NC0089109_Draft Permit_20190129

ROY COOPER . •s'(
Governor .4 1r41,1,e n
MICHAEL S.REGAN
Secretary * -
LINDA CULPEPPER
Director NORTH CAROLINA
Environmental Quality
January 29, 2017
Mr. Robert Williamson,Plant Manager
American Zinc Products,LLC -
484 Hicks Grove Road
Mooresboro,North Carolina 28114
Subject: Draft Permit
Permit NC0089109
American Zinc Products,LLC
Rutherford County
Facility Class II
Dear Mr. Williamson:
Enclosed with this letter is a copy of the Draft Permit for your facility. Please review the draft very
carefully to ensure thorough understanding of the conditions and requirements it contains.
The draft permit contains the following significant changes from your current
permit:
• The flow limit was increased to 0.98 MGD
• The requirement for fish tissue monitoring was added to the permit to address comment -
from the Regional Office.
• The requirement for pollutant scan was added to the permit to address comment from the
Regional Office.
• The limits for Total Cadmium were recalculated (reduced) based on the new flow estimate
and the recent update to the North Carolina water quality standards.The cadmium limit
compliance schedule was added to the permit.
• The limits for Total Chromium,Total Lead, and Total Fluoride were removed from the
permit based on the results of the Reasonable Potential Analysis.
• The quarterly monitoring for the Hexavalent Chromium was added to the permit based on
the review of the effluent data.
DE Q
North Cambia Depart IOC rtt of Eievirot:tntatal Quality 6 Di.iiion of Water;Resources
SQ Nor Ili Salisbury Street I I61T13aiI 5eivtee Center I Ra`tigh.Notch Carolina 2e'b99.1611

Please provide any comments you have regarding the draft permit to this office by March 4,
2019. At this time,the Division is also publishing a notice in the newspapers of general
circulation in Rutherford County,inviting public comment on the draft permit. Following the 30-day
comment period,we will review all pertinent comments received and take appropriate action on the
permit renewal.
If you have any questions about the NPDES permit process,please contact me at the following e-
mail address: [e-mail], or telephone number: 919-707-3606.
Sincerely,
Sergei Chernikov,Ph.D.
‘71
Environmental Engineer II
Complex NPDES Permitting
Unit
cc: NPDES Files
Asheville Regional Office/Surface Water Protection Section (e-copy)
ESS/Aquatic Toxicology Unit(e-copy)
Maureen Kinney(e-copy)
Page 2 of 2

Permit NC0089 109
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
Draft 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,
American Zinc Products, LLC
is hereby authorized to discharge wastewater from a facility located at
American Zinc Products, LLC
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 applicable conditions set forth in
Parts I, II, III and IV hereof.
This permit modification shall become effective
This permit and authorization to discharge shall expire at midnight on July 31, 2023.
Signed this day
Linda Culpepper, Director
Division of Water Resources
By Authority of the Environmental Management Commission
Page 1 of 9

Permit NC0089 109
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.
American Zinc Products, LLC 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
➢ 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 WS-IV waters in the Broad River
Basin.
Page 2 of 9

Permit NC0089109
Part I
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, pg/L Quarterly Composite E
Total Antimony, pg/L Quarterly Composite E
Total Arsenic, pg/L Quarterly Composite E
Total Cadmium 90.4 µg/L6 454.4 µg/L6 2/Month Composite E
Chlorides, mg/L Quarterly Composite E
Chromium (VI), pg/L Quarterly Composite E
Total Cobalt, pg/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, pg/L 2/Month Composite E
Total Nickel, pg/L Monthly Composite E
Total Tin, pg/L Quarterly Composite E
Total Zinc, pg/L 2/Month Composite E
pH2 6.0 s pH <- 9.0 = 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. Therefore, if the effluent
measurement exceeds 50 NTU, the Permittee shall sample upstream and downstream
turbidity in the receiving waterbody, within 24 hours, to demonstrate the existing turbidity
level in the receiving waterbody was not increased. All data shall be reported on the DMRs.
(See 15A NCAC 2B .0211 (21)).
NTU - Nephelometric Turbidity Unit.
Page 3 of 9

Permit NC0089 109
5. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's
eDMR application system. See Special Condition,A. (3.).
6. The limit becomes effective 90 months from the effective date of the permit. Please see A.
(6.) for Compliance Schedule.
THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR FOAM VISIBLE IN OTHER THAN
TRACE AMOUNTS.
A. (2.) CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QUARTERLY)
[15A NCAC 02B .0200 et seq.]
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant
mortality to Ceriodaphnia dubia at an effluent concentration of 0.9%.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures
outlined in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised
December 2010, or subsequent versions or"North Carolina Phase II Chronic Whole Effluent
Toxicity Test Procedure" (Revised- December 2010) or subsequent versions. The tests will be
performed during the months of January, April, July and October. These months signify the
first month of each three-month toxicity testing quarter assigned to the facility. Effluent
sampling for this testing must be obtained during representative effluent discharge and shall be
performed at the NPDES permitted final effluent discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or
ChV below the permit limit, then multiple-concentration testing shall be performed at a
minimum, in each of the two following months as described in "North Carolina Phase II
•
Chronic Whole Effluent Toxicity Test Procedure" (Revised-December 2010) or subsequent
versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the months in which tests were performed, using the
parameter code TGP3B for the pass/fail results and THP3B for the Chronic Value. Additionally,
DWR Form_AT-3 (original) is to be sent to the following address:
Attention: North Carolina Division of Water Resources
Water Sciences Section/Aquatic Toxicology Branch
1621 Mail Service Cenfer
Raleigh, NC 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section no later
than 30 days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements
and all concentration/response data, and be certified by laboratory supervisor and ORC or
approved designate signature. 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 Water Sciences Section at the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required,
monitoring will be required during the following month. Assessment of toxicity compliance is
Page 4 of 9

Permit NC0089109
based on the toxicity testing quarter, which is the three month time interval that begins on the
first day of the month in which toxicity testing is required by this permit and continues until the
final day of the third month.
Should any test data from this monitoring requirement or tests performed by the North Carolina
Division of Water Resources indicate potential impacts to the receiving stream, this permit may be
re-opened and modified to include alternate monitoring requirements or limits.
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.
A. (3.)ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS
[G.S. 143-215.1(b)]
Federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and
program reports. The final NPDES Electronic Reporting Rule was adopted and became effective on
December 21, 2015.
NOTE: This special condition supplements or supersedes the following sections within Part II of
this permit (Standard Conditions for NPDES Permits):
• Section B. (11.) Signatory Requirements
• Section D. (2.) Reporting
• Section D. (6.) Records Retention
• Section E. (5.) Monitoring Reports
1. Reporting Requirements [Supersedes Section D. (2.) and Section E. (5.) (a)J
The permittee shall report discharge monitoring data electronically using the NC DWR's
Electronic Discharge Monitoring Report (eDMR) internet application.
Monitoring results obtained during the previous month(s) shall be summarized for each
month and submitted electronically using eDMR. The eDMR system allows permitted facilities
to enter monitoring datk and submit DMRs electronically using the internet. Until such time
that the state's eDMR application is compliant with EPA's Cross-Media Electronic Reporting
Regulation (CROMERR), permittees will be required to submit all discharge monitoring data to
the state electronically using eDMR and will be required to complete the eDMR submission by
printing, signing, and submitting one signed original and a copy of the computer printed
eDMR to the following address:
NC DEQ / Division of Water Resources / Water Quality Permitting Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the
facility being physically located in an area where less than 10 percent of the households have
broadband access, then a temporary waiver from the NPDES electronic reporting requirements
may be granted and discharge monitoring data may be submitted on paper DMR forms (MR 1,
1.1, 2, 3) or alternative forms approved by the Director. Duplicate signed copies shall be
Page 5 of 9

Permit NC0089 109
submitted to the mailing address above. See "How to Request a Waiver from Electronic
Reporting" section below.
Regardless of the submission method, the first DMR is due on the last day of the month
following the issuance of the permit or in the case of a new facility, on the last day of the
month following the commencement of discharge.
Starting on December 21, 2020, the permittee must electronically report the following
compliance monitoring data and reports, when applicable:
• Sewer Overflow/Bypass Event Reports;
• Pretreatment Program Annual Reports; and
• Clean Water Act (CWA) Section 316(b) Annual Reports.
The permittee may seek an electronic reporting waiver from the Division (see "How to Request
a Waiver from Electronic Reporting" section below).
2. Electronic Submissions
In accordance with 40 CFR 122.41(1)(9), the permittee must identify the initial recipient at the
time of each electronic submission. The permittee should use the EPA's website resources to
identify the initial recipient for the electronic submission.
Initial recipient of electronic NPDES information from NPDES-regulated facilities means the
entity (EPA or the state authorized by EPA to implement the NPDES program) that is the
designated entity for receiving electronic NPDES data [see 40 CFR 127.2(b)].
EPA plans to establish a website that will also link to the appropriate electronic reporting tool
for each type of electronic submission and for each.state. Instructions on how to access and
use the appropriate electronic reporting tool will be available as well. Information on EPA's
NPDES Electronic Reporting Rule is found at:
https://www.federalregister.gov/documents/2015/10/22/2015-24954/national-pollutant-
discharge-elimination-system-npdes-electronic-reporting-rule
Electronic submissions must start by the dates listed in the "Reporting Requirements" section
above.
3. How to Request a Waiver from Electronic Reporting
The permittee may seek a temporary electronic reporting waiver from the Division. To obtain
an electronic reporting waiver, a permittee_must first submit an electronic reporting waiver
request to the Division. Requests for temporary electronic reporting waivers must be
submitted in writing to the Division for written approval at least sixty (60) days prior to the
date the facility would be required under this permit to begin submitting monitoring data and
reports. The duration of a temporary waiver shall not exceed 5 years and shall thereupon
expire. At such time, monitoring data and reports shall be submitted electronically to the
Division unless the permittee re-applies for and is granted a new temporary electronic
reporting waiver by the Division. Approved electronic reporting waivers are not transferrable.
Only permittees with an approved reporting waiver request may submit monitoring data and
reports on paper to the Division for the period that the approved reporting waiver request is
effective.
Information on eDMR and the application for a temporary electronic reporting waiver are
found on the following web page:
http://deq.nc.gov/about/divisions/water-resources/edmr
Page 6 of 9

Permit NC0089 109
4. Signatory Requirements [Supplements Section B. (11.) (b) and Supersedes Section B.
(11.) (d)1
All eDMRs submitted to the permit issuing authority shall be signed by a person described in
Part II, Section B. (11.)(a) or by a duly authorized representative of that person as described in
Part II, Section B. (11.)(b). A person, and not a position, must be delegated signatory
authority for eDMR reporting purposes.
For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR
user account and login credentials to access the eDMR system. For more information on
North Carolina's eDMR system, registering for eDMR and obtaining an eDMR user account,
please visit the following web page:
http:/f deq.nc.gov/about/divisions/water-resources/edmr
Certification. Any person submitting an electronic DMR using the state's eDMR system 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 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."
5. Records Retention [Supplements Section D. (6.)1
The permittee shall retain records of all Discharge Monitoring Reports, including eDMR
submissions. These records or copies shall be maintained for a period of at least 3 years from
the date of the report. This period may be extended by request of the Director at any time [40
CFR 122.41].
A. (4.) FISH TISSUE MONITORIN___G -
[G.S. 143-215.1(b)] -
The facility shall conduct fish tissue moniforing once during the permit cycle and submit the resulfs
with the NPDES permit renewal application. The objective of this monitoring is to evaluate potential
uptake of pollutants by fish tissue near_the facility's discharge. The parameters analyzed in fish
tissue shall be arsenic, cadmium, and zinc. The monitoring shall be conducted in accordance with
the sampling plan approved by the Division. The plan should be submitted to the Division within
180 days from the effective date of the permit modification. Upon approval, the plan becomes an
enforceable part of the permit.
Copies of all the study plans, study results, and any other applicable materials should be
submitted to:
1) Electronic Version Only (pdf and CD)
Division of Water Resources
WQ Permitting Section - NPDES
1617 Mail Service Center
- Raleigh, NC 27699-1617
2) Electronic Version (pdf and CD) and Hard Copy
Division of Water Resources
Water Sciences Section
1621 Mail Service Center
Raleigh, NC 27699-1621
Page 7 of 9

Permit NC0089109
A. (5.) PRIORITY POLLUTANT ANALYSIS
[G.S. 143-215.1(b)]
The Permittee shall perform one Effluent Pollutant Scan for all parameters listed below. The analytical
methods shall be in accordance with 40 CFR Part 136 and shall be sufficiently sensitive to determine
whether parameters are present in concentrations greater than applicable standards and criteria.
Unless otherwise indicated, metals shall be analyzed as "total recoverable."
Ammonia (as N) Trans-1,2-dichloroethylene Bis (2-chloroethyl) ether
Chlorine (total residual, TRC) 1,1-dichloroethylene Bis (2-chloroisopropyl) ether
Dissolved oxygen 1,2-dichloropropane Bis (2-ethylhexyl) phthalate
Nitrate/Nitrite 1,3-dichloropropylene 4-bromophenyl phenyl ether
Kjeldahl nitrogen Ethylbenzene Butyl benzyl phthalate
Oil and grease Methyl bromide 2-chloronaphthalene
Phosphorus Methyl chloride 4-chlorophenyl phenyl ether
Total dissolved solids Methylene chloride Chrysene
Hardness 1,1,2,2-tetrachloroethane Di-n-butyl phthalate
. Antimony Tetrachloroethylene Di-n-octyl phthalate
Arsenic Toluene Dibenzo(a,h)anthracene
Beryllium 1,1,1-trichloroethane 1,2-dichlorobenzene
Cadmium 1,1,2-trichloroethane 1,3-dichlorobenzene
Chromium Trichloroethylene 1,4-dichlorobenzene
Copper Vinyl chloride 3,3-dichlorobenzidine
Lead Acid-extractable compounds: Diethyl phthalate
Mercury (EPA Method 1631E) P-chloro-m-cresol Dimethyl phthalate
Nickel 2-chlorophenol 2,4-dinitrotoluene
Selenium 2,4-dichlorophenol 2,6-dinitrotoluene
Silver 2,4-dimethylphenol 1,2-diphenylhydrazine
Thallium 4,6-dinitro-o-cresol Fluoranthene
Zinc 2,4-dinitrophenol Fluorene
Cyanide 2-nitrophenol ,� Hexachlorobenzene
L Total phenolic compounds 4-nitrophenol -- Hexachlorobutadiene
-Volatile organic compounds: Pentachlorophenoll Hexachlorocyclo-pentadiene
Acrolein Phenol - Hexachloroethane
Acrylonitrile 2,4,6-trichlorophehol Indeno(1,2,3-cd)pyrene
"`- Benzene Base-neutral compounds: Isophorone
Bromoform Acenaphthene Naphthalene
Carbon tetrachloride Acenaphthylene Nitrobenzene
Chlorobenzene Anthracene N-nitrosodi-n-propylamine
Chlorodibromomethane Benzidine N-nitrosodimethylamine
Chloroethane Benzo(a)anthracene N-nitrosodiphenylamine
2-chloroethylvinyl ether Benzo(a)pyrene Phenanthrene
Chloroform 3,4 benzofluoranthene Pyrene
Dichlorobromomethane Benzo(ghi)perylene 1,2,4-trichlorobenzene
1,1-dichloroethane Benzo(k)fluoranthene
1,2-dichloroethane Bis (2-chloroethoxy) •
methane
Reporting. The effluent pollutant scan shall be performed once during the permit cycle and test
results shall be submitted to the Division within 270 days of the sampling.
Page 8 of 9

Permit NC0089109
A. (6.) CADMIUM COMPLIANCE SCHEDULE
[G.S. 143-215.1(b)]
Activity Description Deadline
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 Month 12
compliance.
4. Complete evaluation period. Month 24
5. Prepare a Preliminary Engineering Report (PER) of process Month 30
alternatives and/or pollution prevention/waste minimization (parallel with activity 4)
alternatives designed to achieve compliance. This report would
include the results of the compliance evaluation. Submit to DWR
for review and comment.
6. Agency review and addressing comments Month 32
7. Bench scale test work of process alternatives (start in parallel Month 34
with Activity 6).
8. Evaluate business case and funding requirements for Month 34
technically suitable alternative(s). (parallel with activity 7)
9 Complete pilot test work for selected technology option(s) and Month 38
final technology 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 Month 44
DWR for comment.
12 Agency review and addressing comments Month 46
13 Prepare capital project application and secure funding for _ Month 48
selected option, obtain building permits and all needed (much-of this work will be done in
approvals for implementation. parallel with activities 11,12)
14. Project implementation, including design completion, Month 60
procurement and 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 Month 86
operational status.
18. Achieve full compliance. Month 90
Page 9 of 9

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Latitude: 35°12'3" Sub-Basin: 03-08-02 Facility
Longitude: 81°51'3"
Quad#: F11S Location
Stream Class:Receiving Stream: Broad River American Zinc Recycling
North NC0089109
Mooresboro Facility
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