NCS000304_Geradu Ameristeel US Inc. - Final - 5-14-13_20130716

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North Carolina Department of Environment and
Division of Water Quality
Pat McCrory Thomas A. Reeder
Governor Acting Director
July 16, 2013
Mr. Anthony S. Read
Gerdau Ameristeel US Inc.
P.O. Box 481980
Charlotte, NC 28269
_— —_ __
Natural Resources
John E. Skvarla, III
Secretary
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Subject: Compliance Evaluation Inspe '�
Gerdau Ameristeel US Inc.
6601 Lakeview Road
Charlotte,. NC 28269
NPDES Individual Stormwater Permit NCS000304
Mecklenburg County
Dear Mr. Read:
On May 5, 2013, Jeff Mitchell from Charlotte -Mecklenburg Stormwater Services (CMSWS), conducted a site
inspection of the Gerdau Ameristeel US Inc. facility located at 6601 Lakeview Road in Charlotte, Mecklenburg
County, North Carolina. The site drains to Long Creek, Class C waters located in the Catawba River Basin.
The site visit and file review revealed that the subject facility is covered by NPDES Individual Stormwater
permit NCS000304.
This inspection was conducted as part of a cooperative working agreement between Mecklenburg County and
the Division of Water Quality. In addition, the inspection was conducted on behalf of the City of Charlotte in
compliance with the City's NPDES Permit, NCS000240, Part II Section H. The following observations were
noted during the Charlotte -Mecklenburg Stormwater Services inspection (please see the attached addendum
for information about your permit):
1) Stormwater Pollution Prevention Plan ISPPP)
A Stormwater Pollution Prevention Plan (SPPP) has been developed, recorded, and properly implemented.
Yes ® No ❑
2) Qualitative Monitoring
Qualitative monitoring has been conducted and recorded in accordance with permit requirements.
Yes ® No ❑
3) Analytical Monitoring
Analytical monitoring has been conducted and recorded in accordance with permit requirements.
Yes ® No ❑ NA ❑
4) City of Charlotte Stormwater Ordinance
Dry weather flows were noted during the inspection regarding the on-site capped landfill. As noted in the
enclosed report the Division would like more information regarding these flows.
Mooresville Regional Office
Location: 670 East Center Ave., Suite 301 Mooresville, NC 28115
Phone: [phone] Fax: [phone] Customer Service: 1-877-623-6748
Internet: http:!/potlal.ncdenr.orglweblwq
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Mr. Anthony S. Read, Gerdau Ameristeel US Inc.
Compliance Evaluation Inspection, Page 2
July 16, 2013
Thank you for the assistance and cooperation during the inspection. Overall, the facility's'Stormwater program
was well developed and implemented and this Office commends the permittee's efforts to ensure compliance
with your NPDES permit.
However, as noted above and in the enclosed report, this office is requesting additional information regarding
the dry weather flows described in the report's Summary section; please provide a written response by
August 16, 2013, describing the flows and any existing treatment. In responding to the request, please
address your comments to the attention of Ms. Marcia Allocco at the letterhead address.
If you have any questions, comments; or need assistance understanding any aspect of your permit, please do
not hesitate to contact Jeff Mitchell with CMSWS at [phone] or Ms Allocco of the Division of Water
Quality at [phone] or [e-mail].
cc:
Sincerely, � i �
for Michael L. Parker
Regional Supervisor
Surface Water Protection Section
Mooresville Regional Office
Rusty Rozzelle, MCWQP
Craig Miller, City of Charlotte
Water Quality Central Files
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115
Phone:[phone] Fax: [phone] Customer Service: tA77-623-6748
Internet: http:llportal.ncdenr.org/web/wq
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Mr. Anthony S. Read, Gerdau Ameristeel US Inc.
Compliance Evaluation Inspection, Page 3
July 16, 2013
The National Pollutant Discharge Elimination System (NPDES) program was established under the federal
Clean Water Act and then delegated to the Division of Water Quality for implementation in North Carolina. The
NPDES permitting program for stormwater discharges was established in 1990. Phase I focuses on site and
operations planning to reduce pollutant sources.
Through the NPDES permitting program industrial facilities that fall into one of the subject ten categories are
required to obtain permit coverage under a general permit or an individual permit, depending upon the
facilities SIC code and the industrial activity occurring at the facility. There are currently 19 active general
stormwater permits in North Carolina. One condition that is applicable to both the general permits and
individual stormwater permits is the requirement to develop and implement site-specific comprehensive
Stormwater Pollution Prevention plans (SPPP). These plans are required to include a comprehensive
evaluation of the site and operations to reduce pollutant sources and prevent pollutant discharge.
Copies of the general permits and accompanying documents can be accessed from the following we page:
http://portal.ncdenr.org/web/wq/ws/su/npdessw#General_Permits_NPDES. Permit text, technical bulletins,
discharge monitoring forms, and a Notice of Intent [which is the application for coverage under a NPDES
General Stormwater Permit] can be found on this website.
The following items are a subset of permit requirements and are listed to assist you and help bring your
attention to certain permitting issues, process and condition requirements of your permit. Please see the
above mentioned website to obtain a copy of the permit so you may fully comply with all the conditions therein.
Failure to properly comply with conditions of the permit, like those bulleted below, is a violation(s) of
the permit and subject to civil penalty assessment(s) of up to $25,000.00 per day.
• Industrial facilities that fall into one of the subject ten categories are required to obtain permit coverage
under a general NPDES stormwater permit or an individual NPDES stormwater permit
• All persons desiring to have facilities covered by a General Permit must register with the Division of
Water Quality (DWQ) by filing of a Notice of Intent (NO[) and Applicable Fees.
• This Notice of Intent (NOI) must be submitted and a Certificate of Coverage issued prior to any
discharge of stormwater associated with the industrial activity, process wastewater, and/or mine
dewatering.
• Once the Notice of Intent is received, DWQ will review and determine whether a Certificate of Coverage
(COC) may be issued. If this Certificate of Coverage is issued the facility is covered by the General
Permit. That is, the permittee is authorized to discharge stormwater, process wastewater, and/or mine
dewatering pursuant to the type of General Permit until the permit expires or is modified or revoked.
• 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.
• There are currently 19 active general permits. Permit conditions vary accordingly; however, most of the
permits have the following condition requirements (you must read your entire permit to ensure full
compliance):
o Development and compliance with the Stormwater Pollution Prevention Plan
o Collection, reporting, and recording of Analytical Monitoring
o Collection, reporting, and recording of Qualitative Monitoring
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28175
Phone: [phone] \Fax: [phone] Customer SeNice: 1-877-623-6748
Internet: hgp:llportal.ncdenr.org/web/wq
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Mr. Anthony S. Read, Gerdau Ameristeel US Inc.
Compliance Evaluation Inspection, Page 4
July 16, 2013
o Collection, reporting, and recording of Vehicle Maintenance Monitoring (if applicable)
Records —Visual monitoring shat! be documented and records maintained at the facility along
with the Stormwater Pollution Prevention Plan. Copies of the analytical monitoring results shall
also be maintained on site. The Permittee shall retain records of all monitoring information,
ncluding all calibration and maintenance records and all original strip -chart recordings for
continuous monitoring instrumentation, and copies of all reports required by this general permit
for a period of at least 5 years from the date of the sample measurement, report, or application.
0 Expiration F is not authorized to discharge after the expiration date of the general
permit. 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. 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
subject to enforcement. Failure to renew your permit is a violation.
Transfer —The Certificate of Coverage (COC) issued pursuant to this general permit is not
transferable to any person expect after notice to and approval by the Director. The Director may
require modification or revocation and reissuance of the Certificate of Coverage to change the
name and incorporate such other requirements as may be necessary under the Clean Water
Act. The Permit is NOT transferable.
Name Change, Closure, or Facility Ownership change —Permittee is required to notify the
Division in writing in the event the permitted facility is sold or closed. The Division of Water
Quality views changes of name or ownership as a modification that requires the Director's
approval and reissuance of the permit. Name and ownership changes require you to complete a
Name/Ownership Change Form from the Division and mail it back to the Division of Water
Quality along with all appropriate information.
o Proper Operation and Maintenance is a requirement of the permit.
Mooresville Regional Office
location: 610 East Center Ave., Suite 301 Mooresville, MC 28115
Phone: (704j 663-16991 Fax: [phone] Customer Service: 1-877-623-6748
Internet httpalpodal.ncdenr.orglweblwq
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Permit: NCS000304
SOC:
County: Mecklenburg
Region: Mooresville
Compliance Inspection Report
Effective: 06/01/09 Expiration: 05/31/14 Owner: Gerdau Ameristeel Corporation
Effective: Expiration: Facility: Ameristeel Corporation
6601 Lakeview Rd
Contact Person: Charlie Blubaugh Title:
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Certification:
Charlotte NC 28269
Phone:
Phone:
Inspection Date: 05/14/2013 Entry Time: 01:00 PM Exit Time: 06:00 PM
Primary Inspector: Water Quality Program Meckenburg County Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ■ Compliant fl Not Compliant
Question Areas:
0 Storm Water
(See attachment summary)
Inspection Type: Compliance Evaluation
Page: 1

Permit: NCS000304 Owner -Facility: Gerdau Ameristeel Corporation
Inspection Date: 05/14/2013 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Facility Description:
Gerdau Ameristeel US Inc. is a steel manufacturer that is located at 6601 Lakeview Road on approximately 106 acres.
Compliance History:
A review of Charlotte -Mecklenburg Storm Water Services (CMSWS) files was conducted. A Notice of Violation was issued
by CMSWS for a diesel spill that occurred on July 30, 2012.
Industrial Operations/City of Charlotte Stormwater Ordinance Review
Aboveground Storage Tanks (ASTs) —
A double -walled, diesel aboveground storage tank (AST) is located near the scrap yard. Several fuel ASTs and ASTs
holding lubricants were observed near the slag sorting area. No stormwater issues were noted at the time of the
inspection,
Outdoor material storage area(s) —
Large scrap metal piles, piles of scaling material and large piles of slag are located outdoors and exposed to stormwater.
Oil/water separator and/or Pretreatment -
The facility has an oil/water separator near the AST in the scrap yard. No stormwater issues were observed.
Ad d iti on a I Observations
Dry weather Flows —
Water is sprinkled over hot slag, and the water is allowed to discharge to the west pond. A review of the permit indicates
DWQ is aware of the slag quench water that is discharged to the west pond. It was noted the water from the west pond
can be pumped to the south pond, and from there it can be pumped to the north pond. The slag quench water is ultimately
discharged from the west and south ponds.
During the inspection a dry
weather flow (DWF) was observed in the stormwater ditch near the south pond. A discussion
between the inspector and accompanying facility personnel indicated that stormwater from the capped, inactive
hazardous waste landfill takes several days to drain, and that the landfill cap is checked annually. A second source of the
DWF, as discussed with the accompanying facility personnel, may have been treated leachate water that is pumped from
a leachate tank to the stormwater ditch. It was noted that water discharging to the stormwater ditch was being pH
adjusted. The stormwater ditch is one of the permittee's stormwater outfall sampling locations.
A review of the permittee's most recent application under NCS000304 does not
note any discharges from the capped
landfill on site as possible discharges to the stormwater system. DWQ would like more information regarding possible
stormwater and leachate discharges from the landfill (including any treatment) to determine if permit coverage is needed
for these discharges.
Page: 2

Permit: NCS000304 Owner - Facility: Gerdau Ameristeel Corporation
Inspection Date: 05/14/2013 Inspection Type: Compliance Evaluation
Stormwater Pollution Prevention Plan
Does the site have a Stormwater Pollution Prevention Plan?
#
Does
the
Plan
include a
General Location (USGS) map?
#
Does
the
Plan
include a
"Narrative Description of Practices'?
#
Does
the
Plan
include a
detailed site map including outfall locations and drainage areas?
#
Does
the
Plan
include a
list of significant spills occurring during the past 3 years?
#Has the facility evaluated feasible alternatives to current practices?
# Does the facility provide all necessary secondary containment?
# Does the Plan include a BMP summary?
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
# Does the facility provide and document Employee Training?
# Does the Plan include a list of Responsible Party(s)?
# Is the Plan reviewed and updated annually?
# Does the Plan include a Stormwater Facility Inspection Program?
Has the Stormwater Pollution Prevention Plan been implemented?
Comment: The permittee should update the list of significant spills to include the
diesel spill that occurred on July 30, 2012.
Qualitative Monitoring
Has the facility conducted its Qualitative Monitoring semi-annually?
Comment:
Analytical Monitoring
Has the facility conducted its Analytical monitoring?
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
Reason for visit: Routine
Comment: A review of the analytical monitoring data showed the facility is conducting
monthly monitoring due to the permittee's outfalls being in Tier 2 status. The permittee
contacted the Mooresville Regional Office in 2010 and 2011 regarding the benchmark
exceedances.
Permit and Outfalls
# Is a copy of the Permit and the Certificate of Coverage available at the site?
#Were all outfalls observed during the inspection?
# If the facility has representative ouffall status, is it properly documented by the Division?
Yes No NA NE
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Page: 3

Permit: NCS000304 Owner -Facility: Gerdau Ameristeel Corporation
Inspection Date: 05/14/2013 Inspection Type: Compliance Evaluation Reason for Visit: Routine
# Has the facility evaluated all illicit (non stormwater) discharges? ®n rl Q
Comment: The stormwater system consists of drop inlets and ditches that drain to
three ponds, and a stormwater ditch located near the south pond; no deficiencies with
the system were observed.
Page: 4