Correspondence

Permit NCO089109
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWA'T'ER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1,
other lawful standards and regulations promulgated and adopted by the North Carolina
Environmental Management Commission, and the Federal Water Pollution Control Act, as
amended,
Horsehead Corporation
is hereby authorized to discharge wastewater from a facility located at
Rutherford County Production Facility
Forest City
Rutherford County
to receiving waters designated as the Broad River in the Broad River Basin in accordance with
effluent limitations; monitoring requirements, and other conditions set forth in Parts I, II, III and
IV hereof.
This permit shall become effective December 1, 2011.
This permit and authorization to discharge shall expire at midnight on July 31, 2013.
Signed this day November 11, 2011.
Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit NC0089109
SUPPLEMENT TO PERMIT COVER SHEET
All previous I JPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked. As of this permit issuance, any previously issued permit bearing this number is no longer
effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the
permit conditions, requirements, terms, and provisions included herein.
Horsehead Corporation is hereby authorized to:
1. After constructing the wastewater treatment facility, operate it in accordance
with.the existing wastewater treatment system consisting of the following
components:
Automatic sampler
➢ Instrumented flow measurement, and
D Diffuser
The facility is located near Forest City, Rutherford County; and
2. Discharge from said treatment works at the location specified on the attached
map into the Broad River which is classified C waters in the Broad River Basin.

Permit NCO089109
A (1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee
is authorized to discharge from outfall(s) serial number 001. Such discharges shall be limited and
monitored by the Permittee as specified below:
RFPLUENT=— -
GHARAZ:T'L'RISTICS
-
LIMITS '
Monthly Daily
Average Maximum
MONITORING REQUREMENTS
Measurement =Sample = Sample
Frequency ype Locatlon'
Flow (MGD)
0.62
Continuous
Recording
I or E
Total Suspended Solids
Monthly
Composite
E
NH3-N
Quarterly
Composite
E
Total Aluminum
Quarterly
Composite
E
Antimony
Quarterly
Composite
E
Arsenic
Quarterly
Composite
E
Total Cadmium
350 ug/L 2,143 ug/L
Monthly
Composite
E
Chlorides
Quarterly
Composite
E
Total Chromium
Quarterly
Composite
E
Total Cobalt
Quarterly
Composite
E
Total Copper
Quarterly
Composite
E
Fluoride
315.8 mg/L 315.8mg/L
Monthly
Composite
E
Total Iron
Quarterly
Composite
E
Total Lead
4,386 ug/L 41829 ug/L
Monthly
Composite
E
Total Nickel
Monthly
Composite
E
Total Tin
Quarterly
Composite
E
Total Zinc
Quarterly
Composite
E
pH2
Ea
Weekly
Grab
E
Chronic Toxicity3
Quarterly
Composite
E
Turbidity+
-
Monthly
Grab
E, U, D
NOTES:
1. Sample Locations: I - Influent E - Effluent, U - upstream (50 ft. upstream of the
discharge), D - downstream (50 ft. downstream of the discharge).
2. The pH shall not be less than 6.0 standard units or greater than 9.0 standard units.
3. Chronic Toxicity (Ceriodaphnia) P/F ® 0.57%; Jan., April, July and October; See
condition A(2) of the Supplement to Effluent Limitations and Monitoring Section of this
permit.
4 The discharge from this facility shall not cause turbidity in the receiving stream to
exceed 50 NTU. If the instream turbidity exceeds 50 NTU due to natural background
conditions, the discharge cannot cause turbidity to increase in the receiving stream.
THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR FOAM viSTBLE IN OTHER THAN
TRACE AMOUNTS.

Permit NCO089109
SUPPLEMENT TO EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS
A'(2). CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QUARTERLY)
The effluent discharge shall at no time exhibit chronic toxicity using test procedures outlined in the "North
Carolina Ceriodaplada Chronic Effluent Bioassay Procedure;' Revised November 1995, or subsequent'
versions.
The effluent concentration at which there may be no observable inhibition of reproduction or significant
mortality is 0.57`Y (defined as treatment two in the procedure document). The permit holder shall perform
quarterly monitoring using this procedure to establish compliance with the permit condition. The tests will
be performed during the months of January, April, July and October. Effluent sampling for this testing
shall be performed at the NPDES permitted final effluent, discharge below all treatment processes.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form (MR -1) for the month in which it was performed, using the parameter code TGP3B.
Additionally, DWQ Form AT -1 (original) is to be sent to the following address:
Attention: North Carolina Division of Water Quality
Environmental Sciences Section
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Test data shall be complete and accurate and include all supporting chemical/physical measurements
performed in association with the toxicity tests, as well as all dose/response data. Total residual chlorine of
the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of the
waste stream.
Should there be no discharge'of flow from the facility during a month in which toxicity monitoring is
required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test
form indicating the facility name, permit number, pipe number, county, and the month/year of the report
with the notation of "No Flow" in the comment area of the form. The report shall be submitted to the
Environmental Sciences Branch at the address cited above.
Should any single quarterly monitoring indicate a failure to meet specified limits, then monthly monitoring
will begin immediately until such time that a single test is passed. Upon passing, this monthly test
requirement will revert to quarterly in the months specified above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, then monthly
monitoring will begin immediately until such time that a single test is passed. Upon passing, this monthly
test requirement will revert to -quarterly in the months specified above.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division
of Water Quality indicate potential impacts to the receiving stream, this permit may be re -opened and
modified to include alternate monitoring requirements or limits.

Permit NCO089109
SUPPLEMENT TO EFFLUENT LIMITATIONS
AND ,MONITORING REQUIREMENTS
SPECIAL CONDITIONS (Continued)
If the Permittee monitors any pollutant more frequently then required by this permit, the results of
such monitoring shall be included ur the calculation & reporting of the data submitted on the DMR
& all AT Forms submitted,
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum.
control organism survival, minimum control organism reproduction„ and appropriate '
environmentalcontrols, shall constitute an invalid test and will require immediate follow-up
testing to be completed no later than the last day of the month following the month of the initial
monitoring.

TthitlStiY R.
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,SUITE 405 � TDASI'[e-mail] 412.788.4526 "FE � f �l �� l�t;A,0
PITTSOURGH. PA 15205 CORPORATION
6radiag lire World In Zine Recyrlirrg
June 13, 2011
Mr. Charles Wakild, Deputy Director
North Carolina Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: May 9, 2011 Meeting
Division of Water Quality .
Horsehead Corporation, Proposed Production Facility, Rutherford County
Stormwater NPDES Permitting and 401 Certification Processes
Dear Mr. Wakild:
I'd like to thank you and others from NCDWQ, including Mr. Matt Matthews, Ms. Cyndi
Karoly, Mr. Bradley Bennett, Dr. Sergei Chernikov and Mr. Ken Pickle, for giving
Horsehead Corp. (Horsehead) the opportunity to meet with you on May 9, 2011 and
discuss the potential plans far eonstrltcting a zinc production facility fn Rutherford
County, North Carolina, Horsehead and otir.consultant, McGill Associates, appreciate
information you provided concerning stormwater NPDES permit issues and the 401
certification processes. You provided valuable information with regard to requirements
dealing with these subject areas, that would apply to Hoisehead's proposed facility.
At the meeting, Horsehead provided a summary of the coinpany' usiness, a description
of the new plant and processes involved to produce zinc metal, and noted the importance
of this new production facility to our business plan. As we indicated in our meeting,
understanding the permitting process and securing necessary permits in a timely manner
for the sites under consideration is a critical component in making a decision as to the site
that will be selected for this facility.
The PowerPoint presentation provided at the meeting contains business confidential
information. A copy of the presentation was not provided to you, but Ave request that key
production process design information for the facility and site be protected under State
and Federal law, and that this information be treated as Business Confidential.
As we pointed out during the meeting, the information provided about the facility and the
site is preliminary and represents a general description of the operation of this proposed
facility. We are continuing with our facility design efforts and establishment of the final
operating criteria for the plant. Horsehead and associated consultants for this project are
available to answer any questions that you may have and welcome the opportunity to
discuss stormwater and 401 permitting requirements for the proposed facility.
,s
F:

Discussions during the meeting were beneficial for our understanding of the State's
stormwater and Section 401 permitting processes, and provided information required to
obtain these permits. Furthermore, we gained valuable insight as to the time required by
the agency for review of the permit applications, and the decisions the agency must make
to process the permit requests. Below is a summary of information obtained from the
meeting to clarify our understanding ofpoints made during our discussions.
Hdrsehead currently plans to configure the site in such.a way that any
precipitation on the site that may be exposed to feedstock or final product/co-
product materials will be managed and used for the facility's production process.
The NCDNR indicated that the permit for this stormwater would be evaluated
under the NPDES process wastewater permit and not under a stormwater permit,
NCDWQ characterized this approach generally as a site with a stormwater
drainage area having two separate collection systems: a "clean" side and a
"potentially contaminated" side. The "clean" portion of the facility drainage
would include drainage from the Impervious, non process surfaces on the site
(rooftops, non process holding areas, and parking areas) and the landscaped areas
related to the site development, not including the areas of the property left in a
natural state,
NCDWQ indicated that a stormwater NPDES permit would be required for the
"clean" drainage, and that this permit would essentially be directed at
characterization of the drainage system, identification of outfalls and provisions
for the qualitative periodic monitoring of stormwater runoff from included areas
over the permit period, and development ofa, stormwater management plan for
the areas draining to the "clean" collection system,
♦ Because there is currently no general permit for the Non-Fenous Metals
production SIC, the NCDWQ would be required to process a permit application
under the individual NPDES Stormwater Permit portion of the program,
♦ Horsehead and consultant representatives will work in conjunction with the
NCDWQ to develop all of the information required to provide a complete NPDES
permit application for the facility's stormwater discharges that falll under this
program,
♦ Horsehead and NCDWQ will coordinate activities to manage information
development for the compilation of a complete permit application, and to develop
a schedule for securing a permit in the timeliest manner possible,
NCDWQ agreed to provide direct and quick communication by phone and e-mail
to address any questions related to the application and to resolve any issues in a
timely manner and to keep the review process moving,

♦ NCDWQ appointed Mr. Ken Pickle as the primary point of contact for
communication on the stormwater permit application process,
♦ . Horsehead will submit a stormwater permit application for the site as soon as the
final site facility layout plan is completed. This is expected to occur in the early
fall,
♦ Following submittal of a complete application NCDWQ advised that three to four
months would be required for the development of a final draft permit for public
notice under State requirements,
4 Horsehead anticipates that the only stream/wetland impacts under Sections 404
And 401 of the Clean Water Act to be for an effluent discharge outfall structure on
the Broad River and possibly a water intake structure for process water on the
River both of which likely can be covered under the Corps of Engineers
Nationwide Permit for utility activities and North Carolina's General Certification
for these activities,
It is understood that a complete site evaluation for waters and wetlands will need
to be performed, and Horsehead will obtain such information before finalization
of any applications,
NCDWQ agreed to work in coordination with Horsehead to secure a complete
401 Certification application once final proposed Impacts can be established,
♦ Based on the identified impacts, NCDNR and Horsehead will. establish quick
response lines of communication by e-mail and phone to resolve any questions
about the application and the processing of a final 401 Certification,
♦ Ms. Cyndi Karoly; NCDWQ Branch Chief for the stormwater and 401 programs
will be the initial point of contact, the review process will be assigned to the
appropriate staff for the stream/wetland impacts that are.planned,
♦ NCDWQ indicated that all communication with Horsehead related to any
comments received from staff or the public would occur in a timely manner, and
that if further public review was required, the Division would move this process
along as quickly as possible to a final determination on pending approvals and
permits.
Mr. Ken Pickle has already provided several pieces of information and feed-back
following our meeting. We appreciate his responsiveness in helping us to develop our
approach to stormwater management on the site..
Commitments made by the NCDNR during our meeting provide information that is
critical for completing our site evaluation process. Horsehead looks forward to working
with the NCDNR on this important project. As you are aware, this newproduction

facility represents a large commitment of resources and technology by Horsehead for the
production of zinc and other non-ferrous metal products.
In relation to permitting requirements under the stormwater program, McGill Associates
will serve as our primary resource for development and submittal of a complete permit
application. Mr. Forrest Westalf at McGill Associates will assist in coordinating
information flow between Horsehead and the NCDNR. Mr. Westall_ can be contacted at
828.231.6840 (cell) or 828.252.4575 (office).
We appreciate your assistance and that of NCDWQ's staff in helping us to define the
storinwater permitting requirements for this site. Please feel free to contact me with any
questions you may have.
Sincerely,
Timothy R, Basilone
cc Forrest Westall, McGill Associates
Darin Cooper, Horsehead Corp.

From: Forrest Westall [maiito:[e-mail]]
Sent: Thursday, December 08, 20117:47 AM
To: 'Pickle, Ken'
Ce: 'Bennett, Bradley; 'Chernikov,'Sergei`; 'Karoly, Cyndl'; 'Matthews, Matt'; 'Wakild, Chuck; 'Basilone
Tirn';'Cooper Darin';'[e-mail];'[e-mail]'
Subject: RE: Horsehead Meeting November 29, 2,011
Hello Ken,
Thanks for the follow-up and the confirmation on the substation and the distinction about stormwater
originating within the production area. We will be sure to address your comments about the access and
perimeter roads in the final site layout and design.
We appreciate the time you provided last Tuesday to meet with Darin, Tim and me so we could review the
site stormwater considerations for this new facility in Rutherford County. As we noted, the NPDES
process waste water permit has been issued and construction of the facility has commenced. The
meeting last week served as a follow-up to our preliminary discussions in May when Horsehead
Corporation was completing the site seleetion process. We left the May meeting with a general
agreement with DWQ on a conceptual approach for managing stormwater, At that time we also
committed to return to DWQ with a more specific site plan once production layout was completed. At
yesterday's meeting we provided detail as to the site layout and our approach for development of an
NPDES stormwater permit application for the facility.
Your Input has been and continues to be very helpful in guiding our development of a permit application.
In follow-up to our recent discussion and in addition to the comments you have already made in your
follow-up, I am providing this summary to highlight important observations and conclusions that were
reached. We will now proceed with development of an application package with the clear direction you
provided, confident that the information submitted will be consistent with our understanding. We believe
that this will lead to a quick review:
During the meeting a copy of the production layout design plan was provided for your use. The plan.
provided highlighted areas and facility activities. In addition We described our approach for managing
stormwater from individual and collective areas of the facility. We appreciate your comments and
agreement with our overall approach for managing stormwater at the facility. We plan to develop a draft
of the application for your review, and then finalize the application based on your comments for submittal
to the Department.
- Key points we agreed to during our discussion are as follows:
■ You advised that all stormwater from within production areas (the area referred to in this
correspondence as the "developed site"), would need to be included under the NPDES
stormwater permit and monitored accordingly
■ We agreed that stormwater will be managed under an established management plan to meet the
requirements of the permit. The management plan will include provisions for managing
stormwater from production areas, including capability for accumulating and using this water for
production processes or discharging it based on results of sample analyses. Stormwater
managed in these areas was referred to during our discussions as being "discretionary water" for
process use or discharge.
Storm -water will be routed to one point of discharge, which will be the sole discharge monitoring
point in the NPDES stormwater permit: Discharge baselines for various parameters will be
established for performance monitoring
■ After discussing the general plan for managing storm water at the site, you advised that the
following information should be included with the NPDES stormwater permit application:

A site plan showing the production layout, stormwater collection and containment areas,
and stormwater channels leading to the discharge point
A map delineating the area(s) of stormwater generation regulated under the NPDES
permit
A site stormwater management plan describing details as to how storm water on the site
will be managed, including process and non -process areas. Provisions described in the
plan will be included In a stormwater PPP developed following finalization of the permit
and before commencement of facility operations
As we discussed, permit acquisition is still on the critical path for finalizing construction and commencing
operations in a timely manner. The Department's cooperation, timely review and action on the NPDES
permit for process discharge water was a very Important factor in Horsehead's selection of this site.
Similarly, we appreciate your commitment to work with us in providing a timely review of our application,
and Issuing a NPDES stormwater permit for the facility without delay.
We plan to provide a draft of our permit application to you for comment. Based on comments from your
review, the permit application will be revised and finalized for submittal -to the Department for review. We
believe this approach will result in a complete and accurate permit application, and that following
submittal will -enable the Department to analyze the application and Issue a permit promptly.
Thanks again. Please let me know if you have any questions.
Forrest
Forrest R Westall, Sr., PE
McGill Associates, P.A.
PO Box 2258
Asheville, NC 28802
Physical Location: 38 Orange Street, Asheville
Phone [phone]
Fax [phone]
foirest.westall(a%mc i� llengineers.coan
From: Pickle, Ken [mailto:[e-mail]]
Sent: Wednesday; November 30, 20119:53 AM
To: [e-mail]
Cc: Bennett, Bradley; Chernikov, Serge[
Subject: Horsehead meeting yesterday
Hi Forrest,
Good meeting yesterday from my perspective. I hope you and your client feel the same. Thanks for
taking the trouble to go over the physical facts with me.
A few things occurred to me that were not addressed, or not completely addressed, yesterday:
• As presented yesterday, Horsehead will have a lab on site, and they will be doing their own analyticals
for the NPDES stormwater permit. Please note: for the permit reporting their lab must use the EPA
Methods. I assume that for internal process QA/QC Horsehead mlghtIntend to use analytical methods
other than EPA Methods. That's OK for their internal process QA/QC, but it doesn't satisfy the NPDES

requirement under federal regulation for the water quality analyses undertaken in direct response to
permit requirements.
• However, there is a provislon in the federai,rule that will allow us to accept alternative methods. They
just need to come forward and request our approval in advance if methods other than the EPA Methods
are contemplated. We will pass the request on to our inorganic lab folks for review.
• Of course, it goes -without saying that an acceptable method must go down to an MDL/PQL that will be
below the benchmarks.
• On the Issue of lab certification, two aspects are of note here.
If they will be running analyticals for Sergei's wastewater permit, then the lab must be state certified
for the analyses related to the wastewater permit limit parameters.
• However, for NPDES stormwater permit testing, DWQ certification is not required: Stormwater
analyticals are a special case, and are not required to be by certified labs/staff. However, however - -
Even if not certified, the lab must still use the EPA Methods for stormwater analyses, as required by
federal rule - - or they must have our approval of alternative methods.
• Just chatted with Bradley, and we think that the substation east of the railroad is not part of the
Industrial activity,. and would not have stormwater discharges regulated under the NPDES stormwater
program. We had already reached this tentative conclusion in our meeting, but I had promised to check
on It for us. The substation will not be subject to the stormwater permit.
Just to reiterate the point about the perimeter site roads: Drainage from the site roads is considered
stormwater from industrial activity. Yesterday Horsehead related their intent to capture that runoff.
Just to clarify: Roads are typically designed with a crowned cross-section - - It appears that Horsehead
must either design a sloped but un -crowned cross section draining to the inboard side, or must include
runoff capture features on the outboard side of the road to capture that runoff and direct it back to the
Inside. It's my impression that an un -crowned road is an unusual feature, and typically must be the
subject of deliberate focus during the site design process.
kbp
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. pickleftcdennnov
Website: htto //portal.ncdenr.org/web/wq/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law
and may be disclosed to third parties unless the content is exempt by statute or other regulations.**

ATTACHMENTS TO
EPA FORM 3510-2F
GENERAL INFORMATION
HORSEHEAD CORPORATION
RUTHERFORD COUNTY PRODUCTION FACILITY
• DWG. No. E -0000-G-1004 D Forest City N.C. SX/EW Plant, 'Genera�l✓J Arrangement,
Storm Water Management Plan, Horsehead Corporation, _prepared by Carnegie Strategic
Design Engineers, LLC, Release Date March 1, 2012.
,. • Continuation of Part IV. Narrative Description of Pollutant Sources, B. narrative
description of significant materials..., management practices to minimize contact by
these materials with storm. water...
• Narrative describing the facility's operation, feedstock materials, reagents and products
produced.
• Letter from Horseheads Corporation to Mr. Charles Waklid, Deputy Director, North
Carolina Division of Water Quality, dated June 13, 2011.
• E-mail correspondence between Mr. Ken Pickle, North Carolina Division of Water
Quality, and Mr. Forrest Westall, McGill Associates, P.A. dated November 30, 2011 and
December 8, 2011 respectively.
✓ • Copy of the State of North Carolina, Division of Water Quality, Permit to Discharge
Wastewater under the National Pollutant Discharge Elimination System Permit .No.
NC0089109.

Continuation of:
Part IV. Narrative Description of Pollutant Sources
B. Narrative description of significant materials..., management practices to
minimize contact by these materials with storm water runoff..., materials loading
and access areas, and the location, manner, frequency in which pesticides...
(Page 2 of 3, EPA Form 3510-21T (1-92))
Solvent solutions and other stock materials will be used in an extraction process,
including limestone, sulfuric acid (AR grade), sulfuric acid (93%), Sodium
hypochlorite (12%), hydrochloric acid, lime, manganese, peroxide, kerosene,
strontium carbonate, flocculants, dehpa [Di-(2-ethylhexyl)phosphoric acid], carbon,
sodium hydroxide, sodium hydrosulfide, ammonium chloride, soda ash, and sodium
chloride. Liquid materials will be brought to the plant in rail cars and tanker
trucks and will be unloaded to storage tanks. Solid materials will be purchased in
bags, supersacks or containers and stored in covered storage areas, with the
exception of time, limestone, and soda ash which will be pneumatically offloaded to
process bins.
Along with metallic zinc products, solid byproducts from the process will be stored
at the site, including gypsum and several varieties of solid material containing heavy
metals that will be bagged or containerized for transport by rail or truck to
industrial operations as raw materials or recycled at Horsehead facilities.

Horsehead Corporation
NPDES Stormwater Permit
Rutherford County, North Carolina
Horsehead Corporation is the leading recycler of zinc bearing waste generated by
North American steel mini -mills, and the largest producer of zinc in the United
States. Construction is underway on a new zinc production facility located in
Rutherford County, just south of the Town of Forest City. The facility will have
limited air emissions and will discharge a clean brine process waste water.
This newly constructed facility upon startup in the future will apply a proprietary
hydrometallurgical process (solvent extraction / electro winning) for producing high
grade zinc metal from two primary feed materials including waelz oxide (a.k a.
crude zinc oxide) and zinc metal drosses and skims recovered from galvanizing
operations. The production process includes use of feed materials in an aqueous
and hydrocarbon based solvent extraction process to produce a zinc rich electrolyte
solution for use in a cell house where an electro winning process is applied to
produce metallic zinc. Similar technology is commonly used to produce metallic
copper from mined copper ore feed material in the western United States. The
facility will have the capacity to produce approximately 148,000 tons of Special High
Grade (SHG) Zinc metal annually.
The following tables provide information on Feedstock Materials, Reagents, and
Products and By-product Materials that will be used and produced at the facility:
FEEDSTOCK MATERIALS
FEEDSTOCK
MATERIALS
QUANTITY
tons/ ear
Zine Oxide ZnO)
228,000
Galvanizer Skimmings
28,500
256 SoOTPy / •�
REAGENTS )�- ri
t-(2- � n1
REAGENT
QUANTITY
(tons/ ear
REAGENT
QUANTITY
tons/ ear
Limestone
36,000
2.
De ha
150
Sulfuric acid
41,300
1
Carbon
58
4
NaC10 12%)
5,825
5
„Cl
44
IS
HCL
3,900
5
NaOH
11
Lime
1,608
NaHS
4
l7
Peroxide
975
q
Mn Sulphate
2,218
G
Kerosene
600
io
NaCl
1,200
g
Sr Carbonate
165
11
NaCO3
4,400
Floc
86
l

PRODUCTS / BY-PRODUCTS
PRODUCT
QUANTITY
(tons/year)
PRODUCT
QUANTITY
(tons/year)
Zn SHG
148,000
Final Residue
2,800
Zn CGG/PW
8,000
Non -Zinc Bearing
Metallics
1,132
Gypsum
61,000 J
Metallic Cement'
536
Lead Concentrate
9,200
Crud Residue
156
Glaubers Salt
13,000
PLINT Residue
32,000
The objective of the proposed storm water management plan is to manage all storm
water for discharge from the facility through a single monitored outfall to the Broad
River. Storm water from various areas -of the facility will be managed according to
the following scheme:
1. Storm water falling into various operating/production areas will be collected
in segregated collection basins underlying or. adjacent to these areas, as
designated, will be analyzed for likely pollutants to determine its disposition.
Based on analytical results, the water will be discharged to the storm water
system, used in production process operations, or possibly treated prior to
discharge. This water is referred to as "discretionary storm water" for
discussion purposes.
2. Storm water drainage from standard commercial or landscaped areas and
perimeter roadways, roofed areas having no contact with industrial
processes. This water will be discharged directly to the. storm water system
leading directly to the storm water outfall. This water is referred to as "non -
discretionary storm water", and
3. Storm water falling into a few designated operation areas will be collected in
segregated collection basins underlying the designated area(s) and used for
production process operations at all times, and not discharged to the storm
water system.
4. Storm water from undeveloped areas (fill and vegetated areas not affected by
plant activities) will be discharged through energy- dissipation into natural
drainage channels.
Storm water from described areas 1 and 2- above will discharge to the single
monitored outfall for the facility. Storm water drainage from areas described in
item 3 above will not be discharged but will be used in the production process, and
storm water drainage from areas described in item 4 above, .including unaffected
surrounding property, will discharge into natural drainage channels.
00

NCS000562 11 American Zinc Products LLC 1
Map Scale 1:24,000
Latitude: 350 11' 36" N
Longitude: -810 50'59" W
County: Rutherford
Receiving Stream: Broad River
Stream Class: C
Index Number: 9-(36.5) (Broad River Basin)
Facility Location

L.
From: Belnick, Tom
Sent: Wednesday, May 04, 2011 1:39 PM
To: Bennett, Bradley; Karoly, Cyndi
Cc: Chernikov, Sergei
Subject: FW: Horsehead Corporation, Rutherford County Site
✓ Just to double check that a stormwater permitting rep can attend this meeting that was requested by Forrest and
Horsehead Corp. It's been set for Monday May 9, 1pm, 9fcr, and will be focused on whether there are any stormwater
permitting needs. We already covered wastewater permitting during a previous meeting with the applicant. Sergei will
still plan to attend from the wastewater side, just in case there is need for a combined SW/WW permit.
Tom Belnick
Supervisor, Complex NPDES Permitting Unit
NC DENR/Division of Water Quality
1617 Mail Service Center, Raleigh, NC 27699-1617
[phone]; fax [phone]
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: Forrest Westall [mailto:[e-mail]]
Sent: Monday, April 18, 20115:40 PM
To: Belnick, Tom; Bennett, Bradley; Chernikov, Sergei
Cc: Matthews, Matt; Karoly, Cyndi; Poupart, Jeff; Wakild, Chuck
Subject: Horsehead Corporation, Rutherford County Site
Hello,
As a follow-up to our discussion on this proposed facility, the Company would like to discuss the(stormwater implications)
of the plant. As we noted in our meeting on the 7th the site drains to a section of the Broad River that is class C waters
and is outside of any Phase II area. The company is looking at(several options concerning stormwater management) We
very briefly discussed at our meeting how DWQ might address stormwater permitting and if that process will be a
(separate permit)or incorporated into the process discharge. We would like to schedule something the week of May 9 in
sleigh to review this issue. The best days for me are Monday the 9th and Friday 13th, but we would like to work within
your schedule.
Please let me know of your availability that week.
Thanks,
Forrest
Forrest R. Westall, Sr., PE
McGill Associates, P.A.
PO Box 2259
Asheville, NC 28802
Physical Location: 38 Orange Street, Asheville
Phone [phone]
Fax [phone]
forrest.westallgmcgillengineers.com
Co rrPs�Jan�e7tc9

Sergei — what does this facility make? Presumably not Horseheads — that would be agricultural, not industrial activity,
and outside of our authority.
Ken
From: Georgoulias, Bethany
,/Sent: Friday, May 06, 2011 10:27 AM
To: Bennett, Bradley; Pickle, Ken
Subject: RE: Horsehead Corporation, Rutherford County Site
Bradley,
I can be there if I'm back by 1 PM that day. I'll do my best, but will have to let you know that morning. Unfortunately
I'm typically gone between 12:30-1:30. -Bg
Bethany Georgoulias
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
NEW Website: http://portal.ncdenr.org/web/wq/ws/su
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: Bennett, Bradley
Sent: Wednesday, May 04, 2011 1:44 PM
To: Pickle, Ken; Georgoulias, Bethany
Subject: FW: Horsehead Corporation, Rutherford County Site
Hey Guys,
I think I neglected to forward this around to anyone earlier. I am planning to attend, but if one of you is also available it
would be very useful. I think NPDES Industrial issues may be the most important ones for the project. It may be
worthwhile for us to talk to Forrest before the meeting also
Thanks
BB
Bradley Bennett
Stormwater Permitting Unit
NC Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Phone: [phone]
Fax: [phone]
Email: [e-mail] (New Email Address)
Web: http://portal.ncdenr.org/web/wq/ws/su
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third
parties.

A -
TIMOTHY R. BASILONE
Vice President - Eindronancotal Affairs
4955 STEUBENVILLE PIKE WW..HORSEHEAD.NET 724.773.2223
SUITE 405 TEAS ILONERHORSEH EAO. NET 412.7BB.4526
PITTSBURGH, PA 15205
June 13, 2011
Mr. Charles Wakild, Deputy Director
North Carolina Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Kc ✓1
SBOO EJ S—ADr
CORPORATION
Leading the World in Zinc Recycling
1 JUN 1 5 2011
RE: May 9, 2011 Meeting -
Division of Water Quality
Horsehead Corporation, Proposed Production Facility, Rutherford County
Stormwater NPDES Permitting and 401 Certification Processes
Dear Mr. Wakild:
I'd like to thank you and others from NCDWQ, including Mr. Matt Matthews, Ms Cyndi
Karoly, Mr. Bradley Bennett, Dr. Sergei Chernikov and Mr. Ken Pickle, for giving
Horsehead Corp. (Horsehead) the opportunity to meet with you on May 9, 2011 and
discuss the potential plans for constructing a zinc production facility in Rutherford
County, North Carolina. Horsehead and our consultant, McGill Associates, appreciate
information you provided concerning stormwater NPDES permit issues and the 401
certification processes. You provided valuable information with regard to requirements
dealing with these subject areas that would apply to Horsehead's proposed facility.
At the meeting, Horsehead provided a summary of the company's business, a description
of the new plant and processes invo ved to pro uce zinc metal, and noted the importance
of this new production facility to our business plan. As we indicated in our meeting,
understanding the permitting process and securing necessary permits in a timely manner
for the sites under consideration is a critical component in making a decision as to the site
that will be selected for this facility.
�,X
vvV
The PowerPoint presentation provided at the meeting contains business confidential
information. A copy of the presentation was not provided to you, but we request tha ke
production process design informationfor the facility and site be protected under State
and Federal law, an��rat tlris information e�treate as usiness Codenri - ? "g nsl�ess
s �usf ref—ro dnt�P�nf Pew o, rt rain iPn�re�
o ey �nfa fhe�esn,
As we pointed out during the meeting, the information provided about the facility and the
site is preliminary and represents a general description of the operation of this proposed
facility. We are continuing with our faotlity design efforts and establishment of the final
operating criteria for the plant. Horsehead and associated consultants for this project are
avat a—'1 -61e to answer any questions that you may have and welcome the opportunity to
A;-- ^tormwater and 401 permitting requirements for the proposed facility.

Discussions during the meeting were beneficial for our understanding of the State's
stormwater and Section 401 permitting processes, and provided information required to
obtain these permits. Furthermore, we gained valuable insight as to the time required by
e aitI g for review of the permit a lications, and the decisions the agency must_make
to rocess the permit requests. Below is a summary of information obtained from
meeting to clarify our understanding of points made during our discussions.
♦ Horsehead currently plans to configure the site in such a way that any we_
precipitation on the site that may be exposed to feedstock or final product/.co- sa��
product materials will be managed and used for the facility's production process.
The NCDNR indicated that the permit for this and
would be evaluated
The
the NPDES process wastewater ermit and not under a stormwater permit,
ac/os-o� chm.ce -- --�-
♦ NCDWQ characterized this approach generally as a site with a ormwater C� N PDES"so�mwa2e�
/ LL drainage are having two separate collections terns: a "clean' side and apns�1°FS waswai�r
Gor4 �aln ,7 rJ ri/l y1 cc 2 » "clean"
� �(IOi fB 0.iZ{-CoiD '��•c..i;
-� potentiall ontaminated side. The cleanPortion of the facility drainage N p Dg
/*,17sel" fo S would include drainage from the impervious, non -process surfaces on the site
,4✓��� ..sio%�i�' (rooftops, non -process holding areas, and parking areas) and the landscaped areas
J "tN a / words /0 related to the site development, of including the areas of the property left in a� 3
t6� me���� natura state,--
wha+ s ke
♦ NCDWQ indicated that a stormwater NPDES permit would be required for the
"clean" drainage and that this permit would essentially be directed at
characterization of the drainage system identification of outfalls and provisions
for the qualitative periodic monitoring of stormwater runoff from included areas
over the permit period, and development of a stormwater management plan for
the areas draining to the "clean" collection system,
5dytnc�? k ke
Con'F�lS�nq 2PPI,cdiron
(o DU
rer rA I (-1W I 8 h"94
Because there is currently no general permit for the Non -Ferrous Metals
production SIC, the NCDWQ would be required to process a permit application
under the individual NPDES Stormwater Permit portion of the progr m,h to suhM1f j
—, T �Su6n, 44 if
♦ Horsehead and consultant
NCDWQ to develo G
permit application for
program,
work in
facility's stormwater
junctio with the
Ade a complete NPDES
that fall under this LL
♦ I Horsehead and NCDWQ will coordinate activities to manage
development for the corn_ ip lation_o_f a cob. mlete `permit application,'; and to deve op
a schedule for securing a permit in the timeliest manner possible,
♦ NCDWQ agreed to provide direct and quick communication by phone and e-mail
to address any questions related to the application and to resolve any issues in a
Ptimely manner and to keep the review process moving, /
�Je will do ou.r• F3)r41 ,���i�el �DroC�SSl�iq %S t'a dc°
� J J
po"119ke?c� lhC�ill uY�si �o f�e;� Pari' ch
,P-/-/- 'C®ur5�

*.
♦ NCDWQ appointed Mr. Ken Pickle as the primary point of contact for off'©r off• oe�s`'
communication on the stormwater permit application process, "' �'`/ be crry o/vc� /ete•
♦ Horsehead will submit a stormwater permit application for the site as soon as the
final site facility layout plan is completed. This is expected to occur in the early
fall,
♦ Following submittal of a complete application NCDWQ advised that three to four
months would be required for the development of a final draft permit for public
notice under State requirements,
♦ Horsehead anticipates that the only stream/wetland impacts under Sections 404
and 401 of the Clean Water Act to be for an effluent discharge outfall structure on
the Broad River and possibly a water intake structure for process water on the
River both of which likely can be covered under the Corps of Engineers
Nationwide Permit for utility activities and North Carolina's General Certification
for these activities,
♦ It is understood that a complete site evaluation for waters and wetlands will need
to be performed, and Horsehead will obtain such information before finalization
of any applications,
♦ NCDWQ agreed to work in coordination with Horsehead to secure a complete
401 Certification application once final proposed impacts can be established,
♦ Based on the identified impacts, NCDNR and Horsehead will establish quick
response lines of communication by e-mail and phone to resolve any questions
about the application and the processing of a final 401 Certification,
♦ Ms. Cyndi Karoly, NCDWQ Branch Chief for the stormwater and 401 programs
will be the initial point of contact, the review process will be assigned to the
appropriate staff for the stream/wetland impacts that are planned,
♦ NCDWQ indicated that all communication with Horsehead related to any
comments received from staff or the public would occur in a timely manner, and -
that if further public review was required, the Division would move this process
along as quickly as possible to a final determinatiion' /on pending approvals and
permits. :� 0 rQ /rs.//c% our ,r7": 41 �7ofSL Peed an�` /4c ctr d/S®
de¢errnind 7Xe- sOie'4e5?ss cJe &_fill have rm deEh bqq X0 `M6V& fin%s PrOQJS
Mr. Ken Pickle has already provided several pieces of information and feed -back a/®� epS ��ck-Y as
7A-,-,? kJ following our meeting. We appreciate his responsiveness in helping us to develop our �0 ��6/�
approach to stormwater management on the site.
sefs -lAe ?
sr`a > Commitments made by the NCDNR during our meetinjprovide information that is
critical for completing our site evaluation process. Horsehead looks forward to working
with the NCDNR on this important project. As you are aware�,.this new production
s��s t�� hook

�..._-s at+�.{iRs !�n/4 e�ffio risl��d6i�l�y ��su`yMPoia
the SPS n�, mf f/te
facilit} represents a large commitment of resources and technology by Horsehead or the
production of zinc and other non-ferrous metal products.
ys�.tch d5 �,/,d�7,t/of"sure we kooa)'of�ier P+eialr.
In relation to permitting requirements under the stormwater program, McGill Associates
will serve as our ^p�rimary resource for development and submittal of a complete pe it
a�p_pli_c_a_t_i_on�Mr. POlrest Mall at McGill Associates will assist in coordinating
m orm� f ation flow between Horsehead and the NCDNRI Mr. Westall can be contacted at
828.231.6840 (ce ) or 8.252.0575 (office).
We appreciate your assistance and that of NCDWQ's staff in helping us t define he
stormwater permitting requirements for this situ Please feel free to contact me with any
questions you may have.
Sincerely,
Timothy R. Basilone
s� c e 41.t wor
I'S pecu(lar,f}�doesn'1 de Fina +4e
n B
�ec��rpmesiS,O Co1�'Safons I., {-ltie
4neVe1-inq +e��•2 t.�P9E5 rre-q;uI��"4k
e t,4—r 9.x +0 -full scope or �uN ParFose-,
©.4r,n +he con ver5aiio n "6,le I+Wrt oLLr
cc Forrest Westall, McGill Associatesbest eK+aMroraneous nfnr� of °n
Darin Cooper, Horsehead C MP?r « +1- +IMe Gertz Nly ear ve�bz(
rrPo+ ne+ b,e +tker to
r4Vtr%KQ o� i6a
1 perw.,t+'hg 'i4,
Hl S¢rvG 95 6urr7rimarY frsource�'� a9en� or t�efe�z�ion site.
wtli dSStt} In (Oor�/in�a�<utlq In�orMB�lon �(Otifagenc') or �e�evta�+ 07
•i McFerN eannoU7� 9��dk A, Jwa"5,okld

Pickle, Ken
From:
Forrest Westall[[e-mail]]
Sent:
Tuesday, July 05, 2011 7:16 AM
To:
Pickle, Ken
Cc:
Bennett, Bradley; Chernikov, Sergei; Karoly, Cyndi; 'Basilone Tim'; 'Cooper Darin';
[e-mail]
Subject:
RE: Horsehead
Hi Ken,
Thanks for the note. I was out last week and didn't get a chance to respond
We appreciate the offer to review preliminary permit packages for he SW permit. We will certainly take you up on that and
agree that we want to avoid any delay due to not including information needed for your review. The term "final site facility
layout plan" as used in Mr. Basilone's letter describes a full civil/utilities layout including all site drainage and any
storwmater retention/capture/treatment facilities planned, showing each drainage area and the associated point of
discharge to surface waters. All outfalls from the site would be shown. In addition, using the review process you outline
will give us the opportunity to identify any additional information on the detailed site plan that you will need to complete the
permit review.
Thanks again,
Forrest
Forrest R. Westall, Sr., PE
McGill Associates, P.A.
PO Box 2259
Asheville, NC 28802
Physical Location: 38 Orange Street, Asheville
Phone [phone]
Fax [phone]
fo rrest.westa I I Cal mcg i l l e ng i ne a rs. co m
✓ From: Pickle, Ken fmailto:ken. pickle(ancdenr.gov]
Sent: Thursday, June 30, 20117:46 AM
To: forrest.westall(almcoillenaineers.com
Cc: Bennett, Bradley; Chernikov, Sergei; Karoly, Cyndi
Subject: Horsehead
Hi Forest,
I just reviewed Mr. Basilone's letter of 6/13/2011. 1 have a comment on one bullet item, as follows:
"Horesehead will submit a stormwater permit application for the site as soon as the final site facility layout plan
is completed. This is expected to occur in the early fall"
I'd be glad to do a courtesy review of the site plan earlier, at maybe 50% or 75% or 90% complete, whatever is
convenient for the consultant developing the site layout. You may be familiar with a common dynamic in a design
house, where the least important aspect of the project delays it because no one did an early review. Why wait until the
"final site facility layout plan is completed"? Please consider coming to see me early, and bringing progress drawings on
every aspect that you think may have a bearing on our eventual review in support of the stormwater permit application.

Heads up: Please note that the meaning of "site layout" can vary from engineer to engineer. I don't want us to overlook
that the information most important to us in the review for a stormwater permit might also be called the "site civil", or
the "site drainage" drawing or drawings. I've seen "site layout" drawings for industrial facilities that are little more than
survey staking drawings. That won't be sufficient.
Ken

Pickle, Ken
From: Forrest Westall [[e-mail]]
Sent: Thursday, May 12, 2011 6:43 AM
To: Pickle, Ken
Cc: Bennett, Bradley, Chernikov, Sergei; Belnick, Tom, Wakild, Chuck, Matthews, Matt
Subject: RE: Horsehead stormwater permitting
v�ThankS Ken,
Based on your comments, you are out for a week. I hope you have a good time off
I will pass along your comments to the company and we will formulate a plan for SW based on our site knowledge and
when we can determine the exact configuration of the production facility/activity site. As you note, timing is the critical
factor in terms of moving forward with this site and the prospective permit processing timeline when we submit an
application will be important. At this point I don't see a huge issue with getting a SW permit consistent with the
construction of the facility.
Take care,
Forrest
OMcGM
A S S O C I A T E S
"Building Partnerships by Providing Superior Service with Professional Integrity"
Forrest R. Westall, Sr., PE
McGill Associates, P.A.
PO Box 2259
Asheville, NC 28802
Physical Location: 38 Orange Street, Asheville
Phone [phone]
Fax [phone]
[e-mail]
r/ From: Pickle, Ken [mailto:[e-mail]]
Sent: Tuesday, May 10, 2011 1:05 PM
To: [e-mail]
Cc: Bennett, Bradley; Chernikov, Sergei
Subject: Horsehead stormwater permitting
Hi Forrest, nice to see you yesterday.
I've left a voice message, but I'm out of the office for a week starting tomorrow. If you need to discuss further in the
interim, please contact Bradley.
A few items stuck in my mind from the discussions yesterday.
• As to schedule:
Our unit is doing a pretty good job these days with issuing individual stormwater permits on a quick time
frame. The individual permits have a built-in 30 -day public notice period, and a built-in 15 -day delay
between end of public comment period and our earliest issue date. Our recent performance has been
very good at holding the permitting process to that core time element plus a little at the front end to
make the application complete, and a little time after receipt of the complete application to turn our
individual permit template into an individual permit for Horsehead. We routinely send the applicant an

advance courtesy copy to be sure that he finds the provisions of the permit feasible. He has an
opportunity for further comment during the 30 -day public comment period. We would not routinely
include a public hearing; with the caveat that if the Director determines that sufficient public interest
has been expressed for a public meeting, we will hold one. That would delay the time frame. But, as
Sergei reported — and it's just as true for the Stormwater Unit as for his unit — minor stormwater
individual permits are issued typically without public hearings. In my eight years in SPU, I've
participated in just two industrial individual permits that led to public hearings. Others in the SPU have
done it less frequently than I have, if at all.
o As was identified in the meeting yesterday, it seems more like the time element of concern will be the
preparation of a site plan at a sufficient level of completion to allow a meaningful review of the
stormwater application — subdrainage areas (topo), drainage area divides (finished grade plan),
conveyances (ditches, curb lines), passive vegetative measures if any, etc. I can discuss with you our
likely review points when you all get down to developing the site plan.
o We will look at the potential for pollutants to escape the site via the stormwater. So, the slide
presented yesterday with a listing of materials proposed on site is already 90% of the way there, I guess.
• As to what gets permitted, and what risks and what exposures will be part of the new site: (Forrest, I realize
that you may be well aware of all of the following, I'm presenting it for thoroughness, ie to describe the universe
of stormwater permitting as it applies to our current understanding of Horsehead, and to refresh and sharpen
the boundaries in our minds as to the stormwater discharge permitting process.)
o Capturing the 'dirty side', to use my imprecise words, is a good concept. As Sergei said, we see it
frequently in OCPSF, and it's no biggie for us. Just to clarify the administrative perspective, in NPDES
once the intent is established that those runoff flows will be commingled with the wastewater collection
system, it's all magically wastewater, and the Stormwater Permitting Unit has no concern with the
flows. That's Sergei's permit, and his concern, not ours.
o Concerning the 'clean side' flows: These remain NPDES stormwater discharges and subject to an NPDES
stormwater discharge permit. Considering all possible areal sources of stormwater discharges, we
would look at it like this:
■ Starting around the main processing areas: Horsehead intends to capture those flows and direct
them to either/both the process as 'make up water', or to the wastewater treatment system.
We can remove these dirty -side flows from further consideration in the stormwater permitting
process. No longer our concern in SPU. The number used in the meeting for just a place -holder
was about 30A.
■ That leaves those areas that are still areas of industrial activity, but might be characterized as
less risky from a pollutant generating perspective. The number used in the meeting as just a
place holder was 50A total site grading, which minus the 30A leaves 20A, as I understood the
discussion. The discharge of runoff from this 20A area must be authorized by a NPDES
stormwater discharge permit.
■ For the undeveloped portion of the 190A site, those flows from the remaining 140A (190A -50A =
140A) would be considered as not part of the 'area of industrial activity', and would not be
subject to the authority of the NPDES stormwater rules. Our stormwater permit would not
regulate the runoff from that area. This would include any woodlands; pasture; crop lands;
areas of pre-existing but now proposed to be abandoned development; and even perhaps
facility yard if it's not used for any other industrial purpose and is clearly separated from the
industrial activities. Please note: the federal NPDES rules criterion for regulating the runoff
from these areas via stormwater discharge permit is whether or not there is any industrial
activity - - not whether or not there is any potential for exposure, or any likelihood of pollutant
release. We like it if there is limited exposure, or limited potential for pollutant release, but it's
not our basis for permitting. That's not always intuitive to some applicants. I suspect
Horsehead already understands this, but it bears repeating.
o Concerning what the required elements of a stormwater permit would be:
■ A written management plan specifically serving the objective of controlling stormwater
pollutants. We call this the SPPP, Stormwater Pollution Prevention Plan.
z

Monitoring of discharge flows for pollutants potentially present on site. Monitoring results will
be compared to state-wide benchmark values. Lab results below benchmark values require no
response except submittal to DWQ Central Files. Lab results in excess of benchmark values do
not constitute a permit violation, but rather are a call to the permittee to investigate the source
of the high value, evaluate the feasibility of a corrective response, and if feasible to make that
response. Typically individual permits have either 2/yr or 4/yr sampling requirements.
Stormwater BMPs are not typically required in an individual permit, but we have written them
into individual permits if our understanding of the site conditions suggests that a facility can't
possibly meet benchmark values without them. BMPs may also subsequently be required if the
permittee repeatedly fails to meet the benchmark values despite attempts at pollutant source
control.
I'll be out on vacation starting tomorrow. If you have any follow-up questions in the next week, contact Bradley.
Ken
[phone]

Pickle, Ken
From:
Sent:
To:
Subject:
Attachments
Ken,
Please see attached.
Thank you!
Sergei
Chernikov, Sergei
Tuesday, November 22, 2011 10:55 AM
Pickle, Ken
RE: Horsehead zinc reclamation plant
89109 -permit -2011 docx
Sergei Chernikov, Ph.D.
Environmental Engineer II
Complex Permitting Unit
Phone: [phone], fax [phone]
1617 Mail Service Center
Raleigh, NC 27699-1617
Express mail: 512 North Salisbury St.
Raleigh, NC 27606
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: Pickle, Ken
Sent: Tuesday, November 22, 2011 10:37 AM
To: Chernikov, Sergei
Subject: FW: Horsehead zinc reclamation plant
Hi Sergei,
I'm getting prepared for a meeting with Forrest Westall and Horsehead next week. In a phone call Friday,
Forrest made reference to the monitoring parameters in the wastewater permit: can you send me an electronic
copy of that permit so that I can see what he was referring to?
• The meeting is tentatively set up for Tuesday, Nov 29, 1:00-3:00 in the Land Quality conference room on the 51h
floor. If you have anything to discuss with them, we can make time for you to do that.
Thanks,
Ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]

Fax: [phone]
Email: ken. oickleOncdenr.gov
Website: http://Dortal.ncdenr.org/web/wa/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Forrest Westall [mailto:[e-mail]]
Sent: Monday, November 21, 20112:34 PM
To: Pickle, Ken
Cc: Bennett, Bradley; Georgoulias, Bethany; Chernikov, Sergei
Subject: RE: Horsehead zinc reclamation plant
Thanks Ken. This information is helpful. You indicated you are available the week of the 28'". I'm trying to check the
schedule of the company representative, but if you are available the 291" could you tentatively set aside some time late
morning or early afternoon to go over the site plan and discuss our approach to SW management on the site?
Just let me know,
Have a good afternoon,
Forrest
Forrest R Westall, Sr., PE
McGill Associates, P.A.
PO Box 2259
Asheville, NC 28802
Physical Location: 38 Orange Street, Asheville
Phone [phone]
Fax [phone]
foffest.westall(@,mcgillenpineers.com
From: Pickle, Ken [mailto:[e-mail]]
Sent: Monday, November 21, 2011 11:10 AM
To: [e-mail]
Cc: Bennett, Bradley; Georgoulias, Bethany; Chernikov, Sergei
Subject: Horsehead zinc reclamation plant
Hi Forrest, nice to speak with you this morning.
Just to restate: As we discussed, I am not aware of any instance in which the NPDES industrial stormwater program
identified a design storm approach in our permitting. Our permit has benchmark values that serve to alert the site
manager when pollutants at a level of concern are being discharged. The permit calls on the site manager to react
when he becomes aware of those levels of concern. Our approach might be considered a performance spec —'Just
meet the numbers, however you can.'
As you requested, please see attached below the narrative discussion and the tabulation of the benchmarks that could
appear in any of our stormwater permits.

Th+e indivlWual permit application will ask what materials have the potential to be present on site. Typically we will
assess the significance of the materials, and will write the individual stormwater permit to address the risks in
accordance with our assessment. Where we conclude that significant risk is present, we will write that parameter into
the individual permit, along with its benchmark. For example, if Horsehead tells us that zinc and lead are certainly
present, and that arsenic will be present in trace amounts, we will probably include all three in the stormwater
monitoring program. If you tell us that kerosene is present, we may look at including TPH, or maybe the BETX suite. We
will certainly include as a smatter of course the conventional pollutant measures TSS and pH. If you tell us that nitric acid
or ammonia or other nitrogenous materials are on site in significant amounts, we will probably include Total Nitrogen in
the monitoring suite. If you tell us that the facility's QA/QC lab uses 2 gallons of sulfuric acid per year, we don't care (ie,
we assess the risk as insignificant), and that limited usage by itself would not be reflected in the required monitoring.
A benchmark exceedance is not the same as a permit limit violation. The semantics are relevant here. Both are
numerical measures of performance, but while a limit violation is a permit violation, a benchmark exceedance is not. It
is instead a call to site management to acknowledge the exceedance, to investigate the cause, to evaluate feasible
corrective measures, and to determine whether to implement such measures.
Our stormwater permits are structured to allow the permittee several attempts to address benchmark exceedances
before DWQ steps in to help resolve high discharges of stormwater pollutants. This is the 'Tiered' structure that can be
observed in several of our General Permits. I've also provided a link below to our General Permit NCG03 for metal
industries so that you can see how it works. Typically the Tiered structure is like this:
If the permittee has no benchmark exceedances: 'Keep up the good work. '
One benchmark exceedance: acknowledge, investigate, evaluate, implement response actions if feasible. 'Try to fix it.'
No DWQ involvement.
Two consecutive benchmark exceedances for the same parameter at the same outfall: All of the actions above for one
exceedance, plus begin monthly monitoring. 'Try to fix it.' No DWQ involvement.
Three exceedances for the same parameter at the same outfall: As per above: 'Try to fix it.' No DWQ involvement.
Four exceedances for the same parameter at the same outfall during the term of the permit: Permittee must contact
the DWQ Regional Office and request assistance in resolving the continuing discharge of stormwater pollutants. The
DWQ RO may grant relief: or at the other end of the spectrum may direct the installation of BMPs, as per the broadest
view of all the circumstances and DWQ RO judgment. 'We're here to help you fix it.'
• As we discussed, the NPDES stormwater permitting program is an end -of -pipe program. I'm not aware of any provision
in the federal NPDES stormwater rules for a dilution approach for
industrial stormwater. We do not have the same history or authority as the NPDES wastewater program, as far as
considering the dilution factor into the Broad River, and back -calculating wastewater permit limits based on a
Reasonable Potential Analysis. Please let us know early if you see a need to explore further the Broad River dilution
approach. This idea takes us out of just a routine permitting approach, and calls onus to evaluate programmatic
consistency and impact, as well as equitable treatment of other permittees, as well as consistency with the federal
NPDES stormwater rules and whether we have authority to act based on dilution. If you choose to pursue it, conclusive
discussion of this idea must include those up the chain from me.

• Here are the two attachments and the link to a General Permit to show you roughly how we would write up a Tiered
structure for Horsehead.
http://Portal.ncdenr.orp/c/document library/get file? uuid=fde771c4-fe8e-44ad-ab70-323334845d33&groupld=38364
Forrest, I'm here through Wednesday this week, and back in the office on Monday next week if we need to talk, or to
schedule a site plan review together.
Thanks,
Ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. pickle(&ncdenr.00v
Website: http://portal.ncdenr.orci/web/wo/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**

Pickle, Ken
From: Pickle, Ken
Sent: Tuesday, November 29, 20116:07 PM
To: Georgoulias, Bethany; Bennett, Bradley
Subject: RE: Horsehead zinc reclamation plant
FYI, No Action:
Met this afternoon with Forrest and the folks from Horsehead. No problems, as far as I can see.
• We did touch on the topic of dilution in the Broad River, and the fact that stormwater benchmarks are lower
than some of the wastewater limits. I first acknowledged that it could be viewed as an inconsistency, and began
a defense of this aspect of our program. However, Forrest was enthusiastic about the acceptability of our end of
pipe benchmark approach, and was not interested in my beginning defense: point resolved acceptably to all,
apparently, without me having to get into it. I'm not sure what misapprehension was active here, but we were
all smiling after a while.
He stated that a permit application would be forthcoming, and I did not detect any residual objection to the
'end -of -pipe' approach in our program. He challenged us to beat Sergei's 30 -day turnaround time which, with
suitable bravado, I sniffed at.
I went over NCG17, as an example of the SPPP and the Tiered approach. They seemed content with their
obligations under any similarly constructed permit (an NCS, in their case.)
ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. pickle 0ncdenr.gov
Website: http://portal ncdenr.orci/web/wg/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Pickle, Ken
Sent: Tuesday, November 22, 20113:27 PM
To: Georgoulias, Bethany; Bennett, Bradley
Subject: RE: Horsehead zinc reclamation plant
FYI, No Action
Read further only if you have a special interest.
Just took a look at Sergei s permit for Horsehead. Here's the issue for Forrest, I think, that stormwater benchmarks are
lower than wastewater limits:

Parameter
NCO089109 Wastewater
discharge limits
Potential NCS benchmark
Apparent
discrepancy?
Comment
Flow
0.62 MGD mo. avg.
-
TSS
Monitor only
100 mg/L
Ammonia -N
7.2 mg/L
Aluminum
0.75 mg/L
Antimony
0.09 mg/L
Arsenic
0.36 mg/L
Cadmium
350 ug/L mo. avg : 2143 ug/L
daily max
1 ug/L
x
3 orders of
magnitude
Chlorides
Monitor only
860 mg/L
Chromium
1 mg/L
Cobalt
0.03 mg/L
Copper
0.007 mg/L
Fluoride
315.8 mg/L: 315.8 mg/L
6 mg/L
x
2 orders of
magnitude
Iron
Monitor only
1 mg/L
Lead
4386 ug/L : 4829 ug/L
30 ug/L
x
2 orders of
magnitude
Nickel
Monitor only
0.26 mg/L
Tin
"
Zinc
0.067 mg/L
pH
6-9
6-9
Chronic Toxicity
Monitor only
-
Turbidity
Instream < 50 NTU, or no
increase
Instream < 50 NTU, or no
increase
Considering the above, and based on recollection of our phone call, it wouldn't surprise me for Forrest to highlight the
following aspects of the currently proposed site design:
• There are three natural drainage features on the property, but converting all that pasture and woodland to an
effectively impermeable plant site means that the three features are not hydraulically equipped to handle the
increased flow; with the result that trying to utilize the three features would result in significant erosion and
head cutting. There is a 90' steep slope from the terraced plant site to the flat ground around the river. The
combination of topography and increased flow argues against trying to use the existing features for stormwater
conveyance.
Instead, Horsehead will capture all the excess site runoff and direct it to a single outfall pipe directly into the
Broad River. l Excess site runoff, because a portion of the site runoff will be utilized in the process. So, there
may be discharges only in large events, or when the facility is not operating —1'm not exactly clear on when
discharges would occur.) Given the great dilution in the Broad River, even at low flow, and as reflected in the
relatively high wastewater limits above, does it make sense to have such low benchmarks for the stormwater
discharges? Essentially Forrest's argument may be: If Sergei's analysis quantifies the pollutant limits necessary

to protect the Broad River for a 365d/yr discharge, shouldn't the less frequent, more diluted stormwater
benchmarks be at least as high, if not higher?
• The facility has already been through the DAO, and the emissions into the atmosphere are ok with our brothers
and sisters in DAQ. So, if it's already authorized to be in the environment, then DWQ shouldn't double count
those heavy metals just because some of them fall out on the plant site and are washed off in the runoff.
NOTE: It sounds like Horsehead and Forrest will be coming forward with a site plan that makes no attempt at BMPs or
any stormwater treatment. The primary raw material here is EAFD(?) Electric Arc Furnace Dust - - it's chockfull of heavy
metals — obviously, because zinc and plumbum are their products. Our assessment for the potential for polluted runoff
should consider the hazardous nature of heavy metals.
The first counters that come to mind are:
• The benchmarks are not permit limits. They are flags for the site manager so that he can be vigilant in insuring
that pollutants from industrial sites do not accidentally slip off his site in stormwater runoff. It makes sense for
us to require response actions as outlined in our individual permit template in order to have site managers
serious about the discharge of pollutants from their sites.
• For intractable conditions DWQ can grant relief from the benchmarks.
• Where accumulated data can show that pollutants are not present and not discharged from the site, DWQ can
easily re -open the individual permit and amend the monitoring requirements as to frequency and parameter.
First let's characterize the discharges from this unusual industrial facility (there are none exactly like it in the
world, and only a few even reclaiming EADF by any process), and let's err on the side of protecting the
environment, and then let's back off where accumulated data shows that we have been overly cautious.
• If the site is indeed clean, there shouldn't be a problem meeting these benchmark values.
• If there is a problem, then perhaps street sweepers, or additional roofing, or bioretention cells in hot spot
sources, or grassed conveyances could help. At least try to do something if heavy metals are leaving your site.
• We acknowledge that for some, it may be counterintuitive that stormwater benchmarks would be lower than
wastewater limits. But each program has their own set of procedures and rules that determine how we permit
industrial facilities. An attempt to reconcile the two programs is a programmatic endeavor that we don't have
the resources to attempt at this point in time.
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. [e-mail]
Website: htto://Dortal.ncdenr.org/web/wa/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Georgoulias, Bethany
Sent: Tuesday, November 22, 20117:49 AM
To: Pickle, Ken; Bennett, Bradley
Subject: RE: Horsehead zinc reclamation plant

If he can tell us a way to do it consistently for everybody, I'm all ears.
Bethany Georgoulias
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
NEW Website: http://portal.ncdenr.org/web/wq/ws/su
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: Pickle, Ken
Sent: Monday, November 21, 2011 1:42 PM
To: Bennett, Bradley; Georgoulias, Bethany
Subject: FW: Horsehead zinc reclamation plant
FYI, No Action, Heads up:
The perspective that if there is no resulting WQS violation, it's ok to discharge pollutants crept into the discussion today
with Forrest.
It sounds like it's tied to his thoughts about the dilution capacity in the Broad River, and the RPA procedure.
We have previously rebuffed this approach in other circumstances.
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. oickle(d)ncdenr.Qov
Website: htto://i)ortal.ncdenr.org/web/wQ/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Pickle, Ken
Sent: Monday, November 21, 2011 11:10 AM
To: '[e-mail]'
Cc: Bennett, Bradley; Georgoulias, Bethany; Chernikov, Sergei
Subject: Horsehead zinc reclamation plant
Hi Forrest, nice to speak with you this morning.

• Just to restate: As we discussed, I am not aware of any instance in which the NPDES industrial stormwater
program identified a design storm approach in our permitting. Our permit has benchmark values that serve to
alert the site manager when pollutants at a level of concern are being discharged. The permit calls on the site
manager to react when he becomes aware of those levels of concern. Our approach might be considered a
performance spec —Just meet the numbers, however you can.'
• As you requested, please see attached below the narrative discussion and the tabulation of the benchmarks
that could appear in any of our stormwater permits.
o The individual permit application will ask what materials have the potential to be present on site.
Typically we will assess the significance of the materials, and will write the individual stormwater permit
to address the risks in accordance with our assessment. Where we conclude that significant risk is
present, we will write that parameter into the individual permit, along with its benchmark. For example,
if Horsehead tells us that zinc and lead are certainly present, and that arsenic will be present in trace
amounts, we will probably include all three in the stormwater monitoring program. If you tell us that
kerosene is present, we may look at including TPH, or maybe the BETX suite. We will certainly include as
a matter of course the conventional pollutant measures TSS and pH. If you tell us that nitric acid or
ammonia or other nitrogenous materials are on site in significant amounts, we will probably include
Total Nitrogen in the monitoring suite. If you tell us that the facility's QA/QC lab uses 2 gallons of
sulfuric acid per year, we don't care (ie, we assess the risk as insignificant), and that limited usage by
itself would not be reflected in the required monitoring.
o A benchmark exceedance is not the same as a permit limit violation. The semantics are relevant here.
Both are numerical measures of performance, but while a limit violation is a permit violation, a
benchmark exceedance is not. It is instead a call to site management to acknowledge the exceedance,
to investigate the cause, to evaluate feasible corrective measures, and to determine whether to
implement such measures.
o Our stormwater permits are structured to allow the permittee several attempts to address benchmark
exceedances before DWQ steps in to help resolve high discharges of stormwater pollutants. This is the
'Tiered' structure that can be observed in several of our General Permits. I've also provided a link below
to our General Permit NCG03 for metal industries so that you can see how it works. Typically the
Tiered structure is like this:
■ If the permittee has no benchmark exceedances: 'Keep up the good work. '
■ One benchmark exceedance: acknowledge, investigate, evaluate, implement response actions if
feasible. 'Try to fix it.' No DWQ involvement.
■ Two consecutive benchmark exceedances for the same parameter at the same outfall: All of the
actions above for one exceedance, plus begin monthly monitoring. 'Try to fix it.' No DWQ
involvement.
■ Three exceedances for the same parameter at the same outfall: As per above: 'Try to fix it.' No
DWQ involvement.
■ Four exceedances for the same parameter at the same outfall during the term of the permit:
Permittee must contact the DWQ Regional Office and request assistance in resolving the
continuing discharge of stormwater pollutants. The DWQ RO may grant relief: or at the other
end of the spectrum may direct the installation of BMPs, as per the broadest view of all the
circumstances and DWQ RO judgment. 'We're here to help you fix it.'
• As we discussed, the NPDES stormwater permitting program is an end -of -pipe program. I'm not aware of any
provision in the federal NPDES stormwater rules for a dilution approach for

industrial stormwater. We do not have the same history or authority as the NPDES wastewater program, as far
as considering the dilution factor into the Broad River, and back -calculating wastewater permit limits based on a
Reasonable Potential Analysis. Please let us know early if you see a need to explore further the Broad River
dilution approach. This idea takes us out of just a routine permitting approach, and calls on us to evaluate
programmatic consistency and impact, as well as equitable treatment of other permittees, as well as consistency
with the federal NPDES stormwater rules and whether we have authority to act based on dilution. If you choose
to pursue it, conclusive discussion of this idea must include those up the chain from. me.
• Here are the two attachments and the link to a General Permit to show you roughly how we would write up a
Tiered structure for Horsehead.
<< File: Individual Permit Benchmarks Final.doc>> << File: Individual Permit Benchmarks Rationale Final.doc
http://portal.ncdenr.org/c/document library/get file?uuid=fde771c4-fe8e-44ad-ab70-323334845d33&groupld=38364
Forrest, I'm here through Wednesday this week, and back in the office on Monday next week if we need to talk, or to
schedule a site plan review together.
Thanks,
Ken
Ken Pickle
Environmental Engineer
NCDENR l DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. oickle(a)ncdenr.aov
Website: htto://i)ortal.ncdenr.org/web/wq/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**

Pickle, Ken
From: Forrest Westall[[e-mail]]
Sent: Thursday, December 08, 2011 7:47 AM
To: Pickle, Ken
Cc: Bennett, Bradley; Chernikov; Sergei; Karoly; Cyndi; Matthews, Matt; Wakild, Chuck; 'Basilone
Tim'; 'Cooper Darin'; jeff.bishop@mcg!!!engineers.com; keith.webb@mcgi!leng!reers.com
Subject: RE: Horsehead Meeting November 29, 2011
Hello Ken,
Thanks for the follow-up and the confirmation on the substation and the distinction about stormwater originating within the
production area. We will be sure to address your comments about the access and perimeter roads in the final site layout
and design.
We appreciate the time you provided last Tuesday to meet with Darin, Tim and me so we could review the site stormwater
considerations for this new facility in Rutherford County. As we noted, the NPDES process waste water permit has been
issued and construction of the facility has commenced. The meeting last week served as a follow-up to our preliminary
discussions in May when Horsehead Corporation was completing the site selection process. We left the May meeting
with a general agreement with DWQ on a conceptual approach for managing stormwater. At that time we also committed
to return to DWQ with a more specific site plan once production layout was completed. At yesterday's meeting we
provided detail as to the site layout and our approach for development of an NPDES stormwater permit application for the
facility.
Your input has been and continues to be very helpful in guiding our development of a permit application. In follow-up to
our recent discussion and in addition to the comments you have already made in your follow-up, I am providing this
summary to highlight important observations and conclusions that were reached. We will now proceed with development
of an application package with the clear direction you provided, confident that the information submitted will be consistent
with our understanding. We believe that this will lead to a quick review.
During the meeting a copy of the production layout design plan was provided for your use. The plan provided highlighted
areas and facility activities. In addition we described our approach for managing stormwater from individual and collective
areas of the facility. We appreciate your comments and agreement with our overall approach for managing stormwater at
the facility. We plan to develop a draft of the application for your review, and then finalize the application based on your
comments for submittal to the Department.
Key points we agreed to during our discussion are as follows
• You advised that all stormwater from within production areas (the area referred to in this correspondence as the
"developed site"), would need to be included under the NPDES stormwater permit and monitored accordingly
• We agreed that stormwater will be managed under an established management plan to meet the requirements of
the permit. The management plan will include provisions for managing stormwater from production areas,
including capability for accumulating and using this water for production processes or discharging it based on
results of sample analyses. Stormwater managed in these areas was referred to during our discussions as being
"discretionary water" for process use or discharge.
• Stormwater will be routed to one point of discharge, which will be the sole discharge monitoring point in the
NPDES stormwater permit. Discharge baselines for various parameters will be established for performance
monitoring
• After discussing the general plan for managing storm water at the site, you advised that the following information
should be included with the NPDES stormwater permit application:
A site plan showing the production layout, stormwater collection and containment areas, and stormwater
channels leading to the discharge point
A map delineating the area(s) of stormwater generation regulated under the NPDES permit
A site stormwater management plan describing details as to how storm water on the site will be managed,
including process and non -process areas. Provisions described in the plan will be included in a
stormwater PPP developed following finalization of the permit and before commencement of facility
operations

As we discussed, permit acquisition is still on the critical path for finalizing construction and commencing operations in a
timely manner. The Department's cooperation, timely review and action on the NPDES permit for process discharge
water was a very important factor in Horsehead's selection of this site. Similarly, we appreciate your commitment to work
with us in providing a timely review of our application, and issuing a NPDES stormwater permit for the facility without
delay.
We plan to provide a draft of our permit application to you for comment. Based on comments from your review, the permit
application will be revised and finalized for submittal to the Department for review. We believe this approach will result in
a complete and accurate permit application, and that following submittal will enable the Department to analyze the
application and issue a permit promptly.
Thanks again. Please let me know if you have any questions
Forrest
Forrest R. Westall, Sr., PE
McGill Associates, P.A.
PO Box 2259
Asheville, NC 28802
Physical Location: 38 Orange Street, Asheville
Phone [phone]
Fax [phone]
forrest.westallkn mcgillengineers.com
From: Pickle, Ken [mailto:[e-mail]]
Sent: Wednesday, November 30, 20119:53 AM
To: [e-mail]
Cc: Bennett, Bradley; Chernikov, Sergei
Subject: Horsehead meeting yesterday
Hi Forrest,
Good meeting yesterday from my perspective. I hope you and your client feel the same. Thanks for taking the trouble
to go over the physical facts with me.
A few things occurred to me that were not addressed, or not completely addressed, yesterday:
As presented yesterday, Horsehead will have a lab on site, and they will be doing their own analyticals for the NPDES
stormwater permit. Please note: for the permit reporting their lab must use the EPA Methods. I assume that for
internal process QA/QC Horsehead might intend to use analytical methods other than EPA Methods. That's OK for their
internal process QA/QC, but it doesn't satisfy the NPDES requirement under federal regulation for the water quality
analyses undertaken in direct response to permit requirements.
• However, there is a provision in the federal rule that will allow us to accept alternative methods. They just need to
come forward and request our approval in advance if methods other than the EPA Methods are contemplated. We will
pass the request on to our inorganic lab folks for review.
• Of course, it goes without saying that an acceptable method must go down to an MDL/PQL that will be below the
benchmarks.
On the issue of lab certification, two aspects are of note here.
• If they will be running analyticals for Sergei's wastewater permitthen the lab must be state certified for the analyses
related to the wastewater permit limit parameters.
However, for NPDES stormwater permit testing, DWQ certification is not required. Stormwater analyticals are a
special case, and are not required to be by certified labs/staff. However, however- -Even if not certified, the lab must

still use the EPA Methods for stormwater analyses, as required by federal rule - - or they must have our approval of
alternative methods.
• Just chatted with Bradley, and we think that the substation east of the railroad is not part of the industrial activity, and
would not have stormwater discharges regulated under the NPDES stormwater program. We had already reached this
tentative conclusion in our meeting, but I had promised to check on it for us. The substation will not be subject to the
stormwater permit.
Just to reiterate the point about the perimeter site roads: Drainage from the site roads is considered stormwater from
industrial activity. Yesterday Horsehead related their intent to capture that runoff. Just to clarify: Roads are typically
designed with a crowned cross-section - - It appears that Horsehead must either design a sloped but un -crowned cross
section draining to the inboard side, or must include runoff capture features on the outboard side of the road to capture
that runoff and direct it back to the inside. It's my impression that an un -crowned road is an unusual feature, and
typically must be the subject of deliberate focus during the site design process.
kbp
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. pickle(&ncdenr.gov
Website: htto://portal.ncdenr.orci/web/wa/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**

Permit NCO089109
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1,
other lawful standards and regulations promulgated and adopted by the North Carolina
Environmental Management Commission, and the Federal Water Pollution Control Act, as
amended,
Horsehead Corporation
is hereby authorized to discharge wastewater from a facility located at
Rutherford County Production Facility
Forest City
Rutherford County
to receiving waters designated as the Broad River in the Broad River Basin in accordance with
effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III and
IV hereof.
This permit shall become effective December 1, 2011.
2 -
This
This permit and authorization to discharge shall expire at midnight on July 31, 2013.
Signed this day November 11, 2011.
Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit NC0089109
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked. As of this permit issuance, any previously issued permit bearing this number is no longer
effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the
permit conditions, requirements, terms, and provisions included herein.
Horsehead Corporation is hereby authorized to:
1. • After constructing the wastewater treatment facility, operate it in accordance
with th existing wastewater treatment system onsisting of the following
components: ?
➢ Automatic sampler Q
➢ Instrumented flow measurement, and
➢ Diffuser
The facility is located near Forest City, Rutherford County; and
2. Discharge from said treatment works at the location specified on the attached
map into the Broad River which is classified C waters in the Broad River Basin.

7TO�nNs2
Ganef
/00
0,7s -
0'09
,7S0,09
0.3G
ow
0.O
Permit NCO089109
A (1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee
is authorized to discharge from outfall(s) serial number 001. Such discharges shall be limited and
monitored by the Permittee as specified below:
960
3
/L
7
Ttt
;Total
L
RMWIEMENTS
Monthly Daily Measurement Sample
Average Maximum FrequencyD) 0.62 Continuous Recording
Sam le
IorE
ended Solids
Monthly
Composite
E
NHrN
Quarterly
Composite
E
Total Aluminum
Quarterly
Composite
E
Antimony
Quarterly
Composite
E
Arsenic
Quarterly
Composite
E
otal Cadmium
350 ug/L
2,143 ug/L
Monthly
Composite
E
Chlorides
Quarterly
Composite
E
Total Chromium
Quarterly
Composite
E
Total Cobalt
Quarterly
Composite
E
7
Total Copper
Quarterly
Composite
E
Fluoride
315.8 mg/L
315.8 mg/L
Monthly
Composite
E
Total Iron
Quarterly
Composite
E
otal Lead
4,386 ug/L
4,829 ug/L
Monthly
Composite
E
Total Nickel
Monthly
Composite
E
Total Tin
Quarterly
Composite
E
Total Zinc
Quarterly
Composite
E
pH2
Weekly
Grab
E
Chronic Toxicity3
Quarterly
Composite
E
Turbidity4
Monthly
Grab
E, U, D
NOTES:
1. Sample Locations: I - Influent, E - Effluent, U - upstream (50 ft. upstream of the
discharge), D - downstream (50 ft. downstream of the discharge).
2. The pH shall not be less than 6.0 standard units or greater than 9.0 standard units.
3. Chronic Toxicity (Ceriodaphnia) P/F @ 0.57%; Jan., April, July and October, See
condition A(2) of the Supplement to Effluent Limitations and Monitoring Section of this
permit.
4 The discharge from this facility shall not cause turbidity in the receiving stream to
exceed 50 NTU. If the instream turbidity exceeds 50 NTU due to natural background
conditions, the discharge cannot cause turbidity to increase in the receiving stream.
THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR FOAM VISIBLE IN OTHER THAN
TRACE AMOUNTS.

Permit NCO089109
SUPPLEMENT TO EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS
A (2). CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QUARTERLY)
The effluent discharge shall at no time exhibit chronic toxicity using test procedures outlined in the "North
Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised November 1995, or subsequent
versions.
The effluent concentration at which there may be no observable inhibition of reproduction or significant
mortality is 0.57% (defined as treatment two in the procedure document). The permit holder shall perform
quarterly monitoring using this procedure to establish compliance with the permit condition. The tests will
be performed during the months of January, April, July and October. Effluent sampling for this testing
shall be performed at the NPDES permitted final effluent discharge below all treatment processes.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form (MR -1) for the month in which it was performed, using the parameter code TGP3B.
Additionally, DWQ Form AT -1 (original) is to be sent to the following address:
Attention: North Carolina Division of Water Quality
Environmental Sciences Section
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Test data shall be complete and accurate and include all supporting chemical/ physical measurements
performed in association with the toxicity tests, as well as all dose/ response data. Total residual chlorine of
the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of the
waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is
required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test
form indicating the facility name, permit number, pipe number, county, and the month/year of the report
with the notation of "No Flow" in the comment area of the form. The report shall be submitted to the
Environmental Sciences Branch at the address cited above.
Should any single quarterly monitoring indicate a failure to meet specified limits, then monthly monitoring
will begin immediately until such time that a single test is passed. Upon passing, this monthly test
requirement will revert to quarterly in the months specified above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, then monthly
monitoring will begin immediately until such time that a single test is passed. Upon passing, this monthly
test requirement will revert to quarterly in the months specified above.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division
of Water Quality indicate potential impacts to the receiving stream, this permit may be re -opened and
modified to include alternate monitoring requirements or limits.

Permit NCO089109
SUPPLEMENT TO EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS (Continued)
If the Permittee monitors any pollutant more frequently then required by this permit, the results of
such monitoring shall be included in the calculation & reporting of the data submitted on the DMR
& all AT Forms submitted.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum
control organism survival, minimum control organism reproduction, and appropriate
environmental controls, shall constitute an invalid test and will require immediate follow-up
testing to be completed no later than the last day of the month following the month of the initial
monitoring.

Pickle, Ken
From:
Pickle, Ken
Sent:
Thursday, March 29, 2012 2:19 PM
To:
'[e-mail]'
Cc:
'[e-mail]'
Subjcct:
FW: Horsehead application
Bill,
Per your request.
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. pickle0ncdenr.gov
Website: http://Dortal.ncdenr.org/web/wo/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Pickle, Ken
Sent: Thursday, March 29, 2012 12:55 PM
To: '[e-mail]'
Cc: Bennett, Bradley; Chernikov, Sergei
Subject: RE: Horsehead application
Hi Forrest,
The Horsehead package was stamped in yesterday. Upon first review this afternoon, I note that there is no permit
application fee.
The fee is $860, payable to NCDENR.
We are aware of our promise to you and to Horsehead to expedite processing of the application. But, we cannot even
enter the application into the tracking system and assign an application number, or otherwise process the application
without the fee. Under most circumstances we send such submittals back to the applicant with a form letter noting the
missing fee.
Please send the check to me ASAP. Overnight would be best if you can manage that. I note that there was some
confusion in delivery address for the package (initially directed to Mike Randall, I believe).
Use this street address for me:
NC Division of Water Quality
Archdale Building
512 North Salisbury Street

Raleigh, North Carolina 27604
Attention: Ken Pickle, Stormwater Permitting Unit
Thanks,
Ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken.oickle(a ncdenr.gov
Website: http://i)ortal.ncdenr.org/web/wa/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Pickle, Ken
Sent: Tuesday, March 27, 2012 11:50 AN
To: '[e-mail]'
Cc: Bennett, Bradley
Subject: RE: Horsehead application
Forrest,
There's one other aspect that might provide some additional light on our need to meet and discuss the application.
We will be issuing a stormwater permit. There is no Authorization to Construct permit for stormwater. So, our review
of the application will not be an engineering review of the details of the pollution control facilities. We will issue the
permit based on the following:
• Is there a Site Plan drawing that identifies the property boundaries, the location of manufacturing activities, the
stormwater conveyances, stormwater BMPs (if any), and the discharge points?
o We need this as just general information — what does the site look like? Can our inspectors make their
way around the site with the Site Plan to provide some perspective of how it all goes together?
o We need this to assure ourselves that the applicant has correctly identified all his stormwater discharge
points.
• Is there some identification of the raw materials, ingredients, additives, by products, waste products, and final
products?
o We need this to know what parameters to put into the permit in order to monitor for the appropriate
potential pollutants.
• Is there a clear delineation between wastewater and stormwater, and is it clear that the two different waters
are effectively segregated from each other by virtue of the physical elements of the manufacturing operations?
o We need this to be sure that the permittee understands that our permit authorizes the discharge of
stormwaters, but not wastewaters.
I hope I haven't mis-led the permittee by my interest in his process, his facility, his operations. I have asked a lot of
questions about those things. Those aspects are not permit application review points. My interest in them is only from
the perspective that all of that surrounding knowledge helps knit together the whole in my mind, and helps me feel that

my part (the stormwater permit) is consistent with all the rest of the site conditions. At this point, I need to drop back to
strictly what are the application review points. My interest in all the surrounding knowledge is at an end. So, I don't
need further explanation of their process, their site, their operations. Hence my uncertainty as to why we need to meet.
(Of course, real world conditions can always present circumstances that don't fit my nice neat compartmentalization.)
ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. pickle* ncdenr.gov
Website: htto://Dortal.ncdenr.org/web/wo/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Pickle, Ken
Sent: Tuesday, March 27, 2012 11:16 AM
To:'[e-mail]'
Cc: Bennett, Bradley
Subject: Horsehead application
Hi Forrest,
I listened to your voice message this morning.
It's good to know that the application is either in the mail, or already here. Thanks for the heads -up. We will
attend to it quickly.
Yes, a meeting shortly after we receive the application might be helpful. I suggest we tentatively schedule it,
and allow DWQ the prerogative of calling it off if we don't see any need to meet. Early the week of April 9 might
be best.
o Do you think we will need to meet? I think we talked through the concepts pretty well. I guess the
details will show how well we communicated with each other on the concepts.
o If you think now that we certainly will need to meet, my question would be, why? Let us know in
advance why so that the meeting can be as productive as possible.
o I mean, unless there is something peculiar, we don't need Horsehead to talk us through their
application. Do we?
We have a couple of complicating issues wrt our time to meet that week.
o We were scheduled to be moving personnel and office furniture all around Archdale the week of April 9-
13. But, as soon as Bradley sent around the move schedule this week, we got news of a delay based on
another agency's constraints. Now we are not sure when we will be moving. It may be that the week
will be totally free from moving activities. It may not.
o Bradley and Dave Goodrich are coordinating the move for multiple units in DWQ. So, Bradley's
availability during that week is uncertain, in part because the actual date of the move is now uncertain.

o I have a limited window that week: a meeting with a non -permittee and his attorney seeking special
concessions on stormwater permitting conditions, and enlisting the assistance of Representative Owens
on Thursday afternoon. And, I'll be out of the office Friday in preparation for leaving on vacation in Italy
for the next two weeks. (Through May 1.)
o Hence my suggestion that we tentatively schedule the meeting early in the week. That may only give us
a little more than a week to do a cursory review of the submittal, but that's typically all that is required
anyway to spot a snag in an application.
Ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. oickle(&ncdenr.aov
Website: http://Dortal.ncdenr.org/web/wa/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**

W
Pickle, Ken
From: Forrest Westall [[e-mail]]
Sent: Monday, April 02, 2012 2:56 PM
To: Pickle, Ken
Cc: Bennett, Bradley
Subjcct: RE: Hcrsehead application
Thanks Ken. I will check with Tim Basilone so we can set a date and time.
Forrest
Forrest R. Westall, Sr., PE
Principal
McGill Associates, P.A.
38 Orange Street I Asheville, INC 28801
Phone: [phone] Fax: [phone]
Email: [e-mail] I Website: www.mcgillengineers.com
From: Pickle, Ken [mailto:ken. [e-mail]]
Sent: Monday, April 02, 2012 2:10 PM
To: [e-mail]
Cc: Bennett, Bradley
Subject: RE: Horsehead application
Hi Forrest,
Yes, after I return might be a pretty good arrangement. Either the first or second week of May?
Ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: [e-mail]
Website: htti)://i)ortal.ncdenr.org/web/wq/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Forrest Westall [mailto:[e-mail]]
Sent: Monday, April 02, 2012 1:23 PM
To: Pickle, Ken
Subject: RE: Horsehead application

Thanks Ken. I left you a voice -mail on Friday about waiting until after your trip. How do you feel about that?
you a call to discuss.
Forrest
Forrest R. Westall, Sr., PE
Principal
McGill Associates, P.A.
38 Orange Street I Asheville, NC 28801
Phone: [phone] Fax: [phone]
Email: forrest.westaIICcDmcgiIleneinee rs.com I Website: www.mcgillengineers.com
From: Pickle, Ken [ma ilto:ken. pickle@)ncdenr.aov]
Sent: Monday, April 02, 2012 12:43 PM
To: forrest.westall(a)mcgillengineers.com
Cc: Bennett, Bradley; bill.sperrv(mcgillengineers.com; Jeff.bishop(a)mcgillengineers.com
Subject: RE: Horsehead application
Hi Forrest,
AN
I will give
The check and three copies of the up-to-date Site Plan were stamped in today. This makes the complete package
submittal date today, April 2, 2012.
Ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ l Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. [e-mail]
Website: http://Portal.ncdenr.org/web/wa/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Forrest Westall [mailto:forrest.westall(almcgillengineers.coml
Sent: Thursday, March 29, 2012 9:01 PM
To: Pickle, Ken
Cc: Bennett, Bradley; bill.spgrrv(o)mcgillengineers.com; Jeff.bishop(abmcgillengineers.com
Subject: RE: Horsehead application
Hi Ken,
I was out of the office today. I got your voice mail after 5 today and checked with our folks and found out we had
addressed the fee issue. I apologize for the oversight on the check. We will provide the correct site drawing or make sure
our reference to attachments is correct. I will touch base with our folks tomorrow to make sure.
I will be back in touch on setting up a meeting.
Thanks,

IR
Forrest
Forrest R. Westall, Sr., PE
Principal
McGill Associates, P.A.
38 Orange Street I Asheville, NC 28801
Phone: [phone] Fax: [phone]
Email: [e-mail] I Website: www.mcgillengineers.com
From: Pickle, Ken[ma ilto:ken. oickle(cbncdenr.gov]
Sent: Thursday, March 29, 2012 2:58 PM
To: bill.soerry(a)mcgillengineers.com
Cc: [e-mail]; Bennett, Bradley
Subject: RE: Horsehead application
Bill, Forrest,
I also note in just a quick check of the enclosures listed both in Mr. Basilone's transmittal letter and in the list of
Attachments that the reference is to revision D of the site drawing. Unfortunately, the drawing in my 3 packages is
revision C. Please include the most up to date site plan along with the check.
Thanks,
Ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I, Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. [e-mail]
Website: htto://Portal.ncdenr.org/web/wa/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Pickle, Ken
Sent: Thursday, March 29, 2012 2:19 PM
To: '[e-mail]'
Cc: '[e-mail]'
Subject: FW: Horsehead application
Bill,
Per your request.
Ken Pickle

ff
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken.pickleCo ncdenr.aov
Website: hht�://portal.ncdenr.org/web/wq/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Pickle, Ken
Sent: Thursday, March 29, 2012 12:55 PM
To: '[e-mail]'
Cc: Bennett, Bradley; Chernikov, Sergei
Subject: RE: Horsehead application
Hi Forrest,
The Horsehead package was stamped in yesterday. Upon first review this afternoon, I note that there is no permit
application fee.
The fee is $860, payable to NCDENR.
We are aware of our promise to you and to Horsehead to expedite processing of the application. But, we cannot even
enter the application into the tracking system and assign an application number, or otherwise process the application
without the fee. Under most circumstances we send such submittals back to the applicant with a form letter noting the
missing fee.
Please send the check to me ASAP. Overnight would be best if you can manage that. I note that there was some
confusion in delivery address for the package (initially directed to Mike Randall, I believe).
Use this street address for me:
NC Division of Water Quality
Archdale Building
512 North Salisbury Street
Raleigh, North Carolina 27604
Attention: Ken Pickle, Stormwater Permitting Unit
Thanks,
Ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604

Pickle, Fen
From: Pickle, Ken
Sent: Thursday, April 05, 2012 12:26 PM
To:'[e-mail]'; [e-mail]
Cc: Bennett, Bradley
��IJ�GYt. Horsehead review.- in progress
Hi guys,
Here's my quick, first review of just the site plan, rev.D. I have these few questions on the various areas indicated on the
drawing.
Controlled Release of Clean Sw areas:
• Area 100/300: Looks like the rectangular detention pond will have a valved discharge internal to the pond. Or is
there some other configuration planned?
• Area 200 Detention Pond: You have listed this as a controlled release area, but it's not clear on the drawing
that there are physical provisions to convey any fluid in this area to the storm sewer. Please let me know how
you will do that.
• Area 600: Looks like the rectangular detention pond will have a valved discharge internal to the pond. Or is
there some other configuration planned?
• Transformer containment: It's not clear that there is a catch basin nearby in the storm sewer system. Do you
intend to just open a valve and let the accumulated stormwater run 75' east across the paved area? Is there
intended to be a piped connection? Is there a valved configuration of any sort?
• Acid containment: Is there a valved configuration of any sort? Do you intend to pipe this to the catch basin
immediately to the north? Or do you intend to release the contained stormwater to the paved surface?
• Electrolyte tank containment: Looks like you intend to release to the catch basin immediately to the south of
the tank containment. Right? Piping and valved configuration?
Areas not released to 60" storm sewer:
• Gypsum containment: This area is listed as not discharging, but yet I see a catch basin on the 60" storm sewer
within the gypsum containment area. What's up with that?
• Area 400, EW Process Building roof: This runoff is listed as being totally recycled back to the process. How will
that be physically accomplished? Why? So, the roof runoff is not conveyed to the surface via downspouts?
Areas with uncontrolled release to 60" stormwater:
• Areas 500, 900, 1000, 1100, Lab, Boiler Room, Compressor Room: No comments. Included in this list just for
completeness.
Other:
• 1 see two areas labeled Area 700 Reagents. Is this an error, or are there really two Areas 700? Is there an Area
800?
• As I recall our discussions, the large open area on the north east corner of the site will be unused under current
start-up plans. Horsehead should be sure that any subsequent utilization of this area is checked against
potential stormwater impacts, and compliance with the terms of the eventual stormwater permit.
• Would you remind me how the stormwater runoff from the industrial activity labeled 'WOX and Lime
Unloading' will be handled? I can't remember if we discussed this, and I can't tell from the drawing.
Thanks,

Ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: [e-mail]
Website: http://portal.ncdenr.ora/web/wo/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**

Pickle, Ken
From: Pickle, Ken
Sent: Tuesday, May 08, 2012 1:02 PM
To: Bennett, Bradley
Subject: Horsehead permit application
Bradley,
FYI, No Action:
Met at length this morning with Forrest and Tim Basilone, the head horse for Horsehead.
They wanted to:
• Respond to my email add -info from April 5 (complete submittal received April 2);
• Submit a new Site Plan;
• Explain a slightly revised concept for containment at the site and provide sufficient description of it for my
comfort;
• Answer any questions I may have.
I promised to produce a draft permit within 60 days of the application. I don't see any problem with this, since I have a
good site plan and a pretty good general understanding of their manufacturing activities already in hand.
I explained the next steps were for me to pick the monitoring parameters, and then to go over the individual permit
template and boilerplate in order to be sure all the conditions fit the circumstances at this site.
Ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. pickle2ncdenr.gov
Website: http://portal.ncdenr.org/web/wq/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**

Pickle, Ken
From: Pickle, Ken
Sent: Thursday, May 17, 2012 12:16 PM
To: '[e-mail]'
Cc: 'Basilone Tim'; Bennett, Bradley; Georgoulias, Bethany
Subject: RE: SW Template
Attachments: Individual Perm it—Tern plate_FINAL_1Mar2012.docx
Hi Forrest,
Here's the template we're using now. Some background on how I will convert this template into Horsehead's permit:
We start with the template and then Parts I and II are subsequently crafted/edited to be site specific, and to
address DWQ's assessment of the nature and degree of the pollutant risk on the.site. The anticipation of
crafting this part of the permit is what fuels our seemingly unrelated questions about processes, operations, and
site conditions - - we want a comprehensive picture of what happens on a site so that we can assess the risk of
the potential of pollutant releases via stormwater discharges.
Parts III and IV are the boilerplate provisions which we edit less frequently since the conditions contained
therein are generally considered to be applicable for all of our stormwater permittees, regardless of site-specific
conditions.
® Note that the file is dated March 2012: this template evolves over time as our experience grows implementing
it. It is updated irregularly as we feel the need, usually based on our crisper understanding of exactly what
federal rule requires of the agency (us) and the permittee, and how we might more effectively protect the water
quality of North Carolina.
Although our work on an individual permit is based on the template, we typically review every sentence in the
document to be sure there are no internal inconsistencies. Out of respect for the continuing reuse of the
boilerplate in other permits, we may leave in boilerplate provisions that don't apply for the site conditions of a
particular permittee, as long as they're not contradictory to other portions of the text.
I'm scheduled to complete my first, internal, draft tomorrow. I'll contact you with any questions, but realistically, I don't
expect to have any. I should have a courtesy early -review copy early next week. If you have comments on that version,
I'll consider/incorporate/reject them and then start the 'Staff Report' step with the Regional Office. The RO will review
the pre -draft version and comment on it. I'll then publish the official 'Draft' permit and send it to you for any other
comments.
Ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. pickle0ncdenr.gov
Website: http://portal.ncdenr.orrc/web/wq/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**

From: Forrest Westall [ma iIto: forrest.westaIkslmcgiIlen gineers.com]
Sent: Wednesday, May 16, 2012 10:37 PM
To: Pickle, Ken
Cc: 'Basilone Tim'
Subject: SW Template
Hi Ken,
At our most recent meeting we discussed the SW permit template you planned to use for drafting the Horsehead permit.
You indicated you would share that with us. Could you please shoot me and Tim Basilone a copy of that for our review?
Thanks for your help.
Also, could you update us on the status of the drafting effort? I know you've had a lot to catch up on since returning from
your trip, but just wanted to make sure that if there are any issues we need to address that we can get back to you
quickly.
I appreciate it
Forrest
Forrest R. Westall, Sr., PE
Principal
McGill Associates, P.A.
38 Orange Street I Asheville, NC 28801
Phone: [phone] Fax: [phone]
Email: [e-mail] I Website: www.mcgillengineers.com

Pickle, Ken
From: Pickle, Ken
Sent: Tuesday, June 05, 2012 3:23 PM
To: Ratcliffe, Judith
Cc: Gadd, Laura. Georgoulias, Bethany, Bennett, Bradley
Subject: RE: Broad River, Rutherford County
Judy,
Thanks for the help, I really appreciate it.
Our stormwater permitting program typically would want to know about aquatic T&E species maybe 20 — 30 times per
year. Would you be the best entry point into NHP information? How would we do that most conveniently for you all?
Ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service.Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. Dickle(@ncdenr.gov
Website: htti) 7 8portal.ncdenr.org/web/`­wa/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Ratcliffe, Judith
Sent: Tuesday, June 05, 2012 3:14 PM
To: Pickle, Ken
Cc: Gadd, Laura
Subject: Broad River, Rutherford County
Hi Ken,
I checked our records for aquatic species in the Broad River, Rutherford County, vicinity of the project and there are no
records for any rare aquatic species.
The site of the project itself appears to overlie one of our Programs Significant Natural Heritage Areas, Brice Rare Plant
Site. This site provides habitat for a Federal Threatened plant, Dwarf -flowered heartleaf (Hexastylis naniflora). The
applicant may already be aware of this as our Program provided comments on this project in October 2011. If they
have not already done so, they may wish to consult directly with Mara Alexander with the US Fish and Wildlife Service
(828-258-3939 x238) and/or Rob Evans with the NC Plant Conservation Program (919-218-5774).
I've cc: Laura Gadd, our Program Botanist, as she is responsible for our rare plant records. Please let me know if I can be
of further assistance...
Judy
Judith Ratcliffe
Freshwater Ecologist, Eastern Region

NC Natural Heritage Program
919-707-8628
[e-mail]
www.ncnhp.org
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
From: Pickle, Ken
Sent: Tuesday, June 05, 2012 8:48 AM
To: Ratcliffe, Judith
Subject: FW: Sent via Google Maps: ken. pickle(a)ncdenr.gov sent you: A Maps link
Hi Judy, thanks for your note yesterday.
Did you get the Google Map email? Was the link active?
If not, here's another attempt with a site location:
In Rutherford County,
%2 mile north of the NC -SC state line,
%- %2 mile west of US 221,
South bank of the Broad River,
Tucked into the curl of the railroad line running NE and then NW,
I'm interested in whether there are any T&E aquatic species from this point downstream some nominal distance; and
whether that might impact the conditions that I write into my permit for this site.
Thanks,
Ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. pickle(a)ncdenr.aov
Website: http://portal.ncdenr.org/web/wq/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: noreply(&google.com [mailto:noreplly0)goog1e.com]
Sent: Tuesday, June 05, 2012 8:39 AM
To: Ratcliffe, Judith
Subject: Sent via Google Maps: ken. pickle(a ncdenr.gov sent you: A Maps link
This email was sent to you by a user on Google Maps:

s y
Hi Judy, thanks for your help. OK, here is Google Map's email capability. I hope this works for us. The
site is the cleared area centered in the photo, and on the south bank of the Broad River in Rutherford
County. One-half mile north of the NC -SC state line; one-quarter mile west of US 221. Two powerline
ROWs run east -west in the vicinity, with the southern ROW cutting through the site. The site is
located in the curl of the railroad where it turns from a northeast direction to a northwest direction. I've
never used this from Google Maps so I'll follow up with another email to see if you received this one.
Thanks again for your help! Ken
Hi, I'd like to share a Google Maps link with you. Link: <http://maps.google.com/maps?hl=en&ie=UTF8&11=35.192784,-
81.850805&spn=0.025216, 0.038409&t=h&z=15&vpsrc=6>
3

Pickle, Ken
Froin: Basilone Tim [[e-mail]]
Sent: Wednesday, July 25, 2012 2:07 PM
To: Pickle, Ken
Cc: [e-mail]
Subject: RE: Draft permit, staff report
Ok Ken, plan on this meeting. I'll get an agenda to you beforehand and other information that applies
Thanks.
Tim
Timothy R. Basilone
Vice President - Environmental Affairs
Horsehead Corporation
4955 Steubenville Pike
Suite 405
Pittsburgh, PA 15205
P 724.773.2223
F 412.788.4526
C 412.287.9871
TBasilone(o-)Horsehead.net
From: Pickle, Ken [mailto:[e-mail]]
Sent: Wednesday, July 25, 2012 1:29 PM
To: Basilone Tim
Cc: [e-mail]; Wilson, Susan A; Bennett, Bradley
Subject: RE: Draft permit, staff report
Hi Tim,
That's good for me, and Asheville confirms they will participate via conference call.
Thanks & see you then. Anything you can send in advance will help us have a productive meeting.
Ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. pickle(abncdenr.gov
Website: http://portal.ncdenr.org/web/wg/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Basilone Tim [mailto:[e-mail]]
Sent: Wednesday, July 25, 2012 1:00 PM
To: Pickle, Ken

Cc: [e-mail]
Subject: RE: Draft permit, staff report
Ken,
How does Monday the 6th work for you to meet at your offices? I'll plan on coming in on the morning flight from Pittsburgh
scheduled to arrive at 10:30 AM. The flight in the afternoon is at 3:21 PM:* Could we plan to meet at around 11:30 AM
and reserve two hours for the meeting? I know this is lunch time, but thought maybe we could grab a sandwich and work
through. I'll need to depart around 1:30 PM to catch my flight back to Pittsburgh.
Please advise if this works for you.
Thanks.
Tim
Timothy R. Basilone
Vice President - Environmental Affairs
Horsehead Corporation
4955 Steubenville Pike
Suite 405
Pittsburgh, PA 15205
P 724.773.2223
F 412.788.4526
C 412.287.9871
TBasilone a(,,Horsehead.net
From: Pickle, Ken[mailto:ken.pickle(a)ncdenr.gov]
Sent: Monday, July 23, 2012 8:00 AM
To: Basilone Tim
Subject: RE: Draft permit, staff report
Hi Tim,
Both of those are good for me.
Ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. pickle(cbncdenr.00v
Website: http://Oortal.ncdenr.org/web/wq/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Basilone Tim[mailto:tbasilone(nbhorsehead.net]
Sent: Saturday, July 21, 2012 5:51 PM
To: Pickle, Ken
Subject: RE: Draft permit, staff report
Ken,
It's looking like August 6 or August 8. Are both of these dates available for you to meet in Raleigh? Please advise.
Tim

Timothy R. Basilone
Vice President - Environmental Affairs
Horsehead Corporation
4955 Steubenville Pike
Suite 405
Pittsburgh, PA 15205
P 724.773.2223
F 412.788.4526
C 412.287.9871
TBasiloneCcOHorsehead. net
From: Pickle, Ken [mailto:ken.pickleUncdenr.gov]
Sent: Thursday, July 19, 2012 1:42 PM
To: Forrest Westall; Basilone Tim
Cc: Wilson, Susan A; Bennett, Bradley
Subject: FW: Draft permit, staff report
Hi Tim, Hi Forrest,
I received commen from the Asheville Regional Office on the proposed draft permit for Horsehead. Please see p.
4 of 4, attache
Spe A recommendations:
• uire SPPP to be develo ed before start u .Note this is already required in the boilerplate (Part III Section A
). Oops, my oversight: during the discussion with ARO, I forgot that the draft permit already requires that the
SPPP be in place bn day one. AR comment emphasizes the importance that we attach to implementing the
f SPPP at this site. I'm not inclined to withhold the permit issuance for the completion of the SPPP, however.
O� SPPP to address potential failure modes with a back-up plan identifying management actions in response to
atypical operating conditions. I like it. One path for us would be to revise the draft permit text to require some
form of ARO rior revie and approval of the SPPP. Let's discuss.
• Add chlorides to the monitoring suite. Reasonable, I like it. Draft permit to be revised to include chlorides.
• Add quarterly acute tox testing. Reasonable given that heavy metals are of concern, I like it. Draft permit to be
revised to include tox testing.
• Provide a 'step-down' in analytical testing from quarterly to 2/yr after 3 years, conditional on results. I like it.
Draft permit to be revised to include step-down provisions, conditional on results. After three years, ARO and
Central Office to jointly evaluate results in response to a petition from the permittee for reduced monitoring.
Gentlemen, we talked about a meeting in Raleigh to go over your comments on the draft permit, and on ARO
comments. ARO will participate in the discussion, either by conference call, or in person. I know you're anxious to
expedite our process, so let's have the meeting ASAP. Whatever you can supply as far as any pre -meeting outline of
the topics and supporting ideas would help us prepare for an effective meeting.
Over the next month, I'm available the remainder of July, except for July 26. I'm also available up through August 16,
but not Friday, August 17 —Thursday, August 23. If you will suggest a couple of dates, we can see about ARO
participation.
Thanks,
Ken
Ken Pickle

Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. pickle(a>ncdenr.gov
Website: http://portal.ncdenr.org/web/waZws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Wilson, Susan A
Sent: Wednesday, July 18, 2012 11:58 AM
To: Pickle, Ken
Subject: RE: Draft permit, staff report
Ken — here's the signed staff report/ARO comments. Thanks!
Susan A. Wilson - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Surface Water Protection
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and
therefore may be disclosed to third parties.
From: Pickle, Ken
Sent: Wednesday, July 18, 2012 11:51 AM
To: Wilson, Susan A
Subject: RE: Draft permit, staff report
Ok, will let you know.
kbp
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. pickle(o)ncdenr.gov
Website: http://portal.ncdenr.ora/web/wg/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**

From: Wilson, Susan A
Sent: Tuesday, July 17, 2012 1:18 PM
To: Pickle, Ken
Cc: Cranford, Chuck
Subject: FW: Draft permit, staff report
Ken — I have to sit in on the supervisors meeting.for Chuck on Aug. 1 . let me know when you plan this meeting — I think
we'd like to be included (if not in person then via cont. call).
Susan A. Wilson - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Surface Water Protection
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and
therefore may be disclosed to third parties.
From: Pickle, Ken
Sent: Friday, July 13, 2012 12:52 PM
To: Basilone Tim
Cc: Forrest Westall; Bennett, Bradley; Wilson, Susan A
Subject: RE: Draft permit, staff report
Hi Tim,
I spoke with the Asheville Regional Office this morning and received a verbal review of their issues/comments. They
have some good observations, and have promised written comments NLT next Wednesday.
Maybe we can schedule a meeting around August 1, one way or the other?
Best Regards,
Ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken [e-mail]
Website: http•//Portal ncdenr ora/web/wP/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Pickle, Ken
Sent: Tuesday, July 10, 2012 12:49 PM

To: 'Basilone Tim'
Cc: Forrest Westall; Bennett, Bradley
Subject: RE: Draft permit, staff report
Hi Tim,
Thanks for noting the issues. We'll be glad to meet with you on these items. I'll let you know ASAP after I have
comments in hand from the Regional Office.
See below my attempt to pare back the items that I don't think we have any disagreement on. My comments in red.
I:{a'i1
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken.oickle(a)ncdenr.aov
Website: http://i)ortal.ncdenr.org/web/`w(i/`ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Basilone Tim rmailto:tbasiloneCobhorsehead.net]
Sent: Monday, July 09, 2012 4:13 PM
To: Pickle, Ken
Cc: Forrest Westall
Subject: RE: Draft permit, staff report ` 11
j7Pi(i
Ken, /JAJ
After you receive comments from the re ;buld like to meet with you to discuss our comments. At this point you
sh be advised of the following:
1 The facility will not process a 'waaw material that is a product "zinc oxide". My mistake. Not
significant to my evaluation o catio"Ct 11 change the Fact Sheet accordingly.
2. We need a more complete understanding of the `rise evaluation and the basis for benchmark levels. Let's talk.
It is not kerosene that is the carrier hydrocarbon but a product that has less aromatics than kerosene. We'll get
the specific name for you. Probably not an issue for me whether it is kerosene, or kerosene -like. Is it a
petroleum hydrocarbon? Probably not significant in the resulting elements of the permit text. I'll adjust
ice^ the Fact Sheet accordingly.
4. Benchmark values — we need to discuss these because of specific disc a characteristics for the site. Let's
talk. U dq
5. It appears as though the amount of monitoring in addition to the tiered levels is overly restrictive. Let's talk.
6. Described internal monitoring for water in secondary containment features is inconsistent with our prior
discussions. OK, let's no over this again. O
We'd like to meet with you in Raleigh after you receive other comments. Thanks for the opportunity to review the draft
permit at this early stage.
Tim
Timothy R. Basilone
Vice President - Environmental Affairs
Horsehead Corporation

M
4955 Steubenville Pike
Suite 405
Pittsburgh, PA 15205
P 724.773.2223
F 412.788.4526
C 412.287.9871
TBasilone(o.Horsehead.net
From: Pickle, Ken [mailto:ken.pickleCstncdenr.gov]
Sent: Friday, June 29, 2012 3:06 PM
To: Basilone Tim; forrest.westall(Omcgillengineers.com
Subject: Draft permit, staff report
Hi Tim, Hi Forrest,
Here is the draft permit, and our staff report, which is an abbreviated rationale document in support of the permit
conditions. The staff report makes a condensed record of how we view the site and the application, and serves as the
key communication tool between the initial application reviewers (me) and our Regional Office staff. Our standard step
now is to solicit comments from the Regional Office. I've asked for comments back from the Asheville Regional Office by
mid-July.
By transmittal of this advance courtesy copy, I'm also soliciting your comments on the draft permit.
Sorry for the delay beyond my most recent promise date: COB Friday, instead of COB Thursday.
Best Regards,
Ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. pickle(a)ncdenr.gov
Website: http•//portal ncdenr org/web/wci/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**

�Bii�riP�J �Py
TIMOTHY R. BASILONE
' /,o/j6 2 o/ z
Vice President - Environmental Affairs
i
4SS STEUBENVILLE PIKE WWW.HORSEHEIIO.NET 724.773.2223NET
! f J
SV9ITE 405 TBASILONE@HORSEHEAO.412J88.4526
PITTSBURGH. PA 15205 CORPORATION
Leading the World in Zinc Recycling
September 19, 2012
Mr. Ken Pickle, Environmental Engineer
North Carolina Department of Environment and Natural Resources
r Division of Water Quality
Stormwater Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: Draft Industrial Stormwater NPDES Permit
Horsehead Corporation Zinc Production Facility Li
Rutherford County, North Carolina
LCiJn ..-bV/v7E11 QlirZ'i'Y
Dear Mr. Pickle:
Thank you for the opportunity to comment on the Draft Industrial Stormwater NPDES
Permit (Draft Permit) you provided on June 29, 2012" Furthermore, thank you for your
continuing effort in working with us to develop this permit, and providing time for
meetings and telephone conferences to discuss our permit application and the subject
permit:'Our comments on the Draft Permit, the Staff Review and Evaluation Form (Staff
Review Form), and the Regional Office comments are provided below.—These comments
summarize our discussions, and are responsive to your requests from the conference call
with you and the Regional Office on September 14, 2012, and comments provided earlier
in e-mails to you.'
The overriding storm water management concept is to capture and control the disposition
of all storm water falling into the operating area' This system is to prevent the
uncontrolled discharge of potential pollutants to the discharge stream. , The physical
facility is being designed to support this concept, and operating procedures will be
developed to ensure management controls are documented and implemented. ,The first
oand as a second preference, only as
preference isl!0 use the water in the operatinecessary, —01 ect the water to the site storm water discharg�
The facility is designed tc�_capture and contain all storm water
]Lhat falls within the
operating area of the site. This design will contain rainwat r falling in this area during
the 100 vear 24 hour storm event. Water captured in the area will be managed in one of
three ways, as follows:
■ If part of an individual (isolated) basin, water will be placed directly into thea ✓
process or a tank within that production area,
rig
f

ORouted to the process water management system, or used to partially displace.1
process water (finished water j2rovided by the Town) used by the operation,
Oampa and analyzed before discharge to the storm water outfall system.
® Storm water falling in areas outside the operating area and from rooftops, parking areal
and landscaped areas will be discharged directly to the storm water outfall during the J
storm event.
Details of this system are being developed and will be incorporated as part of the site
operating procedures, and the Storm Water Pollution Prevention Plan (SWPPP). A map
and table describing this system will be provided once the system design is completed. —
Comments on the Draft Permit, Staff Review Form and the Regional Office Comments
are addressed below.
Comments on the Staff Review Form
GY Page 1 Type of Activity and Page 2 Description of Activity
Atso�se The reference to receiving waste is incorrect. The facility will receive zinc oxide
/O as raw material for the process which is a product manufactured at other
Re fa,f 64.14 Horsehead facilities. Zinc oxide feed material contains some lead and cadmium,
in addition to zinc. "the reference to silver should be eliminated, since it is a very
minor component of zinc oxide.
OPage 1, Special Permitting Issues, Risk Considerations, Location
The assigned rating 6 is excessive for risk due to the site location. Since this is a
raf� A 572 n �s new facility, the existing impairment mentioned in this section is a pre-existing
a s is condition located downstream and cannot be attributed to the new facility. Based
,4e,j "tee : a wits. on the actual conditions, the rating should be in the low range of the risk scale.
7.4 "'aw net int +rte
/ /\ Pa rta 1 Snarial PnrmitFinrt Teenne Rielr ('nnciriaratinne (lthnr Fartnrc
Ke oe The assigned rating 10 is excessive for risk considering other factors. This is a
/vJode.a d/�/'k1 new facility that is specifically designed, as described above, to prohibit
stormwater contamination. To the contrary of the statement "proper operator
p actions to a larger than normal degree" and other factors mentioned, during our
discussions you indicated design of the stormwater management systems for this
plant are exceptional. The design includes a stormwater management system
whereby discharge of storm water from the operating area is not possible without
specific action based on management authorization to release the water. If the
agency's risk determination is to be used as a basis for permit decisions, the true
risk of stormwater pollution from the site needs to be described. Our design
presents less than normal risks for most industrial sites. Based on the actual
conditions, the rating should be in the low range of the risk scale.
2

DD 0 Page 3, General Observations
4 Seo n k: It would be appropriate to mention the level of stormwater control, and design of
,44rr & the facility to manage stormwater, which reduces and possibly eliminates risk of
stormwater pollution from the operation.
0 Page 3, Permit Recommendations
Item 1 Analytical Monitoring —
[Although we agree with quarterly sampling, and note that this is more frequent
monitoring than most standard industrial stormwater permits, we do not agree
with the reasons cited for proposing the frequency. The risk factors are actually
ess than most industrial sites based on the design of the facility to prohibit
y�}. stormwater pollution, and the potential for discharge of entrained contaminants
AdJu� I�„�u 0 from the operation. The facility should be a candidate for "no exposure” status
based on the design for stormwater control. Quarterly sampling is appropriate
within the context of an evaluation monitoring period; however, we believe that
once a baseline is established and the plant begins operating the monitoring will
demonstrate the effectiveness of the stormwater controls.
Item 3, Analytical Monitoring Parameters —
V Fa— The description provided should be eliminated and replaced with the
following statement - Zinc, lead and cadmium are the most appropriate metals
for monitoring purposes since these are the most abundant of the metals in the
operation's feedstock. If there is an impact from process materials on
stormwater these metals are the most likely to be detected.
y� b. Organicslease eliminate the reference to kerosene or kerosene -like
petroleum product. More appropriately, please reference the hydrocarbon
material used in the process as "hydrocarbon solution". The hydrocarbon
solution is a key process ingredient. Monitoring for it & Grease is
appropriate.
N� c. Conventional Pollutants: TSS and pH are appropriate; IN and TP seem
No reason
excessive with respect to the operation. Please eliminate these parameters.
Item 4, Benchmarks —
We discussed benchmarks and their use during our last teleconference on
Q September 14, 2012. The use of benchmarks is not appropriate for this new
facility, which is designed to prohibit stormwater pollution from the operation.
A� Instead, we propose quarterly monitoring with samples collected at the
stormwater outfall to the Broad River and analyzed for parameters as mentioned

Comments on the Draft Permit
/ Part II, Pave 2 of 11, (bl Secondary Containment Requirements and Records
The later portion of this section should be eliminated beginning on the seventh
-line and following the words "areas shall be maintained." You have indicated
during prior meetings, calls and communications that the permit will not require
anything on internal monitoring, but will rely entirely on discharge point
monitoring for regulatory purposes. Specific conditions provided on internal
monitoring for captured water are inconsistent with these prior discussions.
Part II Page 5 of 11, Section B: Analytical Monitoring Requirements
Please see the above sections in the Staff Evaluation discussing the Analytical
Monitoring Requirements.
Benchmarks and their use in the permit should be eliminated, including the tiered
approach for monitoring. Instead, Horsehead is proposing a "Monitor Only"
status for the facility for two years (eight quarters) following startup. Monitoring
will be conducted at the discharge point to the Broad River and include collection
and analysis of samples for Zinc, Lead, Cadmium, Oil & Grease, TSS, and pH:
Monitoring results over this period of time will be used to evaluate the
effectiveness of the facility design and stormwater management scheme, which is
Cl
in the section above. We propose the permit be written to require "monitoring
only" for the first two years of the operation.
Information obtained for the first eight quarters of operation should be recorded
a
and summarized in a report to support a recommendation for either a stormwater
r
permit containing benchmark levels established based on potential impact to the
fr a eT
Jwj,
Broad River, or a "no exposure" application and site status. The report would be
�f dfi S
submitted to the agency following the two year period of evaluation for review by
DWQ. Based on this report the permit can be revised accordingly, or eliminated
if the "no exposure" scenario is justified.
The report would provide the raw data, an evaluation of the potential impact to
the receiving waters based on the monitoring data and the conditions of the Broad
River at the time of sampling, a recommendation on the need for benchmarks at
this site, if appropriate a recommendation for the benchmark parameters and
levels, and an evaluation of the site for "no exposure" status. If the "no exposure"
scenario applies, an application for this status will be provided with the report.
Since this is a new plant with no prior history available, and the design of the
plant is such that stormwater is contained and controlled in areas of the operation,
we believe the proposed approach allows for information to be gathered after the
plant begins operating that will serve as a basis for developing a permit for the
operation or justifying a "no exposure" scenario.
Comments on the Draft Permit
/ Part II, Pave 2 of 11, (bl Secondary Containment Requirements and Records
The later portion of this section should be eliminated beginning on the seventh
-line and following the words "areas shall be maintained." You have indicated
during prior meetings, calls and communications that the permit will not require
anything on internal monitoring, but will rely entirely on discharge point
monitoring for regulatory purposes. Specific conditions provided on internal
monitoring for captured water are inconsistent with these prior discussions.
Part II Page 5 of 11, Section B: Analytical Monitoring Requirements
Please see the above sections in the Staff Evaluation discussing the Analytical
Monitoring Requirements.
Benchmarks and their use in the permit should be eliminated, including the tiered
approach for monitoring. Instead, Horsehead is proposing a "Monitor Only"
status for the facility for two years (eight quarters) following startup. Monitoring
will be conducted at the discharge point to the Broad River and include collection
and analysis of samples for Zinc, Lead, Cadmium, Oil & Grease, TSS, and pH:
Monitoring results over this period of time will be used to evaluate the
effectiveness of the facility design and stormwater management scheme, which is
Cl

based on a strategy to prohibit stormwater discharge containing contaminants
from the operation.
As noted, the monitoring results obtained over the eight quarters will be
summarized in a report for submittal to the DWQ, and in support of a revised
stormwater permit with benchmark levels established based on potential impact to
receiving waters, or a "no exposure" status.
Part II Page 10 of 11 Section D• On-site Vehicle Maintenance Monitoring Requirements
Please eliminate this section; there is no vehicle maintenance facility or activity
that will be conducted on site.
Comments on the Regional Office Comments
Require SWPPP to be developed for startup —
An SWPPP will be developed for the site prior to startup of the facility.
Address failure modes with a back -0 Plan identifying management actions in response
to atypical operating conditions —
The SWPPP to be developed prior to plant startup will address this matter.
Add chlorides to the samplingscheme heme —
Based on the proposed approach for stormwater management and the sampling
scheme and parameters described above, this monitoring will provide sufficient
data to assess stormwater from the facility site. Monitoring for chlorides will add
Ino additional benefits and is not justified.
Add quarterly acute toxicity testing to the sampling scheme —
The level of stormwater management on this site is extensive and well beyond
anything required under any other permit for facilities in North Carolina. Aquatic
Whole Effluent Testing is not a standard industrial stormwater requirement.
Application to a site with control systems as described above is not reasonable.
The inclusion of toxicity testing is unsupportable and inappropriate.
Provide a "step-down" in analytical testing from quarterly to 2/yr after 3 years
conditional on results —
In consideration of the proposed approach to monitoring, this should be evaluated
based on results from the quarterly sampling over two years, along with the
evaluation of a "no exposure" status for the site.

wza
DISCHARGE TO BROAD RIVER=�
�uh
Uo<i
D S7'REgM ��a�
Nom ON-SITE STORMWATER SYSTEM s ¢�
COLLECTION MANHOLE z<
CSX RAILROAD
w
m
SEDIMENT/
STORMWATER - ®/';b+ i �G� w
BASIN WETLANDS ♦,-, �� i 0 z w m
1�_
00-
< w
U
UNNAMED STREAM / p J
Lkl " , 9 w m
-� HORSEHEAD CORPORATION SITE /� IiII 0 I— o
o w J UTILITY CORRIDOR WITH �,� i I 0-
Q
54" STORMWATER PIPEIIIo 0 o
2,720 L.F. �'' 00
QH o
Z o
�� D SIRE it
�r r� w U w
�o04
o = ul) 1;ws�
FIGURE
1

Pickle, Ken
From: Pickle, Ken
Sent: Tuesday, October 16, 2012 12:16 PM
To: 'Basilone Tim'
Cc: [e-mail]; Wilson, Susan A; Fox, Tim; Bennett, Bradley;
Georgoulias, Bethany
Subject: RE: status update
Hi Tim,
I apologize for the delay. I've reviewed your September 19 letter, and I think we are in agreement on most of your
points. There are some other points that I think should remain as per the Staff Review Sheet and the draft permit.
Going down your list of comments, here's where I am now with the comments in your 9/19/2012 letter.
A. Staff Review comments
1. Agree to revise reference to waste material as the source of the zinc. You report that your raw material
has not been classified as a waste material.
2. No change to my assessment of the Location Risk as deserving a rating of 6. In my mind this rating is an
intuitive assessment of the sensitivity and fragility of the receiving water, not so much a rating of the
facility. On the basis of the characteristics noted in the Staff Review, this rating stands.
3. Agree to revise downward the Other Factors Risk rating to acknowledge that extraordinary control
measures are planned for this site.
4. Agree to revise the General Observations note on page 3 to acknowledge the level of stormwaters
control designed into the facility.
5. Agree to revise the language referencing "increased risk factors noted above". No change to quarterly
monitoring recommendation, however.
6. Agree to revise the monitoring metals to include Cd instead of Ag, based on your report that Cd would
be more likely present than Ag.
7. Agree to replace the reference to kerosene with "hydrocarbon solution" based on your report that
'kerosene' is not used, and that hydrocarbon solution is a more accurate description.
8. No change to the inclusion of nitrogen and phosphorus monitoring. The materials are present in the
manufacturing process. We can re -visit this once the sampling results begin to accumulate.
9. Agree to revise the rationale for monitoring, and to disconnect the trigger between the monitoring and
the Tiered structure for the first two years of sampling. Since this is an individual stormwater permit, NC
procedures allow us to modify the sampling program during the term of the permit, without having to
again go through the full permit issuance procedures. This provision is an administrative time saver for
us, and it provides our permittees a quicker way to react to data accumulated during the term of the
permit. While we agree that the monitoring without the Tiers approach has benefits in a start-up
scenario for a totally new industry in North Carolina, we are not at this time agreeing with the forward
looking statements in your letter as to No Exposure, or adjusting benchmarks. We will look to the data,
and to the site circumstances in two years for guidance on a protective approach with respect to those
aspects.
10. Agree of course to follow through with these Staff Review changes as they relate to the provisions of the
permit.
B. Draft permit comments
�1 Agree to revise secondary containment requirements in Part II B 2 (b). However, I believe the physical
arrangement at each containment area should still contain manually activated valves or other locking
mechanisms for the discharge to the stormwater system. Contact me to discuss if I misunderstand
something about the physical arrangement in the numerous containment areas.
2. Agree to revise monitoring requirements per the related discussion above for the Staff Review.

3. Agree to remove the vehicle maintenance section based on your report that this activity will not take
place on site.
C. Comments on Regional Office input
1. Acknowledge that an SPPP will be prepared in advance of site operations.
2. Acknowledge that the SPPP will contain failure mode evaluations.
3. No change to the RO suggestion to monitor for chlorides. This is a reasonable parameter to suspect at
the site, and two years of data may be useful in assessing its presence in stormwater discharges. To be
included in the permit.
4. Agree not to include a requirement for toxicity testing on the basis of the proposed containment system
for heavy metal solutions, and on the intuitive assessment of dilution effects from the Broad River.
Consideration of the usefulness of toxicity testing may be revisited after discharge data is accumulated.
S. Agree to include a step-down provision from quarterly monitoring. Note that every step-down provision
comes with a companion step-up provision that would re -institute quarterly monitoring.
D. Additional revisions to the permit
1. We will be writing the permit for an effective period of less than the maximum allowable period of 5
years. We agree that a two-year study with quarterly data, and summary interpretations of the data by
both Horsehead and DWQ will be a good way to move the permittee into permit conditions especially
relevant to the risks at the site. So we see it happening like this: two years of data; and an initial permit
duration of three years; and a revised, re -issued 5 -yr permit to follow based on the results and the
interpretation of the data.
E. Additional information requests
1. The large basin down by the Broad River, is it concrete lined? Is it earthen? Will containment be
achieved by compacted earth liner construction? If earthen liner, what's the compaction spec?
2. We are still unclear on how Horsehead will determine whether to release water from the process
containment areas, or whether not to discharge it but to put it back into the process, one way or
another. Is there a threshold concentration of zinc that identifies a material as salvageable? Is there a
pH? What exactly are the criteria for allowing release of the contained materials into the stormwater
discharge?
Our schedule: I'm out of the office now for a week, but I can put the permit out for public notice the first week in
November.
Best Regards,
Ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604

Phone: [phone]
Fax: [phone]
Email: ken.pickle(cbncdenr.gov
Website: http://portal.ncdenr.orci/web/wq/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Basilone Tim [mailto:[e-mail]]
Sent: Monday, October 01, 2012 11:22 AM
To: Pickle, Ken
Cc: [e-mail]
Subject: status update
Ken,
Hope all is well. Please advise me as to where things stand with our Stormwater Permit. It's been nearly two weeks
since we provided comments to you, this after discussing these with you by telephone. Please advise when you would
like to meet to finalize the draft, as I indicated I will come to Raleigh to work with you on this. Please advise me as to your
schedule for getting the permit issued.
Thanks.
Tim
Timothy R. Basilone
Vice President - Environmental Affairs
Horsehead Corporation
4955 Steubenville Pike
Suite 405
Pittsburgh, PA 15205
P 724.773.2223
F 412.788.4526
C 412.287.9871
TBasilone(a)Horsehead. net

Pickle, Ken
From: Pickle, Ken
Sent: Friday, November 02, 2012 4:06 PM
To: Wilson, Susan A; Fox, Tim
Subject: FW: Answers to Permit questions
Importance: High
FYI,
Horsehead
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. [e-mail]
Website: http://portal.ncdenr.org/web/wq/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Basilone Tim[mailto:tbasiloneCaohorsehead.net]
Sent: Friday, November 02, 2012 4:00 PM
To: Pickle, Ken
Cc: [e-mail]; Staley Anthony
Subject: Answers to Permit questions
Importance: High
Ken,
Per our conversation yesterday, I am providing the following information in response to questions raised in your e-mail
concerning the subject draft stormwater permit:
Answer to EA. The stormwater basin adjacent to the river is being provided primarily for energy dissipation. Its
inclusion in the Stormwater discharge system is not required and is being provided to assure that all of the energy of the
discharged water is effectively transferred into the Broad River with no impact to the River Bank or the River Bottom.
The basin is constructed of compacted earth and isn't lined. A "fore -bay" area at the outlet of the site stormwater pipe
includes a large concrete dissipation structure and a transition area for flow to move into the main part of the basin.
Answer to E.Z. Stormwater from the containment areas will be monitored for relevant analytical parameters including
those to be monitored at the outfall and as listed in the NPDES stormwater permit. Procedures for managing the subject
water will be described in the SWPPP, and will include BMP's for minimizing contaminant levels from entering water
that is captured in containment. This plan will be completed prior to startup of the facility, and will include thresholds as
to whether the water will be placed into process or released to stormwater. Be advised that our line of thinking at this
point is that the rule is to place all water back to process, and the exception is to release the water to the stormwater
outfall provided analytical results warrant such.
Please advise me if you need any additional information. I look forward to receiving the draft permit from you
sometime next week.

Thanks Ken, have a nice weekend.
Tim
Timothy R. Basilone
Vice President - Environmental Affairs
Horsehead Corporation
4955 Steubenville Pike
Suite 405
Pittsburgh, PA 15205
P 724.773.2223
F 412.788.4526
C 412.287.9871
TBasilone(cDHorsehead.net

.Pickle, Ken
From:
Pickle, Ken
Sent:
Friday, November 09, 2012 11:43 AM
To:
'Basilone Tim'
Cc:
[e-mail]; Bennett, Bradley; Wilson, Susan A; Fox, Tim
Subject:
in -progress draft permit and staff report
Hi Tim,
Here are the two documents we have been working on together. My next step is to send.these out to public notice in a
local newspaper and the NC register, and to EPA Region IV. I'll be working on the public notice next week. Not a big
task.
I have made the changes indicated in our last correspondence with a couple of exceptions. Overall there are three
things I want to especially call your attention to, -and solicit your comments.
See Part II page 9 of 11 for the new permit provision that allows de -coupling the sampling results from the
benchmark values and Tiered response actions for two years. I've written this up for eight data points
minimum plus Horsehead's summary report, presumably proposing revisions to the monitoring activities under
the permit conditions. Because this is an individual permit (not one of our General Permits), we have the
authority to revise the elements of any monitoring requirements without the additional administrative
procedures and delay involved in a complete permit re -issuance.
2. In my last note to you, I reported that we would be writing the permit for a shorter than usual duration, three
years instead of five years. As I got down to actually making the changes in other parts of the permit that were
time -dependent, it just seemed to me that the shorter duration was not necessary. So, I'm intending to go with
the standard 5 -year duration on the permit. Two aspects of the permit were on my mind, plus an administrative
consideration:
o As far as my administrative consideration, we're all looking for ways to stretch ourselves to fit the
amount of work in our unit. That's not going to change in the foreseeable future. I'd rather the
Stormwater Permitting Unit address the renewal of this permit in five years, rather than three years.
o We agreed to a step-down, step-up provision in the sampling frequency that would allow semi-annual
sampling rather than quarterly sampling. I base the step-down provision on eight consecutive results
below benchmarks. Well, the provision hardly makes any sense if we stick with a 3 -yr term for the
permit. (This may be moot, since the next item below speaks to the summary report that we will act on
in year 3.)
o You suggested a two year data gathering ("monitor -only") period without benchmarks and Tiers, and
DWQ agreed. So, we are already in agreement to review the monitoring provisions during the third year
and make the changes to the permit that seem prudent. It's easier administratively (no public notice,
for one example) for us to make the monitoring changes than it is to go through a permit renewal
process. Presently I don't see the need to go through a re -issuance with the extra administrative
requirements and comparatively longer time frame, when North Carolina rules allow us to make
monitoring changes essentially unilaterally.
3. 1 have revised the secondary containment language to be consistent with the standard language in all other
North Carolina stormwater permits. Please take a look at that in Part 11 Section A.

H
H
in -progress
FINAL revised
-lorsehead draft N..
Horsehead_Staff ...
Ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. pickle(ci)ncdenr.00v
Website: http://i)ortal.ncdenr.org/web/wq/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**

Pickle, Ken
From:
Basilone Tim [[e-mail]]
Sent:
Monday, November 12, 2012 1:03 PM
To:
Pickle, Ken
Cc:
[e-mail]; Staley Anthony; Harris James
Subject:
Comments on the latest draft permit
Importance: High
Thank you for the opportunity to comment on the draft permit. I appreciate your evaluation and response to our
prior comments on the former draft which were submitted to you and discussed in meetings with you.
Your comments in your e-mail regarding the permit duration are fine, I have no specific comment on this item
or any comments on other matters in your e-mail concerning alteration of the sampling frequency (step down or
step up), and the administrative aspects associated with permit modifications, with the exception of comments
provided below to the degree they relate to these matters.
Our comments:
1. Please use the following description of the facility on the first page of the permit:
Horsehead Metal Products, Inc.
484 Hicks Grove Rd.
Mooresboro, NC 28114
2. The facility will not commence operations until September 2013 or possibly later. This being the case,
please adjust the effective date of monitoring under this permit to the date which the operation of the
facility commences, adjust the language on Page 9 to reflect the eight quarters of monitoring will begin
after startup, and adjust the schedule on Page 6 to reflect the same.
Please consider delaying the application of the Tiered response actions until after completion of the
evaluation period following the submittal of the summary report to the NCDENR. I believe this has
merit because as part of the summary report a proposed alternative monitoring scheme, if applicable,
will be provided — as described in the current language on page 9. This alternative monitoring scheme
will be based on the eight quarters of monitoring results that have been acquired, and may include but
not necessarily be limited to, any or all of the following:
■ a recommendation for alternate benchmark levels based on characterization of stream impacts on
receiving waters,
a recommendation for a No Exposure Exclusion
alteration of the required sampling frequency
alteration of the tiered activities required if a benchmark limit is exceeded
4. In light of our comment in #3 above, we recommend that the NCDENR consider holding off on the
establishment or application of any benchmarks until the monitoring and evaluation period is over, the
report has been submitted for evaluation by NCDENR, and the permit is modified accordingly at that
point in time. Using this approach the monitoring period would be used to establish benchmarks for use
in a permit.
The basis for this comment is consistent with our discussions and prior comments submitted to the
NCDENR, benchmark levels are not related to stream impact or environmental impairment in this

particular case, but are more so arbitrarily assigned. This being the case using benchmark levels such as
0.001 mg/L or 1 ug/L for cadmium, and 0.030 mg/L or 30 ug/L lead, 0.067 mg/L or 67 ug/L zinc, and
860 mg/L chlorides it is well within the realm of possibilities that metal and other concentrations at
levels exceeding the benchmark originate from indigenous / natural sources and not the operating
facility.
In other words the benchmark levels are below levels that may exist under natural conditions. If this is
the case, the tiered levels of activities, which are required, would likely prove to be fruitless in
attempting to understand a cause at the facility, and consequently this would likely result in a waste of
valuable resources in the attempt to mitigate the cause (to below benchmark levels). As discussed with
you earlier, we believe benchmark levels if used, should be established with an appropriate buffer based
on the potential for environmental harm to the receiving stream, and not set at arbitrary low levels that
cannot be explained with respect to their relationship to any potential environmental impairment.
Please advise me if you would to discuss this further. I can meet with you in your office or by telephone to
discuss potential alternative approaches to resolve these matters. Ken, you've done a lot of good work here, and
we appreciate that. We look forward to working with you and remain committed to get this permit completed in
the most reasonable manner and as quickly as possible.
Tim
Timothy R. Basilone
Vice President - Environmental Affairs
Horsehead Corporation
4955 Steubenville Pike
Suite 405
Pittsburgh, PA 15205
P 724.773.2223
F 412.788.4526
C 412.287.9871
TBasilone(cbHorsehead. net

Pickle, Ken
From:
Forrest Westall [[e-mail]]
Sent:
Tuesday, November 13, 2012 9:30 AM
To:
Pickle, Ken
Cc:
'Basilone Tim'
Subject:
RE: in -progress draft permit and staff report
Thanks Ken. I hope you are having a good week,
Forrest
Forrest R. Westall, Sr., PE
Principal
McGill Associates, P.A.
38 Orange Street I Asheville, NC 28801
Phone: [phone] Fax: [phone]
Email: [e-mail]]Website: www.mcgillengineers.com
From: Pickle, Ken [mailto:[e-mail]]
Sent: Tuesday, November 13, 2012 8:28 AM
To: [e-mail]
Cc: Basilone Tim
Subject: RE: in -progress draft permit and staff report
Thanks, Forrest, you are correct, my mistake.
We don't have to provide notice to EPA, nor do we send them a review copy of the permit in advance of finalization of
it. We do send them a paper copy when the permit is issued.
Ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: [e-mail]
Website: http://Dortal.ncdenr.org/web/wci/­ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Forrest Westall [mai Ito:forrest.westallCalmcgillengineers.com]
Sent: Monday, November 12, 2012 7:13 AM
To: Pickle, Ken
Cc: Basilone Tim
Subject: RE: in -progress draft permit and staff report

Thanks Ken. I am in contact with Tim and we are working on some comments. One issue that I noted in reading your e-
mail is EPA review. We had not discussed this previously. Due to the NPDES Process WW permit, the facility is classified
as a minor facility and a review by EPA of the process WW permit was not required. My understanding is that because
the facility is classified as a minor, EPA review isn't required. Please clarify.
Tim will be in touch concerning any comments we may have on the draft package.
Take care,
Forrest
Forrest R. Westall, Sr., PE
Principal
McGill Associates, P.A.
38 Orange Street I Asheville, NC 28801
Phone: [phone] Fax: [phone]
Email: forrest.westall(@mcgilleneineers.com I Website: www.mcgillengineers.com
From: Pickle, Ken [mailto:ken. pickle(d)ncdenr.gov]
Sent: Friday, November 09, 2012 11:44 AM
To: Basilone Tim
Cc: forrest.westall(a)mcgillengineers.com; Bennett, Bradley; Wilson, Susan A; Fox, Tim
Subject: in -progress draft permit and staff report
Hi Tim,
Here are the two documents we have been working on together. My next step is to send these out to public notice in a
local newspaper and the NC register, and to EPA Region IV. I'll be working on the public notice next week. Not a big
task.
I have made the changes indicated in our last correspondence with a couple of exceptions. Overall there are three
things I want to especially call your attention to, and solicit your comments.
1. See Part II page 9 of 11 for the new permit provision that allows de -coupling the sampling results from the benchmark
values and Tiered response actions for two years. I've written this up for eight data points minimum plus Horsehead's
summary report, presumably proposing revisions to the monitoring activities under the permit conditions. Because this
is an individual permit (not one of our General Permits), we have the authority to revise the elements of any monitoring
requirements without the additional administrative procedures and delay involved in a complete permit re -issuance.
In my last note to you, I reported that we would be writing the permit for a shorter than usual duration, three years
instead of five years. As I got down to actually making the changes in other parts of the permit that were time -
dependent, it just seemed to me that the shorter duration was not necessary. 50, I'm intending to go with the standard
5 -year duration on the permit. Two aspects of the permit were on my mind, plus an administrative consideration:
As far as my administrative consideration, we're all looking for ways to stretch ourselves to fit the amount of work in our
unit. That's not going to change in the foreseeable future. I'd rather the•Stormwater Permitting Unit address the
renewal of this permit in five years, rather than three years.
We agreed to a step-down, step-up provision in the sampling frequency that would allow semi-annual sampling rather
than quarterly sampling. I base the step-down provision on eight consecutive results below benchmarks. Well, the

Pickle, Ken
From: Pickle, Ken
Sent: Monday, December 17, 2012 10:09 AM
To: '[e-mail]'
Subject: RE: Horsehead
Thanks Forrest. I appreciate you filling in the blanks a little more for me. The possibility of a public hearing and its
impact on Tim's necessary start-up is something that does retract some of the 'easing' I felt. We'd best be moving
ahead,lsee.
Ken Pickle
Environmental Engineer `
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. DickleCsbncdenr.gov
Website: htto://Dor-tal.ncdenr.org/web/wo/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Forrest Westall [mailto:[e-mail]]
Sent: Monday, December 17, 2012 10:02 AM
To: Pickle, Ken
Subject: RE: Horsehead
Hi Ken,
Thanks for the prompt response. No revision to the expected start-up. The original date was around May. The revision
to later in the year is still good as far as I know. I think that the timetable shift may "ease" some of the pressure, but Tim
is very interested in having all permits in place well before start-up. He periodically gets concerned about the progress
on the SW permit and he could decide that we waited long enough. I didn't realize that you had shifted priorities on the
basis of the revision in the start-up date and I know Tim didn't as well. I also realize that since we applied in a timely
fashion and even if a problem came up with permit issuance by start-up we could work out something in relation to
getting the plant running, but that would not be a good situation for the company. I also don't want to worry too much,
but we could get a request for a hearing. We didn't on the process discharge, but you never know. That means if the
unexpected happens and a hearing was granted, we could be looking at an additional 30 days to schedule the hearing
(min.) and then the hearing and any "open record" time following as well as the Statutory max timeline of 90 days (of
course it doesn't have to be that long) for a report and then 15 days for a Director decision. If you have a draft (we
requested a final review before notice), mid -Jan. and go to notice in Feb., the period would be over March. Adding in
the other "worst case" timeline above we could be waiting until August or
Sept. for a final permit. I don't think this would happen, but it pays to be early instead of late.
Just my thoughts.
I hope you can get a draft permit out for our review soon.
Forrest

•a
Forrest R. Westall, Sr., PE
Principal
McGill Associates, P.A.
38 Orange Street I Asheville, NC 28801
Phone: [phone] Fax: [phone]
Email: [e-mail] I Website: www.mcgillengineers.com
From: Pickle, Ken[mailto:ken. pickle(-Oncdenr.gov]
Sent: Monday, December 17, 2012 9:39 AM
To: forrest.westall(cbmcgillengineers.com
Cc: Bennett, Bradley
Subject: RE: Horsehead
Thanks, Forrest for the communication and the information.
I'll move back to the permit this week, and I'll respond to Tim and you. Approximately a month ago Tim had relayed to
me that the facility start-up was delayed until September 2013, and so I turned my attention to other obligations. It
appears that I misunderstood his information as a relaxing of the urgency/necessary timing of my remaining tasks. I'll
work this week on getting the revised draft permit out to public notice in the first week in January.
Forrest: Are you now reporting that Tim's estimate of a September 2013 start-up is no longer the best guess of start-up?
Ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. pickleC�ncdenr.gov
Website: http://i)ortal.ncdenr.org/web/wci/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Forrest Westall [ma iIto: forrest.westaIIamcgiIlengineers.com]
Sent: Monday, December 17, 2012 8:37 AM
To: Pickle, Ken
Subject: Horsehead
Hi Ken,
I hope you are well.
I know Tim Basilone has sent you notes about the draft status. He continues to bug me about permit status. This note is
just to you. Tim is going to get more militant about the draft permit. The facility is well under construction and though
they won't make the spring for start-up they are under an AQ order for the Penn plant and will have to bring up the new
facility as quick as they can. He is going to be under increasing pressure from the CEO and the Plant Manager about
regulatory status.

If I can be of any assistance, please let me know. If you can at least shoot Tim a note on status that would at least let
him know where you are.
Thanks,
Forrest
Forrest R. Westall, Sr., PE
Principal
McGill Associates, P.A.
38 Orange Street I Asheville, NC 28801
Phone: [phone] Fax: [phone]
Email: [e-mail] I Website: www.mcgillengineers.com

Pickle, Ken
From: Pickle, Ken
Sent: Tuesday, December 18, 2012 11:44 AM
To: 'Basilone Tim'
Cc: [e-mail]'; Bennett, Bradley; Wilson, Susan A; Fox, Tim
Subject: RE: follow up
Hello Tim,
I apologize for the delay in responding to your previous attempts to contact me. I've been in and out of the office some,
and I've been focused on other tasks some, since we last spoke a month ago. I had moved Horsehead to second priority
while I tended to some other obligations, and based on our conversation that the realistic plant start-up would be in
September.
To answer your question, I see no remaining problems in the permit text; and am still intending to proceed as we
discussed in our last couple of exchanges.
I'll move back to Horsehead as the highest priority tomorrow, and I will have the final draft this week incorporating the
items we agreed to on our last contact. I'll send that to you as soon as it's done, this week.
I'll get the public notice into the required local paper in the first week in January. As mandated by North Carolina rule,
we have a mandatory 30 -day public notice period, followed by a mandated 15 -day waiting period (45 days total).
• Assuming no substantive public comment, there should be only minor, if any, changes to the permit text based
on the public comment. I think we have been over the permit text to such a degree that I don't expect to
incorporate any public comments, but anything is possible in that arena. Under this scenario, with public
notice in the first week in January, I would anticipate final issuance of the permit by the end of February.
• If there is sufficient substantive public comment, the Director may determine that a public hearing is required.
so, our time frame would be extended by 2 -3 months. I have no reason to anticipate that degree of public
interest, and I think a public hearing is unlikely to be required by the Director. Have you had any indication of
public interest in the facility?
• Both scenarios appear to be well within the projected start-up date of September.
Again, my apologies for failing to return your earlier contacts. You will have the final draft permit version for review by
the end of the week.
Best Regards,
Ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. oickle(ancdenr.aov
Website: i)://i)ortal.ncdenr.org/web/wa/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**

From: Basilone Tim[mailto:tbasiloneOlhorsehead.net]
Sent: Tuesday, December 18, 2012 10:54 AM
To: Pickle, Ken
Subject: follow up
Ken,
I left you a voice mail and sent an e-mail last week. I'm getting pressure regarding the status of the stormwater permit,
and have no answers other than you are going to issue the permit. I told this to my management last month. I expected
to have the permit done and out for public review by now. Please advise if there are any problems with our comments
and we need to discuss anything. I advised you a while back that I'd come to Raleigh to do this if necessary.
Please provide a status update and a schedule for getting this permit issued. Thanks.
Merry Christmas to you and yours, wishing you all the best,
Tim
Timothy R. Basilone
Vice President - Environmental Affairs
Horsehead Corporation
4955 Steubenville Pike
Suite 405
Pittsburgh, PA 15205
P 724.773.2223
F 412.788.4526
C 412.287.9871
TBasilone(d_)Horsehead.net

Pickle, Ken
From: Basilone Tim [[e-mail]]
Sent: Monday, January 14, 2013 1:56 PM
To: Pickle, Ken
Cc: [e-mail]
Subject: RE: Comments on Draft Stormwater Permit
Importance: High
Ken,
COrr Ps1on-412!8
Below I am providing comments on the latest Draft Permit and Staff Review Form. These same comments
were made earlier, so nothing new — you've seen these, and we discussed some of them in prior meetings. We
believe several of these comments merit specific attention; however we do not want to see the permit process
stalled at this point in time. We anticipate the permit will be issued in draft for public comment, since our
comments, provided below, were submitted 'once before and were not addressed in the latest draft.
As before, please call me to discuss these comments, or if you'd like I am willing to come to Raleigh to meet
with you. I look forward to hearing from you by the end of this week.
Thank you for this opportunity to comment on the permit,
Tim
Staff Review Form Page 3, Permit Recommendations, Item 1 Analytical Monitoring —
Although we agree with quarterly sampling, and note that this is more frequent monitoring than most standard
industrial stormwater permits, we do not agree with the reasons cited for proposing the frequency. The risk
factors are actually less than most industrial sites based on the design of the facility to prohibit stormwater
pollution, and the potential for discharge of entrained contaminants from the operation. The facility should be a
candidate for "no exposure" status based on the design for stormwater control. Quarterly sampling is
appropriate within the context of an evaluation monitoring period; however, we believe that once a baseline is
established and the plant begins operating the monitoring will demonstrate the effectiveness of the stormwater
controls.
Staff Review Form Page 3, Permit Recommendations, Item 3, Analytical Monitoring Parameters —
a. Metals: The description provided should be eliminated and replaced with the following:
Zinc, lead and cadmium are the most appropriate metals for monitoring purposes since
these are the most abundant of the metals in the operation's feedstock. If there is an
impact from process materials on stormwater, these metals are the most likely to be
detected.
b. Conventional Pollutants: TN and TP are excessive with respect to the operation. Please eliminate
these parameters.
Staff Review Form Page 2, Description of Activity:
I suggest replacing the information provided in this section with the following:

Horsehead receives zinc oxide material, and refines it into high purity zinc metal. Byproducts
include solid materials containing zinc, lead and cadmium, and very minor amounts of silver.
Staff Review and Evaluation: Permit Recommendations: Analytical Monitoring. #4, and Page 9 of the Draft
Permit.
Please delay the application of the Tiered response actions until after completion of the evaluation period
following the submittal of the summary report to the NCDENR. I believe this has merit because as part of the
summary report a proposed alternative monitoring scheme, if applicable, will be provided — as described in the
current language on page 9 of the draft permit. This alternative monitoring scheme will be based on the eight
quarters of monitoring results that have been acquired, and may include but not necessarily be limited to, any or
all of the following:
■ a recommendation for alternate benchmark levels based on characterization of stream impacts on
receiving waters,
■ a recommendation for a No Exposure Exclusion
■ alteration of the required sampling frequency
■ alteration of the tiered activities required if a benchmark limit is exceeded
In light of information provided above, we recommend that the NCDENR hold off on the establishment or
application of any benchmarks until the monitoring and evaluation period is over, the report has been submitted
for evaluation by NCDENR, and the permit is modified accordingly at that point in time. Using this approach
the monitoring period would be used to establish benchmarks for use in a permit.
The basis for this comment is consistent with our discussions and prior comments submitted to the NCDENR,
benchmark levels are not related to stream impact or environmental impairment in this particular case, but are
more so arbitrarily assigned. This being the case using benchmark levels such as 0.001 mg/L or 1 ug/L for
cadmium, and 0.030 mg/L or 30 ug/L lead, 0.067 mg/L or 67 ug/L zinc, and 860 mg/L chlorides it is well
within the realm of possibilities that metal and other concentrations at levels exceeding the benchmark originate
from indigenous / natural sources and not the operating facility.
In other words the benchmark levels are below levels that may exist under natural conditions. If this is the case,
the tiered levels of activities, which are required, would likely prove to be fruitless in attempting to understand a
cause at the facility, and consequently this would likely result in a waste of valuable resources in the attempt to
mitigate the cause (to below benchmark levels). As discussed with you earlier, we believe benchmark levels if
used, should be established with an appropriate buffer based on the potential for environmental harm to the
receiving stream, and not set at arbitrary low levels that cannot be explained with respect to their relationship to
any potential environmental impairment.
General comment on Benchmarks —
We discussed benchmarks and their use during our last teleconference on September 14, 2012. The use of
benchmarks is not appropriate for this new facility, which is designed to prohibit stormwater pollution from the
operation. Instead, we propose quarterly monitoring with samples collected at the stormwater outfall to the
Broad River and analyzed for parameters as mentioned in the section above. We propose the permit be written
to require "monitoring only" for the first two years of the operation.
Information obtained for the first eight quarters of operation should be recorded and summarized in a report to
support a recommendation for either a stormwater permit containing benchmark levels established based on
potential impact to the Broad River, or a "no exposure" application and site status. The report would be

1.
submitted to the agency following the two year period of evaluation for review by DWQ. Based on this report
the permit can be revised accordingly, or eliminated if the "no exposure" scenario is justified. The tiered
system, if necessary, should be entered after the permit is revised accordingly, and recommendations in the
report are addressed.
The report would provide the raw data, an evaluation of the potential impact to the receiving waters based on
the monitoring data and the conditions of the Broad River at the time of sampling, a recommendation on the
need for benchmarks at this site, if appropriate a recommendation for the benchmark parameters and levels, and
an evaluation of the site for "no exposure" status. If the "no exposure" scenario applies, an application for this
status will be provided with the report. Since this is a new plant with no prior history available, and the design
of the plant is such that stormwater is contained and controlled in areas of the operation, we believe the
proposed approach allows for information to be gathered after the plant begins operating that will serve as a
basis for developing a permit for the operation or justifying a "no exposure" scenario.
Chlorides Analysis —
Monitoring for chlorides is not justified based on potential for this material to be present in stormwater for
reasons not associated with the plant operations. This should not be a monitored parameter.
Provide a "step-down" in analytical testing from quarterly to 2/yr after 3 years, conditional on results —
In consideration of the proposed approach to monitoring, this should be evaluated based on results from the
quarterly sampling over two years, along with the evaluation of a "no exposure" status for the site.
Timothy R. Basilone
Vice President - Environmental Affairs
Horsehead Corporation
4955 Steubenville Pike
Suite 405
Pittsburgh, PA 15205
P 724.773.2223'
F 412.788.4526
C 412.287.9871
TBasilone(cDHorsehead. net
From: Pickle, Ken [mailto:ken. [e-mail]]
Sent: Tuesday, January 08, 2013 1:58 PM
To: Basilone Tim
Cc: [e-mail]; Bennett, Bradley; Wilson, Susan A; Fox, Tim
Subject: Stormwater Permit documents: Jan 2013 revised Staff Review
Hi Tim,
OK, attached below is the Staff Review in what I imagine is the final form.
The attached Staff Review is little changed from the one that preceded it in November. That previous version
incorporated the changes enumerated in my October 16, 2012 email. The more significant aspects of the previous
version was that it eliminated the references to 'waste material' and 'kerosene', revised the monitoring parameters,
revised the numerical risk rating, provided a rationale for two years of sampling without benchmarks triggering the
Tiered response actions, and provided that DWQ would consider a monitoring results report from Horsehead after the
two years of data are collected.

What has changed in this Staff Review is:
• Revised the name of the facility to, 'Horsehead Metal Products, Inc.' as per your instructions on the draft permit
• Revised the address of the facility to the Hicks Grove Road address, per your instructions on the draft permit
• Corrected the letterhead to show our new Governor and Secretary of NCDENR
• Noted the revision date
At this point, I think the Staff Review and the proposed Draft permit are parallel, with no inconsistencies between them.
So, you have both documents now that would be required for us to go to public notice. I'll move forward with these
documents toward the Wednesday, January 16 development of the public notice. Please let me know if you have
further comments on either document.
Best regards,
Ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617 _
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. picklegtncdenr.4ov
Website: http://portal.ncdenr.ora/web/wq/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
4

Pickle, Ken
From: Palmer, Lisa M
Sent: Wednesday, January 30, 2013 12:29 PM
To: Pickle, Ken
Subject: FW: Public Notice for Stormwater Ashville Citizen -Times 1-30-2013
This ad will run on 1-31 in the Ashville Citizen times cost is 117.50 1 will forward the one from the other newspaper
when I get it.
Wa.M. PaUner
NCDENR/DWQ/Point Source Branch
1617 Mail Service Center
Raleigh, NC 27699-1617
[phone]
From: Casiano, Summer[mailto:scsmithCcbashevill.gannett.com]
Sent: Wednesday, January 30, 2013 12:21 PM
To: Palmer, Lisa M
Subject: RE: Public Notice for Stormwater Ashville Citizen -Times 1-30-2013
$117.50

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RALEIGH, NORTH GAROI
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_orsehead• Metal Prod -I
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acility will discharge)
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n the Broad River Ba-
in. j
-qpies of the draft per,'
it, Na. NCS000562 are]
2 vaiIable--df t 6Tolfow
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u a r y 1 2013:
ttp:j portal; ncdenr.or'
j�ti�e {wq%vrssu[pubT
_ DSZtJ 00-5. 1
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rby contacting: '
en Pickle
G Division of Water)
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517 Mail Service GenJ.
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aleigh, NG 27699-1517 1
3 elephone Number::
9197 30 7-63 76
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e n .FU Llfl e ms' CtD_dq 0 C.¢RL ;
arsons wishing to!
omment u�pan or obi
ect to D3h+Q� - p ro p os edl
etermFriation t0 issue
he requested permitl
re invited to submit;
heir comments in writl
ng to the above ad,
rens no later than'
March 5, 2013. All comb
ants received priorto:
4 -:hat date will be con -1
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ermination regardin,gg)
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Summer Casiano
Legal Advertising Coordinator
ASI EN IL E
edX 1 oup ,4 G.W.L. COID4 V
office 828-232-59251 fax [phone]
14 O.Henry Avenue I PO Box 2090 1 Asheville, NC 28801
(c-)AshevilleB2B i AVLne.ws
»Click here to sign up for Marketing Minute, our monthly e -newsletter featuring news and insights to help you prow your business!
Think Green! Please Consider Before Printing This Email. Ask me how you can sign up for E -Invoicing!
From: Palmer, Lisa M[mailto:Lisa. Palmer(abncdenr.aov]
Sent: Wednesday, January 30, 2013 10:40 AM
To: Asheville-Legals
Subject: Public Notice for Stormwater Ashville Citizen -Times 1-30-2013
Please publish the HIGHLIGHTED, public notice as a line advertisement in the Legal Section of your
paper ONE TIME as soon as possible. Please verify receipt of this email, and send proof/cost/day
AD will run before printing.
Feel free to contact me with any questions, Thanks!
PUBLIC -NOTICE
STATE OF NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
RALEIGH, .,NORTH. CAROLINA 27699-1617
Horsehead Metal Products, Inc., Mooresboro, NC has applied for an NPDES Stormwater Permit to discharge
stormwater associated with industrial activities from a facility located at 484 Hicks Grove Road, Mooresboro, NC,
Rutherford County. The facility will discharge to waters designated as the Broad River within the Broad River Basin.
Copies of the draft permit, No. NCS000562, are available at the following website as of February 1, 2013:
http://iportal.ncdenr.orci/web/wq/ws/­su/­6ublic-notices
Or by contacting:
Ken Pickle
NC Division of Water Quality
1617 Mail Service Center.
Raleigh, NC 27699-161.7,
Telephone Number: (91.9) 807-6376
[e-mail]
Persons wishing to comment upon or object to DwQ's.proposed determination to issue the requested permit are
invited to submit their comments in writing to the above address no later than March 6, 2013. All comments received
prior to that date will be considered in the final determination regarding permit issuance. All comments and requests
should"reference draft permit number NCS000562

Pickle, Ken
From: Palmer, Lisa M
Sent: Thursday, January 31, 2013 9:13 AM
To: Pickle, Ken
Subject: FW: Public Notice Daily Courier 1-30-2013
Attachments: 30347997_00000129.pdf
Good Morning Ken,
See attached for your proof for the other newspaper. It will run 2-1 and cost 96.00.
Have a great day!
LisauM. P at+ne -
NCDENR/DWQ/Point Source Branch
1617 Mail Service Center
Raleigh, NC 27699-1617
[phone]
From: Erika Meyer [mai Ito: emeyerColthedatalcourier.com]
Sent: Thursday, January 31, 2013 9:03 AM
To: Palmer, Lisa M
Subject: Re: Public Notice Daily Courier 1-30-2013
Good Morning Lisa, I have attached a proof for your review. I have the legal scheduled to publish tomorrow,
Friday, 2/1. Please let me know if you see any changes that need to be made before 1:30pm today. Total cost is
$96.00. Thanks, Erika 828-202-2924
On Jan 30, 2013, at 10:42 AM, Palmer, Lisa M wrote:
Acct# 04104850-000
Please publish the HIGHLIGHTED public notice as a line advertisement in the Legal Section of your
paper ONE TIME as soon as possible. Please verify receipt of this email, and send proof/cost/day
AD will run before printing.
Feel free to contact me with any questions, Thanks!
PUBLIC NOTICE
STATE OF NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
RALEIGH, NORTH CAROLINA 27699-1617

Horsehead Metal Products, Inc., Mooresboro, NC has applied for an NPDES Stormwater Permit to discharge
stormwater associated with industrial activities from a facility located at 484 Hicks Grove Road, Mooresboro, NC,
Rutherford County. The facility will discharge to waters designated as the Broad River within the Broad River Basin.
Copies of the draft permit, No. NCS000562, are available at the following website as of February 1,
2013: http://portal.ncdenr.orci/web/wg/ws/su/public-notices
Or by contacting:
Ken Pickle
NC Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Telephone Number: [phone]_
ken. picklePncdenr.gov
Persons wishing to comment upon or object to DWQ's proposed determination to issue the requested permit are
invited to submit their comments in writing to the above address no later than March 6, 2013. All comments received
prior to that date will be considered in the final determination regarding permit issuance. All com_ ments_and requests
should reference draft permit number NCS000562

AFFIDAVIT OF PUBLICATION
STATE OF NORTH CAROLINA
RUTHERFORD COUNTY
Before the undersigned, a Notary Public of said County and State, duly
commissioned, qualified, and authorized by law to administer oaths, personally
appeared
Bobbie Greene
who being first duly sworn, deposes and says: that they are
Customer Sales Representative
(Owner, partner, publisher, or other officer or employee authorized to make this
affidavit) of THE DAILY COURIER, a newspaper published, issued and entered as
second class mail In the town of FOREST CITY, In said County and State; that they
are authorized to make this affidavit and sworn statement; that the notice or other
legal advertisement, a true copy of which is attached hereto, was published in THE
DAILY COURIER on the following date:
February 1, 2013
and that said newspaper in which such notice, paper, document, or legal
advertisement was published was, at the time of each and every such publication, a
newspaper meeting all of the requirements and qualifications of Section 1-597 of the
General Statutes of North Carolina and was a qualified newspaper within the meaning
of Section 1-597 of the General Statutes of North Carolina.
This the 1st day of February, 2013
Bobbie Greene, Customer Sales Representative
Sworn to and subscribed before me this the 1 st day of February, 2013
Cindy D. Branch,(Notary Public)
My commission expires: February 18, 2017.
PUBLIC NOTICE
TE
ENVIRONMENTALL OFNORTH
COMMISSION
RALEIGH, NORTH CAROLINA 27699-1617
Horsehead Metal Products, Inc., Mooresboro
aPPlied for an NPDES Storm water Permit o
stormwater associated NC has
located at 484 with industrial activities to discharge
Ruthertord Hicks Grove Road, Moores rom a facility
designated County. The facility will tli Moo boyo, NC,
9 ated as the Broad River within the Broad a v waters
Copley o1 the draftRiver Basin.
at the foilowlPermit, No. NCS0005621 are available
httpJ/Portal ncden orrg/welOf February 1, 2013:
Wwa su/Public-notices
Or by contacting:
NC Divisionof Water Water
kle
1617 Mall Service CenterRaleigh, , Ralei, NC 2
Telhone Number: /gtoi nn. 7699-1617

fireplace, full unfinished ba' Ola heat I
id 2 car metal carport, 2 V
_. hark deck

eusuc NOTICE
STATE OF NORTH CAROLINA
ENVIRONMENTAL MACAGEMNATz COMMISSION
RALEIGH, NC has
Horsehead Metal Products, Inc., Moorrensib to discharge
NP T tot al
Per a tacility
applied for an Road, Mooresboro, NC,
stormwater associated witGrodestrial activities fOfn waters
located at 484 Hicks
Rutherford County. The facility will discharge °
designated as the Broad River within the Broad River Basin.
ermtt, No. NCS0oo562, are available
website as of February 1, 2013`
Copies of the draft p ,j,u public -notices
M
the following
httpolpo�l•nedenr.orglwe publisher, or other officer or employee authorized to make this
Or by contacting" DAILY Co
a newspaper published, issued and entered as
Ken pickle In the town of FOREST CITY In said County and State; that the
Raleigh, NC 27699'1617 lake this affidavit and sworn statement; that the notice or other
NC DlviCenter Water Quality Y
1617 Mail Service
ais) gp7.6376 Number .9°v
I, a true copy of which is attached hereto, was published in THE
Telephone
ken.pickle@nedenron the following date:
to comment upon or abject to DW are
nested permit are
Persons wishing to the above
mens in writing eats received
proposed sutbmit their cot 6 2 the All comm
invited to 2013
address no later than March 6, nests should
considered in the final determinatio
will beAll comments and req
prior to that
date ssuance. CS000562.
Iregarding Pe permit number N
reference draft p
AFFIDAVIT OF PUBLICATION
STATE OF NORTH CAROLINA
RUTHERFORD COUNTY
iersigned, a Notary Public of said County and State, duly
, qualified, and authorized by law to administer oaths, personally
Bobbie Greene
July sworn, deposes and says: that they are
tomer Sales Representative
February 1, 2013
and that said newspaper in which such notice, paper, document, or legal
advertisement was published was, at the time of each and every such publication, a
newspaper meeting all of the requirements and qualifications of Section 1-597 of the
General Statutes of North Carolina and was a qualified newspaper within the meaning
of Section 1-597 of the General Statutes of North Carolina.
This the 1st day of February, 2013
Bobbie Greene, Customer Sales Represen ivrtit e
SSwom to annd1 subscribed before me this the 1 st day of February, 2013
w �CJt�l�4
Cindy D. Branch,(Notary Public)
My commission expires: February 18, 2017.

ASIE'VI=
CITIZEN TBES
VOICE OF THE MOUNTAINS • CITIZEN-TIMESmm
AFFIDAVIT OF PUBLICATION
,,.ahead Metal prod-'
Phar app o r%bor
BUNCOMBE COUNTY
PUBLIC NOTICE
SS.
IWC NOME
who being first duly sworn, deposes and says: that she is
STATEOF
NORTH CAROLINA
NORTH CAROLINA
engaged in publication of a newspaper known as The
6MANAGEMENTL
Asheville Citizen -Times, published, issued, and entered as
pies of the draft552 per
No. NC6000562,
first class mail in the City of Asheville in said County and
are
,,labia at Me follow-
websitel as of Zowb
>
State; that she is authorized to make this affidavit and
RALEIGH NORTH
CAROLINA X7699.1617
Before the undersigned. a Notary Public of said Countv and
,,.ahead Metal prod-'
Phar app o r%bor
Stated ,
my commissioned qualified and authorized by law
DOES �tormwater pe,-
t to IscharGGe storm-
to administer oaths personally appeared Velene Fagan
s f
iter dssoclatetl wkh
luta .. activkies
who being first duly sworn, deposes and says: that she is
m a faclllryRs located
ad oorcsboroGfOc
therford
�
the Legal Billing Clerk of The Asheville Citizen -Times,
County. The
tors ill tlesfi9�a Ia
engaged in publication of a newspaper known as The
the Broatl fliverwith,
the Broad River Be-
Asheville Citizen -Times, published, issued, and entered as
pies of the draft552 per
No. NC6000562,
first class mail in the City of Asheville in said County and
are
,,labia at Me follow-
websitel as of Zowb
>
State; that she is authorized to make this affidavit and
p://ppowsedencor
offices Q/ws/sWpubli
sworn statement; that the notice or other legal
°II he ing:
advertisement, a true copy of which is attached hereto, was
IIINv"'°" °f Water
I
published in The Asheville Citizen -Times on the
all ServlCen-
ce
.Igh, NC 3]699-1617
following date: January 3151, 2013. And that the said
1pBrrll Number:
pIn 6
newspaper in which said notice, paper, document or legal
[e-mail]
sons wishing to
advertisement was published was, at the time of each and
tment uy on or ob-
IOWOs roposetl
armingqauution Pn
every publication, a newspaper meeting all of the
plasrsun
ImkeE t to . s°ubmi[
rto "the "it€o�ew" :
requirements and qualifications of Section 1-597 of the
ms 6. 2011 All than
:s no later thacomn
General Statues of North Carolina and was a qualified
its receivetl rlor to
date wine =on.
in
newspaper within the meaning of Section 1-597 of the
rethe nal de-
dnatlss `egard'"9
nit Issuance. All
General Statues of North Carolina.
mems yn0 re
its should refer-
Cdras_ ft plennit num b
°3°1.x56201]
a
Signed this 31st day of January, 2013
(,
Sworn to and subscribed before me the 3151 day of January,
2013.
expires the 5`h day of October, 2013
[phone]
14 O. HENRY AVE. I P.O. BOX 2090

NC d0 S9/09
1) Individual Permit Applications: `°1oAg
a) Review (Application,-amp4Rg-data, company contact info,
AeHftn�_
' , correspondence,c__ti_, n�:ncs Basinw_ide Plan,
' c-). See the flags table in Appendix D for guidance. L e e
b) Permit Types: in Llel k+2 /anJ 6464f
i) Rene val. applic�a :ml_ap _ for
ii) New: The applicant should fill out EPA Form I and EPA Form 2F. These forms
(http://h2o.enr.state.nc.us/su/Forms Documents.htm) require composite sampling, but
the State does not. Also,
inform the applicant to send the form to us, rather than to the address listed on the
form itself.
2) Update BIMS* (and later steps with *).
3) Request additional information from applicant if necessary (allow 2 weeks). (*)
4) Mark front of folder if permit includes wastewater discharge to SA or WS waters. f
5) Draft permit using the guidance about items to look for Appendix D and appropriate
benchmarks to set in Appendix E. (*)
6) Send draft to peer review, then to SPU Supervisor (or delegated SPU member) for Staff
Report Request signature.
7) Request a Staff Report from Regional Office by mail or email. Attach draft permit and copy
of application. Allow about 30 days. (*)
8) For major permits, send draft permit to EPA at same time as Staff Report Request. Major
permits are only Phase I municipalities. All others are minor.
9) For SA waters (when WW discharge), request DEH (Shellfish Sanitation) input at same time
as Staff Report Request.
10) For WS waters (when WW discharge), request DEH (Regional WS Supervisor) input after
comments received from Region. (DEH may consult the regional staff).
11) After response(s) received, consider comments and revise draft as appropriate. Update BIMS
and print Permit Tracking Sheet. (*)
12) Prepare draft permit for Notice and permittee's review (See attached Notice schedule). Public
notice and permittee review should happen simultaneously. Prepare a cover letter that
identifies/explains reasons for any monitoring (or other significant) changes from the
previous permit. Give to Processing Assistant
vng later than internal `To Notice' deadline and
/. �eeeivi��j udfar%ess��ca�'on�� (;o?v�h�rvE 03-of-02� 9,�2�W5 IQ
�DIU : lm�ea ,��) � 6e 's I
ss) b

update notice date in BIMS. Comment period is 30 days following Notice publication date.
(*)
13) After response(s) received, consider comments and revise permit as appropriate. (Optional
peer review after this step).
14) 45 days following Notice, after affidavit is received, prepare final permit for issue.
a) Prepare a cover letter that addresses significant issues/comments raised during the
comment period and explains any important changes to the permit.
b) The effective date is the first day of the month following when the permit is signed.
c) Cc: SPU File, DWQ Central Files, DWQ Regional Office, and EPA Region IV; also copy
Wake/Mecklenburg counties when applicable. (See Permit File Checklist) Make sure
actual Notice Publish date is correct in BIMS — only reviewer can update it. (*) Include
language referring to adjudicatory hearing.

florS6, heed/
Issue/Flag
Action/Guidance
for Renewal
Analytical Monitoring:=sure
Semi -Annual monitoring (schedule over calendar year) during
General
-representariv_ storm event. No longer Spring and Fall (change in 2007
Analytical Monitoring:
For each parameter (except pH), if
comes concern- (See BeIIchmarlCC D1ICetttratians irr
all values < benchmark
A"emirr.) Ax 1SQ,co r.T PA Seetouspe tfierreomiterir fbtrl net..#iRA
concentration.
band Basinwide Plan recommendations, is raise $t�estierr
-is-really process wastewater(e:gelevated
arnmema), even -if below benchmarks. Why was parameter -a POC -in the firsL
ee H monitoring regardless ecause (1) pH is important to
interpreting of er ata succ as ammonia), and (2) pH is a useful indicator of
contaminants that may not be monitored. pH also easy to monitor.
EPA -Sector -Specific Guidance:
•Deermine the type of business that the facility (talk to the applicant if
it is n ' the files).
• Determine at the SIC code would be and look it up online:
http://www.os . v/pis/imis/sicsearch.html
• Use this EPA list as gui tential chemicals that they may
need to monitor. This is only a guide, t as its own
benchmarks. (Note that this link is the 2000 versio 006 version
is proposed.): hitp://www.epa.gov/npdes/pubs/msgp2 all-
ro osed. df
Analytteeel-Monitoring:.
Look ar the mnni oring requirem e e
i€a heittcividuai-perrrfit is sim'� t
e that may be-pertment to addl to-the-indiuidual pesaatt4or
_A. general permit category; -butches—
the -facility. These parameters areohen.di erent..frsra the A parafxieters:
c F ACTLYfit...
A" ny ring
Keep -monitoring in (revise to Semi -Annual). Typically -tee few samples.-
-For each parameter; if -
collcMd.during the permit term remove monitoring based on an average,
any values > benchmark (or below,
pa ature-ofTainfall (See Benchmark Concentrations
as in case of pH)
in Appendix E.). Increase frequency if delinquent or other roblemr-
-Ana4TfttMmntermg and Secondary
XRI Sites:
mm
. GoogleTRIMaps: httv)://wviw.turbol)erl.com/i-,ojogkLTRI NC.htm
.Check -t -TRf (toxic -release-
• EPA OTIS htto://www. ne a-'tis:g atis/
ynventory) databases to check
•,_TOX map:
permits for each facility (CAA,
http://toxmap"nlm nih aov/toxmap/combo/trilclent4y.do
CWA; RCRA, EPCRA permits);
ET3A Envirofacts Site: httr)://www.epa.aovlenvirofw/
SIC.codos,-latflong, address, and
•.. Environmental Defense fund's Chemical Scorecard:
releases of chemicals by facility
www.scorecord.orp
andloaloeatior+.,.
• See document: S`:CGaid mce\Secondary Containment\How to get data
from TRI databases
D-1
/�

Issue/Flag
Action/Guidance
for Renewal
Analytical Monitoring and Se ondkiy
We require secondary containment of chemicals in this lignin any amount.
Containment:
See: �://ecfr.gpoaccess gov/cgi/t/text/text--
Check these lists see if you have
idx?type=simple c=ecfr:cc=ecfr sM5-/6cdl05ef93e580cf745c2d4a6249ff-
TRI chemic ound on the
r i n=DIV I 1=EP n=div5 view=text�idno=407n =4 ° 3A27.
0.1.1.13
SARA/ RA Water Priority
Che cal List (EPCRA, 40 CFR,
. See • iti dance\Secondary Containment\SARA EPCRA Water
ion 313, Part 372.65)
Priority Chemicals List.xls
Analytical Monitoring and Sec ary
a We require secondary containment of chemicals in this list in any amount.
Containment -
See: http://ecfr.gpoaccess. ov/cgi/t/text/text-"
Check these lists t e if you have
I
idx?c=ecfr&sid=f00fdbec43cb060Sbe17742a5785e419&rgn=div5&view=t
chemicals list on the Clean
ext&node=40:21.0.1.1.9&idno=40
Water A azardous Substance
. A spreadsheet of these chemicals can be found at:
List A, 40 CFR, Section 311,
SAGuidance\Secondary Containment\CWA Hazardous Substances.xls
116.4
J
Hazardous Waste: Haz Waste
You may want to check and see what hazardous wastes have been reported -t6'
Spill Information Report
local Fire Departments, and if there have been any spi4reported.
Please see contact list S:\Guidanc ndary Containment\Fire
Departments with Haz W nformation.doc
Please a -to" is FD list as you get more contact information.
Discharge to NSW (except Neuse
If site has not monitored for nutrients in the past, ensure TN & TP monitoring
for TN and Tar -Pamlico for
(Semi -Annual). If TN/TP already in permit, a -hers don't indicate
and TP waters)
nutrient problem (see Benchmark Con tons for guidance, Appendix E),
consider removing.
if sk- P-- nutrienm_ emly beeause it drains to NSW, 49 net
Revision on 3/5/08:
Bench s arguably still be appropriate — SPU will likely revise benchmark
ante on this.
Neuse NSW
Ensure TN monitoring if tate. See above for guidance.
Tar -Pamlico NS
Ensure TN/TP monitoring.4sVpropriate. See above for guidance.
Is stream segment impaired (on
Check the Integrated 303(b) &303(4) -report:
303(d) list), and is there a TMDL?
hrm' /lLt2e e»fi stax_ nwusLtmd1.-303d_Arehive.htm
•- - Impaired waters with Draft or Approved TMDL: Add monitoring for
pollutant(s) of concern (POC). VAy-consultw/TMI) Urrit-to-detsrmin
what's appropriate.
rn
T -- ' ------
. Impaired waters (no TMDL ygt): Add language re: potential for future
TMDL and possibility of asking for future monitoring (See permit
templates). Ensure TMDL definition is in boiler plate, Part VI.
Significant process changes
Look for new chemicals and/or necessity for keeping,maaitering of old ones
—
in the permit. Add monitoring for new POC or remove monitoring for old
POC (unless residual pot j. Also, check for new applicable SIC.
Do Stormwater EMuell Guidelines
Check 40 CFR Subchapter N (See Appe n some cases, limits may
applyI
apply, but often those aren't nebecause of the SPPP/BMP
requirements in our . [40 CFR 122.44(k)(3) authorizes use of BMPs in
lieu of num ' uent limitations in NPDES permits when limits are
D-2

Issue/Flag
Action/Guidance
for Renewal
infeasible.]
Threatened or Endangered Species?
--
fhe-N-atural Heritage Program has -created a databas�Zat�).
Current roces' betermir e f there are any Federal T&ee the
/
p['LE.f
it I�
NHP Manual in the ur ance o er on e s are serveeeds
to discuss this interim process. Is this going to be our final process?
LA'S
a�P / In �ljltJ
'sts3/M/13 /1110
hitp://nhpA,ebxDr,stale...ne..us/pgrtner/virtuat wocknoatii,phtml
User name: partner
Pa *
i 1pe2 e/ 40 r? ➢� GPc'2�
Other:
Check:
• 9tttstanrihr�uzltttptiance
• Neftees-ef­Vialat=(NOvs}and' orhercormspnndmTm--e t
Is itns
revisions.
• Specific sub-basin cone s,
• Basinwide Plan: http://h2o.enr.state.nc.us/basinwide/index.htm
recommendations, etc:
a Da a Monirnring-Reports(DMRs), if not all-data-reported in renewal
• -site mo
app4cation..Check ifparameters with 'BDL' or 'ND' (below
detecTLna.detect)values have sufficient MDL (rninttfiflYYY-detection
Gt)
isc
Copy Draft to DEH/Shellfish Sanitation per 2H.0126. (Example Memo
and is to SA waters
attached.)
Contact:
Lee Sabo
DEH, Shellfish Sanitaliorr-
Moorehead Ci r.--'-
Courier I1-Tf-10
Discharge includes wastewat
Copy Draft to Regional Office DEH WS Supervisor, {Example Memo
and is to WS waters
attached.)
Contacts:
ARO - Harold Setzer
FRO — Debra Benoy
MRO — Britt Setzef
RRO — Michael Douglas
Wa$O'and WiRO — Fred Hill, WaRO
WSRO — Lee Spen
Past-due annu fees`
Check
All�vaajor* Individual renewals,-�-
Copy Draft to EPA.
Contact:
Mike Mitchell
*Currentlyirrtludes only Phase I
U.S. EPA Region IV
MS4 permits and DOT permit.
61 Forsyth Street
Atlanta, GA 30303
All mino 5011adual renewals
Copy Final permit to EPA {see above).
Permit is in Wake County** -
Copy Wake County on Final Permit:
Wake County Environmental Services
Attn: Eric Green
P.O. Box 550
Raleigh, NC 27602
FYI — phone #: [phone] email: eric. een wake ov.com
D-3
G�¢

Issue/Flag
Action/Guidance
fwal
Permit is in Mecklenburg C
Copy Mecklenburg Cou final Permit:
Mecklenburg Co EP
Water Qua '
700 Tryon Street
rlotte, NC 28202
**A Memorandum of Agreement (MOA) exists between DENR and these counties, which perform the
inspections of these facilities. Therefore, these counties need to know when a permit is issued.
Interim Benchmark Guidance List
(Benchmarks to be added or corrected at next revision)
Last revised 6/24/2010
See Interim Benchmark Revision Document located:
S:\Stormwater Permitting Unit\Guidance\Benchmark Concentrations
About Metals in Permits
Note that metals benchmarks are based on Total Recoverable metals. All permits should specify "Total
Recoverable" for each metal in the monitoring and benchmark tables. (Acute standards for dissolved metals
are pending with 2010 Triennial Review, and implementation of metal benchmarks will be revisited soon.) _,,
D-4

A
Pickle, Ken
From: Pickle, Ken
Sent: Tuesday, November 22, 2011 3:27 PM
To: Georgoulias, Bethany; Bennett, Bradley
Subject: RE: Horsehead zinc reclamation plant
FYI. No Action
Read further only if you have a special interest.
Just took a look at Sergei s permit for Horsehead. Here's the issue for Forrest, I think, that stormwater benchmarks are
lower than wastewater limits:
Parameter
NCO089109 Wastewater Z5 •OZ'I
discharge limits wQS
Potential NCS benchmark
Apparent
discrepancy?
Comment
Flow
0.62 MGD mo. avg.
TSS
Monitor only
100 mg/L
Ammonia -N
7.2 mg/L
Aluminum
0.75 mg/L
Antimony
0.09 mg/L
Arsenic
S
0. g/L
Cadmium
350 ug/L mo. avg : 2143 u L
daily max 21, L
1 ug/L)
x
3 orders of
magnitude
Chlorides
Monitor only
D.30,,,/L
860 mg/L
Chromium
(J e
1 mg/L
Cobalt
0.03 mg/L
Copper
007
0.007 mg/L
Fluoride
315.8 mg/L: 315.8 mg/
18
6 mg/L
x
2 orders of
magnitude
Iron
Monitor only
I, p L
1 mg/L
Lead
4386 ug/L : 4829 ug/L
2 <
30 ug/L
x
2 orders of
magnitude
Nickel
Monitor only
I ;486M
0.26 mg/L
Tin
" "
-
Zinc
,oSp
0.067 mg/L
pH
6-9
(0-9
6-9
Chronic Toxicity
Monitor only
I
-
Turbidity
Instream < 50 NTU, or n
increase
SL?+TLJ
Instream < 50 NTU, or no
increase
Considering the above, and based on recollection of our phone call, it wouldn't surprise me for Forrest to highlight the
following aspects of the currently proposed site design:
• There are three natural drainage features on the property, but converting all that pasture and woodland to an
effectively impermeable plant site means that the three features are not hydraulically equipped to handle the

.•
increased flow; with the result that trying to utilize the three features would result in significant erosion and
head cutting. There is a 90' steep slope from the terraced plant site to the flat ground around the river. The
combination of topography and increased flow argues against trying to use the existing features for stormwater
conveyance.
Instead, Horsehead will capture all the excess site runoff and direct it to a single outfall pipe directly into the
Broad River. ('Excess site runoff , because a portion of the site runoff will be utilized in the process. So, there
may be discharges only in large events, or when the facility is not operating — I'm not exactly clear on when
discharges would occur.) Given the great dilution in the Broad River, even at low flow, and as reflected in the
relatively high wastewater limits above, does it make sense to have such low benchmarks for the stormwater
discharges? Essentially Forrest's argument may be: If Sergei's analysis quantifies the pollutant limits necessary
to protect the Broad River for a 365d/yr discharge, shouldn't the less frequent, more diluted stormwater
benchmarks be at least as high, if not higher?
• The facility has already been through the DAQ and the emissions into the atmosphere are ok with our brothers
and sisters in DAQ. So, if it's already authorized to be in the environment, then DWQ shouldn't double count
those heavy metals just because some of them fall out on the plant site and are washed off in the runoff.
NOTE: It sounds like Horsehead and Forrest will be coming forward with a site plan that makes no attempt at BMPs or
any stormwater treatment. The primary raw material here is EAFD(?) Electric Arc Furnace Dust - - it's chockfull of heavy
metals — obviously, because zinc and plumbum are their products. Our assessment for the potential for polluted runoff
should consider the hazardous nature of heavy metals.
The first counters that come to mind are:
• The benchmarks are not permit limits. They are flags for the site manager so that he can be vigilant in insuring
that pollutants from industrial sites do not accidentally slip off his site in stormwater runoff. It makes sense for
us to require response actions as outlined in our individual permit template in order to have site managers
serious about the discharge of pollutants from their sites.
• For intractable conditions DWQ can grant relief from the benchmarks.
• Where accumulated data can show that pollutants are not present and not discharged from the site, DWQ can
easily re -open the individual permit and amend the monitoring requirements as to frequency and parameter.
First let's characterize the discharges from this unusual industrial facility (there are none exactly like it in the
world, and only a few even reclaiming EADF by any process), and let's err on the side of protecting the
environment, and then let's back off where accumulated data shows that we have been overly cautious.
• If the site is indeed clean, there shouldn't be a problem meeting these benchmark values.
• If there is a problem, then perhaps street sweepers, or additional roofing, or bioretention cells in hot spot
sources, or grassed conveyances could help. At least try to do something if heavy metals are leaving your site.
• We acknowledge that for some, it may be counterintuitive that stormwater benchmarks would be lower than
wastewater limits. But each program has their own set of procedures and rules that determine how we permit
industrial facilities. An attempt to reconcile the two programs is a programmatic endeavor that we don't have
the resources to attempt at this point in time.
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: [e-mail]

Ideas for Copper and Zinc.Monitoring in 2012 General Permit Renewals
Analytical Monitoring
Table 1. Analytical Monitoring Requirements
' � ---a ' G � F.lS'.:. �. � � \.— M�.-6 a?': � '.}�_.. +{'•
.ti. .J E.t�=d '.ti
r -! L„��Ar!%.�'•` �.� 14
r
�e....LG. � ,
8 cF, � e 1 , ��
•
• . •
semi annual
•
Zinc (Zn)2,3
Copper Total• •
0.067 (Tier One),
0.13 (Tiers Two and Three)2
• •
Total• •
• •
Total
..
Footnotes:
1 Measurement Frequency: Twice per year during a measureable storm event
2 Grab samples shall be collected within the first 30 minutes of discharge.
3 Sample Location: Samples shall be collected at each stormwater discharge outfall (SDO) unless
representative outfall status (ROS) has been granted. A copy of the letter granting ROS shall be kept on site.
The permittee may elect to sample Cu and Zn upstream (U) and downstream (D) of all stormwater outfalls
instead of at each SDO with representative status (no benchmark applies). See also footnote 3 in Table 3.
4 For each sampled measureable storm event, the total precipitation must be recorded. An on-site rain gauge
or local rain gauge reading must be recorded.
Associated Benchmarks
Table 3. Benchmark Values for nalytical Monitoring
Footnotes:
I If pH values outside this range are recorded in sampled stormwater—discharges, but ambient rainfall
data indicate precipitation pH levels are within ± 0.1 standard units of the measured discharge
values or lower, then the lower threshold of this benchmark range does not apply. Readings from an on-
site or local rain gauge (or local precipitation data) must be documented to demonstrate background
concentrations were below the benchmark pH range.
2 These benchmarks are hardness dependent and are based on a default hardness of 50 mg/1. Tiers Two
and Three are prompted by values exceeding twice the initial benchmark.
pH1
standard
6-91
Copper(Cu) 2�3
m91
0.007 (Tier. One),
` 0.014 (Tiers Two and Three)2
Zinc (Zn)2,3
mg/L
0.067 (Tier One),
0.13 (Tiers Two and Three)2
Footnotes:
I If pH values outside this range are recorded in sampled stormwater—discharges, but ambient rainfall
data indicate precipitation pH levels are within ± 0.1 standard units of the measured discharge
values or lower, then the lower threshold of this benchmark range does not apply. Readings from an on-
site or local rain gauge (or local precipitation data) must be documented to demonstrate background
concentrations were below the benchmark pH range.
2 These benchmarks are hardness dependent and are based on a default hardness of 50 mg/1. Tiers Two
and Three are prompted by values exceeding twice the initial benchmark.

reu of benchmarks for Cu and Zn, the permittee may monitor up- and downstream of the
ulative stormwater discharges from the site where feasible and demonstrate that the stormwater
harges subject to this permit do not significantly increase in -stream concentrations of these metals.
t demonstration may take into account total dissolved levels of these metals at ambient conditions.
Alternatively, in lieu of benchmarks, the permittee may identify likely sources of Cu and Zn and devise a
site-specific Monitoring and BMP Plan to address how the facility will assess and reduce or eliminate
these metals from stormwater discharges. The Monitoring and BMP Plan shall be submitted to the
Division's Regional Office for approval and shall be incorporated into the SPPP.
That last alternative - a site-specific Monitoring and BMP plan - comes from a concept
included in the Action Levels water quality standard in 15A NCAC 02B.0211(4). Here's
what that says:
(4) Action Levels for Toxic Substances:
(a)
Copper: 7 ug/I;
(b)
Iron: 1.0 mg/I;
(c)
Silver: 0.06 ug/I;
(d)
Zinc: 50 ug/I;
(e)
Chloride: 230 mg/I;
If the Action Levels for any of the substances listed in this Subparagraph (which are generally
not bioaccumulative and have variable toxicity to aquatic life because of chemical form,
solubility, stream characteristics or associated waste characteristics) are determined by the
waste load allocation to be exceeded in a receiving water by a discharge under the specified
low flow criterion for toxic substances (Rule .0206 in this Section), i
Those substances for which Action
Levels are listed in this Subparagraph shall be limited as appropriate in the NPDES permit based
on the Action Levels listed in this Subparagraph if sufficient information (to be determined for
metals by measurements of that portion of the dissolved instream concentration of the Action
Level parameter attributable to a specific NPDES permitted discharge) exists to indicate that
any of those substances may be a causative factor resulting in toxicity of the effluent. NPDES
permit limits may be based on translation of the toxic form to total recoverable metals. Studies
used to determine the toxic form or translators must be designed. according to "Water Quality
Standards Handbook Second Edition" published by the Environmental Protection Agency (EPA
823 -B -94-005a) or "The Metals Translator: Guidance For Calculating _ a Total Recoverable Permit
Limit From a Dissolved Criterion" published by the Env! ronmental:Protection Agency (EPA 823-
B-96-007) which are hereby incorporated by reference including any subsequent amendments.
The Director shall consider conformance to EPA guidance as well as the presence of
environmental conditions that limit the applicability of translators in approving the use of metal
translators.

4
VIA
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Pat McCrory Charles Wakild, P. E. John E. Skvarla, III
Governor Director Secretary
March 25, 2013
Mr. Timothy R. Basilone
Vice President — Environmental Affairs
Horsehead Corporation
4955 Steubenville Pike, Suite 405
Pittsburgh, Pennsylvania 15205
Subject: Final NPDES Stormwater Permit
Permit No. NCS000562
Horsehead Corporation
Rutherford County
Dear Mr. Basilone:
In response to your application for'coverage under the NPDES stormwater permitting program, the
Division of Water Quality (Division) is forwarding herewith the subject state - NPDES permit.
This permit is issued pursuant to the requirements of North Carolina General Statute 143-215 .1 and
the Memorandum of Agreement between North Carolina and the U.S. Environmental Protection
Agency dated October 15, 2007 (or as subsequently amended).
This final permit includes no changes from the draft permit sent to you on January 30, 2013.
Please note that analytical monitoring is required in this permit. Failure to complete the monitoring
as required is a violation of the permit and any permit noncompliance constitutes a violation of the
Clean; Water Act. Reference Part III, Section A, Item 2 "Duty to Comply", Item 9 "Penalties for
Tampering" and Item 10 "Penalties for Falsification of Reports" of your permit for further
information.
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to an adjudicatory hearing upon written request within
thirty (30) days following receipt of this letter. The request must be in the form of a written petition,
conforming to Chapter 150B of the North Carolina General Statutes, and filed with the Office of
Administrative Hearings, Post Office Drawer 27447, Raleigh, North Carolina 27611 -7447. Unless
such demand is made, our permitting decision shall be final and binding.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone]
Internet: www.ncwaterouality.org
An Equal Opportunity 1 Affirmative Action Employer
Nne
orthCarohna
Naturally

Mr. Basilone
March 25, 2013
Page 2 of 2
Please take notice this permit is not transferable except by the specific action of the Division. Part
III, B.2. addresses the requirements to be followed in case of change in ownership or control of this
discharge. This permit does not affect the legal requirements to obtain other permits which may be
required by the Division or permits required by the Coastal Area Management Act, or any other
federal or local governmental permit that may be required.
If you have any questions or comments concerning this permit, contact Ken Pickle at (919) 807-
6376 or at ken.oickleamcdenngov.
Sincerely,
ORIGINAL SIGNED W
KEN PICKLE
for Charles Wakild, P.E., Director
cc: DWQ Asheville Regional Office, Surface Water Protection
Mike Mitchell, EPA Region IV, 61 Forsyth Street, Atlanta, GA 30303
DWQ Stormwater Permitting Unit permit files
DWQ Central Files
Attachments

NCS000562
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
TO DISCHARGE STORMWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of North Carolina General Statute 143-215.1, other
lawful standards and regulations promulgated and adopted by the North Carolina
Environmental Management Commission, and the Federal Water Pollution Control Act, as
amended,
Horsehead Corporation
is hereby authorized to discharge industrial stormwater from a facility located at
Horsehead Metal Products, Inc.
484 Hicks Grove Road
Mooresboro, North Carolina
Rutherford County
to receiving waters designated as the Broad River, a class C water in the Broad River Basin,
in accordance with the discharge limitations, monitoring requirements, and other
conditions set forth in Parts 1,11,111, and IV hereof.
This permit becomes effective April 1, 2013.
This permit and the authorization to discharge expire at midnight on March 31, 2018.
Signed this day March 25, 2013.
ORIGINAL SIGNED 81
IGEN PICKI.F
for Charles Wakild, P.E., Director
Division of Water Quality
By the Authority of the Environmental Management Commission

Permit No. NCSOOOS62
TABLE OF CONTENTS
PART INTRODUCTION
Section A: Individual Permit Coverage
Section B: Permitted Activities
Section C: Location Map
PART II MONITORING, CONTROLS, AND LIMITATIONS FOR PERMITTED
DISCHARGES
Section A: Stormwater Pollution Prevention Plan
Section B:
Section C:
PART III
Section A:
Analytical Monitoring Requirements
Qualitative Monitoring Requirements
STANDARD CONDITIONS FOR NPDES STORMWATER INDIVIDUAL PERMITS
Compliance and Liability
1. Compliance Schedule
2. Duty to Comply
3. Duty to Mitigate
4. Civil and Criminal Liability
S. Oil and Hazardous Substance Lia
6. Property Rights
7. Severability
8. Duty to Provide Information
9. Penalties for Tampering
10. Penalties for Falsification of Reports
11. Onshore or Offshore Construction
12. Duty to Reapply
Section B: General Conditions
1. Permit Expiration
2. Transfers
3. Signatory Requirements

Permit No. NCS000562
4. Permit Modification, Revocation and Reissuance, or Termination
S. Permit Actions
6. Annual Administering and Compliance Monitoring Fee
Requirements
Section C: Operation and Maintenance of Pollution Controls
1. Proper Operation and Maintenance
2. Need to Halt or Reduce Not a Defense
3. Bypassing of Stormwater Control Facilities
Section D: Monitoring and Records
I.
Representative Sampling
2.
Recording Results
3.
Flow Measurements
4.
Test Procedures
S.
Representative Outfall
6.
Records Retention
7.
Inspection and Entry
Section E: Reporting Requirements
1.
Discharge Monitoring Reports
2.
Submitting Reports
3.
Availability of Reports
4.
Non-Stormwater Discharges
S.
Planned Changes
6.
Anticipated Noncompliance
7.
Spills
8.
Bypass
9.
Twenty-four Hour Reporting
10.
Other Noncompliance
11.
Other Information
PART IV DEFINITIONS
ii

Permit No. NCS000562
PART I INTRODUCTION
SECTION A: INDIVIDUAL PERMIT COVERAGE
During the period beginning on the effective date of the permit and lasting until expiration,
the permittee is authorized to discharge stormwater associated with industrial activity.
Such discharges shall be controlled, limited, monitored, and reported as specified in this
permit.
If industrial materials and activities are not exposed to precipitation or runoff as described
in 40 CFR §122.26(g), the facility may qualify for a No Exposure Exclusion from NPDES
stormwater discharge permit requirements. Any owner or operator wishing to obtain a No
Exposure Exclusion must submit a No Exposure Certification Notice of Intent (N01) form to
the Division; must receive approval by the Division; must maintain no exposure conditions
unless authorized to discharge under a valid NPDES stormwater permit; and must recertify
the No Exposure Exclusion annually.
SECTION B: PERMITTED ACTIVITIES
Until this permit expires or is modified or revoked, the per ittee is authorized to discharge
stormwater to the surface waters of North Carolina that has een ad quately treated and
managed in accordance with the terms and conditions of this rm)(. All stormwater
discharges shall be in accordance with the conditions of this per t.
Any other point source discharge to surface waters of the st# is pibkibited unless it is an
allowable non-stormwater discharge or is covered by anoth r permit, INthorization, or
approval. The stormwater discharges allowed by this permit shall not cause or contribute
to violations of Water Quality Standards.
This permit does not relieve the permittee from responsibility for compliance with any
other applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or
decree.
Part I Page 1 of 2

SECTION C: LOCATION MAP
Permit No. NCS000562
N
S
Map Scale 1.24,000
Horsehead Corporation
Rutherford County facility
Latitude; 351 11' 36' N
Longitude:810 50'5T W
County: Rutherford Caunty
Receivin_q Stream: Broad River
.Stream Class: C
Sub -basin: 03-08-02 Broad Diver Basin
Part I Page 2 of 2
Facility Location

Permit No. NCS000562
PART 11 MONITORING, CONTROLS, AND LIMITATIONS FOR
PERMITTED DISCHARGES
SECTION A: STORMWATER POLLUTION PREVENTION PLAN
The permittee shall develop and implement a Stormwater Pollution Prevention Plan
(SPPP). The SPPP shall be maintained on site. The SPPP is public information in
accordance with Part III, Standard Conditions, Section E, paragraph 3 of this permit. The
SPPP shall include, at a minimum, the following items:
1. Site Overview. The Site Overview shall provide a description of the physical facility
and the potential pollutant sources that have the potential to contribute to
contamination of stormwater discharges. The Site Overview shall contain the following:
(a) A general location map (USGS quadrangle map or appropriately drafted equivalent
map) showing the facility's location in relation to transportation routes and surface
waters; the name of the receiving waters to which the stormwater outfalls
discharge; and accurate latitude and longitude of the points of stormwater discharge
associated with industrial a tivity. The general location map (or alternatively the
site map) shall identify whet er any receiving waters are impaired (on the state's
303(d) list of impaired water or if the site is located in a watershed for which a
TMDL has been established, d what t e parameters of concern are.
(b) A narrative description of stora pr tices, loading and unloading activities,
outdoor process areas, dust or parti ate generating or control processes, and
waste disposal practices. A narrati description of the potential pollutants that
could be expected to be present in e s water discharge from each outfall, and a
discussion of failure modes that ay impac a risk for polluted stormwater
discharges.
(c) A site map drawn at a scale sufficient arly dep ct: the site property boundary;
the stormwater discharge outfalls; all on-site a jacent surface waters and.
wetlands; industrial activity areas (including storage of materials, disposal areas,
process areas, loading and unloading areas, and haul roads); site topography and
finished grade; all drainage features and structures; drainage area boundaries and
total contributing area for each outfall; direction of flow in each drainage area;
industrial activities occurring in each drainage area; buildings; stormwater Best
Management Practices (BMPs); and impervious surfaces. The site map must
indicate the percentage of each drainage area that is impervious, and the site map
must include a graphic scale indication and north arrow.
(d) A list of significant spills or leaks of pollutants during the previous three (3) years
and any corrective actions taken to mitigate spill impacts.
Part 11 Page 1 of 11

Permit No. NCS000562
(e) Certification that the stormwater outfalls have been evaluated for the presence of
non-stormwater discharges. The permittee shall re -certify annually that the
stormwater outfalls have been evaluated for the presence of non-stormwater
discharges. The certification statement will be signed in accordance with the
requirements found in Part 111, Standard Conditions, Section B, Paragraph 3.
2. Stormwater Management Strategy. The Stormwater Management Strategy shall
contain a narrative description of the materials management practices employed which
control or minimize the stormwater exposure of significant materials, including
structural and nonstructural measures. The Stormwater Management Strategy, at a
minimum, shall incorporate the following:
(a) Feasibility Study. An annual review by site management of the technical and
economic feasibility of changing the methods of operations and/or storage practices
to eliminate or reduce exposure of materials and processes to rainfall and run-on
flows. Wherever practical, the permittee shall prevent exposure of storage areas,
material handling operations, manufacturing, and fueling operations. In areas
where elimination of exposure and/or prevention of run-on contact are not
practical, the Feasibility Study shall document the basis for the management
decision that such controls are not feasible.
(b) Secondary Containment Requirements and Records. Secondary containment is
required for: bulk storage of liquid materials includingl2etroleum products; storage
in any amount of Section 313 of Title III of the Superfund Amendments and
Reauthorization Act (SARA) water priority chemicals; and storage in any amount of
hazardous substancesin order to prevent leaks and spills from contaminating
stormwater runoff. A table or summary of all such tanks and stored materials and
their associated secondary containment areas shall be maintained. If the secondary
containment devices are connected to stormwater conveyance systems, the
connection shall be controlled by manually activated valves or other similar devices,
which shall be secured closed with a locking mechanism. Prior to release into the
stormwaters conveyance system, any stormwater that accumulates in containment
areas shall be at a minimum visually observed for color, foam, outfall staining,
visible sheens, and dry weather flow. Accumulated stormwater may be released if
found to be uncontaminated by any material. Records documenting the individual
making the observation or analyses, the visual and analytical description of the
accumulated stormwaters, and the dates and times of the releases shall be kept for a
period of five (5) years.
(c) BMP Summary. A listing of site structural and non-structural Best Management
Practices (BMPs) shall be provided. The installation and implementation of BMPs
shall be based on the assessment of the potential for sources to contribute
significant quantities of pollutants to stormwater discharges and on data collected
through monitoring of stormwater discharges. The BMP Summary shall include a
written record of the specific rationale for installation and implementation of the
PartII Page 2 of 11

Permit No. NCS000562
selected site BMPs. The BMP Summary shall be reviewed by site management and
updated annually.
3. Spill Prevention and Response Procedures. The Spill Prevention and Response
Procedures (SPRP) shall incorporate an assessment of potential pollutant sources based
on a materials inventory of the facility. The SPRP shall address spill response and
failure mode preparations and responses. Site management shall identify facility
personnel responsible for implementing the SPRP in a written list incorporated into the
SPRP along with dated signatures by each individual acknowledging his or her
responsibilities under the SPRP. A responsible person shall be on-site at all times
during facility operations that have the potential to contaminate stormwater runoff
through spills or exposure of,materials associated with the facility operations. The
SPRP must be site stormwater specific. Therefore, an oil Spill Prevention Control and
Countermeasure plan (SPCC) may be a component of the SPRP, but may not be
sufficient to completely address the stormwater aspects of the SPRP. The common
elements of the SPCC with the SPRP may be incorporated by reference into the SPRP.
4. Preventative Maintenance and Good Housekeeping
maintenance and good housekeeping program shall be
The program shall address all stor water control syste
outfalls, all on-site and adjacent su ac
(including material storage areas, t4
areas, loading and unloading areas,
structures, and structural BMPs. The
maintenance, and housekeeping activ
facility equipment, facility areas, and fs
stormwater exposure or stormwater p
another element of the SPPP. Inspecth
cleaning schedules of these areas shall
compliance with the established sched
housekeeping shall be recorded and m
waters and
haul
of
gram. A preventative
sloped and implemented.
stormwater discharge
Is, industrial activity areas
'areas, disposal areas, process
all drainage features and
establish schedules of inspections,
tater control systems, as well as
lity ystems that present a potential for
u on where not already addressed under
of material handling areas and regular
incorporated into the program. Timely
?s for inspections, maintenance, and
Itained in the SPPP.
5. Facility Inspections. Inspections of the fa ility and all stormwater conveyance and
control systems shall occur as part of the Pr entative Maintenance and Good
Housekeeping Program ata minimum on a se annual schedule, once during the first
half of the year (January to June) and once durin the second half (July to December),
with at least 60 days separating nspection dates ( nless performed more frequently
than semi-annually). These f ility inspections ar different from, and in addition to,
the stormwater discharge cha acteristic monitori at the outfall required in Part lI
Sections B and C of this permit.
6. Employee Training. Training programs shall be developed and training provided at a
minimum on an annual basis for facility personnel with responsibilities for: spill
response and cleanup, preventative maintenance activities, and for any of the facility's
operations that have the potential to contaminate stormwater runoff. The facility
PartII Page 3 of 11

Permit No. NCS000562
personnel responsible for implementing the training shall be identified, and their
annual training shall be documented by the signature of each employee trained.
7. Responsible Party. Site management shall identify, and the SPPP shall document, a
specific position or positions responsible for the overall coordination, development,
implementation, and revision of the SPPP. Responsibilities for all components of the
SPPP shall be documented and position assignments provided.
8. SPPP Amendment and Annual Update. The permittee shall amend the SPPP
whenever there is a change in design, construction, operation, site drainage,
maintenance, or configuration of the physical features which may have a significant
impact on the potential for the discharge of pollutants to surface waters. All aspects of
the SPPP shall be reviewed and updated on an annual basis. The annual update
shall include all the aspects required immediately above in items 1-7; and a review and
comparison of monitoring analytical data to benchmark values over the pastyear,
including a discussion about Tiered Response status. The permittee shall use the
Division's Annual Summary Data Monitoring Report form, available from the
Stormwater Permitting Unit's website here:
httpsI/12ortal,ncdenr.org/web/wq/ws/suInpdess3m).
The Director may notify the permittee when the SPPP does not meet one or more of the
minimum requirements of the permit. Within 30 days of such notice, the permittee
shall submit a time schedule to the Director for modifying the SPPP to meet minimum
requirements. The permittee shall provide certification in writing (in accordance with
Part III, Standard Conditions, Section B, Paragraph 3) to the Director that the changes
have been made.
9. SPPP Implementation. The permittee shall implement the Stormwater Pollution
Prevention Plan and all appropriate BMPs to prevent contaminants from entering
surface waters via stormwater. Among other actions identified herein, implementation
of the SPPP shall include the documentation of: all monitoring, measurements,
inspections, maintenance activities, and training provided to employees, including the
log of the sampling data and of actions taken to implement BMPs associated with the
industrial activities. Such documentation shall be kept on-site for a period of five (5)
years and made available to the Director or the Director's authorized representative
immediately upon request.
Part11 Page 4 of 11

Permit No. NCS000562
SECTION B: ANALYTICAL MONITORING REQUIREMENTS
Analytical monitoring of stormwater discharges shall be performed as specified in Table 1.
y4� All analytical monitoring shall be performed during a measureable storm event at each
stormwater discharge outfall (SDO). Only SDOs discharging stormwater associated with
p industrial activity must be sampled (See Definitions).
A measurable storm event is a storm event that results in an actual discharge from the
permitted site outfall. The previous measurable storm event must have been at least 72
hours prior. See Definitions.
Table 1 Analvtical Monitoring Requirements
Discharge
Characteristics
Units
Measurement
Frequencyl
Sample
T e2
Sample
Location3
Total Suspended Solids
m L
quarterly
Grab
SDO
Total Nitrogen
m L
quarterly
Grab
SDO
Total Phosphorus
m L
quarter
Grab
SDO
Zinc, Total Recoverable
m L
quarxrly
Grab
SDO
Lead, Total Recoverable
m L
q rterly
Grab
SDO
Cadmium, Total Recoverable
m L
uarterly
Grab
SDO
Chlorides
m L
quarterly
Grab
SDO
Non -polar Oil & Grease/TPH
EPA Method 1664 SGT -HEM
m L
g/
quarterly
Grab
SDO
H
sta dad
quarterly
Grab
SDO
Total Rainfa114
in es
quarterly
Rain Gauge
Footnotes:
1 Measurement Frequency: Four times per ye { du 'ng
petition DWQ to reduce the analytical monit 'rig fr i
monitoring results all within benchmark val es. Subse
parameter re -institute quarterly monitorin forallpai
2 Grab samples shall be collected within first 30 mi
3 Sample Location: Samples shall be coil ed at each
4 For each sampled measureable storm ent, the total
reading must be recorded.
a measureable storm event The permittee may
ency to twice per year after eight consecutive quarterly
Vently, two consecutive benchmark exceedances for any
discharge outfall (00).
in must be recorded. An on-site rain gauge
The permittee shall complete the analytical samplings in ccordance with the schedule
specified below in Table 2, unless adverse weather condittyris prevent sample collection
(see Adverse Weather in Definitions). A minimum of 30 s must separate successive
sample events. Inability to sample because of adverse weather conditions must be
documented in the SPPP and recorded on the DMR. The permittee must report the results
from each sample taken within the monitoring period (see Part III, Section E).
Part 11 Page 5 of 11

Permit No. NCS000562
Table 2 Monitoring Schedule
Monitoringperiodi;?o
. Sample Number
,Start =,:°
End
Year 1- Period 1
1
April 1, 2013
June 30, 2013
Year 1- Period 2
2
July 1, 2013
September 30, 2013
Year 1- Period 3
3
October 1, 2013
December 31, 2013
Year 1- Period 4
4
January 1, 2014
March 31, 2014
Year 2 - Period 1
5
April 1, 2014
June 30, 2014
Year 2 - Period 2
6
July 1, 2014
September 30, 2014
Year 2 - Period 3
7
October 1, 2014
December 31, 2014
Year 2 - Period 4
8
January 1, 2015
March 31, 2015
Year 3 - Period.1
9
April 1, 2015
June 30, 2015
Year 3 - Period 2
10
July 1, 2015
September 30, 2015
Year 3 - Period 3
11
October 1, 2015
December 31, 2015
Year 3 - Period 4
12
January 1, 2016
March 31, 2016
Year 4 - Period 1
13
April 1, 2016
June 30, 2016
Year 4 - Period 2
14
July 1, 2016
September 30, 2016
Year 4 - Period 3
15
October 1, 2016
December 31, 2016
Year 4 - Period 4
16
January 1, 2017
March 31, 2017
Year 5 - Period 1
17
April 1, 2017
June 30, 2017
Year 5 - Period 2
18
July 1, 2017
September 31, 2017
Year 5 - Period 3
19
October 1, 2017
December 31, 2017
Year 5 - Period 4
20
January 1, 2018
March 31, 2018
Footnotes:
1 Maintain quarterly monitoring until either another permit is issued for this facility or until this permit
is revoked or rescinded. The permittee must submit an application for renewal of coverage before the
submittal deadline (180 days before expiration) to be considered for renewed coverage under the
permit The permittee must continue analytical monitoring throughout the permit renewal process,
even if a renewal permit is not issued until after expiration of this permit.
2 If no discharge occurs during the sampling period, the permittee must submit a monitoring report
indicating "No Flow" within 30 days of the end of the sampling period. For the first term of this
permit, the new facility start-up date is uncertain. Permittee need not sample for the listed
monitoring periods until the facility comes into operation. Accordingly, the "No Plow" monitoring
report is not required during the time before the facility comes into operation.
Failure to monitor quarterly per the permit terms may result in the Division requiring
monthly monitoring for all parameters for a specified time period. "No discharge' from
an outfall, or inability to collect a sample because of adverse weather conditions during a
monitoring period does not constitute failure to monitor, as long as it is properly reported.
The permittee shall compare monitoring results to the benchmark values in Table 3. The
benchmark values in Table 3 are not permit limits, but should be used as management
guidelines for the permittee's responsive implementation of the Stormwater Pollution
Prevention Plan (SPPP).
PartII Page 6 of 11

Permit No. NCS000562
Table 3 Benchmark Values for nalytical Monitoring
Discharge Characteristics
Units
Benchmark'
Total Suspended Solids
m L
100
Total Nitrogen
mg/L
30
Total Phosphorus
mg/L
X2
Zinc, Total Recoverable
mg/L
0.067
Lead, Total Recoverable
mg/L
0.03
Cadmium, Total Recoverable
mg/L
0.001
Chlorides
mg/L
860
Non -polar Oil & Gr se/TPH
[EPA Method 1664 ( GT -HEM)]
mg/L
is
PH
standar
6 - 9
Footnote
1. Analytical results mu not be reported via any f the notations, "BDL. ND, BRL, <MDL, <PQL,
non -detect or any simil non -quantitative nota on. Instead, analytical results below method or
reporting limits must be r orted on the DMRYi the format, "<XX", where XX is the specific numerical
value descriptive of the me od or reporting tYrnit.
During the first term of this pmit, nd fo the period beginning with the on-site initiation of
industrial activity and continuinerg for ears nominal duration thereafter, Horsehead shall
sample quarterly as provided in Table shall tabulate and interpret the collected data
(minimum eight data points). Within months of start-up Horsehead shall present DWQ with
a summary report that uses the colle ed ata to support any proposed alternative monitoring,
benchmark, and response action sc en f the purpose of maintaining site management
awareness and responsiveness to otential ollutant discharges from the site. For the first
term of this permit, benchmark a ceedances will not activate DWQ's standard Tiered Response
actions which are shown below or reference oily.
The summary report shall sp cifically consider and interpret the collected data with respect
to the benchmarks identified in this permit, and shat identify the Tiered Response action
status that would have be triggered by the data coll6oted.
While DWQ is considering Horsehead's summary report Ad determining what revisions to the
permit, if any, may be reasonable and protective, and conti ing on for the remainder of the
permit term until any such changes in the permit requiremen4 may be established by DWQ,
Horsehead shall be subject to the full provisions of sampling, c parison to the benchmarks,
and reporting contained in Part 11 Section B. All other provisions of the permit remain in effect
from the effective date of the hermit until exniration.
Part 1l Page 7 of 11

Permit No. NCS000562
Tier One
If. The first valid sampling results are above a benchmark value, or outside of the benchmark range,
for any parameter at any outfall;
Then: The permittee shall:
1. Conduct a stormwater managementinspection of the facility within two weeks of receiving
sampling results.
2. Identify and evaluate possible causes of the benchmark value exceedance.
3. Identify potential and select the specific: source controls, operational controls, or physical
improvements to reduce concentrations of the parameters of concern, and/or to bring
concentrations within the benchmark range.
4. Implement the selected actions within two months of the inspection.
S. Record each instance of a Tier One response in the SPPP. Include the date and value of the
benchmark exceedence, the inspection date, the personnel conducting the inspection, the
selected actions, and the date the selected actions were implemented.
If: During the term of this permit, the first valid sampling results from two consecutive monitoring
periods are above the benchmark values, or outside of the benchmark range, for any specific
parameter at a specific discharge outfall;
Then: The permittee shall:
1. Repeat all the required actions outlined above in Tier One.
2. Immediately institute monthly monitoring for all parameters. The permittee shall conduct
monthly monitoring at every outfall where a sampling result exceeded the benchmark value for
two consecutive samples. Monthly (analytical and qualitative) monitoring shall continue until
three consecutive sample results are below the benchmark values or within benchmark range.
3. If no discharge occurs during the sampling period, the permittee is required to submit a
monthly monitoring report indicating "No Flow".
4. Benchmark exceedances for a different parameter separately trigger a tiered response.
S. Maintain a record of the Tier Two response and monitoring results in the SPPP.
Part II Page 8 of 11

Permit No. NCS000562
'Tier Three
During the term of this permit, if the valid sampling results required for the permit monitoring periods
exceed the benchmark value, or are outside the benchmark range, for any specific parameter at any
specific outfall on four occasions, the permittee shall notify the DWQ Regional Office Supervisor in
writing within 30 days of receipt of the fourth analytical results. DWQ may, but is not limited to:
• require that the permittee revise, increase, or decrease the monitoring frequency for some
or all parameters;
• require the permittee to install structural stormwater controls;
• require the permittee to implement other stormwater control measures;
• require the permittee to perform upstream and downstream monitoring to characterize
impacts on receiving waters; or
• require the permittee implement site modifications to qualify for a No Exposure Exclusion.
If a Total Maximum Daily Load (TMDL) is approved for this segment of the Broad River, the
permittee may be required to monitor for the pollutant(s) of concern in the future and
submit results to the.Division of Water Quality. The Division will consider the monitoring
results in determining whether additional BMPs are needed to control the pollutant(s) of
concern to the maximum extent practicable.
If additional BMPs are needed to achieve the required level of control, the permittee will be
required to (1) develop a strategy for implementing appropriate BMPs, and (2) submit a
timetable for incorporation of those BMPs into the Stormwater Pollution Prevention Plan.
Part II Page 9 of 11

Permit No. NCS000562
SECTION C: QUALITATIVE MONITORING REQUIREMENTS
The purpose of qualitative monitoring is to quickly evaluate the effectiveness of the
permittee's implementation of the SPPP, and to assess new sources of stormwater pollution,
and to prompt the permittee's response to observed pollution. Qualitative monitoring of
stormwater outfalls must be performed during a measurable storm event.
Qualitative monitoring requires a visual inspection of each stormwater outfall regardless of
representative outfall status. Qualitative monitoring shall be performed quarterly as
specified in Table 4, and concurrent with the required analytical monitoring events.
Inability to monitor because of adverse weather conditions must be documented in the
SPPP and recorded on the DMR (see Adverse Weather in Definitions). Only SDOs discharging
stormwater associated with industrial activity must be monitored.
Table 4 Qualitative Monitoring Requirements
Discharge Characteristics
Frequencyl
Monitoring
Location2
Color
quarterly
SDO
Odor
quarterl
SDO
Clarity
quarterly
SDO
Floating Solids
quarterly
SDO
Suspended Solids
quarterly
SDO
Foam
quarterl
SDO
Oil Sheen
quarterly
SDO
Erosion or deposition at the outfall
quarterly
SDO
Other obvious indicators
of stormwater pollution
quarterly
SDO
Footnotes:
1 Measurement Frequency: Four times per year during a measureable storm event See Table 2 for
schedule of monitoring periods through the end of this permitting cycle. The permittee must continue
qualitative monitoring throughout the permit renewal process until a new permit is issued. Qualitative
monitoring must he continued quarterly, and is not eligible for the semi-annual monitoring frequency under
step-down provisions that apply to analytical monitoring.
2 Monitoring Location: Qualitative monitoring shall be performed at each stormwater discharge outfall
(SDO) regardless of representative outfall status.
A minimum of 30 days must separate monitoring dates, unless additional sampling has
been instituted as part of other analytical monitoring requirements in this permit.
If the permittee's qualitative monitoring indicates that existing stormwater BMPs are
ineffective, or that significant stormwater contamination is present, the permittee shall
investigate potential causes, evaluate the feasibility of corrective actions, and implement
Part II Page 10 of 11

Permit No. NCS000562
those corrective actions within 60 days of the qualitative monitoring event. A written
record of the permittee's investigation, evaluation, and response actions shall be kept in
the SPPP.
Qualitative monitoring is for the purposes of evaluating the effectiveness of the permittee's
implementation of the SPPP, and assessing new sources of stormwater pollution, and prompting the
permittee's response to pollution. If the permittee repeatedly fails to respond effectively to
correct problems indicated by qualitative monitoring, or if the discharge causes or contributes to a
water quality standard violation, DWQ may, but is not limited to:
• require that the permittee revise, increase, or decrease the monitoring frequency and
parameters (analytical or qualitative) for a specified time period;
• require the permittee to install structural stormwater controls;
• require the permittee to implement other stormwater control measures;
• require the permittee to perform upstream and downstream monitoring to characterize
impacts on receiving waters; or
• require the permittee implement site modifications to qualify for a No Exposure Exclusion.
Part 11 Page 11 of 11

Permit No. NCS000562
PART III STANDARD CONDITIONS FOR NPDES STORMWATER INDIVIDUAL PERMITS
SECTION A: COMPLIANCE AND LIABILITY
Compliance Schedule
The permittee shall comply with Limitations and Controls specified for stormwater discharges in
accordance with the following schedule:
Existing Facilities already operating but applying for permit coverage for the first time: The
Stormwater Pollution Prevention Plan shall be developed and implemented within 12 months of the
effective date of the initial permit and updated thereafter on an annual basis. Secondary containment,
as specified in Part II, Section A, Paragraph 2(b) of this permit, shall be accomplished within 12
months of the effective date of the initial permit issuance.
New Facilities applying for coverage for the first time: The Stormwater Pollution Prevention Plan
shall be developed and implemented prior to the beginning of discharges from the operation of the
industrial activity and be updated thereafter on an annual basis. Secondary containment, as specified
in Part II, Section A, Paragraph 2(b) of this permit shall be accomplished prior to the beginning of
discharges from the operation of the industrial activity.
Existing facilities previously permitted and applying for renewal: All requirements, conditions,
limitations, and controls contained in this permit (except revised SPPP elements in a permit renewal)
shall become effective immediately upon issuance of this permit. New elements of the Stormwater
Pollution Prevention Plan for this permit renewal shall be developed and implemented within 6
months of the effective date of this permit and updated thereafter on an annual basis. Secondary
containment, as specified in Part III, Paragraph 2(b) of this permit shall be accomplished prior to the
beginning of discharges from the operation of the industrial activity.
Duty to Comply
The permittee must comply with all conditions of this permit. Any permit noncompliance constitutes
a violation of the Clean Water Act (CWA) and is grounds for enforcement action; for permit
termination, revocation and reissuance, or modification; or denial of a permit upon renewal
application [40 CFR 122.41].
a. The permittee shall comply with standards or prohibitions established under section 307(a) of
the CWA for toxic pollutants within the time provided in the regulations that establish these
standards or prohibitions, 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)]
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
Part III Page 1 of 9

. t
Permit No. NCS000562
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 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)]
3. Duty to Mitigate
The permittee shall take all reasonable steps to minimize or prevent any discharge in violation of this
permit which has a reasonable likelihood of adversely affecting human health or the environment [40
CFR 122.41(d)].
4. Civil and Criminal Liability
Except as provided in Part III, Section C of this permit regarding bypassing of stormwater control
facilities, 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.
5. 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 USC 1321.
6. 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
Part III Page 2 of 9

Permit No. NCS000562
personal rights, nor any infringement of Federal, State or local laws or regulations [40 CFR
122.41(g)].
7. Severability
The provisions of this permit are severable, and 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 15013-23].
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 the permit issued pursuant to 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 to be kept by this permit [40 CFR 122.41(h)].
9. Penalties for Tampering
The Clean Water Act 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].
10. Penalties for Falsification of Reports
The Clean Water Act 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 $10,000 per violation, or
by imprisonment for not more than two years per violation, or by both [40 CFR 122.41].
11. 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.
12. Du1y to Reapply
If the permittee wishes to continue an activity regulated by this permit after the expiration date of
this permit, the permittee must apply for and obtain a new permit [40 CFR 122.41(b)].
SECTION B: GENERAL CONDITIONS
Permit Expiration
The permittee is not authorized to discharge after the expiration date. In order to receive automatic
authorization to discharge beyond the expiration date, the permittee shall submit forms and fees as
are required by the agency authorized to issue permits no later than 180 days prior to the
expiration date, unless permission for a later date has been granted by the Director. (The Director
shall not grant permission for applications to be submitted later than the expiration date of the
existing permit.) [40 CFR 122.21(d)]. Any permittee that has not requested renewal at least 180 days
prior to expiration, or any permittee that does not have a permit after the expiration and has not
requested renewal at least 180 days prior to expiration, will be subjected to enforcement procedures
as provided in NCGS §143-215.36 and 33 USC 1251 et. seq.
Part III. Page 3 of 9

Permit No. NCS00.0562
2. 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 maybe necessary under the CWA [40 CFR 122.41(1) (3), 122.61] or state
statute. The Permittee is required to notify the Division in writing in the event the permitted
facility is sold or closed.
3. Signatory Requirements
All applications, reports, or information submitted to the Permitting Issuing Authority shall be signed
and certified [40 CFR 122.41(k)].
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].
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 122.221
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]
Part III Page 4 of 9

Permit No. NCS000562
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 forgathering 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."
4. 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 2H.0100; and North Carolina
General Statute 143-215.1 et al.
Permit Actions
The permit may be modified, revoked and reissued, or terminated for cause. The notification of
planned changes or anticipated noncompliance does not stay any permit condition [40 CFR
122.41(f)].
6. Annual Administering and Compliance Monitoring Fee Requirements
The permittee must pay the administering and compliance monitoring fee within 30 (thirty) days
after being billed by the Division. Failure to pay the fee in timely manner in accordance with 15A
NCAC 2H .0105(b)(2) may cause this Division to initiate action to revoke the permit.
SECTION C: OPERATION AND MAINTENANCE OF POLLUTION CONTROLS
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 operation of back-up or auxiliary facilities or similar systems which are installed by a permittee
only when the operation is necessary to achieve compliance with the conditions of this permit [40
CFR 122.41(e)].
2. 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)].
3. Bypassing of Stormwater Control Facilities
Bypass is prohibited and the Director 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; and
b. There were no feasible alternatives to the bypass, such as the use of auxiliary control facilities,
retention of stormwater or maintenance during normal periods of equipment downtime or dry
weather. This condition is not satisfied if adequate backup controls should have been installed in
Part III Page 5 of 9

Permit No. NCS000562,
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, Part III, Section E of this permit.
If the Director determines that it will meet the three conditions listed above, the Director may
approve an anticipated bypass after considering its adverse effects.
SECTION D: MONITORING AND RECORDS
Representative Sampling
Samples collected and measurements taken, as required herein, shall be characteristic of the volume
and nature of the permitted discharge. Analytical sampling shall be performed during a measureable
storm event. Samples shall be taken on a day and time that is characteristic of the discharge. All
samples shall be taken before the discharge joins or is diluted by any other waste stream, body of
water, or substance. Monitoring points as specified in this permit shall not be changed without
notification to and approval of the Permit Issuing Authority [40 CFR 122.410)].
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.
3. Flow Measurements
Where required, 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.
4. Test Procedures
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 13.14, of the Federal Water Pollution Control Act, as
Amended, and Regulation 40 CFR 136.
To meet the intent of the monitoring required by this permit, all test procedures must produce
minimum detection and reporting levels and all data generated must be reported down 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.
Representative Outfall
If a facility has multiple discharge locations with substantially identical stormwater discharges that
are required to be sampled, the permittee may petition the Director for representative outfall status.
If it is established that the stormwater discharges are substantially identical and the permittee is
granted representative outfall status, then sampling requirements may be performed at a reduced
number of outfalls.
Part III Page 6 of 9

Permit No. NCS000562
6. Records Retention
Visual monitoring shall be documented and records maintained at the facility along with the
Stormwater Pollution Prevention Plan. Copies of analytical monitoring results shall also be
maintained on-site. The permittee shall retain records of all monitoring information, including
o all calibration and maintenance records,
o all original strip chart recordings for continuous monitoring instrumentation,
o copies of all reports required by this permit,
o 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 5 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. Inspection and Entry
The permittee shall allow the Director, or an authorized representative (including an authorized
contractor acting as a representative of the Director), or in the case of a facility which discharges
through a municipal separate storm sewer system, an authorized representative of a municipal
operator or the separate storm sewer system receiving the discharge, upon the presentation of
credentials and other documents as may be required by law, to:
a. Enter 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 Clean Water Act, any substances or parameters at any location [40
CFR 122.41(i)].
SECTION E: REPORTING REQUIREMENTS
1. Discharge Monitoring_ Reports
Samples analyzed in accordance with the terms of this permit shall be submitted to the Division on
Discharge Monitoring Report (DMR) forms provided by the Director. DMR forms are available on the
Division's website (http://portal.ncdenr.org/web/wq/ws/sulnl2dessw). Submittals shall be
delivered to the Division no later than 30 -days from the date the facility receives the sampling
results from the laboratory.
When no discharge has occurred from the facility during the report period, the permittee is required
to submit a discharge monitoring report, within 30 days of the end of the specified sampling period,
giving all required information and indicating "NO FLOW" as per NCAC T15A 0213.0506.
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 data submitted on the DMR.
The permittee shall record the required qualitative monitoring observations on the SDO Qualitative
Monitoring Report form provided by the Division and shall retain the completed forms on site.
Qualitative monitoring results should not be submitted to the Division, except upon DWQ's specific
requirement to do so. Qualitative Monitoring Report forms are available at the website above.
Part III 'Page 7 of 9

Permit No. NCSO00562
2. Submitting Reports
Two signed copies of Discharge Monitoring Reports (DMRs) shall be submitted to:
Central Files
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
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, analytical 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 143-215.613 or in Section 309 of the Federal
Act.
4. Non-Stormwater Discharges
If the storm event monitored in accordance with this permit coincides with a non-stormwater
discharge, the permittee shall separately monitor all parameters as required under all other
applicable discharge permits and provide this information with the stormwater discharge monitoring
report.
5. Planned Changes
The permittee shall give notice to the Director as soon as possible of any planned changes at the
permitted facility which could significantly alter the nature or quantity of pollutants discharged [40
CFR 122.41(1)]. This notification requirement includes pollutants which are not specifically listed in
the permit or subject to notification requirements under 40 CFR Part 122.42 (a).
6. Anticipated Noncompliance
The permittee shall give advance notice to the Director of any planned changes at the permitted
facility which may result in noncompliance with the permit [40 CFR 122.41(l)(2)].
Snills
The permittee shall report to the local DWQ Regional Office, within 24 hours, all significant spills as
defined in Part IV of this permit. Additionally, the permittee shall report spills including: any oil spill
of 25 gallons or more, any spill regardless of amount that causes a sheen on surface waters, any oil
spill regardless of amount occurring within 100 feet of surface waters, and any oil spill less than 25
gallons that cannot be cleaned up within 24 hours.
8. Bypass
Notice [40 CFR 122.41(m)(3)]:
a. 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 affect of the bypass.
b. Unanticipated bypass. The permittee shall submit notice within 24 hours of becoming aware of
an unanticipated bypass.
Twenty-four Hour Reporting
a. The permittee shall report to the central office or the appropriate regional office any
noncompliance which may endanger 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.
Part III Page 8 of 9

Permit No. NCS000562
The written submission shall contain a description of the noncompliance, and its causes; the
period of noncompliance, including exact dates and times, and if the noncompliance has not
been corrected, the anticipated time compliance 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 [phone], [phone] or [phone].
10. Other Noncompliance
The permittee shall report all instances of noncompliance not reported under 24 hour reporting at
the time monitoring reports are submitted [40 CFR 122.41(1)(7)].
11. 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)].
Part III Page 9 of 9

PART IV DEFINITIONS
1. Act
See Clean Water Act.
NCS000562, .
2. Adverse Weather
Adverse conditions are those that are dangerous or create inaccessibility for personnel, such as local
flooding, high winds, or electrical storms, or situations that otherwise make sampling impractical.
When adverse weather conditions prevent the collection of samples during the sample period, the
permittee must take a substitute sample or perform a visual assessment during the next qualifying
storm event. Documentation of an adverse event (with date, time and written narrative) and the
rationale must be included with your SPPP records. Adverse weather does not exempt the permittee
from having to file a monitoring report in accordance with the sampling schedule. Adverse events and
failures to monitor must also be explained and reported on the relevant DMR.
Allowable Non-Stormwater Discharges
This permit regulates stormwater discharges. Non-stormwater discharges which shall be allowed in
the stormwater conveyance system are:
a. All other discharges that are authorized by a non-stormwater NPDES permit.
b. Uncontaminated groundwater, foundation drains, air -conditioner condensate without added
chemicals, springs, discharges of uncontaminated potable water, waterline and fire hydrant
flushings, water from footing drains, flows from riparian habitats and wetlands.
c. Discharges resulting from fire -fighting or fire -fighting training, or emergency shower or eye wash
as a result of use in the event of an emergency.
4. Best Management_ Practices (BMPs
Measures or practices used to reduce the amount of pollution entering surface waters. BMPs may
take the form of a process, activity, or physical structure. More information on BMPs can be found at:
http•//cfpub epa gov/nodes/stormwater/menuofbml2s/index cfm.
5. Bypass
A bypass is the known diversion of stormwater from any portion of a stormwater control facility
including the collection system, which is not a designed or established operating mode for the facility.
6. Bulk Storage of Liquid Products
Liquid raw materials, manufactured products, waste materials or by-products with a single above
ground storage container having a capacity of greater than 660 gallons or with multiple above ground
storage containers located in close proximity to each other having a total combined storage capacity
of greater than 1,320 gallons.
7. Certificate of Coverage
The Certificate of Coverage (COC) is the cover sheet which accompanies a General Permit upon
issuance and lists the facility name, location, receiving stream, river basin, effective date of coverage
under the permit and is signed by the Director.
8. Clean Water Act
The Federal Water Pollution Control Act, also known as the Clean Water Act (CWA), as amended, 33
USC 1251, et. seq.
9. Division or DWO
The Division of Water Quality, Department of Environment and Natural Resources.
Part IV Page 1 of 4

Permit No. NCS000562
10. Director
The Director of the Division of Water Quality, the permit issuing authority.
11. EMC
The North Carolina Environmental Management Commission.
12. Grab Sample
An individual sample collected instantaneously. Grab samples that will be analyzed (quantitatively or
qualitatively) must be taken within the first 30 minutes of discharge.
13. Hazardous Substance
Any substance designated under 40 CFR Part 116 pursuant to Section 311 of the Clean Water Act.
14, Landfill
A disposal facility or part of a disposal facility where waste is placed in or on land and which is not a
land treatment facility, a surface impoundment, an injection well, a hazardous waste long-term
storage facility or a surface storage facility.
15. Measureable Storm Event
A storm event that results in an actual discharge from the permitted site outfall. The previous
measurable storm event must have been at least 72 hours prior. The 72 -hour storm interval may not
apply if the permittee is able to document that a shorter interval is representative for local storm
events during the sampling period, and obtains approval from the local DWQ Regional Office. Two
copies of this information and a written request letter shall be sent to the local DWQ Regional Office.
After authorization by the DWQ Regional Office, a written approval letter must be kept on site in the
permittee's SPPP.
16. Municipal Separate Storm Sewer System
A stormwater collection system within an incorporated area of local self-government such as a city or
town.
17. No Exposure
A condition of no exposure means that all industrial materials and activities are protected by a storm
resistant shelter or acceptable storage containers to prevent exposure to rain, snow, snowmelt, or
runoff. Industrial materials or activities include, but are not limited to, material handling equipment
or activities, industrial machinery, raw materials, intermediate products, by-products, final products,
or waste products. DWQ may grant a No Exposure Exclusion from NPDES Stormwater Permitting
requirements only if a facility complies with the terms and conditions described in 40 CFR
§122.26(g).
18. Notice of Intent
The state application form which, when submitted to the Division, officially indicates the facility's
notice of intent to seek coverage under a General Permit.
19. Permit Issuing Authority
The Director of the Division of Water Quality (see "Director" above).
20. Permittee
The owner or operator issued this permit.
Part IV Page 2 of 4 Pages

Permit No. NCSO(10562.
21. Point Source Discharge of Stormwater
Any discernible, confined and discrete conveyance including, but not specifically limited to, any pipe,
ditch, channel, tunnel, conduit, well, or discrete fissure from which stormwater is or may be
discharged to waters of the state.
22. Representative Outfall Status
When it is established that the discharge of stormwater runoff from a single outfall is representative of the
discharges at multiple outfalls, the DWQ may grant representative outfall status. Representative outfall status
allows the permittee to perform analytical monitoring at a reduced number of outfalls.
23. Secondary Containment
Spill containment for the contents of the single largest tank within the containment structure plus
sufficient freeboard to allow for the 25 -year, 24-hour storm event.
24. Section 313 Water Priority Chemical
A chemical or chemical category which:
b. Is listed in 40 CFR 372.65 pursuant to Section 313 of Title III of the Superfund Amendments and
Reauthorization Act (SARA) of 1986, also titled the Emergency Planning and Community Right -
to -Know Act of 1986;
c. Is present at or above threshold levels at a facility subject to SARA title III, Section 313 reporting
requirements; and
d. Meets at least one of the following criteria:
L Is listed in appendix D of 40 CFR part 122 on Table II (organic priority pollutants), Table III
(certain metals, cyanides, and phenols) or Table IV (certain toxic pollutants and hazardous
substances);
ii. Is listed as a hazardous substance pursuant to section 311(b) (2) (A) of the CWA at 40 CFR
116.4; or
iii. Is a pollutant for which EPA has published acute or chronic water quality criteria.
25. Severe Property Damage
Substantial physical damage to property, damage to the control 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 does not mean economic loss
caused by delays in production.
26. Significant Materials
Includes, but is not limited to: raw materials; fuels; materials such as solvents, detergents, and plastic
pellets; finished materials such as metallic products; raw materials used in food processing or
production; hazardous substances designated under section 101(14) of CERCLA; any chemical the
facility is required to report pursuant to section 313 of Title III of SARA; fertilizers; pesticides; and
waste products such as ashes, slag and sludge that have the potential to be released with stormwater
discharges.
27. Significant Spills
Includes, but is not limited to: releases of oil or hazardous substances in excess of reportable
quantities under section 311 of the Clean Water Act (Ref: 40 CFR 110.3and 40 CFR 117.3) or section
102 of CERCLA (Ref: 40 CFR 302.4).
28. Stormwater Discharge Outfall (SDO)
The point of departure of stormwater from a discernible, confined, or discrete conveyance, including
but not limited to, storm sewer pipes, drainage ditches, channels, spillways, or channelized collection
areas, from which stormwater flows directly or indirectly into waters of the State of North Carolina.
Part IV Page 3 of 4 Pages

i
a , . Permit No. NCS000562
29. Stormwater Runoff
The flow of water which results from precipitation and which occurs immediately following rainfall
or as a result of snowmelt.
30. Stormwater Associated with Industrial Act vitX
The discharge from any point source which is used for collecting and conveying stormwater and
which is directly related to manufacturing, processing or raw material storage areas at an industrial
site. Facilities considered to be engaged in "industrial activities" include those activities defined in 40
CFR 122.26(b)(14). The term does not include discharges from facilities or activities excluded from
the NPDES program.
31. Stormwater Pollution Prevention Plan
A comprehensive site-specific plan which details measures and practices to reduce stormwater
pollution and is based on an evaluation of the pollution potential of the site.
32. Total Maximum Daily Load (TMDQ
TMDLs are written plans for attaining and maintaining water quality standards, in all seasons, for a
specific water body and pollutant. A list of approved TMDLs for the state of North Carolina can be
found at httn://portal.ncdenr.orgjweb jwq/Us/mtu jtmdl.
33. Toxic Pollutant
Any pollutant listed as toxic under Section 307(a) (1) of the Clean Water Act.
34. Vehicle Maintenance Activity
Vehicle rehabilitation, mechanical repairs, painting, fueling, lubrication, vehicle cleaning operations,
or airport deicing operations. ,
35. Visible Sedimentation
Solid particulate matter, both mineral and organic, that has been or is being transported by water, air,
gravity, or ice from its site of origin which'can be seen with the unaided eye.
36. 25 -year. 24 hour Storm Event
The maximum 24-hour precipitation event expected to be equaled or exceeded, on the average, once
in 25 years.
Part IV Page 4 of 4 Pages
I

f
NCS000562
ALV4,WA®
HCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Pat McCrory Charles Wakild, P.E. John E. Skvarla, III
Governor Director Secretary
STAFF REVIEW AND EVALUATION
NPDES Stormwater Permit, revised 1/8/2013
Facility Name: Horsehead Metal Products, Inc., Horsehead Corporation owner
NPDES Permit Number: NCS000562
Facility Location: 484 Hicks Grove Road, Mooresboro, NC, Rutherford County
Type of Activity: High purity zinc production from zinc oxide
SIC Code: 3341
Receiving Streams: Broad River, see Figure 1
River Basin: Broad River Basin, Sub -basin 03-08-02
Stream Classification & condition: Class C; no TMDL, no 303(d)
Proposed Permit Requirements:
Monitoring Data:
Response Requested by:
Central Office Staff Contact:
Special Permitting Issues:
See attached draft permit.
New permit, no historical data exists.
July 16, 2012
Return to: Ken Pickle [phone]
Risk considerations',`,,-, Y .
Ratin Scaler'1. minimal risk to,;10 risk factors. resent
Compliance history
No history: rate 1
Benchmark exceedance
A new site, with no past measurements: rate 1
Location (TMDL, T&E species, etc)
Downstream benthos impaired; downstream WS -IV and WS -IV CA:
rate 6
Other factors:
Other factors in aggregate present normal risks for most industrial sites:
• Zinc solutions, lead, and acids
rate 6
present.
• Industry is unique in NC, no other
similar facilities.
• A start-up facility.
• Multiple tanks, rail unloading,
potential for process fluids to be
exposed.
® Avoiding heavy metal solutions
discharges depends on proper
operator actions assisted by
extensive containments.
Risk and DWQ scrutiny rating:
14/40 - moderate stormwater pollution risks
Page 1 of 4

NCS000562
Description of Onsite Activities:
• Horsehead receives zinc oxide material, and refines it into a high purity product. Byproducts are
secondary in importance, including minor amounts of lead and silver production.
Documents Reviewed:
• NPDES stormwater permit application materials, received in final form May 8, 2012.
• US Fish and Wildlife Service threatened and endangered species inventory for Rutherford'County
• Natural Heritage Program staff reports no rare aquatic species in the Broad River in this vicinity.
• EPA Sector -Specific Permit, 2008. SIC 3341 covered, but no benchmarks assigned.
• Integrated Report 303(d) List, 2010 final: upstream WS -IV and downstream WS -IV and CA impaired
for aquatic life, but the actual receiving reach is classified C and is not listed.
• July 2008 Broad River Basinwide Plan: no comment on this site (didn't exist); in 2008 the. receiving
water is shown as supporting its classified uses.
History:
• First time stormwater permit application.
• First time NPDES wastewater permit issued Nov. 11, 2011, NC0089109.
Figure 1: Map of Facilityv
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Page 2 of 4

NCS000562
Central Office Review Summary:
1. Owner's Other Permits:
o NCO089109 issued for wastewater discharges. Permit limits on Q, Cd, F, Pb, pH. Monitoring w/o
limits on TSS, NH3, Al, Sb, As, Cl, Cr, Co, Cu, Fe, Ni, Sri, Zn. Also Chronic Toxicity and NTU.
2. General Observations: Extensive containment & management procedures planned. On-site zinc solutions are
materials of primary concern.
3. Impairment: Receiving water not listed as impaired on 303(d) IR.
4. Threatened and Endangered: None identified by USF&WS website; NHP staff contact reports no rare aquatic
species in the Broad River in this vicinity.
5. Location: Close to Brice in southern Rutherford County, on the south bank of the Broad River. Site elevation
relative to the Broad .River discharge point suggests energy dissipation concerns for stormwater flows.
6. Industrial Changes Since Previous Permit.*' New permit, no changes.
7. Analytical Monitoring Notes: Quarterly monitoring.
8. Qualitative Monitoring Notes: Quarterly visual monitoring.
Permit Recommendations: Analytical Monitoring
1. Analytical monitoring has been set to quarterly during a measurable storm event as defined in Part H Section B.
The recommended quarterly monitoring is more frequent than most standard industrial stormwater permits.
This facility handles heavy metal solutions, and is without a track record of performance in North Carolina.
Quarterly sampling is recommended initially. DWQ can consider reducing the sampling frequency later in the
permit term if supported by subsequently collected data.
2. The permittee must document the total precipitation for each sampled event. If no discharge occurs during the
sampling period, the permittee must submit a monitoring report indicating "No Flow" within 30 days of the end
of the three-month sampling period.
3. Analytical monitoring parameters:
a. Metals: Zinc, lead, cadmium. Based on Zn solutions on site; based on identification of Pb as a
secondary byproduct; Cd chosen based on applicant's report that it would be the most prevalent impurity
in the feedstock.
b. Organics: TPH, based on significant on-site presence of hydrocarbon solution as the solvent vehicle for
DEHPA, a key process ingredient.
c. Conventional pollutants: TSS, pH, TN, TP. Nutrients based on N and P compounds reported as
present in the manufacturing process.
4. Benchmarks are referenced in the text for all analytical parameters. For the first term of the permit, the permit
requires monitoring only. Permittee to assemble monitoring results from the first two years of site operation,
interpret them, and present a summary report to DWQ within 6 months of obtaining results from the eight
monitoring events over the two year period. While DWQ considers the summary report, and until DWQ acts in
response to the summary report, the permittee will continue quarterly monitoring as otherwise provided in the
permit.
5. Qualitative monitoring also must be accomplished during a measureable storm event.
6. Vehicle maintenance area monitoring is not applicable since this facility will have only one stormwater outfall.
7. The permittee is required to continue monitoring until the permit is renewed. See Footnote 1 of Table 2.
Discussions with permittee: DWQ met with Tim Basilone, Horsehead Vice President, and with Forrest Westall,
consultant, in an initial meeting, a follow-up meeting prior to application submittal, and a meeting subsequent to the
initial submittal of application materials. In addition, email correspondence was used to request additional
information on the proposed project.
Page 3 of 4.

r
NCS000562
Recommendations: Based on application materials received on March 28, 2012; and again on.April 2; and again on
May 8, SPU considers the combined application materials sufficient to issue an individual Stormwater Permit. We
are requesting Regional Office review comments, and full or qualified emicuri-ence.
Prepared by (Signature) Signature of Ken Pickle Date
- Stoi-mwater-Perm itting Unit -Supervisor _ditto Date
for Bradley Bennett
Concurrence by Regional Office Y -i ^-' . —Date t
ateReRO Waler Quality Supervisor —Date—
Regional
gional Office Staff' Comments (attach additional pages as necessaa)
The ARU/SWPS' of/ers the follotiving comments on the draft permit:
1. Require Horsehead Corporation to have the StornnvaterPollution Prevention Plan (SWPPP),in place prior to start-
s. of operations. Due to the complexity of'the operations (and that the operation does not, fall under a general permit
for a knoivnn industrial sector), the ARO believes it is prudent to have the SYI'PPP in place at the tune of industrial
operations.
2 -,Phe "back zip " plan for potential failures/problems with the detention basins/recycle loop system should be stated
Within the SWPPP. If a failure occurs, will this be a pump and hazel situation? Will this be an operational shin dotvrr?
Iforsehead needs to state what actions will be taken should these problems occur.
This is especially important to the ARO because, dale to state legislation passed in 2011 fret' Session Lasv 201.1-394,
Sec. 91, it is ARO's understanding that the regaiiretrnents for lluthorizat on to Construct Permitting were repealed, for
industrial finer#mits of this nature. Therefore, ive cannot require the company to provide specific information on
detention times for the various basins proposed.
3. Upon review of the wastewaterpermit, andsub.sequent revieiv of'the stormwater draftpermit, ARO recommends that
chlorides be added to the quarterly monitoring. Chlorides are toric to aquatic life, difficult to treat, and maybe present
in the stormwater as well.
4. ARO reconnnends that quarterly acute toxicity testing (or the most appropriate toxicity testing) be required in the
permit (please contact Carol Hollenkamp of ATU for specific language to use in the permit). This testing is
recommended as it nzimics the synergistic effects of the stormrvater discharge and its potential effect on the receiving
stream.
5. ARO would not object to conditional language being placed in the permit to state (basically), that, after 3 years of
successfid quarterly data has been collected (under bench marks and toxicity ))asses ), monitoring thay be reduced to
semi-annually. Three years oj'data, after the beginning of'process operations, should be safcieni to deternnine if
measures are tivorkirng successfully.
Page 4 of 4

Bennett, Bradley
From:
Bennett, Bradley
Sent:
Friday, September 18, 2015 2:09 PM
To:
'jharris@horsehead. net'
Cc:
Davidson, Landon; Aiken, Stan E; Walker, Fred; Pickle, Ken; 'Robin. [e-mail]'
Subject:
Response on Stormwater Pond Question
Jim,
After our discussion this morning I just wanted to get back in touch on the issue of placing Pond 1 ("Ll" shaped pond
near the river) back into service. As discussed, we would like to receive any monitoring results that you have available
for the Pond 1 discharge that has occurred recently. These results should be forwarded to Landon Davidson (DWR) and
Stan Aiken (DEMLR) in our Asheville Regional Office. It is our understanding from our discussions that you have:
• Fixed the leak in the containment in the electrowinning area.
• Put in place a plug in the stormwater drainage system near the electrowinning area.
• Cleaned all the cells of the Pond 1 system.
• Cleaned the material from the energy dissipator at Pond 1.
• Flushed the drainage to pond 1 and you were planning to flush again today.
• Checked all containment systems and stormwater systems in the remainder of the site and have no remaining
non-stormwater flow discharging in the stormwater drainage to Pond 1.
• Instituted new procedures for containment systems and stormwater ponds to assure that needed removal of
material is done in a timely manner and have adequate freeboard in all containment areas.
Given all of the above efforts and the assurances that leaks have been corrected and no non-stormwater flow is present
the Horsehead facility can bring the pond 1 stormwater system back on line. In conjunction with this, you must be
prepared to monitor any discharge from the pond when it first begins in accordance with stormwater permit monitoring
requirements as outlined in Table 1 of the permit. You must also continue this monitoring daily while discharge from
the system occurs.
Please note that we consider this a temporary arrangement until we can conduct our site visit next Wednesday (9/23)
and have further discussions within our agency and with you and other staff with your facility.
If you have any questions, please contact me.
Bradley Bennett
Stormwater Permitting Program Phone: [phone]
NO Division of Energy, Mineral and Land Resources Fax: [phone]
1612 Mail Service Center Email: bradley.benneftoncdenr.gov
Raleigh, NO 27699-1612 Web: http://portal.ncdenr.org/web/Ir/stormwater
Email correspondence to and from this address may be subject to public records laws

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October 9, 2015
Via -Electronic Mail (landon.davidson Ca7nedenr.gov) and U.S. Mail -
Mr. G. Landon Davidson
North Carolina Department of Environment and Natural Resources
Water Quality Regional Operations
Asheville Regional Office
2090 U.S. Highway 70
Swannanoa, NC 28778
Re: Notice of Violation/Notice of Intent to Enforce
NOV-2015-DV-0188 (BIMS Inc. #201501151).
Rutherford County
Dear Mr. Davidson:
On September 24, 2015, Horsehead Metal Products, LLC (Horsehead) received the above -
referenced Notice of Violation/Notice of Intent to Enforce (NOV) related to a release of low pH
solution at the Mooresboro facility. As requested, this letter provides a report assessing the
cause, significance, and extent of the release and a plan listing all actions to prevent future
releases. Ot
With respect to the allegation of discharge in violation of G.S. 143-215.83, the release of the
solution from the cellhouse containment was mitigated such that any discharge to the Broad
River would not have resulted in a violation of G.S. 143-215.83. Specifically, the definition of
"discharge" in Article 21a of Chapter 143 provides in relevant part as follows:
(� "Discharge" shall mean, but shall not be limited to, any emission, spillage,
�j leakage, pumping, poining, emptying, or dumping of oil or other hazardous
substances into waters of the State or into waters outside the territorial limits of
the State which affect lands, waters or uses related thereto within the territorial
limits of the State, or upon land in such proximity to waters that oil or other
hazardous substances is reasonably likely to reach the waters, but shall not
include amounts less than quantities which may be harmful to the public health or
welfare as determined pursuant to G.S. 143-215.77A;
G.S. 143-215.77(4). Section 143-215.77a provides that quantities of designated hazardous
substances for purposes of this Article are the quantities of designated hazardous substances as
established by. the EPA pursuant to Section 311 of the Clean Water Act. The EPA has
promulgated the quantities for designated hazardous substances at 40 C.F.R. § 117.3. The
regulatory quantity for sulfuric acid is 1,000 pounds. Given the concentration of sulfuric acid in
the released process solution and the subsequent efforts to mitigate any portion of the release
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which reached the stormwater system, there is no reasonable potential that the regulatory
quantity for a "discharge" under G.S. 143-215.77a could have been released to the Broad River.
Upon discovery of the lower than typical pH in the energy dissipater on September 5, 2015, plant
personnel closed the main gate valve at the outfall to the Broad River and the gate valve on the
energy dissipater at Basin 1. The energy dissipater is the first structure in the Basin 1 system and
serves to slow stormwater as it enters Basin 1. Since there had been an extended period without
any substantial rainfall prior to September 5, 2015, Basin 1 was empty and no discharge to the
Broad River occurred to that point in time. The gate valves at the energy dissipater and Basin 1
remained closed throughout the investigation of the source of the lower than typical pH.
Following a rain event on September 9, 2015, approximately 200,000 gallons of water was
removed by vacuum truck from Basin 1. This water was recycled for use in the plant process.
Additionally, sediment in the energy dissipater and sediment in Basin 1 with any visible impacts
fiom the solution release were removed and placed in roll -off containers. Although the gate
valve at Basin 1 remained closed, a leak near the gate valve in the discharge structure was
discovered which allowed water fiom the basin to be discharged to the Broad River. While the
leak continued until a repair was completed at 7 p.m. on September 11, the remediation of the
sulfuric acid solution released to the stormwater system was concluded on September 9t" and
thus mitigated any impacts to the stortnwater in Basin 1 such that the quantity of sulfuric acid
discharges would not have reached the regulatory quantity for a "discharge" in violation of G.S.
143-215.83.
Additionally, despite any elevated concentrations of cadmium, lead and zinc in the water sample
referenced in the NOV, these elevated concentrations do not constitute an unlawful discharge
pursuant to G.S. 143-215.83. These metals are covered by the benchmark sampling
requirements under NPDES Stormwater Permit No. NCS000562, and therefore any elevated
levels of these metals would be addressed under the terms of that Permit. As such, any discharge
with these elevated metals would not be a discharge in violation of G.S. 143-215.83.
1. Report on the Release
On the evening of September 5, 2015, plant personnel identified a potential problem during the
course of routine inspection at Basin 1 of the facility stormwater system. Using a basic pH
testing strip, testing indicated a pH less than 6.0 Standard Units in the stormwater entering the
energy dissipater which is the fust structure in the Basin 1 system.' Furfiher investigation
indicated that the source of the subject water may have been material inadvertently making its
way into the storm drain system from a malfunctioning pump in the vicinity of the cellhouse
earlier that day. On September 6, 2015, testing of water entering the energy dissipater again
indicated a lower than typical pH. A subsequent investigation was undertaken to identify the
source of water entering the stormwater system. This investigation revealed water entered the
r Basin 1 is a sedimentation basin, and the energy dissipater serves to slow stormwater entering Basin 1.
Business Confidential Information

X11
HORSEHEAD METAL PRODUCTS, INC.
484: HICKS GROVE ROAD -
MOORESBORD, NORTH CAROLINA 28114
storm drains in the vicinity of the cellhouse, at which time efforts were underway to identify the
source.
On September 7, 2015 an investigation was initiated to identify potential sources of water
entering the stormwater system in the vicinity of the cellhouse. Two contractors were engaged to
assist in this effort. One company conducted a CCTV inspection inside the storm line in the
vicinity of the cellhouse to identify the location of water entering the stormwater system. The
other company installed an air bladder to prohibit water flow from the area into the downstream
stormwater system. While the bladder was effective in stopping any additional flow from the
cellhouse area, the results of the CCTV inspection were inconclusive as to the location of the
water entering the stormwater pipe.
On September 8, 2015, a detailed surface investigation was initiated in the cellhouse area to
identify locations where seepage into the stormwater system may have occurred. A void located
in a joint where a recirculation tank is in contact with the cellhouse secondary containment
structure was discovered. The material escaped, as a consequence of a pump malfunction at the
north sump of the cellhouse containment, when the water/acid solution in the containment area
of the cellhouse rose to an elevation above the joint.
The containment area under the cellhouse is designed to capture water solutions, including rain
water, wash water and cell cleaning solutions from the cellhouse. The composition of the
material in the containment area typically is approximately 93% water, 6.1 % sulfuric acid, 85
ug/1 cadmium,17.3 g/1 zinc, 24.4 mg/l lead, and 203 mg/l chlorides. The solutions are recovered
in the containment area under the cellhouse and pumped to the acid tank and then to the solvent
extraction area for use in the process.
When the low pH water in the stormwater system was discovered on September 5, 2015, the
pump in the North sump that sends the solution to the acid tank had malfunctioned and was
being repaired. While the pump was being repaired, temporary pumps were installed in the
containment area to pump the solution. The liquid levels in these containment structures are
monitored periodically by plant personnel during each operating shift. At the time of the
containment breach, the liquid level in the basement was higher than normal because of the
pump malfunction. Because of this unusually high liquid level in the basement, the liquid
entered the open joint where the wall of the recirculation tank meets the floor of the containment
area. Once the elevation of liquid in the basin rose to the elevation of the joint, the solution
seeped into the joint and entered the area under the recirculation tank and the underlying gravel
layer. The solution traveled through the backfill and infiltrated the stormwater drainage pipe
backfilling the area. The liquid seeped into the stormwater pipe and traveled in the storm drain to
Basin 1.
Business Confidential Information

H ORSEHEADM&A:L PRODUCTS, INC.
"- 484 HICKSGRovE ROAD
MOORESSORO, NORTH CAROUNA281 14
Although plant personnel could not determine whether a reportable quantity of sulfuric acid had
been released, Horsehead called the NRC as a precautionary measure on September 9, 2015 at
3:30 pm, to advise the agency of the apparent release of process solution from the base of
secondary containment structure. After the call to the NRC, Horsehead notified the DENR
Regional Office by telephone. We understand that DENR notified the Forest City Fire
Department.
All secondary containment structures in the facility are constructed of reinforced concrete with
containment sizing based on 110% of the largest tank in the containment. Following the
discovery of the unsealed joint in the containment area under the cellhouse, Horsehead engineers
and maintenance personnel confirmed that no other areas in the facility have similar seal
problems.
Based on the available information, any discharge of the solution from the cellhouse containment
area to the Broad River was minimized through mitigation efforts following the initial discovery
of low pH at the energy dissipater. As soon as the low pH condition of water entering the energy
dissipater was detected on September 5, 2015, plant personnel closed the main gate valve at the
outfall to the Broad River and the gate valve on the energy dissipater at Basin 1. Since there had
been an extended period without any substantial rainfall prior to September 5, 2015, Basin 1 was
empty and no discharge to the Broad River occurred to that point in time.
As noted above, on September 9th and 10th, a rain event of approximately 0.7 inches of
precipitation occurred and stormwater entered Basin 1. At the time, the main gate valve on the
stortrwater discharge outfall was closed and the water was retained in the basin. On September
9, 2015, a leak near the gate valve in the discharge structure was discovered which allowed water
from the basin to be discharged. Water discharged from the discharge structure was tested for
pH and found to be below 6.0 Standard Units. Vacuum trucks were mobilized to remove water
from Basin 1. Removed water was recycled for use in the plant process.
The small leak that allowed water to enter the Broad River resulted from a crack in the concrete
box that serves as the housing for the main gate valve. Hydraulic cement was used to seal the
crack and stop water from leaking through the concrete wall. These repairs were completed on
Friday, September 11, 2015, at approximately 7 p.m.
We determined that water at the concrete discharge structure entered the Broad River from mid-
day on September 9th until 7 p.m. on September 11. The duration of the leak was 55 hours. We
estimated the flow rate from the leak to be 10-15 gallons per minute (GPM). Sample analytical
results showed water discharged to the Broad River contained 3.36 mg/L cadmium, 0.541 mg/L
lead and 685 mg/L of zinc.
Business Confidential lAnnation

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2. Plan to Prevent Future Releases in Containment Areas
The following actions have been implemented to prevent a future releases:
As noted above, the defective joint in the containment area under the cellhouse in Area
200 has been repaired. inspections will be performed on the containment areas for
cracks and repairs will be made as required.
A high level alarm will be installed on the cellhouse containment to alert personnel if
liquid levels are elevated so action can be taken to draw the level down.
Weekly inspections have been initiated at the inlet and outlet of Basin 1, including
field tests for pH.
Horsehead remains committed to operating in a manner protective of the environment and
appreciates the Department's continued assistance as we continue through the startup phase at
the Mooresboro facility. If additional information is needed in support of this request, please call
me at 828-919-3139.
Sincerel ,
Jim Harris
Environmental Manager
Business Confidential Information

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Environmental Spill History for Horsehead Metal Products, 484 Hicks Grove Road,
Mooresboro, IVC 28114
® April 25, 2015 Depleted Solution Spill
May 19, 2015 Depleted Solution Spill
® September 8, 2015 Cellhouse Containment Breach

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North Carolina Department of Environmental Quality
a
Pat McCrory Donald R. van der Vaart
Governor Secretary
September 24, 2015
7014 0510 0000 4466 2374
Anthony K. Staley
Horsehead Corporation
484 Hicks Grove Road
Mooresboro, N.C. 28114
Subject: NOTICE OF VIOLATION/NOTICE OF INTENT TO ENFORCE
NOV-2015-DV-0188 (BIMS Inc. #201501151)
Horsehead Corporation
Rutherford County
Dear Mr. Staley:
On September 9, 2015, the Division of Water Resources (DWR) visited your facility In response to notification that a
release of low pH solution was occurring. The low pH solution had infiltrated into the stormwater system through
subsurface soils and/or stone base material at the cell house. The solution was actively discharging from your
stormwater system to the Broad River when DWR staff arrived onsite. The discharge to the Broad River did not cease
completely until September 121' according to site personnel; it is unclear when the discharge to the Broad River began
and the rate of discharge throughout the release period. A water sample of the solution being discharged indicated
elevated concentrations of metals such as cadmium, lead and zinc at levels above surface water standards.
Violations
As a result of the above -referenced release, the following violations are noted:
(1) illegal discharge
(2) 011 Pollution and Hazardous Substances Control Act — Unlawful Discharge
Violation I. Discharge Without a Valid Permit
G.S. 143-215.1 (a) (1) - "Activities for Which Permits Required. — No person shall do any of the following things or carry
out any of the following activities unless that person has received a permit from the Commission and has complied with
all conditions set forth in that permit.
(1) Make any outlet into the Waters of the State."
Violation 2. Unlawful Discharge
G.S. 143-215.83 — states that "It shall be unlawful, except as otherwise provided in this Part, for any person to discharge, _
or cause to be discharged, oil or other hazardous substances into or upon any waters, tidal flats, beaches, or lands within
this State, or into any sewer, surface water drain or other waters that drain into the waters of this State, regardless of _
the fault of the person having control over the oil or other hazardous substances, or regardless of whether the discharge
was the result of intentional or negligent conduct, accident or other cause."
Waley Quality Regional Operations - Asheville Regional Office
2090 US. Highway 70, Santa=, =, North Carolina 28778
Phone: [phone] FAX: [phone]
Internet httpllportal.ncdenrorglwebtwq
An Equal Opportunity 1 ABlrtnetive Action Employer

Anthony N. Staley
September 24, 2015
Page 2 of 2
Required Response
This Office requests that you respond to this letter in writing within 15 days of receipt of this Notice. Your response
should be sent to this Office at the letterhead address. Your response should address the following items:
1. Please submit a report assessing the cause, sgniffm ante, and extent of the release. The report should contain
details of the estimated quantity of solution released (i.e., amount of product loss, estimated discharge rate
to Broad River, etc.), conditions under which the solution was released and chemical composition of the
solution. Please include specific details as to why secondary containment and spill prevention measures
failed during the release. You are to Include a narrative describing the operational condition of the
containment structures (i.e., seal between tank and cell house floor, etc.) prior to and during the release.
You are to identify other areas within the plant with similar seals as well as providing a narrative describing
in detail the construction specifications of secondary containment structures at the facility. You are also to
submit a timeline of events associated with the release (i.e., time discharge first observed, time discharge to
Broad River observed, notification times, etc.).
2. Please submit a plan listing all actions you will take to prevent future releases including any enhancements
to containment structures, changes in operation and maintenance of existing containment structures or
how similar seals will be evaluated for integrity. Your comments should address but are not limited to the
following issues: spill response plan, preventative maintenance on your containment structures, monitoring
of secondary containment integrity, etc.
' ��iac gN�rcrf toesfa�sh h/qS
Fines may be imposed under NCGS 143-215.6A(a)(1) pf not more than $25,000 per violation of any classification,
standard, limitation or management practice established pursuant td G.S. 143-214.1. Additional action may include the
issuance of a special order against you under the authority of G.S. 143-215.2A or a request to the Attorney General to
institute an action for Injunctive relief. If any failure to act is continuous, penalties may be assessed not to exceed a
maximum penalty of $25,000 per day per violation under NCGS 143-215.6A (b)�o long as the violation continues. Your
response to this correspondence will be considered in any civil penalty assessment process that may occur.
This office requires that the violations, as detailed above, be abated Immediately and properly resolved. Thank you
for your attention to this matter. This Office is considering sending a recommendation for enforcement to the Director
of the Division of Water Resources regarding these issues and any future/continued violations that may be encountered.
If you have any question regarding this Notice, please feel free to contact me direct at 828-296-4680 or via email at
[e-mail].
Sincerely, -0EQ au�Lorz 7e�Gon�nH
�P����irs on Gourilq ?//O�d7io�
L/
G. Landon Davidson, P.G., Regional Supervisor
Water Quality Regional Operations
Asheville Regional Office
cc: Jim Harris, Environmental Manager (via email)
Brent Burch —NCDEQ D W M HWS (via email)
Stan Aiken — NCDEQ DEMLR.(vla email)
Bradley Bennett —NCDEQ DEMLR (via email)
WQ Asheville Files
MSC 1617 -Central Files -Basement
WQ Enforcement

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_.._.._.._ ._.._.._.._..7 Area 600 j
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Waelz Oxide Wash/Leach / ! I PLINT ! I =gConcentrate
SkimmingsNeutralization i Process
ii i_.._.._.._.._.._.._.._..�
i Area 1001
_.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._____ ___ _ _I
SX Extraction SX Washing SX Stripping
i
..................... i
i
su Gypsum Cementation i SX Depletion ! - - - - - - - - - .- i
i Precipitation i
I
i ! Area 200 Electrowinning �
i Bleed
i !
I Treatment i
I
i
Area 400
ii
Final ._.._ ..............
Effluent Treatment
Area 300
Melting i
Zinc Concentrate,, i
Casting i
i i
Area 500
15

DRAFT NCS000562
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE STORMWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
e4 �
In compliance with the provisions of North Caroli 'a" General Statute 143-215.1, other
lawful standards and regulations promulgated an`d'ad:opted by -the North Carolina
Environmental Management Commission, and theFederal Water Pollution Control Act, as
amended,
Horsehead Corporation
is hereby authorized to ,discharge industrial stormwater from a facility located at
.Horsehead'Metal Products, Inc.
4,84, Hicks Grove Road
Mooresboro, North Carolina
N Rutherford County
to receiving waters designated as the Broad River, a class C water in the Broad River Basin,
in accordance with the discharge limitations, monitoring requirements, and other
conditions set forth in Parts I, II, III, and IV hereof.
Note: Draft Permit Dates are Approximate
This permit becomes effective April 1, 2013.
This permit and the authorization to discharge expire at midnight on March 31, 2018.
Signed this day March 25, 2013.
for Charles Wakild, P.E., Director
Division of Water Quality
By the Authority of the Environmental Management Commission

DRAFT Permit No. NCS000562
TABLE OF CONTENTS
PART I INTRODUCTION
Section A: Individual Permit Coverage
Section B: Permitted Activities
Section C: Location Map
PART II MONITORING, CONTROLS, AND LIMITATIONS' FOR PERMITTED
DISCHARGES
Section A: Stormwater Pollution PreventionTlan.;,.
Section B: Analytical Monitoring RequiYements�'
Section C: Qualitative Monitoring,R�equirements
PART III STANDARD CONDITIONS FOR NPDES STORMWATER INDIVIDUAL PERMITS
Section A: Compliance and Liability
1. Com'.pliarice Schedule
2. Duty to Comply
3. Duty to Mitigate
4. Civil and Criminal Liability
S. Oil and Hazardous Substance Liability
6. Property Rights
7. Severability
8. Duty to Provide Information
9. Penalties for Tampering
10. Penalties for Falsification of Reports
11. Onshore or Offshore Construction
12. Duty to Reapply
Section B: General Conditions
1. Permit Expiration
2. Transfers
3. Signatory Requirements
i

DRAFT Permit No. NCSOOOS62
4. Permit Modification, Revocation and Reissuance, or Termination
S. Permit Actions
6. Annual Administering and Compliance Monitoring Fee
Requirements
Section C: Operation and Maintenance of Pollution Controls
1.
Proper Operation and Maintenance
2.
Need to Malt or Reduce Not a Defense
3.
Bypassing of Stormwater Control,Facitities
Section D: Monitoring
and Records
1.
Representative Sampling
2.
Recording Results a
3.
Flow Measurements
4.
Test Procedures .11/
S.
Representative. Outfall ­­,/
6.
:
Records Retention:,, r
7.
Inspectioh qn" Ehtry
Section E: Reporting Requirements
1.
Disschar-ge;.'Monitoring Reports
2.
Submitting Reports
3.
Availability of Reports
4.
Non-Stormwater Discharges
S.
Planned Changes
6.
Anticipated Noncompliance
7.
Spills
8.
Bypass
9.
Twenty-four Hour Reporting
10.
Other Noncompliance
11.
Other Information
PART IV DEFINITIONS
11

DRAFT Permit No. NCS000562
PART I INTRODUCTION
SECTION A: INDIVIDUAL PERMIT COVERAGE
During the period beginning on the effective date of the permit and lasting until expiration,
the permittee is authorized to discharge stormwater associated with industrial activity.
Such discharges shall be controlled, limited, monitored, and reported as specified in this
permit..
If industrial materials and activities are not exposed to precipitation or runoff as described
in 40 CFR §122.26(g), the facility may qualify for a No Expo`sure Exclusion from NPDES
stormwater discharge permit requirements. Any o,wneror operator wishing to obtain a No
Exposure Exclusion must submit a No Exposure Certtfitation Notice of Intent (NOI) form to
the Division; must receive approval by the Division must maintain no exposure conditions
unless authorized to discharge under a valid NPD.ES "s -tor water permit; and must recertify
the No Exposure Exclusion annually.'' a> `
/-j
SECTION B: PERMITTED ACT-IVITIESs' t
Until this permit expires or is modified or, revoked, the permittee is authorized to discharge
stormwater to the surface waters of North Carolina that has been adequately treated. and
managed in accordance with=the terms and conditions of this permit. All stormwater
discharges shall be in accordancewith the conditions of this permit.
Any other point source discharge to surface waters of the state is prohibited unless it is an
allowable non-stormwater discharge or is covered by another permit, authorization, or
approval. The stormwater discharges allowed by this permit shall not cause or contribute
to violations of Water Quality Standards.
This permit does not relieve the permittee from responsibility for compliance with any
other applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or
decree.
Part I Page 1 of 2

SECTION C: LOCATION MAP
DRAFT Permit No. NCS000562
Map Scaie 1.24,000
Horsehead Corporation
Rutherford County Facility
Latitude-. 350 11'367 N
Longitu&:8111 50'SV" W
County: Rutherford Cbunty
Receiving Stream: Broad River -
Stream Class: C
Sub -basin. 03-08-02 Broad River Basin
Part I Page 2 of 2
Facility Location
%
_j
W. M
v,
J) 0
2.
Map Scaie 1.24,000
Horsehead Corporation
Rutherford County Facility
Latitude-. 350 11'367 N
Longitu&:8111 50'SV" W
County: Rutherford Cbunty
Receiving Stream: Broad River -
Stream Class: C
Sub -basin. 03-08-02 Broad River Basin
Part I Page 2 of 2
Facility Location

DRAFT Permit No. NCS000562
PART II MONITORING, CONTROLS, AND LIMITATIONS FOR
PERMITTED DISCHARGES
SECTION A: STORMWATER POLLUTION PREVENTION PLAN
The permittee shall develop and implement a Stormwater Pollution Prevention Plan
(SPPP). The SPPP shall be maintained on site. The SPPP is public information in
accordance with Part III, Standard Conditions, Section E, paragraph 3 of this permit. The
SPPP shall include, at a minimum, the following items:
1. Site Overview. The Site Overview shall provide a description of the physical facility
and the potential pollutant sources that have the potential°to contribute to
contamination of stormwater discharges. The Site Overview shall contain the following:
(a) A general location map (USGS quadranglelmap or appropriately drafted equivalent
map) showing the facility's location in relation,�to"'transportation routes and surface
waters; the name of the receiving waters -f 'Whiththe stormwater outfalls
discharge; and accurate latitude and longtude'of the points of stormwater discharge
associated with industrial activity. 'The,general location map (or alternatively the
site map) shall identify w�hetherariy receiving waters are impaired (on the state's
303 (d) list of impaired waters). or`if the -"s ite is located in a watershed for which a
TMDL has been established„and what he parameters of concern are.
(b) A narrative description of storage practices, loading and unloading activities,
outdoor process areas, dust or particulate generating or control processes, and
waste disposal practices:-A,narrative description of the potential pollutants that
could be expected to be present in the stormwater discharge from each outfall, and a
discussion of failure modes that may impact the risk for polluted stormwater
discharges.
(c) A site map drawn at a scale sufficient to clearly depict: the site property boundary;
the stormwater discharge outfalls; all on-site and adjacent surface waters and.
wetlands; industrial activity areas (including storage of materials, disposal areas,
process areas, loading and unloading areas, and haul roads); site topography and
finished grade; all drainage features and structures; drainage area boundaries and
total contributing area for each outfall; direction of flow in each drainage area.-
industrial
rea;industrial activities occurring in each drainage area; buildings; stormwater Best
Management Practices (BMPs); and impervious surfaces. The site map must
indicate the percentage of each drainage area that is impervious, and the site map
must include a graphic scale indication and north arrow.
(d) A list of significant spills or leaks of pollutants during the previous three (3) years
and any corrective actions taken to mitigate spill impacts.
Part II Page 1 of 11

DRAFT Permit No. NCS000562
(e) Certification that the stormwater outfalls have been evaluated for the presence of
non-stormwater discharges. The permittee shall re -certify annually that the
stormwater outfalls have been evaluated for the presence of non-stormwater
discharges. The certification statement will be signed in accordance with the
requirements found in Part III, Standard Conditions, Section B, Paragraph 3.
2. Stormwater Management Strategy. The Stormwater Management Strategy shall
contain a narrative description of the materials management practices employed which
control or minimize the stormwater exposure of significant materials, including
structural and nonstructural measures. The Stormwater Management Strategy, at a
minimum, shall incorporate the following:
(a) Feasibility Study. An annual review by site management of the technical and
economic feasibility of changing the methods,.of operations and/or storage practices
to eliminate or reduce exposure of materials and-processes"to rainfall and run-on
f y
flows. Wherever practical, the permittee shall <preverit<exposure of storage areas,
material handling operations, manufacturing; and fueling operations. In areas
where elimination of exposure and/or pr-eventi`®n' of run-on contact are not
practical, the Feasibility Study shall do'eufe ,they basis for the management
decision that such controls are not feasible.
� 3
(b) Secondary Containment\Requirements°and Records. Secondary containment is
required for: bulk storage ofliquid materials including petroleum products; storage
in any amount of Section41.3 of_,Title III of the Superfund Amendments and
Reauthorization Act (SAfRA) water priority chemicals; and storage in any amount of
hazardous substances. in order to prevent leaks and spills from contaminating
stormwater runoff. table r summary of all such tanks and stored materials and
their associated secondary containment areas shall be maintained. If the secondary
containment devices are connected to stormwater conveyance systems, the
connection shall be controlled by manually activated valves or other similar devices,
which shall be secured closed with a locking mechanism.' Prior to release into the
stormwaters conveyance system, any stormwater that accumulates in containment
areas shall be at a minimum visually observed for color, foam, outfall staining,
visible sheens, and dry weather flow. Accumulated stormwater may be released if
found to be uncontaminated by any material. Records documenting the individual
making the observation or analyses, the visual and analytical description.of the
accumulated stormwaters, and the dates and times of the releases shall be kept for a
period of five (5) years.
(c) BMP Summary. A listing of site structural and non-structural Best Management
Practices (BMPs) shall be provided. The installation and implementation of BMPs
shall be based on the assessment of the potential for sources to contribute
significant quantities of pollutants to stormwater discharges and on data collected
through monitoring of stormwater discharges. The BMP Summary shall include a
written record of the specific rationale for installation and implementation of the
Part II Page 2 of 11

DRAFT Permit No. NCSOOOS62
selected site BMPs. The BMP Summary shall be reviewed by site management and
updated annually.
3. Spill Prevention and Response Procedures. The Spill Prevention and Response
Procedures (SPRP) shall incorporate an assessment of potential pollutant sources based
on a'.materials inventory of the facility. The SPRP shall address spill response and
failure mode preparations and responses. Site management shall identify facility
personnel responsible for implementing the SPRP in a written list incorporated into the
SPRP along with dated signatures by each individual acknowledging his or her
responsibilities under the SPRP. A responsible person shall be on-site at all times
during facility operations that have the potential to contaminate stormwater runoff
through spills or exposure of materials associated with the facility operations. The
SPRP must be site stormwater specific. Therefore, anoil,Spi11 Prevention Control and
Countermeasure plan (SPCC) may be a component ofthe'SPRP, but may not be
sufficient to completely address the stormwater asprectsoftheoSPRP. The common
elements of the SPCC with the SPRP may be incorporatedby.�reference into the SPRP.
4. Preventative Maintenance and Good Housekee",ing�Program. A preventative
maintenance and good housekeeping pro gram;:shaILI" developed and implemented.
The program shall address all stormwater control= ystems, stormwater discharge
outfalls, all on-site and adjacent surfa'tewaters`rand wetlands, industrial activity areas
(including material storage dreas,/material handling areas,, disposal areas, process
areas, loading and unloadingareas arid -haul roads), all drainage features and
structures, and structural BM.Ps:' T�he`program shall establish schedules of inspections,
maintenance, and housekeeping' activities of stormwater control systems, as well as
facility equipment, facility areas,,and facility systems that present a potential for
stormwater exposurer,stoxrnwater pollution where not already addressed under
another element of the SRRP:` Inspection of material handling areas and regular
cleaning schedules of these areas shall be incorporated into the program. Timely
compliance with the established schedules for inspections, maintenance, and
housekeeping shall be recorded and maintained in the SPPP.
S. Facility Inspections. Inspections of the facility and all stormwater conveyance and
control systems shall occur as part of the Preventative Maintenance and Good
Housekeeping Program at a minimum on a semi-annual schedule, once during the first
half of the year (January to June), and once during the second half (July to December),
with. at least 60 days separating inspection dates (unless performed more frequently
than semi-annually). These facility inspections are different from, and in addition to,
the stormwater discharge characteristic monitoring at the outfall required in Part II
Sections B and C of this.permit.
6. Employee Training. Training programs shall be developed and training provided at a
minimum on an annual basis for facility personnel with responsibilities for: spill
response and cleanup, preventative maintenance activities, and for any of the facility's
operations that have the potential to contaminate stormwater runoff. The facility
Part II Page 3 of 11 "

DRAFT -Permit No. NCS000562
personnel responsible for implementing the training shall be identified, and their
annual' training shall be documented by the signature of each employee trained.
7. Responsible Party. Site management shall identify, and the SPPP shall document, a
specific position or positions responsible for the overall coordination, development,
implementation, and revision of the SPPP. Responsibilities for all components of the
SPPP shall be documented and position assignments provided.
8. SPPP Amendment and Annual Update. The permittee shall amend the SPPP
whenever there is a change in design, construction, operation, site drainage,
maintenance, or configuration of the physical features which may have a significant
impact on the potential for the discharge of pollutants to surface waters. All aspects of
the:SPPP shall be reviewed and updated on an annual�basis. The annual update
shall include all the aspects required immediately?above" in items 1-7; and a review and
comparison of monitoring analytical data to benchmark tal;ues over the pastyear,
including a discussion about Tiered Response status. The,e mittee shall use the
Division's Annual Summary Data Monitoring Report�form, available from the
Stormwater Permitting Unit's website here;,.,
/�J17
The Director may notify the permittee,when.the SPPP does not meet one or more of the
minimum requirements of�thepermit. Witmhih 30 days of such notice, the permittee
shall submit a time schedule o`the'Director for modifying the SPPP to meet minimum
requirements. The permittee?shall,p Ovide certification in writing (in accordance with
Part III, Standard Conditio s, Sec ion'' , Paragraph 3) to the Director that the changes
have been made. R
9. SPPP Implementation'-Therpermittee shall implement the Stormwater Pollution
Prevention Plan and all appropriate BMPs to prevent contaminants from entering
surface waters via stormwater. Among other actions identified herein, implementation
of the SPPP shall include the documentation of. all monitoring, measurements,
inspections, maintenance activities, and training provided to employees, including the
log of the sampling data and of actions taken to implement BMPs associated with the
industrial activities. Such documentation shall be kept on-site for a period of five (5)
years and made available to the Director or the Director's authorized representative
immediately upon request.
Part II Page 4 of 11

DRAFT Permit No. NCS000562
SECTION B: ANALYTICAL MONITORING REQUIREMENTS
Analytical monitoring of stormwater discharges shall be performed as specified in Table 1.
All analytical monitoring shall be performed during a measureable storm event at each
stormwater discharge outfall (SDO). Only SDOs discharging stormwater associated with
industrial activity must be sampled (See Definitions).
A measurable storm event is a storm event that results in an actual discharge from the
permitted site outfall. The previous measurable storm event must have been at least 72
hours prior. See Definitions.
Table 1 Analytical Monitoring Requirements , ;,
Discharge
Measurement --
Sample
Sample
Characteristics =
Units
Fre :uenc 1
Type2
'Location3
Total Suspended Solids
m L.`quarterl'y'
Grab
SDO
Total Nitrogen
m L
quarterly
Grab
SDO
Total Phosphorus
mg/L''
}� quarterly
Grab
SDO
Zinc, Total Recoverable
m ' L ; f�
1}uarterly
Grab
SDO
Lead, Total Recoverable
L� ,�'
quarterly
Grab
SDO
Cadmium, Total Recoverable �'�'
��, �m =;:L,
quarterly
Grab
SDO
Chlorides
rn '` L
quarterly
Grab
SDO
Non -polar Oil & Grease/TPH
'f
�$ '
mg/L
quarterly
Grab
SDO
EPA Method 1664 SGT- ,,M _1
`
H
standard
quarterly
Grab
SDO
Total Rainfa114
inches
quarterly
Rain Gauge
-
Footnotes:
1 Measurement Frequency: Four times per year during a measureable storm event. The permittee may
petition DWQ to reduce the analytical monitoring frequency to twice peryear after eight consecutive quarterly
monitoring results all within benchmark values. Subsequently, two consecutive benchmark exceedances for any
parameter re -institute quarterly monitoring for all parameters.
2 Grab samples shall be collected within the first 30 minutes of discharge.
3 Sample Location: Samples shall be collected at each stormwater discharge outfall (SDO).
4 For each sampled measureable storm event, the total precipitation must be recorded. An on-site rain gauge
reading must be recorded.
The permittee shall complete the analytical samplings in accordance with the schedule
specified below in Table 2; unless adverse weather conditions prevent sample collection
(see Adverse Weather in Definitions). A minimum of 30 -days must separate successive
sample events. Inability to sample because of adverse weather conditions must be
documented in the SPPP and recorded on the DMR. The permittee must report the results
from each sample taken within the monitoring period (see Part III, Section E).
Part II Page 5 of 11

DRAFTPermit No. NCS000562
Table 2 Monitoring Schedule.
1Vlonitoring perhjd11
; S "''d sliumber
.., Start
End, -
Year 1- Period 1
1
April 1, 2013
June 30, 2013
Year 1= Period 2
2
July 1, 2013
September 30, 2013
Year 1= Period 3
3
October 1, 2013
December 31, 2013
Year 1- Period 4
4
January 1, 2014
March 31, 2014
Year 2 - Period 1
5
April 1, 2014
'June 30, 2014
Year 2 - Period 2.
6
July 1, 2014
September 30, 2014
Year 2 _ Period 3
7-
October 1, 2014
December 31, 2014
Year 2 Period 4
8
January 1, 2015
March 31, 2015
Year 3- Period 1
9
April 1, 2015
June 30, 2015
Year 3 _ Period 2
10
July 1, Z93
September 30, 2015
Year 3 -Period 3
11
Oct6ber'1; 20;15
? December 31, 2015
Year 3 - Period. 4
12
Jars ry 1, 201,E
March 31, 2016
Year 4 - Period 1
13
Ap -�j 2016
June 30, 2016
Year 4 - Period 2
14
®yuly�l�16
September 30, 2016
Year 4 - Period 3
15
Octabe.T 2016
December 31, 2016
Year 4.. Period 4
16
, anua y 1, 2017
March 31, 2017
Year 5 =Period 1
17
April 1, 2017
June 30, 2017
Year 5 - Period 2
1y
July 1, 2017
September 31, 2017
Year 5 ' Period 3;19
sy
' October 1, 2017
December 31, 2017
Year 5 - Period 4.
20 5
January 1, 2018
March 31, 2018
Footnotes:
1 Maintain quarterly monitoring until either another permit is issued for this facility or until this permit
is revoked or -rescinded yhe permittee must submit an application for renewal of coverage before the
submittal deadline (180 days before expiration) to be considered for renewed coverage under the
permit. The permittee must continue analytical monitoring throughout the permit renewal process,
even if a renewal permit is not issued until after expiration of this permit.
2 If no discharge occurs during the sampling period, the permittee must submit a monitoring report
indicating "No Flow" within 30 days of the end of the sampling period. For -the first term of this
permit, the new facility start-up date is uncertain. Permittee need not sample for the listed
monitoring periods until the facility comes into operation. Accordingly, the "No Flow" monitoring
report is not required during the. time before the facility comes into operation.
Failure to monitor quarterly per the permit terms may result in the Division requiring
monthly monitoring for all parameters for a specified time period. "No discharge" from
an outfall, or inability to collect a sample because of adverse'weather conditions during a
monitoring period does not constitute failure to monitor, as long as it is properly reported.
The permittee shall compare monitoring results to the benchmark values in Table 3. The
benchmark values in Table 3 are not permit limits, but should be used as management
guidelines for the permittee's responsive implementation of the Stormwater Pollution
Prevention Plan (SPPP).
Part II Page 6 of 11

DRAFT Permit No. NCS000562
Table 3 Benchmark Values for Analvtical Monitoring
Discharge Characteristics
a Units - °
Benchmark)
Total Suspended Solids
mg/L
100
Total Nitrogen
mg/L
30
Total Phosphorus
mg/L
2
Zinc, Total Recoverable
mg/L
0.067
Lead, Total Recoverable
mg/L
0.03
Cadmium, Total Recoverable
mg/L
0.001
Chlorides.
mg/L
860
Non -polar Oil & Grease/TPH
EPA Meth
[ od 1664 (SGT-HEM)],��,
dA�
la
mg
pH
standard �....
6 - 9
Footnote
1. Analytical results must not be reported
non -detect" or any similar non-quantitatiy
reporting limits must be reported on thel
value descriptive of the method -or report,ii
)tations, "BDL. ND, BRL, <MDL, <P:QL,
id, analytical results below method or
<XX", where XX is the specific numerical
Sum rria t Requirement
During the first term of this permit, and r the period beginning with the on-site initiation of
industrial activity and continuing for two years nominal duration thereafter, Horsehead shall
sample quarterly as provided m Table 2, shall tabulate and interpret the collected data
(minimum eight data points)�Withn 30 months of start-up Horsehead shall present DWQ with
a summary report that uses the collected data to support any proposed alternative monitoring,
benchmark, and response action scheme for the purpose of maintaining site management
awareness and responsiveness to potential pollutant discharges from the site. For°the first
term of this permit, benchmark exceedances will not activate DWQ's standard Tiered Response
actions which are shown below for reference only.
The summary report shall specifically consider and interpret the collected data with respect
to the benchmarks identified in this permit, and shall identify the Tiered Response action
status that would have been triggered by the data collected:
While DWQ is considering Horsehead's summary report and determining what revisions to the
permit, if any, may be reasonable and protective, and continuing on for the remainder of the
permit term until any such changes in the permit requirements may be established by DWQ,
Horsehead shall be subject to the full provisions of sampling, comparison to the benchmarks,
and reporting contained in Part II Section B. All other provisions of the permit remain in effect
from the effective date of the-Dermit until expiration.
Part II Page 7 of 11

DRAFT Permit No.. NCS000562
If: The first valid sampling results are above a benchmark value, or outside of the benchmark range,
for anv parameter at anv outfall:
Then: The permittee shall:
1. Conduct a stormwater management inspection of the facility within two weeks of receiving
sampling results.
2. Identify and evaluate possible causes of the benchmark value exceedance.
3. Identify potential and select the specific: source controls, operational controls, or physical
improvements to reduce concentrations of the parameters of concern, and/or to bring
concentrations within the benchmark range.
4. Implement the selected actions within two months of the�mspection.
S. Record each instance of a Tier One response in the SPPP. Iclude the date and value of the
benchmark exceedence, the inspection date, the personnel conducting the inspection, the
selected actions, and the date the selected actions weremplemented.
Tier Tw
If: During the term of this permit, the first valid sampling results from two consecutive monitoring
periods are above the benchmark values, or outside of the benchmark range, for any specific
arameter at a specific discharge outfall;
Then: The permittee shall:
1. Repeat all the required actions outlined above in Tier One.
2. Immediately institute monthly monitoring for all parameters. The permittee shall conduct
monthly monitoring at every outfall where a sampling result exceeded the benchmark value for
two consecutive samples. Monthly (analytical and qualitative) monitoring shall continue until
three consecutive sample results are below the benchmark values or within benchmark range.
3. If no discharge occurs during the sampling period, the permittee is required to submit a
monthly monitoring report indicating "No Flow".
4. Benchmark exceedances for a different parameter separately trigger a tiered response.
S. Maintain a record of the Tier Two response and monitoring results in the SPPP.
Part II Page 8 of 11

DRAFT Permit No. NCS000562
je`rTliree µ
During the term of this permit, if the valid sampling results required for the permit monitoring periods
exceed the benchmark value, or are outside the benchmark range, for any specific parameter at any
specific outfall on four occasions, the permittee shall notify the DWQ Regional Office Supervisor in
writing within 30 days of receipt of the fourth analytical results. DWQ may, but is not limited to:
• require that the permittee revise, increase, or decrease the monitoring frequency for`some
or all parameters;
• require the permittee to install structural stormwater controls;
• require the permittee to implement other stormwaterr-control measures;
• require the permittee to perform upstream and downstream monitoring to characterize
impacts on receiving waters; or
• require the permittee implement site modifications to qualify for a No Exposure Exclusion.
If a Total Maximum Daily Load (TMDL) is approved fgolhis� e i exit of the Broad River, the
tbAN"Y
,
permittee may be required to monitor for the pollutants) of concern in the future and
submit results to the Division of Water Quality. The D,'p ion will consider the monitoring
results in determining whether additional BMPasi rded to control the pollutant(s) of
concern to the maximum extent practicable r`
If additional BMPs are needed to achieve the&eggf-red level of control, the permittee will be
required to (1) develop a strategyfor"implementing appropriate BMPs, and (2) submit a
timetable for incorporation of thgse BMPP4-, into the Stormwater Pollution Prevention Plan.
A-- RW_ .
Part II Page 9 of 11

DRAF7Permit No. NCS000562
SECTION C: QUALITATIVE MONITORING REQUIREMENTS
The purpose of qualitative monitoring is to quickly evaluate the effectiveness of the
permittee's implementation of the SPPP, and to assess new sources of stormwater pollution,
and to prompt the permittee's response to observed pollution. Qualitative monitoring of
stormwater outfalls must be performed during a measurable storm event.
Qualitative monitoring requires a visual inspection of each stormwater outfall regardless of
representative outfall status. Qualitative monitoring shall be performed. quarterly as
specified in Table 4, and concurrent with the required analytical monitoring events.
Inability to monitor because of adverse weather conditions must be documented in the
SPPP and recorded on the D -MR (see Adverse Weather in Definitions). Only SDOs discharging
stormwater associated with industrial activity must be monitoz•ed.
Table 4 Qualitative Monitoring Re uiremts
Discharge Chatactetistics
Frequency1
Monitoring
Location2
n
Color
quarterly
SDO
Odor
, uarterl
SDO
Clari
h uarterl
SDO
�
Floating Solids ;��.
uarterl
SDO
Sus. ended Solids
quarterly
SDO
Foam
quarterly
SDO
Oil Sheen `�,.. ���
quarterly
SDO
Erosion or de osition at the. outfall
quarterly
SDO
Other obvious indicators
quarterly
SDO
of stormwater pollution
Footnotes:
1 Measurement Frequency: Four times per year during a measureable storm event. See Table 2 for
schedule of monitoring periods through the end of this permitting cycle. The permittee must continue
qualitative monitoring throughout the permit renewal process until a new permit is issued. Qualitative
monitoring must be continued quarterly, and is not eligible for the semi-annual monitoring frequency under
step-down provisions that apply to analytical monitoring.
2 Monitoring Location: Qualitative monitoring shall be performed at each stormwater discharge outfall
(00) regardless of representative outfall status.
A minimum of 30 days must separate monitoring dates, unless additional sampling has
been instituted as part of other analytical monitoring requirements in this permit.
If the permittee's qualitative monitoring indicates that existing stormwater BMPs are
ineffective, or that significant stormwater contamination is present, the permittee shall
investigate potential causes, evaluate the feasibility of corrective actions, and implement
Part II Page 10 of 11

DRAFT Permit No. NCS000562
those corrective actions within 60 days of the qualitative monitoring event. A written
record of the permittee's investigation, evaluation, and response actions shall be kept in
the SPPP.
Quahtatiive Monitorin Res, once
Qualitative monitoring is for the purposes of evaluating the effectiveness of the permittee's
implementation of the SPPP; and assessing new sources of stormwater pollution, and prompting the
permittee's response to pollution. If the permittee repeatedly fails to respond effectively- to
correct problems indicated by qualitative monitoring, or if the discharge causes or contributes to a
water quality standard violation, DWQ may, but is not limited to:
• require that the permittee revise, increase, or decrease the monitoring frequency and
parameters (analytical or qualitative) for a spf#6i`e timb,per od;
• require the permittee to install structural sto-inwater conirx,als;
• require the permittee to implement other stolrmwater control measures;
• require the permittee to perform upstream and downstream monitoring to characterize
impacts on receiving waters; or ryT
r e5 3
• require the permittee implement site n odiifW un to qualify for a No Exposure Exclusion.
Part II Page 11 of 11 m

DRAFT Permit No. NCS000562
PART III STANDARD CONDITIONS FOR NPDES STORMWATER INDIVIDUAL PERMITS
SECTION A: COMPLIANCE AND LIABILITY
1. Compliance Schedule
The permittee shall comply with Limitations and Controls specified for stormwater discharges in
accordance with the following schedule:
Existing Facilities already operating but applying for permit coverage for.the first time: The-
Stormwater Pollution Prevention Plan shall be developed and implemented within 12 months of the
effective date of the initial permit and updated thereafter on an annual basis. Secondary containment,
as specified in Part II, Section A, Paragraph 2(b) of this permit, shall be accomplished within 12
months of the effective date of the -initial permit issuance. „
New Facilities applying for coverage for the first time: The Stormwater Pollution Prevention Plan
shall be developed and implemented prior to the beginning of discharges from the operation of the
industrial activity and be updated thereafter on an annual basis. Secondary containment, as specified
in Part II, Section A, Paragraph 2(b) of this permit shaif,' accomplished prior to the beginning of
discharges from the operation of the industrial actiyity fl
Existing facilities previously permitted
limitations, and controls contained in this
shall become effective immediatelv uDonfi
Pollution Prevention Plan foritli;
months of the effective date oftth'
Containment, as specified in Pare
beginning of discharges from'the
d applgiugfor renewal: All requirements, conditions,
errant (except revised SPPP elements in a permit renewal)
;uArice-df this permit. New elements of the Stormwater
n veal shall be developed and imDlemented within 6
nd updated thereafter on an annual basis. Secondary
V
h 2 (b) of this permit shall be accomplished prior to the
of the industrial activity.
Duty to Comply `
The permittee must comply with all conditions of this permit. Any permit noncompliance constitutes
A violation of the Clean Water Act (CWA) and is grounds for enforcement action; for permit
termination, revocation and reissuance, or modification; or denial of a permit upon renewal
Application [40 CFR 122.41].
a. The permittee shall comply with standards or prohibitions established under section 307(a) of
the CWA for toxic pollutants within the time provided in the regulations that establish these
standards or prohibitions, 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
Part III Page 1 of 9

DRAFT Permit No. NCS000562
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 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 imprisonmerit�of nowt moregthan 30 years, or both. An
organization, as defined in section 309(c)(3)(B)f(iii) oftlie'CWA shall, upon conviction of
violating the imminent danger provision, be subject�to a fine of_n 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
f
any person who violates or fails to act inccorance with the terms, conditions, or requirements
utes -215.6
a.
of a permit. [North Carolina General Stat § 14A]
A d
g. Any person may be assessed anradmmistrativepenalty by the Administrator for violating section
301, 302, 306, 307, 308,3,18 nor 40 ofethis Act, or any permit condition or limitation
implementing any of such sections in=a}p'ermit issued under section 402 of this Act.
Administrative penalties for Class°Fyiolations are not to exceed $16,000 per violation, with the
maximum amount of Ay Class I,pehalty assessed not to exceed $37,500. Penalties for Class II
violations are not toe ceed $�-6;000 per day for each day during which the violation continues,
with the maximum lamount of any Class II penalty not to,exceed $177,500. [33 USC 1319(g) (2)
� ". ,
and 40 CFR 122.41fa1f3)1'
3. Duty to Mitigate
The permittee shall take all reasonable steps to minimize or prevent any discharge in violation of this
permit which has a reasonable likelihood of adversely affecting human health or the environment [40
CFR 122.41(d)].
4. Civil and Criminal Liability
Except as provided in Part III, Section C of this permit regarding bypassing of st6rmwater control
facilities, 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.
S. 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 USC 1321.
6. 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
Part III Page 2 of 9

DRAFT Permit No. NCS000562
personal rights, nor any infringement of Federal, State or local laws or regulations [40 CFR
122.41(g)].
7. Severability
The provisions of this permit are severable, and 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 15013-23].
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 the permit issued pursuant to 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 to be kept by this permit [40 CFR 122.41(h)].
9. Penalties for Tampering r�
fig" �"�,
The Clean Water Act provides that any person who falsifies; tampers�wi h, or knowingly renders
t"I/I
inaccurate, any monitoring device or method required,to,be mamtai ""ed 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 ore than 4 years, or both [40 CFR 122.41].
10. Penalties for Falsification of Reports �' e
The Clean Water Act provides that any persom, o knowingly makes any false statement,
representation, or certificatio�nriany recocd�or other document submitted or required to be
maintained under this permit,„_including monitoring reports or reports of compliance or
noncompliance shall, upon,c nviction, be punished by a fine of not more than $10,000 per violation, or
by imprisonment for not more thant`wo years per violation, or by both [40 CFR 122.411.
11. 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.
12. Duty to Reapply
If the permittee wishes to continue an activity regulated by this permit after the expiration date of
this permit, the permittee must apply for and obtain a new permit [40 CFR 122.41(b)].
SECTION B: GENERAL CONDITIONS
Permit Expiration
The permittee is not authorized to discharge after the expiration date. In order to receive automatic
authorization to discharge beyond the expiration date, the permittee shall submit forms and fees as
are required by the agency authorized to issue permits no later than 180 days prior to the
expiration date, unless permission for a later date has been granted by the Director. (The Director
shall not grant permission for applications to be submitted later than the expiration date of the
existing permit.) [40 CFR 122.21(4)]. Any permittee that has not requested renewal at least 180 days
prior to expiration, or any permittee that does not have a permit after the expiration and has not
requested renewal at least 180 days prior to expiration, will be subjected to enforcement procedures
as provided in NCGS §143-215.36 and 33 USC 1251 et. seq.
Part III Page 3 of 9

DRAFT Permit No. NCS000562
2. 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. The Permittee is required to notify the Division in writing in the event the permitted
facility is sold or closed.
3. Signatory Requirements
All applications, reports, or information submitted to the Permitting Issuing Authority shall be signed
and certified [40 CFR 122.41(k)].
a. All permit applications shall be signed as follows: Al
(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 busmess,ftmchon, 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 operatingfaciiities, provided, the manager is authorized
to make management decisions which govern the operation of the regulated facility including
X. V
having the explicit or implicit duty of making"malor,capital investment recommendations,
and initiating and directing other co nprehehsiVe%measures to assure long term
environmental compliance with environmental laws and regulations; the manager can
ensure that the necessary systems are",establ shed or actions taken to gather complete and
accurate information for perni t application requirements; and where authority to sign
documents has been assigne&6r delegated to the manager in accordance with corporate
procedures.
(2) For a partnership of sole proprietorship: by a general partner or the proprietor, respectively;
or
(3) For a municipal t',, State,�Eederal, 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]
Part III Page 4 of 9

DRAFT Permit No. NCS000562
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
properlygather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible forgathering 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. "
4. 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 176bral Regulations, Parts 122 and 123;
Title 15A of the North Carolina Administrative Code .,Subchapter 2H .01(a0; and North Carolina
General Statute 143-215.1 et al.' ),
S. Permit Actions
The permit may be modified, revoked and
planned changes or anticipated noncompl
122.41(x].
The permittee must pay th
after being billed by the Dil
NCAC 2H .0105(b)(2) may
SECTION C: OPERATION.AND
1.
ated for cause. The notification of
any permit condition [40 CFR
f compliance monitoring fee within 30 (thirty) days
iy. the fee in timely manner in accordance with 15A
to initiate action to revoke the permit.
OF POLLUTION CONTROLS
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 operation of back-up or auxiliary facilities or similar systems which are installed by a permittee
only when the operation is necessary to achieve compliance with the conditions of this permit [40
CFR 122.41(e)].
2. 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)].
3. Bypassing of Stormwater Control.Facilities
Bypass is prohibited and the Director 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; and
b. There were no feasible alternatives to the bypass, such as the use of auxiliary control facilities,
retention of stormwater.or maintenance during normal periods of equipment downtime or dry
weather. This condition is not satisfied if adequate backup controls should have been installed in
Part III Page 5 of 9

DRAFT Permit No. NCS000562
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, Part III, Section E of this permit.
If the Director determines that it will meet the three conditions listed above, the Director may
approve an anticipated bypass after considering its adverse effects.
SECTION D: MONITORING AND RECORDS
1. Representative Sampling
Samples collected and measurements taken, as required herein, shall be characteristic of the volume
and nature of the permitted discharge. Analytical sampling shall be performed during a measureable
storm event. Samples shall be taken on a day and time that is characteristic of the discharge. All
samples shall be taken before the discharge joins or dilute`alby�any other waste stream, body of
water, or substance. Monitoring points as specified inlhis permit shall not be changed without
notification to and approval of the Permit Issuing Authority [4'O�CFR 122.410)].
t
2. Recording Results
For each measurement or sample taken pursuant -to the `requirements of this permit, the permittee
shall record the following information [40 CFR -1-22.41]:.•
a. The date, exact place, and time of sampling fr`measurements;
b. The individual(s) who performed thessampling,or�measurements;
c. The date(s) analyses v
d. The individual(s) who
e. The analytical techniques, 6 -methods -,used; and
f. The results of such analvses. ?.
3. Flow Measurements I j;
Where required, 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.
4. Test Procedures
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 Federal Water Pollution Control Act, as
Amended, and Regulation 40 CFR 136.
To meet the intent of the monitoring required by this permit, all test procedures must produce
minimum detection and reporting levels and all data generated must be reported down 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.
Representative Outfall
If a facility has multiple discharge locations with substantially identical stormwater discharges that
are required to be sampled, the permittee may petition the Director for representative outfall status.
If it is established that the stormwater discharges are substantially identical and the permittee is
granted representative outfall status, then sampling requirements may be performed at a reduced
number of outfalls.
Part III Page 6 of 9

DRAFTPermit No. NCS000562
6. Records Retention
Visual monitoring shall be documented and records maintained at the facility along with the
Stormwater Pollution Prevention Plan. Copies of analytical monitoring results shall also be,
maintained on-site. The permittee shall retain 'records of all monitoring information, including
o all calibration and maintenance records,
o all original strip chart recordings for continuous monitoring instrumentation,
o copies of all reports required by this permit,
o copies of all data used to complete the application for this permit
These records or copies shall be maintained for period of at least 5 years from the date of the
sample, measurement, report or application. This period may be extended by request of the Director
at anytime [40 CFR 122.41].
Inspection and Entry
the permittee shall allow the Director, or an autho
contractor acting as a representative of the Directo
through a municipal separate storm sewer system,
operator or the separate storm sewer system recei
credentials and other documents as may be require
a. Enter upon the permittee's premises
or where records must be kept under
b. Have access to and copy, at reasonabl
Of this permit; '
c. Inspect at reasonable times any MUD
equipment), practices, or operations i
d. Sample or monitor at reasonable UME
otherwise authorized byie C1eanztN:
CFR 122.41(i)].
SECTION E: REPORTING
1. Discharge Monitoring Reports
represeptative (including an authorized
inhie case of a facility which discharges
thorizO TepFesentative of a municipal
lie discharge, upon the presentation of
law. to:
ility or activity is located or conducted,
s permit;
that must be kept under the conditions
equipment (including monitoring and control
lated or required under this permit; and
it the purposes of assuring permit compliance or as
Act, any substances or parameters at any location [40
Samples analyzed in accordance with the terms of this permit shall be submitted to the Division on
Discharge Monitoring Report (DMR) forms provided by the Director. DMR forms are available on the
Division's website (httl2:,//not•tal.ncdenr.orgJweb/wq/ws/su/npdessw). Submittals shall be
delivered to the Division no later than 30 days from the date the facility receives the sampling
results from the laboratory.
When no discharge has occurred from the facility during the report period, the permittee is required
to submit a discharge monitoring report, within 30 days of the end of the specified sampling period,
giving all required information and indicating "NO FLOW" as per NCAC T15A 0213.0506.
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 data submitted on the DMR.
The permittee shall record the required qualitative monitoring observations on the SDO Qualitative
Monitoring Report form provided by the Division and shall retain the completed forms on site.
Qualitative monitoring results should not be submitted to the Division, except upon DWQ's specific
requirement to do so. Qualitative Monitoring Report forms are available at the website above.
Part III Page 7 of 9

DRAFT Permit No..NCS000562
2. Submitting Reports "
Two signed copies of Discharge Monitoring Reports (DMRs) shall be submitted to:
Central Files
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
3. Availabilitv 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, analytical 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:�B or in Section 309 of the Federal
Act.F
4. Non-Stormwater Discharges
If the storm event monitored in accordance with this permit coincides with a non-stormwater
discharge, the permittee shall separately monitorallparam6ters as required under all other
applicable discharge permits and provide this information with the stormwater discharge monitoring
report.`
S. Planned Changes'
The permittee shall give notice;to the Directoraso"soon as possible of any planned changes at the
permitted facility which coul nifica
slsklylalter the nature or quantity of pollutants discharged [40
CFR 122.41(1)]. This notification reqs}re npnt includes pollutants which are not specifically listed in
the permit or subject to notification;re`qulrements under 40 CFR Part 122.42 (a).
rel
The permittee shall give advanc6notice to the Director of any planned changes at the permitted
facility which may result in -noncompliance with the permit [40 CFR 122.41(1) (2)].
7. Spills
The permittee shall report to the local DWQ Regional Office, within 24 hours, all significant spills as
defined in Part IV of this permit. Additionally, the permittee shall report spills including: any oil spill
of 25 gallons or more, any spill regardless of amount that causes a sheen on surface waters, any oil
spill regardless of amount occurring within 100 feet of surface waters, and any oil spill less than 25
gallons that cannot be cleaned up within 24 hours.
8. Bypass
Notice [40 CFR 122.41(m)(3)]:
a. 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 affect of the bypass.
b. Unanticipated bypass. The permittee shall submit notice within 24 hours of becoming aware of
an unanticipated bypass.
Twenty-four Hour Reporting
a. The permittee shall report to the central office or the appropriate regional office any
noncompliance which may endanger 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.
Part III Page 8 of 9

DRAFT Permit No. NCS000562
The written submission shall contain a description of the noncompliance, and its causes; the
period of noncompliance, including exact dates and times, and if the noncompliance has not
been corrected, the anticipated time compliance 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 [phone].
1
10. Other Noncompliance
The permittee shall report all instances of noncoml
the time monitoring reports are submitted [40 CFR
11. Other Information
Where the Permittee becomes aware that it failed
or submitted incorrect information in a permit ap
promptly submit such facts or information [4,011CF
11
Part III Page 9 of 9
orted under 24 hour reporting at
ny relevant facts in a permit application,
In any report to the Director, it shall
(8)]•

PART IV DEFINITIONS
1. Act
See Clean Water Act.
DRAFT NCS000562
2. Adverse Weather
Adverse conditions are those that are dangerous or create inaccessibility for personnel, such as local
flooding, high winds, or electrical storms, or situations that otherwise make sampling impractical.
When adverse weather conditions prevent the collection of samples during the sample period; the
permittee must take a substitute sample or perform a visual assessment during the next qualifying
storm event. Documentation of an adverse event (with date;1ime and written narrative) and the
rationale must be included with your SPPP records.,Adverse�weather does not exempt the permittee
from having to file a monitoring report in accordance w thFthe sampl g schedule. Adverse events and
failures to monitor must also be explained and rep o�rtedeon the relevant DMR.
4.
Allowable Non-Stormwater Discharges
This permit regulates stormwater disch
the stormwater conveyance system are:
a. All other discharges that are author
b. Uncontaminated groundwater, fours
chemicals, springs, discharges of
flushings, water from footing drains
c. Discharges resulting from fire figk�ti
as a result of use in th6-' ent`o`f af'i"E
discharges which shall be allowed in
y a non stormwater NPDES permit.
ltdrains, air -conditioner condensate without added
urinated potable water, waterline and fire hydrant
s from riparian habitats and wetlands.
fire -fighting training, or emergency shower or eye wash
Measures or practices used toyi Educe the amount of pollution entering surface waters. BMPs may
take the form of a process', -'activity, or physical structure. More information on BMPs can be found at:
httn://cfl2ub.el2a.gov/npdes/stormwater/menuofbmps/index cfm.
S. Bypass
A bypass is the known diversion of stormwater from any portion of a stormwater control facility
including the collection system, which is not a designed or established operating mode for the facility.
6. Bulk Storage of Liquid Products
Liquid raw materials, manufactured products, waste materials or by-products with a single above
ground storage container having a capacity of greater than 660 gallons or with multiple above ground
storage containers located in close proximity to each other having a total combined storage capacity
of greater than 1,320 gallons.
7. Certificate of Coverage
The Certificate of Coverage (COC) is the cover sheet which accompanies a General Permit upon
issuance and lists the facility name, location, receiving stream, river basin, effective date of coverage
under the permit and is signed by the Director.
8. Clean Water Act
The Federal Water Pollution Control Act, also known as the Clean Water Act (CWA), as amended, 33
USC 1251, et. seq.
9. Division or DWO
The Division of Water Quality, Department of Environment and Natural Resources.
Part IV Page 1 of 4

DRAFT Permit No. NCS000562
10. Director
The Director of the Division of Water Quality, the permit issuing authority.
11. EMC
The North Carolina Environmental Management Commission.
12. Grab Sample
An individual sample collected instantaneously. Grab samples that will be analyzed (quantitatively or
qualitatively) must be taken within the first 30 minutes of discharge.
13. Hazardous Substance
Any substance designated under 40 CFR Part 116 pursuant to Section 311 of the Clean Water Act.
14. Landfill>
A disposal facility or part of a disposal facility where waste is ;placed in or on land and which is nota
land treatment facility, a surface impoundment, an inje&ion well,�a hazardous waste long-term
storage facility or a surface storage facility.
15. Measureable Storm Event -
A storm event that results in an actual discharge
measurable storm event must have been at least
apply if the permittee is able to document that a
events during the sampling period, and obtains
copies of this information and a writtenequest,
A\i I
After authorization by the DWQ,Regional�,Office,
permittee's SPPP.`
16. Municipal Separate Storm Sewer SVsteril-,
A stormwater collection
town.
the�per`mitted site outfall. The previous
urs prior. The 72 -hour storm interval may not
r -interval is representative for local storm
ial from the local DWQ Regional Office. Two
shall be sent to the local DWQ Regional Office.
ten approval letter must be kept on site in the
incorporated area of local self-government such as a city or
17. No Exposure
A condition of no exposure means that all industrial materials and activities are protected by a storm
resistant shelter or acceptable storage containers to prevent exposure to rain, snow, snowmelt, or
runoff. Industrial materials or activities include, but are not limited to, material handling equipment
or activities, industrial machinery, raw materials, intermediate products, by-products, final products,
Or waste products. DWQ may grant a No Exposure Exclusion from NPDES Stormwater Permitting
requirements only if a facility complies with the terms and conditions described in 40 CFR
§122.26(g).
18. Notice of Intent
The state application form which, when submitted to the Division, officially indicates the facility's
notice of intent to seek coverage under a General Permit.
19. Permit Issuing Authority
The Director of the Division of Water Quality (see "Director" above).
20. Permittee
The owner or operator issued this permit.
Part IV Page 2 of 4 Pages

DRAFT Permit No. NCS000562
21. Point Source Discharge of Stormwater
Any discernible, confined and discrete conveyance including, but not specifically limited to, any pipe,
ditch, channel, tunnel, conduit, well, or discrete fissure from which stormwater is or may be
discharged to waters of the state.
22. Representative'Outfall Status
When it is established that the discharge of stormwater runoff from a single outfall is representative of the
discharges at multiple outfalls, the DWQ may grant representative outfall status. Representative outfall status
allows the permittee to perform analytical monitoring at a reduced number of outfalls.
23. Secondary Containment
Spill containment for the contents of the single largest tank within the containment structure plus
sufficient freeboard to allow for the 25 -year, 24-hour storm event.
24. Section 313 Water Priority Chemical
A chemical or chemical category which: ',
b. Is listed in 40 CFR 372.65 pursuant to Section 313 of, Title III of,the, Superfund Amendments and
Reauthorization Act (SARA) of 1986, also titled {the -Emergency -Planning and Community Right -
to -Know Act of 1986;
C. Is present at or above threshold levels at a facility sublect°to SARA title III, Section 313 reporting
requirements; and
}
d. Meets at least one of the following criteria:
L Is listed in appendix D of 40 CFR part 122 qii Table II. (organic priority pollutants), Table III
(certain metals, cyanides, and`phenols),or Table IV (certain toxic pollutants and hazardous
substances);
ii. Is listed as a hazardous substance pursuant to section 311(b) (2) (A) of the CWA at 40 CFR
116.4; or r�
hich EPAtihas published acute or chronic water quality criteria.
iii. Is a pollutant for�w.
57
25. Severe Property Damage r l
Substantial physical da' "age -to -pr perty, damage to the control 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 does not mean economic loss
caused by delays in production.
26. Significant Materials
Includes, but is not limited to: raw materials; fuels; materials such as solvents, detergents, and plastic
pellets; finished materials such as metallic products; raw materials used in food processing or
production; hazardous substances designated under section 101(14) of CERCLA; any chemical the
facility is required to report pursuant to section 313 of Title III of SARA; fertilizers; pesticides; and
waste products such as ashes, slag and sludge that have the potential to be released with stormwater
discharges.
27. Significant Spills
Includes, but is not limited to: releases of oil or hazardous substances in excess of reportable
quantities under section 311 of the Clean Water Act (Ref: 40 CFR 110.3and 40 CFR 117.3) or section
102 of CERCLA (Ref: 40 CFR 302.4).
28. Stormwater Discharge Outfall (SDO)
The point of departure of stormwater from a discernible, confined, or discrete conveyance, including
but not limited to, storm sewer pipes, drainage ditches, channels, spillways, or channelized collection
areas, from which stormwater flows directly or indirectly into waters of the State of North Carolina.
Part IV Page 3 of 4 Pages

DRAFT Permit No. NCS000562
29. Stormwater Runoff
The flow of water which results from precipitation and which occurs immediately following rainfall
or as a result of snowmelt.
30. Stormwater Associated with Industrial Activity
The discharge from any point source which is used for collecting and conveying stormwater and
which is directly related to manufacturing, processing or raw material storage areas at an industrial
site. Facilities considered to be engaged in "industrial activities" include those activities defined in 40
CFR 122.26(b)(14). The term does not include discharges from facilities or activities excluded from
the NPDES program. "
31. Stormwater Pollution Prevention Plan
A comprehensive site-specific plan which details measures and practices to reduce stormwater
pollution and is based on an evaluation of the pollution potential,of the site.
32. Total Maximum Daily Load (TMDL)
TMDLs are written plans for attaining and maintaining water qualfty-standards, in all seasons, for a
specific water body and pollutant. A list of approved TMI)Ls for the -state of North Carolina can be
found at htti): //Dortal.ncdenr;ore/web /wo /ns /mtu 1tmdl.
33. Toxic Pollutant Xy
Any pollutant listed as toxic under Section 307(a)(f)` "of ihe'Clean Water Act.
r `/
34. Vehicle Maintenance Activity
Vehicle rehabilitation, mechanical rep rs, painting fueling, lubrication, vehicle cleaning operations,
or airport deicing operations:,,
35. Visible Sedimentation
Solid particulate matter, both mineral°and organic, that has been or is being transported by water, air,
gravity, or ice from its site�of origin which can be seen with the unaided eye.
36. 25 -year. 24 hour Storm Event -
The maximum 24-hour precipitation event expected to be equaled or exceeded, on the average, once
in 25 years.
Part IV Page 4 of 4 Pages

Mr. Ken Pickle
March 16, 2012
Page 2
In addition, please find the following supple ntal information required in the application and
included for your convenience:
• Figure 1, Site Area Map, Stormwhter NPDES Discharge Permit, Horsehead Corporation,
Rutherford County, NorthCar ma, dated February 2012.
X • DWG. No. E -0000-G-10 Forest City N.C. SX/EW Plant, General Arrangement,
Storm Water Management Plan, Horsehead Corporation, prepared by Carnegie Strategic
Design Engineers, LLC, Release date March 1, 2012.
• Narrative describing the facility's operation, feedstock materials, reagents and products
and by-products.
• Letter from Horsehead Corporation to Mr. Charles Wakild, Deputy Director, North
Carolina Division of Water Quality, dated June 13, 2011.
• E-mail correspondence between yourself and Forrest Westall with McGill Associates,
P.A. dated November 30, 2011 and December 8, 2011, respectively.
✓ • Copy of the State of North Carolina, Division of Water Quality, Permit to Discharge
Wastewater under the National Pollutant Discharge Elimination System, Permit No.
NC0089109.
The objective of the proposed plan is to manage all stormwater for discharge from the facility
through a single monitored outfall to the Broad River. Stormwater from various areas of the
facility will be managed according to the following scheme:
1. Stormwater falling into various operating/production areas will be collected in segregated
collection basins underlying or adjacent to these areas, as designated, will be analyzed for
likely pollutants to determine its disposition. Based on analytical results, the water will
be discharged to the stormwater system, used in production process operations, or
possibly treated prior to discharge. This water is referred to as "discretionary storm
water" for discussion purposes.
2. Stormwater drainage from standard commercial or landscaped areas and perimeter
roadways, roofed areas having no contact with industrial processes. This water will be
discharged directly to the stormwater system leading directly to the stormwater outfall.
This water is referred to as "non -discretionary storm water", and
C3. Stormwater falling into a few designated operation areas will be collected in segregated
collection basins underlying the designated area(s) and used for production process
operations at all times, and not discharged to the stormwater system.
C4. Stormwater from (undeveloped areas (filo and vegetated areas not affected by plant
activities) will be discharged through energy dissipation into natural drainage channels.
7 i// ?� ('"de r10/O//_Z/

Mr. Ken Pickle
March 16, 2012
Page 3
Stormwater from described areas 1 and 2 above will discharge to the single monitored outfall for
the facility. Stormwater drainage from described areas in 3 above will not be discharged but will
be used in the production process. Stormwater drainage from described areas in 4 above,
including unaffected surrounding property, will discharge into natural drainage channels.
We appreciate your guidance and assistance on this important project. [n meetings over the past
year with you, We discussed the importance of havingall rmittin� in lac as quickly as 1eo�ru
possible and well before the mac Ire ty is scheduled for start up We anticipate that you will stand) °
by the commitment made by the Division of Water Quality t provide a quick review and actions
on this permit application. If there is any aspect of this pe it package tha needs clarification
please contact me immediatelyko that the issue can be resol ed without delay]In addition, thj-
Division had indicated that a pre -draft of the permit (before notice) would be provided for our
review before a draft permit is directed to public notice.
If you have any questions please do not hesitate to contact
Sincerely,
HORSEHEAD CORPORATION
G0i/0j��y.� �f OISPn!'?�SZ.� ��
klaSiir9or7�rof r /At°m, ,�w�
j�(J d S 740 X'i ✓i^4 "Ove-i�s d3 ov
q C'AA
Timothy Basilone !/
Vice President, Environmental Affairs oX3461e or 89 r�lo is v�4B fiiPwt
Enclosures Ahvc-e a6scuss,'o17S,ord?7 reAi6,'+
cc: Forrest Westall, PE, McGill Associates, P.A. wy'
No C�dr,Ti t2 Tio.� � rrP[��s+o� Y'o/ Mi,iS/�'lq TNe
e-
-jot' wro�4/ f��p/ate r�/sim

Please print or type in the unshaded areas only.
1\� Cs o C O'Su a�
Form Approwd. OMB No. 2040-0088.
FORM
U. S. ENVIRONMENTAL PROTECTION AGENCY
I. EPA I.D. NUMBER
1
vEPA GENERAL INFORMATION
s e
Consolidated Permits Program
F D
GENERAL
(Read the "General hurtrucdorr"before smrdng.)
1 s ,a , ib
LABEL ITEMS
GENERAL INSTRUCTIONS
If a preprinted label has been provided, affix It In the
designated space. ReYew Ne information cane lly; it any of it
I. EPA I.D. NUMBER
is incorrect, cross through f and enter the correct date in the
appropriate Ir area below. Also, f any of the preprinted data
is absent (the area to the led of the label space lists the
III. FACILITY NAME PLEASE PLACE LABEL IN THIS
SPACE informathon that should appead, please provide it in the proper
Ellin alea(s) below. If the label is complete and correct you
V. FACILITY MAILING
need not complete Items I, III, V, and M (except VI -B which
ADDRESS
must be completed regardless). Complete all items f no label
hes been provided. Refer to the instructions far detailed item
VI. FACILITY LOCATION
descriptions and for the legal authomations under which this
data is collected.
II. POLLUTANT CHARACTERISTICS
INSTRUCTIONS: Complete A through J to determine whether you need to submit any
permit application forms to the EPA. If you answer t'es't° any questions, you must
submit this form and the supplemental forth listed in the parenthesis following the question.
Mark'X' in the box in the third column If the supplemental form is attached. If
you answer'no' to each question, you need not submit any of mese forms. You may
answer'no' 8 your activity is excluded from permit requirements; see Section C of the
instructions. See also, Section D of the instructions for definitions of bold-faced terms. "
Wilk
'r
Mvk'x'
Yss
NO
ATucirEo
YES
No
ATTACHEDF
SPECIFIC QUESTIONS
SPECIFIC QUESTIONS
A. Is this facility a publicly owned treatment works which
B. Does or will this facility (either "Wrig or pmposed)
results in a discharge to waters of the U.S.? (FORM 2A)
X
include a concentrated animal feeding operation or
X
aquatic animal production facility which results in a
+b
+a
m
m
discharge to waters of the U.S.? (FORM 2B)
C. Is this a facility which currently results in discharges to
X
D. Is this a proposed facility (other than those dissented in A
waters of the U.S. other than those described in A or B
or B above) which will result in a discharge to waters of
X
X
above? (FORM 2C)
the U.S.? (}4}81 M7 Form 2F
a
v
u
m
m
a
E. Does or will this facility treat, store, or dispose of
F. Do you or will you inject at this facility industrial or
hazardous wastes? (FORM 3)
X
municipal effluent below the lowermost stratum
X
containing, within one quarter mile of the well bore,
m
-m
underground sources of drinking water? (FORM 4)
G. Do you or will you inject at this facility any produced water
H. Do you or will you inject at this facility fluids for special
or other fluids which are brought to the surface in
processes such as mining of suffur by the Frasch process,
connection with conventional oil or natural gas production,
X
solution mining of minerals, in situ combustion of fossil
X
inject fluids used for enhanced recovery of oil or natural
fuel, or recovery of geothermal energy? (FORM 4)
gas, or inject fluids for storage of liquid hydrocarbons?
(FORM 4)
v
a
s,
sr
m
s,
I. Is this facility a proposed stationary source which is one
J. Is this facility a proposed stationary source which is
of the 28 industrial categories listed in the instructions and�/
X
NOT one of the 28 industrial categories listed in the
�/
X
which will potentially emit 100 tons per year of any air
instructions and which will potentially emit 250 tons per
pollutant regulated under the Clean Air Act and may affect
year of any air Pollutant regulated under the Clean Air Act
w11
4
U
w
or be located in an attainment area? (FORM 5)
and may affect or be located in an attainment area?
(FORM 5)
III. NAME OF FACILITY
SKIP I Rut err ord I County Pro uction Facility
IV. FACILITY CONTACT
A NAME 8 TITLE (last, first, & title)
B. PHONE (aria code & roll
2 Basilone, Timothy R. I Vice -President, Env.
Af airs
v +e
V.FACILTY MAILING ADDRESS
A STREET OR P.O. BOX
3 4 5 to enville Pike, uite 0
15 114
B. CITY OR TOWN
C. STATE D. ZIP CODE
y Pittsburgh
I
A
1192d 5
r
VI. FACILITY LOCATION
A STREET, ROUTE NO. OR OTHER SPECIFIC IDENTIFIER
5 S a ROU a 221
"I'.
u
B. COUNTY NAME
Ruther or
C. CITY OR TOWN
D. STATE E. ZIP CODE F. COUNTY CODE (fkrown)
B F r s i t'
c
EPA Form 3510-1 (8-90) CONTINUE ON REVERSE

CONTINUED FROM THE FRONT
VII. SIC CODES 4 11 M order of WWW
B. SECOND
A FIRST
Gper�l T Gperq)
T 3341
bewMary waiting ami aeOnina De sonrar[mo Meal*
u
C. THIRD D. FOURTH(
(rperl/l) T rPalMa')
7
n
VIIL OPERATOR INFORMATIM B.Is the name 11sted In Item
A NAME
VIII-A also Na o+vne(I
a Horse ea Corporation m YES 0 NO
w .
C. STATUS OF OPERATOR(Maer lhenpp lo(aklarNlodm muxvrlinrl "Ofkeq" erl •.
D. PHONE arca cork Cno.)
F-FEDERAL M- PUBLIC (orhrrNnufM... farvar) P (peclb)
A [phone]
S-STATE O= OTHER (sperlh)
P=PRIVATE
E. STREET OR P.O. BOX
_
4 5 Steubenvi le i e, Suite 405
w
F. CITY OR TOWN G. STATE:H ZIP CODE DCWDIAN LAND
Is the fadiity located on Indian lands?
S Pittsburgh PA 15205 ❑ YES ONO
K OUSTING ENVIRONMENTAL PERMITS
A. NET rchn esro Sarare Borer) e"!Y f Tnanaa
r
r 1
SINSINI NCO089109 8 P 4'j;
B. WC !Hale ronndlrr euro+r FIWdrE. OTHER AsecA4
v
N 0 0
f*-6) groat atesa. L.s Canattaatlan
o U
B
ACtivlHo
e N
C. RCRA Iymles
E OTHER s rrl
C
"we
5
/) zmeson ens seareentation Cantos,
g R
9
RUTHE-2012-002 and 013
1 *hese i IRerNa-201]-002) end
afiart a (RVIx64012 0„)
IS R
a ,r ,•
Y L IS y
w. MAP
Attach to this applkallon a topographic map of the area extending to at least one mile beyond properly boundaries. The map must show the ouWne of the facility, the
location of each of Its settling and proposed Intake and discharge structures, each of it, hazardous waste "aliment. storage, or disposal fadlllies, and each well where it
and surface water bodies in the map area. Sea Instructions for precise requiremenb.
InJects flids underground, include all springs, rivers, other
)GI. NATURE OF BUSINESS inmVide a bdafdasuf fon)
This newly constructed facility upon startup in the future will apply a proprietary hydrometallurgical process
(solvent extraction / alectro winning) for producing high grade zinc metal from two primary feed materials
including wash oxide (a.k.a. crude zinc oxide) and zinc motel drosses and skims recovered from galvanizing
operations. The production process includes use of feed materials in an aqueous and hydrocarbon based solvent
for in a cell house where an alectro winning
extraction process to produce a zinc rich electrolyte solution use
process is applied to produce metalie zinc. Similar technology is commonly used to produce metalie copper from
mined copper ore feed material in the western United States.
All. CERTIFICATION (sea Inabucaons)
1 cerdly anderpena)ty of few that I have pemonsly eremIn d end am famsar with the Infamo 4on subrNMed in pets eppaeeaon and of effachmems and Ma( based on my
inquiry al thoso persons hnalsofslefy responsible for obtaining the Wommaon contained In the application, I bolove that the Inlom5a600 Is MO. aeeomle, and eomOrfe. I
am aware that (here are signlacan/ penalties fersubMldng false Information, Inducting 010 poss@Isty ofhne end fmpdsenment.
A. NAME* OFFICIAL TITLE(4pe orpdnd B. SIGRATUR C. DATE SIGNED
Timothy R, easilone, Vice -President /J ���` _�__
be•eer �G
Environmental Affairs
COMMENTS FOR OFFICIAL USE ONLY
C
EPA Form 3610 -1(e -g0)

ATTACHMENTS TO
EPA FORM 3510-1
GENERAL INFORMATION
HORSEHEAD CORPORATION
RUTHERFORD COUNTY PRODUCTION FACILITY
• Figure 1, Site Area Map, Stormwater NPDES Discharge Permit, Horsehead Corporation,
Rutherford County, North Carolina, dated February 2012, as prepared by McGill
Associates, P.A.

• FIRST CITIZENS BANK
(� C S O D D 5 Lt7 firstcitizens.com 052030
����11
� 66-30/531
A S S 0 C I A T E S DATE
P.O. BOX 2258 : ASHEVILLE, NC 28802
PH: [phone]
March 29, 2012
PAY AMOUNT
Eight Hundred Sixty and 00/100 Dollars
TO THE 860.00 0
ORDER
OF N.C. DENR
1633 Mail Service Center OPERATING ACCOUNT
Raleigh, NC 27699-1633
AUT R ED SIGNATURE
• v�
-
[cGILL ASSOCIATES, P.A.
Check Date: 3/29/2012
052030
Invoice Number Date Voucher Amount Discounts Previous Pay Net Amount
Horsehead NPDES 3/29/2012 1000000016892 860.00 860.00
N.C. DENR TOTAL 860.00 860.00
First Citizens Bank 2 NCDENR
APR ? 2012
NR . WATE QUA[

EPA ID Number (copy from Item 1 of Form 1) Form Approved. OMB No. 2040-0086
Please print or type in the unshaded areas only. I I Approval expires 5-31-92
FORM
2 F
NPDES
U.S. Environmental Protection Agency
A Washington, DC 20460
��� E PA Application for Permit to Discharge Storm Water
Discharges Associated with Industrial Activity
Paperwork Reduction Act Notice
Public reporting burden for this application is estimated to average 28.6 hours per application, including time for reviewing instructions, searching existing data sources,
gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding the burden estimate, any other aspect
of this collection of information, or suggestions for improving this form, including suggestions which may increase or reduce this burden to: Chief, Information Policy
Branch, PM -223, U.S. Environmental Protection Agency, 1200 Pennsylvania Avenue, NW, Washington, DC 20460, or Director, Office of Information and Regulatory
Affairs, Office of Management and Budget, Washington, DC 20503.
(.Outfall Location
For each oudall, list the latitude and longitude of its location to the nearest 15 seconds and the name of the receiving water.
A. Ouffall Number D. Receiving Water
(list) S. Latitude C. Longitude (name)
N35 12 00 Will 51 06 Broad River
II. Improvements
A. Are you now required by any Federal, State, or local authority to meet any implementation schedule for the construction, upgrading or operation of wastewater
treatment equipment or practices or any other environmental programs which may affect the discharges described in this application? This includes, but is not limited
to, permit conditions, administrative or enforcement orders, enforcement compliance schedule letters, stipulations, court orders, and grant or loan conditions.
2. Affected Outfalls 4. Final
1. Identification of Conditions, Compliance Date
Agreements, Etc. number source of discharge 3. Brief Description of Project a.req. b. proj.
N/A - New Facility N/A -New N/A -New Facility N/A - New Facility
Facility
B: You may attach additional sheets describing any additional water pollution (or other environmental projects which may affect your discharges) you now have under
way or which you plan. Indicate whether each program is now under way or planned, and indicate your actual or planned schedules for construction.
III. Site Drainage Map
Attach a site map showing topography (or indicatin outline of drama areas served by the outfalls(s) covered in the application if a topographic map is unavailable)
depicting the facility including: each of its intakend disc tar Sa nu res the drainage area of each storm water outfall; paved areas and buildings within the drainage
area of each storm water outfall, each known pas rase us r outdoor storage of disposal of significant materials, each existing structural control measure
to reduce pollutants in storm water runoff, materials loading and access areas, areas where pesticides, herbicides, soil conditioners and fertilizers are applied; each of
its hazardous waste treatment, storage or disposal units (including each area not required to have a RCRA Permit which is used for accumulating hazardous waste
under40 CFR 262.34); each well where fluids from the facility are injected underground; springs, and other surface water bodies which received storm water discharges
from the facility.
EPA Forn 3510-2F (1-92) Page 1 of 3 Continue on Page 2

Narrative Description of
A For.edl o Wae, feoN . an.senna or Ne arae forded. uiss) d Impsdoua audaear QirAAq paved ansa ndbi/asl r*efr) d'akmd Is M Wel, and n 44—W of Ne Mtaf alafata San
drained by the aural
EPA Form 3510-2F (1-e2) Page 2 of 3 Continue on Page 3
OWan
Area of lmpervlaa Surface
Total Mea Dre'ned
Owes
AmaMbrpalsMntaalrs
Total Area enNN
Number
two Wde VMS)
(P.M. aMa)
Number
W'siae
Wnvko.MS)
1
acres
acres
B. Provide a narrative descdplion of significant materials that are currently or In the past three years have been trealed, stored or disposed In a manner to snowexposurs
to storm water; method or treatment, storage, or disposal; past and present materials management practices employed to minlmiza contact by these materiels Mth
&form water runoff materials loading and access areas, and the location, manner, and frequency In which pesticides, herbicides, soil conditioners, and ledgiZem are
epMad.
This is a new facility under construction. A variety of liquid and solidreaterials will be used in the production poreesa.
Process materials will be managed in tanks or container., and will be transported via pipes throughout the operation. Material
exposed to .tormwater will ba minimized, and when necessary will be managed to avoid potential impact to atormwater discharged
from the facility. h SPCC plan and SiIPPP will be developed and implemented, and employees iwll be trained to properly manage
materials prior to startup of the facility. Visual inspection, and housekeeping requirements will be defined In the SWPPP and
spa plana.
Feed material. include Wasik Oxide (crude zinc oxide) and zinc metal drosses and skims recovered from galvanizing operations.
(see attached sheet for addition information)
C. For each outran, provide the location and a description of axis ing structural and nonsbucluml conlrol nleaauMS to reduce pollutants In storm stater runoff; and a
description of the Vestment the storm waler M05IM3, Including the schedule and type of maintenance fur control and treatment measures and the ultimate disposal
of any solid or laid wastes other than by discharge.
oulfall
Lis(Codestrom
Number
Treatment Table 2F.1
1 All production areae within C e facility will nclude secondary containment and atormwater
collection basins. All storm water captured in the containment basins will be analysed prior to
release to the storswater system, use in the production process, or treated and discharged. This
scheme for managing atormwater in the production area of the facility and other areas of the
property will minimise the potential for polutants to enter atormwater that is discharged from the
este.
V. Nonstormwater Discharges
A I cer* under penalty of lav/ hat the outfall(s) covered by this applicator, have been tested or evaluated for the presence of nonstormwaler discharges, and that all
nonslonshavater discharged from these oulall(s) am Identified In either an accompanying Form 20 or From 2E application for the oudail.
Name and Official This ("a orpdnf)
Sgnatum o /
Dal* Signed
^ ' �I4//I>`C
�'1 4
Timothy R. Bael3one, Vlce-President
S. Provide a description of tha method used, the date ofary testing. and the onsite drainage points that were directly observed during • teat
is is a new facility that ie currently under construction. The facility will be designed and constructed in a manner to
inimize the potential for entry of prates. materials in atormwater that is diacharged.
VI. Significant Leaks or Spills
Provide existing information regarding the history of slgnnlranl leaks or spills of tofdo or hazardous pollutants at tiw facility, In the last ihree years. Including the
approximate date and location of the spill or leak, and the type and amount of matelot released.
W/A - tie. Facility
EPA Form 3510-2F (1-e2) Page 2 of 3 Continue on Page 3

Continued from Page 2 1
EPA ID Number (copy from Item 1 of Form 1)
II. Discharge Information
A, B, C, a D: See Instructions before proceeding. Canplete one set of tables for each oufell. Annotate the outlall number In in* space provided.
Table VII -A, VII -B, "I -C are Included on separate sheets numbers VII -1 and VIP2.
E. Poten0el discharges not covered by analysis — Is any lade pollutant listed N table 2F-2, 2F-3, or 2F-4, a substance or a component of a aubstana which you
currenaq use ormanufecture as an Intermediate or final product or byproduct?
© Yee (Est egsuch pollutants belay) ❑ No (go to Section IX)
See attached background informanloo describing feedstock material*, process chendoels/magenta, and pollutants that will be
monitored in the process wastewater effluent. Materials utilised and produced at the facility will be managed by personnel that
aro trained in procedures developed to minimize the potential for release of material. to the environment. Materials will be
managed to prevent the potential for entry In at.rDsmter that Se discharged from the facility.
III. Biological Toxicity Testing Dafa
Do you have any knowledge or reason to belle" that any biological teal f" acute or chronic hal tau, been mads an any of your discharges Bron a reralWly amler hi
rotation to your discharge within the lest 3 years?
❑ Yes (fist ad such Pollutants below) Q No (go to Sactid l DO
N/A 141. Facility
IX. Contract Analysts Information
Were any of the analyses reported In Item VII performed by • contract laboratory or consulting firm?
m Yes (fist me name, address, and telephone number of, endpollutents
No (go to Section X)
sam4siedb, etch such laboratory"6an belav)
A Name
B. Address
C. Area Code 6 Phone No.
D. Pollutants Analyzed
Tecnicas Seaside.
C1. Arapiles 13-14
28;35 Madrid -Spain
114 91 592 03 DO
Provided the background
information for the
feedstock amterisl,
anticipated process
chemicals/reagents and the
ezpeeted ploceu wa.tevater
effluent characteristics.
X. Certification
I cou y under feenely of few that this document and eN attachments vete prepared under my drecdon "aupeMslon in accordance rbth a system daslgned to .$sum
that qualffied poesonnel pmpery getherand evaluate the Information submitted. Based on my Inquiryofthe parson "persons who manage the system orthoso persons
directly responsible for gathering the infamubon, the infammeon submided /s, to the best of my Irnoiviedge and balot, buo, accumfe, and complete. I em mvam that
there are significant penalties torsubmildng false Information, including me possibility of fine andhnpdsonment forlaowing vlofab'ons.
A. Nome A Official Title (Type OrPdnfj
8. Area Code and Phone No.
Timothy R. Basilone, Vice -President, Env.Affairs
[phone]
C. Signau/re o y,
F1 ev^/losil
O. Date Signed
J 01L -"a
EPA Form 3510.2F (11-M Page 3 of 3

EPA ID Number (copy flour Item 1 o/Form 1) Forth Approved. OMB No. 2040-0086
Approval expires 5-31-92
VII. Discharge
Information (Continued from page 3 of Form 2F7
Part A—You must provide the results of at least one analysis for every pollutant in this table. Complete one table for each outfall. See instructions for additional details.
Pollutant
and
CAS Number
(Ifevailable)
Maximum Values
Include units)
Average Values
(include units)
Number
of
Storm
Events
Sampled
Sources of Pollutants
Grab Sample
Taken During
First 20
Minutes
Flow -Weighted
Composite
Grab Sample
Taken During
First 20
Minutes
Flow -Weighted
Composite
Oil and Grease
New Facility
N/A
Facility is under construction
Biological Oxygen
Demand (BODS)
New Facility
Facility is under construction
Chemical Oxygen
Demand (COD)
New Facility
Facility is under construction
Total Suspended
Solids(TSS)
New Facility
Facility is under construction
Total Nitrogen
New Facility
Facility is under construction
Total Phosphorus
New Facility
Facility is under construction
PH
Minimum New Faci1
Maximum
Minimum
Maximum
Facility is under construction
Pert B — List each pollutant that is limited in an effluent guideline which 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.
Pollutant
and
CAS Number
(if available)
Maximum Values
(include units)
Grab Sample
Taken During
First 20 Flow -Weighted
Minutes Composite
Average Values
(include units)
Grab Sample
Taken During
First 20 Flow -Weighted
Minutes Composite
Number
of
Storm
Events
Sampled
Sources of Pollutants
TSS
Manufacturing Process
NB3-N
Manufacturing Process
Total Aluminum
Manufacturing Process
Antimony
Manufacturing Process
Arsenic
Manufacturing Process
Total Cadmium
Manufacturing Process
Chlorides
Manufacturing Process
Total Chromium
Manufacturing Process
Total Cobalt
Manufacturing Process
Total Copper
Manufacturing Process
Fluoride
Imariufacturing Process
Total Iron
Manufacturing Process
Total Lead
Manufacturing Process
Total Nickel
Manufacturing Process
Total Tin
Manufacturing Process
Total Zinc
Manufacturing Process
PN
Manufacturing Process
ChronicToxicity
Manufacturing Process
Turbidity
Manufacturing Process
EPA Form 3510-21F (1-92) Page VII -1 Continue on Reverse

Continued from the Front
Part C - List each pollutant shown in Table 2F-2, 2F-3, and 2F-4 that you know or have reason to believe is present. See the instructions for additional details and
requirements. Complete one table for each outfall.
Maximum Values Average Values
Include units) (include units) Number
Pollutant Grab Sample Grab Sample M
and Taken During Taken During Stone
CAS Number First 20 Flow -Weighted First 20 Flow -Weighted Events
(if available) Minutes Composite Minutes Composite Sampled Sources of Pollutants
The facil ty is design d and will be onstructed and operated in manner to minimize the potential for
materials to enter sto water that is discharged The production area will Is underlain by containment
basins fo T capturing a ormwater. Sto water in he basins will in analyzed jefore being discharged to the
storrmirater system, used for production processes, or treated and discharged.
Part D— Provide data for the stone event(s) which resulted in the maximum values for the flow weighted composite sample.
1.
Date of
Stone
Event
2.
Duration
of Stone Event
im minutes)
3.
Total rainfall
during storm event
(in inches)
4.
Number of hours between
beginning of storm measured
and end of previous
measurable rain event
5.
Maximum flow rate during
rain event
(gallonshninute or
specify units)
e.
Total flow from
rein event
(gallons or specify units)
N/A - New
Facility
7. Provide a description of the method of flow measurement or estimate.
Stormwater system is designed to manage a 100 -year storm event.
EPA Form 3510-2F (1-92) Page VII -2

TIMOTHY R. BASILONE
Vice Ynaidenf EnoOonmeuhil A(Jnin
4955 STEUBENVILLE PIKE
SUITE 405
PITTSBURGH, PA 15205
March 26, 2012
WWW.HORSEHEAO.NET 724.773.2223
TBASILONEOHORSEHEAO.NET 412.788.4526
Mr. Ken Pickle
Environmental Engineer
North Carolina Department of Environment
and Natural Resources
Division of Water Quality
Stormwater Permitting Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
J
HBORSKHRAS•
C'ORPORA'i'ION
Lending the World in Zinc Recycling
f 0elLo)
f/aH Ow, ep✓= ¢12 112-
AlAd
,0 Q t s n
d � soon
Re: NPDES Stormwater Permit Application
Horsehead Corporation --
Rutherford County, North Carolina
Dear Mr. Pickle:
IN
MAR ?. S 2012
(n accordance with our prior discussions with you occ rring over the past year an NPDES
Stormwater Permit Application has been completed or the new Horsehead Corporation
(Horsehead) facility that is currently under development Rutherford County. As described in
the attached application, a stormwater management syste has been developed�that_is integral to
the operation of this facility and) that is designed to m 'mize the potential for discharge of
pollutants in stormwater from the site.
�'vt//,dddoes fh%s mPa�? CS�n �a�re ?
Please find enclosed three (3) copies of the following doc ents:
• EPA Form 3510-1,
• General Information and EPA Form 3510-2F, and
44�e-4+z°4A• The Application for Permit to Discharge Storm W ter associated with Industrial Activity
for the Rutherford County Production Facility presently being constructed by the
Horsehead Corporation.
��f/a� su6m,fia/ 3/28/2�c�'
Check d 0 eerreC/GYre-f.I rPeeiew� 4/x/nat
,k 41111 J--.54 'f/S/2o/2.JJ
14121-A/efiifle `i
vQ,� f � ®,.;,,,. �✓.P,J a/ae%oil mck

Bennett, Bradley
From: Bennett, Bradley
Sent: Friday, September 18, 2015 2:09 PM
To: [e-mail]'
Cc: Davidson, Landon; Aiken, Stan E; Walker, Fred, Pickle, Ken; 'Robin. [e-mail]'
Subject: Response on Stormwater Pond Question
Jim,
After our discussion this morning I just wanted to get back in touch on the issue of placing Pond 1 ("U" shaped pond
near the river) back into service. As discussed, we would like to receive any monitoring results that you have available
for the Pond 1 discharge that has occurred recently. These results should be forwarded to Landon Davidson (DWR) and
Stan Aiken (DEMLR) in our Asheville Regional Office. It is our understanding from our discussions that you have:
• Fixed the leak in the containment in the electrowinning area.
• Put in place a plug in the stormwater drainage system near the electrowinning area.
• Cleaned all the cells of the Pond 1 system.
• Cleaned the material from the energy dissipator at Pond 1.
• Flushed the drainage to pond 1 and you were planning to flush again today.
• Checked all containment systems and stormwater systems in the remainder of the site and have no remaining
non-stormwater flow discharging in the stormwater drainage to Pond 1.
• Instituted new procedures for containment systems and stormwater ponds to assure that needed removal of
material is done in a timely manner and have adequate freeboard in all containment areas.
Given all of the above efforts and the assurances that leaks have been corrected and no non-stormwater flow is present
the Horsehead facility can bring the pond 1 stormwater system back on line. In conjunction with this, you must be
prepared to monitor any discharge from the pond when it first begins in accordance with stormwater permit monitoring
requirements as outlined in Table 1 of the permit. You must also continue this monitoring daily while discharge from
the system occurs.
Please note that we consider this a temporary arrangement until we can conduct our site visit next Wednesday (9/23)
and have further discussions within our agency and with you and other staff with your facility.
If you have any questions, please contact me.
Bradley Bennett
Stormwater Permitting Program Phone: [phone]
NC Division of Energy, Mineral and Land Resources Fax: [phone]
1612 Mail Service Center Email: bradlev.bennett(d),ncdenr.00v
Raleigh, NC 27699-1612 Web: hdp://portal.nodenr.org/web/Ir/stormwater
Email correspondence to and from this address may be subject to public records laws

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Aug. 2, 2015
PUBLIC NOTICE
N.C. DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES INTENT TO ISSUE
NPDES STORMWATER DISCHARGE PERMIT #NCS000574 ,
Public comment on the draft permit is invited. All comments received by Sept. 10, 2015 will be
considered in the final determination regarding permit issuance and permit provisions.
PERMIT APPLICATION
Duke Energy Carolinas, LLC, 526 South Church St., Charlotte, N.C., has applied for an NPDES
stormwater permit for the Rogers Energy Complex (formerly known as the Cliffside Steam Station), 573
Duke Power Rd., Mooresboro, N.C., Cleveland and Rutherford counties. The facility is a coal -feed
power plant, which discharges industrial stormwater to Suck Creek and the Broad River.
The draft stormwater permit and related documents are available online at:
h=://Mrtal.nr,denr.or web/guestsduke-npdes-permits. Printed copies of the draft permit and related
documents may be reviewed at the department's Mooresville Regional Office, 610 East Center Ave.
Suite 301, Mooresville, N.C. To make an appointment to review the documents, please call 704-663-
1699.
Public comment on the draft permit should be mailed to: Stormwater Permitting, 1612 Mail Service
Center, Raleigh, N.C., 27699-1612.
Public comments may also be submitted by email to: publiccommentsna ncdem.gov. Please be sure to
include "Cliffside" in the email's subject line.
PUBLIC HEARING
The N.C. Department of Environment and Natural Resources will hold a public hearing to accept
comments on the draft permit on Thursday, Sept. 10 at 6 p.m. at Boiling Springs City Hall, 114 East
College Ave., Boiling Springs, N.C. Registration for speakers begins at 5 p.m.

Co -products:
-��rocess Overview
Raffinate
waucu WIUOIII .
Pregnant Leach Solution Recycles:
OIiWSE,H EAD
METAL PRODUC'.:-:; ,

512 N Salisbury St, Raleigh, NC 27604 to 484 Hicks Grove Rd, Mo... https://www.google.com/maps/dir/512+N+Salisbury+St,+Raleigh,...
Go:.-Igle
Maps
512 N Salisbury St, Raleigh, NC 27604 Drive 244 miles, 3 h 54 min
to 484 Hicks Grove Rd, Mooresboro, NC 28114
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Pickle, Ken
From: Forrest Westall <[e-mail]>
Sent: Wednesday, January 27, 2016 7:02 AM
To: Belnick, Tom; Chernikov, Sergei; Pickle, Ken
Subject: FW: Horsehead Idling Mooresboro Facility
Hello,
I thought you may be interested in this development. I have had no contact with them for quite a while. We parted
ways over their approach to compliance.
FYI
Forrest
httu://rccatalyst.com/?p=3 5755

llorsehead putting Mooresboro facility on idle I RC Catalyst Page 1 of 2
Home Search in site...
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for Rutherford County"
HOME BUSINESS DAYTRIPS EVENTSCAUNDAR OPINION OBITUARIES SUBMITYOURSTORY
Horsehead putting Mooresboro facility on idle Find Who Owns This
Number
Added by Staff Reporter on 01/25/2015. spokeo.coMCeh-Phone-Lookup
Saved under Business, News Enter Any Phone Number Now. Get Full Owl
Into. Try Free!
MOORESBORO — Hotsehead Holding Corp.
(NASDAQ: ZINC) today announced that it is
temporarily idling its Moomsbmo, North
Carolina zinc production facility.
The Company stated that the decision to
temporarily idle the facility is the result of many
factors, including a depressed zinc price which
recently has languished near its seven year low
and the Company's current liquidity situation.
A small workforce will be retained to manage the facility during this period.
Tweet IllrOe 4E tN Mrs b
NOAA WEATHER
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Lest Updated - Feb 4 2016,11:35 are EST
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Stormwater Sampling Results
Sample
Type of Sample
Lab Analysis Results
Stormwater Permit
Date
Benchmarks
Total Cadmium - 0.305 mg/I
2nd Qtr. Stormwater
Total Lead - 0.028 mg/I
Cadmium - 0.001
6/27/15
Test (0.3 in rain)
Total Zinc - 3.65 mg/I
mg/I
All other parameters passed
(Metals Analysis Only)
9/10/15
From small leak in the
Total Cadmium - 3.36 mg/I
Lead - 0.030 mg/I
SDO gate housing
Total Lead - 0.541 mg/I
Total Zinc - 685 mg/I
Total Cadmium - 1.01 mg/I
9
3rd Qtr. Stormwater
Total Lead - 0.5 mg/I
Zinc -.067 mg/I
Test (1.25 in rain)
Total Zinc - 25.5 mg/I, All other parameters passed
(Metal Analysis Only)
9/26/15
Requested Stormwater
Total Cadmium - 0.722 mg/I
755 - 100 mg/I
Sample
Total Lead -0.137 mg/I
Total Zinc - 19.2 mg/I
Total Cadmium - 0.86 mg/I
Requested Stormwater
Dissolved Cadmium - 0.75 mg/I
Total Nitrogen - 30
9/
Sample
Total Lead - 0.04 mg/I
mg/I
Total Zinc - 32 mg/l, All other parameters passed
Total Cadmium - 1.79 mg/I
Requested Stormwater
Dissolved Cadmium - 1.52 mg/I
Total Phosphorus -
9/29/15
Sample
Total Lead - 0.54 mg/I
2 mg/I
Total Zinc - 58.1 mg/I, All other parameters passed
Total Cadmium - 0.99 mg/I
Requested Stormwater
9/
Dissolved Cadmium - 0.8 mg/I
Chlorides - 860 mg/I
Sample
Total Lead - 0.0.32 mg/I
Total Zinc - 42.6 mg/l, All other parameters passed
Total Cadmium - 1.04 mg/I
Requested Stormwater
Dissolved Cadmium - 0.9 mg/I
Oil & grease - 15
10
Sample
Total Lead - 0.14 mg/I
mg/I
Total Zinc - 25.0 mg/I, All other parameters passed
Total Cadmium - 0.61 mg/I
10/2/15 Requested Stormwater
Dissolved Cadmium - 0.53 mg/I
pH - 6 to 9
Sample
Total Lead - 0.18 mg/I
Total Zinc - 17.6 mg/l, All other parameters passed

STORMWATER DISCHARGE OUTFALL (SDO)
MONITORING REPORT
Permit Numb _ i + e, R C EIVE „eAMPLES COLLECTED DURING CALENDAR YEAR: 2016 2od Quarter
(This monitoring report shall be received by the Division no later than 30 days from
2016
JUL 2 2 the date the facility receives the sampling results from the laboratory.)
FACIiny NAME Horsehead Metal Products, LLC CENTRAL FILES COUNTY Rutherford
PERSON COLLECTING SAMPLE(S) lm Harris DWR IOIV PHONE NO. [phone]
CERTHUD LABORATORY(S) Pam a - Huntersville Lab #3 81
Pana Lab - Asheville Lab #4U
SIGNATURE OF PERMITTEE OR DESIGNEE
REQUIRED ON PAGE 2.
Part A: Specific Monitoring Requirements
;:�:' �' =}
50050 •lr•
=797.77:
C0530';•1�6sC0600:?
'',CdtAlSuspended• IyewA7ofoiO;ih;collect@d'Total+l
7i'
G6665
x01094 "
�f'
0105Sr
OlOkZs. '
"009 0'.•
- •06556;,'
••0040'0
.D'lite'
^:
r
'o-'
fTolal;•
-
�
-
.,•
Total
's
,rs'�'..
ead, '
.:- ,>.,
'Cadmium,,
"�;
-•nTon=Polap:;'
`
'+:
i' butialLNoa ' ;Sam 'ledr,
p
Cotal.Z low
p Suspon0ed';
�'"' ;dotal'`
'!' '
dZinc, l biar,
I T',otal
; . ,
��Tofal ;,, i'
- hloii8es;:,
:Oil & ;
. `
•'
'
':.. ;:i? gilected•
infall .
itro`en' ,•
; ds'horus'
p
,Recover, dlei,•Iteco'veraiile;,.'
Recoverable;
Greased
;pH.`"'
v
r,
' �'•": •0���
�;,,
�_
%I.7•a +.
t
tp• x
• 'iu
.-m'
r /
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',-"
7':
'.�.[nbh8s :
Ing1p: J'
r;'m
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.
s
-in
:•-.S'YL,':
001 6-27-16
N/A
0.25
279
1.8
0.56
16.8
1.1
0.22
10.5
<0.51
6.0
Does this facility perform Vehicle Maintenance Activities using more than 55 gallons of new motor oil per month? YES 4120
(if yes, complete Part B)
Part B: Vehicle Maintenance Activity Monitoring Requirements
r'
i" �., -'Eoth
,Xorj-bblar•
_:Oytfa
'',CdtAlSuspended• IyewA7ofoiO;ih;collect@d'Total+l
7i'
:1Y'S'.•;.. ;Oil•&,G,rease(if.
Irfall ; -
.'a I'icable'
Q,SiCsfii?II;
yncd'e'
solids^'r `p r -
; :."m"!;
5cT
i" 'SU
Form SWU-247, last revised 21212012
Page 1 bf 2

STORM EVENT CHARACTERISTICS:
Date 6-27-16
Total Event Precipitation(inches): 0.25"
Event Duration (hours): NSA (only if applicable — see permit.)
(if more than one storm event was sampled)
Date
Total Event Precipitation (inches):
Event Duration (hours): (only if applicable —see permit.)
Mail Original and one copy too:
Division of Water Quality
Attn: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
"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."
LL--6� 7Z15/l�
(Sign re of Permittee) (Date)
Form SWU-247, last revised 2/2/2012
Page 2 of 2

STORMWATER DISCHARGE OUTFALL (SDO)
MONITORING REPORT
PermitNumber♦NCS"OOOS62� SAMPLES COLLECTED DURING CALENDAR YEAR: 2016 1st Quarter
(This monitoring report shall be received by the Division no later than 30 days from
the date the facility receives the sampling results from the laboratory.)
FACILITY NAME Horsehead Metal Products, LLC COUNTY Rutherford
PERSON COLLECTING SAMPLES)�i PHONE No. [phone]
CERTIFIED LABORATORY(S) Pace Lab - ar otte Lab # F— CFI�B E LP
Lab ah -Asheville Lab # —
MAY — 4 2016 1 SIGNATURE OF PERMITTEE OR DESIGNEE
REQUIRED ON PAGE 2.
Part A: Specific Monitoring Requirements DWR SECTION
WMRMATION PROCESSING UNIT
Does this facility perform Vehicle Maintenance Activities using more than 55 gallons of new motor oil per month? yes no
(ifyes, complete Part B)
Part B: Vehicle Maintenance Activity Monitoring Requirements
OutfHN6"
50050
79777
C0530
C0600
C0665
01094
01051
01027
00940
00556
00400
Date
Total
:
Cadmium,
Non -Polar
Outfall No. Sampled
Total Flow
Total
Suspended
Total
Total
Zinc, Total
Lead, Total
Total
Chlorides
Oil &
pH
Collected-'•
(if app.)
Rainfall
`Solids
Nitrogen
Phosphorus
;.Recoveraple
.Recoverable
Recoverable
Grease/
•
•rpm.
mo/dd/yr
' -. MG
Inches
mg/L
' mg/L
mg/L
mg/L
tng/L•
mg/l,
m' ' :
mg/L
SU '
1 See Note 1
Does this facility perform Vehicle Maintenance Activities using more than 55 gallons of new motor oil per month? yes no
(ifyes, complete Part B)
Part B: Vehicle Maintenance Activity Monitoring Requirements
OutfHN6"
Date Sample 50050 00556
Total Flow (if, Oil & Gfease (if
Collected Total Rainfall
applicable) applicable)
00530 00400
" Non -polar
O&G!•TPH
(Method 1664'
SGT -HEM), if
applicable
Total Suspended New Motor Oil
pH
Solids Usage
mo/dd/yr. MG inches mg/L
mg/L SU• gal/mo
Form SWU-247, last revised 212/2012
Pagel of 2

STORM EVENT CHARACTERISTICS:
Date See Note 1
Total Event Precipitation (inches):
Event Duration (hours): (only ifapplicable—seepermit.)
(if more than one storm event was sampled)
Date
Total Event Precipitation (inches):
Event Duration (hours): (only if applicable—see permit.)
Mail Original and one copy to:
Division of Water Quality
Attn: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
"I certify, under penalty of law t this document and all attachments were prepared under my direction or supervision in accordance with a
system designed to as a tha qu lified personnel properly gather and evaluate the information submitted. Based on my inquiry of the
person or persons w o ana e t e system, or those persons directly responsible for gathering the information, the information submitted is,
to the best of my kn wlec�ge a td elief, true, accurate, and complete. I am aware that there are significant penalties for submitting false
informatio nclu4i g the po sib lity of fines and imprisonment for knowing violations."
0
4 i2 1
(Signature ttee (Date)
NOTE 1:
There were no measureable storm events that took place during
normal business hours.
Form S WU-247, last revised 2/212012
Page 2 of 2

STORMWATER DISCHARGE OUTFALL (SDO)
R ECPU FRIG REPORT
� I VV GC 1IJJ
Permit Number NCS 000562 0 C T 3 0 2015 SAMPLES COLLECTED DURING CALENDAR YEAR: 2015 3rd Quarter
(This monitoring report shall be received by the Division no later than 30 days from
CENTRAL FILES the date the facility receives the sampling results from the laboratory.)
FACILITY NAME Horsehead Metal Products, LLC SWR SECTION COUNTY Rutherford
PERSON COLLECTING SAMPLE(S) ar to Howell PHONE NO. [phone]
CERTIFIED LABORATORY(S) Pace 55 - Charlotte Lab#5342
Pane T.ah - Asheville Lab #4U
SIGNATURE OF PERMITTEE OR DESIGNEE
REQUIRED ON PAGE 2.
Part A: Specific Monitoring Requirements
Does this facility perforin Vehicle Maintenance Activities using more than 55 gallons of new motor oil per month? yes ®o
Part B: Vehicle Maintenance Activity Monitoring Requirements
Date Sample
50050
79777
C0530
C0600
C0665
01094
01051
01027
00940
00556
00400
Outfall No.
Date
Sampled
Collected
Total Flow
(if app.)
Total
Rainfall
Total
Suspended
Solids
Total
Nitrogen
Total
Phosphorus
Zinc, Total
Recoverable
Lead, Total
Recoverable
Cadmium,
Total
Recoverable
Chlorides
Non -Polar
Od &
Grease/
TPH
pH
Usage
mo/dd/yr
MG
Inches
mg1L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
SU
1
9-25-15
N/A
1.25
61.0
0.56
0.099
25.5
0.5
1.01
<50.0
<5.0
6.6
1
9-26-15
N/A
1.6
19.2
0.137
0.722
6.9
1
9-28-15
N/A
0.3
5.6
0.15
<0.050
32.0
0.0418
0.862
36.3
<5.0
6.6
1
9-29-15
N/A
0.1
32.7
1.2
0.091
58.1
0.539
1.79
53.9
7.3
1
9-30-15
N/A
0.1
4.2
0.16
<0.050
42.6
0.323
0.988
43.4
<5.0
7.2
Does this facility perforin Vehicle Maintenance Activities using more than 55 gallons of new motor oil per month? yes ®o
Part B: Vehicle Maintenance Activity Monitoring Requirements
Form S W U-247, last revised 2/2/2012
Page 1 of 2
Date Sample
50050
00556
00530
00400
Total Flow (if
Total Rainfall
Oil & Grease (if
Non -polar
Total Suspended
pH
New Motor Oil
Outfall No.
Collected
applicable)
applicable)
O&G/TPH
(Method 1664
Solids
Usage
mo/dd/yr
MG
inches
mgtL
SGT -HEM), if
mg/L
SU
gallmo
applicable
Form S W U-247, last revised 2/2/2012
Page 1 of 2

STORM EVENT CHARACTERISTICS:
Date 9-25-15
Total Event Precipitation (inches): 1.25
Event Duration (hours): N/A only if applicable — see permit.)
(if more than one stone event was sampled)
Date 9-26-15
Total Event Precipitation (inches): 1.6
Event Duration (hours): N/A (only if applicable—see permit.)
Mail Original and one copy to:
Division of Water Quality
Attn: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
"I certify, under penalty of law, that this do meet nd all attachments were prepared under my direction or supervision in accordance with a
system designed to assure that qualifie -sono-. properly gather and evaluate the information submitted. Based on my inquiry of the
person or persons who manage the sy to or those persons directly responsible for gathering the information, the information submitted is,
to the best of my knowledge and ie tr a accurate, and complete.. am aware that there are significant penalties for submitting false
information, including the ssibility f I and imprisonment for knowing violations."
(Signature of Permittee)
Lb 26 (5
(Date)
Form SWU-247, last revised 2/2/1012
Page 2 of 2

STORMWATER DISCHARGE OUTFALL (SDO)
MONITORING REPORT
Permit Number NCS 000562
FACILITY NAME Horsehead Metal Products, LLC
PERSON COLLECTING SAMPLE(S) CharlieHowell
CERTIFIED LABORATORY(S) Pace Lab - Charlotte Lab#5342
Par . Lah - Asheville Lab #W_
Part A: Specific Monitoring Requirements
SAMPLES COLLECTED DURING CALENDAR YEAR: 2015 4t1i Quarter
(This monitoring report shall be received by the Division no later than 30 days from
the date the facility receives the sampling results from the laboratory.)
COUNTY Rutherford
PHONE NO. [phone]
SIGNATURE OF PERMITTEE ORDESIGNEE
REQUIRED ON PAGE 2.
" I% ":
''
50050'"
`' 79777
C0530'
C0600
' -00665 ''
01094
'0105f01027.
TotalFlow,(if,
06940 �
00556
00400' '
Obtfall�No:
y;
Date
"Sampled
Collected
Total Floiv
s (if app ), •
Total
• Rainfall• • •
:Total=
Suspended
: Solids•
Total
Nitrogen ,
" -
'Total
Phosphorus •
Zinc,.Iotal
Reco-verable ,
Lead, Total
,Recoverable;'.
Cadmic m•
'
Total
Recoverable
' '
Chlorides
.Non -Polar.
- Oil &
Grease /• .,
TPH
pH
Usage
'Ino/d'd/yr-
1vIG ''
Incties
mg/
•'mgtL
ni %L
mg/L
.•mg/L.
mg/L
•ing/L'`
mg/L' '
; 'SU
I
10-1-15
N/A
1.6
74.0
0.70
0.077
25.0
0.142
1.040
30.7
<5.0
7.2
1
10-2-15
N/A
1.25
47.3
0.25
0.086
I7.6
0.183
0.610
19.6
<5.0
7.1
1
10-5-15
N/A
2.0
7.2
<0.12
0.064
25.2
0.052
0.536
76.0
<5.0
6.8
1
10-6-15
NIA
0.0
5.9
0.19
<0.050
36.7
0.042
0.970
90.1
<5.0
6.4
1
10-27-15
N/A
0.3
123
0.18
0.14
30.7
1.200
0.374
<25.0
<5.0
66
Does this facility perform Vehicle Maintenance Activities using more than 55 gallons of new motor oil per month? yes no
Part B: Vehicle Maintenance Activity Monitoring Requirements
Form SWU-247, last revised 2/212012
Page I of2
Date Sample
50050
00556
00530
t 00400
TotalFlow,(if,
To'ta4Rainfall °r
Oil&Grease(if•
.,: Won -polar,,. ;:
Total Suspended'
PH•
:NewKolor'eil•;
OutfallNo..-r••:
".Collected
a licable)_
a licable
O&G/TPH
i (Method 1664
Solids
Usage
- mo/dd/ys::
1VIG
inches.
mg/L,
SGT-HEbI)i if.
mg/L
SU
�gnUmo ,
a' licable
-
Form SWU-247, last revised 2/212012
Page I of2

STORM EVENT CHARACTERISTICS:
Date 10/27/15
Total Event Precipitation (inches): 0.3
Event Duration (hours): N/A (only if applicable—see permit.)
(if more than one storm event was sampled)
Date
Total Event Precipitation (inches):
Event Duration (hours): (only if applicable —see permit.)
Mail Original and one copy to:
Division of Water Quality
Attn: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
"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 tqxssure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the
person or persons v o manage the system, or those persons directly responsible for gathering the information, the information submitted is,
to the best of my Icn edge and belief, true, accurate, and complete I am aware that there are significant penalties for submitting false
information, i udii ossibility of fines and imprisonment for knowing violations."
(Signature of
(Date)
Form SWU-247, last revised 212/2012
Page 2 of 2

STORMWATER DISCHARGE OUTFALL (SDO)
MONITORING REPORT
Permit Number NCS 000562
FACILITY NAME Horsehead Metal Products Inc.
PERSON COLLECTING SAMPLE(S) Wilt
CERTIFIED LABORATORY(S) Pace Lab - Ullarlotte Lab#5342
Pace T.ah - Asheville Lab #4—
Part A: Specific Monitoring Requirements
SAMPLES COLLECTED DURING CALENDAR YEAR: Z014 10
(This monitoring report shall be received by the Division no later than 30 days from
the date the facility receives the sampling results from the laboratory.)
COUNTY Rutherford
PHONE NO. 828 919-3135
SIGNATURE OF PERMITTEE OR DESIGNEE
REQUIRED ON PAGE 2.
tDatei
i i -------
Sample
Collected
1
00530
00400
Total Flow
(if applicable)
Total
Rainfall
Oil & Grease
(ifappl.)
Non -polar P
O&G/TPH
(Method 1664
SGT -HEM), if
appl.
Total
Suspended
Solids
pH
New Motor
Oil Usage
mo/dd/ r
1MG
linchex
m 1
me/1
----------
aUmo
----------
----------
Does this facility perform Vehicle Maintenance Activities using more than 55 gallons of new motor oil per month? _yesAno
(if yes, complete Part B)
Part B: Vehicle Maintenance Activity Mnnit—ino P -4--t.
Outfall Date
No. Sample
Collected
50050
00556
1
00530
00400
Total Flow
(if applicable)
Total
Rainfall
Oil & Grease
(ifappl.)
Non -polar P
O&G/TPH
(Method 1664
SGT -HEM), if
appl.
Total
Suspended
Solids
pH
New Motor
Oil Usage
mo/dd/ r
1MG
linchex
m 1
me/1
I unit
aUmo
Form S WU-247, last revised 2/2/2012
Page 1 of 2

STORM EVENT CHARACTERISTICS:
Date t4lk
Total Event Precipitation (in hes): N -
Event Duration (hours): tj lir (only if applicable—see permit.)
(ifmore than one storm event was sampled)
Date
Total Event Precipitation (inches):
Event Duration (hours):mpr(onlyifapplicable—see permit.)
Mail Original and one copy to:
Division of Water Quality
Attn: Central Files
1617 Mail Service Center
Raleigh; North Carolina 27699-1617
"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
to the best of my knowled d belief; true, accurate, and complete. i am aware that there are significant penalties for submitting false
information, includiyg h ossa 'lily otfines and imprisonment for knowing violations."
KV
(Signature of Perm'ttee) (Date)
Form SWU-247, last revised 2/2/2012
Page 2 of 2

STORMWATER DISCHARGE OUTFALL (SDO)
MONITORING REPORT
Permit Number NCS 000 501-
FACILITY
002
FACILITY NAME R.MC-1-j S AL -4d ProoL dN 1/l(i
PERSON COLLECTING SAMPLE(S) N h
CERTIFIED LABORATORY(S)Pct L-% . Gko.lot Lab # 5S4 Z.
Paw L•b - lis 6wi l It Lab #,_{+ o
Part A: Specific Monitoring Requirements
RECEIVED
JUL 21 2014
CENTRAL FILES
DWOIBOG
SAMPLES COLLECTED DURING CALENDAR YEAR: ZSl Oce•#.r J
(This monitoring report shall be received by the Division no later than 30 days from
the date the facility receives the sampling results from the laboratory.)
COUNTY R-:tict'fa,A
PHONE NO. (tttg ) 9l'i - 013
SIGNATURE OF PERMITTEE OR DESIGNEE
REQUIRED ON PAGE 2.
Date
Sample
Collected
i Total
Flow (if app.)
--
00556
00530
00400
Total Flow
(if applicable)
Total
Rainfall
Oil & Grease Non -polar
(if appl.) O&G/fPH
(Method 1664
SGT -HEM), if
appl.
Total
Suspended
Solids
pH
New Motor
Oil Usage
mo/dd/ r
MG
inches
m FA
m
----------
al/mo
----------
----------
Does this facility perform Vehicle Maintenance Activities using more than 55 gallons of new motor oil per month? _yes Ono
(if yes, complete Part B)
Part B: Vehicle Maintenance Activity Monitorine Requirements
Outfall Date
No. Sample
Collected
50050
00556
00530
00400
Total Flow
(if applicable)
Total
Rainfall
Oil & Grease Non -polar
(if appl.) O&G/fPH
(Method 1664
SGT -HEM), if
appl.
Total
Suspended
Solids
pH
New Motor
Oil Usage
mo/dd/ r
MG
inches
m FA
m
unit
al/mo
Form SW U-247, last revised 2/2/2012
Page 1 of 2

STORM.EVENT CHARACTERISTICS:
Date–bdF—
Total Event Precipitation ( _ NI K
Event Duration (hours): 1J (only ifapplicable– see permit.)
(if more than one storm event was sampled)
Date
Total Ev nt Precipitation (inpches):
Event Duration (hours): NI(only i applicable–see permit.)
Mail Original and one copy to:
Division of Water Quality
Attn: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
"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 ssure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person
or persons wh nage the system, or those persons directly responsible for gathering the information, the information submitted is, to the
best of my w dge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information,
including h po POT
of fines and imprisonment for knowing violations."
(Sig of Irmittee (Date)
Form SWU-247, last revised 2/2/20/2
Page 2 of 2

PermitN`umber 662
STORMWATER DISCHARGE OUTFALL (SDO)
MONITORING REPORT
FACILITY NAME Horsehead Metal Products, Inc.
PERSON COLLECTING SAMPLE(S)
CERTIFIED LABORATORY(S) Pace Lab - ar otte Lab #
Pace T,nh - Asheville Lab #4U
Part A: Specific Monitoring Requirements
SAMPLES COLLECTED DURING CALENDAR YEAR: 201' j
(This monitoring report shall be received by the Division no later than 30 days from
the date the facility receives the sampling results from the laboratory.)
COUNTY Rutherford
PHONE NO. [phone]
SIGNATURE OF PERMITTEE OR DESIGNEE
REQUIRED ON PAGE 2.
Date
''Collected
Date
Sample
Collected
50050
Total Flow
(ifapplicable)
Samp
00556
Oil & Grease
(ifappl.)
00530
00400
Non -polar
O&G/TPH
(Method 1664
SGT -HEM), if
appl.
Total pH
Suspended
Solids
New Motor
Oil Usage
� •� ii'�\[�i:l��\d�?�t�i�L'1�Lf�"�iiil�
mo/dd/ r
-
�l'S`s��i1 L7i�_Z:�•�
I inches
m fl
ss
I m /I
I unit
al/mo
O
iso R
�a Et O
oaf
, tRio�Q.
S �`Ri/t
4►Y, iy
.4 4- eqL
...
Does this facility perform Vehicle Maintenance Activities using more than 55 gallons of new motor oil per month? Lyes no
(ifyes, complete Part B)
Part B: Vehicle Maintenance Activitv Monitoring Reauirements
Outfall
No.
Date
Sample
Collected
50050
Total Flow
(ifapplicable)
Total
Rainfall
00556
Oil & Grease
(ifappl.)
00530
00400
Non -polar
O&G/TPH
(Method 1664
SGT -HEM), if
appl.
Total pH
Suspended
Solids
New Motor
Oil Usage
mo/dd/ r
1MG
I inches
m fl
I
I m /I
I unit
al/mo
O
iso R
�a Et O
oaf
, tRio�Q.
S �`Ri/t
4►Y, iy
.4 4- eqL
...
Foam SWOT -247, last revised 21212012
Pagel of 2

I .
STORM EVENT CHARACTERISTICS:
Date 0 1 Nc ,,j
Total Event Precipitation (in hes): �—
Event Duration (hours): .
(onlyifapplicable—see permit.)
(if more than one storm event was sampled)
Date I&
Total Event Precipitation (inches): N[A
Event Duration (hours): _��(only ifapplicable —see permit.)
Mail Original and one copy to:
Division of Water Quality
Attn: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
"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."
(i tureofPermittee) (Date)
Form SWU-247, last revised 2/2/2012
Page 2 of 2

STORMWATER DISCHARGE OUTFALL (SDO)
MONITORING REPORT
Permit Number NCS 000562 SAMPLES COLLECTED DURING CALENDAR YE 20gab�
Qer
RECEIVED(This monitoring report shall be received by the Division laays from
the date the facility receives the sampling results frooratory.)
FACILITY NAME Horsehead Metal Products, LLC J U I 1 2015
PERSON COLLECTING SAMPLE(S) ChUlle 11OWell - S
CERTIFIED LABORATORY(S) Pace Lab - Charlotte 'Lab #J ,
Pane Lah - Asheville Lab 4�
Part A: Specific Monitoring Requirements
COUNTY Rutherford
PHONE NO. [phone]
SIGNATURE OF PERMITTEE OR DESIGNEE
REQUIRED ON PAGE 2.
O&Vtt lAA W loo go y 06o67
Does this facility perform Vehicle Maintenance Activities using more than 55 gallons of new motor oil per month?
(if yes, complete Part B)
Part B: Vehicle Maintenance Activity Monitoring Requirements
0.03 01061 %040
yes ©o
15 G-9
utfall No.
Date Sample
Collected
50050
7971"NE l C0530
C0600
C0665
01051
...
00940
0055 X00400
mg/L
Date
Total
x .°':
Cadmium,
Non-Polri `r
Outfall No.
Sampled
Total Flow
Total Suspended
Total
Total
Zinc, o al Lead, Tota
Total
hlorides
Oil& pH
Collected
(if app.)
Rainfall Solids
Nitrogen
Phosphorus
Recoverable Recoverabl
Recoverable
Grease!
TPH
mo/dd/yr
MG
Inches mg/L
mg/L ;'
; mg/L
L mg/L
mg/L
mg/L SU
I
6-27-15
N/A
0.3 5.5 •
<0.12
• <0.050
.3.65 .0.028
.0.305
•86.3
<5.0 7.3
O&Vtt lAA W loo go y 06o67
Does this facility perform Vehicle Maintenance Activities using more than 55 gallons of new motor oil per month?
(if yes, complete Part B)
Part B: Vehicle Maintenance Activity Monitoring Requirements
0.03 01061 %040
yes ©o
15 G-9
utfall No.
Date Sample
Collected
50050
Total Flow (if ._ - _''
a licable) °�1 Fla °
00556: „`
Oil & Grease` on -polar
applicable) O&C/TPH
(Method 1664
mg/L SGT -ITEM), if
applicable
00530
Total Suspended
Solids
00400
PH
New Motor Oil
Usage
...
mo/dd/yr
MG inches
mg/L
SUgal/mo
:,
Form S WU-247, last revised 2/2/2012
Pagel of 2

STORM EVENT CHARACTERISTICS:
Date 6-27-15
Total Event Precipitation (inches): 0.3
Event Duration (hours): N/A (only if applicable — see permit.)
(if more than one storm event was sampled)
Date
Total Event Precipitation (inches):
Event Duration (hours): (only if applicable — see permit.)
Mail Original and one copy to:
Division of Water Quality
Attn: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
"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 aFlctg
that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the
person or persons wage the system, or those persons directly responsible for gathering the information, the information submitted is,
to the best of my knoand belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false
information, includissitl{lity of fines and imprisonment for knowing violations."
(Signature
q2o►S
(Date)
Form S WU-247, last revised 2/2/2012
Page 2 of 2

STORMWATER DISCHARGE OUTFALL (SDO)
MONITORING REPORT
Permit Number NCS 000562
FACILITY NAME
PERSON COLLECTING SAMPLE(S)
CERTIFIED LABORATORY(S) Pace Lab - Charlotte Lab#5342
Pare T.ah - Asheville Lab #40
Part A: Specific Monitoring Requirements
SAMPLES COLLECTED DURING CALENDAR YEAR:
(This monitoring report shall be received by the Division no later than 30 days from
the date the facility receives the sampling results from the laboratory.)
COUNTY Rutherford
_ PHONE NO. [phone]
�10�_ ._
APR 2 0 20 SIGNATURE OF PERMITTEE OR DESIGNEE
REOUIRED ON PAGE 2.
CENTRAL FILES
DUJR SE
Does this facility perform Vehicle Maintenance Activities using more than 55 gallons of new motor oil per month?
(if yes, complete Part B)
Part B: Vehicle Maintenance Activity Monitoring Requirements
yes
-.' Outfall No.
Date Sample J'- 50050
_'' Total Flow (if
Collected applicable)
50050
797.
C,
C060
00400
1094
01051
01027
00940
005561 : 00400
, Outfall No.
Date
Sampled
Total Flow
Total `
To
-"-
Total
0 1 '�
'°
Enc, Total
Lead, Total
Cadmium,
Non -Polar
Oil &
Collected
(if app.)
Rainfall
Suspended
Nitrogen
Phosphorus
Recoverable
Recoverable
Total
Chlorides
Grease/ pH
Solids
Recoverable
'frkl
...
mio/dd/yr
,MG
Inchh�es��
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L SU
-
1
—
N (�
At 0 1QC
r
G(
i/ nq f"
! S
Does this facility perform Vehicle Maintenance Activities using more than 55 gallons of new motor oil per month?
(if yes, complete Part B)
Part B: Vehicle Maintenance Activity Monitoring Requirements
yes
-.' Outfall No.
Date Sample J'- 50050
_'' Total Flow (if
Collected applicable)
Total` ainfatl '
". 00556
'Oil &Grease
applicable)
O&G/TPH
(Method 1664
SGT -HEM), if
applicable
- 00530
. =Total Suspended
Solids
00400
PH
New Motor Oil
Usage
mo/dd/yr MG
inches
mg/L
mg/L
STU
gal/mo
Form S WU-247, last revised 2/2/2012
Pagel of 2

STORM EVENT CHARACTERISTICS:
Date N
Total Event Precipitation (in hes):
IA -
Event Duration (hours): � (only if applicable — see permit.)
(if more than one storm event was sampled)
Date 9 /t
Total Event Precipitation(in hes): A -
Event Duration (hours): (onl if applicable — see permit.)
Mail Original and one copy to:
Division of Water Quality
Attn: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
"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."
N
(Signature of Permittee)
(Date)
Form SWU-247, last revised 2/2/2012
Page 2 of 2

STORMWATER DISCHARGE OUTFALL (SDO)
MONITORING REPORT
Permit Number NCS 000562 SAMPLES COLLECTED DURING CALENDAR YEAR:201 ' !n?'-+ * r-�)
(This monitoring report shall be received by the Division no later than 30 days from
the date the facility receives the sampling results from the laboratory.)
FACILITY NAME Horsehead Metal Products, Inc.
PERSON COLLECTING SAMPLE(S)
CERTIFIED LABORATORY(S) Pace Lab - Charlotte Lab#5342
Pace. Tnh - Asheville Lab 4gpe `ED
Part A: Specific Monitoring Requirements
JAN 14 2015
Mt CC
COUNTY Rutherford
PHONE NO. [phone]
SIGNATURE OF PERMITTEE OR DESIGNEE
REQUIRED ONPAGE 2.
Does this facility perform Vehicle Maintenance Activities using more than 55 gallons of new motor oil per month? _yes NO
(if yes, complete Part B)
Part B: Vehicle Maintenance Activitv Monitoring Requirements
Outfall Date
No. Sample
Collected
50050
00556
00530
----------
Total Flow
(if applicable)
Total
Rainfall
Oil & Grease
(if appl.)
Non -polar
O&G/TPH
(Method 1664
SGT -HEM), if
appl.
Total
Suspended
Solids
pH
New Motor
Oil Usage
mo/dd/yr
MG
inches
----------
mg/1
----------
al/mo
----------
----------
----------
Does this facility perform Vehicle Maintenance Activities using more than 55 gallons of new motor oil per month? _yes NO
(if yes, complete Part B)
Part B: Vehicle Maintenance Activitv Monitoring Requirements
Outfall Date
No. Sample
Collected
50050
00556
00530
00400
Total Flow
(if applicable)
Total
Rainfall
Oil & Grease
(if appl.)
Non -polar
O&G/TPH
(Method 1664
SGT -HEM), if
appl.
Total
Suspended
Solids
pH
New Motor
Oil Usage
mo/dd/yr
MG
inches
mg/1
mg/1
unit
al/mo
Form SWU-247, last revised 2/2/2012
Pagel of 2

STORM EVENT CHARACTERISTICS:
Date N jAr
Total Event Precipitation (inches): N bt
Event Duration (hours): 41A' (only if applicable—see permit.)
(if more than one storm event was sampled)
DateA�
Total Event Precipitation (in hes): NIA
Event Duration (hours): �(onlyifapplicable—see permit.)
Mail Original and one copy to:
Division of Water Quality
Attn: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
"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 forgathering the information, the information submitted is,
to the best of my kne a belief, true, accurate; and complete. Iam aware that there are significant penalties for submitting false
information, includ th py�bility of fines and imprisonment for knowing violations."
(Signature of Permittee)
GSI /C7g /1,5
(Date)
Form SWU-247, last revised 2/2/2012
Page 2 of 2

484 HICKS GROVE ROAD WWW.HORSEHEAD.NET
MOORESBORO. NC 18114
Date: April 25, 2017
Mike Randall
Stormwater Permitting Program
NC Division of Energy, Mineral and Land Resources (DEMLR)
Land Quality Section, Stormwater Permitting
1612 Mail Service Center
Raleigh, NC 27699-1612
Re: NPDES Stormwater Permit NCS000562
Dear Mr. Randall:
METAL PRODUCTS. LLC
a., Wkm fx�Arod
F
ST�R�w_` bvo
FRFFRMC� G
Based on our discussions during the meeting held at the Mooresboro facility on April 11, 2017
between Horsehead Metal Products, LLC ("HMP") and representatives of the North Carolina
Department of Environmental Quality ("DEQ"), including yourself, HMP is requesting a
modification to the stormwater permit for the HMP facility (referenced above) located at 484
Hicks Grove Road, Mooresboro, NC 28114. Described below are the agreed-upon minor
changes being requested:
1) Section B: Analytical Monitoring Requirements:
a. The monitoring schedule contained in Table 2 should be changed to reflect a new
start date for the facility. Given that the precise future date on which the facility
might commence operations is undetermined, HMP proposes inclusion of general
language that references "the date on which the plant begins zinc production,"
with monthly reporting to resume after that date. We hope to begin production of
zinc during 2018, but planning for that has yet to completed, therefore that
general time frame remains uncertain.
h. Remove the requirement to provide a Summary Report given the conclusion at the
April 11 meeting that this has been deemed to be complete.
2) Include language in the permit noting the stormwater samples taken at SDO 01 are
representative of the contribution of the existing stormwater flows from the general site,
including the ponds in the SX area.
0

484 HICKS GROVE ROAD WWW.HORSEHEAD.NET
MOORESBORO, NC 28114
HOR45j1EHEAD
METAL PRODUCT.
a M4YWry 4Jflarxld co �.,,..,.,..,
Development of an engineering plan is underway to address the process issues that were
experienced during the original start up phase. HMP will continue to adhere to the requirements
of the existing permit.
Please send a draft of the modified permit to me for review at your earliest convenience. If you
have questions or comments, please contact me or Jim Harris.
Regards,
r
Williamson

NC5cz>0576l
Riddle, Rick L
From: Randall, Mike
Sent: Tuesday, June 27, 2017 2:15 PM
To: Riddle, Rick L
Subject: Fwd: Horsehead storm water/ waste water permit renewal
Sent from my !Phone
Mike Randall
Stormwater Permitting Program NC Division of Energy, Mineral and Land Resources (DEMLR)
Office: 919-807-6374
Cell: 919-389-7801
1612 Mail Service Center
Raleigh, NC 27699-1612
Email correspondence to and from this address may be subject to public records lows
Begin forwarded message:
From: "Burch, Brent" <[e-mail]>
Date: June 27, 2017 at 2:03:07 PM EDT
To: "Davidson, Landon" <[e-mail]>, "Randall, Mike" <[e-mail]>
Cc: "Woolley, Julie" <[e-mail]>, "Aiken, Stan E" <[e-mail]>, "Morris,
Sean" <[e-mail]>, "Menzel, Jeff" <[e-mail]>
Subject: FW: Horsehead storm water/ waste water permit renewal
Hi Landon and Mike,
The Hazardous Waste Section is requesting that DEMLR and DWR put all stormwater and NPDES permit
modifications related to Horsehead on hold until we can determine what impact, if any, those
modifications may have on our regulatory jurisdiction related to a joint HWS/EPA January sampling
event. As both of you may be aware, 9 of 15 sample results came back exceeding hazardous waste limits
for one or more constituents including lead, cadmium, chromium or silver. All 9 areas are, or could be,
related to stormwater management or regulated discharges.
HWS will be having a conference call this Thursday with Horsehead and EPA to discuss the sampling
results. Additionally, HWS continues to work with EPA to establish a plan of action to address both our
concerns at the site. I know all of our programs have responsibilities to respond to our customers in a
timely manner, so if we need to reach out to DEMLR or DWR staff at the Division level we would be happy
to do so.
Please let me know if you have any questions, concerns or thoughts on moving forward. I would be
happy to set up a conference call where we can all discuss this in more detail internally if that is
preferred.

Thanks ... Brent
Brent G. Burch
Compliance Branch Head
Hazardous Waste Section
Division of Waste Management
828 3219585 office
919 270 2049 mobile
Brent. Burch (d_)ncdenr.gov
PO Box 1427
Andrews, NC 28901
—' Nothing Compares!
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Menzel, Jeff
Sent: Friday, June 23, 2017 3:58 PM
To: Burch, Brent <[e-mail]>; Morris, Sean <[e-mail]>
Subject: Horsehead storm water/ waste water permit renewal
Sean and Brent,
After reviewing the current draft of Storm Water permit NCS000562 for American Zinc Products LLC
(former Horsehead Metals), I would like to request that this draft and any other NPDES permit be placed
on hold.
The current storm water permit does not expire until March 2018 and I feel that any analytical data
available along with observations made by HWS during site visits staff be conveyed to DEMLR/DWR
before any subsequent permits are issued.
This facility, in its shorts life span, has had numerous spills of hazardous material with the primary
conveyance being the storm water/wastewater systems. There are NPDES permits issued for both.
The facility has asked for DEQ's input during their current engineering phase prior to starting operations
again in 2018. To facilitate a beneficial response to the facility I think it is prudent that the various
Division's share information or concerns regarding permit requirements or applicable regulations.
If you need any additional information or supporting documentation for this request I will be happy to
provide that.
Thanks,

Jeff
Jeff Menzel
Western Region Environmental Specialist
Hazardous Waste Section
Division of Waste Management
828 419 5034 office
919 270 1967 cell
Jeff.menzel@ ncdenr.gov
PO Box 117
Black Mountain, NC 28711
N:.
Nothing Compares
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.