NC0089109_Modification_20170906

WarerResources
ENVIRONMENTAL QUALITY
September 08, 2017
Robert Williamson, General Manager
American Zinc Products LLC
484 Hicks Grove Rd
Mooresboro, NC 28114
Subject: Permit Renewal
Application No. NCO089109
American Zinc Products, LLC
Rutherford County
Dear Applicant:
ROY COOPER
G"ffnar
MICHAEL S. REGAN
secmfary
S. JAY ZIMMERMAN
Dlmefor
The Water Quality Permitting Section acknowledges the September 6, 2017 receipt of your permit modification
application and supporting documentation. Your application will be assigned to a permit writer within the Section's
NPDES WW permitting branch. Per G.S. 1506-3 your current permit does not expire until permit decision on the
application is made. Continuation of the current permit is contingent on timely and sufficient application for renewal of
the current permit. The permit writer will contact you if additional information is required to complete your permit
renewal. Please respond in a timely manner to requests for additional information necessary to allow a complete review
of the application and renewal of the permit.
Information regarding the status of your renewal application can be found online using the Department of Environmental
Quality's Environmental Application Tracker at:
https://dgg. nc.gov/permits-regulations/permit-guidance/environmental-application-tracker
If you have any additional questions about the permit, please contact the primary reviewer of the application using the
links available within the Application Tracker.
Sincerely,
J- " ski
Wren The ford
Administrative Assistant
Water Quality Permitting Section
cc: Central Files w/application (ARO)
ec: WQPS Laserfiche File w/application
State of North Carolina 1 Environmental Quality I Water Resources
1617 Mall Service Center I Raleigh, North Carolina 27699-1617
919-807-6300

AMERICAN
A,ZPZINC PRODUCTS
An AZR Company
August 31, 2017
Sergei Chernikov, Ph.D.
Environmental Engineer II
Complex NPDES Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
Express Mail: 512 N. Salisbury St., Raleigh, NC 27604
Re: NPDES Major Modification, Permit NCO089109
Dear Dr. Chernikov:
484 Hicks Grove Road
Mooresboro, NC 28114
www azr com
RECEIVED/NCDEQ/DWR
SEP 0 6 2017
Water Quality
Permitting section
We are requesting a major modification to the site NPDES permit NCO089109 thereby
increasing the flow limit to 0.979 MGD. Please find enclosed two (2) copies of the
Engineering Alternatives Analysis and the Short Form C -MI. Also included is a check for
the modification fee of $260.
Thanks for your assistance on this project. If you have any questions, please don't
hesitate to contact me at 828-919-3134 or Jim Harris at 828-919-3139.
Rob Williamson, General Manager
cc: Ali Alavi

NPDES PERMIT APPLICATION - SHORT FORM C - Minor Industrial
f Minor industrial, manufacturing and commercial facilities.
Mail the complete application to:
N. C. Department of Environment and Natural Resources
Division of Water Quality / NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
NPDES Permit Number INCO089109
Please pant or type.
1. Contact Information:
Owner Name
Facility Name
Mailing Address
City
State / Zip Code
Telephone Number
Fax Number
e-mail Address
American Zinc Recycling LLC
American Zinc Products LLC
484 Hicks Grove Road
Mooresboro
North Carolina, 28114
828-919-3135
RECEIVED/NCDEWWR
qtr u4i-H17
828-245-4237
Water Quail Y
jharris@azr com Permitting Section
2. Location of facility producing discharge:
Check here if same as above
Street Address or State Road
City
State / Zip Code
County
3. Operator Information:
Name of the firm, consultant or other entity that operates the facility (Note that this is not referring to the
Operator to Responsible Charge or ORC)
Name American Zinc Products LLC
Mailing Address 484 Hicks Grove Road
City Mooresboro
State / Zip Code North Carolina, 28114
Telephone Number
Fax Number
4. Ownership Status:
Federal ❑
Page 1 of 5
828-919-3135
828-245-4237
State ❑
Private
Public ❑
C -M 110/08

NPDES PERMIT APPLICATION - SHORT FORM C - Minor Industrial
Minor industrial, manufacturing and commercial facilities.
5. Standard Industrial Classification (SIC) code(s): 3341
6. Number of employees: Approx. 300
7. Describe the treatment system List all installed waste treatment components with capacities,
describe the processes that generate wastewaters. If the space provided is not sufficient attach a
separate sheet of paper with the system description.
Discharge water is generated during the zinc production processes which includes
leaching, extraction, stripping and electrowinning. The series of technologies used to
produce zinc from this facility provides a high degree of metals removal from the process
flow stream, resulting in a discharge with low levels of metals as compared to more
traditional production facilities. The process itself provides a high degree of metals
removal. The effluent from these processes can be characterized as a clear brine solution.
8. Is facility covered under federal effluent limitation guidelines? No ® Yes ❑
If yes, specify the category?
9. Principal product(s) produced: SHG zinc
Principal raw material(s) consumed: Zinc Oxide
Briefly describe the manufacturing process(es):
The process consists of Waelz Oxide leaching, extraction, stripping, and then electrowimmng.
Additional process description and the water balance information on how the facility will be operated
were included in the original NPDES permit application The facility will constitute the application of
several technologies that will allow zinc metal to be produced from metal bearing raw materials from
other parent company-owned facilities As noted in the EAA, the technologies and the configuration of
the plant are considered business confidential information
Page 2 of 5 C -MI 10/08

NPDES PERMIT APPLICATION - SHORT FORM C - Minor Industrial
Minor industrial, manufacturing and commercial facilities.
10. Amount of principal product produced or raw material consumed
(List specific amounts consumed and/or units of production over the last three _years)
11. Frequency of discharge: Continuous
If intermittent:
Days per week discharge occurs:
Intermittent ❑
Duration:
12. Types of wastewater discharged to surface waters only
Discharge
Product Produced or Raw Material
Product Produced or Raw Material
Consumed
Consumed
Process water - monthly average
AVERAGE
PEAK
per Day
Stormwater - monthly average
per Month
Explain
Zinc Oxide - 232,000 short tons
979,000
per Year
consumed, galvanizers skimmings - 26,500
short tons
11. Frequency of discharge: Continuous
If intermittent:
Days per week discharge occurs:
Intermittent ❑
Duration:
12. Types of wastewater discharged to surface waters only
Discharge
Flow
GALLONS PER DAY
Sanitary - monthly average
Utility water, etc - monthly average
Process water - monthly average
979,000 (includes other process related wastewaters
as described in the original application)
Stormwater - monthly average
Other - monthly average
Explain
Monthly Average
979,000
total discharge (all types)
13. Number of separate discharge points: 1 Outfall Identification number(s) 001
14. Name of receiving stream(s) (Provide a map shounng the exact location of each outfall, including
latitude and longitude):
Page 3 of 5 C -MI 10/08

NPDES PERMIT APPLICATION - SHORT FORM C - Minor Industrial
Minor industrial, manufacturing and commercial facilities.
15. Effluent Data [for new or proposed discharges]
Provide data for the parameters listed Temperature and pH shall be grab samples, for all other parameters 24-hour
composite sampling shall be used If more than one analysis is reported, report daily maximum and monthly average
If only one analysis is reported, report as daily maximum
NOTE: Permittees requesting renewal should complete the table ONLY for the parameters
currently monitored. Summarize the ast 3 years of of uent data.
Parameter
Daily
Maximum
Monthly
Average
Units of
Measurement
Biochemical Oxygen Demand (BODS)
N/A
Chemical Oxygen Demand (COD)
N/A
Total Organic Carbon
N/A
Total Suspended Solids*
143
30
Ammonia as N
N/A
Temperature (Summer)
N/A
Temperature (Winter)
N/A
PH*
8 2
7 3
Fecal Coliform (If sanitary waste is
present)
N/A
Total Residual Chlorine (if chlorine is
used)
N/A
*Values obtained from sampling data taken during the operating year of 2015. Facility was
placed in idle mode January 2016.
16. List all permits, construction approvals and/or applications (check all that apply and provide permit
numbers or check none if not applicable):
Type Permit Number Type Permit Number
Hazardous Waste (RCRA)
UIC (SDWA)
NPDES X
PSD (CAA)
Non -attainment program (CAA)
NESHAPS (CAA)
Ocean Dumping (MPRSA)
Dredge or fill (Section 404 or CWA)
Other
17. List any chemicals that may be discharged (Please list and explain source and potential
amounts.)
The original application package includes the base information on the expected effluent
from the facility.
Page 4 of 5 C -MI 10/08

NPDES PERMIT APPLICATION - SHORT FORM C - Minor Industrial
Minor industrial, manufacturing and commercial facilities.
18. Is this facility located on Indian country? (check one)
Yes ❑ No
19. Applicant Certification
I certify that I am familiar with the information contained in the application and that to the
best of my knowledge and belief such information is true, complete, and accurate.
Rob Williamson
General Manager
Printed name gf'ESQn Signing Title
pphcant
9/1 /)?
Date
North Carolina General Statute 143-215 6 (b)(2) provides that Any person who knowingly makes any false
statement representation, or certification in any application, record, report, plan, or other document files or
required to be maintained under Article 21 or regulations of the Environmental Management Commission
implementing that Article, or who falsifies, tampers with, or knowingly renders inaccurate any recording or
monitoring device or method required to be operated or maintained under Article 21 or regulations of the
Environmental Management Commission implementing that Article, shall be guilty of a misdemeanor punishable
by a fine not to exceed $25,000, or by imprisonment not to exceed six months, or by both (18 U S C Section
1001 provides a punishment by a fine of not more than $25,000 or imprisonment not more than 5 years, or both,
for a similar offense)
Page 5 of 5 C -MI 10/08

RECEIVEDINCDEOIDWR
SEP 0 6 2017
dater Quality
on
Permittingec
ENGINEERING ALTERNATIVES ANALYSIS
AMERICAN ZINC PRODUCTS LLC
PROCESS BLEED TREATMENT PLANT
RUTHERFORD COUNTY, NORTH CAROLINA
David Odom, PE
June 2017
Ffiabb'-4
0,
Odom i EngineeriN PLLC
169 Oak Street • Forest City, NC 28043
office 828 247 4495 • fax [phone]

X
Contents
I Introduction and Summary . .. ..................... ..... .
II. Flow Projections .. . ........................
III. Alternatives Analysis........ .................... ... .
A Connection to an Existing Wastewater Treatment System.....
B. Land Application ........ . ...................................................
C. Wastewater Reuse ............................... ................... .
D Direct Discharge to Surface Waters .
E. Combination of Alternatives .........................................
IV Economic Feasibility ............... ...................................
\/ ('nnrh icinn
.2
. .................. ... ...... ...... 3
5
.................. ............. ..... 7
....................................... ...10
..........................................11
.... .............................. .....13
.............................................13
11;
1

. Introduction and Summary
Horsehead Corporation (now known as American Zinc Recycling) is the leading recycler of electric arc
furnace (EAF) dust, a zinc containing waste generated by North American mini -mills. American Zinc
Recycling is the nation's largest producer of zinc.
In May 2014, American Zinc Recycling (AZR) constructed a new facility in Mooresboro, NC, near the
municipality of Forest City (See Figure III -1). This facility is called American Zinc Products LLC (AZP) AZR
operates 4 pre-processing mills which convert the EAF dust into a Zinc Oxide and the AZP facility receives
this material as feedstock.
The AZP facility utilizes solvent extraction and electrowinning (SX/EW) technology to produce special high
grade (SHG) zinc metal. This facility utilizes a proven technology referred to as SX -EW which produces
Special High Grade (SHG) Zinc Metal which has a market of approximately 1,000,000 TPY The SX -EW
technology has minimal air emissions, clean brine wastewater, operates at a lower temperature, and is less
capital intensive The facility has the capacity to produce 155,000 tons per year of SHG Zinc metal, and
employs approximately 300 people
The facility currently holds an NDPES Permit (NC0089109) for a discharge flow of 800,000 gpd that was last
updated 11/20/2015 This report is a revision to the previous EAA and is being used to evaluate how the
new effluent projections affect the alternatives considered Based on the new process projections, the
facility will produce an effluent stream of approximately 979,000 gpd on a monthly average basis Potable
water and domestic wastewater service will be provided by Forest City; therefore, domestic employee
waste will not be included in process effluent flow It is not feasible to send the process effluent to the
municipal system serving Riverstone Business Park which is operated by the Town of Forest City and is
located to the north of the facility site property
The purpose of this evaluation is to determine the most cost-effective and environmentally sound
alternative for disposal of the process effluent stream This alternatives analysis shall evaluate how the
new effluent projections affect the alternatives previously considered
A total of 5 alternatives were considered including;
• Connection to an existing facility
• Land application
• Reuse
• Direct discharge to surface waters
• A combination of alternatives
Of these alternatives, land application and direct discharge were considered the most feasible alternatives
Capital costs and operation costs were estimated for each of these Direct discharge to surface waters is
the most cost-effective alternative for disposal of the process effluent. See Table 1-1 below for a summary
of the feasible alternatives and associated costs.
Table 1-1: Feasible Alternatives
ALTERNATIVE PROJECT COST
B. Land Application $25,104,186.00
D. Direct Discharge to Broad River $516,714.00
N

II. Flow Projections
Flow for the discharge from the AZP facility will be 100% industrial effluent from the zinc production
process. All domestic wastewater will be directed to the existing Town of Forest City, Riverstone Industrial
Park wastewater treatment plant (WWTP), NPDES No NC0087084 or managed onsite. A list of the feed
materials and estimated annual quantities supplied to the facility are listed in Table II -1 below.
Table II -1: Feed Materials
Feed Materials
Quantity
ZnO
221,000 st/yr
Galvanizers Skimmings
45,000 st/yr
The process utilizes solvent extraction followed by electrowinning referred to as SX -EW. The process
consists of Waelz Oxide leaching, extraction, stripping, and then electrowinning. These processes are able
to extract the zinc from the WOX and galvanizers skimmings. The leaching and extraction steps are
essentially "water treatment" processes utilizing accepted "separation" technologies to capture materials
in solution or dissolved in the incoming water. The resulting effluent stream is a treated clear, brine
solution.
Effluent values for contaminates represent relatively low levels of trace materials. The process includes
real time monitoring for conductivity as an indication of chlorides, and pH Effluent is directly related to
the front-end feed rates and the process can be shut down if needed to resolve issues The main reagents
and resulting products with quantities are shown in Table II -2 below. As shown in the table, in addition to
the zinc, several other byproducts are produced which can be utilized by others through further processing
or recycled through the kiln plants owned by AZR
3

TABLE II -2: Reagents and Products
Main reagents
Short tons per annum
Sulfuric Acid (93%)
50,932
Lime (95%)
2,912
Limestone (95%)
41,554
Manganese Metal
662
Sodium Carbonate
4,235
Sodium Chloride
11,947
Flocculant (dry basis)
177
DEHPA
155
Hydrochloric Acid (33%)
7,695
Sodium Sulfide (60%)
2,127
Sodium Hydroxide (50%)
22
Sodium Hypochlorite (12%)
11,454
Carbon media
62
Strontium Carbonate
78
Hydrogen Peroxide (30%)
352
Ammonium Chloride
78
Sulfuric Acid 20% Totes
127
Sodium Bicarbonate
23
DE
34
Diluent
620
Products
Wet short tons per annum
Zn SHG
155,000
Gypsum
99,717
Lead concentrate
10,097
Metallic cement
3,761
Zinc concentrates (to be recycled)
54,814

The AZP facility uses approximately 1,101,000 gpd in raw water including 1,057,000 gpd from public water
supply and stormwater The remaining incoming water is from feed materials and reagents. Table II -3
below shows the approximate water balance and resulting anticipated discharge of 979,000 gpd
Table II -3: Baseline Water Balance
Description
Quantity
Raw Water
1,101,000 gpd
Evaporation
255,000 gpd
Sanitary Sewer
10,000 gpd
Solids Water Content
29,500 gpd
Effluent
979,000 gpd
III. Alternatives Analysis
A total of five (5) alternatives were considered for disposal of the process wastewater effluent. These
include connection to an existing facility, land application, reuse, discharge to surface waters, and a
combination of alternatives. The recommended alternative is direct discharge to surface waters.
Connection to existing facility and land application are considered feasible, however, these approaches
require significant additional capital investment, operating costs, and are significantly more difficult to
implement. The facility has a current NPDES Permit (NC0089109) which was issued based on projected
effluent values provided by Tecnicas Reunidas, a process design firm in Spain that developed this
technological approach. These values have been revised based on the analysis of the facility process
engineers and final design of the process. The revised anticipated effluent concentrations shown in Table
III -1 below were used in evaluating alternatives. The values provided in Table III -1 represent the baseline
numbers that are anticipated from the planned process steps. Based on the receiving waters at low flow
conditions, the Broad River has significant capacity to assimilate this discharge. Detailed cost estimates and
operations costs are included for the feasible alternatives.

TABLE III -1: Anticipated Effluent Concentration
Constituent
Concentration (mg/1)
Constituent
Concentration (mg/1)
Cl
17,000
As
025
K
5,000
Zn
0.08
SO4
4,000
Ni
0.15
Mg
500
Co
NA
Ca
1000
Cu
0.16
Na
8,000
Cd
0.27
F
20
Pb
0.50
Si
10
Al
NA
Mn
80
Cr
NA
Fe
NA
Sb
0.25
Sn
0.001
NA: None Anticipated

A. Connection to an Existing Wastewater Treatment System
The nearest municipal wastewater facility with reasonable capacity to accept the process wastewater is
the Town of Forest City Second Broad River WWTP, NPDES No NC0025984, which is approximately 12
miles away. There are several challenges associated with this alternative including the distance of the
facility from the site and the characteristics of the wastewater. The average flow to Forest City WWTP is
approximately 1,000,000 gpd and the permitted capacity is 4,950,000 gpd The average is expected to
increase beginning in August 2017 as Everest Textiles comes on line. 1,500,000 gpd has been allocated
to accommodate this industry. The Town of Forest City anticipates that by the year 2018, the average
flow to the plant will be at or above 2,000,000 gpd. This would result in approximately 1,950,000 gpd of
flow allocation left available to be permitted for new industry. Therefore, the 979,000 gpd of flow from
the AZP facility would represent 80% of the wastewater flow when combined with the current influent
(3,000,000 gpd). The proposed flow of 979,000 gpd is 20% of the permitted capacity.
As noted, the Forest City WWTP is located approximately 12 miles away from the AZP site as shown in
Figure III -1 Connection to the Forest City WWTP would require a pump station and force main to be
constructed to convey the wastewater to the Forest City WWTP. Pretreatment would also be required
to prevent inhibition of the Town's biological treatment process. It is noted that although pretreatment
could be accomplished to provide wastewater characteristics of the discharge that would prevent
inhibition, the flow from AZP facility is not typical of domestic wastewater or of other carbon -based
industrial wastewater that would be consistent with the plant's design. Acceptance of the wastewater
would also cause other treatment complications due to dilution resulting in negative impacts to the
plant's biological treatment process The Forest City facility was designed to accept industrial
wastewater that is consistent with carbon -based biological treatment processes. A detailed cost
estimate has been included for this alternative to show the many requirements and resulting high cost
Due to the characteristics of the wastewater, the Town of Forest City cannot accept the effluent,
therefore this alternative is not feasible. A letter from the Town of Forest City stating their inability to
accept the wastewater flow has been included within the appendix.
7

Based on the anticipated effluent parameters provided in Table III -1 above, the chloride concentration
of the combined waste stream would be 6,617 mg/I including Forest City's current flows and assuming
the existing wastewater has a typical chloride concentration of 50 mg/I. Inhibition levels for an activated
sludge waste treatment process with nitrification for chlorides are 180 mg/I per "Comprehensive
Guidance for North Carolina Pretreatment Programs" data taken from the "Guidance Manual onthe
Development and Implementation of Local Discharge Limitations Under the Pretreatment Program"
published by the Environmental Protection Agency in December 1987.
The mixture of AZP process wastewater with existing wastewater flow to the Town of Forest Cltywould
cause inhibition without pretreatment Chloride concentrations would be required to be reduced by
approximately 97% to less than 425 mg/I. This level of treatment would bring the combined Influent
level under the 180 mg/I Inhibition level. Chloride removal to this level could be completed with Reverse
Osmosis (RO), electrodialysis (ED) or chemical precipitation. The most effective of these treatment
options for the high chloride concentrations in the process waste Is R0. The capital costs for this system
will be high and recoveries are typically limited to 80-90%. The reject flow of 80,000-160,000 gpd is
concentrated brine requiring additional treatment and disposal RO technology has been applied to a
limited number of situations and is untested In this application. In other proposed or existing RO
systems the disposal of this refect stream is a huge problem. Some facilities in the area of potable water
treatment discharge the wastewater to surface waters. This approach here would defeat the objective
of the treatment. Therefore, it Is assumed that this water would have to be further treated by a brine
concentrator and crystallizer to remove the remaining liquid. The resulting solid waste would have to be
disposed of at a landfill that could accept this material. The Town of Forest City requires an impact fee
for new industries for flow allocation. If this option was pursued by AZP, the Town may assess an Impact
fee. Based on discussion, the fee is estimated to be $150,000 for an outside customer of this size A
detailed cost estimate for this alternative is included in Table 111-2 below
Table 111-2: Cost Estimate — Connection to Existing wastewater Treatment System
ITEM NO.
DESCRIPTION
QUANTITY UNIT UNIT PRICE
EXTENSION
1
Mobilization
1
LS
$ 100,54000 $
100,54000
2
Reverse Osmosis Treatment System
1
LS
$ 2,200,000 00 $
2,200,000 00
3
Brine Concentrators and Crystalizers
1
LS
$ 6,050,000 OD $
6,050,000 00
4
Pumps, Piping, Installation
1
LS
$2,750,00000 $
2,750,00000
5
Treatments stem Building
1
LS
$ 247,50000 $
247,50000
6
Electrical
1
LS
$ 1,76000 $
1,76000
7
Pump Station w/ Standby Generator
1
LS
$ 30250 $
30250
8
12" PVC Force Main
53000
LF
$ 4950 $
2,623,50000
9
Air Release Valve
10
EA
$ 3,85000 $
38,50000
SO
Rock Excavation
2500
CY
$ 82 50 $
206,250 00
11
Select Backfili
2500
CY
$ 1650 $
41,250 00
12
Erosion control
1
LS
$ 137,50000 $
137,500 00
CONSTRUCTION SUBTOTAL
$14,397,102.50
Contingency 10%) $
1,439,710 25
Design and Permitting $
1,316,590 00
Construction Administration $
1,152,03000
Town of Forest City Impact Fee $
150,00000
Legal/Adminstration $
82,50000
Testing $
44,00000
PROJECT TOTAL $18,581,932.75
9

B. Land Application
This alternative considers the potential to spray or drip irrigate the process wastewater. Upon
investigating alternatives for the previous EAA report, this alternative was discussed with Bill
Yarborough, Regional Agronomist with the North Carolina Department of Agriculture and Consumer
Services. The letter that was provided by Mr. Yarborough for the last Engineering Alternatives Analysis
has been included in the appendix Mr. Yarborough indicated that the high chloride concentration would
be problematic for most common field crops and forage crops. Irrigation of the water without
pretreatment for chlorides would likely result in injury to the plants and require constant replanting or
erosion the site would occur due to the inability to maintain a consistent cover crop In addition, Mr.
Yarborough indicated an agronomic rate for irrigation in the area of %" per day which would require
approximately 118 acres of wetted area. Some additional land would inevitably be required for buffers,
maintenance area, water storage and pumping facilities Irrigation could not be permitted during wet
periods and when temperatures are below freezing. The proposed irrigation system is assumed to be
operated as a standalone system for disposal of the water. In this configuration, referred to as a non -
conjunctive system, a large storage pond would also be required to store water when irrigation is not
advisable and to account for seasonal variations in irrigation rates. A complete water balance is required
to determine the exact amount of storage needed, however, typically no less than 30 days is practical.
Based on 30 days of storage approximately 24 million gallons of storage is required. It is assumed for
purposes of this report that a pond could be constructed to retain this volume on or near the irrigation
site. Per Metcalf and Eddy Wastewater Engineering Treatment and Reuse 4th edition pg. 1403 irrigation
with chlorides above 350 mg/I should be severely restricted. Sprinkler irrigation water greater than 100
mg/I of chloride should have slight to moderate restriction Therefore, to maintain the irrigation site
without causing injury to the plants as indicated by Mr. Yarborough a reverse osmosis treatment system
similar to that described in Alternative A is recommended. There is not sufficient property to utilize the
water for irrigation on the industrial facility site so it assumed that property would be acquired within a
mile of the site to be used for irrigation
10

Table III -3: Cost Estimate – Land Application
ITEM NO.
DESCRIPTION
QUANTITY
UNIT UNIT PRICE
EXTENSION
1
Mobilization
1
LS
$ 534,60000
$ 534,60000
2
Reverse Osmosis Treatment System
1
LS
$ 2,200,000 00
$ 2,200,000 00
3
Brine Concentrators and Crystalizers
1
LS
$ 6,050,000 00
$ 6,050,000 00
4
Pumps, Piping, Installation
1
LS
$ 2,750,000 00
$ 2,750,000 00
5
Treatment System Building
1
LS
$ 247,50000
$ 247,50000
6
Electrical
1
LS
$ 1,76000
$ 1,76000
7
Site Work
1
LS
$ 165,000 00
65,000008
$ 165,000-
8
Yard Piping
1
LS
$ 110,000.00
$ 110,000 00
9
Erosion Control
1
LS
$ 82,500 00
$ 82,500 00
10
Effluent Pump Station to Irrigation
1
LS
$ 302,500 00
$ 302,500 00
11
Force Main to Pond at Irrigation Site
5,000
ILF
$ 5500
$ 275,000 00
12
Irrigation Pump Station
1
Its
1 $ 247,500 00
$ 247,500 00
13
Spray Irrigation System
1
LS
$ 2,750,000 00
$ 2,750,000 00
14
24 -Million Gallon Storage Tank
1
LS
$ 3,080,000.00
$ 3,080,000 00
CONSTRUCTION SUBTOTAL
$ 18,796,360.00
Contingency (10%)
$ 1,879,636 00
Design and Permitting
$ 1,644,390 00
Construction Administration $
1,438,800 00
Land (165 acres @ $8,000/acre)
1,320,000 00
Testing $
25,00000
PROJECT TOTAL $
25,104,186.00
C. Wastewater Reuse
This alternative considers the potential to reuse the wastewater for other purposes onsite or nearby.
The large quantity of water and the projected chloride level are the largest hurdles for this alternative.
There are no known needs for this quantity of non -potable water in the AZP facility or any otherareas
nearby. Utilizing the water for typical reuse applications such as toilet flushing are not sufficient to reuse
the quantity produced and will still result in the need to dispose of the water at some point in the
process. Use as a cooling water is not feasible due to the chloride content. This alternative is not feasible
and will not be further considered.
D. Direct Discharge to Surface Waters
Background and Effluent Limitations
The AZP facility is located adjacent to the Broad River in southern Rutherford County. The facility
currently holds an NPDES permit (NC0089109) to discharge 800,000 gpd of process effluent to the Broad
River. This update increases the discharge flow to 979,000 gpd of process effluent with revised
anticipated concentrations of constituents. The Broad River is classified as WS -IV waters according to
NCDEQs Stream Surface Water Classifications. Based on communications with NCDEQ, the discharge
flow of 979,000 gpd would be 0.90% of the Instream Wastewater Concentration (IWC).
Table III -4 below compares the previous anticipated effluent concentrations to the current anticipated
effluent concentrations. The existing NPDES permit includes limits for Total Cadmium, Chromium,
Fluoride, and Total Lead.
11

Table III -4 - Anticipated Effluent Concentrations
Constituent
Revised Anticipated
Concentration
(mg/1)
Previous Anticipated
Concentration
(mg/1)
CI
17,000
>19,680
K
5,000
>9,036
SO4
4,000
>2,496
Mg
500
>1,044
Ca
1000
>672
Na
8,000
>5,760
F
20
>24
S1O2
10
>30
Mn
80
>120 00
Fe
NA
>1.20
Sri
0 001
>2.40
As
025
>0 24
Zn
008
>1.20
Ni
0.15
>0.60
Co
NA
>0.12
Cu
0.16
>0 12
Cd
027
>0 12
Pb
0.50
>0 60
Al
NA
>2.40
Cr
NA
>1.20
Sb
0.25
>0.24
NA: None Anticipated
Proiect Description and Cost
Based on this information additional pretreatment for discharge to the Broad River will remain
unnecessary to meet Water Standards or Action Levels at the increased flow. The process has a
relatively consistent flow and flow equalization is not expected to be required To discharge the process
waters to the Broad River, AZP has constructed 2,200 ft of gravity effluent piping, an instream diffuser,
and effluent flow monitoring and sampling equipment. A detailed cost estimate is included in Table III -5
below.
12

Table III -5: Cost Estimate — Direct Discharge to Broad River
ITEM NO.
DESCRIPTION
QUANTITY
UNIT UNIT PRICE
EXTENSION
1
Mobilization
1
LS
$ 11,440 00
$
11,440 00
2
Site Work
1
LS
$ 22,000.00
$
22,000 00
3
Effluent Piping to Broad River
2200
LF
$ 88.00
$
193,600 00
4
Effluent Diffuser
1
LS
$ 38,500.00
$
38,500.00
5
Effluent Flow Meter and Sampler
1
LS
$ 27,500.00
$
27,500.00
6
Electrical
1
Ls
$ 16,500 00
$
16,500 00
7
Erosion Control
1
LS
$ 82,500 00
$
82,500.00
CONSTRUCTION SUBTOTAL
$
392,040.00
Contingency (10%)
$
39,204.00
Design and Permitting
$
43,120 00
Construction Administration
$
31,350 00
Testing
$
11,000.00
PROJECT TOTAL
$
516,714.00
E. Combination of Alternatives
A combination of alternatives refers to the possibility of using multiple options from the above
alternatives. Potential combinations that can be considered are land application system with discharge
for periods when irrigation is not required, or reuse of a portion of the water with the remaining water
being utilized for irrigation or discharge. As described in the reuse alternative there is very limited
potential use for reuse water from the facility and reusing a small portion would not be cost effective.
Combining land application with a discharge would still require RO treatment for the portion of water to
be land applied and the purchase/lease agreement for property to be irrigated Although the
requirement for effluent storage may be able to be removed by utilizing a discharge as a backup to
irrigation the cost would still be significantly higher than Alternative D. Direct Discharge to Surface
Waters. Based on this information a combination of alternatives is not practical and will not be further
considered.
IV. Economic Feasibility
The feasible alternatives are Land Application and Direct Discharge to the Broad River. The capital costs
for these alternatives are included in Section III. In order to compare these alternatives as accurately as
possible, a present worth calculation is required to account for the impact of salvages values and
operations and maintenance costs.
Land application requires the installing of an RO system. In addition to operation of the RO treatment
system the industry would also be required to operate the irrigation system. Typically, RO operation cost
are $1-$3 per 1,000 gallons treated. Table IV -1 below gives a summary of typical operation and
maintenance associated with an RO system. Assuming a cost of $2 per 1,000 gallons total yearly cost
would be approximately $584,000.
13

Table IV -1: Reverse Osmosis Treatment
System Operation and Maintenance Cost
Item
Cost/1,000 gallons
RO Electricity
$030-$050
Chemicals
$0.20-$040
RO Membrane Replacement
$007-$012
Brine Concentrator Electricity
$0.80-$120
Membrane Cleaning
$0.02-$005
Labor
$003-$005
Operation of the irrigation system would include, certified operator, electricity, sampling/laboratory,
and maintenance Table IV -2 displays an estimate of these costs at $175,000 per year Therefore, the
total estimated operation and maintenance costs are for this alternative estimated as $759,000 per
year
Table IV -2: Land Application System Operation Costs
Item
Cost/1,000
gallons
Maintenance
$30,000
Laboratory/Samples
$12,000
Operator/Staff
$75,000
Utility Costs
$58,000
Total
$175,000
Operation and maintenance costs for the direct discharge alternative will include laboratory/sampling,
operator/staff, and maintenance of the flow meter, and sample equipment Flow will be conveyed by
gravity to the Broad River so electrical and maintenance cost will be minimal. See Table IV -3 below for a
detailed cost estimate.
Table IV -3: Direct Discharge to Broad River
Item
Cost/1,000 gallons
Maintenance
$5,000
Laboratory/Samples
$12,000
Operator/Staff
$10,000
Utility Costs
$2,000
Total
$29,000
A present worth analysis for the feasible alternatives is included in the appendix Detailed calculations
are included in the appendix Direct discharge is the least costly alternative by a very large margin and is
the recommended alternative.
14

V. Conclusion
The process water effluent from the AZP facility is projected to be 979,000 gpd. Five (5) alternatives
were considered for disposal of the process wastewater however, the only reasonable alternative for
disposal of the American Zinc Products LLC process wastewater is direct discharge to the Broad River.
The flow will be high in chlorides and cannot be used for irrigation or treated with typical domestic
wastewater without pretreatment. The most feasible treatment option for removal of chlorides is RO
which carries high capital and operation costs. The discharge will not result in violation of any water
quality standards in the Broad River and will be approximately 0.9% of the instream flow rate at the
7Q1Os flow. The present worth analysis shows that the direct discharge alternative is by far the most
cost-effective alternative. Based on this evaluation the proposed alternative is direct discharge to the
Broad River.
15

Appendix
16

Steven Troxler NC)itll CiiioliilLi t)el),ii-iillelli oI \L'riC'll1llllc
rmmlt'SO : and C 011Slillit'l- SCI'\ iCeS
4,vtf>llrsmfc D11'151r111
i oil em 11 e,t.11i
1lct,dl and 1s,otfat. ,
110 Tim 2250
•>>hel ills NC '_81'02
'fir 11 v,ta,l
Dr Colleen Hudak -Wise
Direvtc,
am nilnn� to you a� ^cr +, ui rGy„cot I,•r an .t rot„rlict , oh nwri t n th, pi r, ,Ld u,,, nr, t >,iht m Ruthcrferdl,nttt+ df=,f
a land apphc at or, ++a,to +• ,iu r pdrmit helots .lie mt +hser+aur„t, ae.d ttttt,ern,
Accoidinu toll,, tnt0nrtaii„�, peri,i,ird t„ me 3 1:11111 appfttat 0�1 lsne, ire the write nater ail hn,rnment
ht i, the th10rIJL COWL -111.a file tt.t,re +' MCI and = (and the most a_rc�11onut u>ncernf is 1111 qu.tntd+ of 10131 nater per day
'' CliIorid,' erc proMr math at the ItseI, PI;,,ufc(I "or moot Wninwri field cror, in forage: trop, (her time ,e+cre plant
injure can he c\pettett at tlte,e fes el: I hl, could Lad to constant r"_planlmu ,.rid PL,-thle erobfoi ,au,n,L olt ,tie d nrt,'r
unles, erov0•t c„n�n l he,f t;t 11131enlcnt pr s,n,r, .1e ta+,tull+ planned to"OhLd .11111 ,art fu' t maintained
.'" Ne,irf} mil' hi file flwrt .arc,uf•1n1+ arm+11111 fila thtc operxlott ,L, +nu tnrru ki,M r
iz a critical cowponcnt ,fanol plain etowli Il,)%%,, t t+c,,,vc ++ater t, n• :rot the 111011 ltrrVttnr> r<+te, rn am Lr+ppmj,,
s+,tem I hi, q tent t+ 0t •, iter uotdd re,it'u, d 1,111111101111 ,0t o+c' IVO a,r,l .,t i ind tri :tppht.tu+ n 127 000 gallons per day
equal, on, a,r, ❑ILII '),r i r.ce,i h>r 26 acre, of ,ue,i tot apphc.,t tin 1 ,,1,,,1 a_toniv n, rate fcr v 11% ++stet is' i in,h per dot to
How for norm II p=c,ipn,%Ewn and ++ inter applicotion ++here Mule to no esaporxwf) ,en he etil weir+! i fill ++rtiuld equate to an
rpphcauon anti of 104 ,,crv, for an applit ,tion tl,ldi h i, ai;o a ri t `ln'iended pratt,e to hae_ a r(palr area of it lca,t 5111,,
of til, aLrea2e to 111,w 1;- r ol'ir" ar tailor unforeseen ad%ef �,t+ -% mlmmum total la,i l area 0f mtr 150 acres v+nuld be
reces•ary to adequa2ls treat iht, quantity oft+,Imo n Iter I +eft ssfth Chia taicul 1'10') t, reful Plot mng of ground cater tapable
ci'handhng this qu.mtft. oft+atet t+ill be required C onvderati011,, of ,lope sail t}pe, permeabilit} pro+trntty=to nater cours,s
etc could also Impact tiff, area ge and require additional land to achtc+e adequate land tr, ttm.m of fill, waste eater rhes
+,ould require a delatied site tn+c�tt,_mtinn to determine site how.ition,
Ifaddnion3l intomean•ln i, requited plta,c Ice rite i,ri,m
Ite,t re_ard,
s. x '
Bill Y arbofough
Regional 1gronomf;t
1040 kli�! Se -vice Center Raleigh, Norw Ca^o're 27S +9 '0_0
[phone] 0 Fax [phone]
TTY 1-500 735.2962 Voice 1.877-735-8?00
An Equal Opeonu^ity Affirmative Acnor'c•rct6yer
17

TOWN OF FOREST CITY
WATER RATES
Fiscal Year 2016-2017
OUTSIDE TOWN LIMITS
Minimum charge for 3,000 gallons $ 27.15
$6.97 per 1,000 for next 7,000 gallons $ 48.79
$6.25 per 1,000 for next 40,000 gallons $ 250.00
$5.42 per 1,000 for next 450,000 gallons $2439.00
$2.02 per 1,000 for all over 500,000 gallons
TOWN FOREST CITY
SEWER RATES
Fiscal year 2016-2017
OUTSIDE TOWN LIMITS
COMMERCIAL AND INDUSTRIAL
Minimum charge for 3,000 gallons $ 27.90
$4.52 per 1,000 for next 997,000 gallons $4506.44
$3.01 per 1,000 for all over 1,000,000 gallons
Flow measurement based on 90% of water consumption
RESIDENTIAL
Sewer rates are same as water rates.

Town of Forest City
f PO Box 728
Forest City, NC 28043
June 9, 2017
To: Skysja Adams
Odom & Associates
From: Sonny Penson
Chief Wastewater Operator/ORC, Town of Forest City
Subject: AZR alternative connection to Forest City WWTP
Skysia,
The Town of Forest City WWTP was requested to consider treating 979,000 GPD flow
from AZR (formerly Horsehead Corporation) as an alternative analysis which was part of
a NPDES permit application for AZR. After consulting with Keith Webb (McGill &
Associates) we concur with the needed improvements stated in scenario #3 of Keith's
June 6, 2017 email to you. Based on the many improvements cited along with our own
internal discussions for potential heavy metals associated with the discharge we agree
with Keith's recommendation that we cannot accept this flow at this time.
If you have any additional questions or comments please contact me.
Respectfully submitted,
Sonn Penson
ORC/Chief Wastewater Operator
Town of Forest City NC
Cc: Jeff Dotson, Superintendent, Town of Forest City W WTP
John Condrey, City Manager, Town of Forest City
PO Box 728 Forest City, NC 28043 Telephone [phone] Fax [phone]
Email address: [e-mail]
Visit our website
www.townofforestcity.com
19

ALTERNATIVE B - Land Application
Description
m �
Cost (2017)
Present Value
}° 06 Total Capital Outlay
$25,104,186 00
$25,104,186 00
a o
M
U AnnualO&M
$759,00000
$9,487,50000
Subtotal
$25,863,186.00
$34,591,68600
m
Type Life (YR) Description
Life (YR)
%Value at n (2037) Salvage at n (2037) Present Value
Structures 50 Treatment System Building
$247,50000
60% $148,500.00 $24,31829
m
Collectors 40 Force Main to Pond at Irrigation Site
$275,00000
50% $137,500.00 $26,13636
Structures 50 24 Million Gallon Storage Pond
$3,080,000 00
60% $1,848,000 00 $302,62762
Subtotall
$3,602,500 00
$2,134,000.00
50%.
$96,80000 $18,40000
Net Present Value $34,289,058.38
ALTERNATIVE D- Direct Discharge to Surface Waters
Description
Cost (2017)
Present Value
m Total Ca ital Outlay
n o y
$516,71400
$516,714 00
m �
m AnnuaIO&M
$29,00000
$362,50000
Subtotal
$545,714.00
$879,214.00
to
Type
Life (YR)
Description
% Value at n (2037)
Salvage at n (2037) Present Value
vmi
Collectors
I 40EffluentPi
ingtoBroadRiver
$193,60000
50%.
$96,80000 $18,40000
Subtotal
$193,600.001
1
$96,800.00
Net Present Value $860,814.00
20