NC0089109_Modification_20181214

Timothy R. Basilone
Vice President—Environmental Affairs
Rh. A M E R I CA N 4955 Steubenville Pike T 724-773-2223 www.azr com
ZINC RECYCLING Suite 405 F 412-788-4526 [e-mail]
Delivering a Sustainable Future Pittsburgh,PA 15205 C 412-287-9871
VIA EMAIL AND OVERNIGHT MAIL
December 14, 2018
Dr.Sergei Chernikov, Ph.D.
Environmental Engineer II
North Carolina Dept. of Environment
& Natural Resources
Division of Water Quality
9th Floor—Archdale Building
512 N Salisbury Street RECEIVED/DENR/DWR
Raleigh, NC 27604
DEC 21 2018
RE: NPDES—Permit Flow Modification Application
Cadmium Compliance Schedule Water Resources
American Zinc Products LLC Permitting Section
American Zinc Recycling, Mooresboro Facility
Rutherford County, NC
Permit NC0089109
Dear Dr.Chernikov:
Please find enclosed three copies of the application and supporting information requesting
modification of the NPDES Permit for American Zinc Products LLC(AZP), American Zinc
Recycling's Mooresboro facility in Rutherford County, North Carolina. This application provides
information supporting AZP's request for the monthly average flow in the current permit be
increased from 0.8 MGD to 0.98 MGD. In addition, as we discussed on several occasions, AZP is
requesting a permit schedule to comply with the anticipated cadmium (Cd) limit in the modified
permit. The attached information will provide details on the need for the requested flow
increase and the Cd compliance schedule. The described revisions are critically important to the
operation of this facility.
Please note that all application information should be considered Confidential Business
Information. Information contained in the application is provided based on the permit
application requirements, consultation with DWR on the information needed to support the
subject requests, and previous discharge information from the facility.
As we have discussed,the AZP Mooresboro facility is undergoing a Restart Project that will
improve the flexibility of the operation, allowing for a successfully restart of the facility and
commencement of commercial zinc production. The requested increase in the flow limit is
necessary to operate the reconfigured facility and to comply with the flow permitted limit.
Because the core production processes and procedures have not been changed,this flow
increase will not change production capacity or significantly affect process materials balances
within the plant. The flow increase reflects improvements made for water management on the
site and comply with all regulatory requirements.

DWR has informed AZP that the NC Water Quality Standards have been revised as a result of
recent changes made to the rules and that the current Cd limit for the facility will be revised to a
lower level. We have discussed with you the effect of this anticipated change, and the fact that
the more stringent limit will likely result in AZP having to significantly modify its process to
reduce the Cd in the process water discharge. DWR advised AZP to include an assessment of the
effect the revised limit would have on operations, and to provide a recommended compliance
schedule to be included into modified the Mooresboro NPDES permit. This permit modification
package includes the results of AZR's assessment.
To facilitate the review of this modification request,we have prepared a Permit Application
Summary that provides an overview of the request and summarizes the supporting application
information.
We appreciate your consideration of this application. As we move toward completion of the
Restart Project early in 2019,we are anxious to complete this permit modification as quickly as
possible. If you have any questions or need any additional information, please contact me. If a
meeting at your office would be helpful to expedite your review of this application, we would be
glad to meet with you.
Sincerely,
era ecee5Jes tee. ->ce
Timothy F . Basilone
Enc.

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Permit Application Summary
Guide to Attachments
Mooresboro NPDES Process Effluent Permit Modification Application
Permit NC0089109
Requested Flow Increase
This permit application and the support information requests modification of the existing NPDES
Permit authorizing discharge from the AZR Mooresboro, NC facility(Permit Number
NC0089109), Rutherford County,North Carolina. American Zinc Products (AZP) is the parent
company for this facility. AZP is requesting that the monthly average process discharge flow
limit for the AZR Mooresboro facility be revised to 0.98 MGD. The current monthly average
flow is limited to 0.8 MGD.
The Mooresboro AZR facility is undergoing a significant facilities improvements process
referred to as the Restart Project. This project is summarized in the attached information. An
application for the renewal of the current permit is pending. However,the requested monthly
average flow modification to 0.98 MGD reflects the flow that will be necessary to effectively
operate the facility as configured upon completion of the Restart Project.
As documented in several sections of the reports and materials attached, the Mooresboro
facility's basic process and steps for production of high quality zinc remain the same as those
described in the initial and subsequent applications made previously for this facility. The
requested flow increase to 0.98 MGD is not being requested to change zinc production capacity,
alter materials balances in the process, or revise the basic processes being used to produce zinc.
However, the Restart Project will result in a better and more flexible production facility,more
effective water balance on the site,better by-products management and improved process
management of the facility. The flow increase is essential to accomplishing the goals of the
Restart Project.
The stormwater footprint of the Mooresboro facility site is being modified by the Restart Project.
By-product temporary storage areas are being covered by roof structures that will prevent any
loss of material from the by-product areas. The overall stormwater management system on the
site is being modified to limit the amount of rainwater that will have to be incorporated into the
process side. Better management of stormwater will help to reduce overall process flow but the
expected amount of stormwater incorporation will still add significant amounts of water to the
process side. This flow adds little in the way of materials or potential pollutants but will add
flow that must be managed. These efforts are aimed at minimizing the potential discharge of
contaminants from the site. The previous water management systems did not effectively account
for these additional flows and past operational efforts demonstrated that the current flow limit
during full plant operational production would be an issue. As a result, the monthly average
permitted flow is expected to exceed the current 0.8 MGD permit limit. A careful evaluation of
the water balance on the site, considering the variability of rainfall/stormwater impacts and
previous experience at the facility, demonstrates that the current flow limit of 0.8 MGD is
inadequate to manage the resultant process flow under all conditions. A monthly average flow

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limit of 0.98 MGD is essential for effective water balance management on the site. The permit
application attached reflects the needed flow limit.
Attachment 1,NPDES Permit Application—Short Form C
Previous Facility Operations
The historic effluent quality information provided in this package reflects the facility as it was
prior to the initiation of the Restart Project. These data provide a general point of reference on
facility discharge values generated in the last 24 months. The Restart Project facility
improvements under construction will result in better management and control of the process
materials and the byproducts produced at the facility. The historic effluent data is being
provided as requested in the permit application form.
In January 2016,the facility curtailed zinc production, and the associated effluent discharge rate
over the past 24 months has fluctuated, averaging 192,842 gallons on a daily average basis,
which is approximately 2.34 million gallons/month total discharge. Obviously, these flows do
not reflect operations of the production facility at full capacity.
Intermittent flow has occurred at an average of around 12 days per month over the past 24
months. It is anticipated that operations at the current level will continue while the Restart
Project proceeds. Restart of production is expected to begin in Spring 2019. As the facility
ramps up production and begins the process of producing product, flows will increase. As noted,
our evaluation of the site and the operational demands of the facility will generate flows up to the
requested permit limit, 0.98 MGD.
Summary tables of the previous 24 months effluent monitoring are attached for general
reference.
Attachment 3: Table 1, Summary of Effluent Monitoring Results; Table 2,Monthly
Maximum Concentrations; Table 3, Other Monitored Parameters
Compliance Schedule
In 2017 AZP submitted a permit modification request that asked for an increase in flow to 0.98
MGD, monthly average. This request was made following the determination that the Restart
Project would be needed to improve the management of water and materials on the site. DWR
began reviewing this application but communicated with AZP that due to changes in some of the
State's metals water quality standards that cadmium(Cd) limits would become significantly
more stringent than the limits in the current permit. As a result, AZP withdrew this application
so that a careful review of the impact of the lower Cd requirement could be performed. As a
result of this evaluation, AZP has determined that Cd capture in the process may not be sufficient
to reduce the trace concentration of Cd sufficiently in the process discharge to allow the
company to comply with the expected Cd limits. Design, installation and operation of additional
process technologies will most likely be necessary to capture additional Cd and achieve the
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expected Cd limits. Based on discussing this issue with DWR,AZP was advised that the needed
permit flow modification request,when resubmitted, should include a requested compliance
schedule that would allow AZP to meet the anticipated Cd limits that would come with a
modified NPDES Permit.
AZP staff and consultants looked at the logistics of modifying production steps to include
additional removal capability. This represents a significant undertaking and will require
sufficient time to evaluate how the Restart Project facility will operate and measure the actual Cd
content in the process water as it moves through the steps of zinc production. On the basis of
this evaluation, the initial report evaluating and developing a compliance schedule was drafted
and provided to DWR for a preliminary review. The comments received resulted in AZP
revising the prospective schedule to shorten the timeline to achieve compliance. These revisions
resulted in a significant reduction in the schedule. However, it should be noted that the steps in
the proposed compliance schedule that allow for the development of accurate process water Cd
levels are the most critical. AZP has made every effort to consolidate and parallel actions
involving the evaluation of data, development of preliminary design information and to develop
final engineering plans. The demonstration periods involving the achievement of stable
operations must be maintained in order to develop appropriate technologies and actions to
achieve the reduction goals needed to comply with final limitations. This report, "NPDES
Process Discharge Compliance Schedule—Revised Stream Standards,"is included in this permit
application package.
The compliance evaluation report notes the change in Cd limit expected in a modified permit
with monthly average flow limit of 0.98 MGD. A copy of the limits page for the current permit
and the limits page from the permit drafted in response to the 2017 application are attached. The
compliance evaluation report includes, in support of the compliance schedule, a discussion of the
facility and the Restart Project along with a summary of the basis for the timeline requested.
AZP's application for renewal of the current permit was filed to meet renewal request
requirements for the current permit. This application included information about mass limits
verses concentration limits. That information points out that due to the significantly larger flow
of the Broad River(even at 7-day, ten-year low flow levels) dominates the determination of
concentration of discharged parameters downstream of the diffused process water discharge.
Because overall mass materials balances from the process will not be affected by the process
discharge flow limit, the mass of each listed potential pollutant, including Cd will not
significantly increase. This is a mitigating factor in considering the compliance schedule
timeline for the modification of the facility's process steps to further reduce Cd in the process
discharge.
Attachment 3,NPDES Process Discharge Compliance Schedule—Revised Stream
Standards
Attachment 4, NPDES Permit Pages for the Current Permit and the Draft 2017 Permit for
a Monthly Average Flow Limit of 0.98 MGD
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Alternatives Analysis
Our meeting and discussions with DWR indicate that the conclusion reached with the initial
permit issuance and subsequent modified permits that direct discharge of the Mooresboro facility
is the most appropriate and really the only feasible option available for management of this
discharge has been established. As a result,the pervious decision on engineering alternatives is
well supported by previous alternatives analysis and DWR's review.
Summary
AZP presents this permit modification package with its commitment to restarting the
Mooresboro facility using a series of improved process management systems that will result in a
more stable, flexible and sustainable zinc refining plant. The improvements made address
environmental water management issues that the company acknowledges presented problems
during the initial efforts to bring this facility up to its zinc production capability. This experience
has informed the Restart Project and resulted in a careful accounting of materials and water
balances on the site. Receiving a permit modification with a 0.98 MGD average monthly flow
limit is extremely important to our operation and really is essential to being able to comply with
the permit.
The requested compliance schedule for meeting the expected Cd limit represents actions
requiring the allocation of significant financial resources and effort. We believe we must
carefully determine with a reasonable level of certainty the amount of Cd reduction necessary to
comply. The potential scope of process revisions necessary and the installation and operation of
any additional equipment is crucial. The time needed to evaluate the several levels of stable
operation required to achieve acceptable product production quality is the most critical input to
the process to make these decisions. The times requested for these steps give us a reasonable
opportunity to take into consideration the factors that will materially impact the concentration of
Cd in our process water within the process and that will be discharged under our NPDES permit.
We have coordinated the development of our Cd compliance report with DWR and believe it
represents a tight schedule that can be met thorough diligent attention to the steps needed to
complete the process.
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Attachment 1
NPDESPermit
Application

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NPDES PERMIT APPLICATION — SHORT FORM C — Minor Industrial
Minor industrial, manufacturing and commercial facilities.
Mail the complete application to:
N. C. Department of Environment and Natural Resources
Division of Water Quality / NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
NPDES Permit Number NC0089109
Please print or type.
1. Contact Information:
Owner Name American Zinc Products LLC (Parent Company)
American Zinc Recycling (AZR)
Facility Name
Mooresboro Zinc Refinery
Mailing Address 484 Hicks Grove Road
City Mooresboro
State / Zip Code North Carolina, 28114
Telephone Number 724-773-2223
Fax Number 412-788-4526
e-mail Address [e-mail]
2. Location of facility producing discharge:
Check here if same as above IZ
Street Address or State Road
City
State / Zip Code
County
3. Operator Information:
Name of the firm, consultant or other entity that operates the facility. (Note that this is not referring to the
Operator in Responsible Charge or ORC)
Name N/A
Mailing Address
City
State / Zip Code
Telephone Number
Fax Number
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NPDES PERMIT APPLICATION — SHORT FORM C — Minor Industrial
Minor industrial, manufacturing and commercial facilities.
4. Ownership Status:
Federal ❑ State ❑ Private ® Public ❑
5. Standard Industrial Classification (SIC) code(s): 3341
6. Number of employees: 160 currently; approximately 300 when fully staffed
7. Describe the treatment system List all installed waste treatment components with capacities,
describe the processes that generate wastewaters. If the space provided is not sufficient attach a
separate sheet of paper with the system description.
There is no wastewater treatment system. Removal of metals and other constituents as by-
products is inherent to the metal production process, as described in Section 9 below.
Process water discharged is the resultant water remaining following all production steps.
8. Is facility covered under federal effluent limitation guidelines? No ® Yes ❑
If yes, specify the category?
9. Principal product(s) produced: Special High-Grade ("SHG") Zinc Metal and other metal
commodities.
Principal raw material(s) consumed: Waelz Oxide (a/k/a Crude Zinc Oxide)
Briefly describe the manufacturing process(es):
The manufacturing process consists of an integrated system of leaching, extraction,
stripping, and electrowinning processes. Feed, including metal bearing oxides and other raw
materials, are managed in solution throughout the process, and metal products are removed
as precipitates, concentrates, and SHG Zinc Metal. Metal bearing Waelz Oxide feed is
produced at parent company-owned facilities. The basic process approach is unchanged
from those described and provided in earlier applications. The specific technologies and
configuration of the operation are confidential business information.
In January 2016, the facility ceased commercial zinc production. The facility is currently
not in production and is in the process of implementing significant design and operational
changes at the facility (Restart Project) that will allow the facility to achieve commercial zinc
production and improve process water and stormwater management capability, improve
storage and management of by-products produced in the process, more carefully isolate
domestic wastewaters, and implement improved operational procedures. Completion of
these actions is expected in early spring 2019. Please see attached report that addresses the
Restart Project and the need for a compliance schedule. This report provides details on the
status of the facility and the modifications to the production site and operational capability
of the plant.
Historic information provided in this permit modification application reflects effluent
discharge monitoring data provided in monthly discharge monitoring reports (DMR's)
submitted to the Department over the past 24 months. This information reflects the volume
and nature of constituents occurring in the plant discharge water under the previous plant
configuration. These data reflect operations at that time and will not accurately reflect
discharge water quality following full implementation of the improvements underway at the
facility.
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NPDES PERMIT APPLICATION - SHORT FORM C - Minor Industrial
Minor industrial, manufacturing and commercial facilities.
10. Amount of principal product produced or raw material consumed
(List specific amounts consumed and/or units of•roduction over the last three years)
Product Produced or Raw Material Product Produced or Raw Material
Consumed Consumed
(AVERAGE) (PEAK)
See Section 9 above and attached
documentation that provided production
per Day and raw materials (Business Confidential
Information)—Plant is currently not
operating in a commercial zinc production
mode.
per Month
per Year
11. Frequency of discharge: Continuous ® Intermittent ❑
This application is for a modification of the existing permit to increase the discharge flow of the
facility. Current discharge is intermittent during the facility improvements project and this flow
is covered under the existing permit. Discharge will be continuous during normal production
operation.
If intermittent:
Days per week discharge occurs: Duration:
12. Types of wastewater discharged to surface waters only
Discharge Flow
(GALLONS PER DAY)
Sanitary monthly average Sanitary WW is discharged to the Town of Forest City
satellite WWTP for RiverStone Commercial Park
Utility water, etc. - monthly average
Process water - monthly average 980,000 gpd
Stormwater-monthly average Stormwater discharge managed under a separate
NPDES SW Individual Permit
Other-monthly average Facility holds an NPDES General Permit for Boiler
Explain: Blowdown, Condensate and Non-Contact Cooling
Tower Blowdown.
Monthly Average 980,000 gpd
total discharge (all types)
13. Number of separate discharge points: 1 Outfall Identification number(s): 001
14. Name of receiving stream(s) (Provide a map showing the exact location of each outfall, including
latitude and longitude):
Broad River
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NPDES PERMIT APPLICATION — SHORT FORM C — Minor Industrial
Minor industrial, manufacturing and commercial facilities.
15. Effluent Data [for new or proposed discharges]
Provide data for the parameters listed. Temperature and pH shall be grab samples,for all other parameters 24-hour
composite sampling shall be used.If more than one analysis is reported, report daily maximum and monthly average.
If only one analysis is reported, report as daily maximum.
NOTE:Permittees requesting renewal should complete the table ONLY for the parameters
currently monitored. Summarize the past 3 years of effluent data.
Parameter Daily Monthly Units of
Maximum Average Measurement
Biochemical Oxygen Demand (BOD5) N/A
Chemical Oxygen Demand (COD) N/A
Total Organic Carbon N/A
SEE ATTACHED
NARRATIVE,
TABLES,AND
Total Suspended Solids* FIGURES
Ammonia as N N/A
Temperature (Summer) N/A
Temperature (Winter) N/A
pH*
Fecal Coliform (If sanitary waste is N/A
present)
Total Residual Chlorine (if chlorine is N/A
used)
16. List all permits, construction approvals and/or applications (check all that apply and provide permit
numbers or check none if not applicable):
Type Permit Number Type Permit Number
Hazardous Waste (RCRA) NESHAPS (CAA)
UIC (SDWA) Ocean Dumping (MPRSA)
NPDES X Dredge or fill (Section 404 or CWA)
PSD (CAA) Other
Non-attainment program (CAA)
17. List any chemicals that may be discharged (Please list and explain source and potential
amounts.)
See attached information describing the anticipated constituents and average
concentrations in effluent water discharged from the facility.
18. Is this facility located on Indian country? (check one)
Yes ❑ No
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NPDES PERMIT APPLICATION — SHORT FORM C — Minor Industrial
Minor industrial, manufacturing and commercial facilities.
19. Applicant Certification
I certify that I am familiar with the information contained in the application and that to the
best of my knowledge and belief such information is true, complete, and accurate.
Rob Williamson General Manager
Printed name of Person Signing Title
y
.. �✓ 12f11/ J 'IS
Signature of Applican Date
North Carolina General Statute 143-215.6 (b)(2) provides that: Any person who knowingly makes any false
statement representation, or certification in any application, record, report, plan, or other document files or
required to be maintained under Article 21 or regulations of the Environmental Management Commission
implementing that Article, or who falsifies, tampers with, or knowingly renders inaccurate any recording or
monitoring device or method required to be operated or maintained under Article 21 or regulations of the
Environmental Management Commission implementing that Article, shall be guilty of a misdemeanor punishable
by a fine not to exceed $25,000, or by imprisonment not to exceed six months, or by both. (18 U.S.C. Section
1001 provides a punishment by a fine of not more than $25,000 or imprisonment not more than 5 years, or both,
for a similar offense.)
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Attachment 2
Table 1, Process Discharge
Summary
11
Table 2, Monthly Maximum
Concentrations
Table 3, Other Monitored
Parameters

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TABLE 1
MONTHLY DISCHARGE INFORMATION-EFFLUENT FLOW,CONSTITUENT CONCENTRATION AND MONTHLY MASS DISCHARGE AMOUNT,
COMPARISON WITH CURRENT PERMIT AND CALCULATED CHRONIC EFFLUENT LIMITS(NEW RULE)
NUMBER OF Monthly Average Concentrations(Mg/L) Monthly Mass Discharged(Total Pounds)
1 TOTAL DISCHARGE DAYS FLOW MONTHLY I I
FOR THE MONTH OCCURRED IN AVERAGE FLOW
YEAR MONTH (GALLONS) MONTH PER DAY Cd Cr Pb Zn F TSS Cd Cr Pb Zn F T55
January 14,260,000 29 491,724 0.0816 0.0055 0 0.94 31.5 6 9.70 0.65 0.00 1 111.9 3748.5 714
February 2,929,000 14 209,214 0.1230 0.00285 0.00275 5.36 12.9 10 3.01 0.07 0.07 131.0 315.3 244
March 4,092,000 18 227,333 0.1425 0 0.1425 1.07 0 7.25 4.87 0.00 4.87 36.5 0.0 248
April 2,460.000 13 15'9,231 0.0610 0 0 0.945 6.8 9.8 1.25 0.00 0.00 19.4 139.6 201
May 2,325,000 13 178,846 0.0340 0 0.0026 0.57 6.6 10.5 0.66 0,00 0.05 11.1 128.1 204
a June 3,360,000 18 186,667 0,0560 0 0 1.35 9.2 10.5 1.57 0.00 0.00 37.9 258.0 294
N+ July 1,705,000 10 170.500 0.0945 0 0 1.3 9.1 5.55 1.34 0.00 0.00 18.5 129.5 79
August 2,418,000 10 241,800 0.1740 0 0.003 2.85 10.3 8.3 3.51 I 0.00 0.06 57.5 207.8 167
September 540,000 4 135.000 0.1050 0 0.00275 4.46 7.7 4.65 0.47 f 0.00 0.01 - 20.1 34.7 21
October 1,271,000 8 158,875 0.0615 0 0 3.56 6 0 0.65 0.00 0.00 37,8 63.6 0
November 290,000 3 96,667 0.0680 0 0 3.7 4.7 0 0.16 0.00 0.00 9.0 11.4 0
December 651,000 6 108,500 0.0940 0 0 4.43 5.2 0 0.51 0.00 0.00 24.1 28.2 0
January 1,364,000 10 136,400 0.0885 0 0 6.46 5,3 0 1.01 0.00 0.00 73.5 60.3 0
February 1.540.000 11 140,000 0.0465 0 0.0033 5.39 5.2 1.5 0.60 0.00 0.04 693 66.8 19
March 963,000 9 107,000 0.0555 0 0 3.9 8.2 2.15 0.45 0.00 0.00 31.3 65.9 17
April 2,265,000 15 151,000 0.0550 0 0 4.12 7.1 1.9 1.04 0.00 0.00 77.9 134.2 36
May 3,114,000 18 173,000 0.0360 0 0.0055 1.71 4.6 0 0.94 0.00 0.14 44.4 119.5 0
June 2,235,000 15 149,000 0.0490 0.005 0 2.65 5.7 1.5 0.91 0.09 0.00 49.4 106.3 28
N July 2,338,000 14 167.000 0.0615 0.0028 0.005 1.9 6,8 v 7.6 1.20 0.05 0.10 37.1 132.7 148
August 1582,000 14 113,000 0.0945 0 0 6.27 6.7 2.7 1.25 0.00 0.00 82.8 88.5 36
September 1,370,000 10 137,000 0.1675 0 0.0027 2.9 5.2 2 1.91 0.00 0.03 33.2 59.4 23
October 1,632,000 16 102,000 0.0975 0 0.00255 6.58 5 1.25 1.33 0.00 0.03 89.6 68.1 17
November 1,110,000 10 111,000 0.0360 0.038 0 18.98 7.5 0 0.33 0.35 0.00 175.8 69.5 0
December 303,000 3 101,000 0.0420 0 0 2.52 0 0.11 0.00 0.00 6.4 0.0 0
TOTAL 56,117,000 291
MONTHLY
AVERAGE 2,338,208 12.13 192,842 0.0802 0.0023 0.0072 3.91 7,39 3.88 1,62 0.05 0.23 53.6 251.5 1 104
Current Permit(Chronic)Limit(Monthly Average Concentration-Mg/L) Permitted Monthly Mass(Total Pounds)
Total Monthly Flow-Limit(gals) Flow/Day(gals) Cd 1 Cr Pb Zn F I55 Cd ; Cr 1 Pb I Zn I F j TSS
24,333,333 800,000 0.27 I 6.75 3.37 No Limit 243.2 Nallo Limit 54.83 j 1,371 j 684.32 j No Limit l 49,385 I No Limit
Calculated Max Effluent Concentration Limit-Chronic Toxicity Limits(Mo.Avg.M8JL)• Calculated Allowable Max Monthly Mass(Total Pounds)
Flow/Day(gals) Cd Cr Pb Zn F TSS Cd Cr ' Pb Zn 1 F TSS
800,000 0.121 0.737 25 150
'Calculated using hardness of 2,500 for effluent water,and 25 for upstream hardness.
"0'value means not detected.
Parameter with Permit Limit

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TABLE 2
MONTHLY DISCHARGE INFORMATION - MAXIMUM CONSTITUENT CONCENTRATION
COMPARISON WITH CURRENT PERMIT LIMITS
AND CALCULATED MAXIMUM DAILY(ACUTE) EFFLUENT LIMITS
Monthly Maximum Concentrations (Mg/L)
YEAR MONTH Cd Cr Pb Zn F TSS
January 0.114 0.011 0 1.44 31.5 12
February 0.128 0.0057 0.0055 5.56 12.9 11.2
March 0.174 0 0.174 1.21 0 7.6
April 0.075 0 0 1 6.8 16.2
May 0.035 0 0.0052 0.64 6.6 12.2
1O June 0.099 0 0 1.6 9.2 15.5
nsi July 0.1 0 0 1.5 9.1 6.5
August 0.228 0 0.006 4.4 10.3 11.8
September 0.14 0 0.0055 4.66 7.7 5.7
October 0.069 0 0 3.74 6 0
November 0.068 0 0 3.7 4.7 0
December 0.094 0 0 4.43 5.2 0
January 0.12 0 0 6.56 5.3 0
February 0.083 0 0.0066 9 5.2 3
March 0.057 0 0 4.2 8.2 4.3
April 0.08 0 0 4.53 7.1 3.8
May 0.038 0 0.011 2.23 4.6 0
June 0.057 5 0 2.8 5.7 3
N July 0.078 0.0055 0.005 2.28 6.8 9.6
August 0.13 0 0 10.5 6.7 5.4
September 0.26 0 0.0054 3.9 5.2 6
October 0.12 0 0.0051 7.24 5 2.5
November 0.72 0.076 0 34.5 7.5 0
December 0.42 0 0 2.52 0
MONTHLY
AVERAGE 0.1453 0.2124 0.0096 5.17 7.39 5.68
Current Permit(Acute)Limit(Daily Maximum Concentration-Mg/L)
Cd Cr Pb Zn F TSS
1.66 113.6 3.75 No Limit 243.2 No Limit
Calculated (Acute) Limit(Daily Maximum Concentration-Mg/L)
Cd Cr Pb Zn F TSS
0.63 17.07
* Calculated using hardness of 2,500 for effluent water, and 25 for upstream
hardness, and at 800,000 gallons/day average flow.
"0"value means not detected.
Parameter with Permit Limit

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TABLE 3
MONTHLY DISCHARGE INFORMATION -OTHER MONITORED CONSTITUENTS
DAILY MAXIMUM AND AVERAGE MONTHLY CONSTITUENT CONCENTRATION
Constituent Units Maximum Average
NH3-N Mg/L 0.12 0.017
Total Aluminum Mg/L 0.151 0.0713
Total Antimony Mg/L 0.0445 0.0125
Total Arsenic Mg/L Not Detected Not Detected
Chlorides Mg/L 4700 1440
Total Cobalt Mg/L 0.0072 0.001
Total Copper Mg/L 0.0238 0.0034
Total Fluoride Mg/L 31.5 25.3
Total Iron Mg/L 110 15.7
Total Nickel Mg/L 0.0071 0.0028
Total Tin Mg/L 0.0068 0.001
pH standard units 6.6-8.3 6.5 - 7.3
Chronic Toxicity Pass/ Fail Failed 1 Time in 8 Monitored Periods
Effluent Turbidity NTU 13.8 3
Upstream Turbidity NTU 83.4 17
Downstream Turbidity NTU 87.3 17

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Attachment 3
NPDES Process Discharge
Compliance Schedule Revised
Stream Standards

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American Zinc Recycling (AZR)
Mooresboro Zinc Refinery
Rutherford County, NC
NPDES Process Discharge Compliance Schedule — Revised Stream Standards
December 2018

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Contents
1. Background 1
1.1. Objectives of this document 1
1.2. The Mooresboro Zinc Production Facility 1
1.3. Restart Project 2
1.3.1. Metals removal technology selection 2
1.3.2. Key performance indicators 3
1.4. Environmental Standards 3
1.4.1. Evolution of water quality standards 3
1.4.2. Compliance risk 3
2. Compliance program 4
3. Implementation philosophy 4
4. Compliance schedule 5
5. Schedule Review and Justification 6
6. Requested Interim Limits 9

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1. Background
1.1.Objectives of this document
The objective of this narrative is twofold: 1) to provide to the Department of Environmental
Quality(DEQ)the basis for the company's request for an increase in the permitted discharge
volume, and 2) provide an outline of a program consisting of necessary tasks and process
equipment/modifications to achieve compliance with the anticipated more restrictive cadmium
(Cd) limit (due to recent rule changes). AZR has previously discussed the need for a flow
increase in its process effluent discharge with DEQ. DEQ has provided AZR with information
indicating that due to a change in regulations the Cd discharge limit will become more stringent.
It is important to note that the requested flow increase is not the result of a production change.
Zinc production capacity at this facility remains the same as that identified in the initial
application for an NPDES permit. The total water balance for this operation and the physical
means of managing process water and stormwater effectively requires that the permitted flow
be increased. There has been no significant change in the materials balance for this facility.
Therefore, the expected mass of metals and other materials within the process essentially
remains unchanged from the mass balance provided previously. However, overall water
management necessary to effectively operate the plant on this site will actually result in lower
expected discharge concentrations. AZR recognizes that changes to the NC water quality
standards will likely require AZR to take actions to reduce process flow discharge
concentrations for Cd.
This document is included with the AZR's application for a revised discharge flow to describe
to DWR the efforts required to achieve consistent compliance with the anticipated effluent Cd
limit. Please be aware that the water balance for this site is dependent on rainfall/stormwater
and as a result will have some variation over time due to actual precipitation events
experienced at the site.
1.2.The Mooresboro Zinc Production Facility
The AZR Corp. Zinc Production Facility, located in Mooresboro NC,was designed to produce
155,000 tons of Special High Grade (SHG) zinc per annum. Numerous technical difficulties,
experienced since the start-up of the facility in May 2014, led to the eventual shut down of the
facility in January 2016 by Horsehead Inc, who subsequently filed for Chapter 11 bankruptcy.
Pursuant to an extensive investigation into the technical problems, the current owners of the
facility, American Zinc Recycling LLC, the parent company of American Zinc Products (AZP),
approved a project to address the technical difficulties, with the assistance of an experienced
technical team, augmented by Asturiana de Zinc, a leading supplier of zinc production

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technology and an owner of several zinc production facilities globally. The restart project,with
a capital budget of $156 million was approved in December 2017 and is planned to be
completed in March 2019, with eventual ramp-up to 155,000 tons of SHG zinc production by
July 2020. The planned eventual production capacity has remained at 155,000 tons per year
and the scope of the Mooresboro Restart Project is limited to the resolution of technical
difficulties and does not include any planned increase in production capacity.
1.3.Restart Project
1.3.1. Metals removal technology selection
Although the key technology blocks for zinc production have been retained,the process
water system, designed to recover valuable metals and other by-products prior to
discharge in the effluent stream, is being expanded and modified to address the
following shortcomings of the original design:
• Constrained capacity to deal with fluctuating flow rates, primarily resulting from
environmental factors,such as significant rainfall and the need to direct potentially
contaminated stormwater into the process.
• Limited solid/liquid separation capacity to remove precipitated metal hydroxides
and sulphides(recoverable by-products).
• Ability to deal with upset conditions due to process equipment failures (e.g. filter
cloth tears, etc.).
During the initial operating phase from May 2014 to January 2016 the above constraints
were addressed through temporary measures, such as the installation of a lamella
thickener, and installation of a temporary metals removal unit to augment capacity.
Evaluation of these technologies during the initial operating phase and subsequent
design reviews, led to the development of the following permanent process changes,
which are included in the restart project scope:
• Procurement and installation of two Veolia Actiflo units, to provide excess capacity
for removal of solid metal hydroxides and sulphides, with 100% redundancy.
• A 40% capacity increase of the process water system.
• Installation of proprietary pH control units, which have been proven to be reliable
in Asturiana de Zinc facilities, to provide increased process stability and more
consistent operation.
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In addition to the improvements to the process system, mentioned above, the capital
investment also includes the following upgrades,which will reduce the volume of metal-
containing solutions, resulting from the incorporation of stormwater into the process:
• Construction of covered storage facilities for all major by-products and reagents.
• Installation of sump pumps and piping systems to more readily collect metal-
containing solutions from around the facility.
1.3.2. Key performance indicators
The design parameters of the collection and process water system were based on
achieving the following key performance indicators:
• Limit water consumption and treated effluent discharge as far as possible. Based
on careful consideration of all of the actions necessary to effectively manage water
on the site, the new design is based on limiting the average daily discharge flow
rate to 0.98 Million Gallons Per Day(MGD).
• Limit the Cd concentration in the discharge stream to achieve the same Cd
discharge on a mass flow basis, as stipulated by the current NPDES permit
(NC0089109).
1.4.Environmental Standards
1.4.1. Evolution of water quality standards
The NC 2007-2015 Water Quality Standard (WQS) was revised in April 2016 and
although the process used to determine metals standards, namely the Reasonable
Potential Analysis (RPA) did not change, the application of dissolved and hardness-
dependent calculations in the RPA represent a significant change. The evaluation of
hardness-based standards requires knowledge of the effluent and upstream hardness
which is used in calculating certain metals concentration limits, including cadmium,for
effluent discharge that will comply with the NC standards.
1.4.2. Compliance risk
The design improvements, included in the scope of the Mooresboro Restart Project,
will improve the consistency of effluent water quality at the facility. Nevertheless,
compliance with the amended NC WQS cannot be confirmed without operating
experience. The changes to the standard are significant and it is possible that further
refinements of the water process system may be required to ultimately achieve
compliance with effluent discharge limits. Without actual operational data, it will be
impossible to determine what, if any, modifications to our process will be necessary.
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2. Compliance program
The scope of the compliance programme is highly dependent on determining potential causes of
non-compliance and will therefore be confirmed during the initial operating phase. However, based
on the nature of the Mooresboro facility and the composition of the various process streams to be
managed by the water process system, it is possible to identify the more likely areas requiring
improvement during the initial operating phase, particularly processes for metals precipitation and
solid/liquid separation of precipitated metals. The scope of work will therefore comprise the
following key aspects:
• Pursuant to plant commissioning and stabilization, the efficiency of metal hydroxide and metal
sulphide precipitation will be assessed through comparison with bench scale test work and
industry best practice. This phase will feature optimization of pH and Redox Potential of the
plant operation.
• The separation of metal hydroxides and precipitates through settling and filtration, using
conventional high rate clarifiers as well as the planned Veolia Actiflo lamella clarifier, will be
assessed through in-plant sampling.
• Based on the assessment above, enhanced chemical removal and/or solid/liquid separation
technologies will be evaluated to address potential areas for improvement of trace metal
removal. The evaluation will comprise a literature survey, as well as bench scale test work in
collaboration with potential technology suppliers.
• The initial technology selection process will yield short-listed technologies which may be
evaluated further through pilot test work at the Mooresboro facility.
• The final selected technologies will be incorporated into the overall facility design, followed by
procurement and construction.
• Commissioning and evaluation of the selected technologies will comprise the final steps in the
program.
3. Implementation philosophy
The project will be implemented in accordance with the Project Management Institute (PMI®)
project life cycle process, as contained in the Project Management Body of Knowledge (PMBOK).
The key steps are as follows:
• Initiation. Subsequent to commissioning of the Mooresboro facility.
• Planning. Detailed planning, based on the outcome of the initial evaluation of the
Mooresboro process water system performance.
• Implementation. Technology selection, detailed design, procurement and construction.
• Control. Project management to achieve target dates.
• Close-out. Final evaluation of the selected technology in operation and confirmation of
compliance,followed by project close-out.
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4. Compliance schedule
The schedule presented in Table 1, commences with the start-up of the Mooresboro Zinc
Production facility. The schedule is therefore linked to the start date, to be no later than June 1,
2019 (month 0).
Table 1. High level draft compliance schedule
Activities Deadline for Completion I
1. Commence production of Zinc at Mooresboro Facility. Month 0
2. Ramp-up production to 75%. Month 6
3. Stabilize plant operation and commence evaluation of permit compliance. Month 12
4. Complete evaluation period. Month 24
5. Prepare a Preliminary Engineering Report(PER)of process alternatives and/or Month 30
pollution prevention/waste minimization alternatives designed to achieve
compliance. This report would include the results of the compliance evaluation. (parallel with activity 4)
Submit to DWR for review and comment.
6. Agency review and addressing comments Month 32
7. Bench scale test work of process alternatives(start following completion of Month 34
Activity 5).
8. Evaluate business case and funding requirements for technically suitable Month 34
alternative(s).
(parallel with activity 7)
9. Complete pilot test work for selected technology option(s)and final technology Month 38
selection.Develop a summary of the results of this evaluation. Submit
summary to DWR for review.
10. Agency review and addressing comments Month 40
11. Detailed engineering and design of selected option. Submit to DWR for Month 44
comment. (in order to meet this schedule,work on this component will begin
following Step 9)
12. Agency review and addressing comments Month 46
13. Prepare capital project application and secure funding for selected option, Month 48
obtain building permits and all needed approvals for implementation.
(much of this work will be
done in parallel with
activities 11,12)
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14. Project implementation,including design completion,procurement and Month 60
construction.
15. Commission and ramp-up. Month 72
16. Stabilize operation and evaluate performance. Month 78
17. Make necessary final modifications to optimize and obtain full operational Month 86
status.
18. Achieve full compliance. Month 90
5. Schedule Review and Justification
Table 1 provides the necessary timeframe for the logical and effective development of required process
modification, if necessary, to increase the capability for Cd capture and reduce concentrations in the
process discharge water in order to comply with the final permit limit. The most critical steps in this
process involve achieving stable operation of the process before assessing resultant discharged water
quality. The time necessary to achieve stable operation is essential to providing accurate information
that will serve as the basis for employing the technologies that will be used to assure compliance. The
schedule reflects the Company's efforts to streamline actions involving the evaluation and reporting of
data and for making important design decisions, A summary of the schedule and the basis for the
assigned time segments for identified actions is provided below:
A. Providingsufficient time to achievingoperational sustainabilityof the facility.
p Y
Steps 1 and 2 accounts for the essential time that facility operators must have to achieve a
sustained zinc production level and acceptable product quality. The facility operation involves the
interaction of a series of chemical and physical production steps. Based on experience with
similar production facilities, management believes the Mooresboro facility will require 6 months to
ramp up production and then an additional 6 months to achieve stable operation. The length of
this time period also accounts for a full year of climate conditions and precipitation, and
associated effects on the process water discharge. As part of its NPDES Stormwater Permit plan,
stormwater that may contain some level of constituents from raw materials and production by-
products must be managed with process water. Seasonal weather conditions will likely have
some effect on effluent water discharge. A full year is required at a minimum to understand the
potential variability in flow and quality over four seasons, and the potential effect on process water
quality. In addition, over the first year of operation variations in the discharge water quality from
the plant process operations will be eliminated.
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B. Evaluate process discharge to determine variation in Cd within the production sequence
and in the resultant process wastewater.
Similar to the rationale provided for Steps 1 and 2 above, seasonal impacts on process water will
need to be assessed. At least one full year is required to evaluate Cd levels within the production
steps and in the effluent discharge water after a consistent operation is achieved. Steps 3 and 4
allow for this evaluation period to be completed. The timeframe allocated, after the evaluation
period,for preparation of the PER is 6 months(Step 5). This time is necessary to fully evaluate
the results of the Cd monitoring from the evaluation period, operational variability during this time,
and other related information. This is the critical analysis needed to develop an approach to
reducing Cd and to evaluate process and pollution prevention alternatives and prepare a final
report.
C. Submittal of reports and information to DWR for review and comment.
The schedule includes steps for submission of evaluation reports and supporting information to
DWR for review and comment. This begins with Step 5. The schedule proposes 2 months for
this review and comment and includes provisions to address comments provided by the agency.
Since the review and comment time segment is not within the company's control, DWR should
note that any schedule impact due to agency review and comment should not be considered in
determining our compliance with the schedule. If DWR believes that the allocated time for review
and comment is not adequate, the schedule will need to be adjusted.
D. Developing real world information for evaluation of specific process technologies and
actions that will result in Cd compliance.
Steps 7,8 and 9 are essential in order to ensure that certain technologies and actions identified to
achieve compliance will be effective in this facility. The process used for production at this facility
is complex and involved. There are no"off the shelf"specific technologies or techniques for
addressing issues with elevated Cd. The potential solutions will require evaluation on a site-
specific basis. The only way to do this with some assurance that the recommended solutions
work at this plant is through bench scale testing. Based on our experience and the processes
involved,this requires a minimum of 12 months to develop appropriate data on the options
identified in the PER, test them, identify the most appropriate actions to achieve the objective,to
evaluate the business case for the actions identified and prepare a report to support the
recommendations. Please note that Step 7, bench scale evaluation, will be started in parallel with
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Step 5 in order to provide enough time for bench testing and to reduce the overall schedule
timeline.
E. Detailed engineering and design of the selected alternative actions.
Step 11 includes the preparation of plans and specifications for the actions selected to address Cd
within the process. This step, in order to allow reasonable time for engineering will have to begin
with preliminary work following the completion of the bench scale testing. Agency review comments
will be incorporated based on the information provided in step 10. This is a tight schedule for the
development of engineered solutions with sufficient detail for final evaluation. This also includes
the necessary evaluation of appropriate technologies from various vendors and ensuring the
equipment is available, and that it can be acquired and installed in a timely fashion to meet the
established schedule in the permit.
F. Moving forward with the actions to install, construct and place into operation the
necessary technologies and actions.
Steps 14, and 15 represent the on-the-ground installation of selected technologies. This
includes necessary time for capital project approvals in the company,obtaining all construction
approvals necessary to allow the project to proceed with installation of equipment. Approvals
will be obtained in advance of the development of detailed plans and specifications. This is an
aggressive approach which will require extensive coordination with Step 11. A 12-month period
is provided for finalizing design, procurement and construction. Considering that at the time of
development of this schedule that the scope of actions needed is not known, this could be a
very difficult objective. However, the company believes it is possible to achieve these
objectives during the time requested. Commissioning and ramp up of the installed equipment
and associated systems requires 6 months.
•
G. Placing the installation and systems into operation and working through initial
operational issues,establishing stable and effective protocols,and making sure that the
system can in fact comply with the limits.
Certainly,the final efforts needed to achieve the ultimate objective of compliance are
identified in Steps 16, 17 and 18. The total time allocated to these critical efforts is 12
months. The effective date of the final discharge limits is extremely important. The time
allowed for these steps need to be sufficient to prevent any circumstances that would
jeopardize final compliance. We see this as a two-step process, achieving stable operation
(16)and a final 6 months to optimize the systems and reach full operational status (17). Once
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compliance with final limits is achieved,the system will be optimized to ensure consistent and
reliable performance.
6. Requested Interim Limits.
The facility is currently undergoing a relatively large upgrade process (Restart Project)to improve the
process operation and overall management of process and storm water on this site. As noted,the
project will not materially impact the general materials balance for the production sequence that was
provided with the initial permit application for this facility. From a mass balance of materials
throughout the process, it is estimated that the effluent discharge will contain Cd levels in excess of
the anticipated concentration limit at the increased 0.98 MGD discharge rate. This projection is,of
course, the basis for this request and the described program for evaluating, selecting, and
implementing measures to reduce Cd in the process water discharge.
This report provides general information on the improvements that are under construction on the site
and the specific facility modifications that could affect resultant process water discharge
concentrations. The production sequences and technologies applied will not be fully tested or proven
until full production and a stable operation is achieved. As the previous operation trials were not
successful, data gathered during the former operating period cannot be used for estimating metal
concentrations in discharge effluent water.
AZR believes that the estimated level of Cd in effluent discharge water while the plant operates at full
production will be similar to the calculated concentration determined from the material balance. We
believe that the most appropriate approach to an interim limit is to establish a monitor-only provision
during the compliance period. As the facility moves toward full production and stable operation in
accordance with the requested compliance schedule, the actual process discharge Cd levels will be
definitively identified.

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Attachment 4
NPDES Permit Limits Pages
Current Permit at 0 . 8 MGD and
Anticipated Limits Page for 0 . 98
MGD

Current 2015 Permit Effluent Limits Page
PROPRIETARY AND CONFIDENTIAL-Do Not Disclose Permit NC0089109
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Part I
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:
EFFLUENT LIMITS MONITORING REQUREMENTS
CHARACTERISTICS
Monthly Daily Measurement Sample Sample
Average Maximum Frequency Type Locationl
Flow(MGD) 0.80 Continuous Recording I or E
Total Suspended Solids 2/Month f4 Composite E
NH3-N Quarterly Composite E
Total Aluminum Quarterly' 'Composite E
Total Antimony Quarterly Composite E
Total Arsenic Quarterly Composite E
Total Cadmium 0.27 mg/L 1.66 mg/L 2/Month -4 Composite E
Chlorides Quarterly Composite E
Total Chromium 6.75 mg/L 113.6 mg/L 2/Month Composite E
Total Cobalt Quarterly Composite E
Total Copper Quarterly Composite E
Total Fluoride 243.2 mg/L 243.2 mg/L F;ateontl?lq Al Composite E
Total Iron Quarterly, Composite E
Total Lead 3.37 mg/L 3.75 mg/L 2/Month Composite E
Total Nickel IAlo thly -4 Composite E
Total Tin Quarterly Composite E
Total Zinc 2/Month Composite E
pH2 Daily Grab E
Chronic Toxicity3 Quarterly Composite E
Turbidity4 Monthly :F 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 @ 0.74%;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.
5. No later than 270 days from the effective date of this permit,begin submitting discharge
monitoring reports electronically using NC DWR's eDMR application system. See Special
Condition A.(3.).
THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR FOAM VISIBLE IN OTHER THAN TRACE
AMOUNTS.
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Proposed Limits Page from 2017 Draft 0.98 MGD Permit
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
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 monitored5 by the Permittee as specified below:
EFFLUENT LIMITS MONITORING REQUREMENTS
CHARACTERISTICS
Monthly Daily Measureme Sample Sample
Average Maximum nt Type Location'
Frequency
Flow (MGD) 0.98 Continuous Recording I or E
Total Suspended Solids, 2/Month Composite E
mg/L
NH3-N, mg/L Quarterly Composite E
Total Aluminum, µg/L Quarterly Composite E
Total Antimony, µg/L Quarterly Composite E
Total Arsenic, µg/L Quarterly Composite E
Total Cadmium 65.5 µg/L 293.2 µg/L 2/Month Composite E
Chlorides, mg/L Quarterly Composite E
Chromium (VI), µg/L Quarterly Composite E
Total Cobalt, µg/L Quarterly Composite E
Total Copper, µg/L Quarterly Composite E
Total Fluoride, mg/L Quarterly Composite E
Total Iron, mg/L Quarterly Composite E
Total Lead 326.0 µg/L 6,832 µg/L 2/Month Composite E
Total Nickel, µg/L Monthly Composite E
Total Tin, µg/L Quarterly Composite E
Total Zinc, µg/L 2/Month Composite E
pH2 Daily 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 @ 0.9%; 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.
5. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's
eDMR application system. See Special Condition A. (3.).
THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR FOAM VISIBLE IN OTHER THAN
TRACE AMOUNTS.