail]>; Kaitlyn
Sampson<[e-mail]>; Kaley R. Stanley<[e-mail]>
Subject: RE: [External] RE: Befesa Zinc Metal, LLC facility stormwater permit NCS000562
Good morning,
Thank you for providing this information. Files for NPDES COC NCG500667 can be found online here. I was able to find a
DEQ email dated 12/13/2018 but was unable to find any documentation dated 3/25/2019. As it appears wastewater and
stormwater are being comingled in the stormwater outfall, can you confirm if stormwater samples are being taken
before or after the wastewater is comingled?Wastewater discharges through stormwater outfalls are not typically
allowed in stormwater permits, and the Stormwater Program should be notified immediately about any changes to site
activities that would affect permitted stormwater outfalls.
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
919-707-3647(office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
From:William N. White<[e-mail]>
Sent:Wednesday, October 18, 2023 7:36 AM
3

To:Young, Brianna A<[e-mail]>
Cc: Kobus de Wet<[e-mail]>;Angelica Martinez-Valdes<[e-mail]>; Kaitlyn
Sampson<[e-mail]>; Kaley R. Stanley<[e-mail]>
Subject: RE: [External] RE: Befesa Zinc Metal, LLC facility stormwater permit NCS000562
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Good morning Brianna,
I appreciate you taking the time to review our records and for reaching out to us regarding these questions. Below are
my responses to your inquiries as outlined in your email.
Documentation of DEQ Approvals:
I acknowledge your request for copies of the emails dated 12/13/2018 and 3/25/2019, as referenced in our NPDES
package. However,these specific emails are not currently in our records. I want to emphasize that the issuance of the
NCG permit does signify the approval of these discharges. Could you kindly confirm whether DEQ has these approval
emails on file? If so,we would greatly appreciate it if you could share them with us for proper filing. If not, please let me
know, and I will re-submit the request to your team.
Sampling Data Accuracy:
I understand your concern regarding the presentation of sampling data.The headers indicating "sum of xxx" in the
provided information do represent the individual sampling events, not aggregated values(excel automatically does this
when creating a pivot table). I apologize for any confusion caused and can assist you further if you require additional
clarification or specific data.
Pond Discharge Locations:
• West Stormwater Pond: No discharge;water is pumped back into our process.
• West Maintenance Pond: No discharge; it is connected to the West Stormwater Pond for overflow protection.
• West Raffinate Pond: No discharge; water is pumped back into our process.
• West Depleted Solution Pond: No discharge; water is pumped back into our process.
• East Effluent Pond: Discharged under wastewater permit.
• East Stormwater Pond: No discharge; water is pumped back into the process.
• Basin 1: Stormwater Sedimentation Pond, discharges to the Broad River(SDO#1).
Potential Pollutants in Stormwater Discharges:
Excluding Chronic Toxicity,these constituents could potentially be present in stormwater due to runoff and overland
flow throughout the site. However, it is important to note that most, if not all, of these constituents are likely below
detection limits in our stormwater discharges. We would be happy to confirm if necessary.
Please feel free to reach out if you require any additional information or if there are further questions.Thanks Brianna!
Respectfully,
BEFESA
William White I EHS Manager—Befesa Zinc Metal
484 Hicks Grove Road,Mooresboro,North Carolina 28114
Work: [phone] I Cell: [phone]
William.whiteL&befesa.com
------------------------------------------------
Do you have environmental concerns from the plant?
Want to give feedback to your BZM Environmental Department?
4

Use the below QR and take our survey!
0 0
ti
d. }
0.
From:Young, Brianna A<[e-mail]>
Sent:Tuesday, October 17, 2023 2:58 PM
To:William N. White<[e-mail]>
Cc: Kobus de Wet<[e-mail]>;Angelica Martinez-Valdes<[e-mail]>; Kaitlyn
Sampson<[e-mail]>; Kaley R. Stanley<[e-mail]>
Subject: RE: [External] RE: Befesa Zinc Metal, LLC facility stormwater permit NCS000562
Good afternoon,
After reviewing all the submitted information, I have a few follow-up questions.
1. My previous information request asked that documentation be provided of DEQ approving discharge of non-
contact cooling water and air compressor condensate through stormwater outfalls. The response to the
information request included COC NCG500667. Per the permit renewal application,there are emails from
12/13/2018 and 3/25/2019 allowing these discharges. Please provide copies of these emails.
2. Your response to the information request included sampling data, however,the data appears to have summed
values of each parameter for each month, rather than results from each sampling event. Please provide the
results for individual sampling points (not the sum for each month)for August 2022 to the most recent sampling
event.
3. Information in the permit file history indicates there are 4 ponds onsite: Storm Pond, West Maintenance Pond,
Raffinate Pond, and Depleted Solution Pond.The information indicates discharges from the maintenance,
raffinate, and solution ponds go back into the process, and water from the storm pond is discharged with a
wastewater permit. Can you confirm the location of discharge for each pond?
4. Information in the permit file history indicates there are additional potential pollutants onsite related to
industrial processes. Please confirm if any of these pollutants are or could be present in stormwater discharges:
NH3-N,Total Aluminum,Antimony, Arsenic,Total Chromium,Total Cobalt,Total Copper, Fluoride,Total Iron,
Total Nickel,Total Tin,Total Silver, Chronic Toxicity, and Turbidity.
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
5

Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
From:Young, Brianna A
Sent:Thursday, October 5, 2023 11:45 AM
To:William N. White<[e-mail]>
Cc: Kobus de Wet<[e-mail]>;Angelica Martinez-Valdez<[e-mail]>; Kaitlyn
Sampson<[e-mail]>; Kaley R. Stanley<[e-mail]>
Subject: RE: [External] RE: Befesa Zinc Metal, LLC facility stormwater permit NCS000562
Good morning,
Thank you for providing this information. I will reach out with any additional questions once I've had a chance to review
everything.
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
From: William N. White<[e-mail]>
Sent:Thursday, October 5, 2023 9:42 AM
To:Young, Brianna A<[e-mail]>
Cc: Kobus de Wet<[e-mail]>;Angelica Martinez-Valdez<[e-mail]>; Kaitlyn
Sampson<[e-mail]>; Kaley R. Stanley<[e-mail]>
Subject: [External] RE: Befesa Zinc Metal, LLC facility stormwater permit NCS000562
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Good morning Brianna,
I appreciate your prompt communication and the detailed list of requirements for the renewal of our stormwater
permit. Attached you will find following/requested documents for your review and verification:
6

File 1: NPDES NCG500000(NCG500667, Non-Contact Cooling Water, Boiler Blowdown, etc.)
File 2: BZM Site Map/Drain Configuration
File 3: List of Chemicals (Tier 11)
File 4: Industrial Activity (Per Area)— Refer to page 13, hyperlinked in the table of contents on page 3.
File 5: Stormwater Database (PDF)
File 6: Stormwater Database (Excel)
In response to your specific requests:
Response 1: Regarding the status of rerouting discharges, our team is actively exploring the feasibility of redirecting all
discharges from our sedimentation pond back into the manufacturing process.The aim is to transition towards
becoming a zero-discharge facility.
Response 2: 1 have noted an administrative change that needs to be addressed. Specifically, on EPA Form 3510-1,the
personnel information may need a change.Jan, who was previously designated, is no longer with the company. I have
assumed the role of the appropriate facility contact. All technical details in the application remain accurate.
Response 3:There have been notable operational enhancements. We have utilized GIS mapping to enhance our
understanding of site characteristics.Additionally, our BMP processes have been refined to target key areas contributing
to Tier 3 status.
Furthermore, I can confirm that all information in the stormwater summary report has been reviewed and updated to
reflect our current operational status. Should you require any further clarification or additional details, please do not
hesitate to contact me. We look forward to your feedback and appreciate your efforts in facilitating this permit renewal
process.
Respectfully,
BEFESA
William White I EHS Manager—Befesa Zinc Metal
484 Hicks Grove Road,Mooresboro,North Carolina 28114
Work: [phone] I Cell: [phone]
William.whiteLwbefesa.com
------------------------------------------------
Do you have environmental concerns from the plant?
Want to give feedback to your BZM Environmental Department?
Use the below QR and take our survey!
0 0
r• r
From:Young, Brianna A<[e-mail]>
Sent:Tuesday, October 3, 2023 2:31 PM
To: Kobus de Wet<[e-mail]>
Cc:Jan Nedbal <[e-mail]>; William N. White<[e-mail]>
Subject: Befesa Zinc Metal, LLC facility stormwater permit NCS000562
Good afternoon,

I am working on renewing the individual stormwater permit for the Befesa Zinc Metal, LLC facility
(NCS000562). I need additional information in order to 1) confirm that the information I have is correct and 2)
make sure the permit adequately serves the needs of the facility. Please provide the following:
• Provide documentation of DEQ approval to discharge non-contact cooling water and air compressor
condensate through stormwater outfalls;
• Provide an update on the status of rerouting the above discharges back into the process;
• Provide an updated site map (the one provided with the application is not clear to read);
• Description of chemicals stored onsite;
• Description of industrial activity in each drainage area;
• An electronic spreadsheet summarizing all of the monitoring data that has been collected since the
effective date of the current permit;
• Verification that the information in the renewal application is still complete and correct; and
• An explanation of any operational changes since the renewal application was submitted.
Enter your stormwater permit number into the Stormwater Permit Summary Report and you will see a form that
includes the address of the facility, contact information for the permit, and the regulated stormwater outfall(s)
for the facility. Please review the facility information to make sure it is correct. Information can be updated
using the links provided below, where applicable:
• Facility/Company name or ownership: Name/Ownership Change. Form
• Owner Affiliation (Legally responsible person; i.e., someone with the company who is designated to
represent the company per signatory requirements or another authorized representative): Permit Contact
Update Request Form
• Delegation of Signature Authority (DOSA): Permit Contact Update Request Form
• Billing contact: Permit Contact Update Request Form
• Permit contact: Permit Contact Update Request Form
• Facility contact: Permit Contact Update Request Form
• Facility address only: Email Bethany og ulias
• Stormwater outfall information: Email Bethany Georgoulias
• Visit the eDMR Six Steps website and complete Steps 1 and 2
• Pay outstanding permit fees: Stormwater ePUment website
Once I have the above listed information, I can continue my review. You will receive a draft permit for a 30-day
comment period. During this time we will be able to address any comments or concerns you have. During the
same 30-day period, the draft will be sent to a Regional Office staff member for review as well as out to public
notice. Once all comments and concerns are addressed, you may be issued a final permit.
Please contact me if you have any questions.
Thank you,
Brianna Young, MS (she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/ Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred) PLEASE NOTE NEW EMAIL ADDRESS
919-707-3647(office)
8

Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
small correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.
Befesa complies with the regulations on personal data protection.Please,check our Privacy Policy
*******Internet Email Confidentiality footer*****
This email and any files transmitted with it are confidential and intended solely for the use of the organization or individual to whom they are addressed.It is expressly forbidden to retransmit or copy email
and/or this attached files without our permission.If you are not the addressee indicated in this message(or responsible for delivery of the message to such person),you may not copy or deliver this
message to anyone.In such case,you should destroy this message and kindly notify the sender by reply email.Please advise immediately if you or your employer does not consent to Internet email for
messages of this kind.Opinions,conclusions and other information in this message that do not relate to the official business of my firm shall be understood as neither given nor endorsed by it.
Befesa complies with the regulations on personal data protection.Please,check our Privacy Policy
*******Internet Email Confidentiality footer*****
This email and any files transmitted with it are confidential and intended solely for the use of the organization or individual to whom they are addressed.It is expressly forbidden to retransmit or copy email
and/or this attached files without our permission.If you are not the addressee indicated in this message(or responsible for delivery of the message to such person),you may not copy or deliver this
message to anyone.In such case,you should destroy this message and kindly notify the sender by reply email.Please advise immediately if you or your employer does not consent to Internet email for
messages of this kind.Opinions,conclusions and other information in this message that do not relate to the official business of my firm shall be understood as neither given nor endorsed by it.
Befesa complies with the regulations on personal data protection.Please,check our Privacy Policy
*******Internet Email Confidentiality footer*****
This email and any files transmitted with it are confidential and intended solely for the use of the organization or individual to whom they are addressed.It is expressly forbidden to retransmit or copy email
and/or this attached files without our permission.If you are not the addressee indicated in this message(or responsible for delivery of the message to such person),you may not copy or deliver this
message to anyone.In such case,you should destroy this message and kindly notify the sender by reply email.Please advise immediately if you or your employer does not consent to Internet email for
messages of this kind.Opinions,conclusions and other information in this message that do not relate to the official business of my firm shall be understood as neither given nor endorsed by it.
Befesa complies with the regulations on personal data protection.Please,check our Privacy Policy
*******Internet Email Confidentiality footer*****
This email and any files transmitted with it are confidential and intended solely for the use of the organization or individual to whom they are addressed.It is expressly forbidden to retransmit or copy email
and/or this attached files without our permission.If you are not the addressee indicated in this message(or responsible for delivery of the message to such person),you may not copy or deliver this
message to anyone.In such case,you should destroy this message and kindly notify the sender by reply email.Please advise immediately if you or your employer does not consent to Internet email for
messages of this kind.Opinions,conclusions and other information in this message that do not relate to the official business of my firm shall be understood as neither given nor endorsed by it.
9

Young, Brianna A
From: William N.White <[e-mail]>
Sent: Wednesday, October 18, 2023 7:36 AM
To: Young, Brianna A
Cc: Kobus de Wet; Angelica Martinez-Valdes; Kaitlyn Sampson; Kaley R. Stanley
Subject: RE: [External] RE: Befesa Zinc Metal, LLC facility stormwater permit NCS000562
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Good morning Brianna,
I appreciate you taking the time to review our records and for reaching out to us regarding these questions. Below are
my responses to your inquiries as outlined in your email.
Documentation of DEQ Approvals:
I acknowledge your request for copies of the emails dated 12/13/2018 and 3/25/2019, as referenced in our NPDES
package. However,these specific emails are not currently in our records. I want to emphasize that the issuance of the
NCG permit does signify the approval of these discharges. Could you kindly confirm whether DEQ has these approval
emails on file? If so, we would greatly appreciate it if you could share them with us for proper filing. If not, please let me
know, and I will re-submit the request to your team.
Sampling Data Accuracy:
I understand your concern regarding the presentation of sampling data.The headers indicating "sum of xxx" in the
provided information do represent the individual sampling events, not aggregated values(excel automatically does this
when creating a pivot table). I apologize for any confusion caused and can assist you further if you require additional
clarification or specific data.
Pond Discharge Locations:
• West Stormwater Pond: No discharge; water is pumped back into our process.
• West Maintenance Pond: No discharge; it is connected to the West Stormwater Pond for overflow protection.
• West Raffinate Pond: No discharge; water is pumped back into our process.
• West Depleted Solution Pond: No discharge; water is pumped back into our process.
• East Effluent Pond: Discharged under wastewater permit.
• East Stormwater Pond: No discharge; water is pumped back into the process.
• Basin 1: Stormwater Sedimentation Pond, discharges to the Broad River(SDO#1).
Potential Pollutants in Stormwater Discharges:
Excluding Chronic Toxicity,these constituents could potentially be present in stormwater due to runoff and overland
flow throughout the site. However, it is important to note that most, if not all, of these constituents are likely below
detection limits in our stormwater discharges. We would be happy to confirm if necessary.
Please feel free to reach out if you require any additional information or if there are further questions.Thanks Brianna!
Respectfully,
BEFESA
William White I EHS Manager—Befesa Zinc Metal
484 Hicks Grove Road,Mooresboro,North Carolina 28114
1

Work: [phone] I Cell: [phone]
William.whitekbefesa.com
------------------------------------------------
Do you have environmental concerns from the plant?
Want to give feedback to your BZM Environmental Department?
Use the below QR and take our survey!
0 0
0.
From:Young, Brianna A<[e-mail]>
Sent:Tuesday, October 17, 2023 2:58 PM
To: William N. White<[e-mail]>
Cc: Kobus de Wet<[e-mail]>; Angelica Martinez-Valdes<[e-mail]>; Kaitlyn
Sampson<[e-mail]>; Kaley R. Stanley<[e-mail]>
Subject: RE: [External] RE: Befesa Zinc Metal, LLC facility stormwater permit NCS000562
Good afternoon,
After reviewing all the submitted information, I have a few follow-up questions.
1. My previous information request asked that documentation be provided of DEQ approving discharge of non-
contact cooling water and air compressor condensate through stormwater outfalls. The response to the
information request included COC NCG500667. Per the permit renewal application,there are emails from
12/13/2018 and 3/25/2019 allowing these discharges. Please provide copies of these emails.
2. Your response to the information request included sampling data, however,the data appears to have summed
values of each parameter for each month, rather than results from each sampling event. Please provide the
results for individual sampling points (not the sum for each month)for August 2022 to the most recent sampling
event.
3. Information in the permit file history indicates there are 4 ponds onsite: Storm Pond, West Maintenance Pond,
Raffinate Pond, and Depleted Solution Pond.The information indicates discharges from the maintenance,
raffinate, and solution ponds go back into the process, and water from the storm pond is discharged with a
wastewater permit. Can you confirm the location of discharge for each pond?
4. Information in the permit file history indicates there are additional potential pollutants onsite related to
industrial processes. Please confirm if any of these pollutants are or could be present in stormwater discharges:
NH3-N,Total Aluminum,Antimony, Arsenic,Total Chromium,Total Cobalt,Total Copper, Fluoride,Total Iron,
Total Nickel,Total Tin,Total Silver, Chronic Toxicity, and Turbidity.
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
2

[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
From:Young, Brianna A
Sent:Thursday, October 5, 2023 11:45 AM
To: William N. White<[e-mail]>
Cc: Kobus de Wet<[e-mail]>;Angelica Martinez-Valdez<[e-mail]>; Kaitlyn
Sampson<[e-mail]>; Kaley R. Stanley<[e-mail]>
Subject: RE: [External] RE: Befesa Zinc Metal, LLC facility stormwater permit NCS000562
Good morning,
Thank you for providing this information. I will reach out with any additional questions once I've had a chance to review
everything.
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
From: William N. White<[e-mail]>
Sent:Thursday, October 5, 2023 9:42 AM
To:Young, Brianna A<[e-mail]>
Cc: Kobus de Wet<[e-mail]>;Angelica Martinez-Valdez<[e-mail]>; Kaitlyn
Sampson<[e-mail]>; Kaley R. Stanley<[e-mail]>
Subject: [External] RE: Befesa Zinc Metal, LLC facility stormwater permit NCS000562
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
3

Good morning Brianna,
I appreciate your prompt communication and the detailed list of requirements for the renewal of our stormwater
permit. Attached you will find following/requested documents for your review and verification:
File 1: NPDES NCG500000(NCG500667, Non-Contact Cooling Water, Boiler Blowdown, etc.)
File 2: BZM Site Map/Drain Configuration
File 3: List of Chemicals (Tier 11)
File 4: Industrial Activity (Per Area)—Refer to page 13, hyperlinked in the table of contents on page 3.
File 5: Stormwater Database (PDF)
File 6: Stormwater Database (Excel)
In response to your specific requests:
Response 1: Regarding the status of rerouting discharges, our team is actively exploring the feasibility of redirecting all
discharges from our sedimentation pond back into the manufacturing process.The aim is to transition towards
becoming a zero-discharge facility.
Response 2: 1 have noted an administrative change that needs to be addressed. Specifically, on EPA Form 3510-1,the
personnel information may need a change.Jan, who was previously designated, is no longer with the company. I have
assumed the role of the appropriate facility contact. All technical details in the application remain accurate.
Response 3:There have been notable operational enhancements. We have utilized GIS mapping to enhance our
understanding of site characteristics.Additionally, our BMP processes have been refined to target key areas contributing
to Tier 3 status.
Furthermore, I can confirm that all information in the stormwater summary report has been reviewed and updated to
reflect our current operational status. Should you require any further clarification or additional details, please do not
hesitate to contact me. We look forward to your feedback and appreciate your efforts in facilitating this permit renewal
process.
Respectfully,
BEFESA
William White I EHS Manager—Befesa Zinc Metal
484 Hicks Grove Road,Mooresboro,North Carolina 28114
Work: [phone] I Cell: [phone]
William.whiteLcvbefesa.com
------------------------------------------------
Do you have environmental concerns from the plant?
Want to give feedback to your BZM Environmental Department?
Use the below QR and take our survey!
0 0
0.
From:Young, Brianna A<[e-mail]>
Sent:Tuesday, October 3, 2023 2:31 PM
To: Kobus de Wet<[e-mail]>
4

Cc:Jan Nedbal <[e-mail]>; William N. White <[e-mail]>
Subject: Befesa Zinc Metal, LLC facility stormwater permit NCS000562
Good afternoon,
I am working on renewing the individual stormwater permit for the Befesa Zinc Metal, LLC facility
(NCS000562). I need additional information in order to 1) confirm that the information I have is correct and 2)
make sure the permit adequately serves the needs of the facility. Please provide the following:
• Provide documentation of DEQ approval to discharge non-contact cooling water and air compressor
condensate through stormwater outfalls;
• Provide an update on the status of rerouting the above discharges back into the process;
• Provide an updated site map (the one provided with the application is not clear to read);
• Description of chemicals stored onsite;
• Description of industrial activity in each drainage area;
• An electronic spreadsheet summarizing all of the monitoring data that has been collected since the
effective date of the current permit;
• Verification that the information in the renewal application is still complete and correct; and
• An explanation of any operational changes since the renewal application was submitted.
Enter your stormwater permit number into the Stormwater Permit Summary Report and you will see a form that
includes the address of the facility, contact information for the permit, and the regulated stormwater outfall(s)
for the facility. Please review the facility information to make sure it is correct. Information can be updated
using the links provided below, where applicable:
• Facility/Company name or ownership: Name/Ownership Change. Form
• Owner Affiliation (Legally responsible person; i.e., someone with the company who is designated to
represent the company per signatory requirements or another authorized representative): Permit Contact
Update Request Form
• Delegation of Signature Authority (DOSA): Permit Contact Update Request Form
• Billing contact: Permit Contact Update Request Form
• Permit contact: Permit Contact Update Request Form
• Facility contact: Permit Contact Update Request Form
• Facility address only: Email Bethany og ulias
• Stormwater outfall information: Email Bethany Georgoulias
• Visit the eDMR Six Steps website and complete Steps 1 and 2
• Pay outstanding permit fees: Stormwater ePayment website
Once I have the above listed information, I can continue my review. You will receive a draft permit for a 30-day
comment period. During this time we will be able to address any comments or concerns you have. During the
same 30-day period, the draft will be sent to a Regional Office staff member for review as well as out to public
notice. Once all comments and concerns are addressed,you may be issued a final permit.
Please contact me if you have any questions.
Thank you,
Brianna Young, MS (she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
5

NC DEQ/ Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred) PLEASE NOTE NEW EMAIL ADDRESS
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, INC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.
Befesa complies with the regulations on personal data protection.Please,check our Privacy Policy
*******Internet Email Confidentiality footer*****
This email and any files transmitted with it are confidential and intended solely for the use of the organization or individual to whom they are addressed.It is expressly forbidden to retransmit or copy email
and/or this attached files without our permission.If you are not the addressee indicated in this message(or responsible for delivery of the message to such person),you may not copy or deliver this
message to anyone.In such case,you should destroy this message and kindly notify the sender by reply email.Please advise immediately if you or your employer does not consent to Internet email for
messages of this kind.Opinions,conclusions and other information in this message that do not relate to the official business of my firm shall be understood as neither given nor endorsed by it.
Befesa complies with the regulations on personal data protection.Please,check our Privacy Policy
*******Internet Email Confidentiality footer*****
This email and any files transmitted with it are confidential and intended solely for the use of the organization or individual to whom they are addressed.It is expressly forbidden to retransmit or copy email
and/or this attached files without our permission.If you are not the addressee indicated in this message(or responsible for delivery of the message to such person),you may not copy or deliver this
message to anyone.In such rase,you should destroy this message and kindly notify the sender by reply email.Please advise immediately if you or your employer does not consent to Internet email for
messages of this kind.Opinions,conclusions and other information in this message that do not relate to the official business of my firm shall be understood as neither given nor endorsed by it.
6

Young, Brianna A
From: William N.White <[e-mail]>
Sent: Thursday, October 5, 2023 9:42 AM
To: Young, Brianna A
Cc: Kobus de Wet; Angelica Martinez-Valdez; Kaitlyn Sampson; Kaley R. Stanley
Subject: [External] RE: Befesa Zinc Metal, LLC facility stormwater permit NCS000562
Attachments: File 1 - NPDES NCG500000 (NCG500667).pdf, File 2 - BZM Site Map & Drain
Configuration.pdf, File 3 - List of Chemicals.pdf, File 4 - Industrial Activities (Per
Area).pdf, File 5 - Stormwater Database Information (PDF).pdf; File 6 - Electronic
Stomwater Database (Excel).xlsx
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Good morning Brianna,
I appreciate your prompt communication and the detailed list of requirements for the renewal of our stormwater
permit. Attached you will find following/requested documents for your review and verification:
File 1: NPDES NCG500000(NCG500667, Non-Contact Cooling Water, Boiler Blowdown, etc.)
File 2: BZM Site Map/Drain Configuration
File 3: List of Chemicals (Tier 11)
File 4: Industrial Activity (Per Area)—Refer to page 13, hyperlinked in the table of contents on page 3.
File 5: Stormwater Database (PDF)
File 6: Stormwater Database (Excel)
In response to your specific requests:
Response 1: Regarding the status of rerouting discharges, our team is actively exploring the feasibility of redirecting all
discharges from our sedimentation pond back into the manufacturing process.The aim is to transition towards
becoming a zero-discharge facility.
Response 2: 1 have noted an administrative change that needs to be addressed. Specifically, on EPA Form 3510-1,the
personnel information may need a change.Jan, who was previously designated, is no longer with the company. I have
assumed the role of the appropriate facility contact. All technical details in the application remain accurate.
Response 3:There have been notable operational enhancements. We have utilized GIS mapping to enhance our
understanding of site characteristics.Additionally, our BMP processes have been refined to target key areas contributing
to Tier 3 status.
Furthermore, I can confirm that all information in the stormwater summary report has been reviewed and updated to
reflect our current operational status. Should you require any further clarification or additional details, please do not
hesitate to contact me. We look forward to your feedback and appreciate your efforts in facilitating this permit renewal
process.
Respectfully,
BEFESA
William White I EHS Manager—Befesa Zinc Metal
1

484 Hicks Grove Road,Mooresboro,North Carolina 28114
Work: [phone] 1 Cell: [phone]
W illiam.white(&befesa.com
------------------------------------------------
Do you have environmental concerns from the plant?
Want to give feedback to your BZM Environmental Department?
Use the below QR and take our survey!
0: f0
r
a. .
From: Young, Brianna A<[e-mail]>
Sent:Tuesday, October 3, 2023 2:31 PM
To: Kobus de Wet<[e-mail]>
Cc:Jan Nedbal <[e-mail]>; William N. White<[e-mail]>
Subject: Befesa Zinc Metal, LLC facility stormwater permit NCS000562
Good afternoon,
I am working on renewing the individual stormwater permit for the Befesa Zinc Metal, LLC facility
(NCS000562). I need additional information in order to 1) confirm that the information I have is correct and 2)
make sure the permit adequately serves the needs of the facility. Please provide the following:
• Provide documentation of DEQ approval to discharge non-contact cooling water and air compressor
condensate through stormwater outfalls;
• Provide an update on the status of rerouting the above discharges back into the process;
• Provide an updated site map (the one provided with the application is not clear to read);
• Description of chemicals stored onsite;
• Description of industrial activity in each drainage area;
• An electronic spreadsheet summarizing all of the monitoring data that has been collected since the
effective date of the current permit;
• Verification that the information in the renewal application is still complete and correct; and
• An explanation of any operational changes since the renewal application was submitted.
Enter your stormwater permit number into the Stormwater Permit Summary Report and you will see a form that
includes the address of the facility, contact information for the permit, and the regulated stormwater outfall(s)
for the facility. Please review the facility information to make sure it is correct. Information can be updated
using the links provided below, where applicable:
• Facility/Company name or ownership: Name/Ownership Change Form
• Owner Affiliation(Legally responsible person; i.e., someone with the company who is designated to
represent the company per signatory requirements or another authorized representative): Permit Contact
Update Request Form
• Delegation of Signature Authority (DOSA): Permit Contact Update Request Form
• Billing contact: Permit Contact Update Request Form
• Permit contact: Permit Contact Update Request Form
• Facility contact: Permit Contact Update Request Form
• Facility address only: Email Bethany og ulias
2

• Stormwater outfall information: Email Bethany og ulias
• Visit the eDMR Six Steps website and complete Steps 1 and 2
• Pay outstanding permit fees: Stormwater ePayment website
Once I have the above listed information, I can continue my review. You will receive a draft permit for a 30-day
comment period. During this time we will be able to address any comments or concerns you have. During the
same 30-day period, the draft will be sent to a Regional Office staff member for review as well as out to public
notice. Once all comments and concerns are addressed, you may be issued a final permit.
Please contact me if you have any questions.
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.
Befesa complies with the regulations on personal data protection.Please,check our Privacy Policy
*******Internet Email Confidentiality Tooter*****
This email and any files transmitted with it are confidential and intended solely for the use of the organization or individual to whom they are addressed.It is expressly forbidden to retransmit or copy email
and/or this attached files without our permission.If you are not the addressee indicated in this message(or responsible for delivery of the message to such person),you may not copy or deliver this
message to anyone.In such case,you should destroy this message and kindly notify the sender by reply email.Please advise immediately if you or your employer does not consent to Internet email for
messages of this kind.Opinions,conclusions and other information in this message that do not relate to the official business of my firm shall be understood as neither given nor endorsed by it.
3

oF.Me STATE o011�
ROY COOPER
Governor
MICHAEL S.REGAN
Secretary *4s`�^^0"'
S.DANIEL SMITH NORTH CAROLINA
Director Environmental Quality
1/6/2021
Mr. Charles Howell
American Zinc Products LLC
484 Hicks Grove Rd
Mooresboro, NC 28114
Subject: Renewal of General Permit NCG500000
American Zinc Products, LLC
Certificate of Coverage NCG500667
Rutherford County
Dear Permittee:
The Division has renewed General Permit NCG500000. We hereby reissue Certificate of Coverage
(CoC) NCG500667 under General Permit NCG500000. It is issued pursuant to the requirements of North
Carolina General Statue 143-215.1 and the Memorandum of Agreement between North Carolina and the US
Environmental Protection agency dated October 15, 2007 [or as subsequently amended].
If any parts, measurement frequencies or sampling requirements contained in this General Permit
are unacceptable to you, you have the right to request an individual permit by submitting an individual
permit application. Unless such demand is made, the certificate of coverage shall be final and binding.
Please take notice that this Certificate of Coverage is not transferable except after notice to the
Division. The Division may require modification or revocation and reissuance of the certificate of coverage.
Contact the Asheville Regional Office prior to any sale or transfer of the permitted facility.
Regional Office staff will assist you in documenting the transfer of this CoC.
This permit does not affect the legal requirements to obtain any other State, Federal, or Local
governmental permit that may be required. If you have any questions concerning the requirements of the
General Permit, please contact John Hennessy [[e-mail]] or Sydney Carpenter
[[e-mail]].
Sincerely,
for S. Daniel Smith, Director
Division of Water Resources
cc: NPDES file
DE Q�� North Carolina Department of Environmental Quality I Division of Water Resources
_ 512 North Salisbury Street 1 1617 Mail Service Center I Raleigh,North Carolina 27699-1617
NORTH C aROLINA
Department f Environmental Quality /`� 919.707.9000

Technical Bulletin
For General Permit NCG500000
NORTH CAROLINA DIVISION OF WATER RESOURCES
Revised November 13,2020
The NPDES permitting proaram's objective is to • Any exceedances of the permit limits must be
reduce the pollutant load entering the waters of the reported to the Division within 24 hours from the
state by: time the permittee becomes aware of the
circumstances. (Part II, Section E:6)
1. Educating the permitted community about
wastewater and stormwater pollutants,
2. Encouraging the use of Best Management Practices Coverage Under This Permit
(BMPs)to minimize the entry of pollutants into the
waters of the state via wastewater and stormwater This permit covers the following types of discharges:
discharges,and
3. Using collected analytical data to assess these • Non-contact cooling water and water used in
discharges contribution to water pollution to help industrial processes for the sole purpose of cooling
prioritize controls in problem areas. machinery and other equipment. Contact cooling
water discharges require an individual NPDES
permit. Non-contact cooling water is defined as
Changes in Reissued General Permit water used for cooling which does not come into
direct contact with any raw material,intermediate
Several important changes from the previous version of product,waste product or finished product.
this permit are: • Condensate wastewater from atmospheric cooling
systems(air conditioners,etc.)
• Effluent limitations and monitoring requirements for • Blowdown wastewaters. Blowdown is defined as
air compressor condensate and similar wastewaters the minimum discharge of recirculating water for
have been removed from Part I,Section B. (L)and the purpose of discharging materials contained in
included in a new table,found in Part 1, Section B. the water,the further buildup of which would cause
(2•)• concentration in amounts exceeding limits
• Part 1,Section C.has been added to further clarify established by best engineering practice.
reporting requirements. • Exempt stormwater,which is defined as discharges
• Part I,Section D.has been added to further clarify of stormwater which do not require permits under
the role of ORCs for non-classified facilities covered the state or Federal NPDES programs. Exempt
under this general permit. stormwater includes stormwater which accumulates
• Additional language has been added to Part I, Section in outdoor basins or ponds designed for cooling
E:4 to further clarify sampling requirements. water or other waters covered by this permit.
• Additional language has been added to Part 1, Section • Water associated with hydroelectric power facilities,
A.to specify which dischargers are ineligible for including cooling waters,waters from sumps and
coverage. drains,dam seepage and exempt stormwater.
• Other similar wastewaters which may qualify for
coverage under this General Permit.
Key Permit Requirements
Facilities that qualify as a Major discharger,as classified
• Semi-annual or quarterly effluent monitoring of by the EPA,are ineligible for coverage under this General
parameters specified in Part I,Section B. Permit.
• All samples should be collected before the effluent
joins or is diluted by any other wastestream,water or
substance. (Part I, Section B.1,2,&3,Part Il, Other sources of information on North Carolina's
Section D:1) NPDES General Permits Program
• The permittee shall give notice to the Division of any
planned physical alterations or additions to the The Division of Water Resources website is can be found
system that could significantly increase the quantity at hltps:Hdeq.nc.gov/about/divisions/water-resources.
of pollutants discharged or introduce new pollutants
to the discharge. (Part Il, Section E:3)

Frequently Asked Questions
1) Do I need to submit the monitoring results
annually?
No. The submission of monitoring reports for this
permit is not required. There are no standardized
Discharge Monitoring Reports (DMRs) associated
with this permit. All monitoring results should be kept
on site for three years.The Division may request these
reports for review at any time.(Part II,Section E:1)
2) Do I need to employ a certified wastewater
treatment plant operator to manage and run the
system?
Not at this time.The Division's Operator Training and
Certification Unit does not currently plan to classify
these types of facilities for the purposes of needing a
certified operator. The requirement was left in the
permit at this time with clarification, in the event that
classification was assigned in the future. (Part II,
Section C:1)
3) Where do I find my stream classification?
The stream classification,i.e.WS-IV,C,Tr,etc.can
usually be found in the Certificate of Coverage or the
Division's Website at:
https:Hdeq.nc.Gov/about/divisions/water-
resources/planning/classification-
standards/classifications
4) Does a certified lab need to be used to analyze
samples?
Yes,a North Carolina certified lab must be used to
perform analytical monitoring.The only exception to
this rule is when measuring the value of pH.pH
values should be measured in the field because they
may change considerably between when the sample
is taken,and it is analyzed at the laboratory.A list of
certified labs is available from the Division.
5) What if I sell my business or the name of my
business changes?
The Division views changes of name or ownership as
a minor modification and requires the Director's
approval.Name and ownership changes require you
to complete a Name/Ownership Change Form.The
forms are available on our web site:
https:Hdeq.nc.aov/about/divisions/water-
resources/water-quality_permittina/npdes-
wastewater/npdes-compliance-and-0
6) When does my permit expire and how do I renew
it?
The expiration date of the permit is on the first page
of the General Permit.This General Permit expires
on November 30,2025.

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
GENERAL PERMIT NCG500000
CERTIFICATE OF COVERAGE NCG500667
DISCHARGE OF NON-CONTACT COOLING WATER, COOLING TOWER AND BOILER
BLOWDOWN, CONDENSATE, EXEMPT STORMWATER, COOLING WATERS ASSOCIATED
WITH HYDROELECTRIC OPERATIONS, AND SIMILAR WASTEWATERS 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 from a facility located at the
American Zinc Products, LLC
484 Hicks Grove Rd
Mooresboro
Rutherford County
to receiving waters designated as directly to the BROAD RIVER, a class C stream in subbasin 03-
08-02 of the Broad River Basin in accordance with the effluent limitations, monitoring
requirements, and other conditions set forth in Parts I, II, and III hereof.
This certificate of coverage takes effect 1/6/2021.
This Certificate of Coverage shall remain valid for the duration of the General Permit.
Signed this day 1/6/2021
for S. Daniel Smith, Director
Division of Water Resources
By Authority of the Environmental Management Commission

DocuSign Envelope ID:A5A31D1C-527B-48C6-A13E-AE070AC8CF23
NPDES General Permit NCG500000
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
GENERAL PERMIT NCG500000
TO DISCHARGE NON-CONTACT COOLING WATER, COOLING TOWER AND BOILER
BLOWDOWN, CONDENSATE, EXEMPT STORMWATER, COOLING WATERS
ASSOCIATED WITH HYDROELECTRIC OPERATIONS, AND SIMILIAR
WASTEWATERS 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,this permit is hereby issued to all owners or operators,
hereafter permittees,which are covered by this permit as evidenced by receipt of a Certificate of Coverage
(CoC) from the Environmental Management Commission to allow the discharge of wastewater in
accordance with the effluent limitations,monitoring requirements, and other conditions set forth in Parts I,
11, and III hereof.
This permit shall become effective December 1, 2020.
This permit shall expire at midnight on November 30,2025.
Signed this day
Docu Signed by:
^, f Pbuf� 12/7/2020
RFR99Rfia9DD9d7R
S. Daniel Smith,Director
Division of Water Resources
By Authority of the Environmental Management Commission
Page 1 of 23

DocuSign Envelope ID:A5A31D1C-527B-48C6-A13E-AE070AC8CF23
General Permit NCG500000
PART I
SECTION A. APPLICABILITY
This permit is applicable to the following types of discharges defined below:
1. Non-contact cooling water and open recirculation cooling water systems used in industrial processes for the
sole purpose of cooling machinery and other equipment. Non-contact cooling water is defined as water used
for cooling which does not come into direct contact with any raw material, intermediate product, waste
product or finished product. Contact cooling water is defined as cooling water that comes into contact with
raw material,intermediate product,finished product,byproduct or waste product.Open recirculating cooling
water systems,continuously reuse the cooling water which passes through the heat transfer equipment. Open
recirculating cooling water system discharges to a Water Supply water body may require an individual
NPDES permit. Contact cooling water discharges require an individual NPDES permit.
2. Condensate wastewater from atmospheric cooling systems.
3. Blowdown wastewaters. Blowdown is defined as the minimum discharge of recirculating water for the
purpose of discharging materials contained in the water, the further buildup of which would cause
concentration in amounts exceeding limits established by best engineering practice.
4. Exempt stormwater, which is defined as discharges of stormwater which do not require permits under the
state or Federal NPDES programs. Exempt stormwater includes stormwater which accumulates in outdoor
basins or ponds designed for cooling water or other waters covered by this permit.
5. Water associated with hydroelectric power facilities,including cooling waters,waters from sumps and drains,
dam seepage and exempt stormwater.
6. Other similar wastewaters which may qualify for coverage under this General Permit.
Facilities are ineligible for coverage under this General Permit if they qualify as a Major discharger, as classified by
the EPA.
SECTION B. (L) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FOR NON-
CONTACT COOLING WATER,COOLING TOWER AND BOILER BLOWDOWN
AND SIMILAR WASTEWATERS
[15A NCAC 02B .0400 et seq., 02B .0500 seq.]
During the period beginning on December 1,2020 and lasting until expiration,the permittee is authorized to
discharge non-contact cooling water, cooling tower and boiler blowdown and similar wastewaters from outfalls
numbered serially beginning with 001 (specific outfall numbers shall be assigned by the permittee). Such
discharges shall be limited and monitored by the permittee as specified below:
PARAMETER LIMITS MONITORING REQUIREMENTS
Monthly Daily Measurement Sample Sample Location
Average Maximum Frequency Type
Flow Semi-annually Estimate Effluent
Temperature' Semi-annually Grab Effluent,Upstream,
Downstream
Total Residual Chlorine' FW: 17.0 µg/L Effluent
SW: 13.0 µg/L Semi-annually Grab
pH3 Semi-annually Grab Effluent
Chemical Oxygen Demand' Semi-annually Grab Effluent
Page 2 of 23

DocuSign Envelope ID:A5A31D1C-527B-48C6-A13E-AE070AC8CF23
General Permit NCG500000
1. Effluent temperature will be regulated so that the temperature of the receiving stream does not increase more
than:
Freshwater classifications: 2.8°C above the natural water temperature
However,the receiving water temperature shall in no case exceed 29°C at the
downstream monitoring location for mountain and upper piedmont waters.
However,the receiving water temperature shall in no case exceed 32°C at the
downstream monitoring location for lower piedmont and coastal plain waters.
Trout water classifications: 0.5°C above the natural water temperature due to discharge of heated liquids
However,the receiving water temperature shall in no case exceed 20°C at the
downstream monitoring location for trout waters.
Saltwater classifications: 0.8°C above the natural water temperature during the months of June, July and
August,and 2.2°C above the natural water temperature during any other months
However,the receiving water temperature shall in no case exceed 32°C at the
downstream monitoring location for saltwater due to the discharge of heated
liquids.
The permittee shall demonstrate compliance with the effluent temperature limitations by monitoring the
temperature of the receiving stream upstream and downstream of the discharge outfall. The Division should be
consulted in selecting location(s)that provide(s) a representative upstream/downstream site. Upstream and
downstream monitoring is not necessary if the discharge is to a receiving stream that does not contain any
flowing water at the time of discharge.
Page 3 of 23

DocuSign Envelope ID:A5A31D1C-527B-48C6-A13E-AE070AC8CF23
General Permit NCG500000
2. Monitoring requirements and limits apply only if chlorine is present in the discharge. Discharges to freshwater
(FW)will be required to meet a daily maximum discharge limitation of 17 µg/L of Total Residual Chlorine
(TRC). Discharges to saltwater(SW)will be required to meet a daily maximum discharge limitation of 13
µg/L of TRC. The Division shall consider all effluent TRC values reported below 50 µg/L to be in compliance
with the permit. However,the Permittee shall continue to record all values reported by a North Carolina
certified laboratory(including field certified), even if these values fall below 50 µg/L.
3. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units for discharges to receiving
streams classified as freshwater.
The pH shall not be less than 6.8 standard units nor greater than 8.5 standard units for discharges to receiving
streams classified as saltwater.
4. Monitoring requirement applies only if water treatment and/or chemical additives, i.e. corrosion inhibitors,
oxygen scavengers,biocides or cleaning solvents, are added to the system.
This permit does not authorize the discharge of water treatment or chemical additives (including but not
limited to chromium,zinc or copper) other than chlorine and approved de-chlorinating reagents without
written approval from the Division.
The permittee shall obtain approval from the Division prior to the use of any chemical additive in the permittee's
systems covered under this permit. To obtain approval the permittee shall notify the Director in writing at least
ninety(90)days prior to instituting use of any new additive(other than additives previously approved by the
Division). Such approval requests shall include a completed Biocide Worksheet Form 101 or equivalent worksheet
form approved by the Division, a copy of the Material Data Safety Sheet(MSDS)for the additive, and a map
indicating the discharge point and receiving stream. Please direct all inquiries to the Aquatic Toxicology Branch.
All non-contact cooling water sample locations shall provide representative samples of the discharge and require
sampling prior to discharge commingling with any other waters or substances, such as stormwater or surface water,
to enable characterization of a pollutant of concern.
All samples collected should be from a representative and a measurable discharge event that results in an actual
discharge from the permitted discharge outfall.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Page 4 of 23

DocuSign Envelope ID:A5A31D1C-527B-48C6-A13E-AE070AC8CF23
General Permit NCG500000
SECTION B. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FOR AIR
COMPRESSOR CONDENSATE AND SIMILAR WASTEWATERS
[15A NCAC 02B .0400 et seq., 02B .0500 seq.]
During the period beginning on December 1, 2020 and lasting until expiration,the permittee is authorized to
discharge air compressor condensate and similar wastewaters from outfalls numbered serially beginning with 001
(specific outfall numbers shall be assigned by the permittee). Such discharges shall be limited and monitored by
the permittee as specified below:
PARAMETER LIMITS MONITORING REQUIREMENTS
Monthly Daily Measurement Sample Sample Location
Average Maximum Frequency Type
Flow Semi-annually Estimate Effluent
Temperature' Semi-annually Grab Effluent,Upstream,
Downstream
Total Residual Chlorine' FW: 17.0 µg/L Effluent
SW: 13.0 µg/L Semi-annually Grab
Oil and Grease 15.0 mg/L 20.0 mg/L Semi-annually Grab Effluent
pH3 Semi-annually Grab Effluent
Chemical Oxygen Demand' Semi-annually Grab Effluent
1. Effluent temperature will be regulated so that the temperature of the receiving stream does not increase more
than:
Freshwater classifications: 2.8°C above the natural water temperature
However,the receiving water temperature shall in no case exceed 29°C at the
downstream monitoring location for mountain and upper piedmont waters.
However,the receiving water temperature shall in no case exceed 320C at the
downstream monitoring location for lower piedmont and coastal plain waters.
Trout water classifications: 0.5°C above the natural water temperature due to discharge of heated liquids
However,the receiving water temperature shall in no case exceed 200C at the
downstream monitoring location for trout waters.
Saltwater classifications: 0.8°C above the natural water temperature during the months of June, July and
August,and 2.2°C above the natural water temperature during any other months
However,the receiving water temperature shall in no case exceed 32°C at the
downstream monitoring location for saltwater due to the discharge of heated
liquids.
The permittee shall demonstrate compliance with the effluent temperature limitations by monitoring the
temperature of the receiving stream upstream and downstream of the discharge outfall. The Division should be
consulted in selecting location(s)that provide(s) a representative upstream/downstream site. Upstream and
downstream monitoring is not necessary if the discharge is to a receiving stream that does not contain any
flowing water at the time of discharge.
Page 5 of 23

DocuSign Envelope ID:A5A31D1C-527B-48C6-A13E-AE070AC8CF23
General Permit NCG500000
2. Monitoring requirements and limits apply only if chlorine is present in the discharge. Discharges to freshwater
(FW)will be required to meet a daily maximum discharge limitation of 17 µg/L of Total Residual Chlorine
(TRC). Discharges to saltwater(SW)will be required to meet a daily maximum discharge limitation of 13
µg/L of TRC. The Division shall consider all effluent TRC values reported below 50 µg/L to be in compliance
with the permit. However,the Permittee shall continue to record all values reported by a North Carolina
certified laboratory(including field certified), even if these values fall below 50 µg/L.
3. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units for discharges to receiving
streams classified as freshwater.
The pH shall not be less than 6.8 standard units nor greater than 8.5 standard units for discharges to receiving
streams classified as saltwater.
4. Monitoring requirement applies only if water treatment and/or chemical additives, i.e. corrosion inhibitors,
oxygen scavengers,biocides or cleaning solvents, are added to the system.
This permit does not authorize the discharge of water treatment or chemical additives(including but not
limited to chromium,zinc or copper)other than chlorine and approved de-chlorinating reagents without
written approval from the Division.
The permittee shall obtain approval from the Division prior to the use of any chemical additive in the permittee's
systems covered under this permit. To obtain approval the permittee shall notify the Director in writing at least
ninety(90)days prior to instituting use of any new additive (other than additives previously approved by the
Division). Such approval requests shall include a completed Biocide Worksheet Form 101 or equivalent worksheet
form approved by the Division, a copy of the Material Data Safety Sheet(MSDS)for the additive, and a map
indicating the discharge point and receiving stream. Please direct all inquiries to the Aquatic Toxicology Branch.
All sample locations shall provide representative samples of the discharge and require sampling prior to discharge
commingling with any other waters or substances, such as stormwater or surface water,to enable characterization of
a pollutant of concern.
All samples collected should be from a representative and a measurable discharge event that results in an actual
discharge from the permitted discharge outfall.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Page 6 of 23

DocuSign Envelope ID:A5A31D1C-527B-48C6-A13E-AE070AC8CF23
General Permit NCG500000
SECTION B. (3.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FOR
HYDROELECTRIC FACILITIES—ONCE-THROUGH COOLING WATER AND
SIMILAR WASTEWATERS
[15A NCAC 02B .0400 et seq., 02B .0500 seq.]
During the period beginning on December 1,2020 and lasting until expiration,the permittee is authorized to discharge
once-through cooling waters(including generator cooling water,generator thrust bearing cooling water,turbine guide
cooling water & transformer cooling water) and other similar waters associated with hydroelectric facilities from
outfalls numbered serially beginning with 001 (specific outfall numbers shall be assigned by the permittee). Such
discharges shall be limited and monitored by the permittee as specified below:
PARAMETER LIMITS MONITORING REQUIREMENTS
Monthly Daily Measurement Sample Sample Location
Average Maximum Frequency Type
Flow Semi-annually Estimate Effluent
Temperature' Semi-annually Grab Effluent,Upstream,
Downstream
Total Residual Chlorine' FW: 17.0 µg/L Effluent
SW: 13.0 µg/L Semi-annually Grab
pH3 Semi-annually Grab Effluent
Chemical Oxygen Demand'
Semi-annually Grab Effluent
1. Effluent temperature will be regulated so that the temperature of the receiving stream does not increase more
than:
Freshwater classifications: 2.8°C above the natural water temperature
However,the receiving water temperature shall in no case exceed 29°C at the
downstream monitoring location for mountain and upper piedmont waters.
However,the receiving water temperature shall in no case exceed 32°C at the
downstream monitoring location for lower piedmont and coastal plain waters.
Trout water classifications: 0.5°C above the natural water temperature due to discharge of heated liquids
However,the receiving water temperature shall in no case exceed 20°C at the
downstream monitoring location for trout waters.
Saltwater classifications: 0.8°C above the natural water temperature during the months of June, July and
August,and 2.2°C above the natural water temperature during any other months
However,the receiving water temperature shall in no case exceed 320C at the
downstream monitoring location for saltwater due to the discharge of heated
liquids.
The permittee shall demonstrate compliance with the effluent temperature limitations by monitoring the
temperature of the receiving stream upstream and downstream of the discharge outfall. The Division should be
consulted in selecting location(s)that provide(s) a representative upstream/downstream site. Upstream and
downstream monitoring is not necessary if the discharge is to a receiving stream that does not contain any
flowing water at the time of discharge.
2. Monitoring requirements and limits apply only if chlorine is present in the discharge. Discharges to freshwater
(FW)will be required to meet a daily maximum discharge limitation of 17 µg/L of Total Residual Chlorine
(TRC). Discharges to saltwater(SW)will be required to meet a daily maximum discharge limitation of 13
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DocuSign Envelope ID:A5A31D1C-527B-48C6-A13E-AE070AC8CF23
General Permit NCG500000
µg/L of TRC. The Division shall consider all effluent TRC values reported below 50 µg/L to be in compliance
with the permit. However,the Permittee shall continue to record all values reported by a North Carolina
certified laboratory(including field certified), even if these values fall below 50 µg/L.
3. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units for discharges to receiving
streams classified as freshwater.
The pH shall not be less than 6.8 standard units nor greater than 8.5 standard units for discharges to receiving
streams classified as
saltwater.
4. Monitoring requirement applies only if water treatment and/or chemical additives, i.e. corrosion inhibitors,
oxygen scavengers,biocides or cleaning solvents, are added to the system.
This permit does not authorize the discharge of water treatment or chemical additives(including but not
limited to chromium,zinc or copper)other than chlorine and approved de-chlorinating reagents without
written approval from the Division.
The permittee shall obtain approval from the Division prior to the use of any chemical additive in the permittee's
systems covered under this permit. To obtain approval the permittee shall notify the Director in writing at least
ninety(90)days prior to instituting use of any new additive(other than additives previously approved by the
Division). Such approval requests shall include a completed Biocide Worksheet Form 101 or equivalent worksheet
form approved by the Division, a copy of the MSDS for the additive, and a map indicating the discharge point and
receiving stream. Please direct all inquiries to the Aquatic Toxicology Branch.
All non-contact cooling water sample locations shall provide representative samples of the discharge and require
sampling prior to discharge commingling with any other waters or substances, such as stormwater or surface water
to enable characterization of a pollutant of concern.
All samples collected should be from a representative and a measurable discharge event that results in an actual
discharge from the permitted discharge outfall.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
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DocuSign Envelope ID:A5A31D1C-527B-48C6-A13E-AE070AC8CF23
General Permit NCG500000
SECTION B. K) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FOR
HYDROELECTRIC FACILITIES — SUMPS AND DRAINS AND OTHER
MISCELLANEOUS WASTEWATERS
[15A NCAC 02B .0400 et seq., 02B .0500 seq.]
During the period beginning on December 1,2020 and lasting until expiration,the permittee is authorized to
discharge waters from sumps&drains(including powerhouse sumps&drains,wheel pit drains,head cover drains
and gallery sumps&drains) and other miscellaneous wastewaters(from sumps &drains associated with
hydroelectric facilities)from outfalls numbered serially beginning with 001 (specific outfall numbers shall be
assigned by the permittee). Such discharges shall be limited and monitored by the permittee as specified below:
PARAMETER LIMITS MONITORING REQUIREMENTS
Monthly Daily Measurement Sample Sample Location
Average Maximum Frequency Type
Flow Quarterly Estimate Effluent
Oil and Grease' 15.0 mg/L 20.0 mg/L Quarterly Grab Effluent
pH2 Quarterly Grab Effluent
Total Residual Chlorine' FW: 17.0 µg/L Semi-annually Grab Effluent
SW: 13.0 µg/L
Chemical Oxygen Demand' Semi-annually Grab Effluent
1. The tailrace shall be visually inspected for oil sheens when a permitted discharge occurs immediately after
the lubrication of wicket gates(or other lubrication operations which might result in the discharge of oil
and grease) at the hydroelectric facility.
2. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units for discharges to
receiving streams classified as freshwater.
The pH shall not be less than 6.8 standard units nor greater than 8.5 standard units for discharges to
receiving streams classified as saltwater.
3. Monitoring requirements and limits apply only if chlorine is present in the discharge. Discharges to
freshwater(FW)will be required to meet a daily maximum discharge limitation of 17 µg/L of Total
Residual Chlorine(TRC). Discharges to saltwater(SW)will be required to meet a daily maximum
discharge limitation of 13 µg/L of TRC. The Division shall consider all effluent TRC values reported
below 50 µg/L to be in compliance with the permit. However,the Permittee shall continue to record all
values reported by a North Carolina certified laboratory(including field certified), even if these values fall
below 50 µg/L.
4. Monitoring requirement applies only if water treatment and/or chemical additives, i.e. corrosion inhibitors,
oxygen scavengers,biocides or cleaning solvents, are added to the system.
Chemical wheel pit cleaning is permitted on a monthly basis. When cleaning of the wheel pits occurs,the tailrace
shall be inspected visually for foam and oil. Cleaning shall be conducted only with solvents pre-approved by the
Division. The permittee is responsible for retaining documentation of all solvent approvals. Should the permittee
wish to change cleaning solvents (other than solvents previously approved), a written request should be made to the
Division including the MSDS for the proposed solvent.
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DocuSign Envelope ID:A5A31D1C-527B-48C6-A13E-AE070AC8CF23
General Permit NCG500000
Mechanical cleaning operations which do not contribute any wastewater to the discharge are not limited by this
permit. Non-discharging cleaning operations may be conducted as often as necessary to ensure safety and proper
facility operation.
This permit does not authorize the discharge of water treatment or chemical additives(including but not
limited to chromium,zinc or copper)other than chlorine and approved de-chlorinating reagents without
written approval from the Division.
The permittee shall obtain approval from the Division prior to the use of any chemical additive in the permittee's
systems covered under this permit. To obtain approval the permittee shall notify the Director in writing at least
ninety(90)days prior to instituting use of any new additive (other than additives previously approved by the
Division). Such approval requests shall include a completed Biocide Worksheet Form 101 or equivalent worksheet
form approved by the Division, a copy of the MSDS for the additive, and a map indicating the discharge point and
receiving stream. Please direct all inquiries to the Aquatic Toxicology Branch.
All non-contact cooling water sample locations shall provide representative samples of the discharge and require
sampling prior to discharge commingling with any other waters or substances, such as stormwater or surface water,
to enable characterization of a pollutant of concern.
All samples collected should be from a representative and a measurable discharge event that results in an actual
discharge from the permitted discharge outfall.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
SECTION C. DISCHARGE MONITORING REPORTS (DMRs)
The submittal of monthly Discharge Monitoring Reports(DMRs) shall not be required, except upon demand by
the Division. Even though the submittal of the monthly monitoring reports to the Division is not required, all
monitoring requirements must be met, and the data must be maintained on site for a period of three years.
All violations must be reported to the appropriate regional office.
This section supersedes the requirement for the submittal of monthly Discharge Monitoring Reports(DMRs)
specified in Part II, Section D. (2.)of this permit.
SECTION D. OPERATION AND MAINTENANCE
The permittee shall at all times provide the operation and maintenance necessary to operate the existing facilities in
accordance with the Standard Conditions for NPDES Permits found in Part II, Section C. 2. of this permit.
A facility covered under this general permit will not need a designated Operator in Responsible Charge(ORC)unless
the permittee receives a letter notifying them that the facility has been classified by the Water Pollution Control
System Operator Certification Commission (Commission). Please note that any water pollution control system,
regardless of type or ownership, may be classified and required to designate an ORC and a Back-up ORC, in the
event that the Commission determines that the system is not being operated or maintained in accordance with permit
conditions, as reported by regional office DEQ staff or from citizen complaints, as per 15A NCAC 08G .0301 (f).
SECTION E. SCHEDULE OF COMPLIANCE
1. The permittee shall comply with Final Effluent Limitations by the effective date of the Certificate of Coverage.
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DocuSign Envelope ID:A5A31D1C-527B-48C6-A13E-AE070AC8CF23
General Permit NCG500000
2. Permittee shall operate the existing facilities such that constituents and/or characteristics of the discharge
qualify for Certificate of Coverage under the General Permit in accordance with 15A NCAC 02H .0127. In
accordance with NPDES regulations at § 122.45, allowing detection of a pollutant: Instances could arise
where the combination of process and non-process wastewaters result in dilution of a pollutant of concern such
that it would not be detectable using approved analytical methods. Internal monitoring would enable
characterization of the pollutant before dilution with other wastewaters.
3. The upstream location for the natural water temperature shall be interpreted as the influent to the penstock or
other appropriate location in the impounded waterbody. Effluent is the outflow from the powerhouse. The
temperature change between these two values is considered the heat added and judged for compliance with
Footnote#1 in Section A. (1.)and Section A. (2.) of the permit and 15A NCAC 2B .0211 (18).
4. A facility with multiple wastewaters covered under this permit must adhere to the applicable effluent table in
Sections A. (1-4) for each waste stream and sample prior to the wastewater commingling with any other waters
or substances.
SECTION F. NOTICE OF INTENT
General Permit Expiration
General Permits will be effective for a term not to exceed five years, at the end of which the Division may renew
them after all public notice requirements have been satisfied. If a General Permit is renewed, existing permittees do
not need to submit a renewal request or pay a renewal fee unless directed by the Division. New applicants seeking
coverage under a renewed General Permit must submit a Notice of Intent to be covered and obtain a Certificate of
Coverage under the renewed General Permit [15A NCAC 02H .0127(e)]. A current version of the NOI for this
General Permit can be obtained by contacting the NPDES Permitting Branch at(919) 707-3615 or can be
downloaded from the internet at hgps:Hdeq.nc.gov/about/divisions/water-resources/water-quality_permittin nndes-
wastewater/npdes-permittiniz-]2rocess-1. NOIs must be signed and submitted to the NPDES Permitting Branch(1617
Mail Service Center,Raleigh,NC 27699-1617). Applicants who have submitted a completed NOI are not
authorized to discharge until a Certificate of Coverage is issued. In general,the NOI shall include the following
information:
1. The mailing address,telephone number, and email address for the owner and/or operator.
2. The facility name, address and telephone number where the discharge will occur.
3. The permit number of any existing NPDES permit(s) for any discharge(s)from the site.
4. A description of the discharge, including the number of discharge points, the volume of discharge, the
frequency of discharge and any treatment methods applied prior to discharge.
5. The name(s)of the receiving stream(s)and the stream classification(s).
6. An analysis of non-discharge alternatives, including connection to a regional sewer collection system,
subsurface disposal and spray irrigation.
7. A 7.5 minute series USGS topographic map with the discharge location clearly indicated.
8. Final plans and specifications for the treatment system and all major components(if applicable).
9. A certification that the information contained in the NOI is true, complete and accurate.
10. A listing of all previously approved water treatment and/or chemical additives i.e. biocides, oxygen
scavengers, corrosion inhibitors,and cleaning solvents. Water treatment and chemical additives include any
material that is added to water used at the facility or to a wastewater generated by the facility to condition or
treat water.
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DocuSign Envelope ID:A5A31D1C-527B-48C6-A13E-AE070AC8CF23
General Permit NCG500000
PART II
STANDARD CONDITIONS FOR NPDES PERMITS
Section A. Definitions
2/Month
Samples are collected twice per month with at least ten calendar days between sampling events. These samples shall be
representative of the wastewater discharged during the sample period.
3/Week
Samples are collected three times per week on three separate calendar days. These samples shall be representative of the
wastewater discharged during the sample period.
Act or"the Act"
The Federal Water Pollution Control Act,also known as the Clean Water Act(CWA),as amended, 33 USC 1251,et.
seq.
Annual Avera;;e
The arithmetic mean of all"daily discharges"of a pollutant measured during the calendar year. In the case of fecal
coliform,the geometric mean of such discharges.
Arithmetic Mean
The summation of the individual values divided by the number of individual values.
Bypass
The known diversion of waste streams from any portion of a treatment facility including the collection system,which is
not a designed or established or operating mode for the facility.
Calendar Day
The period from midnight of one day until midnight of the next day.However, for purposes of this permit,any
consecutive 24-hour period that reasonably represents the calendar day may be used for sampling.
Calendar Week
The period from Sunday through the following Saturday.
Calendar Quarter
One of the following distinct periods: January through March,April through June,July through September,and October
through December.
Composite Sample
A sample collected over a 24-hour period by continuous sampling or combining grab samples of at least 100 mL in such
a manner as to result in a total sample representative of the wastewater discharge during the sample period. The Director
may designate the most appropriate method(specific number and size of aliquots necessary,the time interval between
grab samples, etc.)on a case-by-case basis. Samples may be collected manually or automatically. Composite samples
may be obtained by the following methods:
(1) Continuous: a single,continuous sample collected over a 24-hour period proportional to the rate of flow.
(2) Constant time/variable volume: a series of grab samples collected at equal time intervals over a 24 hour period
of discharge and combined proportional to the rate of flow measured at the time of individual sample collection,
or
(3) Variable time/constant volume: a series of grab samples of equal volume collected over a 24 hour period with
the time intervals between samples determined by a preset number of gallons passing the sampling point.Flow
measurement between sample intervals shall be determined by use of a flow recorder and totalizer,and the
preset gallon interval between sample collection fixed at no greater than 1/24 of the expected total daily flow at
the treatment system,or
(4) Constant time/constant volume: a series of grab samples of equal volume collected over a 24-hour period at a
constant time interval.Use of this method requires prior approval by the Director.This method may only be
used in situations where effluent flow rates vary less than 15 percent.The following restrictions also apply:
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DocuSign Envelope ID:A5A31D1C-527B-48C6-A13E-AE070AC8CF23
General Permit NCG500000
➢ Influent and effluent grab samples shall be of equal size and of no less than 100 milliliters
➢ Influent samples shall not be collected more than once per hour.
➢ Permittees with wastewater treatment systems whose detention time<24 hours shall collect effluent grab
samples at intervals of no greater than 20 minutes apart during any 24-hour period.
➢ Permittees with wastewater treatment systems whose detention time exceeds 24 hours shall collect effluent
grab samples at least every six hours;there must be a minimum of four samples during a 24-hour sampling
period.
Continuous flow measurement
Flow monitoring that occurs without interruption throughout the operating hours of the facility. Flow shall be monitored
continually except for the infrequent times when there may be no flow or for infrequent maintenance activities on the
flow device.
Daily Discharge
The discharge of a pollutant measured during a calendar day or any 24-hour period that reasonably represents the
calendar day for purposes of sampling. For pollutants measured in units of mass,the "daily discharge" is calculated as the
total mass of the pollutant discharged over the day. For pollutants expressed in other units of measurement,the"daily
discharge"is calculated as the average measurement of the pollutant over the day. (40 CFR 122.2; see also"Composite
Sample,"above.)
Daily Maximum
The highest"daily discharge"during the calendar month.
Daily Sampling
Parameters requiring daily sampling shall be sampled 5 out of every 7 days per week unless otherwise specified in the
permit. Sampling shall be conducted on weekdays except where holidays or other disruptions of normal operations
prevent weekday sampling. If sampling is required for all seven days of the week for any permit parameter(s),that
requirement will be so noted on the Effluent Limitations and Monitoring Page(s).
DWR or"the Division"
The Division of Water Resources,Department of Environmental Quality.
Effluent
Wastewater discharged following all treatment processes from a water pollution control facility or other point source
whether treated or untreated.
EMC
The North Carolina Environmental Management Commission
EPA
The United States Environmental Protection Agency
Facility Closure
Cessation of all activities that require coverage under this NPDES permit. Completion of facility closure will allow this
permit to be rescinded.
Geometric Mean
The Nth root of the product of the individual values where N=the number of individual values. For purposes of
calculating the geometric mean,values of"0"(or"< [detection level]")shall be considered= 1.
Grab Sample
Individual samples of at least 100 mL collected over a period of time not exceeding 15 minutes. Grab samples can be
collected manually. Grab samples must be representative of the discharge(or the receiving stream,for instream samples).
Hazardous Substance
Any substance designated under 40 CFR Part 116 pursuant to Section 311 of the CWA.
Instantaneous flow measurement
The flow measured during the minimum time required for the flow measuring device or method to produce a result in
that instance. To the extent practical,instantaneous flow measurements coincide with the collection of any grab samples
required for the same sampling period so that together the samples and flow are representative of the discharge during
that sampling period.
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DocuSign Envelope ID:A5A31D1C-527B-48C6-A13E-AE070AC8CF23
General Permit NCG500000
Monthly Average(concentration limit)
The arithmetic mean of all"daily discharges"of a pollutant measured during the calendar month. In the case of fecal
coliform or other bacterial parameters or indicators,the geometric mean of such discharges.
Permit Issuing Authority
The Director of the Division of Water Quality.
Quarterly Average(concentration limit)
The arithmetic mean of all samples taken over a calendar quarter.
Severe property damage
Substantial physical damage to property,damage to the treatment facilities which causes them to become inoperable,or
substantial and permanent loss of natural resources which can reasonably be expected to occur in the absence of a
bypass. Severe property damage excludes economic loss caused by delays in production.
Toxic Pollutant:
Any pollutant listed as toxic under Section 307(a)(1)of the CWA.
Upset
An incident beyond the reasonable control of the Permittee causing unintentional and temporary noncompliance with
permit effluent limitations and/or monitoring requirements.An upset does not include noncompliance caused by
operational error,improperly designed treatment facilities,inadequate treatment facilities,lack of preventive
maintenance,or careless or improper operation.
Weekly Average(concentration limit)
The arithmetic mean of all"daily discharges"of a pollutant measured during the calendar week. In the case of fecal
coliform or other bacterial parameters or indicators,the geometric mean of such discharges.
Section B. General Conditions
1. Duty to Comply_
The Permittee must comply with all conditions of this permit.Any permit noncompliance constitutes a violation of
the CWA and is grounds for enforcement action;for permit termination,revocation and reissuance,or modification;
or denial of a permit renewal application[40 CFR 122.41].
a. The Permittee shall comply with effluent standards or prohibitions established under section 307(a)of the CWA
for toxic pollutants and with standards for sewage sludge use or disposal established under section 405(d)of the
CWA within the time provided in the regulations that establish these standards or prohibitions or standards for
sewage sludge use or disposal,even if the permit has not yet been modified to incorporate the requirement.
b. The CWA provides that any person who violates section[s] 301, 302,306, 307,308, 318 or 405 of the Act,or
any permit condition or limitation implementing any such sections in a permit issued under section 402,or any
requirement imposed in a pretreatment program approved under sections 402(a)(3)or 402(b)(8)of the Act,is
subject to a civil penalty not to exceed$37,500 per day for each violation. [33 USC 1319(d)and 40 CFR
122.41(a)(2)]
c. The CWA provides that any person who negligently violates sections 301,302, 306,307, 308,318,or 405 of the
Act,or any condition or limitation implementing any of such sections in a permit issued under section 402 of the
Act,or any requirement imposed in a pretreatment program approved under section 402(a)(3)or 402(b)(8)of the
Act,is subject to criminal penalties of$2,500 to$25,000 per day of violation, or imprisonment of not more than
1 year,or both. In the case of a second or subsequent conviction for a negligent violation, a person shall be
subject to criminal penalties of not more than$50,000 per day of violation,or by imprisonment of not more than
2 years, or both. [33 USC 1319(c)(1)and 40 CFR 122.41(a)(2)]
d. Any person who knowingly violates such sections, or such conditions or limitations is subject to criminal
penalties of$5,000 to$50,000 per day of violation,or imprisonment for not more than 3 years,or both. In the
case of a second or subsequent conviction for a knowing violation, a person shall be subject to criminal penalties
of not more than$100,000 per day of violation, or imprisonment of not more than 6 years, or both. [33 USC
1319(c)(2)and 40 CFR 122.41(a)(2)]
e. Any person who knowingly violates section 301, 302, 303, 306, 307,308,318 or 405 of the Act,or any permit
condition or limitation implementing any of such sections in a permit issued under section 402 of the Act,and
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DocuSign Envelope ID:A5A31D1C-527B-48C6-A13E-AE070AC8CF23
General Permit NCG500000
who knows at that time that he thereby places another person in imminent danger of death or serious bodily
injury, shall,upon conviction,be subject to a fine of not more than$250,000 or imprisonment of not more than
15 years, or both. In the case of a second or subsequent conviction for a knowing endangerment violation, a
person shall be subject to a fine of not more than$500,000 or by imprisonment of not more than 30 years,or
both.An organization,as defined in section 309(c)(3)(B)(iii)of the CWA, shall,upon conviction of violating the
imminent danger provision,be subject to a fine of not more than$1,000,000 and can be fined up to$2,000,000
for second or subsequent convictions. [40 CFR 122.41(a)(2)]
f. Under state law,a civil penalty of not more than$25,000 per violation may be assessed against any person who
violates or fails to act in accordance with the terms, conditions, or requirements of a permit. [North Carolina
General Statutes § 143-215.6A]
g. Any person may be assessed an administrative penalty by the Administrator for violating section 301, 302,306,
307,308, 318 or 405 of this Act, or any permit condition or limitation implementing any of such sections in a
permit issued under section 402 of this Act.Administrative penalties for Class I violations are not to exceed
$16,000 per violation,with the maximum amount of any Class I penalty assessed not to exceed$37,500.
Penalties for Class II violations are not to exceed$16,000 per day for each day during which the violation
continues,with the maximum amount of any Class II penalty not to exceed$177,500. [33 USC 1319(g)(2)and
40 CFR 122.41(a)(3)]
2. Duty to Mitigate
The Permittee shall take all reasonable steps to minimize or prevent any discharge or sludge use or disposal in
violation of this permit with a reasonable likelihood of adversely affecting human health or the environment[40 CFR
122.41(d)].
3. Civil and Criminal Liability
Except as provided in permit conditions on"Bypassing"(Part H.C.4),"Upsets"(Part II.C.S)and"Power Failures"
(Part II.C.7),nothing in this permit shall be construed to relieve the Permittee from any responsibilities,liabilities, or
penalties for noncompliance pursuant to NCGS 143-215.3, 143-215.6 or Section 309 of the Federal Act, 33 USC
1319.Furthermore,the Permittee is responsible for consequential damages, such as fish kills,even though the
responsibility for effective compliance may be temporarily suspended.
4. Oil and Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the Permittee from
any responsibilities, liabilities,or penalties to which the Permittee is or may be subject to under NCGS 143-215.75 et
seq. or Section 311 of the Federal Act,33 USG 1321. Furthermore,the Permittee is responsible for consequential
damages, such as fish kills, even though the responsibility for effective compliance may be temporarily suspended.
5. Property Rights
The issuance of this permit does not convey any property rights in either real or personal property, or any exclusive
privileges,nor does it authorize any injury to private property or any invasion of personal rights,nor any
infringement of Federal, State or local laws or regulations [40 CFR 122.41(g)].
6. Onshore or Offshore Construction
This permit does not authorize or approve the construction of any onshore or offshore physical structures or facilities
or the undertaking of any work in any navigable waters.
7. Severability
The provisions of this permit are severable. If any provision of this permit,or the application of any provision of this
permit to any circumstances,is held invalid,the application of such provision to other circumstances,and the
remainder of this permit, shall not be affected thereby[NCGS 150B-23].
8. Duty to Provide Information
The Permittee shall furnish to the Permit Issuing Authority,within a reasonable time, any information which the
Permit Issuing Authority may request to determine whether cause exists for modifying,revoking and reissuing,or
terminating this permit or to determine compliance with this permit.The Permittee shall also furnish to the Permit
Issuing Authority upon request,copies of records required by this permit[40 CFR 122.41(h)].
9. Signatory Requirements
All applications,reports,or information submitted to the Permit Issuing Authority shall be signed and certified[40
CFR 122.41(k)].
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DocuSign Envelope ID:A5A31D1C-527B-48C6-A13E-AE070AC8CF23
General Permit NCG500000
a. All permit applications shall be signed as follows:
(1) For a corporation: by a responsible corporate officer.For the purpose of this Section,a responsible
corporate officer means: (a)a president, secretary,treasurer or vice president of the corporation in charge of
a principal business function,or any other person who performs similar policy or decision making functions
for the corporation,or(b)the manager of one or more manufacturing,production,or operating facilities,
provided,the manager is authorized to make management decisions which govern the operation of the
regulated facility including having the explicit or implicit duty of making major capital investment
recommendations,and initiating and directing other comprehensive measures to assure long term
environmental compliance with environmental laws and regulations;the manager can ensure that the
necessary systems are established or actions taken to gather complete and accurate information for permit
application requirements; and where authority to sign documents has been assigned or delegated to the
manager in accordance with corporate procedures .
(2) For a partnership or sole proprietorship: by a general partner or the proprietor,respectively; or
(3) For a municipality, State,Federal,or other public agency: by either a principal executive officer or ranking
elected official [40 CFR 122.22].
b. All reports required by the permit and other information requested by the Permit Issuing Authority shall be
signed by a person described in paragraph a. above or by a duly authorized representative of that person.A
person is a duly authorized representative only if:
(1) The authorization is made in writing by a person described above;
(2) The authorization specified either an individual or a position having responsibility for the overall operation
of the regulated facility or activity, such as the position of plant manager,operator of a well or well field,
superintendent,a position of equivalent responsibility,or an individual or position having overall
responsibility for environmental matters for the company. (A duly authorized representative may thus be
either a named individual or any individual occupying a named position.);and
(3) The written authorization is submitted to the Permit Issuing Authority[40 CFR 122.22]
c. Changes to authorization: If an authorization under paragraph(b)of this section is no longer accurate because a
different individual or position has responsibility for the overall operation of the facility, a new authorization
satisfying the requirements of paragraph(b)of this section must be submitted to the Director prior to or together
with any reports,information,or applications to be signed by an authorized representative [40 CFR 122.22]
d. Certification.Any person signing a document under paragraphs a. or b. of this section 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.I am aware that there are significant penalties for
submitting false information, including the possibility of fines and imprisonment for knowing violations."
10. Permit Actions
This permit may be modified,revoked and reissued,or terminated for cause. The filing of a request by the Permittee
for a permit modification,revocation and reissuance,or termination,or a notification of planned changes or
anticipated noncompliance does not stay any permit condition[40 CFR 122.41(f)].
11. Permit Modification,Revocation and Reissuance,or Termination
The issuance of this permit does not prohibit the permit issuing authority from reopening and modifying the permit,
revoking and reissuing the permit,or terminating the permit as allowed by the laws,rules,and regulations contained
in Title 40, Code of Federal Regulations,Parts 122 and 123;Title 15A of the North Carolina Administrative Code,
Subchapter 02H .0100; and North Carolina General Statute 143.215.1 et. al.
12. Annual Administering and Compliance Monitoring Fee Requirements
The Permittee must pay the annual administering and compliance monitoring fee within thirty days after being billed
by the Division. Failure to pay the fee in a timely manner in accordance with 15A NCAC 02H .0105(b)(2)may
cause this Division to initiate action to revoke the permit, and/or the Certificate of Coverage issued to the permittee
under this permit.
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DocuSign Envelope ID:A5A31D1C-527B-48C6-A13E-AE070AC8CF23
General Permit NCG500000
Section C. Operation and Maintenance of Pollution Controls
1. Certified Operator
Owners of classified water pollution control systems must designate operators, certified by the Water Pollution
Control System Operators Certification Commission(WPCSOCC),of the appropriate type and grade for the system,
and, for each classification must[T15A NCAC 08G .0201]:
a. designate one Operator In Responsible Charge(ORC)who possesses a valid certificate of the type and grade at
least equivalent to the type and grade of the system;
b. designate one or more Back-up Operator(s)in Responsible Charge(Back-up ORCs)who possesses a valid
certificate of the type of the system and no more than one grade less than the grade of the system,with the
exception of no backup operator in responsible charge is required for systems whose minimum visitation
requirements are twice per year;and
c. submit a signed completed"Water Pollution Control System Operator Designation Form"to the Commission(or
to the local health department for owners of subsurface systems)countersigned by the designated certified
operators,designating the Operator in Responsible Charge(ORC)and the Back-up Operator in Responsible
Charge(Back-up ORC):
(1) 60 calendar days prior to wastewater or residuals being introduced into a new system; or
(2) within 120 calendar days following:
➢ receiving notification of a change in the classification of the system requiring the designation of a new
Operator in Responsible Charge(ORC)and Back-up Operator in Responsible Charge(Back-up ORC)
of the proper type and grade;or
➢ a vacancy in the position of Operator in Responsible Charge(ORC)or Back-up Operator in Responsible
Charge(Back-up ORC).
(3) within seven calendar days of vacancies in both ORC and Back-up ORC positions replacing or designating
at least one of the responsibilities.
The ORC of each Class I facility(or the Back-up ORC,when acting as surrogate for the ORC)must:
➢ Visit the facility as often as is necessary to insure proper operation of the treatment system;the treatment
facility must be visited at least weekly
➢ Comply with all other conditions of 15A NCAC 08G.0204.
Note: This requirement does not apply until the permittee receives a letter notifying them of classification of
the facility. Currently,facilities are not being classified for this purpose,but may at some time in the future.
2. Proper Operation and Maintenance
The Permittee shall at all times properly operate and maintain all facilities and systems of treatment and control(and
related appurtenances)which are installed or used by the Permittee to achieve compliance with the conditions of this
permit. Proper operation and maintenance also includes adequate laboratory controls and appropriate quality
assurance procedures. This provision requires the Permittee to install and operate backup or auxiliary facilities only
when necessary to achieve compliance with the conditions of the permit[40 CFR 122.41(e)].
NOTE: Properly and officially designated operators are fully responsible for all proper operation and maintenance
of the facility,and all documentation required thereof,whether acting as a contract operator[subcontractor] or a
member of the Permittee's staff.
3. Need to Halt or Reduce not a Defense
It shall not be a defense for a Permittee in an enforcement action that it would have been necessary to halt or reduce
the permitted activity in order to maintain compliance with the condition of this permit[40 CFR 122.41(c)].
Page 17 of 23

DocuSign Envelope ID:A5A31D1C-527B-48C6-A13E-AE070AC8CF23
General Permit NCG500000
4. Bypassing of Treatment Facilities
a. Bypass not exceeding limitations [40 CFR 122.41(m)(2)]
The Permittee may allow any bypass to occur which does not cause effluent limitations to be exceeded,but only
if it also is for essential maintenance to assure efficient operation. These bypasses are not subject to the
provisions of Paragraphs b. and c. of this section.
b. Notice [40 CFR 122.41(m)(3)]
(1) Anticipated bypass. If the Permittee knows in advance of the need for a bypass,it shall submit prior notice,
if possible at least ten days before the date of the bypass; including an evaluation of the anticipated quality
and effect of the bypass.
(2) Unanticipated bypass. The Permittee shall submit notice of an unanticipated bypass as required in Part
II.E.6. (24-hour notice).
c. Prohibition of Bypass
(1) Bypass from the treatment facility is prohibited and the Permit Issuing Authority may take enforcement
action against a Permittee for bypass,unless:
(A) Bypass was unavoidable to prevent loss of life,personal injury or severe property damage;
(B) There were no feasible alternatives to the bypass, such as the use of auxiliary treatment facilities,
retention of untreated wastes or maintenance during normal periods of equipment downtime. This
condition is not satisfied if adequate backup equipment should have been installed in the exercise of
reasonable engineering judgment to prevent a bypass which occurred during normal periods of
equipment downtime or preventive maintenance; and
(C) The Permittee submitted notices as required under Paragraph b.of this section.
(2) Bypass from the collection system is prohibited and the Permit Issuing Authority may take enforcement
action against a Permittee for a bypass as provided in any current or future system-wide collection system
permit associated with the treatment facility.
(3) The Permit Issuing Authority may approve an anticipated bypass, after considering its adverse effects,if the
Permit Issuing Authority determines that it will meet the three conditions listed above in Paragraph c. (1)of
this section.
5. Upsets
a. Effect of an upset[40 CFR 122.41(n)(2)]: An upset constitutes an affirmative defense to an action brought for
noncompliance with such technology based permit effluent limitations if the requirements of paragraph b. of this
condition are met.No determination made during administrative review of claims that noncompliance was
caused by upset,and before an action for noncompliance,is final administrative action subject to judicial review.
b. Conditions necessary for a demonstration of upset:Any Permittee who wishes to establish the affirmative
defense of upset shall demonstrate,through properly signed, contemporaneous operating logs,or other relevant
evidence that:
(1)An upset occurred and that the Permittee can identify the cause(s)of the upset;
(2)The Permittee facility was at the time being properly operated; and
(3)The Permittee submitted notice of the upset as required in Part II.E.6 of this permit.
(4)The Permittee complied with any remedial measures required under Part II.B.2. of this permit.
c. Burden of proof[40 CFR 122.41(n)(4)]: The Permittee seeking to establish the occurrence of an upset has the
burden of proof in any enforcement proceeding.
6. Removed Substances
Solids, sludges,filter backwash,or other pollutants removed in the course of treatment or control of wastewaters
shall be utilized/disposed of in accordance with NCGS 143-215.1 and in a manner such as to prevent any pollutant
from such materials from entering waters of the State or navigable waters of the United States except as permitted by
the Commission. The Permittee shall comply with all applicable state and Federal regulations governing the disposal
of sewage sludge,including 40 CFR 503, Standards for the Use and Disposal of Sewage Sludge;40 CFR Part 258,
Criteria For Municipal Solid Waste Landfills; and 15A NCAC Subchapter 2T,Waste Not Discharged To Surface
Waters. The Permittee shall notify the Permit Issuing Authority of any significant change in its sludge use or
disposal practices.
Page 18 of 23

DocuSign Envelope ID:A5A31D1C-527B-48C6-A13E-AE070AC8CF23
General Permit NCG500000
7. Power Failures
The Permittee is responsible for maintaining adequate safeguards(as required by 15A NCAC 02H .0124)to prevent
the discharge of untreated or inadequately treated wastes during electrical power failures either by means of alternate
power sources, standby generators or retention of inadequately treated effluent.
Section D. Monitoring and Records
1. Representative Sampling
Samples collected and measurements taken,as required herein, shall be representative of the permitted discharge.
Samples collected at a frequency less than daily shall be taken on a day and time that is representative of the
discharge for the period the sample represents.All samples shall be taken at the monitoring points specified in this
permit and,unless otherwise specified,before the effluent joins or is diluted by any other wastestream,body of
water,or substance.Monitoring points shall not be changed without notification to and the approval of the Permit
Issuing Authority[40 CFR 122.41(j)].
2. Reporting
Monitoring results obtained during the previous month(s)shall be summarized for each month and reported on a
monthly Discharge Monitoring Report(DMR)Form(MR 1, 1.1,2,3)or alternative forms approved by the Director,
postmarked no later than the last calendar day of the month following the completed reporting period.
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.Duplicate signed copies of these,
and all other reports required herein, shall be submitted to the following address:
NC DENR/Division of Water Resources/Water Quality Permitting Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
3. Flow Measurements
Appropriate flow measurement devices and methods consistent with accepted scientific practices shall be selected
and used to ensure the accuracy and reliability of measurements of the volume of monitored discharges. The devices
shall be installed,calibrated and maintained to ensure that the accuracy of the measurements is consistent with the
accepted capability of that type of device. Devices selected shall be capable of measuring flows with a maximum
deviation of less than 10%from the true discharge rates throughout the range of expected discharge volumes. Flow
measurement devices shall be accurately calibrated at a minimum of once per year and maintained to ensure that the
accuracy of the measurements is consistent with the accepted capability of that type of device. The Director shall
approve the flow measurement device and monitoring location prior to installation.
Once-through condenser cooling water flow monitored by pump logs, or pump hour meters as specified in Part I of
this permit and based on the manufacturer's pump curves shall not be subject to this requirement.
4. Test Procedures
Laboratories used for sample analysis must be certified by the Division.Permittees should contact the Division's
Laboratory Certification Section(919 733-3908 or http://portal.ncdenr.org/web/wq/lab/cert)for information
regarding laboratory certifications.
Facilities whose personnel are conducting testing of field-certified parameters only must hold the appropriate field
parameter laboratory certifications.
Test procedures for the analysis of pollutants shall conform to the EMC regulations(published pursuant to NCGS
143-215.63 et. seq.),the Water and Air Quality Reporting Acts,and to regulations published pursuant to Section
304(g),33 USC 1314,of the CWA(as amended), and 40 CFR 136;or in the case of sludge use or disposal,approved
under 40 CFR 136,unless otherwise specified in 40 CFR 503,unless other test procedures have been specified in
this permit[40 CFR 122.41].
To meet the intent of the monitoring required by this permit,all test procedures must produce minimum detection
and reporting levels that are below the permit discharge requirements and all data generated must be reported down
Page 19 of 23

DocuSign Envelope ID:A5A31D1C-527B-48C6-A13E-AE070AC8CF23
General Permit NCG500000
to the minimum detection or lower reporting level of the procedure. If no approved methods are determined capable
of achieving minimum detection and reporting levels below permit discharge requirements,then the most sensitive
(method with the lowest possible detection and reporting level)approved method must be used.
5. Penalties for Tampering
The CWA provides that any person who falsifies,tampers with,or knowingly renders inaccurate,any monitoring
device or method required to be maintained under this permit shall,upon conviction,be punished by a fine of not
more than$10,000 per violation,or by imprisonment for not more than two years per violation,or by both. If a
conviction of a person is for a violation committed after a first conviction of such person under this paragraph,
punishment is a fine of not more than$20,000 per day of violation,or by imprisonment of not more than 4 years,or
both[40 CFR 122.41].
6. Records Retention
Except for records of monitoring information required by this permit related to the Permittee's sewage sludge use
and disposal activities,which shall be retained for a period of at least five years(or longer as required by 40 CFR
503),the Permittee shall retain records of all monitoring information, including:
➢ all calibration and maintenance records
➢ all original strip chart recordings for continuous monitoring instrumentation
➢ copies of all reports required by this permit
➢ copies of all data used to complete the application for this permit
These records or copies shall be maintained for a period of at least 3 years from the date of the sample,measurement,
report or application. This period may be extended by request of the Director at any time [40 CFR 122.41].
7. Recording Results
For each measurement or sample taken pursuant to the requirements of this permit,the Permittee shall record the
following information [40 CFR 122.41]:
a. The date,exact place, and time of sampling or measurements;
b. The individual(s)who performed the sampling or measurements;
c. The date(s)analyses were performed;
d. The individual(s)who performed the analyses;
e. The analytical techniques or methods used;and
f. The results of such analyses.
8. Inspection and Entry
The Permittee shall allow the Director,or an authorized representative(including an authorized contractor acting as a
representative of the Director),upon the presentation of credentials and other documents as may be required by law,
to;
a. Enter,at reasonable times,upon the Permittee's premises where a regulated facility or activity is located or
conducted,or where records must be kept under the conditions of this permit;
b. Have access to and copy,at reasonable times,any records that must be kept under the conditions of this permit;
c. Inspect at reasonable times any facilities,equipment(including monitoring and control equipment),practices, or
operations regulated or required under this permit; and
d. Sample or monitor at reasonable times,for the purposes of assuring permit compliance or as otherwise
authorized by the CWA,any substances or parameters at any location[40 CFR 122.41(i)].
Page 20 of 23

DocuSign Envelope ID:A5A31D1C-527B-48C6-A13E-AE070AC8CF23
General Permit NCG500000
Section E Reporting Requirements
1. Change in Discharge
All discharges authorized herein shall be consistent with the terms and conditions of this permit. The discharge of
any pollutant identified in this permit more frequently than or at a level in excess of that authorized shall constitute a
violation of the permit.
2. Planned Changes
The Permittee shall give notice to the Director as soon as possible of any planned physical alterations or additions to
the permitted facility[40 CFR 122.41(1)].Notice is required only when:
a. The alteration or addition to a permitted facility may meet one of the criteria for new sources at 40 CFR
122.29(b); or
b. The alteration or addition could significantly change the nature or increase the quantity of pollutants discharged.
This notification applies to pollutants subject neither to effluent limitations in the permit,nor to notification
requirements under 40 CFR 122.42(a)(1); or
c. The alteration or addition results in a significant change in the Permittee's sludge use or disposal practices,and
such alteration, addition or change may justify the application of permit conditions that are different from or
absent in the existing permit,including notification of additional use or disposal sites not reported during the
permit application process or not reported pursuant to an approved land application plan.
3. Anticipated Noncompliance
The Permittee shall give advance notice to the Director of any planned changes to the permitted facility or other
activities that might result in noncompliance with the permit[40 CFR 122.41(1)(2)].
4. Transfers
This permit is not transferable to any person without prior written notice to and approval from the Director in
accordance with 40 CFR 122.61. The Director may condition approval in accordance with NCGS 143-215.1,in
particular NCGS 143-215.1(b)(4)b.2.,and may require modification or revocation and reissuance of the permit,or a
minor modification,to identify the new permittee and incorporate such other requirements as may be necessary
under the CWA[40 CFR 122.41(1)(3), 122.61] or state statute.
5. Monitoring Reports
Monitoring results shall be reported at the intervals specified elsewhere in this permit [40 CFR 122.41(1)(4)].
a. Monitoring results must be reported on a Discharge Monitoring Report(DMR)(See Part II.D.2)or forms
provided by the Director for reporting results of monitoring of sludge use or disposal practices.
b. If the Permittee monitors any pollutant more frequently than required by this permit using test procedures
approved under 40 CFR Part 136 and at a sampling location specified in this permit or other appropriate
instrument governing the discharge,the results of such monitoring shall be included in the calculation and
reporting of the data submitted on the DMR.
6. Twenty-four Hour Reporting
a. The Permittee shall report to the Director or the appropriate Regional Office any noncompliance that potentially
threatens public health or the environment.Any information shall be provided orally within 24 hours from the
time the Permittee became aware of the circumstances.A written submission shall also be provided within 5
days of the time the Permittee becomes aware of the circumstances.The written submission shall contain a
description of the noncompliance,and its cause;the period of noncompliance,including exact dates and times,
and if the noncompliance has not been corrected,the anticipated time it is expected to continue; and steps taken
or planned to reduce,eliminate,and prevent reoccurrence of the noncompliance [40 CFR 122.41(1)(6)].
b. The Director may waive the written report on a case-by-case basis for reports under this section if the oral report
has been received within 24 hours.
c. Occurrences outside normal business hours may also be reported to the Division's Emergency Response
personnel at(800)662-7956,[phone] or(919)733-3300.
7. Other Noncompliance
The Permittee shall report all instances of noncompliance not reported under Part II.E.5 and 6. of this permit at the
time monitoring reports are submitted. The reports shall contain the information listed in Part II.E.6. of this permit
[40 CFR 122.41(1)(7)].
Page 21 of 23

DocuSign Envelope ID:A5A31D1C-527B-48C6-A13E-AE070AC8CF23
General Permit NCG500000
8. Other Information
Where the Permittee becomes aware that it failed to submit any relevant facts in a permit application, or submitted
incorrect information in a permit application or in any report to the Director,it shall promptly submit such facts or
information[40 CFR 122.41(1)(8)].
9. Noncompliance Notification
The Permittee shall report by telephone to either the central office or the appropriate regional office of the Division
as soon as possible,but in no case more than 24 hours or on the next working day following the occurrence or first
knowledge of the occurrence of any of the following:
a. Any occurrence at the water pollution control facility which results in the discharge of significant amounts of
wastes which are abnormal in quantity or characteristic, such as the dumping of the contents of a sludge digester;
the known passage of a slug of hazardous substance through the facility; or any other unusual circumstances.
b. Any process unit failure,due to known or unknown reasons,that render the facility incapable of adequate
wastewater treatment such as mechanical or electrical failures of pumps,aerators,compressors,etc.
c. Any failure of a pumping station, sewer line,or treatment facility resulting in a by-pass without treatment of all
or any portion of the influent to such station or facility.
Persons reporting such occurrences by telephone shall also file a written report within 5 days following first
knowledge of the occurrence. Also see reporting requirements for municipalities in Part IV.C.2.c. of this permit.
10. Availability of Reports
Except for data determined to be confidential under NCGS 143-215.3 (a)(2)or Section 308 of the Federal Act,33
USC 1318,all reports prepared in accordance with the terms shall be available for public inspection at the offices of
the Division.As required by the Act,effluent data shall not be considered confidential.Knowingly making any false
statement on any such report may result in the imposition of criminal penalties as provided for in NCGS 143-
215.1(b)(2)or in Section 309 of the Federal Act.
11. Penalties for Falsification of Reports
The CWA provides that any person who knowingly makes any false statement,representation,or certification in any
record or other document submitted or required to be maintained under this permit,including monitoring reports or
reports of compliance or noncompliance shall,upon conviction,be punished by a fine of not more than$25,000 per
violation,or by imprisonment for not more than two years per violation,or by both[40 CFR 122.41].
PART III
OTHER REQUIREMENTS
Section A. Construction
a. The Permittee shall not commence construction of wastewater treatment facilities,nor add to the plant's treatment
capacity,nor change the treatment process(es)utilized at the treatment plant unless(1)the Division has issued an
Authorization to Construct(AtC)permit or(2)the Permittee is exempted from such AtC permit requirements under
Item b. of this Section.
b. In accordance with NCGS 143-215.1(a5) [SL 2011-394],no permit shall be required to enter into a contract for the
construction,installation, or alteration of any treatment work or disposal system or to construct,install,or alter any
treatment works or disposal system within the State when the system's or work's principle function is to conduct,
treat, equalize,neutralize, stabilize,recycle,or dispose of industrial waste or sewage from an industrial facility and
the discharge of the industrial waste or sewage is authorized under a permit issued for the discharge of the industrial
waste or sewage into the waters of the State. Notwithstanding the above,the permit issued for the discharge may be
modified if required by federal regulation.
c. Issuance of an AtC will not occur until Final Plans and Specifications for the proposed construction have been
submitted by the Permittee and approved by the Division.
Page 22 of 23

DocuSign Envelope ID:A5A31D1C-527B-48C6-A13E-AE070AC8CF23
General Permit NCG500000
Section B. Groundwater Monitoring
The Permittee shall,upon written notice from the Director,conduct groundwater monitoring as may be required to
determine the compliance of this NPDES permitted facility with the current groundwater standards.
Section C. Changes in Discharges of Toxic Substances
The Permittee shall notify the Permit Issuing Authority as soon as it knows or has reason to believe(40 CFR 122.42):
a. That any activity has occurred or will occur which would result in the discharge,on a routine or frequent basis,of
any toxic pollutant which is not limited in the permit,if that discharge will exceed the highest of the following
"notification levels";
(1) One hundred micrograms per liter(100 µg/L);
(2) Two hundred micrograms per liter(200 µg/L)for acrolein and acrylonitrile; five hundred micrograms per liter
(500 µg/L)for 2,4-dinitrophenol and for 2-methyl-4,6-dinitrophenol; and one milligram per liter(1 mg/L)for
antimony;
(3) Five times the maximum concentration value reported for that pollutant in the permit application.
b. That any activity has occurred or will occur which would result in any discharge, on a non-routine or infrequent
basis, of a toxic pollutant which is not limited in the permit,if that discharge will exceed the highest of the following
"notification levels";
(1) Five hundred micrograms per liter(500 µg/L);
(2) One milligram per liter(1 mg/L)for antimony;
(3) Ten times the maximum concentration value reported for that pollutant in the permit application.
Section D. Facility Closure Requirements
The Permittee must notify the Division at least 90 days prior to the closure of any wastewater treatment system covered
by this permit. The Division may require specific measures during deactivation of the system to prevent adverse impacts
to waters of the State. This permit cannot be rescinded while any activities requiring this permit continue at the permitted
facility.
Page 23 of 23

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Submission Home TieT2 Filing Management Validate Record Invoice for 2022 Invoice History Account Information LogoA
CURRENT FACILITY OONYACT LIST
CHE MICAL LIST
No. Chemical Name CAS Number Option
13. Hydrated Lime EDIT DELETE COPY
16. Lead concentrate EDIT DELETE Law
20. Sodium Hydroxide,25% EDIT DELETE COPY
13 Manganese Sulfate 10034-96-5 EDrT DELETE COPY
1. Ammonium Chloride 12125-e2-9 EDIT DELETE COPY
22. Sodium Sulfide Solution 10%NaHS 1313-82-2 EDIT DELETE COPY
23. Sodium Sulfide.Flake 1313-82-2 EDIT DELETE COPY
12. Final Zinc Concentrate 13397-24-5 EDrT DELETE COPY
3. BiCar Sodium Bicarbonate Industrial Grade 144-55-8 EDIT DELETE COPY
24. Strontium Carbonate 1633-0s2 EDIT DELETE COPY
a. ❑EPHA(Bis-2-ethylhexyl ester)Phosphoric Acid 29a-07-7 EDIT DELETE COPY
5. Cationic Polyac ylamide(InnoOoc 5627&4000) 64742-47-e EDIT DELETE COPY
10_ Escaid 110 Fluid 6474237-8 EDIT DELETE COPY
9. Diesel Fuel 60476-34-G EDIT DELETE COPY
17. Manganese Dioxide(Anode Scale) 69012-43-1 EDIT DELETE COPY
7. Crude Zinc Oxide or Waelx Oxide 69012-63-1 EDIT DELETE COPY
4. Carbon,Activated 744e-4A-0 EDIT DELETE COPY
6. Course Zinc Granular 7440-66-6 EDIT DELETE Law
27. U ltraPure Zinc Dust 7446-66-6 EDIT DELETE COPY
14. HydrochlodcAcid-35%,33%,20%&5% 7647-01-0 EDIT DELETE COPY
25_ Sulfuric Acid 20%&32% 7654-93-9 EDIT DELETE COPY
26. Sllll Acid 93% 7664-93-9 EDIT DELETE COPY
21. Sodium Hypochlodte 10-20% 7691-52-9 EDIT DELETE COPY
11. Ferric Chloride(40%) 7795-0" EDIT DELETE COPY
is. Hydrogen Peroxide 35% 7722-84-1 EDIT DELETE COPY
2. Arabic Gum 9MC-01-5 EDIT DELETE COPY
19_ Partite 93763-7fl-3 EDIT DELETE COPY
BEFESA

Stormwater Pollution Prevention Plan (SWPPP)
13 Ell !!S
STORMWATER POLLUTION
PREVENTION PLAN
For:
BEFESA ZINC METAL (BZM)
484 HICKS GROVE ROAD
MOORESBORO, NORTH CAROLINA, 28114
ENVIRONMENTAL MANAGEMENT PLAN CONTACTS
William White
Environmental Compliance Manager
Office: 828-919-3246 1 Cell: 704-692-3476
William.whitePbefesa.com
1

Stormwater Pollution Prevention Plan (SWPPP)
EXECUTIVE SUMMARY
This organization specific Environmental Management Plan (EMP) was developed using the
Environmental Protection Agencies (EPA) Industrial Stormwater Pollution Prevention Plan
(SWPPP) template. This plan is not an exhaustive inventory of all stormwater requirements
and practices.Where applicable, external resources including federal, state,local and permit
requirements are referenced.
This SWPPP is optimized to be accessed and viewed electronically and is the preferred
method for publication viewing. Access for viewing of this SWPPP can be coordinated
through the SWPPP contacts listed on page 8.
This SWPPP may differ in format and organization from other templates developed by
regulatory agencies or other organizations. If applicable, a cross-reference table of sections
is included below to simplify review.
This SWPPP (with the exception of any confidential business or restricted information)
shall be made available to Befesa Zinc Metal employees and for internal or external
inspection.
2

Stormwater Pollution Prevention Plan (SWPPP)
TABLE OF CONTENTS
EXECUTIVE SUMMARY.....................................................................................................................................2
CERTIFICATION...................................................................................................................................................5
SWPPP DOCUMENT CONTROL.....................................................................................................................6
SECTION 1: INTRODUCTION..........................................................................................................................7
1.1 Environmental Management System...........................................................................................7
1.2 Roles and Responsibility Information........................................................................................8
SECTION 2: SITE CHARICTERISTICS....................................................................................................... 10
2.0 Site History............................................................................................................................................. 10
2.1 Site Physical Setting........................................................................................................................... 11
2.2 Geology and Soil Properties.......................................................................................................... 11
2.2 Hydrology and Drainage Patterns.............................................................................................. 12
SECTION 3: POTENTIAL POLLUTANT SOURCE AREAS................................................................. 13
SECTION 4: STORMWATER CONTROL MEASURES &BEST MANAGEMENT PRACTICES
................................................................................................................................................................................... 15
4.1 Non-Structural BMPs.......................................................................................................................... 15
4.1.1 Maintain Riparian Corridors/Buffers.................................................................................. 16
4.1.2 Protection of Sensitive and Special Value Features...................................................... 16
4.1.3 Protection and Utilization of Natural Flow Pathways ................................................. 17
4.1.4 Minimize Total Disturbed Areas from Reduced Site Grading.................................. 18
4.1.5 Minimize Soil Compaction and Erosion............................................................................... 18
4.1.6 Re-Vegetate and Re-Forest Disturbed Areas....................................................................20
4.1.7 Reduce Street and Parking Imperviousness.....................................................................20
4.1.8 Disconnection from Storm Sewers.........................................................................................21
4.1.9 Street Sweeping................................................................................................................................21
4.2 Structural BMPs....................................................................................................................................22
4.2.1 Vegetated Swales.............................................................................................................................23
4.2.2 Bioretention and Rain Gardens...............................................................................................23
4.2.3 Vegetated Filter Strips..................................................................................................................24
4.2.4 Constructed Filters.........................................................................................................................24
4.2.5 Wet Ponds ...........................................................................................................................................24
4.2.6 Water Quality Filters and Hydrodynamic Devices........................................................25
4.2.6 Runoff Capture and Reuse..........................................................................................................25
SECTION 5: MONITORING, REPORTING AND RECORD KEEPING............................................26
3

Storrawater Pollution Prevention Plan (SWPPP)
5.1 Storm Event Definition......................................................................................................................26
5.2 Sampling Data Summary..................................................................................................................26
5.3 Quantitative Monitoring..................................................................................................................27
4.2 Qualitative (Visual) Monitoring..................................................................................................28
4.3 Inspections .............................................................................................................................................29
4.10 Employee Training..........................................................................................................................29
4.11 Record Keeping.................................................................................................................................30
SECTION 6: SPILL RESPONSE PROCEDURES RELATED TO STORMWATER.......................31
SECTION 7: DOCUMENTATION TO SUPPORT ELIGIBILITY UNDER OTHER LAWS.........31
SECTION 8: BEFESA ZINC METAL SPECIFIC CONTENT..................................................................32
8.1 Feasibility Study..................................................................................................................................32
8.2 Evaluation of Stormwater Discharge Outfalls......................................................................32
8.3 Secondary Containment Plan........................................................................................................33
8.4 Preventative Maintenance/Good Housekeeping Program (PMGHP)......................34
FIGURE 1-1: Web Soil Survey Map..............................................................................................................i
FIGURE 1-2: U.S. EPA WATERS GeoViewer Map..................................................................................ii
FIGURE 1-3: Stormwater Conveyance System Map.........................................................................iii
FIGURE 1-4: Delineated Stream/Wetlands Location Map............................................................iv
FIGURE 1-5: Site Drainage Area Map........................................................................................................v
FIGURE 1-6: Discharge Location Map .....................................................................................................vi
ATTACHMENT A: Significant Spill History...........................................................................................vii
ATTACHMENT B: Tier Action Log History.........................................................................................viii
4

Stornlvvater Pollution Prevention Plan (SWPPP)
CERTIFICATION
This section contains the annual certification that all stormwater outfalls have been
evaluated for the presence of non-stormwater discharges, signed by the appropriate
responsible official. Additionally, this section will serve as the annual recertification of the
Befesa Zinc Metal SWPPP.
By signing below, I certify under penalty of the law that this document and all attachments
were prepared under my direction or supervision in accordance with (IAW) a system
designed to assure that qualified personnel properly gathered and evaluated the information
submitted. Based on my inquiry of the person or persons who manage the system, of 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.
Responsible Official Certification
Printed Name: Date:
�>��Signature: � Title: LhV;t0hJAev14'0.[ �avttp(�ah�e- �tavla�2'r
5

Stormwater Pollution Prevention Plan (SWPPP)
SWPPP DOCUMENT CONTROL
Standardized Template
The standard content in this document is reviewed periodically,updated as appropriate,and
approved by the Befesa Zinc Metal Water Quality Subject Matter Expert (SME) and
Responsible Official.
This version is current as of 05/30/23 and supersedes all previous versions.
Record of Updates - The document is a "living" document and is required to be modified
and updated, as necessary, in response to corrective actions and deadlines.
Page/Section Nature of Change Date of Change Approved B
Record of Annual Review - This document is reviewed annually IAW applicable permit
requirements.
Page/Section Nature of Change Date of Change Approved B
Version Table - A new version of the plan is created when changes are incorporated that
cause the need to publish a new version of this document. Below is a list of all various
updated under the current permit.
Version Description Date
V.1 SWPPP Initial Rewrite 30 May 2023
6

Stormwater Pollution Prevention Plan (SWPPP)
SECTION 1: INTRODUCTION
This SWPPP is a living document that outlines the procedures Befesa Zinc Metal personnel
follow to prevent discharges of potential pollution to stormwater resulting from industrial
operations. The document is designed to be flexible and will be updated to reflect the
changing conditions of the facility. The procedures outlined in the SWPPP are intended to
minimize the risk of industrial stormwater pollution in drainage areas located within Befesa
Zinc Metal boundaries. The SWPPP describes:
• Identification and evaluation of activities and potential stormwater pollution sources
• Identification and implementation of stormwater Best Management Practices (BMPs)
• Pollution reduction measures and procedures
• Monitoring and inspection procedures
The Befesa Zinc Metal Stormwater Pollution Prevention Team (SWPPT) is responsible for
developing, implementing, and managing the SWPPP.
1.1 Environmental Management System
Befesa Zinc Metal adheres to the Environmental Management System (EMS) framework and
its Plan, Do, Check,Act cycle for ensuring companywide success. Befesa Zinc US Inc. and the
International Organization for Standardization (ISO) 14001 standard provide guidance on
how environmental management programs (EMPs) should be established, implemented,
and maintained to operate under the EMS framework.
In accordance with the Befesa Zinc US Inc. EMS framework, the stormwater program
employs EMS-based processes to achieve compliance will all legal obligations and current
policy drivers, effectively manage associated risks and instill a culture of continual
improvement. This plan serves as an administrative operational control that defines
compliance-related activities and processes.
7

Stormwater Pollution Prevention Plan (SWPPP)
1.2 Roles and Responsibility Information
Scope of Plan Befesa Zinc Metal
Facility Operator Address: 484 Hicks Grove Road
City, State, Zip Code: Mooresboro, North Carolina, 28114
Latitude/Longitude: 36°11'36" N / -81°50'59" W
Office of Primary OPR: Befesa Zinc Metal Environmental Department
Responsibility
The OPR has overall responsibility for implementing this
plan and is the lead organization for monitoring compliance
with applicable federal, state, and local regulations.
Responsible Name: Kobus de Wet
Official/Legally Title: General Manager
Responsible Person Phone: W: [phone] 1 C: [phone]
Email: [e-mail]
Program Manager Name: William White
Title: Environmental Compliance Manager
Phone: W: [phone] 1 C: [phone]
Email: [e-mail]
Permitting Authority North Carolina Department of Environmental Quality
(NCDEQ)
Department of Environment and Natural Resources Division
of Energy, Mineral, and Land Resources
Permit Type National Pollutant Discharge Elimination System (NPDES)
Permit Number/Permit NCS000562
Tracking Number
Industrial Activity SIC 3341
Code(s)
NAICS 331492
Permit Expiration Date April 30, 2023 (New Permit is under review by NCDEQ)
General Location Map Located in Figure 1-6
Site Map Located in Figure 1-4
The SWPPP requires the involvement of multiple organizations and varied personnel
within the Befesa Zinc Metal construct, including contractors and other outside
8

Stormwater Pollution Prevention Plan (SWPPP)
organizations. The major roles/organizations involved in supporting the SWPPP at Befesa
Zinc Metal include:
• Befesa Zinc Metal General Manager
• Environmental Manager
• Site Execution Manager
• Stormwater Pollution Prevention Team
• Environmental Specialists
• General Employees
Organizational and personnel roles and responsibilities are described through this SWPPP
and in referenced documents.
Befesa Zinc Metal Stormwater Pollution Prevention Team
Ultimately, the General Manager is responsible for all activities at Befesa Zinc Metal,
including SWPPP implementation. The Environmental Manager has been designated as the
responsible party and signatory for environmental matters and supports the General
Manager.
Responsibility for preventing stormwater pollution at Befesa Zinc Metal lies with all
employees, but the Befesa Zinc Metal Pollution Prevention Team (SWPPT) is primarily
responsible for executing the Stormwater Pollution Prevention Plan (SWPPP). The team
consists of three categories of members: the Environmental Manager, the SWPPT, and
Support Team members. The Environmental Manager and/or the Water Quality Program
Manager,along with the support team members,have primary responsibilities in developing
and implementing the SWPPP. The following is a brief description of each of the three
categories of the Pollution Prevention Team.
Environmental Manager
• Serves as the authorized representative of the General Manager in achieving compliance
with stormwater regulations.
• Leads the SWPPT in stormwater management planning and provides information
regarding stormwater management to the General Manager.
• Responsible for final certification,implementation, reporting and inspection of all aspects
of the SWPPP as required by federal, state, and local laws and authorities.
• Responsible for obtaining/maintaining all permits related to discharging industrial
stormwater.
• Coordinates inspections, monitoring and sampling activities to maintain and improve
stormwater pollution prevention.
9

Stormwater Pollution Prevention Plan (SWPPP)
• Supports training efforts relative to stormwater pollution prevention and ensuring
integration of these concepts into related environmental management training.
• Develops BMPs to reduce/eliminate potential pollutant sources and risks.
Note:The General Manager may delegate signature authority for all reports required by the
applicable permits to a duly authorized representative, if the authorization is made in
writing and submitted to the appropriate regulatory agency.
SWPPT
The SWPPT will consist of subject matter experts (SME) in key Befesa Zinc Metal leadership
positions that can provide environmental, engineering/construction, training, and safety
expertise regarding stormwater management. The SWPPT will convene at least annually to
review and discuss matters pertaining to stormwater management. Meeting notes will be
filed as a matter of record IAW permit record keeping requirements.
SWPPT Members
Environmental Manager Leads the SWPPT/facilitates discussion on stormwater
management
Site Execution Manager Provides facility construction feasibility and expertise
Senior Engineer Provides engineering feasibility expertise to BMP
implementation
Safety Manager Provides spill response and emergency management
expertise
Training Manager Provides feasibility of employee engagement and training
Environmental Team Provide environmental knowledge taken from the field
Support Team
The Support Team members consist of program managers and representatives of various
groups from Befesa Zinc Metal. The Support Team members will assist in providing the
required information to be included in the SWPPP. The Support Team members will also aid
in implementing and ensuring compliance with the elements established in the SWPPP.
SECTION 2: SITE CHARICTERISTICS
2.0 Site History
Befesa Zinc Metal is located in Rutherford County, North Carolina, in close proximity to the
city of Forest City and approximately 70 miles west of Charlotte. The site was not developed
until the 1900s, and by the 1920s, agricultural land and residential structures had appeared
on the south side of the site. In 1924, the railroad and Hicks Grove Road were constructed
10

Stormwater Pollution Prevention Plan (SWPPP)
across the site. The location remained largely wooded and undeveloped until 2011, when
construction began on the facility. In 2014, Horsehead Metal Products, LLC commenced
operations on the site, which ceased in February 2016. In early 2017, the corporate family
underwent a rebranding as "American Zinc Recycling," and Horsehead Metal Products was
renamed "American Zinc Products." Operations resumed in 2019, but a fire in April of that
year resulted in severe damage to the facility, leading to a portion of the plant being
demolished. Renovations and improvements were undertaken, and operations resumed in
February 2020.The company was acquired by Befesa in 2022 and rebranded as "Befesa Zinc
Metal."
The Befesa Zinc Metal facility is dedicated to the production of hydrometallurgical zinc metal,
primarily using Waelz Oxide (WOX) as the feedstock. WOX, which contains approximately
60% zinc, is produced by processing electric arc furnace (EAF) dust, a hazardous waste, in
Waelz kilns. At the facility, WOX is dissolved in an acidic solution, and the zinc is selectively
transferred to a solvent solution and then to another acidic electrolyte solution before being
plated onto cathodes in a cellhouse. Zinc metal sheets harvested from the cathodes are
melted and cast into ingots for shipping. Supporting departments at the facility include
environmental, maintenance, engineering, laboratory, human resources, logistics,
purchasing, and customer service.
2.1 Site Physical Setting
North Carolina is situated within the southeastern United States and can be divided into
three primary physiographic provinces based on topography and geology: the Blue Ridge,
the Piedmont, and the Coastal Plain. The Blue Ridge province is characterized by
mountainous terrain, while the Piedmont is a high plateau located in the central portion of
the state and extends from the overall Appalachian region.The Coastal Plain is situated along
the eastern edge of the Piedmont and stretches to the coast. The Befesa Zinc Metal facility is
located in Rutherford County, North Carolina, within the Piedmont region, near the
boundary between the Blue Ridge and the Piedmont provinces. Additional information on
the physiographic regions of North Carolina can be found on the United States Geographic
Services website.
2.2 Geology and Soil Properties
The physiography of the Befesa Zinc Metal site and the associated soil types based on
location are presented in Figure 11=1. Soil descriptions for the site were obtained from the
Natural Resources Conservation Service Web Soil Survev database of the United States
Department of Agriculture.The soil type for the site area is the Pacolet, Cecil,Appling and/or
Madison series,which falls under the category of Piedmont soils.
The typical characteristics of these soils are characterized by being very deep, well-drained,
and moderately permeable. They typically form in residuum weathered from felsic igneous
and metamorphic rocks of the Piedmont uplands.Slopes associated with Pacolet soils usually
11

Stormwater Pollution Prevention Plan (SWPPP)
range from 15 to 25 percent but may range from 2 to 60 percent. The soil horizon profile of
Pacolet soils consists of the following layers:
A Horizon (Surface): Brown sandy loam with few fine, distinct yellowish-red mottles;
moderate medium granular structure; many fine and medium roots; strongly acidic; clear
wavy boundary.
B Horizon (Subsoil): Red clay with reddish-yellow mottles; medium subangular blocky
structure; firm to friable; strongly acidic; gradual wavy boundary.
C Horizon (Substratum): Mottled red and reddish-yellow clay loam saprolite; massive;
friable; thin, discontinuous, distinct clay seams in cracks; few fine flakes of mica; strongly
acidic; gradual wavy boundary.
These soils are well-drained, with a medium to rapid rate of runoff, and a moderate
permeability rating.The soil type and characteristics of the site are important considerations
for stormwater management and remediation efforts at the Befesa Zinc Metal facility.
2.2 Hydrology and Drainage Patterns
The Befesa Zinc Metal site's surface water drainage is divided into two basins, with a ridge
or divide running along the path of the former Hicks Grove Road, as revealed by information
obtained from the United States Environmental Protection Agency WATERS database, as
shown in Figure 11=2.The area north of the facility drains into the Broad River,while the area
south of the facility drains into Big Horse Creek. Stormwater generated at the site is either
utilized for process water or directed via an underground pipe to Basin 1 before being
discharged into the Broad River.
A hydrologic assessment of the Befesa Zinc Metal property was conducted by environmental
consultant firm (Hatch) in 2015, to evaluate daily runoff volumes across the site, using
GoldSim software to simulate and compile daily precipitation results for all stormwater
analyses. Precipitation data obtained from the Chesnee climate station spanning from 1929
to 2015,with a median annual rainfall of approximately 50 inches,was used.Extreme rainfall
events ranging between 28 and 77 inches per year were recorded, and there is a 29 percent
chance of rainfall on any given day,with at least six consecutive days with rainfall occurring
annually, and up to 13 consecutive days with rainfall being reported. The National Oceanic
and Atmospheric Administration's Hydro meteorological Design Studies Center's Point
Precipitation Frequency estimates suggest that the average storm event at a 1-year interval
in the region lasts for approximately 1.0 hour, with an intensity of 1.36 inches/hour.
The current onsite stormwater drainage system is depicted in Figure 1-3, comprising a
gravity drainage network of catch basins that direct onsite and offsite stormwater runoff to
appropriate receptacles, including the hard-piped conveyance system. The hard-piped
conveyance system runs parallel to the facility's northeast side and can be accessed via a
12

Stormwater Pollution Prevention Plan (SWPPP)
gravel road leading from the facility to Basin 1, ultimately discharging from a permitted
stormwater discharge outfall (#001) into the Broad River.
Total Maximum Daily Load (TMDL)
The United States Clean Water Act provides for the implementation of the Total Maximum
Daily Load (TMDL) Program, which is designed to address water bodies that do not meet
water quality standards. The program involves calculating the maximum amount of
pollutants a water body can receive while still meeting quality standards. This information
is then used to establish limits on sources of pollutants, which are classified as either point
sources (waste load allocation) or non-point sources (load allocation).As of now,there is no
TMDL for the receiving water, the Broad River, that applies to the stormwater discharges
from Befesa Zinc Metal.For more details,please refer to the North Carolina Division of Water
Resources webpage.
SECTION 3: POTENTIAL POLLUTANT SOURCE AREAS
The EPA has identified six types of activities at industrial facilities that have the potential to
be major sources of pollutants in stormwater(EPA, 2021):
• Loading and Unloading Activities
• Outdoor Storage
• Outdoor Process Activities
• Dust or Particulate Generating Processes
• Illicit Connections and Non-Stormwater Discharges
• Waste Management
The following sections outline the areas at Befesa Zinc Metal where industrial materials or
activities are exposed to storm water. The environmental department maintains records of
noteworthy spills and releases,which can be accessed upon request.
Area 100 - Leaching/Neutralization
Within this area, WOX undergoes a washing process before being introduced into the
leaching unit with zinc skimmings. This results in the dissolution of zinc and other metals in
a solution containing sulfuric acid, recycled hydrochloric acid, and zinc raffinate. The
resultant liquid, known as Pregnant Leaching Solution (PLS), is heated and pumped to Area
200 (Solvent Extraction). Any solid residue from the procedure is retrieved using filter
presses and is directed to the PLINT process, situated in Area 600. The following activities
occur in this area: loading and unloading, outdoor storage, outdoor processing, dust or
particulate generating processes and waste generation.
Area 200 - Solvent Extraction
13

Stormwater Pollution Prevention Plan (SWPPP)
The Solvent Extraction (SX) process is utilized to create an ultra-pure zinc sulfate electrolyte
from the Pregnant Leaching Solution (PLS) produced in Area 100. PLS is combined with an
organic solution to transfer zinc into the organic phase. The organic phase is then separated
and combined with the zinc sulfate electrolyte to transfer zinc in the solution to the
electrolyte solution. Following separation, the loaded electrolyte solution is directed to the
cell house (Area 400), where zinc metal is produced. Moreover, several supplementary
procedures in the plant facilitate the regeneration of solutions for use in the SX process and
recovery of solid materials from the SX process. The following activities occur in this area:
outdoor storage,waste generation.
Area 300 - Bleed Treatment
Area 300 undertakes the treatment of aqueous raffinate from the SX processes (Area 200) to
impede the accumulation of soluble impurities in the leaching circuit while also retrieving
valuable metals and residues from effluent solutions. This treatment process incorporates
several steps, including gypsum precipitation, cementation, bleed treatment, and final
treatment. The following activities occur in this area: loading and unloading, outdoor
storage, outdoor processing, dust or particulate generating processes and waste generation.
Area 400 - Electrowinning (Cell House)
Area 400 is where the electrowinning (EW) cell house is located, where the zinc-loaded
electrolyte solution generated in the SX process (Area 200) is circulated. The objective is to
produce zinc metal by electrochemical plating of the zinc from the electrolyte solution onto
aluminum cathode sheets. Once the plating process is complete, each cathode is removed
and washed, after which the zinc is mechanically stripped from the surfaces. The following
activities occur in this area: waste generation.
Area 500 - Casting
The stripped zinc is transported to the casting area where it is melted and cast into ingots of
various sizes. Additionally, zinc alloys are also manufactured in this area. The following
activities occur in this area: loading and unloading, outdoor storage, outdoor processing,
dust or particulate generating processes and waste generation.
Area 600 - PUNT
The PLINT process is designed to recover lead and silver from the residues produced during
the leaching process. This process results in the production of a lead concentrate derived
from the leach residue. The following activities occur in this area: loading and unloading,
outdoor storage, outdoor processing, and waste generation.
Area 700 - Reagents Preparation and Distribution
Area 700 is allocated for the preparation and distribution of reagents throughout the facility.
It is also utilized for the storage of oils, solvents, paints, chemical reagents, cleaning agents,
14

Stormwater Pollution Prevention Plan (SWPPP)
antifreeze, and other materials, which are also kept in small amounts in the laboratory,
maintenance, and production facilities. The following activities occur in this area: waste
generation.
SECTION 4: STORMWATER CONTROL MEASURES &BEST MANAGEMENT PRACTICES
The State of North Carolina recommends volume matching or reduction as an alternative to
treating stormwater runoff. Volume matching aims to maintain pre-construction runoff
volumes by implementing design techniques that filter, store, infiltrate, detain, and
evaporate runoff close to its source. This practice offers both environmental and economic
benefits while preserving the natural hydrology of the site. Commonly used techniques
include vegetation, permeable pavement, disconnected impervious surfaces, infiltration
systems, rainwater harvesting, and green roofs.
Befesa Zinc Metal has adopted a stormwater control strategy that aligns with North
Carolina's volume matching principles as much as possible,while minimizing or eliminating
point source discharges to the stormwater drainage system from industrial activities.This is
achieved by limiting the contact of stormwater with industrial activities and pollutants. The
company has implemented structural and non-structural Stormwater Control Measures
(SCMs) and Best Management Practices (BMPs) across several categories, as outlined by the
USEPA National Menu of Best Management Practices for Stormwater, to meet all relevant
permit effluent limits. These categories encompass schedules of activities, prohibitions of
practices, maintenance procedures, treatment requirements, operating procedures, and
practices to control site runoff, spillage or leaks, sludge or waste disposal, or drainage from
raw materials storage.
Befesa Zinc Metal will implement the following SCMs and BMPs to the maximum extent
possible,while also considering their feasibility. The locations of all implemented BMPs will
be tracked and displayed on a variety of tools,including online mapping programs,to ensure
that they are managed effectively. The data will be conveyed in a way that addresses any
SCMs or BMPs that may become inadequate over time. The feasibility of all SCMs and BMPs
will be analyzed on an annual basis and will be included as an attachment in this document.
By implementing these practices, Befesa Zinc Metal aims to reduce the impact of industrial
activities on the surrounding environment and maintain compliance with regulatory
standards.
4.1 Non-Structural BMPs
The most effective way to manage stormwater begins with the prevention of problems. Non-
structural BMPs, sometimes called Low Impact Development (LID) techniques include
design approaches and practices that are used for their ability to prevent the occurrence of
stormwater runoff. Utilizing non-structural BMPs during site development is much more
efficient and cost-effective than attempting to correct problems after development has
occurred.
15

Stormwater Pollution Prevention Plan (SWPPP)
4.1.1 Maintain Riparian Corridors/Buffers
The riparian corridor is an important component of aquatic ecosystems, encompassing the
body of water (e.g., streams, rivers, ponds, or lakes), its upper and lower banks, and the
vegetation that stabilizes the adjacent land. This zone, also referred to as a "riparian buffer,"
serves as a transition between aquatic and upland environments and supports high species
diversity, density, and bio-productivity. The preservation and restoration of riparian
corridors/buffers is essential for improving water quality, reducing soil erosion, providing
habitat and food for aquatic organisms and wildlife,and mitigating the impacts of floods.The
riparian corridors/buffers at Befesa Zinc Metal include areas along the following waterways:
Broad River and un-named tributaries (UT) one and four. Befesa Zinc Metal recognizes the
importance of protecting and restoring these riparian corridors/buffers and aims to
undertake the following measures,whenever feasible:
• Reestablishing Buffer Areas: Restore the buffer areas along perennial, intermittent, and
ephemeral streams that may have been lost or degraded due to facility activities. The
restoration efforts will aim to maintain the natural vegetation of the buffer zone and
restore any damaged areas.
• Planting Native, Diverse Vegetation: Plant native, diverse tree and shrub vegetation that
is appropriate for the local ecosystem. This will help to improve the structural and
functional characteristics of the buffer zone, enhancing its ability to filter out storm water
pollutants and retain floodwater.
• Creating Maintenance Plans: Create both short-term and long-term maintenance plans to
ensure the success of the restoration efforts. The short-term plan will focus on post-
planting care, while the long-term plan will include monitoring, maintenance, and
adaptive management to ensure the health and sustainability of the buffer zone.
• Clear and Well-Marked Boundaries: Ensure that the buffer zone is clearly marked and free
of encroachment from adjacent land uses. This will ensure that the buffer zone remains
intact and fully functional.
4.1.2 Protection of Sensitive and Special Value Features
To minimize the negative impacts of stormwater on the environment, land development
should avoid areas with important natural stormwater functional values and stormwater
impact sensitivities.Sensitive/special value resources such as floodplains,wetlands,riparian
areas, drainageways, steep slopes, and adjoining properties play a crucial role in mitigating
stormwater impacts. The objective of this BMP to avoid harming sensitive/special value
resources during land development. Befesa Zinc Metal recognizes the importance of
protecting sensitive/special value resources and aims to undertake the following measures,
whenever feasible:
• Identify and Map Floodplains and Riparian Areas: Floodplains and riparian areas are
critical for mitigating the impacts of stormwater. Befesa Zinc Metal will identify and map
these areas to avoid encroaching upon them during land development.
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Stormwater Pollution Prevention Plan (SWPPP)
• Identify and Map Wetlands: Wetlands are valuable for retaining stormwater and filtering
pollutants. Befesa Zinc Metal will identify and map these areas to avoid their loss during
land development.
• Identify and Map Woodlands: Woodlands provide important ecosystem services, such as
carbon sequestration and wildlife habitat. Befesa Zinc Metal will identify and map these
areas to avoid their destruction during land development.
• Identify and Map Natural Flow Pathways/Drainage Ways: Natural flow pathways and
drainage ways are important for directing stormwater flow and preventing erosion.
Befesa Zinc Metal will identify and map these areas to avoid their disruption during land
development.
• Identify and Map Steep Slopes: Steep slopes are susceptible to erosion, which can result
in significant stormwater impacts. Befesa Zinc Metal will identify and map these areas to
avoid their disturbance during land development.
• Identify and Map Other Sensitive Resources: Other sensitive resources, such as cultural
and historical sites, may have important ecological functions. Befesa Zinc Metal will
identify and map these areas to avoid their loss during land development.
4.1.3 Protection and Utilization of Natural Flow Pathways
Natural sites often contain drainage features such as watercourses, swales, depressions,and
ephemeral streams that help to manage the stormwater generated on-site. By identifying,
protecting, and utilizing these features, developers can reduce or eliminate the need for
structural drainage systems that rapidly convey runoff downstream. Befesa Zinc Metal
acknowledges the significance of preserving and using natural flow pathways, and aims to
implement the following measures,whenever feasible:
• Identifying and Mapping Natural Flow Pathways/Drainage Ways: Natural flow pathways
and drainage ways are important for directing stormwater flow and preventing erosion.
Befesa Zinc Metal will identify and map these areas to avoid their disruption during land
development.
• Using Natural Drainage Features to Guide Site Design: Instead of ignoring or replacing
natural drainage features with engineered systems, designers should use these features
to guide site design and minimize the need for structural drainage systems.
• Minimizing Filling, Clearing, or Other Disturbances of Drainage Features: Minimize
disturbances to natural drainage features such as filling, clearing, or other activities that
may affect their natural functioning.
• Distributing Non-Erosive Surface Flow to Natural Drainage Features: Distribute non-
erosive surface flow to natural drainage features to reduce the impacts of stormwater.
• Native Vegetative Buffers Around Drainage Features: Plant native vegetative buffers
around drainage features to stabilize the banks, prevent erosion, and filter pollutants.
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Stormwater Pollution Prevention Plan (SWPPP)
• Inspecting Natural Pathways: Regularly inspect natural pathways to assess erosion, bank
stability, sediment/debris accumulation, and vegetative conditions, including the
presence of invasive species, to ensure the continued functioning of the natural drainage
features.
4.1.4 Minimize Total Disturbed Areas from Reduced Site Grading
This focuses on minimizing grading and overall site disturbance during land development,
while maximizing conservation of existing vegetation. Grading for roadway alignment and
slope requirements can increase site disturbance, especially in areas with topographic
variation. Land development plans are often formulated as 2-dimensional plans that do not
consider topographic constraints. The design of internal roadways and infrastructure on
sloped land development sites can result in extensive earthwork and vegetation removal,
requiring significant grading. Site design can be less disruptive if it conforms to the existing
topography, with road alignments following existing contours as much as possible, varying
the grade and alignment criteria as necessary for safety. Minimizing the total disturbed area
can reduce the volume of runoff through increased infiltration and evapotranspiration.
Preventively, minimizing total disturbed area can also improve water quality by reducing
sediment-laden runoff during the construction phase. Befesa Zinc Metal acknowledges the
significance of minimizing disturbed areas caused by grading, and aims to implement the
following measures,whenever feasible:
• Identify and avoid special value and environmentally sensitive areas.
• Minimize the overall disturbance at the site.
• Minimize the disturbance at the individual area level.
• Maximize soil restoration to restore permeability
• Minimize construction traffic locations
• Minimize stockpiling and storage areas.
4.1.5 Minimize Soil Compaction and Erosion
Soil is a complex physical matrix that comprises weathered rock particles and organic
matter, which provides a habitat for a diverse biological community. The physical and
chemical properties of soil vary significantly within different regions due to the long-term
development process. Healthy soils perform valuable stormwater functions such as nutrient
cycling,runoff and erosion minimization,water-holding capacity maximization,storm runoff
surge reduction, excess nutrient, sediment, and pollutant adsorption and filtering,providing
a healthy root environment, habitat for microbes, plants, and animals, and reducing
resources needed to maintain turf and landscape plantings. However, once natural soils are
overly compacted and permeability is drastically reduced, these functions are lost and
cannot be completely restored. Therefore, it is essential to implement BMPs to prevent or
minimize soil compaction in areas intended to be "pervious" following development. Befesa
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Stormwater Pollution Prevention Plan (SWPPP)
Zinc Metal recognizes the significance of minimizing soil compaction and aims to implement
the following measures whenever feasible:
• Protect disturbed soil areas from excessive compaction during construction.
• Minimize large, cleared areas and stockpiling of topsoil.
• Use quality topsoil during projects.
• Maximize soil restoration to restore permeability.
• Minimize construction traffic locations.
• Minimize stockpiling and storage areas.
Additionally, Befesa Zinc Metal is committed to reducing soil erosion and sedimentation on-
site. Erosion potential is influenced by four key factors: soils, surface cover,topography, and
climate, which are interrelated in their effect on erosion potential. The erodibility of a soil,
or its susceptibility to erosion, depends on several soil characteristics that can be divided
into two groups: those influencing infiltration, the movement of water into the ground, and
those affecting the resistance to detachment and transport by rainfall and runoff. Soil is a
highly complex system that provides essential environmental benefits such as biofiltration
of pollutants, nutrients for plant growth, storage, and slow release of storm flows. The fate
of the hydrologic system is primarily dependent on soil properties, including texture,
structure, organic matter content, biota, and depth. Soil porosity and structure determine
the soil's ability to store and slowly release water, which is essential in reducing water loss,
utilization, contamination, and purification. Soil stability and porosity are contributed to by
plant roots, macro fauna, and microbes, which physically and chemically bond soil particles
and form stable aggregates. Vegetation is the most effective means of stabilizing soils and
controlling erosion. It shields the soil surface from the impact of falling rain, reduces flow
velocity, and disperses flow. Vegetation provides a rough surface that slows the runoff
velocity and promotes infiltration and deposition of sediment. Additionally, organic matter
is a vital ingredient for soil function, as it absorbs water, physically separates clay and silt
particles, reduces erosion, and replenishes nutrients for vegetation and microbial growth.
Natural erosion occurs primarily on a geologic time scale,but industrial activities can greatly
accelerate the erosion process when they alter the landscape. Construction activities disturb
the soil by removing the upper layers, compacting exposed subsoils with low organic matter,
and altering the site's hydrologic characteristics by converting the predominantly
subsurface flow regime to primarily overland flow. Befesa Zinc Metal ensures that site
personnel and project managers are informed of the relevant stormwater requirements
related to erosion control and the importance of adhering to established stormwater plans
and BMPs. By following these BMPs, Befesa Zinc Metal seeks to reduce the impact of
construction activities on the physical and chemical properties of soil and protect its
essential functions.
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Stormwater Pollution Prevention Plan (SWPPP)
4.1.6 Re-Vegetate and Re-Forest Disturbed Areas
This Best Management Practice (BMP) emphasizes the importance of re-vegetating
disturbed areas with native plant species, including grasses, shrubs, and trees. By utilizing
plant species that are adapted to local climatic and environmental conditions, it is possible
to reduce the need for fertilizers and pesticides, while increasing the chances of successful
establishment and growth. Furthermore, established native plantings offer significant
stormwater benefits, including volume and rate reduction and improvements in water
quality. The first step in re-vegetation efforts is to preserve the existing vegetation on the
development site wherever possible, in order to minimize the need for subsequent
landscaping and re-vegetation efforts. However, in cases where re-vegetation is necessary,
this BMP emphasizes the selection and use of plant species that do not require significant
chemical maintenance, including fertilizers, herbicides, and pesticides. This is based on the
assumption that native species are the most tolerant and resistant to pests and require less
chemical application and fertilization than non-native species. Befesa Zinc Metal
acknowledges the significance of re-vegetating disturbed areas and is committed to
implementing the following measures whenever feasible:
• Preserve all existing high-quality plant materials and soil mantle whenever possible, as
they play a crucial role in supporting the overall ecosystem of the site.
• Protect these areas during construction activities, in order to minimize soil compaction
and other disturbances that may harm the existing vegetation.
• Develop landscape plans during projects that utilizes native species, in order to enhance
the ecological value of the site and promote successful establishment and growth.
• Reduce landscape maintenance, particularly grass mowing, in order to minimize the need
for fertilizers and herbicides.
• Reduce or eliminate chemical applications to the site wherever possible, in order to
minimize the environmental impact and promote the use of sustainable practices.
• Reduce or eliminate fertilizer and chemical-based pest control programs, wherever
possible, in order to promote the use of natural and sustainable alternatives.
4.1.7 Reduce Street and Parking Imperviousness
An effective approach to reducing stormwater runoff and improving water quality is through
the reduction of impervious surfaces such as streets and parking areas.Reducing impervious
street areas performs valuable stormwater functions, in contrast to conventional or baseline
development. Innovative planning can lead to numerous benefits, including increased
infiltration, decreased stormwater volume, pollutant load reduction, and preservation of
natural habitats. Imperviousness greatly influences stormwater runoff volume and quality
by facilitating the rapid transport of stormwater and collecting pollutants from various
sources. Increased imperviousness alters an area's hydrology, habitat structure, and water
quality. Therefore, reducing impervious areas is crucial for effective stormwater pollution
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Stormwater Pollution Prevention Plan (SWPPP)
control. Befesa Zinc Metal recognizes the importance of reducing impervious areas and aims
to implement the following measures whenever feasible:
• Evaluate traffic volume and on-street parking requirements to determine the minimum
amount of impervious area needed.
• Minimize pavement by using alternative roadway layouts, restricting on-street parking,
minimizing cul-de-sac or turn around radii, and using permeable pavers.
4.1.8 Disconnection from Storm Sewers
Stormwater generated from impervious areas, such as roads and driveways, is a major
contributor to stormwater pollution. Conventional stormwater management has involved
the rapid removal and conveyance of stormwater from these surfaces. However, this
management system has resulted in increased runoff volume, decreased time of
concentration, and greater pollutant mobility. Therefore, it is necessary to implement
innovative stormwater pollution control measures to minimize these negative impacts. One
such measure is disconnecting stormwater generated from impervious areas from storm
sewers and directing it towards structural BMPs such as bio-infiltration areas. Routing road
and driveway runoff to vegetated swales can reduce runoff volume and peak discharge, as
well as improve water quality by slowing runoff, allowing for filtration, and providing
opportunities for infiltration and evapotranspiration. Distributed stormwater management
through the use of vegetated swales and bioretention areas can reduce the volume of
stormwater runoff while providing on-site treatment and pollutant removal. Befesa Zinc
Metal recognizes the significance of disconnection from storm sewers and aims to implement
the following measures whenever feasible:
• Disconnect road and driveways from stormwater collection systems.
• Redirect road and driveway runoff into grassed swales or other vegetated systems
designed to receive stormwater.
• Eliminate curbs/gutters/conventional collection and conveyance.
4.1.9 Street Sweeping
Streets, roads, highways and parking lots are a significant source of water pollution due to
the accumulation of pollutants, which are often combined with stormwater runoff, leading
to water quality impacts. Street sweeping has been identified as an effective strategy to
minimize these pollutants, including sediment, debris, yard waste, trash, deicing materials
and trace metals. The EPA estimates that at least 75% of the ERA Level 1 evaluations result
in a recommendation for increased site sweeping, especially for Total Suspended Solids
(TSS) issues and particulate metal exceedances (e.g., zinc and copper) in industrial
stormwater. Good housekeeping via site sweeping works extremely well to address this
issue. The effectiveness of street sweeping is primarily dependent upon the frequency of
sweeping and the interval between storms. Other factors in order of importance are: total
mass of the area to be swept and its relation to loadings on other areas not accessible to
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Stormwater Pollution Prevention Plan (SWPPP)
sweepers; the efficiency of sweepers compared to the storm runoff of the pollutant of
interest; and local storm characteristics. Befesa Zinc Metal recognizes the significance of
sweeping and aims to implement the following measures whenever feasible:
• Using proper equipment: Vacuum-assisted and regenerative air sweepers are generally
more efficient than mechanical sweepers at removing finer sediments,which often bind a
higher proportion of heavy metals. The performance of sweepers can be enhanced by
operating them at optimal speeds (6 to 8 mi/hr.), ensuring that brushes are properly
adjusted, and ensuring that appropriate rotation rates and sweeping patterns are used.
The EPA and state level agencies have tested the efficiency of street sweeping for an
extended length of time. Studies conducted on the newer vacuum-assisted dry sweepers
have shown they have significantly enhanced capabilities to remove sediment compared
to conventional sweepers, with projected reductions of up to 79 percent in total
suspended solids loadings from urban streets. In addition, these sweepers are extremely
effective at removing respirable (PM-10) particulate matter (particles with an
aerodynamic diameter less than or equal to 10 microns) compared to conventional
sweepers and are designed to help meet National Ambient Air Quality standards. As an
example, Table 1 demonstrates the efficiency of sweeping in Northern Virginia and was
published in the states BMP manual. More literature on this topic is available on both the
EPA's National Menu of BMPs for Stormwater and state level environmental quality
webpages.
Table 1
Constituent Mechanical Sweeper Efficiency(%) Vacuum-assisted Sweeper Efficiency(%)
Total Solids 55 93
Total Phosphorus 40 74
Total Nitrogen 42 77
COD 31 63
BOD 43 77
Lead 35 76
Zinc 47 85
Northern Virginia BMP Handbook
• Develop a proper program: Vary sweeping frequency by street pollutant load (a function
of road type, traffic, adjacent land uses and other factors); sweep roads with curbs and
gutters after heavy rains in which sediment is present on the roads, in drains or in
stormwater swales.
4.2 Structural BMPs
The EPA defines structural BMPs as "stationary and permanent BMPs that are designed,
constructed, and operated to prevent or reduce the discharge of pollutants in stormwater".
Structural BMPs include a wide range of engineered systems, such as retention ponds,
infiltration basins, and permeable pavement,as well as natural systems, such as constructed
wetlands and bioretention areas. Structural BMPs are effective in reducing the quantity and
improving the quality of stormwater runoff. By slowing down and filtering stormwater,
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Stormwater Pollution Prevention Plan (SWPPP)
structural BMPs can prevent or reduce the transport of pollutants into nearby waterways. In
addition, consideration will be given to selecting appropriate plant species for structural
BMPs that are well-suited for slowing flow or uptake of pollutants, such as cattails or other
relevant vegetation.
4.2.1 Vegetated Swales
Vegetated swales, also known as bioswales, are an effective and environmentally superior
alternative to conventional curb and gutter conveyance systems for stormwater
management. These broad channels are designed to slow runoff, promote infiltration, and
filter pollutants and sediments,while providing peak rate control.Vegetated swales can also
attenuate and sometimes infiltrate flow, thereby improving water quality. The swales are
often heavily vegetated with a dense and diverse selection of native, close-growing, water-
resistant plants with high pollutant removal potential.The effectiveness of a vegetated swale
is directly related to various factors such as the contributing land use,the size of the drainage
area, soil type, slope, drainage area imperviousness, proposed vegetation, and swale
dimensions. Swales may be suited for use in natural low points in the topography or natural
drainage courses, but infiltration capability may be reduced in these situations. It is
important to ensure that the topography of a site allows for the design of a swale with a
sufficiently mild slope and flow capacity,as swales are impractical in areas of extreme slopes.
Adequate space is also necessary for the construction of vegetated swales. The various
pollutant removal mechanisms of a swale include sedimentary filtering by the vegetation on
both side slopes and the bottom, filtering through a subsoil matrix, and/or infiltration into
the underlying soils with the full array of infiltration-oriented pollutant removal
mechanisms. The use of check dams may be necessary in sloped areas to enhance the
stormwater management functions of vegetated swales. Befesa Zinc Metal recognizes the
significance of vegetated swales and aims to implement them whenever feasible.
4.2.2 Bioretention and Rain Gardens
A rain garden is an engineered, landscaped area designed to mitigate stormwater runoff by
capturing and infiltrating rainwater from impervious surfaces such as roofs, driveways, and
lawns. It is typically planted with a diverse array of native wildflowers and vegetation that
provide multiple benefits to the surrounding environment. Bioretention is a related method
that employs pooling of water on the surface for settling of suspended solids and sediment
at the mulch layer, followed by infiltration and pollutant removal in the plant-soil-microbe
complex media. Bioretention techniques serve to improve water quality and reduce water
quantity. The plants in a rain garden filter and transpire stormwater runoff,while their root
systems enhance infiltration. The soil medium filters out pollutants and stores stormwater,
reducing the amount of runoff entering the sewer system. The bed also provides additional
volume control, thereby reducing the risk of flooding during heavy rainfall events. Properly
designed bioretention systems mimic natural ecosystems with species diversity,density,and
distribution of vegetation. Native species are preferred as they are more resistant to insect
infestations, disease, pollution, and climatic stresses. Bioretention systems are flexible and
can be integrated into a site to balance with other structural and non-structural stormwater
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Stormwater Pollution Prevention Plan (SWPPP)
management systems such as porous asphalt parking lots and infiltration trenches. Befesa
Zinc Metal recognizes the value of bioretention and rain gardens and is committed to
implementing them whenever feasible.
4.2.3 Vegetated Filter Strips
Vegetated Filter Strips are an effective method for mitigating nonpoint source pollutants in
stormwater runoff. According to the EPA, a vegetated filter strip is a permanent, well-
maintained strip of vegetation that is planted between nonpoint sources of pollution and
receiving water bodies. The primary function of a vegetated filter strip is to remove or
mitigate the effects of nonpoint source pollutants such as nutrients, pesticides, sediments,
and suspended solids. A vegetated filter strip can include native or indigenous vegetation
such as grasses, shrubs, and trees. Turf grasses are also used sometimes, but their
functionality in stormwater management is limited. In addition to water quality
improvement, a vegetated filter strip can also contribute to volume reduction and ground
water recharge, depending on site conditions such as soil and slope. Depending on
hydrologic soil group, vegetative cover type, slope, and length, a filter strip can allow for a
modest reduction in runoff volume through infiltration. A vegetated filter strip can also
reduce total suspended solid (TSS) levels, and levels of other pollutants such as
hydrocarbons, heavy metals, and nutrients may also be reduced. Befesa Zinc Metal
recognizes the significance of VFS and aims to implement them whenever feasible.
4.2.4 Constructed Filters
A constructed stormwater filter is a structure or excavated area that is filled with material
that filters stormwater. The design of the filter can vary depending on the specific needs of
the site. Some of the variations include vegetated and non-vegetated, infiltration, contained,
subsurface, and linear perimeter filters. The filter media used in the constructed filter may
include sand,peat, compost,granular activated carbon (GAC),perlite, or other materials.The
selection of the filter media is based on the performance goals of the filter. Additional
filtration media may be used as long as data is available to verify their capability to meet
performance goals. Befesa Zinc Metal recognizes the significance of constructed stormwater
filters and aims to implement them whenever feasible.
4.2.5 Wet Ponds
Wet Ponds,also referred to as retention basins,are highly effective stormwater management
systems that offer peak rate mitigation and water quality advantages. These ponds feature a
permanent water pool along with extra storage capacity for temporary stormwater storage.
Wet Detention Ponds are another alternative that provides a permanent pool for water
quality treatment and additional capacity for temporary storage above the permanent pool.
Forebays are necessary in Wet Ponds to trap coarse sediment and avoid short-circuiting.The
pond perimeter should also have dense emergent wetland vegetation. Wet Ponds require
sufficient inflow to maintain a constant water surface. Although they may not achieve
significant groundwater recharge or volume reduction, they can be highly effective in
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Stormwater Pollution Prevention Plan (SWPPP)
removing pollutants and mitigating peak rates. Hydrologic calculations should be done to
ensure the Wet Pond has enough inflow and estimate the water surface level under different
conditions. The pollutant removal effectiveness may vary seasonally and depend on the
pond's age.In Wet Ponds,peak rate mitigation is primarily controlled in the transient storage
above the normal water level. Wet Ponds enhance runoff quality through settling, filtration,
uptake, chemical and biological decomposition, volatilization, and adsorption. They are
relatively efficient in eliminating common pollutants like suspended solids, heavy metals,
total phosphorus, and total nitrogen. Wet Ponds also offer aesthetic and wildlife benefits.
They can accomplish some volume reduction through infiltration and evapotranspiration,
particularly during minor storms. Befesa Zinc Metal acknowledges the value of Wet Ponds
and aims to implement them whenever possible.
4.2.6 Water Quality Filters and Hydrodynamic Devices
Water Quality Filters and Hydrodynamic Devices are stormwater management structures
designed to filter pollutants from runoff. They effectively remove suspended solids, oil and
grease, and other pollutants conveyed with stormwater, providing "hot-spot" control,
reducing sediment loads to infiltration devices, and removing litter, heavy metals, dissolved
solids, and nutrients. Water Quality Filters are devices installed in stormwater inlets or
replace the catch basin itself, limiting detention time and hydraulic capacity, affecting their
pollutant removal effectiveness. Hydrodynamic Devices are separate flow-through devices
that use various designs, including baffle plates, vortex, tube settler, and inclined plate
settler, to remove sediments and pollutants from runoff. They work most effectively in
conjunction with other BMPs, either as pre-treatment or final treatment. Both Water Quality
Filters and Hydrodynamic Devices have numerous commercially available variations, with
manufacturers providing mechanical design, construction, and installation instructions.
Selection of the appropriate device and development of a maintenance plan should be
carefully considered by the Designer. Regular maintenance according to the manufacturer's
recommendations is crucial for continued performance. Befesa Zinc Metal recognizes the
value of these devices and aims to implement them whenever possible.
4.2.6 Runoff Capture and Reuse
Runoff capture and reuse is an effective stormwater management approach that involves the
collection and storage of precipitation for later use. It is achieved using a range of devices
such as rain barrels, cisterns,vertical storage structures, and below-ground storage systems.
Rainwater harvesting using these devices is particularly useful in controlling small,frequent
storm events. It provides numerous benefits for stormwater management, including volume
reduction, improved water quality, peak rate control, and groundwater recharge. By
capturing and storing runoff,these devices help reduce the volume of stormwater runoff that
reaches streams, rivers, and other waterways, reducing the risk of flooding and erosion.
Moreover, runoff capture and reuse devices also improve water quality by reducing the
amount of pollutants entering waterways. The captured water can be used for non-potable
purposes such as irrigation, washing vehicles, and flushing toilets. Befesa Zinc Metal
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Stormwater Pollution Prevention Plan (SWPPP)
recognizes the immense value of runoff capture devices for effective stormwater
management and aims to implement them whenever feasible.
SECTION 5: MONITORING. REPORTING AND RECORD KEEPING
Befesa Zinc Metal implements procedures for conducting the following types of monitoring,
as necessary:
• Benchmark Monitoring
• Effluent limitations guidelines monitoring
• State or Tribal specific monitoring
• Impaired waters monitoring
• Other monitoring as required
At a minimum, procedures describe:
• Locations where samples are collected
• Pollutant parameters sampled
• Monitoring schedules
• Numeric limits,where applicable
• Sample collection and analysis
• Sampling and analysis reporting requirements such as a Discharge Monitoring Report
(DMR)
5.1 Storm Event Definition
The sampling procedure for stormwater management is crucial to ensure the accurate
measurement and analysis of pollutants in runoff. The purpose of the procedure is to collect
samples from "average" storm events, as defined earlier. To qualify as an average storm
event, precipitation of at least 0.1 inches must occur at least 72 hours after the previous
measurable storm event, and there must be a detectable discharge (intentional or
unintentional) of stormwater into a receiving watershed. The 72 hours of dry weather after
a qualifying storm are required to ensure that the sample is not affected by residual
contaminants from the previous storm.Furthermore,if possible,samples should be obtained
from representative storm events, which vary in intensity and frequency. Representative
storm events typically range from 50 to 150 percent of the average seasonal rainfall event at
the site. This range of variability ensures that the sample is reflective of the stormwater
conditions and runoff that occur in the region.
5.2 Sampling Data Summary
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Stormwater Pollution Prevention Plan (SWPPP)
Befesa Zinc Metal has designated one location (outfall #001) for sampling stormwater. This
outfall serves as the point where runoff from the entire area is collected and conveyed to the
receiving water. The selection of the sampling location follows the guidance criteria
provided by the USEPA, which includes several key factors. Firstly, the sampling location
should be situated at the lowest point in the drainage area. Secondly, it should be easily
accessible and not pose any hazards for the sampling personnel.Additionally, the sampling
location must be located within the boundaries of the installation property, discharge
through a conveyance, and be suitable for the measurement of flow rates. By adhering to
these criteria, Befesa Zinc Metal ensures that accurate and reliable stormwater samples can
be collected in a safe and efficient manner.
5.3 Quantitative Monitoring
As guidance, Befesa Zinc Metal follows the procedures and recommendations outlined in the
"Guidance Manual for the Monitoring and Reporting Requirements of the NPDES Stormwater
Multi-Sector General Permit" (USEPA, 1999), as well as other USEPA and state guidance, to
include applicable permits when conducting stormwater sampling. Befesa Zinc Metal
collects grab samples from the stormwater outfall designated for sampling, which is where
runoff from the entire area is collected and conveyed to receiving water. The location of the
sampling point is determined based on USEPA guidance criteria,which includes factors such
as accessibility, safety, and flow measurement suitability. Samples are collected by an
Environmental Specialist at strategic locations near the center of each flow channel, where
turbulence is at a maximum and runoff is well mixed.
Analytical grab samples are collected and analyzed at least once per month after a qualifying
rain event that results in an actual discharge from the permitted outfall. To qualify as an
event, precipitation must be at least 0.1 inches and occur at least 72 hours after the previous
measurable storm event. The event must also occur during normal operating hours, not
coincide with adverse weather conditions, and be characteristic of the volume and nature of
the permitted discharge. Grab samples are collected within the first 30 minutes of discharge
from an outfall. If an outfall is not sampled during the first measurable storm event, it will be
sampled during the next measurable storm event in the monitoring period until a sample is
collected.
All samples are handled, stored, and analyzed according to the methods contained in 40 CFR
Part 136. Quality assurance/Quality Control (QA/QC) methods are implemented in both the
field and the lab to ensure the accuracy and validity of the analytical results. To maintain
quality control, a chain-of-custody record accompanies the samples during shipment to
identify individuals relinquishing and receiving the samples and to document the time and
date of the transfer. Field instruments used to measure environmental data are calibrated
periodically to ensure data accuracy and reproducibility.
Befesa Zinc Metal compares the analytical results for each parameter with the benchmark
values stated in our NPDES Stormwater permit. If any benchmark value is exceeded, a tiered
response is necessary for the respective outfall as outlined in the permit. The analytical
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Stormwater Pollution Prevention Plan (SWPPP)
monitoring data is incorporated into the annual report, in accordance with permit
requirements. Any anticipated modifications to the monitoring plan during the following
year will also be included.
Benchmark Exceedances Tiered Response Level
A single exceedance of a benchmark Tier 1 response
value
Two benchmark exceedances for a single Tier 2 Response (which includes Tier 1
parameter within the permit term responses)
Four benchmark exceedances for a single Tier 3 Response (to include Tier 2 and 1
parameter within the permit term responses)
Note:Currently, Befesa Zinc Metal is considered a Tier 3 organization for exceedances in metal
(Lead, Cadmium and Zinc) benchmarks.
4.2 Qualitative (Visual) Monitoring
Befesa Zinc Metal will follow the permit regulations and record monthly observations of the
quality of the stormwater discharged from the Stormwater Discharge Outfall (SDO). These
observations will be documented on a form provided by the North Carolina Department of
Environmental Quality (NCDEQ) for qualitative monitoring and kept on site. The results of
qualitative monitoring do not need to be submitted to the NCDEQ unless requested. When
conducting quantitative monitoring, visual inspections will also be performed to assess the
following discharge characteristics:
• Color
• Odor
• Clarity
• Floating Solids
• Suspended Solids
• Foam
• Sheen
• Deposition at or immediately below the outfall
• Erosion at or immediately below the outfall
• Other visual indicators of stormwater pollution
The purpose of conducting qualitative monitoring is to quickly and cost-effectively evaluate
the effectiveness of SWPPP BMPs, identify any new sources of stormwater pollution, and
trigger a prompt response from Befesa Zinc Metal in case of pollution. If the qualitative
monitoring shows that the SWPPP and/or existing stormwater BMPs are not effective, or if
there is significant stormwater contamination, Befesa Zinc Metal will investigate the
28

Stormwater Pollution Prevention Plan (SWPPP)
potential causes, assess the feasibility of corrective actions, and implement the necessary
corrective actions within 60 days. A written record of the investigation, assessment, and
response actions will be documented in Attachment B of the SWPPP and in Befesa Zinc
Metal's records management system.
4.3 Inspections
Befesa Zinc Metal completes the following types of inspections for BMPs, as necessary:
• Routine facility inspections (During weekly housekeeping)
• Visual assessment of stormwater discharges (Qualitative monitoring)
• Comprehensive site inspections (Semi-annual conveyance system inspections)
• Dry weather flow monitoring (During weekly housekeeping, during dry periods)
4.10 Employee Training
Befesa Zinc Metal provides stormwater training programs to ensure that everyone in the
organization,including contractors and visitors,understands their roles and the importance
of their participation in the program's success. Befesa Zinc Metal's leadership ensures that
relevant personnel receive the necessary education, training, and certification to perform
their job duties.
Training records are maintained by the Befesa Zinc Metal learning and development
department and can be retrieved from Befesa Zinc Metal's training website (ZLink).
Training Requirements
The following personnel must understand the requirements of the Befesa Zinc Metal NPDES
stormwater permit and their specific responsibilities with respect to those requirements:
• All general employees (Base Level Training)
• Personnel responsible for the design, installation, maintenance, and/or repair of controls
(Base Level Training).
• Personnel responsible for the storage and handling of chemicals and materials that could
become contaminants in stormwater discharges (Base Level Training).
• Personnel responsible for conducting monitoring and inspections (Top Level Training).
• Personnel responsible for documentation requirements for monitoring and inspections
(Top Level Training).
• Personnel responsible for implementing and documenting correction actions (Top Level
Training).
29

Stormwater Pollution Prevention Plan (SWPPP)
At a minimum, personnel will be trained in the following, as related to the scope of their job
duties (e.g., only personnel responsible for conducting inspections need to understand how
to conduct inspections):
• An overview of what is in the SWPPP.
• An overview of spill response procedures, solvent management practices, and material
management practices.
• An overview of the location of all BMPs and structural controls on the site required by the
permit, and how they are maintained.
• An overview of the pollution prevention requirement procedures to follow.
• An overview of when and how to conduct inspections,record applicable findings,and take
corrective action.
Training tools used at Befesa Zinc Metal include the following:
• PowerPoint Presentations
• Practice Drills
• Routine SWPPP Meetings
• Public Education and Outreach Information
4.11 Record Keeping
The personnel responsible for the items listed in this SWPPP take actions to make sure they
comply with the record keeping and reporting requirements of the permits that apply to
them. These records are kept, stored, and disposed of according to the permit reporting and
file disposition requirements.
Befesa Zinc Metal stores the following records related to permits, inspections, monitoring,
and certifications along with the SWPPP. Whenever possible, an electronic version of the
record is included in the references section of the plan.
• Copy of the Notice of Intent (NOI)
• Copy of acknowledgement letter containing the permit tracking number
• Copy of the permit
• Description and dates of any significant spill, leaks, or other releases
• Employee training records
• Documentation of deviations from the schedule for monitoring or assessments and the
reason for deviation
30

Stormwater Pollution Prevention Plan (SWPPP)
• Documentation of corrective actions taken
• Documentation of benchmark exceedance and any response actions
• Documentation to support determination that pollutants of concern are not expected to
be present above natural background levels if water is discharged directly to impaired
waters when required by the permitting agency
Additional Record Keeping
Additional records to be kept may include, but are not limited to the following:
• Calibration and maintenance records
• Copies of Electronic Discharge Monitoring Reports (eDMR)
• Visual Monitoring Records (SDO Qualitative Monitoring Report)
• Annual Summary eDMR
• Records of evaluations for unauthorized non-stormwater discharges
• Copies of data used to complete the NOI to be covered by this permit
SECTION 6: SPILL RESPONSE PROCEDURES RELATED TO STORMWATER
Both the Befesa Zinc Metals Spill Prevention and Response Procedures and the Spill
Prevention Control and Countermeasure Procedures share certain elements that are
relevant to stormwater management. These plans cover spill response procedures and
failure mode preparation and response and identify the personnel responsible for
implementing them. The Befesa Zinc Metal Integrated Contingency Plan includes both these
plans and can be obtained for reference by coordinating with the environmental department.
In the event of a spill or a release,the following individuals shall be contacted:
Name Role Phone Number
Site Security Main Site Point of Contact 828-919-3155
William White Environmental Manager 704-692-3476
Jan Nedbal Environmental Manager 828-8296172
Bobby Lowery Emergency Coordinator 828-371-7803
SECTION 7: DOCUMENTATION TO SUPPORT ELIGIBILITY UNDER OTHER LAWS
Befesa Zinc Metal keeps records verifying its eligibility determination under other federal
regulations such as the Endangered and Threatened Species and Critical Habitat Protection,
Historic Properties Preservation, and the National Environmental Policy Act (NEPA) in a
separate document, which is distinct from this SWPPP. The Environmental Department
holds such records and makes them available when needed.
31

Stormwater Pollution Prevention Plan (SWPPP)
SECTION 8: BEFESA ZINC METAL SPECIFIC CONTENT
8.1 Feasibility Study
Befesa Zinc Metal is required by NCDEQ to assess the technical and economic feasibility of
altering its operation methods and/or storage practices to eliminate or minimize the
exposure of materials to stormwater and run-on flows. If elimination of exposure is not
feasible, Befesa Zinc Metal will document the feasibility of redirecting stormwater runoff
away from areas of potential contamination. The locations of industrial outfalls, potential
pollutants/release points,and associated BMPs that have undergone a feasibility assessment
and have been approved by the management team of Befesa Zinc Metal are detailed in
section 3 of this document.
8.2 Evaluation of Stormwater Discharge Outfalls
Every year, Befesa Zinc Metal conducts an evaluation of its SWPPP which involves assessing
all Stormwater Discharge Outfalls for any illicit discharges.
The assessment takes place during dry weather conditions (i.e., no precipitation for at least
three days prior) and involves visually inspecting each outfall for any stagnant water or
liquid discharge, which may indicate a non-stormwater discharge. The SWPPP team will
investigate the source of the discharge and determine if further action is required to
eliminate it. They will also look for indicators of past or intermittent illicit discharges, such
as stains at the discharge point. Examples of potential non-stormwater discharges that may
be identified include:
• Discharges from emergency/unplanned fire-fighting activities
• Fire hydrant flushing
• Potable water, including uncontaminated water line flushing
• Uncontaminated condensate from air conditioners, coolers, and other compressors
• Irrigation/landscape drainage
• Pavement wash waters
• External building/structure wash water
• Uncontaminated ground water or spring water
• Foundation or footing drains where flows are not contaminated with process materials
• Incidental windblown mist from cooling towers that collects on rooftops
The Befesa Zinc Metal Environmental Department will assess if the discharge is allowed,
which means that it is an incidental event that does not significantly affect water quality.The
32

Stormwater Pollution Prevention Plan (SWPPP)
findings of the SDO evaluation will be documented and recorded in this SWPPP (refer to
"Certification").
In case there are no non-storm water discharges, the designated official (specified in section
1.2) will confirm the evaluation outcomes. The completed and verified evaluation must be
kept with this document.
If non-stormwater discharges are detected, the SWPPT will identify the source and
document if the discharge is allowed by rule or another permit. Moreover, the SWPPT will
assess the environmental significance of the non-stormwater discharges and will create a
written summary to be included with this document. After all investigation procedures are
finished,the responsible official will certify the evaluation outcomes.
8.3 Secondary Containment Plan
Employees of Befesa Zinc Metal are advised to consult the SPCC Plan to determine the
required secondary containment and capacities for drums, tanks, and mobile equipment
with capacities greater than 55 gallons.
Containers of hazardous materials, including drums, are stored on spill pallets, in hazardous
material or flammable storage cabinets, or inside buildings with adequate containment
features. In addition, absorbent materials are kept on hand to facilitate prompt response in
the event of a spill.
Commitment to Visually Observe any Accumulated Storm Water Prior to Release
Befesa Zinc Metal employees are expected to follow the SPCC Plan when managing
stormwater in secondary containment. This plan provides instructions for recording
observations and releasing stormwater into the conveyance system.
Before releasing stormwater from secondary containment, the responsible individual must
inspect the accumulated water for hazardous materials present in each drainage event. If
visual indicators of contamination are detected, employees must remove the sheen or
contamination with absorbent materials or a pump system before releasing the stormwater.
Any contaminated absorbents must be placed in a drum and transported to the 90-Day
Hazardous Waste Accumulation Point (HWAP) for proper disposal and recovery.
Commitment to Only Release Uncontaminated Accumulated Stormwater
To ensure that the accumulated water in the secondary containment areas is free of any
potential contaminants, Befesa Zinc Metal will conduct pH testing on the water before
release. This testing will be performed by trained employees using appropriate equipment,
and the results will be documented to ensure compliance with regulatory standards. Only
water found to be within acceptable pH ranges will be released into the storm drainage
33

Stormwater Pollution Prevention Plan (SWPPP)
system under direct observation, with valves attended at all times to prevent any
uncontrolled discharge.
Records of Stormwater Releases from Secondary Containment
Before discharging water from secondary containment areas holding hazardous materials,
Befesa Zinc Metal shall conduct a visual inspection and create written documentation. The
inspection and discharge shall be documented using a Containment Area Stormwater
Release Record. These forms shall be collected by the Befesa Zinc Metal environmental
department monthly and retained for a period of 5 years.
8.4 Preventative Maintenance/Good Housekeeping Program (PMGHP)
Maintaining a clean and orderly work environment is crucial for preventing pollution in
stormwater discharges at Befesa Zinc Metal. The Preventative Maintenance and Good
Housekeeping Practices (PMGHP) program ensures that stormwater control systems, SCMs,
BMPs,and industrial activity areas are inspected,maintained,and cleaned on a regular basis.
The PMGHP elements at Befesa Zinc Metal include:
• Proper disposal of hazardous wastes
• Materials are removed from the floors daily, and floors and grounds are kept clean by dry
methods such as sweeping and vacuuming. Hosing areas off as a cleaning method,
especially outside, are minimized or eliminated
• Garbage and waste materials are either stored under cover or in closed containers
• Garbage and waste material are picked up daily
• Daily inspections are conducted for leaks or conditions that may lead to the discharge of
chemicals or the contact of stormwater with materials
• Spill clean-up procedures are understood by all Befesa Zinc Metal employees
• Areas are arranged to ease material transfer and inspection access
• Containers, drums, and bags are away from direct traffic routes to prevent accidental
spills
• Containers are stacked according to manufacturer's instructions to avoid damaging the
containers from improper weight distribution
• Containers are stored on pallets or similar devices to prevent contact with moisture and
aid in leak inspections
• Containers are stored in covered locations to prevent rust and leaks
• Personnel are trained in hazardous materials handling
• All chemical substances present in the workplace are identified and an SDS is maintained
for each
34

Stormwater Pollution Prevention Plan (SWPPP)
• Containers are labeled to show the name and type of substances,stock number,expiration
date, health hazards, suggestions for handling, and first-aid information. Information is
also available via SDSs
• Hazardous materials requiring special handling, storage, use,and disposal considerations
are clearly and plainly marked
35

Storrawater Pollution Prevention Plan (SWPPP)
THIS PAGE INTENTIONALLY LEFT BLANK
36

Storrawater Pollution Prevention Plan (SWPPP)
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Stormwater Pollution Prevention Plan (SWPPP)
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Stormwater Pollution Prevention Plan (SWPPP)
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Storrawater Pollution Prevention Plan (SWPPP)
FIGURE 1-6: Discharge Location Map
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Vi

Stormwater Pollution Prevention Plan (SWPPP)
ATTACHMENT A: Significant Spill History
The Befesa Zinc Metal filing system contains a list of significant spills and releases from the past, which can be obtained upon
request by coordinating with the Environmental Department.
vii

Stormwater Pollution Prevention Plan (SWPPP)
ATTACHMENT B: Tier Action Log History
The Befesa Zinc Metal filing system contains the Tier Action Log, which can be obtained upon request by coordinating with the
Environmental Department.
viii

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Jan-19 22.4 0.52 0.086 4.8 0.059 0.066 36.8 0 6.9
Apr-19 0 0 0 0 0 0 0 0 0
Jul-19 114 0.81 0.18 2.9 0.047 0.24 4.5 0 6.7
Oct-19 4.3 0.5 0.28 0.029 0.001 0.005 13.6 0 7.7
Jan-20 25.3 0.56 0.19 3.5 0.058 0.069 20.2 0 6.9
Apr-20 5.6 0.93 0.05 33.1 0.58 0.043 22.9 0 6.5
Jul-20 9.4 0.59 0.11 2.7 0.085 0.078 5.8 0 6.8
Aug-20 15.2 1.25 0.177 7.37 0.12 0.083 14.6 0 12.9
Sep-20 43.7 2.59 0.267 29.7 0.836 0.236 41.1 0 27.4
Oct-20 49.6 2.88 0.86 27.7 0.691 0.381 158.2 0 35.6
Nov-20 51.7 4.82 0.8 68.2 1.45 0.422 96.9 0 25.2
Dec-20 67 1.2 0.29 7.3 0.23 0.33 5.8 0 6.4
Feb-21 23 0.63 0.11 17.1 0.25 0.2 24.3 0 6.1
Mar-21 70.4 0.52 0.13 9.8 0.15 0.43 7.7 0 6.6
Apr-21 62.4 1.4 0.16 10.4 0.096 0.14 18.9 0 6.4
May-21 237 0.82 0.34 7.3 0.13 0.79 6.6 0 6.2
Jun-21 5.8 0.94 0.058 18.3 0.049 0.049 13.1 0 6.1
Jul-21 15.8 0.52 0.083 13.4 0.12 0.1 11.7 0 6.2
Aug-21 6.3 0.56 0.05 27.4 0.4 0.054 25.6 0 5.7

Sep-21 4.1 0.52 0.12 4.7 0.06 0.014 11.5 0 6.2
Oct-21 7.1 0.52 0.17 5 0.057 0.026 12.2 0 6.9
Nov-21 5.4 0.83 0.072 7.1 0.082 0.038 1080 0 6.8
Dec-21 2.5 0.54 0.25 1.3 0.012 0.0086 10.1 0 6.4
Jan-22 0 0 0.27 2.7 0.042 0.032 60 0 6.34
Feb-22 7.3 0 0.093 2 0.028 0.029 13.5 0 7.41
Mar-22 10.2 0.39 0.096 2.36 0.0352 0.0574 11.4 0 7.46
Apr-22 14 0.61 0.057 2.1 0.036 0.047 6.5 0 6.44
May-22 15.6 0.84 0.11 5.96 0.0486 0.0878 11.7 0 6.63
Jun-22 13.3 0.97 0 1.32 0.0174 0.0325 17 0 9.59
Jul-22 7.7 0.6 0 5.2 0.044 0.035 17 0 7.33
Aug-22 10 0.308 0.066 2.66 0.0279 0.0313 17.6 0 6.69
Sep-22 9.7 0.56 0.11 3.9 0.031 0.0285 9.5 0 7.37
Oct-22 4.3 0.37 0.1 4.6 0.039 0.025 10.1 0 6.39
Nov-22 16.8 0.28 0.12 6.2 0.044 0.099 6.6 0 6.66
Dec-22 14.8 0.49 0.15 3.47 0.0336 0.0858 4.6 0 7.31
Jan-23 18 0.61 0.11 4.25 0.062 0.0633 8 0 6.2
Feb-23 16.2 0.62 0.11 4.59 0.061 0.0587 6.1 0 6.2
Mar-23 9.1 0.55 0.14 3.49 0.0403 0.0365 18.3 0 7.26
Apr-23 13.8 0 0.079 3.1 0.0274 0.0476 5.7 0 6.1
May-23 12.2 0.22 0.076 3.07 0.033 0.0422 4.5 0 6.55
Jun-23 6.1 0.62 0.21 1.38 0.0105 0.0241 278 0 7.55
Jul-23 18.6 0.57 0.14 4.11 0.0309 0.052 36.9 0 6.94

Aug-23 18.6 0.45 0.078 3.72 0.0367 0.0537 11.9 0 6.39

Prepared by William White
STORMWA TER COMPLIANCE SUMMARY BZM Environmental Compliance Manager FE
Current as of:8/16/23
SS IBM TSS I PhosphorusBM Phosphorus
100 ---- --------- ---------
67J� q - 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2
434�5�.7 2 - - 0.81b.8- - - - - - - - - - - - - - -
50 22.4 25.3 g
9.3 0 .3 5.69.45. 45.9.34.17.15.4f2.5 p 7.10.:145.f$.4.7109.7q• 3 .�i• 1 0 (P.08fD0.1%•26.1@.pg•p11Q�6 0.26.1Q.10.1%•-V0881$A06.1Q.�0-P228.�093OM9711p d).06G1D.D.1Q.16.1Q.10.b300� �.ba078
0 0
yw ti� ya 10 ti0 L° LO yti Ly 1ti Ly fl> fl> fp, LL -0, -P, 'L -P, LS L'i L3 y3 N% y�i ya L° LO 'L° LO Ly Lti yti yti yti �ti Lb Lb LL LL LL LL y3 L'i �3 L3
OLD Oe� Leo PQ�" �J� PO OLD QeL Leo Pit" �J� PO �`�� �a� �`�� �a� l`�� �eQ 04 Leo PQt" �J� PJ4° O Qev pep PQ�" �J� PJao OLD Oec t�ep Pit" 1J0 PO
Month Month
inc BM Zinc Nitrogen BM Nitrogen
80 68.2 40 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30
60 33.1 29S7 27.4 30 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
40 1 �.8�-' 33.4
20
20 0.0Z.71.8 0 2�0233 •7.3 37 4.7 5 7.11 .7 22.30. ` ?3 .66.9}•��.4�2&53 4s.8.OQ3�13L72 10 0 00.5200.8D.D.se.91i.59.2$•58.8$ � Sd•41.8Q.90.5Q 58.5Q.SQ 8(i.540 00.39.6Q sgi9D$.3858.30.28 49.6Q 6Q 5500.2Q 6Q 50.45
0 - --- 0
tiro tia tia do do do do titi titi titi titi titi titi titi titi titi titi titi titi ti3 ti3 y'' y3 ti� ti� tia yo do yo do titi titi titi titi titi titi titi titi titi titi titi titi ti'' ti� ti'' ti�
PQc" Oc� O�� Leo PQ� �Jc PJ� OL` Oe� lea PQi" ,J� PJ �J� ,a� �J� ,a� �o� �eQ �o� Leo PQc" ,�� PJ� O Oe� pep PQc" ,J� P�� O Oe� pep PQ� �Jc V0
Month Month
admiumBM Cadmium Chlorides BM Chlorides
2 1.45 1500 1080
1.5 0. fi 1000 863636(B6(8636(B636CB6(863636363636(�636(E636(616(E60;61 (86(3636363636(8636(86(36(86363636363636363636360
0.58 _
1 0.4 278
0.5 p•p[pQ(805gq.q �QS .085E 1�912 O.O�Ct$ �03� ®0 4�0 3�963tik08A�OS0967 500 2.32.36.80 4.33 E022.3.54.�1 •` ,g4.�.�8.3.a33.1135.b1.b2 .16013.51.,6.31.7171717.9.30.b.64.6 8 6.18.3.74.5 36.91.9
0 ---- 0
tiw ti� tia ,yo ,yo ,yo ,yo titi titi ,yti titi ,yti titi titi titi titi titi titi titi ,y3 ,y3 ti� ,y3 tiw tie ti� do do ,yo do titi titi titi ,yti titi titi titi titi titi titi titi titi ,y3 ,y3 ,y3 ,y3
Month Month
Lead BM Lead pH BM pH (Low)BM pH (High)
1 0.79 9.5 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9
0.43 8.5 -7.7- _ _ _ _ - 7.4i. - _ 7.26 T.S�
0.5 0.24 0.23163 7.5 6.7 6.96.56.8 6.76.66 46 4 6.66 q 6.96.86�.3 6.69 .66 5 6.96. 9
0.&R966� � �98 0.2 0 6.5 661 6 6 661 6 6616625Gj662 6 6 6 6 6
0 5.5
M M O O O O O O O O c 1 -1 N N N N N N N N N N N N M M M M M M M M
lJ�y �7 ¢ � c-I a-I N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N Ni N N N N N
55 5 co a > b $ n > c 5 co a > b c - n m c oa aV > b >, c N¢w
Z 0) o (, a) vO oa ¢ a) ° ci ¢ M
�a� a� 01 O Q ¢ � O Z ❑ ¢ v, z ❑ ¢ v, O zO
Month Month

BM TSS
300 23]
200 114
100 43.7 49.6 51.7 6] ]0.4 62A -- _ ------ -M%-M%
RS--18%-13
0
4ti 10 Y O°' �N° lA ti ti ti ti 'p1 ,y ;1, 'l .11 ,y '1, +',11 , 't'1. ll I'll,
;pR 'LA" '1'1. '¢?I'll 'Lv '✓ 'pA a, ;L'' '✓ ;L'' I '4'h
l O°� >°° pQ l O°� l PO 1','P� Se O� Sa° O- Fe yP° P� �Sa l l P� Se OC Sa° p- l F� �� PQ �S°+ 1 � P� `F� O Oe lTC Fe lf° PQ ASa \ y P�
Mon[h
nc BM Zinc
68.2
80
60 33.1 29.] 2].] 27.4
20 2.7 4.8 2.9 3.5 2.] ].3] ].3 0A 9.8 10.4 ].3 18.3 13.4 4.] 5 ].1 13 27 2 2.36 2.1 5.96 1.32 5.2 2.66 3.9 4.6 6.2 3.47 4.25 4.59 3.49-3.1 3.07 1.38 4.11 3.72
l ry P4'~ ..�eY'Y p�'LO�A,O 0¢�'•1, F¢.p `qa.¢ pF.y�.T,y ,° l\ p�.p c'¢�.¢ p�,p 2o,y p° C'1.F¢0.p �.5•¢ pR•¢`y.T,y ,P'L l�'4 P�•1, S¢Q p�,p 20•p p° P F¢•1, a.S•¢ pC•¢^s`y.T•p'h ,P'h l�3 P�•1�'
Month
Cadmium BM Cadmiu
2 1.45
1.5 0.58 0.836 0.691
05 0.001 0.03]0.059 0 0.04]0.001 0.058 0.085 0.12 0.23 0.25 0.15 0.096 0.13 0.049 0.12 04 0.06 0.057 0.082 0.012 0.042 0.0280.03520.0360.04860.01]40.0440.02]90.031 0.039 0.0440.03360.062 0.0610.04030.02]40.0330.0109).03090.036]
p
ro ° v° ti ti v° ;r° ti ti �ti ti v v ti +ti ti vv vv �,vv a' v vv vv vv a' ti ti ti
P° S P� S� O� ?° F°� eF°
Month
Lead BM Lead
1 0.]9
0.3810.422 033 0.43
0.5 0.092 0.066 0.24 0.069 0.043 0.0]8 0.083 0.236 0.2 0.14 p4q 0.1 0.05o 0.4 0.014 0.02b 0.0380.00860.032 0.029 0.0574 0."7 .032 2850.025 0.0990.085%.06330.058]0,03650.04]60.MZM.02410.0520.0537
0.005 0 0.005
0 0 ti OO O .y0 O O ti l v0 ti ti ti ti ti ti ti ti ;dry ;try ;try ;try vry lv v v vry vry +;Sry ti ti �ti l
l Ob S 9 PQ.ti9 l C�S9 l PQ h P@ ,�,7 OC' i H C i h @ P � � C i h @ p h Qry,
2� O F° �'a P � ,Cv v p S° C� 2°v O F°'O eP¢ P � l� P S° O� 2 p°u• ~ F¢O � P
Month
Ph.pho,,sBM Phosphorus
3 2 2 2 2 2 2 2 2 2 2
] 0 1 0.086 0 0.18 0.28 0.19 0,05 0.11 0.1))0.26]`_ 0.29 0.11 0.13 0.16 0-M 0.058 0.083 0.05 0.12 0.1) 0p]i 0.25 0.27 0.033 OA%0-7 0.11 0 0 0.%6 0.31 OA 0- 0.15 0.31 0- 0- 0.%9 0.076 0.21 0- 0.0I8
0 •TI /�• • • �♦ • •� ��♦ • • • ♦ 1 /� �• • • /�- • • • • • •T• • 1
�ti S°' ,� \.gY ti ti �ti ti ti ti ti ti h h1 ;1- v1 v l�'1 1F11 SQvl Odl I'll
of I 4;O Fill"I'll
te"",vry A 11 1;11 10
1,Sevry Odl ti ¢+,I o°1�4,Fill"I'll
te,",L' ;¢' 101
pQN
Month
Nitrogen BM Nitogen
41 0 30 30
30
20 0.52 0.81 OS O56 0.93 059 1.25 I.59 2.86 4.62 1.2 00 052 1.4 O.BI 094 052 O56 052 052 083 054 039 O61 0.84 0.9] O6 0308 O56 03) OIB 049 O61 Ofi2 O55 02I 062 05) 0.45
10 0 0 0 0 0
0 •�T• • ♦-♦ • • ♦ • ♦-/ / / • • •�T�• 1 • • • • • •�
Month
ChloridesBM Chlorides
1500 g60 860 860 860 860 860 860 860 860 860 860 860 860 860 860 860 860 860 860 860 860 860 860 8� 860 S. 860 860 860 860 860 860 860 860 860 8. 860 8. 860 860 860 860 860 860 860
000
500 _--_-- - _ ___158.2 969 5 __ _______ ___ ___ ng __
.9 11.9
0
ti ;5 y ti ti9 ti ti 11 ti 11 ti ti ti vv v, , ti v'` 1, '' +'b vv vv vv ;l vv vv v a' vv � vv v" ;1l "' N
�~ O� \ PQ l O� S PR l pF' `7p OL e`°+ O¢° 4eK al'm PQ e1'9 l 1 P4' Sev O°� 2v O� l Fe �� pQ t1'4Y l �� PO 'fQ 06 ?� De � F2O Ay,¢y p'v�P2 l S p0
Month
pH BM pH(LOW)BM pH(High)
95 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9
8.5 ))
6.9 6.8 6.) 6.6 6.6 69 ].41 ).46 6 ].33 6.69 ].3] 6.66 �3� ].I6 )�51
].5 6.7 6.5 6.4 6A 6A 6.4 6.334 6.4 6 9 6.55 6.90 6.9
6 6 6 6 6 6
5.5 Jul-1
OR-19 Jan-20 Ap'20 Jul-20 Aug-20 Se 20 OR-20 Nov-20 Dec-20 Fea21 Mar-21 Apr-21 May-21 lun-21 Ju1-21 Aug-21 Sep-21 Oct-21 Nov-21 Dec-21 Jan-22 Feb-22 Mar-22 Apr-22 May-22 Jun-22 Jul-22 Aug-22 Sep-22 Oct-22 Npy-22 Dec-22 Jan-23 Feb-23 Mar-23 Ap 23-a 23 Jun-23 Jul-23 Aug-23
Month

Years Month All
Data
Row Labels Sum of TSS Sum of Nitrogen Sum of Phosphorus Sum of Zinc Sum of Cadmium Sum of Lead Sum of Chlorides Sum of Grease/Oil Sum of pH Sum of BM TSS Sum of BM Nitrogen Sum of BM Phosphorus
Apr-15 5.5 0 0 3.65 0.305 0.028 86.3 0 7.3 100 30 2
Jul-15 25.9 0 0 35.5 1.07 0.31 45.9 0 6.9 100 30 2
Oct-15 123 0 0 30.7 0.374 1.2 25 0 6.6 100 30 2
Jan-16 IF 0 0 00 0 0 1 0 ' 0- 100 30 2
Apr-16 279 0 0 16.8 0.22 1.1 10.5 0 6 100 30 2
Jul-16 0 0 00 0 0 1 0 0 6.75 100 30 2
Oct-16 192 0 0 2.8 0.044 0.34 3.6 0 6.84 100 30 2
Jan-17 124 0 0 1.5 0.023 0.18 44.8 0 6.78 100 30 2
Apr-17 265 0 0 2.5 0.034 0.26 3.6 0 6.69 100 30 2
Jul-17 174 0 0 1.3 0.021 0.14 7.4 0 6.71 100 30 2
Oct-17 497 0 0 5.6 0.059 0.73 25.8 0 6.72 100 30 2
Jan-18 � 0 0 0 0 0 TMMb 0- 100 30 2
Apr-18 58.8 0 0 0.6 0 0.12 6 0 6.53 100 30 2
Jul-18 9.3 0 0 0.01 0.001 0.005 2.3 0 7.11 100 30 2
Oct-18 0 0 2.7 0.037 0.092 22.2 0 6.93 100 30 2
Jan-19 22.4 0.52 0.086 4.8 0.059 0.066 36.8 0 6.9 100 30 2
Apr-19 0 0_ 0 0 0 0 M 100 30 2
Jul-19 114 0.81 0.18 2.9 0.047 0.24 4.5 0 6.7 100 30 2
Oct-19 4.3 0.5 0.28 0.029 0.001 0.005 13.6 0 7.7 100 30 2
Jan-20 25.3 0.56 0.19 3.5 0.058 0.069 20.2 0 6.9 100 30 2
Apr-20 5.6 0.93 0.05 33.1 0.58 0.043 22.9 0 6.5 100 30 2
Jul-20 9.4 0.59 0.11 2.7 0.085 0.078 5.8 0 6.8 100 30 2
Aug-20 15.2 1.25 0.177 7.37 0.12 0.083 14.6 0 6.1 100 30 2
Sep-20 43.7 2.59 0.267 29.7 0.836 0.236 41.1 0 6.7 100 30 2
Oct-20 49.6 2.88 0.86 27.7 0.691 0.381 158.2 0 6.6 100 30 2
Nov-20 51.7 4.82 0.8 68.2 1.45 0.422 96.9 0 6.4 100 30 2
Dec-20 67 1.2 0.29 7.3 0.23 0.33 5.8 0 6.4 100 30 2
Feb-21 23 0.63 0.11 17.1 0.25 0.2 24.3 0 6.1 100 30 2
Mar-21 70.4 0.52 0.13 9.8 0.15 0.43 7.7 0 6.6 100 30 2
Apr-21 62.4 1.4 0.16 10.4 0.096 0.14 18.9 0 6.4 100 30 2
May-21 237 0.82 0.34 7.3 0.13 0.79 6.6 0 6.2 100 30 2
Jun-21 5.8 0.94 0.058 18.3 0.049 0.049 13.1 0 6.1 100 30 2
Jul-21 15.8 0.52 0.083 13.4 0.12 0.1 11.7 0 6.2 100 30 2
Aug-21 6.3 0.56 0.05 27.4 0.4 0.054 25.6 0 5.7 100 30 2
Sep-21 4.1 0.52 0.12 4.7 0.06 0.014 11.5 0 6.2 100 30 2
Oct-21 7.1 0.52 0.17 5 0.057 0.026 12.2 0 6.9 100 30 2
Nov-21 5.4 0.83 0.072 7.1 0.082 0.038 1080 0 6.8 100 30 2
Dec-21 2.5 0.54 0.25 1.3 0.012 0.0086 10.1 0 6.4 100 30 2
Jan-22 0.27 2.7 0.042 0.032 60 0 6.34 100 30 2
Feb-22 7.3 0.093 2 0.028 0.029 13.5 0 7.41 100 30 2
Mar-22 10.2 0.39 0.096 2.36 0.0352 0.0574 11.4 0 7.46 100 30 2
Apr-22 14 0.61 0.057 2.1 0.036 0.047 6.5 0 6.44 100 30 2
May-22 15.6 0.84 0.11 5.96 0.0486 0.0878 11.7 0 6.63 100 30 2
Jun-22 13.3 0.97 0 1.32 0.0174 0.0325 17 0 9.59 100 30 2
Jul-22 7.7 0.6 5.2 0.044 0.035 17 0 7.33 100 30 2
Aug-22 10 0.308 0.066 2.66 0.0279 0.0313 17.6 0 6.69 100 30 2
Sep-22 9.7 0.56 0.11 3.9 0.031 0.0285 9.5 0 7.37 100 30 2
Oct-22 4.3 0.37 0.1 4.6 0.039 0.025 10.1 0 6.39 100 30 2
Nov-22 16.8 0.28 0.12 6.2 0.044 0.099 6.6 0 6.66 100 30 2
Dec-22 14.8 0.49 0.15 3.47 0.0336 0.0858 4.6 0 7.31 100 30 2
Jan-23 18 0.61 0.11 4.25 0.062 0.0633 8 0 6.2 100 30 2
Feb-23 16.2 0.62 0.11 4.59 0.061 0.0587 6.1 0 6.2 100 30 2
Mar-23 9.1 0.55 0.14 3.49 0.0403 0.0365 18.3 0 7.26 100 30 2
Apr-23 13.8- 0.079 3.1 0.0274 0.0476 5.7 0 6.1 100 30 2
May-23 12.2 0.22 0.076 3.07 0.033 0.0422 4.5 0 6.55 100 30 2
Jun-23 6.1 0.62 0.21 1.38 0.0105 0.0241 278 0 7.55 100 30 2
Jul-23 18.6 0.57 0.14 4.11 0.0309 0.052 36.9 0 6.94 100 30 2
Aug-23 18.6 0.45 0.078 3.72 0.0367 0.0537 11.9 0 6.39 100 30 2

Sum of BM Zinc Sum of BM Cadmium Sum of BM Lead Sum of BM Chlorides Sum of BM Grease/Oil Sum of BM pH(Low) Sum of BM pH(High) Data SS BM T55
0.067 0.001 0.03 860 15 6 9 Month TSS BM TSS
0.067 0.001 0.03 860 15 6 9 Jul-18 9.3 100
0.067 0.001 0.03 860 15 6 9 Oct-18 0 100 500
0.067 0.001 0.03 860 15 6 9 Jan-19 22.4 100 400
0.067 0.001 0.03 860 15 6 9 Apr-19 0 100
0.067 0.001 0.03 860 15 6 9 Jul-19 114 100 300
0.067 0.001 0.03 860 15 6 9 Oct-19 4.3 100 zoo
0.067 0.001 0.03 860 15 6 9 Jan-20 25.3 100
0.067 0.001 0.03 860 15 6 9 Apr-20 5.6 100 100
0.067 0.001 0.03 860 15 6 9 Jul-20 9.4 100 0
0.067 0.001 0.03 860 15 6 9 Aug-20 15.2 100
0.067 0.001 0.03 860 15 6 9 Sep-20 43.7 100 "3,
0.067 0.001 0.03 860 15 6 9 Oct-20 49.6 100
0.067 0.001 0.03 860 15 6 9 Nov-20 51.7 100 Month
0.067 0.001 0.03 860 15 6 9 Dec-20 67 100
0.067 0.001 0.03 860 15 6 9 Feb-21 23 100
0.067 0.001 0.03 860 15 6 9 Mar-21 70.4 100
0.067 0.001 0.03 860 15 6 9 Apr-21 62.4 100
0.067 0.001 0.03 860 15 6 9 May-21 237 100
0.067 0.001 0.03 860 15 6 9 Jun-21 5.8 100
0.067 0.001 0.03 860 15 6 9 Jul-21 15.8 100
0.067 0.001 0.03 860 15 6 9 Aug-21 6.3 100
0.067 0.001 0.03 860 15 6 9 Sep-21 4.1 100
0.067 0.001 0.03 860 15 6 9 Oct-21 7.1 100
0.067 0.001 0.03 860 15 6 9 Nov-21 5.4 100
0.067 0.001 0.03 860 15 6 9 Dec-21 2.5 100
0.067 0.001 0.03 860 15 6 9 Jan-22 0 100
0.067 0.001 0.03 860 15 6 9 Feb-22 7.3 100
0.067 0.001 0.03 860 15 6 9 Mar-22 10.2 100
0.067 0.001 0.03 860 15 6 9 Apr-22 14 100
0.067 0.001 0.03 860 15 6 9 May-22 15.6 100
0.067 0.001 0.03 860 15 6 9 Jun-22 13.3 100
0.067 0.001 0.03 860 15 6 9 Jul-22 7.7 100
0.067 0.001 0.03 860 15 6 9 Aug-22 10 100
0.067 0.001 0.03 860 15 6 9 Sep-22 9.7 100
0.067 0.001 0.03 860 15 6 9 Oct-22 4.3 100
0.067 0.001 0.03 860 15 6 9 Nov-22 16.8 100
0.067 0.001 0.03 860 15 6 9 Dec-22 14.8 100
0.067 0.001 0.03 860 15 6 9 Jan-23 18 100
0.067 0.001 0.03 860 15 6 9 Feb-23 16.2 100
0.067 0.001 0.03 860 15 6 9 Mar-23 9.1 100
0.067 0.001 0.03 860 15 6 9 Apr-23 13.8 100
0.067 0.001 0.03 860 15 6 9 May-23 12.2 100
0.067 0.001 0.03 860 15 6 9 Jun-23 6.1 100
0.067 0.001 0.03 860 15 6 9 Jul-23 18.6 100
0.067 0.001 0.03 860 15 6 9 Au -23 18.6 100
0.067 0.001 0.03 860 15 6 9 Grand Total 1093.6 4500
0.067 0.001 0.03 860 15 6 9
0.067 0.001 0.03 860 15 6 9
0.067 0.001 0.03 860 15 6 9
0.067 0.001 0.03 860 15 6 9
0.067 0.001 0.03 860 15 6 9
0.067 0.001 0.03 860 15 6 9
0.067 0.001 0.03 860 15 6 9
0.067 0.001 0.03 860 15 6 9
0.067 0.001 0.03 860 15 6 9
0.067 0.001 0.03 860 15 6 9
0.067 0.001 0.03 860 15 6 9

Data inc BM Zinc Data Lead BM Lead
Month Zinc BM Zinc Month Lead E
Jul-18 0.01 0.067 80 Jul-18 0.005 0.9
Oct-18 2.7 0.067 70 Oct-18 0.092 0.8
Jan-19 4.8 0.067 60 Jan-19 0.066 0.7
Apr-19 0 0.067 so Apr-19 0 0.6
Jul-19 2.9 0.067 40 - Jul-19 0.24 0.5
Oct-19 0.029 0.067 30 Oct-19 0.005 0.4
Jan-20 3.5 0.067 20 Jan-20 0.069 0.3 AA
Apr-20 33.1 0.067 10 Apr-20 0.043 o.z
Jul-20 2.7 0.067 Jul-20 0.078 0.l
Aug-20 7.37 0.067 o a o 0 o Aug-20 0.083 0
Sep-20 Se
Y ti ti ti ti ti 3 ei N N N N N N N N N N N N
fee�1e`ry� SeQ fee�ce`~� ti Oct-20 27.7 0.067 a �° a' z ' o ' o ' O t-20 0.3811 a°a J �,y0 J\tio¢ o ¢tiPQPJ ` ¢ ¢tiPQ,y'c PJ�tio�tio¢ ¢,yls 10
Nov-20 68.2 0.067 Month Nov-20 0.422
Dec-20 7.3 0.067 Dec-20 0.33 Month
Feb-21 17.1 0.067 Feb-21 0.2 0.03
Mar-21 9.8 0.067 Mar-21 0.43 0.03
Apr-21 10.4 0.067 Apr-21 0.14 0.03
May-21 7.3 0.067 May-21 0.79 0.03
Jun-21 18.3 0.067 Jun-21 0.049 0.03
Jul-21 13.4 0.067 Jul-21 0.1 0.03
Aug-21 27.4 0.067 Aug-21 0.054 0.03
Sep-21 4.7 0.067 Sep-21 0.014 0.03
Oct-21 5 0.067 Oct-21 0.026 0.03
Nov-21 7.1 0.067 Nov-21 0.038 0.03
Dec-21 1.3 0.067 Dec-21 0.0086 0.03
Jan-22 2.7 0.067 Jan-22 0.032 0.03
Feb-22 2 0.067 Feb-22 0.029 0.03
Mar-22 2.36 0.067 Mar-22 0.0574 0.03
Apr-22 2.1 0.067 Apr-22 0.047 0.03
May-22 5.96 0.067 May-22 0.0878 0.03
Jun-22 1.32 0.067 Jun-22 0.0325 0.03
Jul-22 5.2 0.067 Jul-22 0.035 0.03
Aug-22 2.66 0.067 Aug-22 0.0313 0.03
Sep-22 3.9 0.067 Sep-22 0.0285 0.03
Oct-22 4.6 0.067 Oct-22 0.025 0.03
Nov-22 6.2 0.067 Nov-22 0.099 0.03
Dec-22 3.47 0.067 Dec-22 0.0858 0.03
Jan-23 4.25 0.067 Jan-23 0.0633 0.03
Feb-23 4.59 0.067 Feb-23 0.0587 0.03
Mar-23 3.49 0.067 Mar-23 0.0365 0.03
Apr-23 3.1 0.067 Apr-23 0.0476 0.03
May-23 3.07 0.067 May-23 0.0422 0.03
Jun-23 1.38 0.067 Jun-23 0.0241 0.03
Jul-23 4.11 0.067 Jul-23 0.052 0.03
Au -23 3.72 0.067 Au -23 0.0537 0.03
Grand Total 381.989 3.015 Grand Total 4.868 1.35

Data Data
Month Cadmium BI admiurnBM Cadmium Month Chlorides BM Chlorides ChloridesBM Chlorides
Jul-18 0.001 1.6 Jul-18 2.3 860 1200
Oct-18 0.037 1.4 Oct-18 22.2 860 1000
Jan-19 0.059 1.2 Jan-19 36.8 860 La
Apr-19 0 1 Apr-19 0 860 800
Jul-19 0.047 08 Jul-19 4.5 860 600
Oct-19 0.001 0.6 Oct-19 13.6 860
Jan-20 0.058 Jan-20 20.2 860 400
Apr-20 0.58 0.4 Apr-20 22.9 860 200
Jul-20 0.085 0'2 Jul-20 5.8 860
Aug-20 0.12 0 ------- Aug-20 14.6 860 0
Sep-20 0.836 0 ya ti� ti0 ti0 ti0 ti0 L1 �Y titi 1 L1 ti~ titi titi titi titi titi titi L3 l3 ti� Sep-20 41.1 860 m o 0 0 o ry ry N N ry ry N Oct-20 0.691 S° ° >° >°> 49 ° o � >° °O cvo 01, c � Oct-20 158.2 860 O,
Nov-20 1.45 Nov-20 96.9 860
Dec-20 0.23 Month Dec-20 5.8 860 Month
Feb-21 0.25 0.001 Feb-21 24.3 860
Mar-21 0.15 0.001 Mar-21 7.7 860
Apr-21 0.096 0.001 Apr-21 18.9 860
May-21 0.13 0.001 May-21 6.6 860
Jun-21 0.049 0.001 Jun-21 13.1 860
Jul-21 0.12 0.001 Jul-21 11.7 860
Aug-21 0.4 0.001 Aug-21 25.6 860
Sep-21 0.06 0.001 Sep-21 11.5 860
Oct-21 0.057 0.001 Oct-21 12.2 860
Nov-21 0.082 0.001 Nov-21 1080 860
Dec-21 0.012 0.001 Dec-21 10.1 860
Jan-22 0.042 0.001 Jan-22 60 860
Feb-22 0.028 0.001 Feb-22 13.5 860
Mar-22 0.0352 0.001 Mar-22 11.4 860
Apr-22 0.036 0.001 Apr-22 6.5 860
May-22 0.0486 0.001 May-22 11.7 860
Jun-22 0.0174 0.001 Jun-22 17 860
Jul-22 0.044 0.001 Jul-22 17 860
Aug-22 0.0279 0.001 Aug-22 17.6 860
Sep-22 0.031 0.001 Sep-22 9.5 860
Oct-22 0.039 0.001 Oct-22 10.1 860
Nov-22 0.044 0.001 Nov-22 6.6 860
Dec-22 0.0336 0.001 Dec-22 4.6 860
Jan-23 0.062 0.001 Jan-23 8 860
Feb-23 0.061 0.001 Feb-23 6.1 860
Mar-23 0.0403 0.001 Mar-23 18.3 860
Apr-23 0.0274 0.001 Apr-23 5.7 860
May-23 0.033 0.001 May-23 4.5 860
Jun-23 0.0105 0.001 Jun-23 278 860
Jul-23 0.0309 0.001 Jul-23 36.9 860
Au -23 0.0367 0.001 Au -23 11.9 860
Grand Total 6.3295 0.045 Grand Total 2221.5 38700

Data
Data
Month pH BM H(Low) BM H(High) pH BM pH(Low)BM pH(High) Month Phosphorus BM Phosphorus
Jul-19 6.7 6 9 9.5 Jul-18 0 2
Oct-19 7.7 6 9 9 Oct-18 0 2
Jan-20 6.9 6 9 8.5 Jan-19 0.086 2
Apr-20 6.5 6 9 8 Apr-19 0 2
Jul-20 6.8 6 9 7.5 Jul-19 0.18 2
Aug-20 6.1 6 9 7 Oct-19 0.28 2
Sep-20 6.7 6 9 Jan-20 0.19 2
Oct-20 6.6 6 9 6'S Apr-20 0.05 2
^m m Nov-20 6.4 6 9 6 LV - Jul-20 0.11 2
a o o a a Dec-20 6.4 6 9 5.5 Aug-20 0.177 2
Feb-21 6.1 6 9 a�°J� eQoePQ�,c PJ� oecti�0 PQt�,c PJ�tio�voe� PQ�v>J vPJ�ti' Sep-20 0.267 2
Mar-21 6.6 6 9 Oct-20 0.86 2
Apr-21 6.4 6 9 Nov-20 0.8 2
May-21 6.2 6 9 Month Dec-20 0.29 2
Jun-21 6.1 6 9 Feb-21 0.11 2
Jul-21 6.2 6 9 Mar-21 0.13 2
Aug-21 5.7 6 9 Apr-21 0.16 2
Sep-21 6.2 6 9 May-21 0.34 2
Oct-21 6.9 6 9 Jun-21 0.058 2
Nov-21 6.8 6 9 Jul-21 0.083 2
Dec-21 6.4 6 9 Aug-21 0.05 2
Jan-22 6.34 6 9 Sep-21 0.12 2
Feb-22 7.41 6 9 Oct-21 0.17 2
Mar-22 7.46 6 9 Nov-21 0.072 2
Apr-22 6.44 6 9 Dec-21 0.25 2
May-22 6.63 6 9 Jan-22 0.27 2
Jun-22 9.59 6 9 Feb-22 0.093 2
Jul-22 7.33 6 9 Mar-22 0.096 2
Aug-22 6.69 6 9 Apr-22 0.057 2
Sep-22 7.37 6 9 May-22 0.11 2
Oct-22 6.39 6 9 Jun-22 0 2
Nov-22 6.66 6 9 Jul-22 0 2
Dec-22 7.31 6 9 Aug-22 0.066 2
Jan-23 6.2 6 9 Sep-22 0.11 2
Feb-23 6.2 6 9 Oct-22 0.1 2
Mar-23 7.26 6 9 Nov-22 0.12 2
Apr-23 6.1 6 9 Dec-22 0.15 2
May-23 6.55 6 9 Jan-23 0.11 2
Jun-23 7.55 6 9 Feb-23 0.11 2
Jul-23 6.94 6 9 Mar-23 0.14 2
Au -23 6.39 6 9 Apr-23 0.079 2
Grand Total 275.21 246 369 May-23 0.076 2
Jun-23 0.21 2
Jul-23 0.14 2
Au -23 0.078 2
Grand Total 6.948 90

PhosphorusBM Phosphorus Data
Month Nitrogen BM Nitrogen NitrogenBM Nitrogen
2.5 Jul-18 0 30 35
Oct-18 0 30 30
2 - - - - - - - - - - - - - - - - - - - - -
Jan-19 0.52 30 zs
1.5 Apr-19 0 30
Jul-19 0.81 30 20
1 Oct-19 0.5 30 15
Jan-20 0.56 30 10
0.5 Apr-20 0.93 30
5
Jul-20 0.59 30
O Aug-20 1.25 30 0
0 0 0 0
N75 7_ 4 > .6 ` N 6 N N O N N m i N .6 N Se 20 2.59 30 _ _ _ ; ` N m Y N
z LL a ¢ o a LL a Oat-20 2.88 30 z LL a ¢' o o LL a
Month Nov-20 4.82 30 Month
Dec-20 1.2 30
Feb-21 0.63 30
Mar-21 0.52 30
Apr-21 1.4 30
May-21 0.82 30
Jun-21 0.94 30
Jul-21 0.52 30
Aug-21 0.56 30
Sep-21 0.52 30
Oct-21 0.52 30
Nov-21 0.83 30
Dec-21 0.54 30
Jan-22 0 30
Feb-22 0 30
Mar-22 0.39 30
Apr-22 0.61 30
May-22 0.84 30
Jun-22 0.97 30
Jul-22 0.6 30
Aug-22 0.308 30
Sep-22 0.56 30
Oct-22 0.37 30
Nov-22 0.28 30
Dec-22 0.49 30
Jan-23 0.61 30
Feb-23 0.62 30
Mar-23 0.55 30
Apr-23 0 30
May-23 0.22 30
Jun-23 0.62 30
Jul-23 0.57 30
Au -23 0.45 30
Grand Total 33.508 1350

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2023 Tier 3 Response Summary
December 2022 Stormwater *Corrective actions must be implemented within 60 days of sampling event
Sample
Date Results Benchmark(s) Benchmark Value Actual Value
Collection Investigation Notes Investigation Lead
Date: Received: Exceeded (mg/L) (mg/L) Completed
Cadmium 0.001 0.03 Despite TSS being lower than benchmark,sediment that could hold metals is not being controlled.Sediment removal from In-Progress
12/6/2022 12/22/2022 Zinc 0.67 3.47 storm drains has not been completed in 6 months.No PM to clean Energy Dissipator,No Vac-Truck Schedule,Boot washes arE William White Not-Completed
Lead 0.03 0.08 inoperable,Erosion SDO,Admin buildin,hills by Gypsum Pad).No consistent tier log on file.
Action Item Details
Action Date Assigned By Person Due Date Status Completion Date
Number Assigned Responsible
1 1/1/2023 William White Mike Zell 2/20/2023 Sediment Control-SDO repair(New Rip Rap) ompleted 2/16/2023
2 1/1/2023 Kaitlyn Sampson Superintendents 2/20/2023 Sediment Control-Discuss and enforce dry sweeping during EHS meeting ompleted 1/24/2023
3 1/1/2023 William White Site Services 2/20/2023 Sediment Control-Implement Vac-Truck schedule with Site Services %ompleted 2/14/2023
4 1/1/2023 William White Site Services 2/20/2023 Sediment Control-Have Site Services remove sediment from Safe Drains ompleted 2/1/2023
5 1/1/2023 Kaitlyn Sampson Kaitlyn Sampson 2/20/2023 Sediment Control-Safe Drain procedures(switch to normally closed operations) ompleted 1/2/2023
6 1/1/2023 Jan Nedbal Site Services 2/20/2023 Sediment Control-Create quarterly Energy Dissipator cleaning PM ompleted 1/13/2023
7 1/1/2023 William White Mike Zell 2/20/2023 Sediment Control-Design erosion control plan near admin building In-Progress
8 1/1/2023 William White William White 2/20/2023 Sediment Control-Add work orders for all broken boot washes(7 in total) Completed 1/25/2023
9 1/1/2023 William White Kaitlyn Sampson 2/20/2023 Housekeeping-Discuss procedures with Superintendents during monthly walkthroughs ompleted 2/1/2023
10 1/1/2023 William White William White 2/20/2023 Water Management-Increase dry monitoring-Start program and write SWPPP EMP ompleted 5/1/2023
11 1/1/2023 William White Kaitlyn Sampson 2/20/2023 Water Management-Increase sampling plan during qualifying storm events amplete 1/24/2023
12 1/1/2023 William White William White 2/20/2023 Water Management-Investigate possibilities for storm water capturing in plant 2/16/2023
13 1/1/2023 William White Kaitlyn Sampson 2/20/2023 Regulatory Requirement-Create Tier Log for proper tier response 1/23/2023
January 2023 Stormwater *Corrective actions must be implemented within 60 days of sampling event
Sample Date Results Benchmark(s) Benchmark Value Actual Value
Collection Investigation Notes Investigation Lead
Date: Received: Exceeded (mg/L) (mg/L)
Cadmium 0.001 0.06 Sediment that could hold metals is not being controlled.Although drains have been cleaned at the point of entry,it is
1/17/2023 2/1/2023 Zinc 0.67 4.15 unknown how much sediment is in the stormwater conveyance system(Investigation required).Basin one draining confirms
Lead 0.03 0.07 high accumulation of sediment,which could result in high metal loads being released from the outfall during qualifying William White
Cadmium 0.001 0.06 storms.Environmental has still noticed that boot washes and general housekeeping procedures are not being used.Drains are
1/25/2023 2/6/2023 Zinc 0.67 4.25 still being left open,or are not opened when it rains(resulting in sediment pooling).
Lead 0.03 0.06
Action Item Details
Action Date Assigned By Person Due Date Title Status Completion Date
Number Assigned Responsible
1 2/1/2023 William White Kaitlyn Sampson 4/7/2023 Housekeeping-Perform inspection of all bootwash stations to ensure proper functionality Completed 1/23/2023
2 2/1/2023 William White William White 4/7/2023 Sediment Control-Submit MOC for PLINT bootwash Completed 2/6/2023
3 2/14/2023 William White Simon Joy 4/7/2023 Water Management-Operations revise SafeDrain notification verification procedures Completed 2/27/2023
4 2/14/2023 William White Kaitlyn Sampson 4/7/2023 Water Management-Draining Basin 1 for Sampling/Confirm Sediment accumulation Completed 2/17/2023
5 2/14/2023 William White William White 4/2/2023 Water Management-Purchase storm drain sampling collection pods Completed 3/9/2023
5 2/13/2023 William White Simon Joy 4/7/2023 Sediment Control-Institute Vac Truck usage plan--Agreed to 4-hrs per week(Whole Plant) Completed 2/14/2023
6 2/14/2023 William White Simon Joy 4/7/2023 Sediment Control-Institute Operations Vac Truck usage Log-Collected by Environmental Monthly Completed 2/27/2023
7 1 2/14/2023 William White Simon Joy 4/7/2023 Sediment Control-Institute Vac Truck Maintenance Log completed 2/27/2023
February 2023 Stormwater *Corrective actions must be implemented within 60 days of sampling event
Sample Date Results Benchmark(s) Benchmark Value Actual Value
Collection Received: Exceeded (mg/L) (mg/L) Investigation Notes Investigation Lead
Date:
Cadmium 0.001 0.061 Sediment is being controlled,but more understanding of the site is needed in order to assess where high level of constitutes
2/2/2023 2/28/2023 Zinc 0.67 4.59 are coming from.General housekeeping is still an issue.The Environmental department is drafting a sediment/water sampling William White
Lead 0.03 0.059 cam ai n to create"Zones"to increase the knowled a of the site.
Action Item Details
Action Date Person
Assigned By Due Date Title Status Completion Date
Number Assigned Responsible
1 3/13/2022 William White William White 5/12/2022 Sediment Control-Create Soil/Water Sampling Plan to create Zones Map Complete 4/1/2023
2 3/13/2022 William White William White 5/12/2022 Housekeeping-Inspect every SW drains,and note repairs Complete 3/21/2023
OPR:BEFESA ZINC METAL ENVIRONMENTAL DEPARTMENT

Young, Brianna A
From: Jan Nedbal <[e-mail]>
Sent: Thursday, October 27, 2022 8:46 AM
To: Young, Brianna A
Subject: [External] Befesa (American Zinc Products) Stormwater Permit Renewal
Attachments: NPDES Stormwater Permit NCS000562 Renewal - FINAL 2022.10.25 Signed JN.pdf
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Brianna,
Please find the attached final copy of Befesa's Stormwater Permit NCS000562 Renewal application. Signed originals have
been FeclExed today as well.
Kind Regards,
BEFESA
Jan Nedbal I Acting Environmental Manager—Befesa Zinc Metal
484 Hicks Grove Road,Mooresboro,North Carolina 28114
Cell: [phone] 1 Fax: [phone]
[e-mail]
i

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:
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
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.
4. A summary of the Best Management Practices utilized at the permitted facility.
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
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)
i
i

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 or tank 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.
Monitorinq 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.
Ongoing 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 ERA
Application for NPDES Permit to Discharge Wastewater
NPDES h/ GENERAL INFORMATION
1.1 Applicants Not Required to Submit Form 1
Is the facility a new or existing publicly owned Is the facility a new or existing treatment works
1.1,1 treatment works? 1,1.2 treating domestic sewage?
If yes,STOP.Do NOT complete F,"77I No If yes,STOP.Do NOT 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,
E operation or a concentrated aquatic animal commercial,mining,or silvicultural facility that is
a production facility? currently discharging process wastewater?
oYes 4 Complete Form 1 No 0 Yes 4 Complete Form No
z and Form 26. 1 and Form 2C.
R 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 F✓ No Yes 4 Complete Form No
CD
W and Form 2D. 1 and Form 2E.
UN
1.2.5 Is the facility a new or existing facility whose
discharge is composed entirely of stormwater
associated with industrial activity or whose
discharge is composed of both stormwater and
non-stormwater?
Yes 4 Complete Form 1 No
and Form 2F
unless exempted by
40 CFR
122.26(b)(14)(x)or
b 15 .
2.1 Facility Name
Befesa Zinc Metal,LLC
M0 2.2 EPA Identification Number
m
0 NCR000159038
R 2.3 Facility Contact
Name(first and last) Title Phone number
L
a Jan Nedbal Environmental Manager [phone]
-a
Q
Email address
[e-mail]
2.4 Facility Mailing Address
W 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 03/05/19
NCR000159038 NCS000562 Befesa Zinc Metal,LLC OMB No.2040-0004
2.5 Facility Location
a Street,route number,or other specific identifier
a U 484 Hicks Grove Road
0 County name County code(if known)
Rutherford County 161
E _j City or town State ZIP code
z ,co Mooresboro North Carolina 28114
• a o ' •� i
3.1 SIC Code(s) Description(optional)
3341 Secondary Nonferrous Metals
N
N
-a
O
U
U
z 3.2 NAICS Code(s) Description(optional)
c
R
U
4.1 Name of Operator
Befesa Zinc Metal,LLC
0 4.2 Is the name you listed in Item 4.1 also the owner?
R
E 0 ❑✓ Yes ❑ No
4.3 Operator Status
CIO ❑ Public—federal ❑ Public—state ❑Other public(specify)
C ❑✓ Private ❑ Other(specify)
4.4 Phone Number of Operator
[phone]
4.5 Operator Address
Street or P.O. Box
R
E 484 Hicks Grove Road
CID
City or town State _ZIP code
`0 0 Mooresboro North Carolina 28114
� U
o Email address of operator
0 [phone]
0 5.1 Is the facility located on Indian Land?
`� ❑Yes ❑✓ 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
6.1 Existing Environmental Permits(check all that apply and print or type the corresponding permit number for each)
d ❑ NPDES(discharges to surface ❑ RCRA(hazardous wastes) ❑ UIC(underground injection of
r_ water) fluids)
o 12 NCS000562
w a
C ❑✓ PSD(air emissions) ElNonattainment program(CAA) ❑ NESHAPs(CAA)
10248R07
❑ Ocean dumping(MPRSA) ❑ Dredge or fill(CWA Section 404) ❑✓ Other(specify)
NCG500000(NC Cooling)
• a � 1
7.1 Have you attached a topographic map containing all required information to this application?(See instructions for
Co specific requirements.)
❑✓ Yes ❑ No ❑ CAFO—Not Applicable(See requirements in Form 213.)
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
U) 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
00 delivered to the subject facility from local and international sources.The specific technologies and configuration of
O the operation are confidential business information.
d
z
9.1 Does your facility use cooling water?
❑ Yes ❑ No 4 SKIP to Item 10.1.
9.2 Identify the source of cooling water.(Note that facilities that use a cooling water intake structure as described at
M 40 CFR 125,Subparts I and J may have additional application requirements at 40 CFR 122.21(r).Consult with your
ocoNPDES permitting authority to determine what specific information needs to be submitted and when.)
V � Forest City,NC Water Supply
c
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
N apply.Consult with your NPDES permitting authority to determine what information needs to be submitted and
when.)
cu
d ❑ Fundamentally different factors(CWA ❑ Water quality related effluent limitations(CWA Section
Section 301(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 03/05/19
NCR000159038 NCS000562 Befesa Zinc Metal,LLC OMB No.2040-0004
SECTION 11.CHECKLIST 1 I
11.1 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.
Column 1 Column 2
0 Section 1:Activities Requiring an NPDES Permit ❑ w/attachments
❑✓ Section 2:Name,Mailing Address,and Location ❑ wl attachments
❑✓ Section 3:SIC Codes ❑ w/attachments
❑✓ Section 4:Operator Information ❑ w/attachments
❑✓ Section 5:Indian Land ❑ w/attachments
❑✓ Section 6:Existing Environmental Permits ❑ w/attachments
w/topographic
❑✓ Section 7:Map 0 map Elw/additional attachments
o ❑✓ Section 8:Nature of Business ❑ w/attachments
❑✓ Section 9:Cooling Water Intake Structures ❑ w/attachments
�e
❑✓ Section 10:Variance Requests ❑ w/attachments
N_ Section 11:Checklist and Certification Statement ❑ wl attachments
Y
Q3 11.2 Certification Statement
s
U
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.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
i
i
EPA Form 3510-1(revised 3-19) Page 4

N
SIR
a. (�
• ,,
WASTEWATER AND
•� -
. 1
1
1
y rjL
DISCHARGE LOCATION
.; � � ��� �Il• Lam►
FIR
ill
_ FIGURE
DISCHARGE LOCATION MAP
LLC
BEFE
� .,
RUTHERFORD COUNTY, • CAROLINA

NPDES Form 2F
Stormwater Discharges
Associatedi Industrial Activity

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NCR000159038 NCS000562 Befesa Zinc Metal,LLC OMB No.2040-0004
Form c U.S Environmental Protection Agency
2F \/Gn Application for NPDES Permit to Discharge Wastewater
NPDES STORMWATER DISCHARGES ASSOCIATED WITH INDUSTRIAL ACTIVITY
1.1 Provide information on each of the facilit 's 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
c
0
U
O
tQ
0
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
c
m
E
a
0
a
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,LLC OMB No.2040.0004
a� 3.1 Have you attached a site drainage map containing all required information to this application?(See instructions for
specific guidance.)
65
o ® Yes ❑ No
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
specify units specify units
specify units specify units
specify units specify units
specify 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
U) table referred to in Section 4.3 for descriptions and locations of the BMP's utilized to prevent and address the
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 03/05/19
NCR000159038 NCS000562 Befesa Zinc Metal,LLC OMB No.2040-0004
SECTION • •' 1 1
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
rn 5.2 Provi e t e testing information requ st d in the table below.
= Onsite Drainage Points
Outfall Description of Testing Method Used Date(s)of Testing Directly Observed
o Number During Test
d
m
3
E
0
w
0
z
SECTION •• SPILLS t CFR /
6.1 Describe any significant leaks or spills of toxic or hazardous pollutants in the last three years.
See attached Significant Spill Record
.Q
U)
`0
NY
W
N
J
C
V
.0
U)
SECTIONDISCHARGE INFORMATION1
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.
7.1 Is this a new source or new discharge?
o ❑ Yes 4 See instructions regarding submission of ❑ No 4 See instructions regarding submission of
estimated data. actual data.
d
tm
Tables A,B,C,and D
N 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
NCR000159O38 NCSO00562 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-3, 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?
0 Yes ❑ No 4 SKIP to Item 7.7.
7.6 Have you listed all pollutants in Exhibit 2F-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?
0 ❑✓ Yes ❑ No
0 7.10 Do you expect any of the pollutants in Exhibit 217-3 to be discharged in concentrations of 10 ppb or greater?
E ❑ Yes ❑ No 4 SKIP to Item 7.12.
0
7.11 Have you provided quantitative data in Table C for those pollutants in Exhibit 217-3 that you expect to be discharged in
c concentrations of 10 ppb or greater?
Ca
0 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)?
0 Yes ❑ No
7.15 Do you know or have reason to believe any pollutants in Exhibit 2F-4 are present in the discharge?
❑ Yes M 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 M No
EPA Form 3510-2F(Revised 3-19) Page 4

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NCR000159O38 NCS000562 Befesa Zinc Metal,LLC OMB No.2040-0004
o Used or Manufactured Toxics
7.18 Is any pollutant listed on Exhibits 217-2 through 2F-4 a substance or a component of a substance used or
manufactured as an intermediate or final product or byproduct?
�' ❑✓ Yes ❑ No 4 SKIP to Section 8.
0
E 7.19 List the pollutants below,including TCDD if applicable.
1,Cadmium 4. 7.
a
rn
s
2•Lead 5' 8'
U
0 L3.ZiinL 6. 9.
• • oRki• i ,
8.1 Do you have any knowledge or reason to believe that any biological test for acute or chronic toxicity has been made on
any of your discharges or on a receiving water in relation to your discharge within the last three years?
0
0 Yes ❑ No 4 SKIP to Section 9.
8.2 Identify the tests and their purposes below.
Submitted to NPDES
.x
Test(s) Purpose of Tests) Permitting Authority? Date Submitted
0
~ Fish Tissue Sampling Biological,Under NPDES Fell � Yes ❑ No
CO G�
U_
a' El Yes ❑ No
0
0
m
❑ Yes ❑ No
• e 61 ait In I Is] i
9.1 Were any of the analyses reported in Section 7(on Tables A through C)performed by a contract laboratory or
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
0
a
m
E
0
Laboratory address
,� Y 9800 Kincey Ave. Suite 100
N Huntersville,NC 28078
T
R
C
Q
V
R
c Phone number
0
V [phone]
Pollutants)analyzed All pollutants lists in Tables A,
B,and C.
EPA Form 3510-21'(Revised 3-19) Page 5
j
i

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NCR000159038 NCS000562 Befesa Zinc Metal,LLC OMB No.2040-0004
SECTION1 CHECKLIST AND CERTIFICATION1
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 ❑ wl attachments(e.g.,responses for additional outfalls)
0 Section 2 ❑ wl attachments
❑✓ Section 3 ❑✓ w/site drainage map
❑✓ Section 4 ✓❑ w/attachments
❑✓ Section 5 ❑ w/attachments
❑✓ Section 6 ED w/attachments
E ❑✓ Section 7 ❑✓ Table A ❑ w/small business exemption request
"' ❑✓ Table B ✓❑ wl analytical results as an attachment
0
❑✓ Table C ❑ Table D
LE
0 ❑✓ Section 8 ❑ w/attachments
N ❑✓ Section 9 ❑ wlattachments(e.g.,responses for additional contact laboratories or firms)
7
CD
❑ Section 10 ❑
U
10.2 Certification Statement
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.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
i
I,
EPA Form 3510-21'(Revised 3-19) Page 6

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

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

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FORM 2F: SECTION 6 ATTACHMENTS
SIGNIFICANT SPILL RECORD

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

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Appendix
SPPP Certification r

STORMWATER POLLUTION PREVENTION PLAN
DEVELOPMENT AND IMPLEMENTATION
CERTIFICATION
North Carolina Division of Energy, Mineral, and Land Resources— Stormwater Program
Facility Name: Sefesa Zinc Mere),LLC
Permit Number: NCS000562
Location Address: 404 Hicks Grove Road
Mooresboro,NC 20114
County:
Rutherford County
"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
Ili f 2b• ,
Print or type name of person signing above Title
SPPP Certification 10/13

Young, Brianna A
From: Georgoulias, Bethany
Sent: Friday, September 9, 2022 7:43 AM
To: Vinson, Toby; Granger, T. Mack; Aiken, Stan E; Smith, Danny; Cole, Albert B
Cc: Young, Brianna A
Subject: RE: American Zinc Products
I agree these are good ideas. Just as perspective from my air quality days, I would recommend investigating the air
deposition to try and quantify that.
All, I am pretty tied up with Laserfiche happenings the next couple weeks, particularly as Bev transitions out of her job at
DWR to start in DWI at the same time we are coordinating important preparation steps for migration. She is also sick
this week, and I'm covering as primary back-up Admin. Feel free to schedule something and I will attend if I can, but I
may not be able to.
Bg
Bethany Georgoulias (she/her)
Environmental Engineer
Stormwater Program,Division of Energy,Mineral,and Land Resources
N.C.Department of Environmental Quality
919 707 3641 office
bethan .georgoulias(@ncdenr.gov
512 N. Salisbury Street, Raleigh, NC 27604 (location)
1612 Mail Service Center, Raleigh, NC 27699-1612 (mailing)
Website: http://deq.nc.gov/about/divisions/energy-mineral-land-resources/stormwater
tff,DEQ>
vay."a W w Emuau.MnM mairy\
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has
adjusted operations to protect the health and safety of the staff and public. Many employees are working remotely or
are on staggered shifts.To accommodate these staffing changes, all DEQ office locations are limiting public access to
appointments only. Please check with the appropriate staff before visiting our offices, as we may be able to handle your
requests by phone or email. We appreciate your patience as we continue to serve the public during this challenging
time.
From:Vinson,Toby<[e-mail]>
Sent: Friday, September 9, 2022 7:30 AM
To: Granger,T. Mack<[e-mail]>; Aiken, Stan E<[e-mail]>; Smith, Danny
<[e-mail]>; Cole,Albert B<[e-mail]>
Cc:Young, Brianna A<[e-mail]>; Georgoulias, Bethany<[e-mail]>
Subject: RE:American Zinc Products
1

I think all those are good ideas. Let's get input from Danny, Bethany and Brianna to walk through each of those
individually or as a combination of all. Given the history of this site and the issues you and Isaiah have seen in the past
2-3 years let's also talk seriously about recommendation 3. (the concern there is, how many chances do they get to get
it right???)
tV
William E.Toby Vinson,Jr., PE,CPESC,CPM
Chief of Program Operations and NCORR Liaison
Department of Environmental Quality
Division of Energy, Mineral, and Land Resources
512 N Salisbury St
1612 Mail Service Center
Raleigh, NC 27699
Office: 919-707-9201
Email: [e-mail]
-� E
��D,_
ooWrtm&M al Enriw�wial auamy
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
From: Granger,T. Mack<[e-mail]>
Sent:Thursday,September 8, 2022 4:34 PM
To:Vinson,Toby<[e-mail]>;Aiken, Stan E<[e-mail]>; Smith, Danny
<[e-mail]>; Cole,Albert B<[e-mail]>
Cc:Young, Brianna A<[e-mail]>; Georgoulias, Bethany<[e-mail]>
Subject: RE:American Zinc Products
Toby,
I have three recommendations.
We can request a plan for facility modifications from AZP and place a deadline on implementation. As part of the plan,
AZP must take investigative monitoring samples to demonstrate the effectiveness of the facility modifications.
From my site assessment, I believe volatilized zinc from the industrial process may be a potential point source and is
precipitating out of the air. One suggestion may be to involve air quality or require air sampling for zinc.
2

Lastly,from conversations with Isaiah Reed, an additional option would be to give the permittee 12 months to apply for
and obtain a NPDES discharge permit from Water Quality followed by the revocation of their industrial stormwater
permit.This would be due to the likelihood of chemical treatment effectively rendering this discharge as process water.
Respectfully,
Mack Granger
Environmental Specialist II
Division of Energy, Mineral and Land Resources
North Carolina Department of Environmental Quality
828 296-4500 main
828 296-4613 office
mack.granger(a)ncdenr.gov
2090 US70 Highway
Swannanoa, NC 28778-8211
c,��D- E
aaPWMnwM 01&"Hw row"WWI"
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties
From:Vinson,Toby<[e-mail]>
Sent:Thursday,September 8, 2022 4:13 PM
To: Granger,T. Mack<[e-mail]>;Aiken, Stan E <[e-mail]>; Smith, Danny
<[e-mail]>; Cole,Albert B<[e-mail]>
Cc:Young, Brianna A<[e-mail]>; Georgoulias, Bethany<[e-mail]>
Subject: RE:American Zinc Products
Do you have any recommendations and does the company have any plans to improve discharges to get out of Tier 3
status that are scheduled to be implemented?
tV
William E.Toby Vinson,Jr., PE,CPESC,CPM
Chief of Program Operations and NCORR Liaison
Department of Environmental Quality
Division of Energy, Mineral, and Land Resources
512 N Salisbury St
1612 Mail Service Center
Raleigh, NC 27699
Office: 919-707-9201
Email: [e-mail]
3

D,E Qx&7,A-
6pp�r�me,Hra1 Fnri�on n,{a inl ps,allYy
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
From: Granger,T. Mack<[e-mail]>
Sent:Thursday,September 8, 2022 2:37 PM
To:Aiken, Stan E<[e-mail]>; Smith, Danny<[e-mail]>; Vinson,Toby
<[e-mail]>; Cole,Albert B<[e-mail]>
Cc:Young, Brianna A<[e-mail]>; Georgoulias, Bethany<[e-mail]>
Subject:American Zinc Products
All,
During the latest inspection (attached), American Zinc Products was found to be operating in Tier 3 response. As such,
the Division can require additional tier response.This email serves to open a dialogue, should the Division choose to
pursue additional response. Please let me know your comments.
Respectfully,
Mack Granger
Environmental Specialist II
Division of Energy, Mineral and Land Resources
North Carolina Department of Environmental Quality
828 296-4500 main
828 296-4613 office
mack.granger(@ncdenr.gov
2090 US70 Highway
Swannanoa, NC 28778-8211
�D_ E
QT;&F r"41 brArNg ellij I q%,.,11ty
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties
4

9/26/23, 12:25 PM North Carolina Secretary of State Search Results
• File an Annual Report/Amend an Annual Report • Upload a PDF Filing • Order a Document Online -
Add Entity to My Email Notification List • View Filings • Print a Pre-Populated Annual Report form • Print
an Amended a Annual Report form
Limited Liability Company
Legal Name
Befesa Zinc Metal LLC
Prev Legal Name
American Zinc Products LLC
Prev Legal Name
Horsehead Metal Products, Inc.
Prev Legal Name
Horsehead Metal Products, LLC
Information
Sosld: 1280147
Status: Current-Active O
Date Formed: 9/27/2012
Citizenship: Domestic
Annual Report Due Date: April 15th
Currentgnnual Report Status:
Registered Agent: CT Corporation System
Addresses
Mailing Principal Office Reg Office
150 Fayetteville Street 150 Fayetteville Street 160 Mine Lake Court, Suite 200
Raleigh, NC 27601 Raleigh, NC 27601 Raleigh, NC 27615
Reg Mailing
160 Mine Lake Court, Suite 200
Raleigh, NC 27615
Company Officials
https://www.sosnc.gov/online_services/search/Business_Registration_ResuIts 1/2

9/26/23, 12:25 PM North Carolina Secretary of State Search Results
All LLCs are managed by their managers pursuant to N.C.G.S. 57D-3-20.
Manager
Asier Zarraonadia Ayo
150 Fayetteville Street
Raleigh NC 27601
https://www.sosnc.gov/onIine_services/search/Business_Registration_ResuIts 2/2

Young, Brianna A
From: Young, Brianna A
Sent: Wednesday, November 2, 2022 9:38 AM
To: Jan Nedbal
Cc: [e-mail]
Subject: RE: [External] RE: Befesa (American Zinc Products) Stormwater Permit Renewal
Good morning,
The Division of Energy, Mineral, and Land Resources (DEMLR) Stormwater Permitting Program
acknowledges receipt of your renewal application for coverage under NPDES Permit Number NCS000562.
Please continue to comply with all conditions and monitoring requirements in your current NPDES stormwater
permit. As long as you have submitted a complete renewal request package and maintain compliance with those
permit conditions, stormwater discharges from this facility are authorized by that permit until the Division
issues a renewal permit or notifies you of an alternative action. Please note that due to the current backlog and
staff shortages, review of this permit renewal is not scheduled until 2024,however this schedule is subject to
change. Please let me know if you have any questions in the interim.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From:Jan Nedbal <[e-mail]>
Sent:Thursday, October 27, 2022 11:59 AM
To:Young, Brianna A<[e-mail]>
Subject: RE: [External] RE: Befesa (American Zinc Products) Stormwater Permit Renewal
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
The mailed copies are correct.
i

From:Young, Brianna A<[e-mail]>
Sent:Thursday, October 27, 2022 11:56 AM
To:Jan Nedbal <[e-mail]>
Subject: RE: [External] RE: Befesa (American Zinc Products) Stormwater Permit Renewal
CAUTION:This email originated from outside of the organization. Do not click links or open attachments unless you recognize the
sender and know the content is safe.
Thank you,Jan. I will be on the lookout for the hard copy in the mail.
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
INC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From:Jan Nedbal <[e-mail]>
Sent:Thursday, October 27, 2022 11:41 AM
To:Young, Brianna A<[e-mail]>
Subject: [External] RE: Befesa (American Zinc Products) Stormwater Permit Renewal
Importance: High
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Brianna,
Please disregard the first email's attachment. I just realized my printer did not completely print out the application.
Attached is the full application for renewal.
Thank you
Jan Nedbal
From:Jan Nedbal
Sent:Thursday, October 27, 2022 8:46 AM
To: '[e-mail]'<[e-mail]>
Subject: Befesa (American Zinc Products) Stormwater Permit Renewal
Brianna,
2

Please find the attached final copy of Befesa's Stormwater Permit NCS000562 Renewal application. Signed originals have
been FeclExed today as well.
Kind Regards,
BEFESA
Jan Nedbal I Acting Environmental Manager—Befesa Zinc Metal
484 Hicks Grove Road,Mooresboro,North Carolina 28114
Cell: [phone] 1 Fax: [phone]
[e-mail]
3

25 October 2022
North Carolina Dept.of Energy, Mineral& Land Resources
SW Individual Permit Coverage Renewal I'ON 0 12022
Stormwater Permitting Program
1612 Mall Service Center DEI�.i't-LrlldD Q�1hI_ITY
STORNI'ti`4'A'ER PERM T(ING
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:
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
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 outfal I 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.
�- 4. A summary of the Best Management Practices utilized at the permitted facility.
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.
b. Certification of the development and implementation of a Stormwater Pollution
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
N CG50000.
■ NC0089109 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; and
■ Management in a pond ortank for analysis and then discharge or use for process operations.
The figure attached to Form 2F identifies how stormwaterfrom 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.
Ongoing 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 1
General Information
NPDES FORM 1: GENERAL INFORMATION
DISCHARGE LOCATION MAP

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03105/19
NCR000159038 NC5000562
Befesa Zinc Metal,LLC OMB No.2040-0004
Form U.S.Environmental Protection Agency
1 \=.EPA Application for NPDES Permit to Discharge Wastewater
NPDES GENERAL INFORMATION
REQUIRINGSECTION 1.ACTIVITIES PD r
71.1.1Applicants Not Required to Submit Form 1
Is the facility a new or existing publicly owned Is the facility a new or existing treatment works
treatmentworks? 1.1.2 treating domestic sewage?
If yes, STOP.Do NOT complete No If yes,STOP.Do NOT No
Form 1, Complete Form 2A. complete Form 1.Complete
Form 2S,
1.2 Applicants Required to Submit Form 1
w 1.2.1 Is the facility a concentrated animal feeding 1.2.2 Is the facility an existing manufacturing,
E operation or a concentrated aquatic animal commercial, mining,or silvicultural facility that is
a production facility? currently discharging process wastewater?
aYes 4 Complete Form 1 0 No Yes 4 Complete Form ❑ No
z and Form 26. 1 and Form 2C.
1.2.3 s 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?
Ej Yes 4 Complete Form 1 Z No Yes 4 Complete Form No
and Form 2D, 1 and Form 2E.
gn
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 0 No
and Form 2F
unless exempted by
40 CFR
122.26(b)(14)(x)or
b (15).
ADDRESS,SECTION 2.NAME,MAILING f i
2.1 Facility Name
Befesa Zinc Metal,LLC
0 2.2 EPA Identification Number
U
NCR000159038
b
b 2.3 Facility Contact
V
Name(fist and fast) Title Phone number
Jan Nedbal Environmental Manager [phone]
M 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 03105/19
NCRO00159038 NCS000562
Befesa Zinc Metal,LLC OMB No.2C40-0004
y 2.5 Facility Location
Street,route number,or other specific identifier
Q o 484 Hicks Grove Road
U
0 County name County code(if known)
Rutherford County 161
0
City or town State ZIP code
z cw Mooresboro North Carolina 28114
SECTION •D i
3.1 SIC Code(s) Description(optional)
3341 Secondary Nonferrous Metals
N
N
0
O
U
v7
U
z 3.2 NAICS Code(s) Description(optional)
U
SECTI
• 4.OPERATOR INFORMATIONI
4.1 Name of Operator
Befesa Zinc Metal,LLC
0 4.2 Is the name you listed in Item 4.1 also the owner?
E
o ❑✓ Yes ❑ No
`
4.3 Operator Status
❑ Public—federal ❑ Public—state ❑ Other public(specify)
o ❑✓ Private ❑ Other(specify)
4.4 Phone Number of Operator
t828)829-6172
4.5 Operator Address
Street or P.O. Box
E 484 Hicks Grove Road
`0 0
City or town State ZIP code
o �0 Mooresboro North Carolina 28114
m
a Email address of operator
[phone]
SECTIONI
5.1 Is the facility located on Indian Land?
d E
❑ Yes ❑✓ N o
EPA Form 3510-1 (revised 3-19) Page 2

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NCROOD159038 NCS000562 Befesa Zinc Metal,LLC OMB No.2040-0004
SECTION `• I
6.1 Existing Environmental Permits(check all that apply and print or type the corresponding permit number for each)
❑ NPDES(discharges to surface ❑ RCRA(hazardous wastes) ❑ UIC(underground injection of
� water) fluids)
2 CA
NCS000562
w 0 PSD(air emissions) ❑ Nonattainment program(CAA) ❑ NESHAPs(CAA)
C 1024BRd7
❑ Ocean dumping(MPRSA) ❑ Dredge or fill(CWA Section 404) Other(specify)
NCGS00000(NC Cooiing)
SECTION 7.MAP 1
7.1 Have you attached a topographic map containing all required information to this application?(See instructions for
C specific requirements.)
❑✓ Yes ❑ No ❑ CAFO—Not Applicable(See requirements in Form 2B,)
SECTIONOF I
8.1 Describe the nature of your business.
This facility processes Waelz Oxide fa.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
Enintegrated system of leaching,extraction,stripping,and electrowinning processes.Feed,including metal bearing
CD oxides(e,g.Waeez 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
CO delivered to the subject facility from local and international sources.The specific technologies and configuration of
m
the operation are confidential business information.
ro
z
SECTION ' COOLING WATER INTAKE STRUCTURES(40
9.1 Does your facility use cooling water?
❑✓ Yes ❑ No 4 SKIP to item 10.1.
3 9.2 Identify the source of coaling water.(Note that facilities that use a cooling water intake structure as described at
M 40 CFR 125, Subparts I and J may have additional application requirements at 40 CFR 122.21(r),Consult with your
NPDES permitting authority to determine what specific information needs to be submitted and when.)
D Forest City,NC Water Supply
SECTIONI VARIANCE REQUESTS1 I
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
apply.Consult with your NPDES permitting authority to determine what information needs to be submitted and
when.)
❑ Fundamentally different factors(CWA ❑ Water quality related effluent limitations(CWA Section
Section 301(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 NPI)ES Permit Number Facility Name Form Approved 03105/19
NCR000159038 NC5004562
Befesa Zinc Metal,LLC OMB No.2040-0004
SECTION1 CERTIFICATION STATEMENT(40
11.1 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.
Column 1 Column 2
❑✓ Section 1:Activities Requiring an NPDES Permit ❑ wl attachments
0 Section 2:Name,Mailing Address,and Location ❑ wl attachments
❑✓ Section 3:SIC Codes ❑ wl attachments
❑✓ Section 4:Operator Information ❑ wl attachments
❑✓ Section 5:Indian Land ❑ wl attachments
❑✓ Section 6: Existing Environmental Permits ❑ wl attachments
0
wl topographic Section 7; Map ❑ map ❑ wi additional attachments
a.
0 0 Section 8:Nature of Business ❑ wl attachments
[✓ Section 9:Cooling Water Intake Structures ❑ wl attachments
C
Section 10:Variance Requests ❑ wl attachments
a
c
y Section 11:Checklist and Certification Statement ❑ wl attachments
Y
d 11.2 Certification Statement
U
l certify underpenalty 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. l am aware that there are significant penalties for submitting false information,
including the possibility of lino and imprisonment for knowing violations.
Name(print or type first and last name) Official title
Jan Nedbal Environmental Manager
Signature Date signed
EPA Form 3510-1(revised 3-19) Page 4

JIM
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STORNAWATER
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DISCHARGE LOCATION MAP
119p
- ORD COUNTY, NORTH CAROLINA

NPDES Form 2F
Stormwater Discharges
Associated with Industrial Activity

EPA Identification Number NPDES Permit Number Facifity Name Form Approved 03105119
NCR000159038 NCS000562 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 LOCATIONi
1,1 Provide information on each of the facT 's 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
.12
D
U
O
7
0 o
SECTION "• I
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?
ElYes ✓❑ 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 (listeutfall numbers)
Required Projected
N
C
W
E
U7
7
O
d
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 Identfication Number NPOES Permit Number Facilfty Name Form Approved 03/05/19
NCR000159038 NC5000562 Befesa Zinc Metal,LLC OMB No.2040-0004
SECTIONDRAINAGE !
W 3.1 Have you attached a site drainage map containing all required information to this application?(See instructions for
specific guidance.)
� f9
n` ® Yes ❑ No
SECTIONPOLLUTANT SOURCES !
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 mice radius et the facility) (within a mile radius of the facility)
specify units I specify units
001 1,611,789 SF 2,231,711 SF
specify units specify units
specifyunits spedN units
specify units specify units
specify units specify units
specify 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 stormwaterwith 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
rn table referred to in Section 4.3 for descriptions and locations of the BMP's utilized to prevent and address the
exposure of Waelz Oxide and Gypsum to stormwater at the facility,including but not limited to street sweeping,
2 containments,and Safe Drain proprietary storm drain inlet valves.
`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
007 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 03105/19
NCR0001.59038 NCS000562 Befesa Zinc Metal,LLC OMB No.2040-0004
SECTION •N STORMVVATER DISCHARGES" 1
5.1 l certify under penalty of law that the ouffail(s) covered by this application have been tested or evaluated for the
presence of non-stormwater discharges. Moreover, l certify that the eutfalls identified as having non-stormwafer
discharges are described in either an accompanying NPD1=S Form 2C, 2D,or 2E application.
Name(print or type first and last name) Official title
Y1,T�
Signature Date signed
2 .2Z
21 5.2 Provi e t e testing Information requ st d in the table below.
U Ootfall Onsite Drainage Points
Number Description of Testing Method used Date(s)of Testing Directly Observed
During Test
3
E
`o
c
0
z
SECTIONOR i
6.1 Describe any significant leaks or spills of toxic or hazardous pollutants in the last three years.
En See attached Significant Spill Record
0
Y
f9
Q1
J
C
L]
.E
See the instructions to determine the pollutants and parameters you are required to monitor and,in turn,the tables you must
o com lete.Not all applicants need to complete each table.
E 7.1 Is this a new source or new discharge?
❑ Yes 4 See instructions regarding submission of ❑ No 3 See instructions regarding submission of
estimated data. actual data.
Tables A,B,C,and D
N 7.2 Have you completed Table A for each outfall?
❑✓ Yes ❑ No
EPA Form 3510-2F(Revised 3-19) Page 3

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NCROOO159O38 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 2F-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-+SKIP to Item 7.18. 0 No
7.8 Do you know or have reason to believe any pollutants in Exhibit 2F-3 are present in the discharge?
0 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
C Table C?
C
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 ❑ No 4 SKIP to Item 7.12.
0
7.11 Have you provided quantitative data in Table C for those pollutants in Exhibit 2F-3 that you expect to be discharged in
rn 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 0 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 0 No
EPA Form 3510-21'(Revised 3-19) Page 4

EPA Identifcation Number NPDES Permit Number Facility Name Form Approved 03105119
NCROOD159038 NCS000562 Befesa Zinc Metal,LLC OMB No.2040-0004
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
manufactured as an intermediate or final product or byproduct?
0
0 Yes El >C SK1P to Section 8•
C
0
CZ 7.19 List the pollutants below,including TCDD if applicable.
E
c
I.Cadmium 4. 7.
as
L
2.Lead 5. 8•
U
p 3•zinc 6. 9.
SECTION •GICAL TOXICITY TESTING DATA ,i
8.1 Do you have any knowledge or reason to believe that any biological test for acute or chronic toxicity has been made on
:a any of your discharges or on a receiving water in relation to your discharge within the last three years?
co
0
tm
0 Yes ❑ No 4 SKIP to Section 9.
8.2 Identify the tests and their purposes below.
Test(s) Purpose of Test(s) Submitted to NPDES Date Submitted
x Permitting Authority?
0
~ Fish Tissue Sampling Biological,Under NPDES Perm 0 Yes ❑ No
m
a ❑ Yes ❑ No
0
oa ❑ Yes ❑ No
CONTRACTSECTION 9. •' • I
9.1 Were any of the analyses reported in Section 7(on Tables A through C)performed by a contract laboratory or
consulting firm?
21 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
o
E
o �
Vj I Laboratory address 9800 Kincey Ave. Suite 100
} i Huntersville,NC 28078
m
d
U
o Phone number
v [phone]
Pollutant(s)analyzed All pollutants lists in Tables A,
B,and C.
EPA Form 3510.2F(Revised 3-19) Page 5

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03105119
NCR000159038 NCS000562 Befesa Zinc Metal,LLC OMS No.2040.0004
SECTIONI CHECKLIST AND CERTIFICATION STATEMENT1
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 t Column 2
❑ Section 1 ❑ wl attachments(e.g.,responses for additional outfalls)
R] Section 2 ❑ wl attachments
❑ Section 3 ❑ wl site drainage map
❑ Section 4 ✓❑ wl attachments
✓❑ Section 5 ❑ wl attachments
� ❑ Section 6 0 wi attachments
❑✓ Section 7 ❑ Table A ❑ wl small business exemption request
R
❑ Table 8 ❑ wl analytical results as an attachment
0
❑ Table C ❑ Table D
U Section 8 ❑ wlaftachments
❑✓ Section 9 ❑ wlattachments(e.g.,responses for additional contact laboratories or firms)
Y
❑ Section 10 ❑
10.2
Certification Statement
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 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.l 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
a A-AV
EPA Form 3510-2F(Revised 3-19) Page 5

EPA Identification Number NPDES Permit Number Facility Name Outfall Number Form Approved 03/05/19
NCR000159038 NC5000562 Befesa Zinc Metal,LLC 001(SDO) OMB No.2040-0004
CONVENTIONAL AND NON CONVENTIONAL
You must provide the results of at least one analysis for every_. ollutant in this table.Complete one table for each outfall.See instructions for additional details and re uirements.
Maximum Daily Discharge Average Daily Discharge Source of
(spec4yunits) (specify units) Number of Storm Information
Pollutant or Parameter Grab Sample Taken Flow-Weighted Grab Sample Taken Flow-Weighted Events Sampled (new source/new
During First During First dischargers only;use
30 Minutes Composite 30 Minutes Composite codes in instructions)
1. Oil and grease 5.1 mg/L <5.0 mg/L 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
pH(minimum) 5.7 SU L2 5U 46
8,
pH(maximum) 9.6 SU 108.2 SU F=46
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 Farm 3510-2F(Revised 3-19) Page 7

This.page'intentionally,left blank.

EPA Identficafion Number NPDES Permit Number Facility Name Outfall Number Form Approved 03/05119
NCR000159038 NC5000562 Befesa Zinc Metal,LLC 001(5DO) :1 OMB No.2040.DD04
—TABLE B.CERTAIN CONVENTIONAL AND NON CONVENTIONAL POLLUTANTS(40 CFR 122.26(c)(1)(i)(E)(4)and 40 CFIR 122.21(g)(7)(vl)(A))1
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 outfall.See the instructions for additional details and requirements.
Maximum Daily Discharge Average Daily Discharge Source of
(sped units s eci units Number of Storm Information
Pollutant and CAS Number(if available) Grab Sample Taken Flow-Weighted Grab Sample Taken Flow-Weighted Events Sampled (new sourceinew
During First During First dischargers only,use
30 Minutes Composite 30 Minutes Composite codes in instructions)
Chlorides 1080 mg/L N/A 40.0 mg/L N/A 16
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 O.See instructions and 40 CFR 122.21(e)(3).
EPA Form 3510-2F(Revised 3-19) Page 9

This page intentionally left.blank.

EPA Identification Number NPDES Permit Number Facility Name Outfall Number Form Approved 03/05/19
NCR000159038 NC5000562 Befesa Zinc Metal,LLC 001(5DO) OMB No.2040-0004
• [11;011111 - i• rr • r r
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 outfall.See the instructions for additional
details and requirements.
Maximum Daily Discharge Average Daily Discharge Source of
s eci units s ecif units Number of Storm Information
Pollutant and CAS Number(if available) Grab Sample Taken Grab Sample Taken (new source/new
During First Flow Weighted During First Flow-Weighted Events Sampled dischargers only;use
30 Minutes Composite 30 Minutes Composite codes in instructions)
Cadmium 17440-43-9) 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/t. 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
Sampling shall be conducted according to sufficiently sensitive test procedures(i.e.,methods)approved under 40 CFR 136 for the analysis of pollutants Dr pollutant parameters or
required under 40 CFR chapter I,subchapter N or 0.See instructions and 40 CFR 122.21(e)(3).
EPA Form 3510-2F(Revised 3-19) Page 11

TVs-page intentionally left blank.

-T-
EPA identification Number NPDES Permit Number Facility name Oulfall Number Form Approved 43/05/19
NCROOD159038 NC5000562 Be€esa Zinc Metal,LLC 001(5D0) OMB Na.2444-0444
STORMTABLE D. •- • I
Provide data for the storm event(s)that resulted in the maximum daily discharges for the flow-weighted composite sample.
Number of Hours Between
Total Rainfall During Maximum Flow Rate
Duration of Storm Event Beginning of Storm Measured and Total Flow from Rain Event
Date of Storm Event (in hours) Storm Event End of Previous Measurable Rain During Rain Event (in gallons or specify units)
(in inches) Event (in gpm or specify units}
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 3514-2F(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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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
0 0 G o w
a 0 c
vi a o o a°
0 0 0 0 0 0 0 0 ro R L w O a c m w ° 0
Best Management Practice(BMP) 0 0 0 0 a 0 0 0 ¢ a-
BMP Description N m v sn ;a n m 0 m W In vt c m P. 'A +
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Compliance Obligations Compliance obligations are met and items are reviewed for improvement.
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 Assessment Benchmark Assessments are completed and Tiered responses have an
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. I !
f
Floors/Liners are maintained,free of debris and cracks. If issues are found �.
Containment-Floors/Liners upon visual inspection,a repair plan is developed to remedy the issue. x x x x j x x
These are monitored under a regular inspection program.
Containment-Walls Walls are kept free of debris an outside.These are monitored under a
regular inspection program.
Conta€nment-Roofs Roofs are maintained to prevent leaking.The roof is monitored under a
regular inspection program.
Containment Reviews _ Regular reviews are completed by area under an inpsection 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.
BMA Assessment

BMP Assessment
Area
m
o io c Li
a o 0 5 v
Best Management Practice BMP o 0 0 0 0 0 0 o ro c � q � V .0.p1+ 'n n o
R ) o 0 0 0 0 0 0 0 4 s
BMP Description a o �
� � o
P tt N m ce u� m n rn oo � 0. � � �
,y N C fD C 3
o a' W w W
w 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.
Storm pond-East Pond is operational and appropriate. Liner is inspected per PM schedule
and is maintained
Storm pond-West Pond is operational and appropriate. Liner is inspected per PM schedule
and is maintained
Maintenance Pond-West Pond is no longer operational and now serves as a secondary containment.
Liner is inspected per PM schedule and is maintained
Effluent Pond Pond is operational and appropriate. Liner is inspected per PM schedule
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
Raffinate Pond Pond is no longer operational and now serves as a secondary containment.
Liner is inspected per PM schedule and is maintained
Water from west storm pond is no longer released to Basin 1. This would
Operator Inspection before Discharge
only be implemented in the event of an emergency.
Inlet inspections Regular inspections are completed,issues have a repair plan
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. x x
Boot wash stations Boot washes areto present tracking of debris in buildings or site caused by
footwear.The wash water from the boot wash is returned to the process.
Chemical storage Practices Chemicals are stored per regulatory requirements x_ x x x x x x x x..
Emergency Plan is kept up-to-date and is tested.Drills are performed. l
Emergency Response Plan x'
Further training is in process of implementation
BMP Assessment

BMP Ass -nt
Area
m `o
C C C p N
C o M p G - C LU
' of CR 0. N d
C G o O o 0 o 0 'o C ti d u
Best Management Practice(BMP) 3 c m +n c
BMP Description 0 0 0 0 0 0 0 0 ¢ o p ro M a
nr m v Gn to r, m o ro to '� c ro ° +n «
m y C =
0 o a L
o U
EH5 Audits for Housekeeping Regular audits are completed for housekeeping under an in-house
___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 x x x x
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 x x x r
weekly.
Training Regulatory training of facility personell is completed initially and annually. x x x x x x
BMP Assessment

FORM 2F: SECTION 6 ATTACHMENTS
SIGNIFICANT SPILL RECORD

AZP Significant Spill Record
Date Incident Actions
Gypsum Pad-Truck Wash leak to Documentation on file. Material did not reach Broad River. NRC and DEQ notified. No RQ released. Velocity
1/3/2019 stormwater drain Report IN-20190104-001,NRC Report#1234535
Documentation on file. Fire caused low pH/High metals electrolyte to be collected in Basin 1. Due to significant
4/28/2019 Fire at Electrowinning 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 off loading occurred when a pipe failed during a pneumatic offloading operation. The release was reported out of an
piping system. 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 2Fe SECTION l ATTACHMENTS
ANALYTICAL MONITORING DATA SUMMARY
(MAXIMUM DISCHARGE VALUE HIGHLIGHTED)
VISUAL MONITORING DATA SUMMARY

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Visual Monintoring Data Summary
Floating ,- .-.
Clarity
Outfall
Sample date Color Odor (1-5) Solids Solids Any Foam? Oil Sheen? Erosion? Obvious Indic@tors?
7/19/2018 Clear None 2 1 2 No No No
Reddish Brown,
9/28/2D18 none 2 1 2 No Na No
Medium
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
11/25/2020 NA NA NA NA NA NA NA NA Reportcomp[eted 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
2/11/2021 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 Brawn 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 TOLLUTION PREVENTION PLAN
DEVELOPMENT AND IMPLEMENTATION
CERTIFICATION
North Carolina Division of Energy. Mineral, and Land Resources—Stormwater Program
Facility Name: safes Zft M-W.LLC
Permit Number: NCSOD0582
Location Address: 484 Hkhe Gm Real
Momosbor.NC 28114
County:
Ruthortortl County
"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 \a� Date e of , ' ""'li
k) �b ��� .
Print or type name of person signing above Title
SPPP Certification 10/13