NCS000304 Review Document

Last update: 111512018
NC Division of Energy, Mineral and Land Resources
Review for Permit Renewal — NCS000304
Gerdau Ameristeel US, Inc.
Charlotte, NC
Facility Activities and Process - SIC 3312 — Steel Manufacturing.
Monitoring — The facility has been monitoring for TSS, BOD, COD, Al, Cd, Cr, Cu, Pb, Ni, Zn, 0&G, and pH. Previous
permit did have tier system.
— Data from 2009 — 2013 (in renewal app)
— Al, Cu, Pb, Zn and TSS had values consistently above the benchmark numbers through this time period. The
metals results were compared to current benchmark values and not the lower ones that were in the
previous permit.
— Cd, BOD and pH has more sporadic benchmark exceedances over the time period.
— COD had consistent exceedances up until the middle of 2012.
— Cr, Ni and O&G had few or no exceedances over the time period.
— 2014-present — only a few DMRs submitted? 2014 — 1, 2015 — 1, 2016 — 0, 2017 — 3. Facility staff are fairly
new and not aware of some past activities but felt that the few DMRs was a result of no discharge from the
facility. Data from this time period show numbers near or over benchmarks only for Cu, Zn and Cd.
— Propose removing Cr, Ni, O&G and BOD.
— Maintain in permit -> TSS, COD, Al, Cd, Cu, Pb, Zn and pH.
— Tier structure adjusted to have the three levels as in current permits.
— Parameter codes added to permit.
Discussions with Facility— Need to check on changes in 2012 that may have resulted in the monitoring result
changes. Check on the ponds onsite and sample locations. Why are they only monitoring outfall 002? Conference
call 9/5/2018 with Bob Churchill, Jill Gee and Kristina Brink (consultant). See second page of this document with
summary email after call. Jill responded 9/14/18 and 9/17/18 through email and with documents. Information is
included in the file and in the Laserfiche folder. Main items from this information:
— Facility collects a lot of onsite stormwater for use in their process. They have three onsite ponds and flow
goes through these (pumped, etc.) ultimately to the North pond to be used in their process. No process
water is mixed in the stormwater ponds so any overflow and discharge is stormwater. Exception is the west
pond that collects some slag cooling water and is treated with CO2 as needed. This has been permitted for
some time in the stormwater system and seems okay.
— Nomenclature for outfalls and ponds is similar but these aren't really the same. Review the Outfall
Narrative document for clarification.
— Discharges are only in larger events as overflow from areas where stormwater is collected for use in
process.
— They do not feel that there is any discharge of landfill leachate as questioned in the 2013 inspection.
— Oil -Water Separator on site is no longer utilized and may be removed.
— The facility wants to continue to monitor Outfall 4 as their only representative outfall. After clarification in
the outfall narrative it appears that this outfall does handle the major flow across the site and should be
okay as representative outfall. This should be evaluated at the site visit.
— The documents provided — Outfall Narrative, Water Systems Map and Topographic Map are helpful in
understanding the stormwater characteristics at the site.
Surface Water Information - Facility drains to UT to Long Creek Creek in the Catawba River Basin, 11-120-(0.5) , a
class C stream. 2016 Integrated Report does not list this stream segment specifically as having any impairment
issues. There are some parameters noted (Cu, Fe, TSS and Turbidity) as being in Category 3 indicating data is
inconclusive. There is a 2005 TMDL that was developed for various streams in the Catawba basin including Long
Creek. This facility has had some TSS values that exceeded the benchmark, though not in the most recent
monitoring.
NC National Heritage review — NHP report shows no aquatic resources within project area. Within one mile there
are some managed areas like open space. But no areas of concern for the discharge from this facility.
Regional Office Information - MRO — Draft to region and CMSWS on 9/19/2018 by email. MRO inspected 10/17/18
and emailed approval to issue 10/22/18. Talked to James 11/5/18 about sample locations and possible dry weather
flow issues. He seemed ok with sample point but had encouraged them to sample upstream of the 004 location
closer to industrial activity. James want to go out in drier weather to evaluate the possible dry weather flow.

Last update: 111512018
Stormwater Permit Renewal Information —
Text of email sent after call
Date: September 6, 2018, 8:46 PM
To: [e-mail]; [e-mail]
Bob, Jill,
See file with email responses (9114 and
9116118) and documents provided in
answering these items (Email from Jill
9-17-181. Copy in file and in Laserfiche
folder.
Thanks for taking the time yesterday for the conference call to discuss this permit renewal. The talk was helpful in the
process. As I indicated I am sending this email to hopefully touch on the points we discussed and highlight (underlined) the
areas where you were going to try and provide additional information.
• Contact updates — you indicated that there where a number of changes that need to be made from the report that I
forwarded previously. Please send me the needed changes and we will get them updated in our database.
• Electronic reporting — EPA regulation do now require electronic reporting of data and some other reports. At this point
our database is not yet ready to support electronic entry of stormwater DMR data. This will happen during the permit
cycle so the language will be in the permit, but at first you will continue to submit DMR data in hard copy form. When
electronic submittal is ready all permitees will be notified. We do still need to gather accurate latitude/longitude for
outfall points.
• Outfalls - We discussed the outfalls at the facility. It was noted that the facility is set up to capture stormwater and reuse
stormwater in the production process. Actual "process water" is handled in a non -discharge closed loop recycle system
that does not over flow to the stormwater ponds. This system is covered by a DWR Recycle System permit
(W Q0006060).
o Outfall listed as 1 in the application material has previously been noted as draining only employee parking area with
no other "industrial area" drainage going through it. As long as this remains the case then this area is not covered by
the stormwater NPDES permit.
o Outfall 2 - From discussions it appears that with some changes to relocate an entrance this outfall may have been
routed (pumped?) to the South pond. The South Pond is pumped to the North Pond. The South Pond may discharge
in some larger storm events. It appears that this outfall should remain in the permit since the discharge would occur
for events smaller than the 25 yr storm event.
o Outfall 3 — North Pond. This pond is used as make up water for your process and feeds various holding ponds. No
process water is returned to the pond. Outfall location for monitoring should be at the outlet of the North Pond.
Given the use of water in your process this pond will only discharge for larger events like the South Pond.
o Outfall 4 — West Pond. Water from the West Pond is pumped to the South Pond, so it ultimately goes to the North
Pond. West pond receives stormwater flow but also some slag cooling water. Appears that this water is pH adjusted
with lime. The water is diluted through the three -pond system and this was addressed in the previous issuance of
the permit.
Please verify this information and provide narrative information and possibly site drainage info to verify to confirm the
characterization of the outfalls. In our discussions we noted that there are some questions about your outfalls that
would be best addressed as part of the site visit with our regional office staff.
• Monitoring — As I noted in our call, we have a summary of your monitoring data for 2010-2013 as part of your renewal
application submitted in 2013. Our records show only a few DMR submittals since that time. Can you please provide a
summary of your available data from 2014-the present?
• You asked about monitoring schedule and if this could be placed on an annual cycle. All of our current permits are set up
this way and your renewed permit will required semi-annual monitoring with the first sampling period January -June and
the second July- December.
• In a 2013 inspection report to your facility it was noted that inspection staff had observed dry weather flow that
potentially came from your capped landfill. The report asked for a response on this issue, but we don't have any record
of a response. In our call you indicated that you had a copy of this report and would review the findings and provide a
response on this issue.
• Oil -Water Separator — It appears that the O/W Separator is no longer in place.
• It doesn't appear that there have been any major operational, process or site changes since the renewal application that
would impact the potential sources of stormwater pollution.
• If there is an updated site map that would help with characterizing drainage areas and outfalls, an electronic copy would
be helpful.