NCS000562_HISTORICAL WITH APPLICATION_20180215

----STORIVIINATER-DIVISION-CODING SKEET " -
PERMIT NO.
CS Op
DOC TYPE
[I FINAL PERMIT
� MONITORING INFO
tAPPLICATI-
0PlIANCE
0 OTHER
DOC DATE
❑ �-01$01 IS
YYYYM M DD

Energy, Mineral &
Land Resources
ENVIRONMENTAL QUALITY
February 15, 2018
Mr. Robert D. WilIiamson
American Zinc Products, LLC
484 Hicks Grove Rd
Mooresboro, NC 28114
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
WILLIAM E. (TOBY) VINSON, JR.
Interim Director
Subject: NPDES Stormwater Permit Renewal
American Zinc Products, LLC
NPDES Individual Permit No. NCS000562
Rutherford County
Dear Mr. Williamson:
Your facility is currently covered for stormwater discharge under NPDES Individual Permit
NCS000562. This permit expires on March 31, 2018. To assure consideration for continuing
coverage under your permit, you must apply to the Division of Energy, Mineral and Land Resources
(DEMLR) for renewal of your permit.
Enclosed you will find a permit Renewal Application Form, Supplemental Information request, and a
Stormwater Pollution Prevention Plan Certification for your facility. You can also find this information
on our website: https://deg.nc.gov/about/divisions/energy-mineral-land-resources/npdes-industrial-
stormwater. Submitting the application form along with the requested supplemental information will
constitute your application for renewal of this permit. Until your permit renewal is completed and you
receive a new permit, please continue to comply with all conditions and monitoring requirements in
your expired NPDES stormwater permit.
Please submit the application and supplemental information to DEMLR by March 31, 2018.
Discharge of stormwater without coverage under a valid stormwater NPDES permit constitutes a
violation of N.C. General Statute 143-215.1 and may result in the assessment of civil penalties up to
$25,000 per day.
State of North Carolina I Environmental Quality I Energy, Mineral and Land Resources
512 N. Salisbury Street 1 l612 Mail Service Center I Raleigh, North Carolina 27699-1612
9l9 707 9200

If you have any questions concerning this permit renewal, please contact Julie Ventaloro at telephone
number [phone] or by email [e-mail].
Sincerely,
9 . C
Annette Lucas, Supervisor
Stormwater Permitting Program
cc: Central Files
Stormwater Permitting Program Files
State of North Carolina Environmental quality I Energy, Mineral and Land Resources
512 N. Salisbury Street 116t2 Mail Service Center i Raleigh, North Carolina 27699-1612
919 707 9200

Ad—
�v V
AMERICAN
1�
RZINC RECYCLING Su to 405 Steubenville Pike www.azr.co
Delivering a Sustainable Future Pittsburgh, PA 15205
NC DIVISION OF ENERGY MINERAL
AND LAND RESOURCES
ATTN: STORMWATER BILLING
RALEIGH, NC 27699-1612
May 1, 2017
Re: Change in Names of Horsehead Corporation and Horsehead Metal Products, LLC
Dear Valued Supplier,
R8ce1w: 0
NAY
�7�t1lfi1>''V ~
On May 1, 2017, Horsehead Corporation and Horsehead Metal Products, LLC changed their
corporate names to "American Zinc Recycling Corp." and "American Zinc Products LLC",
respectively. Please note these name changes in your records and change your documentation
to be sent to us accordingly.
For each company, this is only a name change, and the business entity otherwise is unaffected,
as are our existing contractual relationships. There is no assignment or transfer of these
agreements, merely a change in our companies' names.
On the same date, the parent holding company, Horsehead Holding LLC, changed its name to
"American Zinc Recycling LLC". As with the change in the name of Horsehead Corporation and
Horsehead Metal Products, LLC, this is only a change in the name, and not a change in the entity
or a transfer of any of its obligations or rights.
Please note that documentation, labeling, or purchase or sales forms may be sent to you that
include or reference the prior name, until we have completed switching out all such
documentation for the name changeovers. However, any documentation, labeling, or purchase
or sales forms we send that include or reference the prior name shall continue to be binding
notwithstanding these name changes.
Wayne Isaacs
Chief Executive Officer ,
American Zinc Recycling Corp.

0 i
Aiken, Stan IE
From: Aiken, Stan E
Sent: Wednesday, February 14, 2018 10:36 AM
To: Riddle, Rick L
Subject: FW: Horsehead storm water/ waste water permit renewal
Attachments: DRAFT NPDES NCS000562 American Zinc Products (formerly Horsehead) 8.19.2015.docx
Rick,
I have reviewed the attached draft permit and concur with the revised language and requirements. Should you have any
questions or require further information, please advise. Thank you for your help in this matter.
Thank You,
Stanley E Aiken
Regional Engineer
Land Quality Section
North Carolina Department of Environmental Quality
828 296-4500 main
828 296-4610 office
stars. aikentancdenr. gov
2090 US70 Highway
Swannanoa, NC 28778-8211
+`: �Notfiing Compares--,
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Randall, Mike
Sent: Saturday, August 19, 2017 9:02 AM
To: Aiken, Stan E <[e-mail]>
Subject: RE: Horsehead storm water/ waste water permit renewal
Stan
I'll be out of the office until August 24. Attached is the final draft. I doubt that the they can add anything before I
retire that would suggest we should modify the attached draft any further.
We will still need to evaluate their SPPP and any written inspection and maintenance plans. That may shed further
light.

Unless they can provide additional information and/or clarification in the next few weeks, my recommendation is
to reissue the permit and let them challenge it if they have objections. The permit can always be modified later if
they can provide further information and/or clarification.
Mike Randall
Stormwater Permitting Program
NC Division of Energy, Mineral and Land Resources (DEMLR)
Land Quality Section
Stormwater Permitting
1612 Mail Service Center
Raleigh, NC 27699-1612
Office: 919-807-6374
Cell: 919-389-7801
Email correspondence to and from this address may be subject to public records laws
Initial response to comments
Proposed language "SDO 01 is representative of the contribution of existing stormwater flows from the site, OR61 dine the
po„asTR the SX aFea .
Proposed additional language in Part II Section A (2)(b)
"Secondary Containment Requirements and Records. Secondary containment is required for: bulk storage of
liquid materials including petroleum products; any amount of Section 313 of Title III of the Superfund
Amendments and Reauthorization Act (SARA) water priority chemicals; any amount of hazardous substances,
and/or any amount of process makeup including the process ponds in the SX area.,
Proposed additional language in Part 11 Section A (2)(c) and (d)
"In lieu of providing secondary containment for the process ponds in the SX area, the permittee may provide for
additional storage for the 25 year-24 hour storm event (5.72-6.70) plus one foot of free board."
"The permittee shall provide annual certification of the integrity of all bulk storage tanks and/or lined storage of liquid
materials including petroleum products; any amount of Section 313 of Title III of the Superfund Amendments and
Reauthorization Act (SARA) water priority chemicals; any amount of hazardous substances, and/or including the process
ponds in the SX area."
Proposed additional language in Part II Section A (4)
"Any stormwater control measures that collects sediment shaft be designed to hold one foot of sediment, plus the 25
year-24 hour storm event (5.72-6.70) plus one foot of free board for 2 to 5 days. All such stormwater control measures
shall be cleaned out when the sediment exceeds one foot. All hazardous waste determination records and dispose
records shall be maintained on site for five years."

0
From: James D. Harris [mailto:[e-mail]]
Sent: Thursday, August 17, 2017 4:25 PM
To: Aiken, Stan E <stan.aikenf ncdenr.gov>; Randall, Mike <mike.randall@ncden_r.gov>
Cc: Riddle, Rick L <[e-mail]>
Subject: FW: Horsehead storm water/ waste water permit renewal
I recommend the following change to the wordage on page 5 of the draft permit. Currently the draft permit contains this
sentence:
"SDO 01 is representative of the contribution of existing stormwater flows from the site, including the ponds in the
SX area."
Please change this sentence to state:
"SDO 01 is representative of the contribution of existing stormwater flows from the site, including the stormwater
ponds in the SX area."
There are process related ponds in the SX area that are not allowed to flow to the SDO 01. Only stormwater should
be allowed to flow to SDO 01.
Thanks,
Jim Harris
From: Randall, Mike [ma ilto:mike. [e-mail]]
Sent: Thursday, June 29, 2017 1:48 PM
To: James D. Harris
Cc: Riddle, Rick L
Subject: FW: Horsehead storm water/ waste water permit renewal
Jim
All stormwater and NPDES permit modifications related to Horsehead are on hold (see email thread below). That being
said I attached the DRAFT permit for your review and comment. I have not received any comment from the RO — there
may be additional comments and request from the RO. I suspect the RO will hold their comments per Brent Burch,
Compliance Branch Head with the Hazardous Waste Section.
Mike
From: Burch, Brent
Sent: Tuesday, June 27, 2017 2:03 PM
To: Davidson, Landon <[e-mail]>; Randall, Mike <[e-mail]>
Cc: Woosley, Julie <iulie.woosle ncdenr. ov>; Aiken, Stan E <[e-mail]>; Morris, Sean
<sean.morris ncdenr. ov>; Menzel, Jeff <[e-mail]>
Subject: FW: Horsehead storm water/ waste water permit renewal
Hi Landon and Mike,
The Hazardous Waste Section is requesting that DEMLR and DWR put all stormwater and NPDES permit modifications
related to Horsehead on hold until we can determine what impact, if any, those modifications may have on our
regulatory jurisdiction related to a joint HWS/EPA January sampling event. As both of you may be aware, 9 of 15 sample
results came back exceeding hazardous waste limits for one or more constituents including lead, cadmium, chromium or
silver. All 9 areas are, or could be, related to stormwater management or regulated discharges.
HWS will be having a conference call this Thursday with Horsehead and EPA to discuss the sampling
results. Additionally, HWS continues to work with EPA to establish a plan of action to address both our concerns at the

0 0
site. I know all of our programs have responsibilities to respond to our customers in a timely manner, so if we need to
reach out to DEMLR or DWR staff at the Division level we would be happy to do so.
Please let me know if you have any questions, concerns or thoughts on moving forward. I would be happy to set up a
conference call where we can all discuss this in more detail internally if that is preferred.
Thanks... Brent
Brent G. Burch
Compliance Branch Head
Hazardous Waste Section
Division of Waste Management
828 321 9585 office
919 270 2049 mobile
Brent. [e-mail]
PO Box 1427
Andrews, NC 28901
�INothing Compares.. -,-
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Menzel, Jeff
Sent: Friday, June 23, 2017 3:58 PM
To: Burch, Brent <[e-mail]>; Morris, Sean <[e-mail]>
Subject: Horsehead storm water/ waste water permit renewal
Sean and Brent,
After reviewing the current draft of Storm Water permit NC5000562 for American Zinc Products LLC (former Horsehead
Metals), I would like to request that this draft and any other NPDES permit be placed on hold.
The current storm water permit does not expire until March 2018 and I feel that any analytical data available along with
observations made by HWS during site visits staff be conveyed to DEMLR/DWR before any subsequent permits are
issued.
This facility, in its shorts life span, has had numerous spills of hazardous material with the primary conveyance being the
storm water/wastewater systems. There are NPDES permits issued for both.
The facility has asked for DEQ's input during their current engineering phase prior to starting operations again in 2018.
To facilitate a beneficial response to the facility I think it is prudent that the various Division's share information or
concerns regarding permit requirements or applicable regulations.

E
If you need any additional information or supporting documentation for this request I will be happy to provide that.
Thanks,
Jeff
Jeff Menzel
Western Region Environmental Specialist
Hazardous Waste Section
Division of Waste Management
828 41.9 5034 office
919 270 1967 cell
[e-mail]
PO Sox 117
Black Mountain, NC 28711
nothing Compares--,,
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

NCS000562
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF ENERGY, MINERAL, AND LAND RESOURCES
PERMIT
TO DISCHARGE STORMWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of North Carolina Gene" Zraltatute 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 herebyauthorized to dischl r e`storm ater from a facility located at
� \ tY
Ameri�cZinc Products LLC
484,Hicks Grove Road
•esboro, North Carolina
Rutherford County
to receiving waters designated as the Broad River, a class C water in the Broad River Basin,
in accordance with the discharge limitations, monitoring requirements, and other
conditions set forth in Parts 1, II, 111, and IV hereof.
This permit shall become effective [DATE].
This permit and the authorization to discharge shall expire at midnight on [DATE].
Signed this day [DATE].
for Tracy E. Davis, P.E., CPM, Director
Division of Energy, Mineral and Land Resources
By the Authority of the Environmental Management Commission

Permit No. NCS000562
PART
Section A:
Section B:
Section C:
PART II
Section A:
Section B:
Section C:
TABLE OF CONTENTS
INTRODUCTION
Individual Permit Coverage
Permitted Activities
Location Map
MONITORING, CONTROLS, AND LIMITATIONS FOR PERMITTED
DISCHARGES
Stormwater Pollution Prevention Plan \ %
Analytical Monitoring Requirements
Qualitative Monitoring Requirements
�� A /�
PART III STANDARD COND,ITION'FOR NPDES STORMWATER INDIVIDUAL PERMITS
Section A: Compliance and-L'iabi
p _ �Y
s
1. Compliance Schedule
2. Duty to Comply
3. Duty -to -Mitigate
4. Civil and Criminal Liability
5. Oil and Hazardous Substance Liability
6. Property Rights
7. Severability
8. Duty to Provide Information
9. Penalties for Tampering
10. Penalties for Falsification of Reports
11. Onshore or Offshore Construction
12. Duty to Reapply
Section B: General Conditions
1. Permit Expiration
2. Transfers
3. Signatory Requirements
4. Permit Modification, Revocation and Reissuance, or Termination
S. Permit Actions
6. Annual Administering and Compliance Monitoring Fee
Requirements

E
0
Permit No. NCS000562
Section C:
Section D:
Section E:
PART IV
Operation and Maintenance of Pollution Controls
1. Proper Operation and Maintenance
2. Need to Halt or Reduce Not a Defense
3. Bypassing of Stormwater Control Facilities
Monitoring and Records
1.
2.
3.
4.
5.
6.
7.
Representative Sampling
Recording Results
Flow Measur^~„^„�,
Test Proced
Representa
Records Ref
Inspection <
Reporting Requirer
1.
2.
3.
4.
S.
6.
7.
8.
9.
10
11
Discharge N
Submitting
Availability
Non-Stormwater,ll2scnarges
Planned Changes v
Anticipated Noncompliance
Spills
Bypass
Twenty-four Hour Reporting
Other Noncompliance
Other Information
DEFINITIONS
ni

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

0
Permit No. NCS000562
SECTION C: LOCATION MAP
American Zinc Products LLC
�i
J
Part 1 Page 2 of 2

Permit No. NCS000562
PART II MONITORING, CONTROLS, AND LIMITATIONS FOR
PERMITTED DISCHARGES
SECTION A: STORMWATER POLLUTION PREVENTION PLAN
The permittee shall develop and implement a Stormwater Pollution Prevention Plan
(SPPP). The SPPP shall be maintained on site. The SPPP is public information in
accordance with Part III, Standard Conditions, Section E, paragraph 3 of this permit. The
SPPP shall include, at a minimum, the following items:
1. Site Overview. The Site Overview shall provide a description of the physical facility
and the potential pollutant sources that may be expected to contribute to
contamination of stormwater discharges. The Site Overview shall contain the following:
a A general location ma USGS quadrangle " or appropriately "drafted equivalent
() g p( A g 1^ P�
map), showing the facility's location in relation to'transportation routes and surface
waters; the name of the receiving waters'to which the stormwater outfalls
discharge, or if the discharge is to a municipal separate storm sewer system, the
name of the municipality and the ultimate receiving waters; and accurate latitude
and longitude of the points of stormwater-discharge associated with industrial
activity. The general location,map..(or alternatively the site map) shall identify
whether any receiving wat rs.a a impaired (on the state's 343(d) list of impaired
waters) or if the site is located in.a watershed for which a TMDL has been
established, and what the parameters of concern are.
(b) A narrative descr4 on-of�storage practices, loading and unloading activities,
outdoor process areas, dust or particulate generating or control processes, and
waste disposal practices. A narrative description of the potential pollutants that
could be expected to be present in the stormwater discharge from each outfall.
(c) A site map drawn at a scale sufficient to clearly depict: the site property boundary;
the stormwater discharge outfalls; all on -site and adjacent surface waters and
wetlands; industrial activity areas (including storage of materials, disposal areas,
process areas, loading and unloading areas, and haul roads); site topography and
finished grade; all drainage features and structures; drainage area boundaries and
total contributing area for each outfall; direction of flow in each drainage area;
industrial activities occurring in each drainage area; buildings; stormwater Best
Management Practices (BMPs); and impervious surfaces. The site map must
indicate the percentage of each drainage area that is impervious, and the site map
must include a graphic scale indication and north arrow.
(d) A list of significant spills or leaks of pollutants during the previous three (3) years
and any corrective actions taken to mitigate spill impacts.
Part 11 Page 1 of 12

Permit No. NCS000562
(e) Certification that the stormwater outfalls have been evaluated for the presence of
non-stormwater discharges. The permittee shall re -certify annually that the
stormwater outfalls have been evaluated for the presence of non-stormwater
discharges. The certification statement will be signed in accordance with the
requirements found in Part III, Standard Conditions, Section B, Paragraph 3,
2. Stormwater Management Strategy. The Stormwater Management Strategy shall
contain a narrative description of the materials management practices employed which
control or minimize the stormwater exposure of significant materials, including
structural and nonstructural measures. The Stormwater Management Strategy, at a
minimum, shall incorporate the following:
(a) Feasibility Study. An annual review by site management of the technical and
economic feasibility of changing the methods of operations and/or storage practices
to eliminate or reduce exposure of materials and-processes•to rainfall and run-on
flows. Wherever practical, the permittee shall -prevent.exposure of all storage areas,
material handling operations, and manufacturirig,or fueling operations. In areas
where elimination of exposure and/or prevention of run-on contact are not
practical, the Feasibility Study shall document -the basis for the management
decision that such controls are no�feasihle.
(b) Secondary Containmerit,Requirements and Records. Secondary containment is
required for: bulk storage ofliquid materials including petroleum products; any
amount of Section 313 of Title III ofthe Superfund Amendments and
Reauthorization Act (SACRA] water priority chemicals; any amount of hazardous
substances, and/or any amount of process makeup including the process ponds in
the SX area., "' n_1 to V71r,rn.��riY �n ��.� .r r� r r ;ll Fr rim rnnYnminntinn rtnrm...n Yn.
ru e€€ A table or summa v of all such tanks and stored materials and their
associated secondary containment areas shall be maintained. If the secondary
containment devices are connected to stormwater conveyance systems, the
connection shall be controlled by manually activated valves or other similar devices,
which shall be secured closed with a locking mechanism. Prior to release into the
stormwater conveyance system, any stormwater that accumulates in the
containment area shall be at a minimum visually observed for color, foam, outfall
staining, visible sheens and dry weather flow. Accumulated stormwater may be
released if found to be uncontaminated by any material. Records documenting the
individual making the observation, the description of the accumulated stormwater,
and the date and time of the release shall be kept for a period of five (5) years.
(c) In lieu of providing secondary containment for the process ponds in the SX area, the
permittee may provide for additional storage for the 25 year-24 hour storm event
(5.72-6.70) plus one foot of free board.
(d) The permittee shall provide annual certification of the integrity of all bulk storage
tanks and/or lined storage of liquid materials including petroleum products; any
amount of Section 313 of Title III of the Superfund Amendments and
Part I I Page 2 of 12

Permit No. NCS000562
Reauthorization Act (SARA) water priority chemicals; any amount of hazardous
substances, and/or including the process ponds in the SX area.
(e) BMP Summary. A listing of site structural and non-structural Best Management
Practices (BMPs) shall be provided. The installation and implementation of BMPs
shall be based on the assessment of the potential for sources to contribute
significant quantities of pollutants to stormwater discharges and on data collected
through monitoring of stormwater discharges. The BMP Summary shall include a
written record of the specific rationale for installation and implementation of the
selected site BMPs. The BMP Summary shall be reviewed and updated annually.
3. Spill Prevention and Response Procedures. The Spill Prevention and Response
Procedures (SPRP) shall incorporate an assessment of,potential pollutant sources based
on a materials inventory of the facility. The SPRP/shall address spill response and
failure mode preparation and responses. Site m nagement shall identify facility
personnel responsible for implementing the SPRP' n a written list incorporated into the
SPRP aleirg with dated signatures by each individuals acknowledging their
responsibilities for the SPRP. A responsible,person^shall be on -site at all times during
facility operations that have potential to contaminate stormwater runoff through spills
or exposure of materials associated withthefacilityoperations. The SPRP must be site
stormwater specific. Therefore, an o�il,Spill Prevention Control and Countermeasure
plan (SPCC) may be a component of the SPRP, but may not be sufficient to completely
address the stormwater aspects,of the SPRP. The common elements of the SPCC with
the SPRP may be incorporated -by reference into the SPRP.
4. Preventative Maintenance and�Good Housekeeping Program. A preventative
maintenance and goodhousekeeping program shall be developed and implemented.
The program shall address -all stormwater control systems, stormwater discharge
outfalls, all on -site and adjacent surface waters and wetlands, industrial activity areas
(including material storage areas, material handling areas, disposal areas, process
areas, loading and unloading areas, and haul roads), all drainage features and
structures, and existing structural BMPs. The program shall establish schedules of
inspections, maintenance, and housekeeping activities of stormwater control systems,
as well as facility equipment, facility areas, and facility systems that present a potential
for stormwater exposure or stormwater pollution where not already addressed under
another element of the SPPP. Inspection of material handling areas and regular
cleaning schedules of these areas shall be incorporated into the program. Timely
compliance with the established schedules for inspections, maintenance, and
housekeeping shall be recorded and maintained in the SPPP.
Any stormwater control measures that collects sediment shall be designed to hold one
foot of sediment, plus the 25 year-24 hour storm event (5.72-6.70) plus one foot of free
board for 2 to 5 days. All such stormwater control measures shall be cleaned out when
the sediment exceeds one foot. All hazardous waste determination records and dispose
records shall be maintained on site for five years.
Part lI Page 3 of 12

9
Permit No. NCS000562
S. Facility Inspections. Inspections of the facility and all stormwater conveyance and
control systems shall occur as part of the Preventative Maintenance and Good
Housekeeping Program at a minimum on a semi-annual schedule, once during the first
half of the year (January to June), and once during the second half (July to December),
with at least 64 days separating inspection dates (unless performed more frequently
than semi-annually). These facility inspections are different from, and in addition to,
the stormwater discharge characteristic monitoring at the outfalls required in Part II
Section B and C of this permit.
6. Employee Training. Training programs shall be developed and training provided at a
minimum on an annual basis for facility personnel with responsibilities for: spill
response and cleanup, preventative maintenance activities, and for any of the facility's
operations that have the potential to contaminate stormwater runoff. The facility
personnel responsible for implementing the training shall be identified, and their
annual training shall be documented by the signature -of each employee trained.
Part II Page 4 of 12

Permit No. NCS000562
7. Responsible Party. Site management shall identify, and the SPPP shall document a
specific position or positions responsible for the overall coordination, development,
implementation, and revision of the SPPP. Responsibilities for all components of the
SPPP shall be documented and position assignments provided.
8. SPPP Amendment and Annual Update. The permittee shall amend the SPPP
whenever there is a change in design, construction, operation, site drainage,
maintenance, or configuration of the physical features which may have a significant
effect on the potential for the discharge of pollutants to surface waters. All aspects of
the SPPP shall be reviewed and updated on an annual basis. The annual update
shall include all aspects required immediately above in items 1- 7; and review and
comparison of monitoring analytical data to benchmark values over the past year,
including a discussion about Tiered Response status. �The•permittee shall use the
Division's Annual Summary Data Monitoring Report,form, available from the c"^er-
Der-mitting Unit's website he-e:
/� \ \ %
The Director may notify the permittee when the SPPP does not meet one or more of the
minimum requirements of the permit.,Within 30 days of such notice, the permittee
shall submit a time schedule to the Director for modifying the SPPP to meet minimum
requirements. The permittee. halllprovide certification in writing (in accordance with
Part I11, Standard Conditions, SectionB�Paragraph 3) to the Director that the changes
have been made.
9. SPPP Implementation. The permittee shall implement the Stormwater Pollution
Prevention Plan and all \appropriate BMPs to prevent contaminants from entering
surface waters via stormwater. Among other actions identified herein, implementation
of the SPPP shall include documentation of, all monitoring, measurements, inspections,
maintenance activities, and training provided to employees, including the log of the
sampling data and of actions taken to implement BMPs associated with the industrial
activities. Such documentation shall be kept on -site for a period of five (5) years and
made available to the Director or the Director's authorized representative immediately
upon request.
Part II Page 5 of 12

0 0
Permit No. NCS000562
SECTION B: ANALYTICAL MONITORING REQUIREMENTS
Analytical monitoring of stormwater discharges shall be performed as specified in Table 1.
All analytical monitoring shall be performed during a measurable storm event at each
stormwater discharge outfall (SDO). Only SDOs discharging stormwater associated with
industrial activity must be sampled (See Definitions). SDO 01 is representative of the
contribution of existing stormwater flows from the site, including the ponds in the cv aFea.
A measurable storm event is a storm event that results in an actual discharge from the
permitted site outfall. The previous measurable storm event must have been at least 72 hours
prior. See Definitions.
Table 1. Analytical Monitoring Requirements /j
Discharge
Measurement
Sample
Sample
Characteristics
Units
Freq uencyl
TypC2
Location3
Total Suspended Solids (TSS)
m L
" �Quar�erly/
Grab
SDO
Total Nitrogen
m L s
quarterly
Grab
SDO
Total Phosphorus
m l �
quarterly
Grab
SDO
Zinc, Total Recoverable
im L�/
7/-­/quarterly
Grab
SDO
Lead, Total Recoverable /
,"(m � L j
quarterly
Grab
SDO
Cadmium, Total Recoverable'
m L
quarterly
Grab
SDO
Chlorides
,gym L
quarterly
Grab
SDO
Non -polar Oil & Grease/TPH
m L
g�
quarterly
Grab
SDO
EPA Method 1664 SGT M-HE
H ���
standard
quarterly
Grab
SDO
Total Rainfa114
inches
quarterly
Rain
Gauge
Footnotes:
1 Measurement Frequency: Four times per year during a measurable storm event. The permittee may
petition DEQ DWQ to reduce the analytical monitoring frequency to twice per year after eight consecutive
quarterly monitoring results all within the benchmark values. Subsequently, two consecutive benchmark
exceedances for any parameter re -institutes quarterly monitoring for all parameters.
2 Grab samples shall be collected within the first 30 minutes of discharge.
3 Sample Location: Samples shall be collected at each stormwater discharge outfall (00). SDO 01 is
representative of the contribution of existing stormwater flows from the site, including the ponds in the SX
area.
4 For each sampled measurable storm event, the total precipitation must be recorded. An on -site rain gauge
reading must be recorded.
The permittee shall complete the analytical samplings in accordance with the schedule
specified below in Table 2, unless adverse weather conditions prevent sample collection
(see Adverse Weather in Definitions). A minimum of 30 days must separate successive
sample events. Inability to sample because of adverse weather conditions must be
Part II Page 6 of 12

•
Permit No. NCSOOOS62
documented in the SPPP and recorded on the DMR. The permittee must report the results
from each sample taken within the monitoring period (see Part 111, Section E).
Table 2. Monitoring Schedule
Monitoring periodl,z
Sample Number
Frequency
Year 1 - Period 1
1
151 Quarter
Year 1- Period 2
2
2nd Quarter
Year 1- Period 3
3
3rd Quarter
Year 1 - Period 4
4
4th Quarter
Year 2 - Period 1
5
1st Quarter
Year 2 - Period 2
6
2nd Quarter
Year 2 - Period 3
7
3rd Quarter?
Year 2 - Period 4
8
,4th Quarter ,
Year 3 - Period 1
9
; i5t Quarter\'�/
Year 3 - Period 2
10
�2�d;Quarter-'
Year 3 - Period 3
11
�3",Quarter
Year 3 -Period 4
12
n 4th Quarter
Year 4 - Period 1
13 , //
f� �15Y Quarter
Year 4 - Period 2
14
Quarter
Year 4 - Period 3
/\15 </ �r
3rd Quarter
Year 4 - Period 4
'\\16,\
4th Quarter
Year 5 - Period 1
- 17\ �v
15tQuarter
Year 5 - Period 2
18)/\/
2nd Quarter
Year 5 - Period 3
19�
3rd Quarter
Year 5 - Period 4
0
4th Quarter
Footnotes:
1 The date on which the plant begins zinc production, the permittee shall maintain quarterly
monitoring until either another permit is issued for this facility or until this permit is revoked or
rescinded. The permittee must submit an application for renewal of coverage before the submittal
deadline (180 days before expiration) to be considered for renewed coverage under the permit. The
permittee must continue analytical monitoring throughout the permit renewal process, even if a
renewal permit is not issued until after expiration of this permit.
2 If no discharge occurs during the sampling period, the permittee must submit a monitoring report
indicating "No Flow' or "No Discharge" within 30 days of the end of the sampling period. For the first
term of this permit, the new facility start-up date is uncertain. Permittee need not sample for the
listed monitoring period until the facility comes into operation, Accordingly, the "No Flow" or "No
Discharge" report is not required during the time before the facility comes into operation.
Failure to monitor quarterly per permit terms may result in the Division requiring
monthly monitoring for all parameters for a specified time -period. "No discharge" from
an outfall, or inability to collect a sample because of adverse weather conditions during the
monitoring period during a monitoring period does not constitute failure to monitor, as
long as provided it is properly recorded and reported.
Part I1 Page 7 of 12

Permit No. NCS000562
The permittee shall compare monitoring results to the benchmark values in Table 3. The
benchmark values in Table 3 are not permit limits, but should be used as management
guidelines for the permittee's responsive implementation of the Stormwater Pollution
Prevention Plan (SPPP).
Table 3. Benchmark Values for Analytical Monitoring
Discharge Characteristics
Units
Benchmark'
Total Suspended Solids (TSS)
mg/L
100
Total Nitrogen
mg/L
30
Total Phosphorus
mg/L
2
Zinc, Total Recoverable
mg/L') >�v
0.067
Lead, Total Recoverable
mg/L
0.03
Cadmium, Total Recoverable
mg�L
0.001
Chlorides
//--i4/L -
860
Non -polar Oil & Grease/TPH
EPA method 1664 SGT-HEM-
�mg L
15
PH �\
�% standard
6-9
Footnote��.�
1 Analytical results must not be reported via any of the notations, "BDL, ND, BRL, <MDL, <PQL, non -detect" or
any similar non -quantitative notations. Instead, analytical results below method or reporting limits must be
reported on the DMR in the forma , "<XV, where XX is the specific numerical value of the method or
reporting limit.
Part I1 Page 8 of 12

Permit No. NCS000562
Tier One
If. The first valid sampling results are above a benchmark value, or outside of the benchmark range, for
any parameter at any outfall;
Then: The permittee shall:
1. Conduct a stormwater management inspection of the facility within two weeks of receiving
sampling results.
2. Identify and evaluate possible causes of the benchmark value exceedance.
3. Identify potential, and select the specific feasible: source controls, operational controls, or physical
improvements to reduce concentrations of the parameters of concern, and/or to bring
concentrations within the benchmark range.
4. Implement the selected feasible actions within two months of the inspection.
S. Record each instance of a Tier One response in the SPPP. Include the date and value of the
benchmark exceedence, the inspection date, the personnel -conducting the inspection, the selected
actions, and the date the selected actions were im lemented.
Tier Two
If. During the term of this permit, the first valid sampl
are above the benchmark values, or outside of the 1
ecific discharge outfall;
results from two consecutive monitoring periods
:hmark range, for any specific parameter at a
Then: The permittee shall:
1. Repeat all the required actions outlined above in'Tier One.
2. Immediately institute monthly monittoring and reporting for all parameters. The permittee shall
conduct monthly monitoring at every outfall where a sampling result exceeded the benchmark
value for two consecutive samples. Monthly (analytical and qualitative) monitoring shall continue
until three consecutive sample result are below the benchmark values or within benchmark range.
3. If no discharge occurs during the sampling period, the permittee is required to submit a monthly
monitoring report indicating "No Flow" to comply with reporting requirements.
4. Benchmark exceedances�for-a different parameter separately trigger a tiered response.
S. Maintain a record of the -Tier Two response in the SPPP.
Tier Three
During the term of this permit, if the valid sampling results required for the permit monitoring periods
exceed the benchmark value, or are outside the benchmark range, for any specific parameter at any specific
outfall on four occasions, the permittee shall notify the DVA�-DEMLR Regional Office er- Engineer in
writing within 30 days of receipt of the fourth analytical results. P" The Division may, but is not limited
to:
• require that the permittee revise, increase, or decrease the monitoring and reporting frequency for
some or all of the parameters herein;
• require sampling of additional or substitute parameters;
• require the permittee to install structural stormwater controls;
• require the permittee to implement other stormwater control measures;
• require the permittee to perform upstream and downstream monitoring to characterize impacts
on receiving waters; or
• require the permittee implement site modifications to qualify for a No Exposure Exclusion;
• require the permittee to continue Tier Three obligations through the permit renewal process.
Part II Page 9 of 12

• 0
Permit No. NCS000562
If a Total Maximum Daily Load (TMDL) is approved for this segment of the Broad River, the
permittee may be required to monitor for the pollutant(s) of concern in the future and
submit results to the Division . The Division will consider the monitoring
results in determining whether additional BMPs are needed to control the pollutant(s) of
concern to the maximum extent practicable.
If additional BMPs are needed to achieve the required level of control, the permittee will be
required to (1) develop a strategy for implementing appropriate BMPs, and (2) submit a
timetable for incorporation of those BMPs into the Stormwater Pollution Prevention Plan.
Part 11 Page 10 of 12

0 •
Permit No. NCS000562
SECTION C: QUALITATIVE MONITORING REQUIREMENTS
The purpose of qualitative monitoring is to evaluate the effectiveness of the Stormwater
Pollution Prevention Plan (SPPP) and identify new potential sources of stormwater
pollution. Qualitative monitoring of stormwater outfalls must be performed during a
measurable storm event.
Qualitative monitoring requires a visual inspection of each stormwater outfall regardless of
representative outfall status. Qualitative monitoring shall be performed quarterly as
specified in Table 4, and ,.,,,,,.,,. Fent �• *� during the required analytical monitoring events.
Inability to monitor because of adverse weather conditions must be documented in the
SPPP and recorded on the DA4R Qualitative Monitoring Report form (see Adverse Weather in
Definitions). Only SDOs discharging stormwater associated with industrial activity must be
monitored.
In the event an atypical condition is noted at a stormwater discharge outfall, the permittee
shall document the suspected cause of the condition and.any actions taken in response to
the discovery. This documentation will be maintained'with the SPPP.
Table 4. Qualitative Monitoring Requir.e �ments/
Discharge Characteristics
Frequencyl
Monitoring
Location2
Color
quarterly
SDO
Odor vquarterly
SDO
ClarityJ� vquarterly
SDO
`��
Floating Solids \ �'- oquarterly
SDO
Suspended Solids �+quarterly_SDO
Foam
uarterly
SDO
Oil Sheen
quarterly
SDO
Erosion or deposition at the outfall
quarterly
I SDO
Other obvious indicators
of stormwater pollution
quarterly
SDO
Footnotes:
1 Measurement Frequency: Four times per year during a measureable storm event. See Table 2 for
schedule of monitoring periods through the end of this permitting cycle. The permittee must continue
qualitative monitoring throughout the permit renewal process until a new permit is issued. Qualitative
monitoring must be continued quarterly, and is not eligible for semi-annual monitoring frequency under
step-down provisions that apply to analytical monitoring.
2 Monitoring Location: Qualitative monitoring shall be performed at each stormwater discharge outfall
(SDO) regardless of representative outfall status.
A minimum of 30 days must separate monitoring dates, unless additional sampling has
been instituted as part of other analytical monitoring requirements in this permit.
Part 11 Page 11 of 12

0 0
Permit No. NCS000562
If the permittee's qualitative monitoring indicates that existing stormwater BMPs are
ineffective, or that significant stormwater contamination is present, the permittee shall
investigate potential causes, evaluate the feasibility of corrective actions, and implement
those corrective actions within 60 days of the qualitative monitoring event. A written
record of the permittee's investigation, evaluation, and response actions shall be kept in
the Stormwater Pollution Prevention Plan (SPPP).
I Qualitative Monitoring Response
Qualitative monitoring is for the purposes of evaluating the effectiveness of the permittee's
implementation of the SPPP, and new sources of stormwater pollution, and prompting the permittee's
response to pollution. If the permittee repeatedly fails to respond effectively to correct
problems indicated by qualitative monitoring, or if the discharge causes or contributes to a water
quality standard violation, DWQ the Division may, but is not limited to:
V�
• require that the permittee revise, increase, or,ecrease the monitoring frequency and
parameters (analytical or qualitative) for a specified time period;
• require the permittee to install structural stormwater controls;
• require the permittee to implement other stormwater control measures;
• require the permittee to perform upstream and downstream monitoring to characterize
impacts on receiving waters; or
• require the permittee implement site /modifications to qualify for a No Exposure Exclusion.
"V 1 ��/
Part 11 Page 12 of 12

0 0
Permit No. NCS004562
PART III STANDARD CONDITIONS FOR NPDES STORMWATER INDIVIDUAL PERMITS
SECTION A: COMPLIANCE AND LIABILITY
1. Compliance Schedule
The permittee shall comply with Limitations and Controls specified for stormwater discharges in
accordance with the following schedule:
Existing Facilities already operating but applying for permit coverage for the first time: The
Stormwater Pollution Prevention Plan shall be developed and implemented within 12 months of the
effective date of the initial permit and updated thereafter on an annual basis. Secondary
containment, as specified in Part II, Section A, Paragraph 2(b) of this permit, shall be accomplished
within 12 months of the effective date of the initial permit issuance.
New Facilities applying for coverage for the first time: `he Sit rmwater Pollution Prevention Plan
shall be developed and implemented prior to the beginning•of discharges from the operation of the
industrial activity and be updated thereafter on an annual basis., Secondary containment, as specified
in Part II, Section A, Paragraph 2(b) of this permit shall be accomplished prior to the beginning of
stormwater discharges from the operation of the industrial'activity.
Existing facilities previously permitted and applying for renewal.• All requirements, conditions,
limitations, and controls contained in this per mit'(exceptnew SPPP elements in this permit renewal)
shall become effective immediately upon'issuance oft ispermit. New elements of the Stormwater
Pollution Prevention Plan for this permit renewal§hall be developed and implemented within 6
months of the effective date/of this permit and -updated thereafter on an annual basis. Secondary
containment, as specified in Part II; Paragraph 2(b) of this permit shall be accomplished prior to the
beginning of stormwater discharges from�tfie operation of the industrial activity.
2. Duty to Comply / ( )Jv�
The permittee must complyith.all conditions of this permit. Any permit noncompliance constitutes
a violation of the Clean Water Act(CWA) and is grounds for enforcement action; for permit
termination, revocation and reissuance, or modification; or denial of a permit upon renewal
application [40 CFR 122.41].
a. The permittee shall comply with standards or prohibitions established under section 307(a) of
the CWA for toxic pollutants within the time provided in the regulations that establish these
standards or prohibitions, even if the permit has not yet been modified to incorporate the
requirement [40 CFR 122.41].
b. The CWA provides that any person who violates section [s] 301, 302, 306, 307, 308, 318 or 405 of
the Act, or any permit condition or limitation implementing any such sections in a permit issued
under section 402, or any requirement imposed in a pretreatment program approved under
sections 402(a)(3) or 402(b)(8) of the Act, is subject to a civil penalty not to exceed $37,500 per
day for each violation [33 USC 1319(d) and 40 CFR 122.41(a)(2)].
c. The CWA provides that any person who negligently violates sections 301, 302, 306, 307, 308,
318, or 405 of the Act, or any condition or limitation implementing any of such sections in a
permit issued under section 402 of the Act, or any requirement imposed in a pretreatment
program approved under section 402(a)(3) or 402(b)(8) of the Act, is subject to criminal
penalties of $2,500 to $25,000 per day of violation, or imprisonment of not more than 1 year, or
both. In the case of a second or subsequent conviction for a negligent violation, a person shall be
subject to criminal penalties of not more than $50,000 per day of violation, or by imprisonment
of not more than 2 years, or both [33 USC 1319(c)(1) and 40 CFR 122.41(a)(2)].
Part ill Page 1 of 9

0 0
Permit No. NCS000562
d. Any person who knowingly violates such sections, or such conditions or limitations is subject to
criminal penalties of $5,000 to $50,000 per day of violation, or imprisonment for not more than 3
years, or both. In the case of a second or subsequent conviction for a knowing violation, a person
shall be subject to criminal penalties of not more than $100,000 per day of violation, or
imprisonment of not more than 6 years, or both [33 USC 1319(c)(2) and 40 CFR 122.41(a)(2)].
e. Any person who knowingly violates section 301, 302, 303, 306, 307, 308, 318 or 405 of the Act,
or any permit condition or limitation implementing any of such sections in a permit issued under
section 402 of the Act, and who knows at that time that he thereby places another person in
imminent danger of death or serious bodily injury, shall, upon conviction, be subject to a fine of
not more than $250,000 or imprisonment of not more than 15 years, or both. In the case of a
second or subsequent conviction for a knowing endangerment violation, a person shall be
subject to a fine of not more than $S00,000 or by imprisonment of not more than 30 years, or
both. An organization, as defined in section 309(c)(3)(B)(iii),of the CWA, shall, upon conviction
of violating the imminent danger provision, be subject to aA,ne of not more than $1,000,000 and
can be fined up to $2,000,000 for second or subsequent convictions,[40 CFR 122.41(a)(2)].
/f �
f. Under state law, a civil penalty of not more thari $25 400 \violn may be assessed against
any person who violates or fails to act in accordance with the terms, conditions, or requirements
of a permit [North Carolina General Statutes § 143-215.6A].
g. Any person may be assessed an administrative penalty by the Administrator for violating section
301, 302, 306, 307, 308, 318 or 405 of this Act, or;any permit condition or limitation
implementing any of such sections in'a permit -issued under section 402 of this Act.
i. i r i
Administrative penalties for Class I violations are not to exceed $16,000 per violation, with the
maximum amount of any-Class.l penalty.assessed not to exceed $37,500. Penalties for Class I1
violations are not to exceed'
$16;000�per day for each day during which the violation continues,
with the maximum amount of an Class II penalty not to exceed $177,500 [33 USC 1319(g)(2)
and 40 CFR 122.41(a)(3)].
3. Duty to Mitigate ((//
The permittee shall take all reasonable steps to minimize or prevent any discharge in violation of this
permit which has a reasonable likelihood of adversely affecting human health or the environment [40
CFR 122.41(d)].
4. Civil and Criminal Liability
Except as provided in Part III, Section C of this permit regarding bypassing of stormwater control
facilities, nothing in this permit shall be construed to relieve the permittee from any responsibilities,
liabilities, or penalties for noncompliance pursuant to NCGS 143-215.3,143-215.6, or Section 309 of the
Federal Act, 33 USC 1319. Furthermore, the permittee is responsible for consequential damages,
such as fish kills, even though the responsibility for effective compliance may be temporarily
suspended.
Oil and Hazardous_Sub.�tance Liability
Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the
permittee from any responsibilities, liabilities, or penalties to which the permittee is or may be
subject to under NCGS 143-215.75 et seq. or Section 311 of the Federal Act, 33 USC 1321.
6. Property Rights
The issuance of this permit does not convey any property rights in either real or personal property,
or any exclusive privileges, nor does it authorize any injury to private property or any invasion of
personal rights, nor any infringement of federal, state or local laws or regulations [40 CFR 122.41(g)].
Part Ill Page 2 of 9

Permit No. NCS000562
&verability
The provisions of this permit are severable, and if any provision of this permit, or the application of
any provision of this permit to any circumstances, is held invalid, the application of such provision to
other circumstances, and the remainder of this permit, shall not be affected thereby [NCGS 15013-23].
Duty to Provide Information
The permittee shall furnish to the Permit Issuing Authority, within a reasonable time, any
information which the Permit Issuing Authority may request to determine whether cause exists for
modifying, revoking and reissuing, or terminating the permit issued pursuant to this permit or to
determine compliance with this permit. The permittee shall also furnish to the Permit Issuing
Authority upon request, copies of records required to be kept by this permit [40 CFR 122.41(h)].
9. Penalties for Tam,rine
The Clean Water Act provides that any person who falsifies, tampers with, or knowingly renders
inaccurate, any monitoring device or method required to be maintained under this permit shall, upon
conviction, be punished by a fine of not more than $10,000 per violation, or by imprisonment for not
more than two years per violation, or by both. If a conviction of a,person-is for a violation committed
after a first conviction of such person under this paragraph, punishment is a fine of not more than
$20,000 per day of violation, or by imprisonment dnot"more than 4 years, or both [40 CFR 122.41].
G
10. Penalties for Falsification of Reports �
The Clean Water Act provides that any person -who k\nowingly makes any false statement,
representation, or certification in any record�o/r other)document submitted or required to be
maintained under this permit, including monitoring reports or reports of compliance or
noncompliance shall, upon conviction; be punished;by a fine of not more than $10,000 per violation,
or by imprisonment for not.,more than two years -per violation, or by both [40 CFR 122.41].
11. Onshore or Offshore Constructio\
This permit does not authorize or approve the construction of any onshore or offshore physical
structures or facilities or the undertaking of any work in any navigable waters.
12. Duty to Reapply
If the permittee wishes to continue an activity regulated by this permit after the expiration date of
this permit, the permittee must apply for and obtain a new permit [40 CFR 122.41(b)].
SECTION B; GENERAL CONDITIONS
1. ,Pgrmit Expiration
The permittee is not authorized to discharge after the expiration date. In order to receive automatic
authorization to discharge beyond the expiration date, the permittee shall submit forms and fees as
are required by the agency authorized to issue permits no later than 100 days prior to the
expiration date, unless permission for a later date has been granted by the Director. (The Director
shall not grant permission for applications to be submitted later than the expiration date of the
existing permit) [40 CFR 122.21(d)]. Any permittee that has not requested renewal at least 180 days
prior to expiration, or any permittee that does not have a permit after the expiration and has not
requested renewal at least 180 days prior to expiration, will be subjected to enforcement procedures
as provided in NCGS §143-215.36 and 33 USC 1251 et. seq.
Part III Page 3 of 9

a �
Permit No. NCS000562
2. Transfers
This permit is not transferable to any person without prior written notice to and approval from the
Director in accordance with 40 CFR 122.61. The Director may condition approval in accordance with
NCGS 143-215.1, in particular NCGS 143-215.1(b)(4)b.2., and may require modification or revocation
and reissuance of the permit, or a minor modification, to identify the new permittee and incorporate
such other requirements as may be necessary under the CWA [40 CFR 122.41(1)(3), 122.61] or state
statute. The Permittee is required to notify the Division in writing in the event the permitted
facility is sold or closed.
3. Signatory Requirements
All applications, reports, or information submitted to the Permitting Issuing Authority shall be signed
and certified [40 CFR 122.41(k)].
a, All permit applications shall be signed as follows:
(1) For a corporation: by a responsible corporate officer. For the purpose of this Section, a
responsible corporate officer means: (a) a president, secretary, treasurer or vice president
of the corporation in charge of a principal business function, or,any other person who
performs similar policy or decision making functions for the corporation, or (b) the manager
of one or more manufacturing, production, or operating facilities, provided, the manager is
authorized to make management decisionswhich govern the operation of the regulated
facility including having the explicit or implicit duty of making major capital investment
recommendations, and initiating and directing other comprehensive measures to assure
long term environmental compliance with'environmental laws and regulations; the manager
can ensure that the necessary systems,are established or actions taken to gather complete
and accurate information for permit application requirements; and where authority to sign
documents has been assigned or.delegated to the manager in accordance with corporate
procedures. \\ (2) For a partnership or sol:!�Proprie hip: by a general partner or the proprietor,
respectively; or / >
(3) For a municipality, state, federal, or other public agency: by either a principal executive
officer or ranking elected, [40 CFR 122.221.
b. All reports required by the permit and other information requested by the Permit Issuing
Authority shall be signed by a person described in paragraph a. above or by a duly authorized
representative of that person. A person is a duly authorized representative only if:
(1) The authorization is made in writing by a person described above;
(2) The authorization specified either an individual or a position having responsibility for the
overall operation of the regulated facility or activity, such as the position of plant manager,
operator of a well or well field, superintendent, a position of equivalent responsibility, or an
individual or position having overall responsibility for environmental matters for the company.
(A duly authorized representative may thus be either a named individual or any individual
occupying a named position.); and
(3) The written authorization is submitted to the Permit Issuing Authority [40 CFR 122.22].
c. Changes to authorization: If an authorization under paragraph (b) of this section is no longer
accurate because a different individual or position has responsibility for the overall operation of
the facility, a new authorization satisfying the requirements of paragraph (b) of this section must
be submitted to the Director prior to or together with any reports, information, or applications to
be signed by an authorized representative [40 CFR 122.22].
Part ll l Page 4 of 9

Permit No. NCS000562
d. Certification. Any person signing a document under paragraphs a. or b. of this section, or
submitting an electronic report (e.g., eDMR), shall make the following certification [40 CFR
122.22]. NO OTHER STATEMENTS OF CERTIFICATION WILL BE ACCEPTED:
"1 certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properlygather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible forgathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate,
and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fines and imprisonment for knowing violations."
e. Electronic Reports. All electronic reports (e.g., eDMRs) submitted to the Permit Issuing
Authority shall be signed by a person described in paragraph a. above or by a duly authorized
representative of that person as described in paragraph b. A person, and not a position, must be
delegated signatory authority for eDMR or other electronic reporting purposes.
The Permit Issuing Authority may require the permittee 'begin reporting monitoring data
electronically during the term of this permit. The,permittee may be required to use North
Carolina's Electronic Discharge Monitoring Report (eDMR),internet application for that purpose.
For eDMR submissions, the person signing and `submitting the eDMR must obtain an eDMR user
account and login credentials to access the eDMR"system.
4. Permit Modification. Revocation and Reissuance. arje minat on
The issuance of this permit does not prohibjt the,Permit Issuing Authority from reopening and
modifying the permit, revoking and reissuing the permit, or terminating the permit as allowed by the
laws, rules, and regulations contained'in,Title�40,-Code of Federal Regulations, Parts 122 and 123;
Title 15A of the North Carolina Administrative Code, Subchapter 2H .0100; and North Carolina
General Statute 143-215.1 et al. \ g
S. Permit Action 1 `!
The permit may be modified, revoked and reissued, or terminated for cause. The notification of
planned changes or anticipated noncompliance does not stay any permit condition [40 CFR
122.41(f)].
6. Annual Administering and Compliance Monitoring Fee RR uirements
The permittee must pay the administering and compliance monitoring fee within 30 (thirty) days
after being billed by the Division. Failure to pay the fee in timely manner in accordance with 15A
NCAC 2H .0105(b)(2) may cause the Division to initiate action to revoke the permit.
SECTION C: OPERATION AND MAINTENANCE OF POLLUTION CONTROLS
1. Proper Operation and Maintenance
The permittee shall at all times properly operate and maintain all facilities and systems of treatment
and control (and related appurtenances) which are installed or used by the permittee to achieve
compliance with the conditions of this permit. Proper operation and maintenance also includes
adequate laboratory controls and appropriate quality assurance procedures. This provision requires
the operation of back-up or auxiliary facilities or similar systems which are installed by a permittee
only when the operation is necessary to achieve compliance with the conditions of this permit [40
CFR 122.41(e)].
2. Need to Halt or Reduce Not a Defense
It shall not be a defense for a permittee in an enforcement action that it would have been necessary
to halt or reduce the permitted activity in order to maintain compliance with the condition of this
permit [40 CFR 122.41(c)].
Part Il l Page 5 of 9

Permit No. NCS000562
3. Bypassing of Stormwater Control Facilities
Bypass is prohibited and the Director may take enforcement action against a permittee for bypass
unless:
a. Bypass was unavoidable to prevent loss of life, personal injury or severe property damage; and
b. There were no feasible alternatives to the bypass, such as the use of auxiliary control facilities,
retention of stormwater, or maintenance during normal periods of equipment downtime or dry
weather. This condition is not satisfied if adequate backup controls should have been installed in
the exercise of reasonable engineering judgment to prevent a bypass which occurred during
normal periods of equipment downtime or preventive maintenance; and
c. The permittee submitted notices as required under, Part III, Section E of this permit.
If the Director determines that it will meet the three conditions listed above, the Director may
approve an anticipated bypass after considering its adverse effects.
SECTION D: MONITORING AND RECORDS
ReprQsentatiu 5amplin
Samples collected and measurements taken, as req u�ir ed herein, shall be characteristic of the volume
and nature of the permitted discharge. Analytical -sampling shall be performed during a measureable
storm event. Samples shall be taken on a day�� nd-t and -is characteristic of the discharge. All
samples shall be taken before the discharge joins,or is diluted by any other waste stream, body of
water, or substance. Monitoring points as specified inthispermit shall not be changed without
notification to and approval of the Permit Issuing.uthority [40 CFR 122.41(j)].
Recording.Results
For each measurement or sample taken pursuant to the requirements of this permit, the permittee
shall record the following information [40 CFR 122.41]:
ru
a. The date, exact place, d ti e o'f sampling or measurements;
b. The individual(s) who performed the sampling or measurements;
c. The date(s) analyses 'were performed;
d. The individual(s) who performed the analyses;
e. The analytical techniques or methods used; and
f. The results of such analyses.
3. Flow Measurements
Where required, appropriate flow measurement devices and methods consistent with accepted
scientific practices shall be selected and used to ensure the accuracy and reliability of measurements
of the volume of monitored discharges.
4. Test Procedures
Test procedures for the analysis of pollutants shall conform to the EMC regulations published
pursuant to NCGS 143-215.63 et. seq, the Water and Air Quality Reporting Acts, and to regulations
published pursuant to Section 304(g), 33 USC 1314, of the Federal Water Pollution Control Act, as
Amended, and Regulation 40 CFR 136.
To meet the intent of the monitoring required by this permit, all test procedures must produce
minimum detection and reporting levels and all data generated must be reported down to the
minimum detection or lower reporting level of the procedure. If no approved methods are
determined capable of achieving minimum detection and reporting levels below permit discharge
requirements, then the most sensitive (method with the lowest possible detection and reporting
level) approved method must be used.
Part III Page 6 of 9

0 0
Permit No. NCS000562
5. Representative Outfall
If a facility has multiple discharge locations with substantially identical stormwater discharges that
are required to be sampled, the permittee may petition the Director for representative outfall status.
If it is established that the stormwater discharges are substantially identical and the permittee is
granted representative outfall status, then sampling requirements may be performed at a reduced
number of outfalls.
6. Records Retention
Visual monitoring shall be documented and records maintained at the facility along with the
Stormwater Pollution Prevention Plan. Copies of analytical monitoring results shall also be
maintained on -site. The permittee shall retain records of all monitoring information, including
o all calibration and maintenance records,
o all original strip chart recordings for continuous monitoring instrumentation,
o copies of all reports required by this permit, including Discharge Monitoring Reports (DMRs)
and eDMR or other electronic DMR report sub�missions,
o copies of all data used to complete the applic`at ion for this permit
These records or copies shall be maintained for a period of at least 5 years from the date of the
sample, measurement, report or application. This period �y be extended by request of the Director
at any time [40 CFR 122.41].
Inspection and Entry
The permittee shall allow the Director, or an authorized representative (including an authorized
contractor acting as a representative of the Director), or in the case of a facility which discharges
through a municipal separa�e-storm sewer system, an authorized representative of a municipal
operator or the separate storm -sewer. system i receiving the discharge, upon the presentation of
credentials and other documents as may,be required by law, to:
a. Enter upon the permrttee's premises where a regulated facility or activity is located or conducted,
or where records must be keptunder the conditions of this permit;
b. Have access to and copy, -at reasonable times, any records that must be kept under the conditions
of this permit;
c. Inspect at reasonable times any facilities, equipment (including monitoring and control
equipment), practices, or operations regulated or required under this permit; and
d. Sample or monitor at reasonable times, for the purposes of assuring permit compliance or as
otherwise authorized by the Clean Water Act, any substances or parameters at any location [40
CFR 122.41(i)],
SECTION E: REPORTING REQUIREMENTS
Discharge Monitoring
Samples analyzed in accordance with the terms of this permit shall be submitted to the Division on
Discharge Monitoring Report (DMR) forms provided by the Director or submitted electronically to
the appropriate authority using an approved electronic DMR reporting system (e.g., eDMR). DMR
forms are available on the Division's website (http: j/portal.ncdenr.org/web/Ir/npdes-stormwater).
Regardless of the submission method (paper or electronic), submittals shall be delivered to the
Division or appropriate authority no later than 30 days from the date the facility receives the
sampling results from the laboratory.
Part II I Page 7 of 9

0
0
Permit No. NCS000562
When no discharge has occurred from the facility during the report period, the permittee is required
to submit a discharge monitoring report, within 30 days of the end of the specified sampling period,
giving all required information and indicating "NO FLOW" as per NCAC T15A 02B .0506.
If the permittee monitors any pollutant more frequently than required by this permit using test
procedures approved under 40 CFR Part 136 and at a sampling location specified in this permit or
other appropriate instrument governing the discharge, the results of such monitoring shall be
included in the data submitted on the DMR.
The permittee shall record the required qualitative monitoring observations on the SDO Qualitative
Monitoring Report form provided by the Division and shall retain the completed forms on site.
Qualitative monitoring results should not be submitted to the Division, except upon the Division's
specific requirement to do so. Qualitative Monitoring Report forms are available at the website
above.
2. Submitting Reports
Two signed copies of Discharge Monitoring Reports (DMRs) shall be submitted to:
Central File's����
Division of Water Resources
1617 Mail Service Center >
Raleigh, North Carolina 276991617
The Permit Issuing Authority may require thp tee to begin reporting monitoring data
electronically during the term of this permit. fThe•permittee may be required to use North Carolina's
eDMR internet application for that purpose. Until such time that the state's eDMR application is
compliant with EPA's Cross-Med a•Electronic Reporting Regulation (CROMERR), permittees will be
required to submit all discharge1 to 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 address above.
3. Availability of Reports
Except for data determined to be confidential under NCGS 143-215.3(a)(2) or Section 308 of the
Federal Act, 33 USC 1318, all reports prepared in accordance with the terms of this permit shall be
available for public inspection at the offices of the Division. As required by the Act, analytical data
shall not be considered confidential. Knowingly making any false statement on any such report may
result in the imposition of criminal penalties as provided for in NCGS 143-215.613 or in Section 309 of
the Federal Act.
4. Non-Stormwater Discharges
If the storm event monitored in accordance with this permit coincides with a non-stormwater
discharge, the permittee shall separately monitor all parameters as required under all other
applicable discharge permits and provide this information with the stormwater discharge
monitoring report.
S. Planned Changes
The permittee shall give notice to the Director as soon as possible of any planned changes at the
permitted facility which could significantly alter the nature or quantity of pollutants discharged [40
CFR 122.41(1)]. This notification requirement includes pollutants which are not specifically listed in
the permit or subject to notification requirements under 40 CFR Part 122.42 (a).
6. Anticipated Noncompliance
The permittee shall give advance notice to the Director of any planned changes at the permitted
facility which may result in noncompliance with the permit [40 CFR 122.41(I)(2)].
Partill Page 8 of 9

LJ
0
Permit No. NCS000562
7. Gills
The permittee shall report to the local DEMLR Regional Office, within 24 hours, all significant spills
as defined in Part IV of this permit. Additionally, the permittee shall report spills including: any oil
spill of 25 gallons or more, any spill regardless of amount that causes a sheen on surface waters, any
oil spill regardless of amount occurring within 100 feet of surface waters, and any oil spill less than
25 gal,lons that cannot be cleaned up within 24 hours.
8. Bypass
Notice [40 CFR 122.41(m)(3)]:
a. Anticipated bypass. If the permittee knows in advance of the need for a bypass, it shall submit
prior notice, if possible at least ten days before the date of the bypass; including an evaluation of
the anticipated quality and effect of the bypass.
b. Unanticipated bypass. The permittee shall submit notice within 24 hours of becoming aware of
an unanticipated bypass.
9. Twenty-four Hour Reporting
a. The permittee shall report to the central office orjh �approp\ is regional office any
noncompliance which may endanger health or the environment. Any information shall be
provided orally within 24 hours from the time the permittee became aware of the circumstances.
A written submission shall also be provided within 5•days-of the time the permittee becomes
aware of the circumstances.
The written submission shall contain adescription pp tion of the noncompliance, and its causes, the
period of noncompliance, including exact -dates and times, and if the noncompliance has not
been corrected, the anticipated time {compliance is expected to continue; and steps taken or
planned to reduce, eliminate, and prevent reoccurrence of the noncompliance [40 CFR
122.41(I)(6)]. � w
b. The Director may waive the written report on a case -by -case basis for reports under this section
if the oral report has Len receifved within 24 hours.
c. Occurrences outside normal business hours may also be reported to the Division's Emergency
Response personnel at [phone], [phone] or [phone].
10. Other Noncompliance
The permittee shall report all instances of noncompliance not reported under 24 hour reporting at
the time monitoring reports are submitted [40 CFR 122.41(1)(7)].
11, Other Information
Where the Permittee becomes aware that it failed to submit any relevant facts in a permit
application, or submitted incorrect information in a permit application or in any report to the
Director, it shall promptly submit such facts or information [40 CFR 122.41(1)(8)].
Partill Page 9 of 9

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

• 0
Permit No. NCS000562
10. Director
The Director of the Division of"'� Energy, Mineral, and Land Resources, the permit issuing
authority.
11. EMC
The North Carolina Environmental Management Commission.
12. Grab Sample
An individual sample collected instantaneously. Grab samples that will be analyzed (quantitatively
or qualitatively) must be taken within the first 30 minutes of discharge.
13. Hazardous Substance
Any substance designated under 40 CFR Part 116 pursuant to Section 311 of the Clean Water Act.
14. Landfill
A disposal facility or part of a disposal facility where waste` pla ed in or on land and which is not a
land treatment facility, a surface impoundment, an injection well; a hazardous waste long-term
storage facility or a surface storage facility.
15. Measureable Storm Event
A storm event that results in an actual discharge from thi permitted site outfall. The previous
measurable storm event must have been at leas 72 hours prior. The 72-hour storm interval may not
apply if the permittee is able to document that a shorter interval is representative for local storm
events during the sampling period, and obtains approval from the local DEMLR Regional Office. Two
copies of this information and a written request -letter shall be sent to the local DEMLR Regional
Office. After authorization by the DEMLR Regional Office, a written approval letter must be kept on
site in the permittee's SPPP.� \
16. Municipal Separate Storm SewerSstem>(M541
A stormwater collection system within/an incorporated area of local self-government such as a city or
town. l �%
17. No Exposure
A condition of no exposure means that all industrial materials and activities are protected by a storm
resistant shelter or acceptable storage containers to prevent exposure to rain, snow, snowmelt, or
runoff. Industrial materials or activities include, but are not limited to, material handling equipment
or activities, industrial machinery, raw materials, intermediate products, by-products, final products,
or waste products [40 CFR 122.26 (b)(14)]. DEMLR may grant a No Exposure Exclusion from NPDES
Stormwater Permitting requirements only if a facility complies with the terms and conditions
described in 40 CFR §122.26(g).
18. Notice of Intent
The state application form which, when submitted to the Division, officially indicates the facility's
notice of intent to seek coverage under a General Permit.
19. Permit Issuing -Authority
The Director of the Division ofWaterQuality Energy, Mineral, and Land Resources (see "Director"
above).
20. Permittee
The owner or operator issued this permit
Part IV Page 2 of 4 Pages

Permit No. NCS000562
21. Point Source Discharge of Stormwater
Any discernible, confined and discrete conveyance including, but not specifically limited to, any pipe,
ditch, channel, tunnel, conduit, well, or discrete fissure from which stormwater is or may be
discharged to waters of the state.
22. Representative Outfall Status
When it is established that the discharge of stormwater runoff from a single outfall is representative of the
discharges at multiple outfalls, the Division may grant representative outfall status. Representative outfall
status allows the permittee to perform analytical monitoring at a reduced number of outfalls.
23. Secondary Containment
Spill containment for the contents of the single largest tank within the containment structure plus
sufficient freeboard to contain the 25-year, 24-hour storm event.
24, Section 313 Water Priority Chemical
A chemical or chemical category which: ^ z
b. Is listed in 40 CFR 372.65 pursuant to Section 31,3 of Title III,of the Superfund Amendments and
Reauthorization Act (SARA) of 1986, also titledtheEmergency Planning and Community Right -
to -Know Act of 1986;
c. Is present at or above threshold levels at a facility subject to SARA title III, Section 313 reporting
requirements, and \
d. Meets at least one of the following criteria:/��/
i
i. Is listed in appendix D of 40 CFR part 122 on Table I[ (organic priority pollutants), Table
III (certain metals, cyanides, a/nd phenols).1or Table IV (certain toxic pollutants and
hazardous substances); ((//
ii. Is listed as a hazardous substance pursuant to section 311(b)(2)(A) of the CWA at 40 CFR
116.4;or\\�,ublished
iii. Is a pollutant fohich�J">
EPA acute or chronic water quality criteria.
25. Severe Property Dama e
Substantial physical damage to property, damage to the control facilities which causes them to
become inoperable, or substantial and permanent loss of natural resources which can reasonably be
expected to occur in the absence of a bypass. Severe property damage does not mean economic loss
caused by delays in production.
26. Significant Materials
Includes, but is not limited to: raw materials, fuels; materials such as solvents, detergents, and plastic
pellets; finished materials such as metallic products; raw materials used in food processing or
production; hazardous substances designated under section 101(14) of CERCLA; any chemical the
facility is required to report pursuant to section 313 of Title III of SARA; fertilizers, pesticides; and
waste products such as ashes, slag and sludge that have the potential to be released with stormwater
discharges.
27. Significant Spills
Includes, but is not limited to: releases of oil or hazardous substances in excess of reportable
quantities under section 311 of the Clean Water Act (Ref: 40 CFR 110.3and 40 CFR 117.3) or section
102 of CERCLA (Ref: 40 CFR 302.4).
28. Stormwater Discharge Outfall (SDO)
The point of departure of stormwater from a discernible, confined, or discrete conveyance, including
but not limited to, storm sewer pipes, drainage ditches, channels, spillways, or channelized collection
areas, from which stormwater flows directly or indirectly into waters of the State of North Carolina.
Part IV Page 3 of 4 Pages

0 0
Permit No. NCS000562
29. Stormwater Runoff
The flow of water which results from precipitation and which occurs immediately following rainfall
or as a result of snowmelt.
30. Stormwater Associated with Industrial Activity.
The discharge from any point source which is used for collecting and conveying stormwater and
which is directly related to manufacturing, processing or raw material storage areas at an industrial
site. Facilities considered to be engaged in "industrial activities" include those activities defined in
40 CFR 122.26(b)(14). The term does not include discharges from facilities or activities excluded
from the NPDES program.
31. Stormwater Pollution Prevention Plan
A comprehensive site -specific plan which details measures and practices to reduce stormwater
pollution and is based on an evaluation of the pollution potentiall000f the site.
32. Total Maximum Daily Load (TMDL)
TMDLs are written plans for attaining and maintaininwater quality standards, in all seasons, for a
specific water body and pollutant. A list of approved TMDLs forthe'state of North Carolina can be
found at http: //portportalmcdenr.org/web/wgIps/mtu/tmdl.
33. Toxic Pollutant J
Any pollutant listed as toxic under Section 07Ca) (1) of the,Clean Water Act.
34. Vehicle Maintenance Activity
Vehicle rehabilitation, mechanical repairs, painting, fueling, lubrication, vehicle cleaning operations,
or airport deicing operations t
35, Visible Sedimentation ��
Solid particulate matter, both mineral and organic, that has been or is being transported by water,
air, gravity, or ice from its,site of origin which can be seen with the unaided eye.
36. 25- ear 24 hour Storm (I v t
The maximum 24-hour precipitation event expected to be equaled or exceeded, on the average, once
in 25 years.
Part 1V Page 4 of 4 Pages

From: Forrest Westall[maiito:[e-mail]]
Sent: Thursday, December 08, 20117:47 AM
To: 'Pickle, Ken'
Cc: 'Bennett, Bradley'; 'Chernikov, Serge€'; 'Karoly, Cyndi; 'Matthews, Matt; 'Wakild, Chuck'; 'Basilone
Tim'; 'Cooper Darin'; '[e-mail]';'[e-mail]'
Subject: RE: Horsehead Meeting November 29, 2011
Hello Ken,
Thanks for the follow-up and the confirmation on the substation and the distinction about stormwater
originating within the production area. We will be sure to address your comments about the access and
perimeter roads In the final site layout and design.
We appreciate the time you provided last Tuesday to meet with Darin, Tim and me so we could review the
site stormwater considerations for this new facility in Rutherford County. As we noted, the NPDES
process waste water permit has been issued and construction of the facility has commenced. The
meeting last week served as a follow-up to our preliminary discussions in May when Horsehead
Corporation was completing the site selection process. We left the May meeting with a general
agreement with DWQ on a conceptual approach for managing stormwater. At that time we also
committed to return to DWQ with a more specific site plan once production layout was completed: At
yesterday's meeting we provided detall as to the site layout and our approach for development of an
NPDES stormwater permit application for the facility.
Your Input has been and continues to be very helpful In guiding our development of a permit application.
In follow-up to our recent discussion and In addition to the comments you have already made in your
follow-up, I am providing this summary to highlight important observations and conclusions that were
reached. We will now proceed with development of an application package with the clear direction you
provided, confident that the information submitted will be consistent with our understanding. We believe
that this will lead to a quick'review.
During the meeting a copy of the production layout design plan was provided for your use. The plan
provided highlighted areas and facility activities. In addition we described our approach for managing
stormwater from Individual and collective areas of the facility. We appreciate your comments and
agreement with our overall approach for managing stormwater at the facility. We plan to develop a draft
of the application for your review, and then finalize the application based on your comments for submittal
to the Department.
Key points we agreed to during our discussion are as follows:
■ You advised that all stormwater from within production areas (the area referred to in this
correspondence as the "developed site"), would need to be included under the NPDES
stormwater permit and monitored accordingly
■ We agreed that stormwater will be managed under an established management plan to meet the
requirements of the permit. The management plan will Include provisions for managing
stormwater from production areas, including capability for accumulating and using this water for
production processes or discharging it based on results of sample analyses. Stormwater
managed In these areas was referred to during our discussions as being "discretionary water" for
process use or discharge.
■ Stormwater will be routed to one point of discharge, which will be the sole discharge monitoring
point in the NPDES stormwater permit. Discharge baselines for various parameters will be
established for performance monitoring
■ After discussing the general plan for managing storm water at the site, you advised that the
following Information should be Included with the NPDES stormwater permit application:

A site plan showing the production layout, stormwater collection and containment areas,
and stormwater channels leading to the discharge point
A map delineating the area(s) of stormwater generation regulated under the NPDES
permit
A site stormwater management plan describing details as to how storm water on the site
will be managed, including process and non -process areas. Provisions described in the
plan will be Included In a stormwater PPP developed following finallzation of the permit
and before commencement of facility operations
As we discussed, permit acquisition Is still on the critical path for finalizing construction and commencing
operations in a timely manner. The Department's cooperation, timely review and action on the NPDES
permit for process discharge water was a very important factor in Horsehead's selection of this site.
Similarly, we appreciate your commitment to work with us In providing a timely review of our application,
and Issuing a NPDES stormwater permit for the facility without delay.
We plan to provide a draft of our permit application to you for comment. Based on comments from your
review, the permit application will be revised and finalized for submittal to the Department for review. We
believe this approach will result in a complete and accurate pemllt application, and that following
submittal will enable the Department to analyze the application and Issue a permit promptly.
Thanks again. Please let me know If you have any questions.
Forrest
Forrest R. Westall, Sr., PE
McGill Associates, P.A.
PO Box 2259
Asheville, NC 28802
Physical Location: 38 Orange Street, Asheville
Phone [phone]
Fax [phone]
forrest.westall cgillengineers.com
From: Pickle, Ken [malito:[e-mail]]
Sent: Wednesday, November 30, 2011 9:53 AM
To: [e-mail]
Cc: Bennett, Bradley; Chernikov, Sergel
Subject: Horsehead meeting yesterday
H€ Forrest,
Good meeting yesterday from my perspective, I hope you and your client feel the same. Thanks for
taking the trouble to go over the physical facts with me.
A few things occurred to me that were not addressed, or not completely addressed, yesterday:
• As presented yesterday, Horsehead will have a lab on site, and they will be doing their own analyticals
for the NPDES stormwater permit. Please note: for the permit reporting their lab must use the EPA
Methods. I assume that for Internal process QA/QC Horsehead might intend to use analytical methods
other than EPA Methods. That's OK for their Internal process QA/QC, but it doesn't satisfy the NPDES

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

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

Permit NC00891.09
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked. As of this permit issuance, any previously issued permit bearing this number is no longer
effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the
permit conditions, requirements, terms, and provisions included herein.
Horsehead Corporation is hereby authorized to:
1. After constructing the wastewater treatment facility, operate it in accordance
with the existing wastewater treatment system consisting of the following
components:
➢ Automatic sampler
A Instrumented flow measurement, and
Diffuser
The facility is located near Forest City, Rutherford County; and
2. Discharge from said treatment works at the location specified on the attached
map into the Broad River which is classified C waters in the Broad River Basin.

Pernnit NCO089109
A (1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee
is authorized to discharge from outfall(s) serial number 001. Such discharges shall be limited and
monitored by the Pem-dttee as specified below:
CHA1WM- RISTICS-__
= ; =::;.......
-...."............ ......... ...
_,...":..:..._ .:...:....:.:....... . .:
= ....... _LIlVIITS = = '::::: ' ::-:
._-_-.-- -- '''.;
' .:_ MONITORING RE UREMENTS
:Monthl :'-:
;::: 'Dail
'.Maximum`I
Measurement.
:.-_S�Fn--1e:
a:;:::::.::
r., . _..,
.. Y.ocation 1
Flow (MGD)
0.62
Continuous
Recording
I or E
Total Suspended Solids
Monthly
Composite
E
.NH3-N
Quarterly
Composite
E
Total Aluminum
Quarterly
Composite
E
Antimony
Quarterly
Composite
E
Arsenic
Quarterly
Composite
E
Total Cadmium
350 ug/L
2,143 ug/L
Monthly
Composite
E
Chlorides
Quarterly
Composite
E
Total Chromium
Quarterly
Composite
E
Total Cobalt
Quarterly
Composite
E
Total Copper
Quarterly
Composite
E
Fluoride
315.8 mg/L
315.8 mg/L
Monthly
Composite
E
Total Iron
Quarterly
Composite
E
Total Lead
4,386 ug/L
4,829 ug/L
Monthly
Composite
E
Total Nickel
Monthly
Composite
E
Total Tin
Quarterly
Composite.
E
Total Zinc
Quarterly
Composite
E
pH2
Weekly
Grab
E
Chronic Toxicity3
Quarterly
Composite
E
Turbidity4
Monthly
Grab I
E, U, D
NOTES:
1. Sample Locations: I -- Influent, E - Effluent, U - upstream (50 ft. upstream of the
discharge), D -- downstream (50 ft. downstream of the discharge).
2. The pH shall not be less than 6.0 standard units or greater than 9.0 standard units.
3. Chronic Toxicity (Ceriodaphnia) P/F ® 0.57%; Jan., April, July and October; See
condition A(2) of the Supplement to Effluent Limitations and Monitoring Section of this
permit.
4 The discharge from this facility shall not cause turbidity in the receiving stream to
exceed: 50 NTU. If the instream turbidity exceeds 50 NTU due to natural background
conditions, the discharge cannot cause turbidity to increase in the receiving stream.
THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR FOAM VISIBLE IN OTHER THAN
TRACE AMOUNTS.

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

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

0
Pickie, Ken
From: Pickle, Ken
Sent: Thursday, March 29, 2012 2:19 PM
To:'[e-mail]'
Cc: 'forrest.,u estal!@rnca:l!eng!neers.corn'
oubject: Horsehead application
Bill,
Per your request.
Ken Pickle
Environmentai Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. pickle*ncdenr.gov
Website: http:LJ0ortal.ncdenr.org/webLq/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may
disclosed to third parties unless the content is exempt by statute or other regul,,ations.*,*_
From: Pickle, Ken
Sent: Thursday, March 29, 2012 12:55 PM
To:'[e-mail]'
Cc: Bennett, Bradley; Chernikov, Sergei
Subject: RE: Horsehead application
Hi Forrest,
The Horsehead package was stamped in yesterday.
application fee.
The fee is $860, payable to NCDENR.
be
_ r
JUL - 5 2412 th-
11' 7rlJ� E r G T SEC i0A
Upon first review this afternoon, I note that there is no permit",
We are aware of our promise to you and to Horsehead to expedite processing of the application. But, we cannot even
enter the application into the tracking system and assign an application number, or otherwise process the application
without the fee. Under most circumstances we send such submittals back to the applicant with a form letter noting the
missing fee.
Please send the check to me ASAP. Overnight would be best if you can manage that. I note that there was some
confusion in delivery address for the package (initially directed to Mike Randall, I believe).
Use this street address forme:
NC Division of Water Quality
Archdale Building
512 North Salisbury Street

Please print or type in the unshaded areas only. Form Approved, OMB No, 2040-0088,
FORM U.S. ENVIRONMENTAL PROTECTION AGENCY 1. EPA I.D. NUMBER
\=.EPA GENERAL INFORMATION =�
Consolidated Permits Program 9 p
GENERAL (Read Me "General instructions"before staning.)
1 12 %31 14 1 ,S
LABEL ITEMS
GENERALINSTRUCTiONS
If a preprinted label has been provided, affix it in the
_
designated space. Review the information carehrlty; if any of it
I. EPA LD_ NUMBER
is incorrect, cross through it and enter the convet data in the
•
appropriate 11114n area below. Also, if any of the preprinted data
•
is absent (the area to the left of the label space fists the
111. FACILITY NAME
PLEASE PLACE LABEL IN THIS SPACE
information that should appear), please provide it in the proper
_ '.'' "
filHn area(s) below. If the label is complete and correct, you
V. FACILITY MAJUNG
need not complete Items I, 111. V, and VI (except VI-B which
ADDRESS
must be completed regard19 }. Complete all items if no label
has been pro ided. Refer to the instuctions for detailed item
Vt.. FACILITY LOCATION
descriptions and for the legal authorizations under which this
data Is collected.
IL POLLUTANT CHARACTERISTICS
INSTRUCTIONS: Complete A through J to determine whether you need to submit any permit application forms to the EPA. If you answer yes' to any questions, you must
submit this forth and the supplemental form listed in the parenthesis following the question. Mark W in the box in the third column if the supplemental forth is attached. If
you answer 'no' to each question, you need not submit any of these forms. You may answer 'no"if your activity
is excluded from permit requirements; see Section C of the
instructions. See also, Section D of the instructions for definitions of bold-faced terms.
Merk'X'
Mark'r
rEs
NO
ATfACCHHED
rFs
r+o
ArrFORM
arAG m
SPECIFIC QUESTIONS
SPECIFIC QUESTIONS
A. Is this facility a publicly owned treatment works which
results in a discharge to waters of the U.S.? (FORM 2A)
X
B. Does or will this facility (either existing or proposed)
include a concentrated animal feeding operation or
X
aquatic animal production facility which results in a
+e
v
+a
discharge to waters of the U.S.? (FORM 2B)
C. Is this a facility which currently results in discharges to
�/
X
D. Is this a proposed facility, (other than those described in A
X
X
waters of the U.S. other than those described in A or B
or B above) which will result in a discharge to waters of
above? (FORM 2C)
a
n
71
the U.S.? (R-- X)d Form 2F
n
m
=r
E. Does or will this facility treat, store, or dispose of
F. Do you or will you inject at this facility industrial or
hazardous wastes? (FORM 3)
X
municipal effluent below the lowermost stratum
X
containing, within one quarter mile of the well bore,
underground sources of drinking water? (FORM 4)
31
,r
M
G. Do you or will you inject at this facility any produced water
H. Do you or will you inject at this facility fluids for special
or other fluids which are brought to the surface in
connection with conventional oil or natural gas production,
X
processes such as mining of sulfur by the Frasch process,
solution mining of minerals, in situ combustion of fossil
X
inject fluids used for enhanced recovery of oil or natural
fuel, or recovery of geothermal energy? (FORM 4)
gas, or inject fluids for storage of liquid hydrocarbons?
(FORM 4)
75
M
37
38
n
I. Is this facility a proposed stationary source which is one
J. Is this facility a proposed stationary source which is
of the 28 industrial categories listed in the instructions and
X
NOT one of the 28 industrial categories listed in the
�/
X
which will potentially emit 100 tons'per year of any air
instructions and which will potentially emit 250 tons per
pollutant regulated under the Clean Air Act and may affect
year of any air pollutant regulated under the Clean Air Act
40
41
42
43
N
a
or be located in an attainment area? (FORM 5)
and may affect or be located in an attainment area?
(FORM 5)
111. NAME OF FACILITY
SKEP �RuItUrLr'dlcolunitly Pro uction Facility
EPA Form 3510-1 (8-90) CONTINUE ON REVERSE

CONTINUED FROM THE FRONT
VII, S1C CODES 1t In orderof " t:
A. FIRST
B. SECOND
r2edfil
APt 01
7 3341
7
ug I eecoedary sxel " and Ratining of Iknferrcus estais
C. THIRD
D. FOURTH
(rPerhl
(SPrrUll
VIIL OPERATOR INFORMATION
A. NAME lit is the name fisted In Item
I-Aatsothaawn*4
e Horse ea COlporatian fB YES O NO
u ,+ u
C.STATUS OFOPERATOR Wdrr(heap ate&ltertarotheau-erbox:r "Other," tc :
EF
= FEDERAL M a PUBLIC (aae,,1Wnfrdsrat orsrare)
NDD.p}I
(sPah)S=PRATE
P [phone]
a=OTHER(specO/
P ++ PRIVATE4
-lots :1a ae
E. STREET OR P.O. BOX
4 5 teubenvi le i e, Sui e 4
F. CITY OR TOWN
I G. STATE LL H. ZIP CODE lIX INDIAN LAND
r7ylocated ianlands7
13
Pittsbuxgh
P}1 11205 p YES ONO
>s
,
X. EXISTING ENVIRONMENTAL PERMITS
A- NPDES PjtF 14 STurface Mated
D. pSO Fd&=rxjI
s N NCO089109
g p
nita
Il UlC undr dewed le rNdo) Ffrddr
E. OTHER 1 rr )
01ril I I
t1 U
G-r—TI
g
F (r "o)
N -10000 YJ/ypoCa LCorsaeter Conatructfan
hativit:iaa
is I to I if n
C. RCRA Hazrirsfens 11r rrs
E. OTHER di
c r
-ei r
r
Cj ereaton and Sediacatatfen Control
9 R
g
?l
RUTHE-2012-002 and 013 ?lane - Phase 1 (WnW-3013-002) and
ehssa 3 rRvra6.2012-011)
u u n
u- u
yI y I
u fit - m
Attach to this appllcallon a topographic map of the area extending to at least one mle"beyand property boundartos. The map must show the oulltne of the faclity, the
locaton of mach of Its a)dsing and proposed Intake and discharge slri auras, each of its hazardous waste treatment storage, or. disposal facllties, and each well where Et
lnjocts Olds underground, include all springs, rivers, and other surface vretet bodies In the map area. Sam InstruAons Tor precise requiremants,
This newly constructed facility upon startup in the future will apply a proprietary hydrometallurgiaal process
(solvent extraction / electro winning) for producing high grade zinc metal from two primary feed materials
including waelz oxide (a.k.a. Crude zinc oxide) and zinc metal drosses and skims recovered from galvanizing
3perations. The production process includes use of feed materials in etn aqueous end hydrocarbon based solvent
extraction process to produce a zinc rich electrolyte solution for use in a cell house where an electro winning
process is applied to produce metalio zinc. Similar technolcgy is commonly used to produce metalic copper from
Wined copper ore feed material in the western United States.
XUL CERTIFICATION (sea k,staxiionsj
I certifyunder penalty of (siv that 1 hava personelly axamtnad and am f"iar with the tnfaimadon subrrlff edin this oppficatron and ad altachments and (hat, based an my
Enquiryof those persons tmmmdfately responstbfe for obtalaliv (he Inkrmadoa coNahted to the appacs0*4 f baiavo Thal tha Information to true; accurafe, and conlptats. t
am mvata that there are slgntiican!penalties rorsubM WrQ false lnformaft ftwks nQ the posiWit r offine end laWso=eat
A. NAME S OFFICIAL TITLE (fpe orprinij B. SIGNATUR C. DATE SIGNED
Timothy R. Basilonee Vice -President - /J
Environmental AffairS
COMMENTS FOR OFFICIAL USE ONLY
EPA Form 3510-1 (8-10)

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

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Please print or type in the unshaded areas
EPA ID Number (copy from Item 1 of Form 1) I Form Approved. OMB No. 2040-0086
Approval expires 5-31-92
U.S. Environmental Protection Agency
FORM 0#1 E PA Washington, DC 20460
ZFApplication for Permit to Discharge Storm Water
NPDES Discharges Associated with Industrial Activity
Paperwork Reduction Act Notice
Public reporting burden for this application is estimated to average 28.6 hours per application, including time for reviewing instructions, searching existing data sources,
gathering and maintaining the data needed, and completing and reviewing the oolection of information. Send comments regarding the burden estimate, any other aspect
of this Collection of information, or suggestions for improving this form, including suggestions which may increase or reduce this burden to: Chief, Information Policy
Branch, PM-223, U.S. Environmental Protection Agency, 1200 Pennsylvania Avenue, NW, Washington, DC 20460, or Director, Office of Information and Regulatory
Affairs, Office of Management and Budget, Washington, DC 20503.
IL Outfall Location
For each outfan, list the latitude and longitude of its location to the nearest 15 seconds and the name of the receiving water.
A. Outfall Number
(kso
B. Latitude
C. Longitude
D. Receiving Water
(name)
1
N35
12
00
W61
51
06
Broad River
ll. fmprovements
A. Are you now required by any Federal, State, or local authority to meet any implementation schedule for the construction, upgrading or operation of wastewater
treatment equipment or practices or any other environmental programs which may affect the discharges described in this application? This includes, but is not limited
to, permit conditions, administrative or enforcement orders, enforcement compliance schedule letters, stipulations, court orders, and grant or loan conditions.
1. Identification of Conditions,
Agreements, Etc
2. Affected Outfalls
3. Brief Description of Project
4. Final
Compliance Date
number
source of discharge
a, req.
b. proj.
N/A - New Facility
N/A -New
N/A -New Facility
N/A - New Facility
Facility
B: You may attach additional sheets describing any additional water pollution (or other environmental projects which may affect your discharges) you now have under
way or which you plan. Indicate whether each program is now under way or planned, and indicate your actual or planned schedules for construction.
III. Site Drainage Mao
Attach a site map showing topography (or indicating the outline of drainage areas served by the outfalls(s) covered in the application if a topographic map is unavailable)
depicting the facility including: each of its intake and discharge structures; the drainage area of each storm water outfall; paved areas and buildings within the drainage
area of each storm water outfall, each known past or present areas used for outdoor storage of disposal of significant materials, each existing structural control measure
to reduce pollutants in storm water runoff, materials loading and access areas, areas where pesticides, herbicides, soil conditioners and fertilizers are applied; each of
its hazardous waste treatment, storage or disposal units (including each area not required to have a RCRA permit which is used for accumulating hazardous waste
under 40 CFR 262.34); each well where fluids from the facility are injected underground; springs, and other surface water bodies which received storm water discharges
from the facility.
EPA Foim 3510-2F (1-92) Page 1 of 3 Continue on Page 2

Continued from the Front
IV- Narrative Description of Pollutant Sources
A. For aech ouffas, pm*o an ristirnato of the area (rnduda uets) of tmpadous surfaces Or#*Kerg pared areas and t ualln roots) dratnad to the outfas, and an esdmets or the foist surfaces arm
drained by the outfi&
Oudatt Are a ofrmpervtout6udace TotatAraaWaned Ou7a!<
Area ofmpervbus6urace
Told NeesOraLmed
Rurber (proHde mmdsJ (Pruri?a amity krnuxr
�ro+ua enPrJ
fF+ovido W4
1 acres acre.
S. Provide a narrallva descripllon of significant materials that are currently or In the past three years have been treated, stored or disposed In a manner to allow exposuro
to storm water, method of treatment, storage, or disposal. peal and present materials management practices employed to minimize contact by these materials with
storm water runoff; materials loading and access areas, and the location, manner, and frequency to which pesticides, harblddes, Boll condlooners, and fertilizers are
applied.
This is a new facility under construction, A variety of liquid and aolidmaterials will be used in the production porcesa.
Process materiala will be managed in tanks or containers, and will be transported via pipes throughout the operation. traterial
exposed to atorrywater will be minimized, and when necessary will he.managed to avoid potential impact to stormwater discharged
from the facility. A SPCC plan and Srrppp will be developed and implemented, and employees iwll be trained to properly manage
materials p'rloi to startup of the facility; visual inspections and housekeeping requirements will be defined in the S11PPP end
SPC plans.
Feed materials include Waelz oxide (crude zinc oxide) and zinc metal drosses and skims recovered from galvanizing operations.
(see attached sheet for addition information)
C, For each oulfati, provide the location and a dascripilan of exisUng structural and nonstructural control measures to reduce pollutants In storm vrater runoff; and a
description of the treatment the storm water receives, including the sthedule end type of maintenance for control and treatment measures and the ultimate disposal
of any solid or ttuld wastes other than by discharge.
OuUall
List Codes from
Number
Treatment
Table 2F•1
1
11 product cn areas within E e foe 1 ty Will Include secondary containment and otorrra+ater
-
collection baeina, All atozm water captured in the containment basins will be analyzed prior to
release to the Ctormxater system, use in the production process, or treated and discharged, This
scheme for managing storcedater In the production area of the facility and other areas of the
property will minimize the potential for polutants to enter atormwater that to discharged from the
site.
V. Nonstormwater Discharges
A. I certify under penalty or law hat the outfall(s) covered by this application have been tested or evalusled for the presence of nonstoanwater discharges, and that all
nonstonnwater discharged from these outraRs) are idenUtied In either an accompanying Form 2C or From 2E application for the outtall.
Name and Official Title (fype orpdnf) jSignaLufa ` Date Signed
Timothy A. nlasilone, Vice- President
8. ProvI a a descrfpUon of the method used, the date of an lesting. and the onsile drainage points thatware directly observed during a fast.
Thin is a new facility that ie currently under construction. The facility will be designed andconstructedin a manner to
rainimiza the potential for entry of process materials in stormxrater that is discharged.
Vi. Significant leaks or Spills
Provide existing Information regarding the history of algrXirant leaks or spills of twic or hazardous polutants at lh. facility In the Iasi three years, fnctuding the
Approximate data and location of the spill or teak, end the type and amount of rnaterial released,
N/A -drew Facility
EPA Form 3W1 2F (1.92) Pace 2 of 3 Continue on Page 3

Continued from Page 2 f PA ID Number (copyfromItem i of Form f)
rll, DEsebarge Information
h B, C, S D: See Instructions before proceeding, Complete one set of tables for each outfall. Annotate the mdal number In the space provided,
Table VII-A Vtl-B, VII-C are Included on separefe sheets numbers %AI-1 and Vli-2.
E. Potential discharges nol covered by analysis — Is any kWc pollutant Usted In table 2F-2, 2F-3, or 2F4, a substance or a component of a substance %-which you
currently use or manufacture is an tnterinedlate arfi all product or byproduct?
© Yes (931 a9 such pollcrlanls 1501004 ❑ No (go to Section IX)
Sca attached background information describing feedstock materials, process chemicals/reagents, and pollutants that will be
monitored in the preset was effluent, materials utilised and produced at the facility will be managed by personnel that
ace trained in procedures developed to minimize the potential for release of materials to the environment. materials will be
managed to prevent the potential for entry in stormVater that is discharged from the facility.
III. tiiofolgical Toxicity Testing Data
Do you have any knowledge or reason to believe that any blologkal last for acute or chronic Welty has been made on any of your disc haryes oron a receiving ivater In
relation to your discharge Mthln the lest 3 years?
❑ Yes (Rd at such poWlenls boforr) 0 No (go 6 Saedon tX)
N/A Hew Facility
IX. Contract Analysis Information
Were any of the analyses repotted In item Vil performed by a contract laboratory or consulting f+m%?
Yes (psi the name, address, and telephone number or, and pollutants ❑ No (go to Soctlon X)
analyzed by, each such laborstowy orfirm helot
K Name D, Address C. Area Code & Phone No. D. Pollutants Analyzed
TecniCas Reunidas C1. Arapiles 13-14 [phone] provided the background
2Eo15 tiadkid-Spain information for the
feedstock euterlal,
anticipated proeeae
chemicals/reagenta and the
expected process wastewater
effluent characteristica.'
X. Certification
1 ce& under penalty of lase that f is docamarl and ell elladownts there prepared corder my efrecCon or supordston In accardancs with a system designed to assure
that qualified personnel property gafherond evaluate the hrlbrmabon subau;leedd Basadoa myingtky offhe person or persons who manage the system orlhose persons
drecily responslble for gathering the informapon, the lnforma5m subnYaod 14 to ttte bast of my kaoWedge and bedof, into, occurak and complete. I am Divers that
there are slgrOcant penaRles fi rsubmll5ng false lnformaffon, lackrdtng Rue possl6rTdy oflfae endkmpdsonmwd forknoudng vfola5ons
A. Name & Otfiefal Title (Typo 4r P&O B. Area Coda and Phone No.
Timothy R. Basilan, vice --President, Env,Affairs [phone]
C, Signature O D. Dale Signed
EPA Form 3510.217 (1-92) Page 3 of 3

EPA ID Number (copy from Item f of Form 1) I Form Approved. OMB No, 204MO86
Approval expires 5.31.92
i VII. Discharge information (Continued from page 3 of Form 2F) I
Part A — You must provide the results of at least one analysis for every pollutant in this table, Complete one table for each outfall. See instructions for additional details
Maximum Values
Average Values
(include units)
(include units)
Number
Pollutant
of
Grab Sample
Grab Sample
and
Taken During
Taken During
Storrs
CAS Number
First 20
Flow -Weighted
First 20
Flaw -Weighted
Events
(if available)
Minutes
Composite
Minutes
Composite
Sampled
Sources of Pollutants
Oil and Grease
New Facility
NIA
Facility is under construction
Biological Oxygen
Demand (RODS)
New Facility
Facility is under construction
Chemical Oxygen
Demand (COD)
New Facility
Facility is under construction
Total Suspended
Solids(TSS)
New Facility
Facility is under construction
Total Nitrogen
New Facility
Facility is under construction
Total Phosphorus
New Facility
Facility is under construction
PH 1
Minimum New Pacil
Maximum
Minimum
Maximum
Facility is under construction
Part B — List each pollutant that is limited in an effluent guideline which the facility is subject to or any pollutant listed in the fatality's NPDES permit for its process
wastewater (if the facility is operating under an existing NPDES permit). Complete one table for each outfall. See the instructions for additional details and
requirements.
Pollutant
and
CAS Number
(if available)
Maximum Values
(include units)
Average Values
(include units)
Number
of
Storm
Events
Sampled
Sources of Pollutants
Grab Sample
Taken During
First 20
Minutes
Flow -Weighted
Composite
Grab Sample
Taken During
First 20
Minutes
Flow -Weighted
Composite
TSS
Manufacturing Process
N113-N
Manufacturing Process
Total Aluminum
Manufacturing Process
Antimony
Manufacturing Process
Arsenic
Manufacturing Process
Total cadmium
Manufacturing Process
Chlorides
Manufacturing Process
Total Chromium
Manufacturing Process
Total Cobalt
Manufacturing Process
Total Capper
Manufacturing Process
Fluoride
Manufacturing Process
Total Iron
Manufacturing Process
Total Lead
Manufacturing Process
Total Nickel
Manufacturing Process
Total Tin
Manufacturing Process
Total Zinc
Manufacturing Process
PH
Manufacturing Process
ChronicToxicity
Manufacturing Process
Turbidity
Manufacturing Process
EPA Form 3510-2F (1-92) Page VII-1 Contnue on Reverse

Continued from the Front
Part C - List each pollutant shown in Table 2F-2, 2F-3, and 2F-4 that you know or have reason to believe is present. See the instructions for additional details and
requirements. Complete one table for each outfall.
Pollutant
and
GAS Number
(ifavailable)
Maxmum Values
(include units)
Average Values
(include units)
Number
of
Storm
Events
Sampled
Sources of Pollutants
Grab Sample
Taken During
First 20
Minutes
Flow -Weighted
Composite
Grab Sample
Taken During
First20
Minutes
Flow -Weighted
Composite
The facil
ty is designed
and will be
onstructed
and operated in
manner to
minimize the potential for
materials
to enter sto
water that is
discharged
The production
area will
be underlain by containment
basins for
capturing s
crmwater. Sto
water in
he basins will b
analyzed
before being discharged to the
stormwater
system, used
for productior
processes,
or treated and cischarged.
Part D — Provide data for the storm event(s) which resulted in the maximum values for the flow weighted composite sample. 1
4.
5.
1 •
2.
3.
Number of hours between
Maximum flow rate during
6.
Date of
Duration
Total rainfall
beginning of storm measured
rain event
Total flow from
Storm
of Storm Event
during storm event
and end of previous
(gallons/minute or
rain event
Event
(in minutes)
(in inches)
measurable rain event
specify units)
(gallons or specify units)
N/A - New
Facility
7. Provide a description of the method of (tow measurement or estimate.
Stormwater system is designed to manage a 100-year storm event.
EPA Form 3510-2F (1-92) Page VII-2

ATTACHMENTS TO
EPA FORM 3510-2F
GENERAL INFORMATION
HORSEHEAD CORPORATION
RUT14ERFORD COUNTY PRODUCTION FACILITY
• DWG. No. E-0000-G-1004-D, Forest City N.C. SX/EW Plant, General Arrangement,
Storm Water Management Plan, Horsehead Corporation, prepared by Carnegie Strategic
Design Engineers, LLC, Release Date March 1, 2012.
• Continuation of. Part IV. Narrative Description of Pollutant Sources, B. narrative
description of significant materials..., management practices to minimize contact by
these materials with storm water...
• Narrative describing the facility's operation, feedstock materials, reagents and products
produced.
• Letter from Horsehead Corporation to Mr. Charles Waklid, Deputy Director, North
Carolina Division of Water Quality, dated June 13, 2011.
• E-mail correspondence between Mr. Ken Pickle, North Carolina Division of Water
Quality, and Mr. Forrest Westall, McGill Associates, P.A. dated November 30, 2011 and
December 8, 2011 respectively.
• Copy of the State of North Carolina, Division of Water Quality, Permit to Discharge
Wastewater under the National Pollutant Discharge Elimination System, Permit No.
NC0089109.

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

Horsehead Corporation
NPDES Stormwater Permit
Rutherford County, North Carolina
Horsehead Corporation is the leading recycler of zinc bearing waste generated by
North American steel mini -mills, and the largest producer of zinc in the United
States. Construction is underway on a new zinc production facility located in
Rutherford County, just south of the Town of Forest City. The facility will have
limited air emissions and will discharge a clean brine process waste water.
This newly constructed facility upon startup in the future will apply a proprietary
hydrometallurgical process (solvent extraction / electro winning) for producing high
grade zinc metal from two primary feed materials including waelz oxide (a.k.a.
crude zinc oxide) and zinc metal drosses and skims recovered from galvanizing
operations. The production process includes use of feed materials in an aqueous
and hydrocarbon based solvent extraction process to produce a zinc rich electrolyte
solution for use in a cell house where an electro winning process is applied to
produce metallic zinc. Similar technology is commonly used to produce metallic
copper from mined copper ore feed material in the western United States. The
facility will have the capacity to produce approximately 148,000 tons of Special High
Grade (SHG) Zinc metal annually.
The following tables provide information on Feedstock Materials, Reagents, and
Products and By-product Materials that will be used and produced at the facility:
FEEDSTOCK MATERIALS
FEEDSTOCK
MATERIALS
QUANTITY
(tons/year)
Zinc Oxide Zn0
228,000
Galvanizer Skimmings
28,500
REAGENTS
REAGENT
QUANTITY
tons/ ear)
REAGENT
QUANTITY
(tons/year)
Limestone
36,000
Depha
150
Sulfuric acid
41,300
Carbon
58
NaC10 (12%)
5,825
NH4C1
44
HCL
3,900
NaOH
11
Lime
1;608
NaHS
4
Peroxide
975
Mn Sulphate
2,218
Kerosene
600
NaCl
1,200
Sr Carbonate
165
NaCO
4,400
Floc
86

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

TIMOTHY R. BACILONL' -
I+krPrreirfrill-Envinuxrtrnfefrlff�lri �\
ti'� qqq.� �'•�l
4955 STEVOEHVILLE PINE WWW.HQR6EH9AO•NET 724.773.2223 i + i
SUITE 405 TpASILONEOHOASEHENE AO.T 412.7IIB.45ZO W J1f � A 0;
PITTSnvnaH, PA 15205 - C0 R k` O N AT 10 N
Jane 13, 2011 Leading the World in Xh+c Rery; ling
Mr. Charles Wakild, Deputy Director
North Carolina Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: May 9, 2011 Meeting
Division of Water Quality
Horsehead Corporation, Proposed Production Facility, Rutherford County
Stormwater NPDES Permitting and 401 Certification Processes
Dear Mr. Wakild:
I'd Iike to thank you and others from NCDWQ, including Mr. Matt Mattliews, Ms,Cyndi
Karoly, Mr. Bradley Bennett, Dr. Serge! Chernikov and Mr, Ken Pickle, for giving
Horsehead Corp, (Horsehead) the opportunity to meet with you on May 9, 2011 and
discuss the potential plans for constructing a zinc production facility In Rutherford
County, North Carolina, Horsehead and ou'r consultant, -McGill Associates, appreciate
information you provided concerning stormwater NPDFS permit Issues and the 401
certification processes. You provided valuable information with regard to requirements
dealing with these subject areas that would apply to Horsehead's proposed facility.
At the meeting, Horsehead provided a summary of the company's business, a description
of the new plant and processes involved to produce xurc metal, and noted the importance
of this new production facility to our business plan. As we indicated in our meeting,
understanding the permitting process and securing necessary permits in a timely manner
for the sites under consideration is a critical eonVonent in making a decision as to the site
that will be selected for this facility,
The PowerPoint presentation provided at the meeting contains business confidential
information. A copy of the presentation was not provided to you, but we request that key
production process design information for the facility and site be protected under State
and Federal law, and that this information be treated as Business Confidential.
As we pointed out during the meeting, the information provided about the facility and the
site is preliminary and represents a general description of the operation of this proposed .
facility. We are continuing with our facility design efforts and establishment of the final
operating ctitenia for the plant. Horsehead and associated consultants for this project are
available to answer any questions that you may have and welcome the opportunity to
discuss stormwater and 401 permitting requirements for the proposed facility. .

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

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

facility represents a large commitment of resources and technology by Horsehead for the
production of zinc and other non-ferrous metal products.
In relation to permitting requirements under the stormwater program, McGill Associates
will serve as our primary resource for development and submittal of a complete permit
application. Mr. Forrest Westall at McGill Associates will assist in coordinating
information flow between Horsehead and the NCDNR. Mr. Westall can be contacted at
828.231.6840 (cell) or 828.252.0575 (office).
We appreciate your assistance and that of NCDWQ's staff in helping us to define the
stormwater permitting requirements for this site. Please feel free to contact me with any
questions you may have.
Sincerely,
Timothy R. Basilone
cc Forrest Westall, McGill Associates
Darin Cooper, Horsehead Corp.

Pickle, Ken
From: Pickle, Ken
Sent: Friday, June 29, 2012 2:52 PM
To: Cranford, Chuck
Cc: Bennett, Bradley
Subject: Request to review draft stormwater permit Horsehead Corportation
Hi Chuck,
Please see attached draft permit and staff report for the under -construction. Rutherford County Production Facility of
Horsehead Corporation.
These folks will take waste zinc and produce a high -purity zinc product for the general market.
Forrest Westall is their consultant.
If you all could review the staff report, and send me back an original with comments, I'd appreciate it.
Thanks,
,�
H Vi
Copy of Horsehead Copy of
draft accept... rsehead_Staff Repor
_5�Zly?.7-,QZ,5
0 /A// 7-14,1- 5"W" / I-r,4 L
Per rh. 70'
/71/JrsiAV wee , Free r Pcel vc�c
Ken Pickle
Environmental Engineer
-
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone] t M�
Email: [e-mail]
Website: http:////portal.ncdenr.00ra/web/wq/ws/su `-
** Email correspondence to and from this address is subject to the North Z T'61ina151i6 ie Rec&A-Law aritl`may,be
disclosed to third parties unless the content is exempt by statute or other regulations.**

TIMOTHY R. BASILONE
1 rm hesidrnf - Cirvimrru:nuolf jlffrrirs
4955 STEUBENVILLE PIKE
SUITE 405
PITTSBURGH, PA 15205
March 26, 2012
WWW.H0RSEHEA0.NET 724.773.2223
TBASILONEOHORSEHEAU.NET 4t2.706.4526
Mr. Ken Pickle
Environmental Engineer
North Carolina Department of Environment
and Natural Resources
Division of Water Quality
Stormwater Permitting Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Re: NPDES Stormwater Permit Application
Horsehead Corporation
Rutherford County, North Carolina
Dear Mr. Pickle:
CORPORATION
Lredirrg NIC! Warld i1r.Ziur_8tcyc1iRs
_1
'D
JUL - 5 2012 _
WATER C!,A_ITY SECTION
A= �"LFI i C" ,L CFFiCE +
@@ff-0 [
I
MAR 9, 8 2012
DENR - WA'r-,, : j-Zlry
`Sftnd.sr
In accordance with our prior discussions with you occurring over the past year, an NPDES
Stormwater Permit Application has .been completed for the new Horsehead Corporation
(Horsehead) facility that is currently under development in Rutherford County. As described in
the attached application, a stormwater management system has been developed that is integral to
the operation of this facility and that is designed to minimize the potential for discharge of
pollutants in stormwater from the site.
Please find enclosed three (3) copies of the following documents:
o EPA Form 3510-1,
o General Information and EPA Form 3510-217, and
o The Application for Permit to Discharge Storm Water associated with Industrial. Activity
for the Rutherford County Production Facility presently being constructed by the
Horsehead Corporation.

Mr. Ken Pickle
March 1 G, 2012
Page 2
In addition, please find the following'supplemental information required in the application and
included for your convenience:
• Figure 1, Site Area Map, Stormwater NPDES Discharge Permit, Horsehead Corporation,
Rutherford County, North Carolina, dated February 2012.
• DWG. No. E-0000-G-1004-D, Forest City N.C. SX/EW Plant, General Arrangement,
Storm Water Management Plan, Horsehead Corporation, prepared by Carnegie Strategic
Design Engineers, LLC, Release date March 1, 2012.
• Narrative describing the facility's operation, feedstock materials, reagents and products
and by-products.
• Letter from Horsehead Corporation to Mr. Charles Wakild, Deputy Director, North
Carolina Division of Water Quality, dated June 13, 2011.
• E-mail correspondence between yourself and Forrest Westall with McGill Associates,
P.A. dated November 30, 2011 and December 8, 2011, respectively.
• Copy of the State of North Carolina, Division of Water Quality, Permit to Discharge
Wastewater under the National Pollutant Discharge Elimination System, Permit No.
NC0089109.
The objective of the proposed plan is to manage all stormwater for discharge from the facility
through a single monitored outfall to the Broad River. Stormwater from various areas of the
facility will be managed according to the following scheme:
1. Stormwater falling into various operating/production areas will be collected in segregated
collection basins underlying or adjacent to these areas, as designated, will be analyzed for
likely pollutants to determine its disposition. Based on analytical results, the water will
be discharged to the stormwater system, used in production process operations, or
possibly treated prior to discharge. This water is referred to as "discretionary storm
water" for discussion purposes.
2. Stormwater drainage from standard commercial or landscaped areas and perimeter
roadways, roofed areas having no contact with industrial processes. This water will be
discharged directly to the stormwater system leading directly to the stormwater outfall.
This water is referred to as "non -discretionary storm water", and
3. Stormwater falling into a few designated operation areas will be collected in segregated
collection basins underlying the designated area(s) and used for production process
operations at all times, and not discharged to the stormwater system.
4. Stormwater from undeveloped areas (fill and vegetated areas not affected by plant
activities) will be discharged through energy dissipation into natural drainage channels.

Mr. Ken Pickle
March 16, 2012
Page 3
Stormwater from described areas I and 2 above will discharge to the single monitored outfall for
the facility. Stormwater drainage from described areas in 3 above will not be discharged but will
be used in the production process. Stormwater drainage from described areas in 4 above,
including unaffected surrounding property, will discharge into natural drainage channels.
We appreciate your guidance and assistance on this important project. In meetings over the past
year with you, we discussed the importance of having all permitting in place as quickly as
possible and well before the facility is scheduled for start up. We anticipate that you will stand
by the commitment made by the Division of Water Quality to provide a quick review and action
on this permit application. If there is any aspect of this permit package that needs clarification,
please contact me immediately so that the issue can be resolved without delay. In addition, the
Division had indicated that a pre -draft of the permit (before notice) would be provided for our
review before a draft permit is directed to public notice.
If you have any questions please do not hesitate to contact me.
Sincerely,
HORSEHEAD CORPORATION
Timothy R. Basilone
Vice President, Environmental Affairs
Enclosures
cc: Forrest Westall, PE, McGill Associates, P.A.

NCS000562
A�
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P.E. Dee Freeman
Governor Director Secretary
STAFF REVIEW AND EVALUATION
NPDES Stormwater Permit
Facility Name:
Rutherford County Production Facility, Horsehead Corporation owner
NPDES Permit Number:
NCS000562
Facility Location:
US 221, south of Forest City, NC, Rutherford County
Type of Activity:
High purity zinc recovery from waste material
SIC Code:
3341
Receiving Streams:
Broad River, see Figure 1
River Basin:
Broad River Basin, Sub -basin 03-08-02
Stream Classification & condition:
Class C, no TMDL, no 303(d)
Proposed Permit Requirements:
See attached draft permit.
Monitoring Data:
New permit, no historical data exists.
Response Requested by:
duly 16, 2012
Central Office Staff Contact:
Return to: Ken Pickle, [phone]
Special Permitting Issues:
Risk considerations
Rating Scale: 1 minimal risk to 10 risk factors resent
Compliance history
No history: rate 1
Benchmark exceedance
A new site, with no past measurements: rate 1
Location (TMDL, T&E species, etc)
Downstream benthos impaired; downstream WS-IV and WS-IV CA:
rate 6
Other factors:
Other factors in aggregate present larger than normal risks for most
• Zinc solutions, lead, and acids
industrial sites: rate 10
present.
• Industry is unique in NC, no other
similar facilities.
• A start-up facility.
• Multiple tanks & containments,
rail unloading, potential for
process fluids to be exposed.
• Avoiding heavy metal solutions
discharges depends on proper
operator actions to a larger than
normal degree.
Risk and DWQ scrutiny rating:
18/40 - moderate stormwater pollution risks
Page 1 of 4

NCS000562
Description of Onsite Activities:
• Horsehead receives waste zinc material, and refines it into a high purity product. Byproducts are
secondary in importance, including minor amounts of lead and silver production.
Documents Reviewed:
• NPDES stormwater permit application materials, received in final form May 8, 2012.
• US Fish and Wildlife Service threatened and endangered species inventory for Rutherford County
• Natural Heritage Program staff reports no rare aquatic species in the Broad River in this vicinity.
• EPA Sector -Specific Permit, 2008. SIC 3341 covered, but no benchmarks assigned.
• Integrated Report 303(d) List, 2010 final: upstream WS-IV and downstream WS-IV and CA impaired
for aquatic life, but the actual receiving reach is classified C and is not listed.
• July 2008 Broad River Basinwide Plan: no comment on this site; in 2008 the receiving water is shown
as supporting its classified uses.
History:
• First time stormwater permit application.
• First time NPDES wastewater permit issued Nov. 11, 2011, NC0089109.
Figure 1: Map of Facility
r .t,
777
4 � Iles L\ 1 1 ti \��i � i� s• ` I 1 � " • ' r _ t ...
ti: �� I f' .1' •� > l i I 1 \ � � �' ' �f fir-
Horsehead Corporation y�y,�++ j\� s `• , ,� �` �L �,
.�M i111 � i � irr t`i •, � 9
's ` �,;•. 4. x• ... �. .-r may • c
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Page 2 of 4

NCS000562
Central Office Review Summary:
1. Owner's Other Permits:
o NCO089109 issued for wastewater discharges. Permit limits on Q, Cd, F, Pb, pH. Monitoring w/o
limits on TSS, NH3, Al, Sb, As, Cl, Cr, Co, Cu, Fe, Ni, Sn, Zn. Also Chronic Toxicity and NTU.
2. General Observations: New, large site with no history. On -site zinc solutions are materials of primary concern_
3. Impairment: Receiving water not listed as impaired on 303(d) IR.
4. Threatened and Endangered: None identified by USF&WS website: NHP staff contact reports no rare aquatic
species in the Broad River in this vicinity.
5. Location: Close to Brice in southern Rutherford County, on the south bank of the Broad River. Site elevation
relative to the Broad River discharge point suggests energy dissipation concerns for stormwater flows.
6. Industrial Changes Since Previous Permit: New permit, no changes.
7. Analytical Monitoring Notes: Quarterly monitoring.
8. Qualitative Monitoring Notes: Quarterly visual monitoring.
Permit Recommendations: Analytical Monitoring
1. Analytical monitoring has been set to quarterly during a measurable storm event as defined in Part Il Section B.
The recommended quarterly monitoring is more frequent than most standard industrial stormwater permits.
This facility handles heavy metal solutions, and is without a track record of performance in North Carolina.
Quarterly sampling is recommended in response to the increased risk factors noted above. DWQ can consider
reducing the sampling frequency later in the permit term if supported by subsequently collected data.
2. The permittee must document the total precipitation for each sampled event. If no discharge occurs during the
sampling period, the permittee must submit a monitoring report indicating "No Flow" within 30 days of the end
of the three-month sampling period.
3. Analytical monitoring parameters:
a. Metals: Zinc, lead, silver. Based on Zn solutions on site; based on identification of Pb as a secondary
byproduct, Ag chosen for very low benchmarks and as a surrogate for all other heavy metals potentially
present. Ag reported as expected to be present and recovered in very small amounts.
b. Organics: TPH, based on significant on -site presence of kerosene or kerosene -like petroleum product as
the solvent vehicle for DEHPA, a key process ingredient.
c. Conventional pollutants: TSS, pH, TN, TP. Nutrients based on N and P compounds reported as
present in the manufacturing process.
4. Benchmarks are included for all analytical parameters. Exceedances of benchmark values require a response
action from the permittee in a tiered program. If the sampling results are above a benchmark value, then the
facility shall follow the Tier 1 guidelines which require a facility inspection within two weeks and if feasible,
implementation of a mitigation plan within two months. If during the term of this permit, the sampling results
are above the benchmark values, or outside of the benchmark range, for any specific parameter at the discharge
outfall two times in a row (consecutive), then the facility shall follow the Tier 2 guidelines which require a
repetition of the steps listed for Tier 1 and shall also immediately institute monthly monitoring for all parameters
at every outfall where a sampling result exceeded the benchmark value for two consecutive samples.
5. Qualitative monitoring also must be accomplished during a measureable storm event.
6. Vehicle maintenance area monitoring is not applicable since this facility will have only one stormwater outfall.
7. The permittee is required to continue monitoring until the permit is renewed. See Footnote I of Table 2.
Discussions with permittee: DWQ met with Tim Basilone, Horsehead Vice President, and with Forrest Westall,
consultant, in an initial meeting, a follow-up meeting prior to application submittal, and a meeting subsequent to the
initial submittal of application materials. In addition, email correspondence was used to request additional
information on the proposed project.
Page 3 of 4

NCS000562
Recommendations: Based on application materials received on March 28, 2012; and again on April 2; and again on
May 8, SPU considers the combined application materials sufficient to issue an individual Stormwater Permit. We
are requesting Regional Office review comments, and full or qualified concurrence.
Prepared by (Signature) Signature of Ken Pickle Date
Stormwater Permitting Unit Supervisor
for Bradley Bennett
Date
Concurrence by Regional Office Date
RO Water Quality
Regional Office Staff Comments (attach additional paces as necessary)
Page 4 of 4

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

Thanks ... Brent
Brent G. Burch
Compliance Branch Head
Hazardous Waste Section
Division of Waste Management
828 321 9585 office
919 270 2049 mobile
Brent. Burch(@-ncdenr.gov
PO Box 1427
Andrews, NC 28901
C.-
-:5' Noth1n9 Compares�,
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Menzel, Jeff
Sent: Friday, June 23, 2017 3:58 PM
To: Burch, Brent <[e-mail]>; Morris, Sean <[e-mail]>
Subject: Horsehead storm water/ waste water permit renewal
Sean and Brent,
After reviewing the current draft of Storm Water permit NCS000562 forAmerican Zinc Products LLC
(former Horsehead Metals), I would like to request that this draft and any other NPDES permit be placed
on hold.
The current storm water permit does not expire until March 2018 and I feel that any analytical data
available along with observations made by HWS during site visits staff be conveyed to DEMLR/DWR
before any subsequent permits are issued.
This facility, in its shorts life span, has had numerous spills of hazardous material with the primary
conveyance being the storm water/wastewater systems. There are NPDES permits issued for both.
The facility has asked for DEQ's input during their current engineering phase prior to starting operations
again in 2018. To facilitate a beneficial response to the facility I think it is prudent that the various
Division's share information or concerns regarding permit requirements or applicable regulations.
If you need any additional information or supporting documentation for this request I will be happy to
provide that.
Thanks,

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

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Pickle, Ken
From: Pickle, Ken
Sent: Friday, February 26, 2016 10:46 AM
To: Aiken, Stan E
Cc: Bennett, Bradley; Walker, Fred
Subject: Horsehead spill and Stormwater Permitting Program wrap up for now
Hi Stan,
It's Friday, and I'm trying to wrap-up/nail-down a few issues that crossed my desk over the last couple of weeks,
including our comments on the February spill at Horsehead and the suspension of start-up and manufacturing
activities. I've spoken with Bradley (programmatic concerns) and with Mike Lawyer (experienced in
enforcement/implementation of our permits from a Regional Office perspective.) Most of this we have already covered,
but just in case it comes up again in ARO, here's where I think we should be (based on what I think we know about the
site and spill):
• They have not applied for rescission of the stormwater permit yet, but if they do it would not be automatic for
us. I think there's a reasonable case to be made that we would require them to clean up the site (remove
potential stormwater exposure to our satisfaction) before we would rescind the permit. We have the authority
in federal rule to require continuing permit coverage and compliance even if the plant shuts down. Continuing
on this idea, ARO or RCO should advise HH that the permit is still in effect until we officially rescind it. Do you
guys want to do that, or would you prefer me to?
The "Storm Pond" should never discharge directly to surface waters based on our understanding of its use and
contents. Discharge of the fluids in that basin is not authorized under the our stormwater permit, NCS000562.
With respect to the February 2016 spill:
o The text of the permit requires HH to provide secondary containment. Arguably leaking secondary
containment is no secondary containment, and results in a violation of permit conditions. So, yes there
has been a permit violation. However, I have the impression that their response was pretty good, and
that no zinc solution reached the receiving waters. ARO can decide if issuing an NOV/NOD is
appropriate.
o On the same topic, the text of the permit requires the permittee to properly operate and maintain all
systems for pollution control at all times. Again, leaking secondary containment is evidence of the
permittee's failure to properly operate and maintain that control system. Again, again —your call on
how much to make out of this.
o Summary: Yes, the circumstances of the spill amount to a permit violation. The appropriate level of our
response to the violation deserves careful consideration.
I know you all have been out to the site several times during construction and start up, but I don't see a BIMS
entry for a permit compliance inspection. If HH is high on your radar, consider if it's time for a compliance
inspection. The fact that they are shutting down operations might ease our concerns a little, but imo reduced
staff and management attention to the physical plant along with atypical operations (shut down procedures)
would increase our concerns to an even greater degree.
o It might be worthwhile to get copies and review all their stormwater monitoring results as part of the
inspection. (I'd like to see those, too.)
o After the big spill in 2015 HH promised to go around to all the containments and
inspect/repair/revise/address the failure mechanism (seam between tank wall and containment wall)
identified in that spill. Can they provide work orders/logs/ physical evidence that indeed they did that
to a substantial extent?
o Do they intend to do the same thing for the failure mechanism in this second spill (I mean both the
water line break and the containment failure.)

Ken
Ken Pickle
Stormwater Program Specialist
DEMLR Stormwater Permitting Program
Department of Environmental Quality
919 807 6376 office
ken. gickleancdenr.gov
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury St, Raleigh, NC 27604
�; Nothing Compares,-,-
M.I'
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

r- �
Pickle, Ken
From: Pickle, Ken
Sent: Tuesday, February 23, 2016 12:37 PM
To: Bennett, Bradley
Subject: FW: Interpretations of site conditions vs permit requirements, Horsehead Corp, ARO
Hi Bradley,
I spoke with Mike Lawyer about Horsehead. His comments included:
• We shouldn't rescind their permit, even though they are shutting down. 1 advised that they hadn't requested
rescission, and .hat my expectation is that significant exposed materials would remain.
• Did they make timely notification of the spills? I advised Yes.
• Sounds like they did just what we would hope they would do in response to a spill. Based on my description of
their response actions on the first spill.
• Note that permit provides they still can't contravene WQS. DWR should pursue this if they're interested, but
not DEMLR.
• Mike concurs that leaking secondary containment is inadequate, and does not meet the permit
requirements. He has encountered this before and required permittees to beef up the secondary
containment to the point of adequacy. I explained the mechanism of the first leak, and that although I don't
know the exact mechanism in the second leak, it was again a containment failure.
• Mike suggested review of the permittee's Spill Prevention and Response Plans to see if they're adequate. 1
reported that the spill responses have been good, so for. And that after the first spill HH reported that they
would institute on inspection and repair program specifically targeting the failure mechanism for
prevention. Whether they have followed through with the spill prevention portion or not 1 don't know. He
suggested we confirm the follow through on the first spill prevention actions.
• Mike suggested review of the permittee's secondary containment design basis. 1 failed to report to Mike that
HH asserted that the containment has been designed for the 100-yr rainfall —1 probably need to check that early
comment to be sure it's still vvolid.--l-did-eonfirm_th.at the failure mechanism was not overtopping, ofaik.
• Mike would consider a CEI. 1 advised that ARO had been
in April
response to the first spill, but not to conduct a CE1. /
• Mike would be interested in whether the sampling shows that the facility was meeting the benchmarks
before/after the spills.
KBP Summary Conclusions and Actions:
(Based on review of permit text, 2F and application materials, SPPP chapter in the integrated Contingency Pion,
discussion with Mike Lawyer)
• inadequate secondary containment is a permit violation. Response actions have been very good. KBP
opinion: No further action by DEMLR.
• We/ARO should notify HH that the stormwater permit remains in efferr mtil wa rescind it: and we likely won't
based on our understanding of site conditions.
• We/ARO should review any monitoring results in relation to I efore and after the spills.
• We/ARO should confirm that HH subsequently acted to prev t containment failure 'a'the mechanism in the (I
first spill, and that the mechanism in the second spill will likewise re preventative measures at other` j
r
ments. ay want to consider a storm aterCEItorm Pond" should never discharge directly to surface waters based on our understanding of its use and
ts.
f

• KBP to advise Stan of these conclusions. Bradley, any cautions, comments, or corrections?
KBP
Ken Pickle
Stormwater Program Specialist
DEMLR Stormwater Permitting Program
Department of Environmental Quality
919 807 6376 office
[e-mail]
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury St, Raleigh, NC 27604
Nothing Compares ---,-
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Lawyer, Mike
Sent: Tuesday, February 23, 2016 9:32 AM
To: Pickle, Ken <[e-mail]>
Cc: Bennett, Bradley <[e-mail]>
Subject: RE: Interpretations of site conditions vs permit requirements, Horsehead Corp, ARO
Hey Ken. I should be in the office today and likely tomorrow as well.
Michael Lawyer, CPSWQ
Environmental Program Consultant
Division of Energy, Mineral and Land Resources I Land Quality Section
North Carolina Department of Environmental Quality
910 433-3394 office
mike. lawyer(aDncdenr-gov
225 Green Street, Suite 714
Fayetteville, NC 28301
-5��'Nothifng Compares.....
0---
'Er correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Pickle, Ken
Sent: Tuesday, February 23, 2016 9:08 AM

To: Lawyer, Mike <mike.lawyerPncdenr.gov>
Cc: Bennett, Bradley <[e-mail]>
Subject: Interpretations of site conditions vs permit requirements, Horsehead Corp, ARO
H1 Mike,
I'd like to chat with you about the circumstances around a permitted facility in ARO. Are you available over the next
couple of days to speak with me on two issues at the subject facility in ARO?
Background:
o Horsehead Corporation holds our individual stormwater permit NCS000562, issued for the first time April 1,
2013. The facility is sited above the flood plain, on the high banks of the Broad River, just west and south of
Mooresboro, NC. The Broad River is class C at that point.
o They take zinc by-products from manufacturing processes and further refine it into ultra -high purity zinc, for
which there is a very profitable specialty market.
o The construction and start-up have been plagued with problems both wrt production and ironmental. Th
plant was moth -balled earlier this month, never having reached full scale production. T e shake -out period jus
stretched on and on.
o We have a report that a portion of the management and engineering staff will remain on site
being. They are not going down to just security staff.
o First issue: There have been at least two spills of zinc -enriched solutions, one earlier this month, and one last
year.
o DEMLR ARO and SPP are interested because both spills made it to our site stormw in the
hill o round immediately adjacent to the Broad River. A portion of a first spill passed into e
(road R�iv r;�the second spill was contained in the 'energy dissipater, the oncrete lined first c ber
`oft stormwater basin (Energy dissipater because: 60" stormwater pipe, 8 ro .
o DWR ARO surface water and ground water are interested because of the potential for zinc to reach both
the Broad River and ground water. Conside!d
o DWR ARO Haz Waste folks are interested because the spilled zinc solution might be hazwaste now that it has been released to the environment.����`7
o DWR NPDES has issued a wastewater discharge permit for the fa ut the spill incidents don't
appear to trigger any concern under the wastev�a e A portion of t first spill reached the
Broad River, and might be considered,discharging wastewater without a perm
o Second issue: The facility has a large basin forstormwater collection adjacent to draining the
production area. The basin's primary purpose is to -ah—d spills for introduction back into the
process (they need rainwater to augment city water in the process.) Discussion has arisen on whether that
stormwater could ever be discharged if it tested clean, given the sloppy operation and presence of process fluids
leaking onto the pavement draining to the pond.
So, my questions have to do with whether you have had opportunity to apply the stormwater permit conditions or
boilerplate to similar spill circumstances. The other ARO Divisions seem to expect DEMLR to act under the
stormwater permit, but it's not clear to Bradley and me where the text might be used to either require action or to be
the basis of an enforce ment/NOWNOD. What portions of the permit text have you used to encourage better
behavior from our permittees?
Please let me know when you can make time to chat.
Thanks,
Ken
Ken Pickle
Stormwater Program Specialist

DEMLR Stormwater Permitting Program
Department of Environmental Quality
919 807 6376 office
[e-mail]
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury St, Raleigh, NC 27604
Nothing Compares.,..
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

Pickle, Ken
From: Pickle, Ken
Sent: Monday, February 22, 2016 5:50 PM
To: Bennett, Bradley
Subject: FW: Description of Ponds, Horsehead, NCS000562
Bradley,
It looks to me like there are two open items recently raised requiring our review and comment. The first is the spill. The
second is the basin designated as the "Storm Pond", one of four ponds on the west side of the facility. As you suggest,
I'll look again at the permit text, and at the application materials. NCS000562, effective 4/1/2013.
Summary:
• For the spill into the energy dissipater, and whether there is a permit violation:
o Part I Section B authorizes the discharge of stormwater that has been "adequately treated." With
respect to any zinc residuals in the energy dissipater or the rest of Basin #1, until the benchmark testing
is accomplished, we won't have a basis to assess whether or not any zinc residuals from the spill are a
possible cause of violation of the 'adequately treated' requirement.
o Part II Section A requires secondary containment to prevent runoff pollution. Leaking secondary
containment is no secondary containment. The permittee has violated this requirement of the
permit. But, presumably he fixed it right away.
o Part III Section C requires the permittee to properly operate and maintain the systems put in place to
achieve compliance with the permit. We would apply this requirement to the requirement for
secondary containment, and note that he has failed to properly operate and maintain the system. But
again, presumably he fixed it right away.
o Summary: Yes, there's a permit violation as a result of a water line breaking and ineffective
secondary containment. Environmental impact is not yet established.
For the "Storm Pond" and whether discharees from it are permitted under our hermit:
o Not mentioned by name in the text of the permit.
o Not mentioned by name in the application narrative, although the submitted site drawing indicates that
the pond in question is part of the 10-acre Area 200 part of the facility. The whole Area 200 is noted on
the drawing as having recycle back to the process for contaminated stormwater, or controlled release
for tested and confirmed clean stormwater, as are several other areas of the site. The level of detail of
the drawing does not indicate the nature of any effluent structure or piping configurations, either in the
individual containment structures, or in the Storm Pond. As I think I recall from the on -site meeting
previously, site personnel reported that there was a piping connection at the pond, but that it had never
been used, and that it never would be used to discharge stormwater. I conclude that the purpose of this
basin is a manufacturing process purpose, not an environmental or stormwater purpose, despite the HH
name. Note that HH correspondence reports that the facility captures rainfall to reduce reliance on city
water.
o We have an inspection report indicating sediment accumulation in the pond, with the assumed potential
for zinc concentrations.
o Summary: Our permit provides that fluids from secondary containment can be released if found
uncontaminated. I would not consider this Storm Pond a secondary containment. To me, secondary
containment implies limiting the environmental exposure to an area immediately around the tankage
involved. That is not the case here. I think the pond is functioning more for rainfall capture for process
purposes, process fluid volume capacitor, spill reclaim, and recycle basin. I think there is a very basic

r
distinction to be made between normally passive, infrequently used, secondary containment for
environmental protection and a process fluid capacitor.
Ken
BACKGROUND DISCUSSION SUPPORTING THE SUMMARY ABOVE
On the first issue of the spill. I've gone over the Horsehead permit, NCS000562, and see these potential elements of the
permit that might be relevant. The circumstances are: a water line break that filled a containment structure to a point
where a portion of the contents of the containment leaked out through a failed seam between materials, and then got
into the stormwater-only collection system.
• No help: our permit authorizes stormwater discharges associated with industrial activity, and it does not appear
that the circumstances have resulted in a discharge. (Jeff reports that HH reports that the material was
completely contained in the concrete -lined energy dissipater basin.)
• No help: As to any zinc residuals, the material was pumped out. We would rely on the zinc benchmark in the
permit to control zinc content in any stormwater discharges due to any (presumably?) small amount of
residuals remaining in the energy dissipater structure.
• No help: Part I Section B: "Any other point source discharge to surface waters of the state is prohibited unless
it is an allowable non-stormwater discharge or is covered by another permit, authorization, or approval. The
stormwater discharges allowed by this permit shall not cause or contribute to violations of Water Quality
Standards." Again, in the first sentence, there was no discharge. In the second sentence no evidence of a wqs
violation from the non -discharge.
• No help: Part IV Definitions: "Allowable Non-Stormwater Discharges This permit regulates stormwater
discharges. Non-stormwater discharges which shall be allowed in the stormwater conveyance system are:
a. All other discharges that are authorized by a non-stormwater NPDES permit.
b. Uncontaminated groundwater, foundation drains, air -conditioner condensate without added chemicals,
springs, discharges of uncontaminated potable water, waterline and fire hydrant flushings, water from
footing drains, flows from riparian habitats and wetlands.
c. Discharges resulting from fire -fighting or fire -fighting training, or emergency shower or eyewash as a result
of use in the event of an emergency."
But, again, without a resulting discharge. I question whether this part of the permit is triggered.
No help: With respect to any portion of the original application submittal, there are portions that speak in a
limited way to provisions for spills. Form 2F in four places reports that, "Material exposed to stormwater will be
minimized, and when necessary will be managed to avoid potential impact to stormwater discharge_d from the
facility." (2F, IV B). "This scheme for managing stormwater in the production area of the facility and other areas
of the property will minimize the potential for pollutants to enter stormwater that is discharged from the site."
(2F, IV Q. "Materials will be managed to prevent the potential for entry in stormwater that is discharged from
the facility." (2F, VII E). "The facility is designed and will be constructed and operated in a manner to minimize
the potential for materials to enter stormwater that is discharged." (2F, VII Q. So, the application states that
HH will manage the materials and stormwater, and will also design and construct the facility, to prevent the
discharge of polluted stormwater. Those statements might together be construed to say that spilled
materials would not be transported off site in a stormwater discharge. But again, without a resulting
discharge, the reasonable interpretation might be that the facility indeed managed the spill to prevent the
discharge of site stormwater containing the spilled materials.
• Some help: Part I Section B: "Until this permit expires or is modified or revoked, the permittee is authorized to
discharge stormwater to the surface waters of North Carolina that has been adequately treated and managed in
accordance with the terms and conditions of this permit." Vague "adequately treated and managed" offers some
direction, but would be hard to definitively pin a violation on HH, imo. I think the probable measure of

"adequately treated" is the discharge concentration of Zn. If the zinc concentration is over benchmarks, and if
the exceedance might be attributable to the spill from the WOX containment, then the spill might be the basis
for asserting that the permittee did not adequately treat and manage his stormwater discharge.
• Some help: Part II Section A SPPP: "Secondary Containment Requirements and Records. Secondary
containment is required for: bulk storage of liquid materials including petroleum products; storage in any
amount of Section 313 of Title III of the Superfund Amendments and Reauthorization Act15ARA)_water
priority chemicals; and storage in any amount of hazardous substances in order to prevent leaks and spills
from contaminating stormwater runoff. A table or summary of all such tanks and stored materials and their
associated secondary containment areas shall be maintained. If the secondary containment devices are
connected to stormwater conveyance systems, the connection shall be controlled by manually activated
valves or other similar devices, which shall be secured closed with a locking mechanism. Prior to release into
the stormwaters conveyance system, any stormwater that accumulates in containment areas shall be at a
minimum visually observed for color, foam, outfall staining, visible sheens, and dry weather
flow. Accumulated stormwater may be released if found to be uncontaminated by any material." The leaking
secondary containment system has failed this part of the permit requirements, since leaking secondary
containment is no secondary containment. Failure to provide secondary containment would be a permit
violation.
• Some help: Part III Section C Boilerpate: " Proper Operation and Maintenance The permittee shall at all times
properly operate and maintain all facilities and systems of treatment and control (and related appurtenances)
which are installed or used by the permittee to achieve compliance with the conditions of this
permit." Possibly we could propose that the permittee has not complied with this permit requirement since
leaking secondary containment is not proper operation and control of the systems installed to achieve
compliance with the permit.
With respect to the basin designated as the "Storm Pond" and any discharge from it:
• The text of the permit does not speak to such a pond by name. Nor by any indirect reference.
• However, note that the face of the permit references GS 143-215.1, which establishes the requirement for a
permit, and from which 15A NCAC 2H .0126 springs which incorporates by references 40 CFR 122.26which
authorizes "discharges composed entirely of storm water", which is the basis for us casually characterizing our
permits as "stormwater-only" permits. All to say that if this pond has any process fluid flowing into it, it can't
be discharged under our permit. But, we do have a confusing circumstance with area drainage from the sloppy
areas of the facility. If that material produced by operations sloppiness is transported by runoff into the Storm
Pond, can it be discharged under our permit, assuming it would be found to be uncontaminated? Even so, it is
not clear that the Storm Pond is equipped with a discharge line to our Basin #1 along the Broad River.
• The HH application materials describe four categories of flows that mi ht be generated at the siterJ vy b°' rZ-
o HH uses the term `discretionary storm water" for r ' in so proce as will be colleted
and tested and potentially used in the process, or Areated prior to discharge r released as stormwater.
o HH further intends to collect rainfall from certain ther process areas and al ays use the water as part
of the process.
o Additionally, HH uses the term "non -discretionary storm w r" fort infall originating on the perimeter
roadways, commercial areas, and roof tops of the site, but without contact with the industrial
processes. Such flows will be discharged directly to the stormwater outfall.
o Rainfall originating from undeveloped areas (fill and vegetated areas not affected by plant activities) will
be essentially treated as not qualifying as regulated stormwater, and will be discharged unmanaged as
the terrain dictates.
o None of the HH categorizations above specifically identifies the "Storm Pond."
o While these are HH classifications, they mean nothing to us except insofar as the containment structure
liquids are stormwater-only liquids, testing clean. Our permit only authorizes stormwater-only
discharges, free of any contamination
• The HH 2O13 Integrated Contingency Plan covers the SPPP requirements in Chapter 4.0.
3

f .
o Paragraph 4.2.2 reports that, `Th�e_are no secondary containment areas th re connected to storm
water conveyance systems. A portable hose will be used to transfer water from the secondary containment
to the storm water system, if needed. Storm water that accumulates in the containment areas will be
visually observed and tested to ensure contaminants are below permit limits before being released to the
storm water conveyance system." This entry would be consistent with our permit requirements for
secondary containment.
Ken Pickle
Stormwater Program Specialist
DEMLR Stormwater Permitting Program
Department of Environmental Quality
919 807 6376 office
ken. pickle@ncdenr. gov
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury St, Raleigh, NC 27604
Nothing Compares
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Pickle, Ken
Sent: Friday, February 19, 2016 1:47 PM
To: Davidson, Landon <[e-mail]>; Menzel, Jeff <[e-mail]>; Burch, Brent
<[e-mail]>; Heim, Tim <[e-mail]>
Cc: Bennett, Bradley <[e-mail]>; Aiken, Stan E <[e-mail]>
Subject: FW: Description of Ponds
Hi guys,
Thanks for bringing us up to speed. I'll talk with Bradley a little more about this over the next few days to see what/if
this may mean under our permit coverage of Horsehead.
Ken
Ken Pickle
Stormwater Program Specialist
DEMLR Stormwater Permitting Program
Department of Environmental Quality

919 807 6376 office
[e-mail]
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury St, Raleigh, NC 27604
h - 01.
—�"Noth€ng Compares.`
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Davidson, Landon
Sent: Friday, February 19, 2016 1:26 PM
To: Menzel, Jeff <ieff.menzelC�ncdenr.gov>; Burch, Brent <[e-mail]>; Aiken, Stan E
<[e-mail]>; Pickle, Ken <[e-mail]>
Cc: Heim, Tim <Tim.Heim @ncdenr.gov>
Subject: RE: Description of Ponds
To all,
Thanks Jeff. This is a good revision or correction to my email from yesterday. This sentence regarding the stormwater
pond: Most likely there is zinc and other constituents within this sediment the concentrations are not known at this time.
could suggest a potential violation of the stormwater permit? Does there need to be more investigation into how the
ponds, or at least the SW capture pond, is being used and its connection to stormwater outlets? I just don't have the
background on the SW side for this type of facility where SW is captured in ponds that are bled into a process and if
recycling occurs in that same pond.
G. Landon Davidson, P.G.
Regional Supervisor — Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4680 office
828 230 4057 mobile
Landon. Davidson(5ncdenr.gov
2090 U.S. Hwy. 70
Swannanoa, N.C. 28711
�Nothing Compares.`
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Menzel, Jeff
Sent: Friday, February 19, 2016 11:39 AM
To: Burch, Brent <brent.burch(@ncdenr.gov>
Cc: Davidson, Landon <[e-mail]>; Aiken, Stan E <[e-mail]>
Subject: Description of Ponds

On the West side of the HH property there is a series of 4 lined ponds. Starting south and going north the ponds are
called the following names; Storm pond, West Maintenance Pond, Raffinate Pond, and Depleted Solution Pond.
1. Storm Pond. Collects storm water from the road ways on the western half of the property. Collected storm
water than can be introduced into the process as needed or if there is a surplus after a storm event the water is
routed through bleed treatment and discharged as wastewater. There is approximately 3 to 4 feet of material in
the bottom of this pond consisting of sediment introduced during construction and process materials
introduced through spills, tracked materials washing off roadways, etc. Most likely there is zinc and other
constituents within this sediment the concentrations are not known at this time.
2. West Maintenance Pond. This pond was designed to collect storm water and process materials
within secondary containment units on the west side of the property. This water can be introduced back into
the process to recover process materials.
I am unsure the extent of sedimentation within this pond.
3. Raffinate Pond. Collects water from the 200 Area Raffinate secondary containment. Can be introduced back into
process.
4. Depleted Solution Pond. Spent electrolyte solution can be introduced back into process to be combined with
organic solvent to hold the purified zinc in solution or can be routed through bleed treatment to remove built
up impurities or contaminants.
During this idling period the facility will have to continue to process storm water on the west side of the property. They
will do this by collecting the water from west roadways and containment units, routing storm water to the Storm and
West maintenance ponds, and then processing in the bleed treatment process to be discharged from their 001
wastewater outfall. Other parts of facility which will also have to remain active during this time included units which
process the organic solvent solution and the zinc furnace.
There was a release this week to storm water Basin 1. The spill was contained in the energy dispersion unit. A 2" city
water line broke around 5 am this water flowed into the WOX silos containment. A leaked then occurred in the WOX
silo containment wall seam and the water made its way into the storm water system on the east side of the property.
The concrete energy dispersion unit collected the water and they were able to pump and haul from this unit so there
was no discharge to the other parts of the storm water basin.
Jeff Menzel
Western Region Environmental Specialist
Hazardous Waste Section
Division of Waste Management
828 419 5034 office
919 270 1967 cell
Jeff. menzetencdenr.eov
PO Box 1568
Black Mountain, NC 28711
K-;II
Nothing Compares s
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

fig} 91q- 313 �5��) �y8- 5a�'►3 (G)
Bennett, Bradley
From:
Sent:
To:
Subject:
Reported sequence:
Pickle, Ken
Thursday, September 17, 2015 6:10 PM
Bennett, Bradley
Horsehead leak
• Saturday 9:30 pm, 9/5. staff observed flow into the energy dissipater during a dry weather period; staff tested
with pH strips commonly carried; discovered pH low; closed valves out of the energy dissipater and the effluent
valve in the Basin 1 outlet structure. Moved up gradient into the plant and cleaned up the area around an
earlier acid pump spill. Material in the energy dissipater vacuumed up and returned to process.
• Sunday, 9/6: staff observed continuing flow, concluded that the acid pump spill was not the source, but with no
obvious source. Staff pulled manhole covers back up stream until isolated in the Electrowinning area (Area 400)
storm sewer.
• Monday, 9/7: EHS Manager continued to receive reports of flow over the weekend. Installed rubber plug in the
area storm sewer. An attempt to run a camera through the line was inconclusive, but a leaking joint was
detected.
• Tuesday, 9/8: Normal process operations Q) Monday night pulled down liquid stored in the containment area
under Electrowinning: Staff observed a breach in the containment liner to polypropylene tank seal. Fluid
reported to be 7% H2SO4 laden with Zn. Construction project manager reported lots of gravel backf lied in the
area of this particular storm sewer leg. Working scenario: the breach in the liner allowed containment fluid to
flow through the underlying gravel fill to the concrete sewer pipe (no joint gasket, just concrete to concrete
construction at the joint) and down the collection system to the energy dissipater at the foot of the hill.
• Wednesday, 9/9: Horsehead contacts ARO to report leak/spill into the Broad River. Valve on Basin 1 discharge
does not effectively seal, and a trickle of Basin 1 contents are still discharging.
J •' Thursday, 9/10: Basin 1 still leaking into the Broad River. Landon reports that he has told Horsehead that no
discharge from the Basin is perms until the current inventory in the stormwater system and Basin 1 is
`T normal pH and free of elevated metals. BRADLEY: SEEMS LIKE THIS IS THE TEST OF WHEN THEY CAN
DISCHARGE. JIM NEEDS TO CONVEY THESE RESULTS TO LANDON AND US.
• Friday, 9/11: Horsehead reports they have flushed and neutralized the stormwater piping from the cell house
area to the energy dissipater; adjusted the pH levels in Basin 1; maintained water levels below the breach in the
seal at the cellhouse containment; and are obtaining quotes to repair the defective seal.
• Saturday, 9/12: Horsehead reports leak out of Basin 1 stopped on previous Friday night, 9/11. Horsehead
continuing to vacuum truck water out of Basin 1 and back into the process.
Wednesday, 9/16: Horsehead verbal report that Basin 1 cleaned up & requests permission to bring the storm
system back on line. YESTERDAY'S ASSERTION OF CLEAN UP SHOULD BE CORROBORATED BY ANALYTICALS,
S WHICH SHOULD BE AVAILABLE ON FRIDAY, IF THEY ACTED AS THEY SHOULD HAVE.
• Thursday, 9/17: DEMLR SPP contacted Mr. Harris and began conversation about site conditions; conversation
interrupted. Weather forecast this afternoon for the plant area indicates potential for rain Monday night,
9/21. Conversation to be continued Friday, 9/18.
• Friday, 9/18: Discuss with Jim Harris:
o Please provide us with all metals and pH results on discharges or contained volumes in any way related
to this incident.
of o Photos show large amounts of sediment in the energy dissipater. Have you cleaned that out? It's a
�} potential reservoir for Zn, Pb, Cd.
n o Has the dry weather flow into the energy dissipater stopped?
J o KBP floating an idea: ?????—"Please take pH, Cd, Zn, and Pb analyses daily on every discharge from
�il► Basin 1 for one week starting with the first discharge. Send full EPA Method analyses to Pace labs on
Lj rush processing: find a Hach Kit for metals, or other rapid field measurement method, if available,

and use it for operational guidance concurrent with the approved EPA Method sampling. Report
results daily to RCO and ARO DWR and DEMLR" -- ???
Ken
Ken Pickle
Stormwater Program Specialist
NCDENR I DEMLR I Stormwater Permitting Program
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. [e-mail]
Website: htti)://Portal.ncdenr.org/webOr4stormwater
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
• wi�4- SA"6 H P Do
2

Pickle, Ken
From: Pickle, Ken
Sent: Friday, February 26, 2016 10:46 AM
To: Aiken, Stan E
Cc: Bennett, Bradley; Walker, Fred
Subject: Horsehead spill and Stormwater Permitting Program wrap up for now
Hi Stan,
It's Friday, and I'm trying to wrap-up/nail-down a few issues that crossed my desk over the last couple of weeks,
including our comments on the February spill at Horsehead and the suspension of start-up and manufacturing
activities. I've spoken with Bradley (programmatic concerns) and with Mike Lawyer (experienced in
enforcement/implementation of our permits from a Regional Office perspective.) Most of this we have already covered,
but just in case it comes up again in ARO, here's where I think we should be (based on what I think we know about the
site and spill):
• They have not applied for rescission of the stormwater permit yet, but if they do it would not be automatic for
us. I think there's a reasonable case to be made that we would require them to clean up the site (remove
potential stormwater exposure to our satisfaction) before we would rescind the permit: We have the authority
in federal rule to require continuing permit coverage and compliance even if the -plant shuts down. Continuing
on this idea, ARO or RCO should advise HH that the permit is still in effect until we officially rescind it. Do you
guys want to do that, or would you prefer me to?
• The "Storm Pond" should never discharge directly to surface waters based on our understanding of its use and
contents. Discharge of the fluids in that basin is not authorized under the our stormwater permit, NCS000562.
• With respect to the February 2016 spill:
o The text of the permit requires HH to provide secondary containment. Arguably leaking secondary
containment is no secondary containment, and results in a violation of permit conditions. So, yes there
has been a permit violation. However, 1 have the impression that their response was prettygood, and
that no zinc solution reached the receiving waters. ARO can decide if issuing an NOV/NOD is
appropriate.
o On the same topic, the text of the permit requires the permittee to properly operate and maintain all
systems for pollution control at all times. Again, leaking secondary containment is evidence of the
permittee's failure to properly operate and maintain that control system. Again, again —your call on
how much to make out of this.
o Summary: Yes, the circumstances of the spill amount to a permit violation. The appropriate level of our
response to the violation deserves careful consideration.
I know you all have been out to the site several times during construction and start up, but I don't see a BIMS
entry for a permit compliance inspection. If HH is high on your radar, consider if it's time for a compliance
inspection. The fact that they are shutting down operations might ease our concerns a little, but imo reduced
staff and management attention to the physical plant along with atypical operations (shut down procedures)
would increase our concerns to an even greater degree.
o It might be worthwhile to get copies and review all their stormwater monitoring results as part of the
inspection. (I'd like to see those, too.)
o After the big spill in 2015 HH promised to go around to all the containments and
inspect/repair/revise/address the failure mechanism (seam between tank wall and containment wall)
identified in that spill. Can they provide work orders/logs/ physical evidence that indeed they did that
to a substantial extent?
o Do they intend to do the same thing for the failure mechanism in this second spill (I mean both the
water line break and the containment failure.)

Ken
Ken Pickle
Stormwater Program Specialist
DEMLR Stormwater Permitting Program
Department of Environmental Quality
919 807 6376 office
ken. pickleAncdenr.gov
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury St, Raleigh, NC 27604
h Ol'-
Nothing Compares,..,.
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

y: - L.
Pickle, Ken
From: Pickle, Ken
Sent: Tuesday, February 23, 2016 12:37 PM
To: Bennett, Bradley
Subject: FW: Interpretations of site conditions vs permit requirements, Horsehead Corp, ARO
Hi Bradley,
I spoke with Mike Lawyer about Horsehead. His comments included:
• We shouldn't rescind their permit, even though they are shutting down. I advised that they hadn't requested
rescission, and that my expectation is that significant exposed materials would remain.
• Did they make timely notification of the spills? !advised Yes.
• Sounds like they did just what we would hope they would do in response to a spill. Based on my description of
their response actions on the first spill.
• Note that permit provides they still can't contravene WQS. DWR should pursue this if they're interested, but
not DEMLR.
• Mike concurs that leaking secondary containment is inadequate, and does not meet the permit
requirements. He has encountered this before and required permittees to beef up the secondary
containment to the point of adequacy. I explained the mechanism of the first leak, and that although I don't
know the exact mechanism in the second leak, it was again a containment failure.
• Mike suggested review of the permittee's Spill Prevention and Response Plans to see if they're adequate. I
reported that the spill responses have been good, so far. And that after the first spill HH reported that they
would institute an inspection and repair program specifically targeting the failure mechanism for
prevention. Whether they have followed through with the spill prevention portion or not I don't know. He
suggested we confirm the follow through on the first spill prevention actions.
• Mike suggested review of the permittee's secondary containment design basis. I failed to report to Mike that
HH asserted that the containment has been designed for the 100-yr rainfall — I probably need to check that early
comment to be sure it's still Ifl&—Vdid-coafirm_tkpt the failure mechanism was not overtopping, afaik.
• Mike would consider a CEI. l advised that ARO had been on3it suction, in April20 in
response t he first spill, but not to conduct a CEI.
• Mike would be interested in whether the sampling shows that the facility was meeting the benchmarks
before/after the spills.
(Based on review of permit text, 2F and application materials, SPPP chapter in the Integrated Contingency Plan,
discussion with Mike Lawyer)
• Inadequate secondary containment is a permit violation. Response actions have been very good. KBP
opinion: No further action by DEMLR.
• We/ARO should notify HH that the stormwater permit remai=eforeand
rescind it: and we likely won't
based on our understanding of site conditions.
• We/ARO should review any monitoring results in relation toer the spills.
• We/ARO should confirm that HH subsequently acted to prev t containm�ntfure the mechanism in thefirst spill, and that the mechanism in the second spill will likewise re tative measures at other �` 1
co ments. �— LO RO may want to consider a storm ater CEI.
• The "Storm Pond" should never discharge directly to surface waters based on our understanding of its use and
contents.

• KBP to advise Stan of these conclusions. Bradley, any cautions, comments, or corrections?
KBP
Ken Pickle
Stormwater Program Specialist
DEMLR Stormwater Permitting Program
Department of Environmental Quality
919 807 6376 office
ken. oickle@ncden r.gov
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury St, Raleigh, NC 27604
C
Nothing Compares--,
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Lawyer, Mike
Sent: Tuesday, February 23, 2016 9:32 AM
To: Pickle, Ken <[e-mail]>
Cc: Bennett, Bradley <[e-mail]>
Subject: RE: Interpretations of site conditions vs permit requirements, Horsehead Corp, ARO
Hey Ken. 1 should be in the office today and likely tomorrow as well.
Michael Lawyer, CPSWQ
Environmental Program Consultant
Division of Energy, Mineral and Land Resources I Land Quality Section
North Carolina Department of Environmental Quality
910 433-3394 office
mike. lawyer(a)_ncdenr:gov
225 Green Street, Suite 714
Fayetteville, NC 28301
N- " C.-
��Nothing Compares, -
Email correspondence to and from this address is subject to the
North -Carolina Public Records Law and may be disclosed to third parties.
From: Pickle, Ken
Sent: Tuesday, February 23, 2016 9:08 AM
2

To: Lawyer, Mike <[e-mail]>
Cc: Bennett, Bradley <[e-mail]>
Subject: Interpretations of site conditions vs permit requirements, Horsehead Corp, ARO
Hi Mike,
I'd like to chat with you about the circumstances around a permitted facility in ARO. Are you available over the next
couple of days to speak with me on two issues at the subject facility in ARO?
Background:
o Horsehead Corporation holds our individual stormwater permit NCS000562, issued for the first time April 1,
2013. The facility is sited above the flood plain, on the high banks of the Broad River, just west and south of
Mooresboro, NC. The Broad River is class C at that point.
o They take zinc by-products from manufacturing processes and further refine it into ultra -high purity zinc, for
which there is a very profitable specialty market.
o The construction and start-up have been plagued with problems both wrt production and ironmental. T
plant was moth -balled earlier this month, never having reached full scale production. T e shake -out period jus
stretched on and on.
o We have a report that a portion of the management and engineering staff will remain on site
being. They are not going down to just security staff.
o First issue: There have been at least two spills of zinc -enriched solutions, one earlier this month, and one last
0
year.
o DEMLR ARO and SPP are interested because both spills made it to our site st w �n the
hill o round immediately adjacent to the Broad River. A portion of a first spill passed into e
roa" Riv • he second spill was contained in the `energy dissipater', the oncrete lined first c ber
e stormwater basin (Energy dissipater because: 60" stormwater pipe, S
o DWR ARO surface water and ground water are interested because of the potential for zinc to reach both
the Broad River and ground water. p
o DWR ARO Haz Waste folks are interested because the spilled zinc solution might be onsidered haz �►!
waste now that it has been released to the environment. 1 •[i�
o DWR NPDES has issued a wastewater discharge permit for the fa ut the spill inci en s on't
appear to trigger any concern under the st a e A portion A�permfi.
rst spill reached the
Broad River, and might be considere discharging wastewater withc - a
production area. The basin's primary purpose is to spills for introduction back into the
process (they need rainwater to augment city water in the process.) Discussion has arisen on whether that
stormwater could ever be discharged if it tested clean, given the sloppy operation and presence of process fluids
leaking onto the pavement draining to the pond.
So, my questions have to do with whether you have had opportunity to apply the stormwater permit conditions or
boilerplate to similar spill circumstances. The other ARO Divisions seem to expect DEMLR to act under the
stormwater permit, but it's not clear to Bradley and me where the text might be used to either require action or to be
the basis of an enforcement/NOV/NOD. What portions of the permit text have you used to encourage better
behavior from our permittees?
Please let me know when you can make time to chat.
Thanks,
Ken
Ken Pickle
Stormwater Program Specialist

DEMLR Stormwater Permitting Program
Department of Environmental Quality
919 807 6376 office
ken. [e-mail]
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury St, Raleigh, NC 27604
Nothing Compares.`
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

r
Pickle, Ken
From: Pickle, Ken
Sent: Monday, February 22, 2016 5:50 PM
To: Bennett, Bradley
Subject: FW: Description of Ponds, Horsehead, NCS000562
Bradley,
it looks to me like there are two open items recently raised requiring our review and comment. The first is the spill. The
second is the basin designated as the "Storm Pond", one of four ponds on the west side of the facility. As you suggest,
I'll look again at the permit text, and at the application materials. NCS000562, effective 4/1/2013.
Summary:
• For the spill into the energy dissipater, and whether there is a permit violation:
o Part I Section B authorizes the discharge of stormwater that has been "adequately treated." With
respect to any zinc residuals in the energy dissipater or the rest of Basin #1, until the benchmark testing
is accomplished, we won't have a basis to assess whether or not any zinc residuals from the spill are a
possible cause of violation of the 'adequately treated' requirement.
o Part II Section A requires secondary containment to prevent runoff pollution. Leaking secondary
containment is no secondary containment. The permittee has violated this requirement of the
permit. But, presumably he fixed it right away.
o Part III Section C requires the permittee to properly operate and maintain the systems put in place to
achieve compliance with the permit. We would apply this requirement to the requirement for
secondary containment, and note that he has failed to properly operate and maintain the system. But
again, presumably he fixed it right away.
o Summary: Yes, there's a permit violation as a result of a water line breaking and ineffective
secondary containment. Environmental impact is not yet established.
• For the "Storm Pond" and whether discharges from it are permitted under our permit:
o Not mentioned by name in the text of the permit.
o Not mentioned by name in the application narrative, although the submitted site drawing indicates that
the pond in question is part of the 10-acre Area 200 part of the facility. The whole Area 200 is noted on
the drawing as having recycle back to the process for contaminated stormwater, or controlled release
for tested and confirmed clean stormwater, as are several other areas of the site. The level of detail of
the drawing does not indicate the nature of any effluent structure or piping configurations, either in the
individual containment structures, or in the Storm Pond. As I think I recall from the on -site meeting
previously, site personnel reported that there was a piping connection at the pond, but that it had never
been used, and that it never would be used to discharge stormwater. I conclude that the purpose of this
basin is a manufacturing process purpose, not an environmental or stormwater purpose, despite the HH
name. Note that HH correspondence reports that the facility captures rainfall to reduce reliance on city
water.
o We have an inspection report indicating sediment accumulation in the pond, with the assumed potential
for zinc concentrations.
o Summary: Our permit provides that fluids from secondary containment can be released if found
uncontaminated. I would not consider this Storm Pond a secondary containment. To me, secondary
containment implies limiting the environmental exposure to an area immediately around the tankage
involved. That is not the case here. I think the pond is functioning more for rainfall capture for process
purposes process fluid volume capacitor spill reclaim, and recycle basin. I think there is a very basic

distinction to be made between normally passive, infrequently used, secondary containment for .
environmental protection and a process fluid capacitor.
Ken
BACKGROUND DISCUSSION SUPPORTING THE SUMMARY ABOVE
On the first issue of the spill. I've gone over the Horsehead permit, NCS000562, and see these potential elements of the
permit that might be relevant. The circumstances are: a water line break that filled a containment structure to a point
where a portion of the contents of the containment leaked out through a failed seam between materials, and then got
into the stormwater-only collection system.
• No o help: our permit authorizes stormwater discharges associated with industrial activity, and it does not appear
that the circumstances have resulted in a discharge. (Jeff reports that HH reports that the material was
completely contained in the concrete -lined energy dissipater basin.)
• No help: As to any zinc residuals, the material was pumped out. We would rely on the zinc benchmark in the
permit to control zinc content in any stormwater discharges due to any (presumably?) small amount of
residuals remaining in the energy dissipater structure.
• No help: Part 1 Section B: "Any other point source discharge to surface waters of the state is prohibited unless
it is an allowable non-stormwater discharge or is covered by another permit, authorization, or approval. The
stormwater discharges allowed by this permit shall not cause or contribute to violations of Water Quality
Standards." Again, in the first sentence, there was no discharge. In the second sentence no evidence of a wqs
violation from the non -discharge.
• No help: Part IV Definitions: "Allowable Non-Stormwater Discharges This permit regulates stormwater
discharges. Non-stormwater discharges which shall be allowed in the stormwater conveyance system are:
a. All other discharges that are authorized by a non-stormwater NPDES permit.
b. Uncontaminated groundwater, foundation drains, air -conditioner condensate without added chemicals,
springs, discharges of uncontaminated potable water, waterline and fire hydrant flushings, water from
footing drains, flows from riparian habitats and wetlands.
c. Discharges resulting from fire -fighting or fire -fighting training, or emergency shower or eye wash as a result
of use in the event of an emergency."
But, again, without a resulting discharge, I question whether this part of the permit is triggered.
No help: With respect to any portion of the original application submittal, there are portions that speak in a
limited way to provisions for spills. Form 2F in four places reports that, "Material exposed to stormwater will be
minimized, and when necessary will be managed to avoid potential impact to stormwater discharged from the
facility." (2F, IV B). "This scheme for managing stormwater in the production area of the facility and other areas
of the property will minimize the potential for pollutants to enter stormwater that is discharged from the site."
(2F, IV Q. "Materials will be managed to prevent the potential for entry, in stormwater that is discharged from
the facility." (2F, Vll E). "The facility is designed and will be constructed and operated in a manner to minimize
the potential for materials to enter stormwater that is discharged." (2F, VII Q. So, the application states that
HH will manage the materials and stormwater, and will also design and construct the facility, to prevent the
discharge of polluted stormwater. Those statements might together be construed to say that spilled
materials would not be transported off site in a stormwater discharge. But again, without a resulting
discharge, the reasonable interpretation might be that the facility indeed managed the spill to prevent the
discharge of site stormwater containing the spilled materials.
Some help: Part I Section B: "Until this permit expires or is modified or revoked, the permittee is authorized to
discharge stormwater to the surface waters of North Carolina that has been adequately treated and managed in
accordance with the terms and conditions of this permit." Vague "adequately treated and managed" offers some
direction, but would be hard to definitively pin a violation on HH, imo. I think the probable measure of

r-=
"adequately treated" is the discharge concentration of Zn. If the zinc concentration is over benchmarks, and if
the exceedance might be attributable to the spill from the WOX containment, then the spill might be the basis
for asserting that the permittee did not adequately treat and manage his stormwater discharge.
• Some help: Part II Section A SPPP: "Secondary Containment Requirements and Records. Secondary
containment is required for: bulk storage of liquid materials including petroleum roducts; storage in any
amount of Section 313 of Title III of the Superfund Amendments and Reauthorization Act (SARA) water
priority chemicals; and storage in any amount of hazardous substances, in order to prevent leaks and spills
from contaminating stormwater runoff. A table or summary of all such tanks and stored materials and their
associated secondary containment areas shall be maintained. if the secondary containment devices are
connected to stormwater conveyance systems, the connection shall be controlled by manually activated
valves or other similar devices, which shall be secured closed with a locking mechanism. Prior to release into
the stormwaters conveyance system, any stormwater that accumulates in containment areas shall be at a
minimum visually observed for color, foam, outfall staining, visible sheens, and dry weather
flow. Accumulated stormwater may be released if found to be uncontaminated by any material." The leaking
secondary containment system has failed this part of the permit requirements, since leaking secondary
containment Is no secondary containment. Failure to provide secondary containment would be a permit
violation.
• Some help: Part III Section C Boilerpate: " Proper Operation and Maintenance The permittee shall at all times
properly operate and maintain all facilities and systems of treatment and control (and related appurtenances)
which are installed or used by the permittee to achieve compliance with the conditions of this
permit." Possibly we could propose that the permittee has not complied with this permit requirement since
leaking secondary containment is not proper operation and control of the systems installed to achieve
compliance with the permit.
With respect to the basin designated as the "Storm Pond" and any discharge from it:
• The text of the permit does not speak to such a pond by name. Nor by any indirect reference.
• However, note that the face of the permit references GS 143-215.1 which establishes the requirement for a
permit, and from which 15A NCAC 2H .0126 springs which incorporates by references 40 CFR 122.26which
authorizes "discharges composed entire!y of storm water", which is the basis for us casually characterizing our
permits as "stormwater-only" permits. All to say that if this pond has any process fluid flowing into it, it can't
be discharged under our permit. But, we do have a confusing circumstance with area drainage from the sloppy
areas of the facility. If that material produced by operations sloppiness is transported by runoff into the Storm
Pond, can it be discharged under our permit, assuming it would be found to be uncontaminated? Even so, it is d
not clear that the Storm Pond is equipped with a discharge line to our Basin #1 along the Broad River.w'� n
The HH application materials describe four categories of flows that might be generated at the site S�
o HH uses the term `discretionary storm water" for r ' in�dischar
as will be collected,
and tested and potentially used in the process, or reated prior r released as stormwater.
o HH further intends to collect rainfall from certain ther process areas and al ays use the water as part
of the process.
o Additionally, HH uses the term "non -discretionary storm w infall originating on the perimeter
roadways, commercial areas, and roof tops of the site, but without contact with the industrial
processes. Such flows will be discharged directly to the stormwater outfall.
o Rainfall originating from undeveloped areas (fill and vegetated areas not affected by plant activities) will
be essentially treated as not qualifying as regulated stormwater, and will be discharged unmanaged as
the terrain dictates.
o None of the HH categorizations above specifically identifies the "Storm Pond."
o While these are HH classifications, they mean nothing to us except insofar as the containment structure
liquids are stormwater-only liquids, testing clean. Our permit only authorizes stormwater-only
discharges, free of any contamination
The HH 2O13 Integrated Contingency Plan covers the SPPP requirements in Chapter 4.0.
3

n►,
o Paragraph 4.2.2 reports that, 'Th e are no seconds containment areas th are connected to'storm
water conveyance systems. A portable hose will be used to transfer water from the secondary containment
to the storm water system, if needed. Storm water that accumulates in the containment areas will be
visually observed and tested to ensure contaminants are below permit limits before being released to the
storm water conveyance system." This entry would be consistent with our permit requirements for
secondary containment.
Ken Pickle
Stormwater Program Specialist
DCMLR Stormwater Permitting Program
Department of Environmental Quality
919 807 6376 office
ken. gickle(a ncdenr.gov
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury St, Raleigh, NC 27604
h - M-:.
Nothing Compares
Email correspondence to and from this address is subject to the
North Carolina Public Records Caw and may be disclosed to third parties.
From: Pickle, Ken
Sent: Friday, February 19, 2016 1:47 PM
To: Davidson, Landon <[e-mail]>; Menzel, Jeff <[e-mail]>; Burch, Brent
<[e-mail]>; Heim, Tim <[e-mail]>
Cc: Bennett, Bradley <[e-mail]>; Aiken, Stan E <[e-mail]>
Subject: FW: Description of Ponds
Hi guys,
Thanks for bringing us up to speed. I'll talk with Bradley a little more about this over the next few days to see what/if
this may mean under our permit coverage of Horsehead.
Ken
Ken Pickle
Stormwater Program Specialist
DEMLR Stormwater Permitting Program
Department'of Environmental Quality
4

. #'It
n ,,
919•807 6Z76 office
ken. ickle ncdenr. gov
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury St, Raleigh, NC 27604
h 0`1_
-5>*Nothing Compares
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Davidson, Landon
Sent: Friday, February 19, 2016 1:26 PM
To: Menzel, Jeff <Ileff.menzel@ncdenr.,gov>; Burch, Brent <brent.burch00ncdenr.gov>; Aiken, Stan E
<[e-mail]>; Pickle, Ken <[e-mail]>
Cc: Heim, Tim <Tim.Heim @ncdenr.gov>
Subject: RE: Description of Ponds
To all,
Thanks Jeff. This is a good revision or correction to my email from yesterday. This sentence regarding the stormwater
pond: Most likely there is zinc and other constituents within this sediment the concentrations are not known of this time.
could suggest a potential violation of the stormwater permit? Does there need to be more investigation into how the
ponds, or at least the SW capture pond, is being used and its connection to stormwater outlets? I just don't have the
background on the SW side for this type of facility where SW is captured in ponds that are bled into a process and if
recycling occurs in that same pond.
G. Landon Davidson, P.G.
Regional Supervisor —Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4680 office
828 230 4057 mobile
Landon. [e-mail]
2090 U.S. Hwy. 70
Swannanoa, N.C. 28711
Nothing Compares--,.,
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Menzel, Jeff
Sent: Friday, February 19, 2016 11:39 AM
To: Burch, Brent <[e-mail]>
Cc: Davidson, Landon <[e-mail]>; Aiken, Stan E <stan.aiken@ncdenr,j%ov>
Subject: Description of Ponds

On the West side of the HH property there is a series of 4 lined ponds. Starting south and going north the ponds are
called the following names; Storm pond, West Maintenance Pond, Raffinate Pond, and Depleted Solution Pond.
Storm Pond. Collects storm water from the road ways on the western half of the property. Collected storm
water than can be introduced into the process as needed or if there is a surplus after a storm event the water is
routed through bleed treatment and discharged as wastewater. There is approximately 3 to 4 feet of material in
the bottom of this pond consisting of sediment introduced during construction and process materials
introduced through spills, tracked materials washing off roadways, etc. Most likely there is zinc and other
constituents within this sediment the concentrations are not known at this time.
2. West Maintenance Pond. This pond was designed to collect storm water and process materials
.within secondary containment units on the west side of the property. This water can be introduced back into
the process to recover process materials.
I am unsure the extent of sedimentation within this pond.
3. Raffinate Pond. Collects water from the 200 Area Raffinate secondary containment. Can be introduced back into
process.
4. Depleted Solution Pond. Spent electrolyte solution can be introduced back into process to be combined with
organic solvent to hold the purified zinc in solution or can be routed through bleed treatment to remove built
up impurities or contaminants.
During this idling period the facility will have to continue to process storm water on the west side of the property. They
will do this by collecting the water from west roadways and containment units, routing storm water to the -Storm and
West maintenance ponds, and then processing in the bleed treatment process to be discharged from their 001
wastewater outfall. Other parts of facility which will also have to remain active during this time included units which
process the organic solvent solution and the zinc furnace.
There was a release this week to storm water Basin 1. The spill was contained in the energy dispersion unit. A 2" city
water line broke around 5 am this water flowed into the WOX silos containment. A leaked then occurred in the WOX
silo containment wall seam and the water made its way into the storm water system on the east side of the property.
The concrete energy dispersion unit collected the water and they were able to pump and haul from this unit so there
was no discharge to the other parts of the storm water basin.
Jeff Menzel
Western Region Environmental Specialist
Hazardous Waste Section
Division of Waste Management
828 419 5034 office
919 270 1967 cell
[e-mail]
PO Box 1568
Black Mountain, NC 28711
—/`Nothing Compares
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
6'

T010'MY R. 13ASILONE
ylre Predderd - Grrdnungrnlal Affid?9
4955 STEUOEHVILLK PIr<E V1WW.HOR%&H6AO.N9T 724.773,2223 �I A�-
SUITE 4GS TPASILONEGHOnSE"EAO.NEF 412.7e8.4526 =jA�B
PITTSOURGH, PA 1520E CO€ PONZATION
June 13, 2011 Lrnding lire World In Zine Reeyefrng
Mr. Charles Wakild, Deputy Director
North Carolina Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: May 9, 2011 Meeting
Division of Water Quality
Ho -sehead Corporation, Proposed Production Facility, Rutherford County
Stormwater NPDES Permitting and 401 Certification Processes
Dear Mr. Wakild:
I'd like to thank you and others from NCDWQ, including Mr. Matt Matthews, Ms.Cyndi
Karoly, Mr. Bradley Bennett, Dr. Sergel Chernikov and Mr. Ken Pickle, for giving
Horsehead Corp. (Horsehead) the opportunity to meet with you on May 9, 2011 and
discuss the potential plans for constructing a zinc production facility In Rutherford
County, North Carolina. Horsehead and our consultant, McGill, Associates, appreciate
information you provided concerning stormwater NPDES permit issues and the 401
certification processes. You provided valuable information with regard to requirements
dealing with these subject areas that would apply to Horsehead's proposed facility.
At the meeting, Horsehead provided a summary of the company's business, a description
of the new plant and processes involved to produce zinc metal, and noted the importance
of this new production facility to our business plan. As we indicated In our meeting,
understanding the permitting process and securing necessary permits in a timely manner
for the sites under consideration is a critical component in making a decision as to the site
that will be selected for this facility,
The PowerPoint presentation provided at the meeting contains business confidential
information, A copy of the presentation was not provided to you, but we request that key
production process design information for the facility and site be protected under State
and Federal law, and that this information be treated as Business Confidential.
As we pointed out during the meeting, the information provided about the facility and the
site is preliminary and represents a general description of the operation of this proposed
facility. We are continuing with our facility design efforts and establishment of the final
operating criteria for the plant. Horsehcad and associated consultants for this project are
available to answer any questions that you may have and welcome the opportunity to
discuss storniwate• and 401 permitting requirements for the proposed facility.
,Z

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

♦ NCDWQ appointed Mr. Ken Pickle as the primary point of contact for
communication on the stormwater permit application process,
♦ Horsehead will submit a stormwater permit application for the site as soon as the
final site facility layout plan is completed. This is expected to occur in the early
fall,
♦ Following submittal of a complete application NCDWQ advised that three to four
months would be required for the development of a final draft permit for public
notice under State requirements,
♦ Horsehead anticipates that the only stream/wetland impacts under Sections 404
and 401 of the Clean Water Act to be for an effluent discharge outfall structure on
the Broad River and possibly a water intake structure for process water on the
River both of which likely can be covered under the Corps of Engineers .
Nationwide Permit for utility activities and North Carolina's General Certification
for these activities,
♦ it is understood that a complete site evaluation for waters and wetlands will need
to be performed, and Horsehead will obtain such information before finalization
of any applications,
♦ NCDWQ agreed to work in coordination with Horsehead to secure a complete
401 Certification application once final proposed impacts can be established,
♦ Based on the identified impacts, NCDNR and Horsehead will establish quick
response lines of communication by e-mail and phone to resolve any questi6s
about the application and the processing of a final 401 Certification,
♦ Ms. Cyndi Karoly, NCDWQ Branch Chief for the stormwater and 401 programs
will be the initial point of contact, the review process will be assigned to the
appropriate staff for the stream/we€land impacts that are planned,
♦ NCDWQ indicated that all communication with Horsehead related to any
comments received from staff or the public would occur in a timely manner, and
that if further public review was required, the Division would move this process
along as quickly as possible to a final determination on pending approvals and
permits.
Mr. Ken Pickle has already provided several pieces of information and feed -back
following our meeting. We appreciate his responsiveness in helping us to develop our
approach to stormwater management on the site.
Commitments made by the NCDNR during our meeting provide information that is
critical for completing our site evaluation process. Horsehead looks forward to working
with the NCDNR on this important project. As you are aware, this new production

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facility represents a large commitment of resources and technology by Horsehead for the
production of zinc and other non-feirous metal products.
In relation to permitting requirements under the stormwater program, McGill Associates
will serve as our primary resource for development and submittal of a complete permit
application. Mr. FoiTest Westalf at McGill Associates will assist in coordinating
information flow between Horsehead and the NCDNR. Mr. Westall can be contacted at
828.231.6840 (cell) or 828.252.0575 (office),
We appreciate your assistance and that of NCDWQ's staff in helping us to define the
stormwater permitting requirements for this site. Please feel fi-ee to contact me with any
questions you may have.
Sincerely,
Timothy R. Basilone
cc Foirest Westall, McGill Associates
Darin Cooper, Horsehead Cofp.

r
r ,
October 9, 2015
Via Electronic Mail Qandon.davidson (a7ncdenngov) and U.S. Mail
Mr. G. Landon Davidson
North Carolina Department of Environment and Natural Resources
Water Quality Regional Operations
Asheville Regional Office
2090 U.S. Highway 70
Swannanoa, NC 28778
Re: Notice of Violation/Notice of Intent to Enforce
NOV-2015-DV-0188 (B1MS Inc. -9201501151)
Rutherford County
Dear Mr. Davidson:
On September 24, 2015, Horsehead Metal Products, LLC (Horsehead) received the above -
referenced Notice of Violation/Notice of Intent to Enforce (NOV) related to a release of low pH
solution at the Mooresboro facility. As requested, this letter provides a report assessing the
cause, significance, and extent of the release and a plan listing all actions to prevent future
releases.
With respect to the allegation of discharge in violation of G.S. 143-215.83, the release of the
solution from the cellhouse containment was mitigated such that any discharge to the Broad
River would not have resulted in a violation of G.S. 143-215.83. Specifically, the definition of
"discharge" in Article 21a of Chapter 143 provides in relevarit part as follows;
"Discharge" shall mean, but shall not be limited to, any emission, spillage,
leakage, pumping, pouring, emptying, or dumping of oil or other hazardous
substances into waters of the State or into waters outside the territorial limits of
the State which affect lands, waters or uses related thereto within the territorial
limits of the State, or upon land in such proximity to waters that oil or other
hazardous substances is reasonably likely to reach the waters, but shall not
include amounts less than quantities which may be haimful to the public health or
welfare as determined Dursuant to G.S. 143-215.77A;
G.S. 143-215.77(4). Section 143-215.77a provides that quantities of designated hazardous
substances for purposes of this Article are the quantities of designated hazardous substances as
established by the EPA pursuant to Section 311 of the Clean Water Act. The EPA has
promulgated the quantities for designated hazardous substances at 40 C.FR § 117.3. The
regulatory quantity for sulfuric acid is 1,000 pounds. Given the concentration of sulfuric acid in
the released process solution and the subsequent efforts to mitigate any portion of the release

H ORSHEAO M ETAL PRO[?IiCTS, INC.
....._ ... ..:;,a �S��H9GKSG�tOVE`ROA_ D ..`.:.....''.
MOOIiESBORO, NORTH CAROL[NA 28114
which reached the stormwater system, there is no reasonable potential that the regulatory
quantity for a "discharge" under G.S. 143-215.77a could have been released to the Broad River.
Upon discovery of the lower than typical pH in the energy dissipater on September 5 2015, plant
personnel closed the main Eate valve at the outfall to the Broad River an the gate valve on the
energy dissipater at Basin 1. The energy dissipater is the first stricture in the Basin 1 system and
serves to slow stormwater as it enters Basin 1. Since there had been an extended period without
any substantial rainfall prior to September 5, 2015, Basin 1 was empty and no discharge to the
Broad River occurred to that point in time. The gate valves at the energy dissipater an asin 1
remained closed throu ut the investi ation of the source of the lower than typical pH.
Following a rain event on September 9 2015, approximately 200,000 gallons of � was
remov truck from Basin 1. This water was recycled for use in the plant process.
Additionally, sediment in the en Lr&y di ipater-and sedim nLin Basin 1 with an visa aim acts
from the solution release were removed and placed in roll -off cant ' s. Although the gate
valve at Basin 1 remained closed, a leak near the gkte valvp in the dischar a eture as
discovered which allowed water from the basin to be discharged to tho BmadBiYe .,` While the
leak continued until a repair was completed at 7 p.m. on September 11, the remediation of the
sulf uk-,azid-soluliopreleased to the stormwater system was conclud on Se tember and
thus mitigated any impacts to the stormwater in Basin 1 such drat the quantity of sulfuric acid
discharges would not have reached the regulatory quantity for a "discharge" in violation of G.S.
143-215.83,
Additionally, despite any elevated concentrations of cadmium, lead and zinc in the water sample
referenced in the NOV, these elevate nge
pursuant to G.S. 143-215.83. These metals go covered by the benchmark aumarin
re uirements under NPD Storm a 056 , and therefore any elevated 0 n� 5
levels of these metals would be addressed under the terms of that Permit. As such, any discharge
with these elevated metals would not be a discharge in violation of G.S. 143-215.83.
1. Report on the Release
On the evening of September 5, 2015, plant personnel identified a potential problem during the
course of routine inspection at Basin 1 of the facility stormwater system. Using a basic pH
testing strip, testing indicated a pH less than 6.0 Standard Units in the stormwater entering the
energy dissipater which is the first structure in the Basin 1 systeni.1 Further investigation
indicated that the source of the subject water may have been material inadvertently making its
way into the storm drain system from a malfunctioning pump in the vicinity of the celihouse
earlier that day, On September 6, 2015, testing of water entering the energy dissipater again
indicated a lower than typical pH. A subsequent investigation was undertaken to identify the
source of water entering the stormwater system. This investigation revealed water entered the
i Basin 1 is a sedimentation basin, and the energy dissipater serves to slow stormwater entering Basin 1.
Business Confidential Information
;J I

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

HIIR$EHEAD METAL PRDDUCTS, INC.
GAROUINA 2$1 14
Although plant personnel could not determine whether a reportable quantity of sulfuric acid had
been released, Horsehead called the NRC as a precautionary measure on September 9, 2015 at
3:30 pm, to advise the agency of the apparent release of process solution from the base of
secondary containment structure. After the call to the NRC, Horsehead notified the DENR
Regional Office by telephone. We understand that DENR notified the Forest City Fire
Department,
All secondary containment structures in the facility are constructed of reinforced concrete with
containment sizing based on 110% of the largest tank in the containment. Following the
discovery of the unsealed joint in the containment area under the cellhouse, Horsehead engineers
and maintenance personnel confirmed that no other areas in the facility have similar seal
problems.
Based on the available information, any discharge of the solution from the cellhouse containment
area to the Broad River was minimized through mitigation efforts following the initial discovery
of low pH at the energy dissipater. As soon as the low pH condition of water entering the energy
dissipater was detected on September 5, 2015, plant personnel closed the main gate valve at the
outfall to the Broad River and the gate valve on the energy dissipater at Basin 1. Since there had
been an extended period without any substantial rainfall prior to September 5, 2015, Basin 1 was
empty and no discharge to the Broad River occurred to that point in time.
As noted above, on September 9th and loth, a rain event of approximately 0.7 inches of
�s precipitation occurred and stormwater entered Basin 1. At the time, the main gate valve on the
stormwater discharge outfall was closed and the water was retained in the basin. On September
9, 2015, a leak near the gate valve in the discharge structure was discovered which allowed water
from the basin to be discharged. Water discharged from the discharge structure was tested for
pH and found to be below 6.0 Standard Units. Vacuum trucks were mobilized to remove water
from Basin 1. &Qgyo water was re� c d for use in the plant process.
The small leak that allowed water to enter the Broad River resulted fiom a crack in the concrete
box that serves as the housing for the main gate valve. Hydraulic cement was used to seal the
crack and stop water from leaking through the concrete wall. These repairs were completed on
Friday, September 11, 2015, at approximately 7 p.m.
We determined that water at the concrete discharge structure entered the Broad River fiom mid-
day on September 9th until 7 p.m. on September 11. The duration of the leak was 55 hours. We
estimated the flow rate from the leak to be 10-15 gallons per minute (GPM). Sample analytical
results showed water discharged to the Broad River contained 3.36 mg/L cadmium, 0.541 mg/L
lead and 685 mg/L of zinc.
Business Confidential Information

HORSEHEAD METAL PRODUCTS, INC J
ll$4,HICKSRO_ vEROAp.<;.= �J,'- l
MOORESBORO, NORTH CAROLINA 28114 ., 1Nc' '
2. Plan to Prevent Future Releases in Containment Areas
The following actions have been implemented to prevent a future releases:
As noted above, the defective joint in the containment area under the cellhouse in Area
200 has been repaired. Inspections will be performed on the containment areas for
cracks and repairs will be made as required.
A high level alatin will be installed on the cellhouse contaimnent to alert personnel if
liquid levels are elevated so action can be taken to draw the level down.
Weekly inspections have been initiated at the inlet and outlet of Basin 1, including
field tests for pH.
Horsehead remains committed to operating in a manner protective of the environment and
appreciates the Department's continued assistance as we continue through the startup phase at
the Mooresboro facility. If additional information is needed in support of this request, please call
me at 828-919-3139.
Sincerel ,
Jim Harris
Environmental Manager
Business Confidential Information

m
..........

Table 2
Significant Stored Materials: Containerized Stored Materials
American Zinc Products Inc.
Mooresboro, North Carolina Facility
Description
Tank,
yellow/shaded bkgd. = bulk oil
storage
CITY
Area
Capacity
��<
Containment
QVerfIIllQVerflow
Storn,water Exposure/Controls
Container # :
bold =oil -filled operating or
(Gals)
Method
manufacturing equipment
No exposure, all water (considered
High level alarm
process water) and product is
DC-101 A 11
LEACHING/NEUTRALIZATION
Diked
system in the
contained and placed in process,
F
REACTOR
6
0100
119156
concrete area
operations control
water is used to substitute for
with sump
required city water. Inspection and
room.
monitoring by Operations personnel
daily.
No exposure, all water (considered
High level alarm
process water) and product is
FIRST WOX WASHING
Diked
system in the
contained and placed in process,
DC-104
REACTOR
1
0100
34924
concrete area
operations control
water is used to substitute for
with sump
required city water. Inspection and
room,
monitoring by Operations personnel
daily.
No exposure, all water (considered
High level alarm
process water) and product is
SECOND WOX WASHING
Diked
system in the
contained and placed in process,
DC-105
REACTOR
1
0100
12686
concrete area
operations control
water is used to substitute for
with sump
required city water. Inspection and
room,
monitoring by Operations personnel
daily.
No exposure, all water (considered
High level alarm
process water) and product is
AREA 100/300
system in the
contained and placed in process,
FA-101
MAINTENANCE POND
1
0100
166340
operations control
water is used to substitute for
required city water. Inspection and
room.
monitoring by Operations personnel
daily. INeed to ver:
�ajt kej ? I — - . — . -
2-1

Description
Tank
yellowlshaded bkgd. = bulk oil
storage
OTY
Area,
Capacity
Containment
Overlfill/Overt dw
=
Stormwater Exposure/Controls
Container #
bold = oil -filled operating or
{Gals)
Method
manufacturing equipment
No exposure, all water (considered
High level alarm
process water) and product is
UN THICKENER
Diked
system in the
contained and placed in process,
FB-114
UNDERFLOW PRESS FILTER
1
0100
11646
concrete area
operations control
water is used to substitute for
FILTRATE TANK
with sump
required city water. Inspection and
room.
monitoring by Operations personnel
daily.
No exposure, all water (considered
High level alarm
process water) and product is
UN THICKENER
Diked
system in the
contained and placed in process,
FB-116
UNDERFLOW PRESS FILTER
1
0100
449
concrete area
operations control
water is used to substitute for
CORE SEPARATION TANK
with sump
required city water. Inspection and
roam.
monitoring by Operations personnel
daily.
No exposure, all water (considered
High level alarm
process water) and product is
OXIDIC FINES DC-101A
Diked
system in the
contained and placed in process,
FF-110
REACTOR FEED BIN
1
0100
928
concrete area
operations control
water is used to substitute for
with sump
required city water. Inspection and
room.
monitoring by Operations personnel
daily.
No exposure, all water (considered
High level alarm
process water) and product is
OXIDIC FINES PRE-
Diked
system in the
contained and placed in process,
FF-111
DIGESTION FEED BIN
1
0100
928
concrete area
operations control
water is used to substitute for
with sump
required city water. Inspection and
room.
monitoring by Operations personnel
daily.
No exposure, all water (considered
High level alarm
process water) and product is
system in the
contained and placed in process,
FA-300
OFF -SPEC EFFLUENT POND
1
0100
1362018
operations control
water is used to substitute for
required city water. Inspection and
room.
monitoring by Operations personnel
daily.
2-4

Description
Tank
Container #
yeuowlshaded bkgd. = bulk oil
storage
QTY
Area
Capacity"
Containment
Overtilllwerflow
s
Method
Stormwater Ex posurelCootrols
bold =oll-filled operating or
(Galsj,
manufacturing equipment
No exposure, all water (considered
High level alarm
process water) and product is
Diked
system in the
contained and placed in process,
FA-211
CRUD TREATMENT TANK
1
0200
23674
concrete area
operations control
water is used to substitute for
with sump
required city water. Inspection and
roam.
monitoring by Operations personnel
daily.
No exposure, all water (considered
High level alarm
process water) and product is
ORGANIC REGENERATION
Diked
system in the
contained and placed in process,
FA-213
MIXER
1
0200
1780
concrete area
operations control
water is used to substitute for
with sump
required city water. Inspection and
room.
monitoring by Operations personnel
daily.
No exposure, all water (considered
High level alarm
process water) and product is
system in the
contained and placed in process,
FA-219
SX MAINTENANCE POND
1
0200
223402
operations control
water is used to substitute for
required city water. Inspection and
room.
monitoring by Operations personnel
daily.
No exposure, all water (considered
High level alarm
process water) and product is
Diked
system in the
contained and placed in process,
FA-224
DRAIN TANK FROM FE-214
1
0200
1833
concrete area
operations control
water is used to substitute for
with sump
required city water. Inspection and
room.
monitoring by Operations personnel
daily.
No exposure, all water (considered
High level alarm
process water) and product is
Diked
system in the
contained and placed in process,
FA-226
DRAIN TANK FROM FE-210
1
0200
1833
concrete area
operations control
water is used to substitute for
with sump
required city water. Inspection and
room.
monitoring by Operations personnel
daily.
2-7

INTEGRATED CONTINGENCY PLAN
AMERICAN ZINC PRODUCTS LLC FACILITY
MOORESBORO, NORTH CAROLINA
MAY 2017
AREA 600 — PLINT
PLINT is a process for recovering lead and silver from residues from the leaching process and area 100.
The product is lead / silver concentrate (suitable for smelting) from the MZP leaching residue. To achieve
this objective, the PLINT Process includes four unit operations.
• Leaching
• Precipitation
• Purification
• Brine Conditioning
AREA 700 — REAGENTS PREPARATION AND DISTRIBUTION
Area 700 is designated for reagents preparation and distribution to the MZP Plant. This area is also used
for storage of reagents and effluents, classified according to uses in the different areas.
In addition to process materials and end -products in area 700, there are various quantities of oils,
solvents, paints, chemical reagents, cleaning agents, anti -freeze, etc., stored in small quantities
throughout the laboratory, maintenance, and production facilities.
In the EW area, parking lots and surrounding non -operating areas, surface drainage is routed from
surface drains through underground pipes to the primary retention basin designated as Basin 1, located
by the river. The SX manufacturing area includes containment areas to hold rainwater until the
accumulated water can be pumped over to the maintenance pond and used in the production process.
My understanding is there will not be any release from the "stormwater containment areas -except was is
pumped to the maintenance pond. The RO should review the records as to when water is pumped, when
levels are too high_ to retain a 25 year— 24 hour storm event with an additional 1 foot of free board
{around 16 inches)..
We also need to review records that verify the integrity of the containment area, i. e., the liners.; and
A "Contingency Plan" to ensure the levels in the containment ponds are dropped to a safe level to prevent
overflows into or from each containment area for the 25 year — 24 hour storm as well as for larger events
that can be predicted._"
The facility has an NPDES stormwater permit for discharging stormwater from Basin 1 into the Broad
River. The permit -required sampling and testing process is in place, and meets the permitted and
state/federal requirements.
Figures 2 through 11 provide a layout of the facility, including the location of each container storing oil or
other significant materials. In addition, Figure 12 illustrates stormwater drainage pathways and collection
basins. A list of significant stored materials is provided on Tables 1 and 2.
10

INTEGRATED CONTINGENCY PLAN
AMERICAN ZINC PRODUCTS LLC FACILITY
MOORESBORO, NORTH CAROLINA
MAY 2017
2.3.2.1 Discharge Prevention
Procedures have been established for routine handling of oil and other materials and to reduce the
likelihood of a release of material to the environment. Trained employees are present to witness all
transfer operations. All active storage and operational areas of the facility are visually inspected during
normal operations.
2.3.2.2 Discharge Drainage Controls
A release of oil or other materials within the manufacturing area would be contained within containment
areas and pumped back to the process. Stormwater is controlled within containment areas and sumps
within the process area, and used to supply water for manufacturing. Stormwater falling on the property
in areas outside of the manufacturing area flows through drainage piping to the Basin 1 retention pond.
If oil or other materials outside the manufacturing area (from parking lots, roadways, etc.) are released to
the stormwater piping, Basin 1 would provide temporary retention of the release while the facility
personnel respond with cleanup/containment equipment.
2.3.3 Countermeasures for Discharge Discovery, Response and Cleanup
h 12.7(a)(3)(iv)]
This subsection describes actions to be taken by facility personnel in response to injuries, accidents, fires,
explosions, other emergencies, or an unplanned release of hazardous waste, hazardous material, or oil to
the environment (air, soil, or surface water).
A minimum of 2 feet of aisle space is maintained throughout the facility to allow the unobstructed
movement of emergency response personnel and equipment in the event of an emergency.
2.3.3.1 Emergency Coordinators/Contacts
A list of Emergency Coordinators and emergency contacts can be found in the EAP section at the front of
this ICP, beginning on page EAP-i.
2.3.3.2 Emergency Coordination
Someone????? The RO will need to review all training records including who conducted the training,
their qualifications, who needs to be trained, what they are trained on, copies of the training material used
and documentation when the training was held and who attended the training..
As soon as an emergency situation is encountered by someone on site, that person shall promptly
estimate the extent of the problem, implement immediate actions to control the situation in a safe manner,
as described below in Section 2.3.3.3, and then immediately notify their supervisor if available, or the
Security Officer 1 Scale House Clerk, who will contact an Emergency Coordinator. Once the Emergency
Coordinator is notified, personnel will respond under the direction of the Emergency Coordinator, based
on the type of emergency, individual skills, training, and facility responsibilities.
12

INTEGRATED CONTINGENCY PLAN
AMERICAN ZINC PRODUCTS LLC FACILITY
MOORESBORO, NORTH CAROLINA
MAY 2017
Also reference Tables 1 and 2 for a summary of the significant materials stored in the various areas,
containment, leak detection methods, and pollution prevention controls.
2.7 Containment and/or Diversionary Structures or Equipment to Prevent Discharge
[112.7(c)]
As described in previous sections, the release of material from storage areas at the facility is prevented
primarily by secondary containment and spill response. Tables 1 and 2 provide a description of the
containment and/or diversionary structures present for oil storage and all other stored materials.
Rainwater falling into chemical storage tank areas is collected in secondary containment and routed for
use in the manufacturing operation. Rainwater may be discharged to the stormwater system after being
tested to ensure that it meets the criteria for the limits of the discharge permit.
RO will need to verify what test are performed and whether or not the test are adequate.
An unlikely release may occur from transformers located on site, due to external rust or corrosion of the
case; or small crack failure associated with seams, covers, or connectors. Oil released from a
transformer would likely be a small volume. Rust or corrosion that could result in a release of oil will be
observed and mitigated as a result of formal and informal inspections of these areas and equipment, as
described in Section 2.9.
The facility may accumulate hazardous waste on site for less than 90 days, in accordance with Title 15A
NCAC 13A.0107. Material that cannot be recycled back to the process on site or at other facilities will be
managed for disposal. A minimum of two feet of aisle space will be maintained between containers in
waste storage areas to allow the unobstructed movement of personnel, fire protection equipment, spill
control equipment, and decontamination equipment to any area of facility operation in an emergency.
Containers holding hazardous waste will be kept closed when not in use.
2.8 Demonstration of Practicability [112.7(d)]
Adequate controls are established to prevent discharge of materials to the environment, as described at
40 CFR Part 112.1(b).
2.9 Inspections, Tests, and Records [112.7(e)]
Written procedures for inspections, testing, and record keeping requirements are described below.
I nsr)ections
Informal/undocumented visual inspections will periodically be conducted to detect faulty equipment, leaks,
or hazards. In particular to the main processing areas, process equipment, chemical storage tanks and
piping will be inspected by personnel working in these areas. Unusual circumstances which cannot be
immediately corrected will be reported to management.
25

INTEGRATED CONTINGENCY PLAN
AMERICAN ZINC PRODUCTS LLC FACILITY
MOORESBORO, NORTH CAROLINA
MAY 2017
Findings will be documented for inspections conducted in material handling and storage areas and for the
following purposes.
• RCRA Waste Storage Area Inspection. Weekly inspection of satellite and accumulation
areas for hazardous wastes (if present).
• Housekeeping. Daily inspections of recyclable materials, solid non -hazardous waste
storage areas, and truck off-loading areas.
• Environmental Inspection, Inspections of the facility and all stormwater conveyance and
control systems will occur as part of the Good Housekeeping Program for Operations. In
addition, the environmental department will address all stormwater control systems, the
stormwater discharge outfall, all on -site and adjacent surface waters and wetlands,
industrial activity areas (including material storage areas, material handling areas, disposal
areas, process areas, loading and unloading areas, and haul roads), all drainage features
and structures, and structural BMP's.
• Universal Waste. Weekly inspection of universal waste storage areas (batteries and
lamps).
• Used Oil. Weekly inspection of used oil storage areas.
• SPCC Inspection. Monthly inspection will be performed on the production vessels
containing petroleum hydrocarbon in the 200 area and the diesel fuel tanks for the fire
pumps and fuel distribution.
• Emergency Response Equipment Inspection. Monthly inspection of the emergency
response equipment.
• Railcar Offloading Area Inspection. Daily inspection at the railcar offloading area.
• Stormwater Inspection. Daily inspections of the process areas to ensure that rainwater
collected in sumps and dikes is routed to the process water or stormwater systems.
Stormwater inlets will be inspected bi-weekly. Basin 1, process area stormwater ponds,
wetlands and drainage channels will be inspected weekly. These inspections will address
the semi-annual facility inspections required by NPDES Permit, Part 11, Section A.5.
• Qualitative monitoring of stormwater._ Quarterly observations of stormwater outfall sample.
• Process water inspection. Daily area inspections of the following: sumps, containments,
tanks, associated piping and flanges, and sampling of the effluent and upstream flows.
Weekly inspections of the automatic sampling system and diffuser. Bi-weekly inspections
of the effluent monitoring system and calibration logs.
• Air quality inspection. Daily inspections of the air quality controls such as: dust collectors,
scrubbers, ACT cooling towers, etc. Also, daily inspections of the material piles and gravel
roadways.
For each inspection and/or monitoring requirement, the RO needs to verify if there is a checklist,
whether or not the checklist is adequate, are the inspections documented and is there any
follow up?
26

INTEGRATED CONTINGENCY PLAN
AMERICAN ZINC PRODUCTS LLC FACILITY
MOORESBORO, NORTH CAROLINA
MAY 2017
3.0 REQUIREMENTS FOR PETROLEUM OIL FACILITIES [112.8]
3.1 General Requirements [112.8(a)]
The general requirements for the Plan listed under 40 CFR 112.7 have been met as discussed in
Section 2.0. This section of the ICP specifically addresses the requirements of 40 CFR Part 112.8.
3.2 Facility Drainage [112.8(b)]
The overall facility drainage outside of containments in the SX Area is designed to be retained within
detention ponds (see Figure 12). All drainage from individual containment areas will be controlled by
manually activated pumps or valves and released into a detention pond. Any discharge from the
detention ponds will be controlled per the requirements of an NPDES discharge permit.
Water falling in all other non -process areas of the plant will drain to the storm sewer system and
discharge into Basin 1 at the bottom of the utility corridor road. Water in the basin will be evaluated for
contaminants as defined by the NPDES discharge permit on a routine basis. In addition to routine
monitoring, the pond has a series of rock weirs designed to remove suspended solids before discharging
at the permitted Stormwater Discharge Outfall into the Broad River.
What about the sediment in the basin? My understanding is that it recently failed the TCLP test for
hazardous waste. There should be a sampling and testing procedure for the sediment. All such
stormwater control measures shall be cleaned out when the sediment exceeds one foot. All hazardous
waste determination records and dispose records shall be maintained on site for five years. The RO
needs to verify procedures are in place and records are maintained for five years.
(Area 100 has diked containments equipped with sumps that have manually operated control valves. Any incidental
stormwater captured will be used in the zinc production process. All areas outside of the curbed containments are
paved. A stormwater catch basin system and network of stormwater gravity sewers direct all of these flows to the
Area 100/300 stormwater detention pond FA-104.
Area 200 has diked containments equipped with sumps that have manually operated control valves. Any incidental
stormwater captured will be used in the process. All areas outside of the curbed containments are paved. A
stormwater catch basin system and network of stormwatergravity sewers direct all of these flows to the Area 200
stormwater detention pond FA-218.
Area 300 has diked containments equipped with sumps that have manually operated control valves. Any incidental
stormwater captured will be used in the process. All areas outside of the curbed containments are paved. A
stormwater catch basin system and network of stormwater gravity sewers direct all of these flows to the Area 1001300
stormwater detention pond FA-104.
Area 400 Cell House is under roof. The Cell House transformer containment is designed to capture the accidental
release of oil from a transformer failure. The containment has a sump with a valve that can be opened to release
captured rainwater (once tested and determined to be clean) to the storm sewer system. If the water is
contaminated, it will be properly managed.
O

Munger, Bridget
From: Lisa Sorg <[e-mail]>
Sent: Tuesday, November 7, 2017 2:21 PM
To: Munger, Bridget
Subject: [External] public records request
Follow Up Flag: Follow up
Flag Status: Flagged
CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an attachment to
[e-mail].
Dear Bridget,
I'm following up on a story about the proposed Guilford County mine that I wrote about last week.
I am requesting several documents related to mining in NC:
1. All NOVs, NODs, fines and enforcement actions against mining and quarry operations in North Carolina,
2012-2017. This includes supporting documents showing the narrative and other details of the reasons for
these notices and actions.
2. All documents, emails, plus other electronic, written and telephonic records of communication, including
citizen complaints, regarding the Redford Quarry/Mine in Ashe County. Please include the keyword DJ Cecile.
Time frame 2014-present.
4. And finally, all documents, emails plus other electronic, written and telephonic records of communication
between Tracy Davis and the NC Aggregates Association, including Jay Stem. Keywords: Tracy Davis, NC
Aggregates Association, Jay Stem, legislation, state mining act, life -of -site, quarries, mining. Time frame 2014-
present
If you have questions, please contact me at this email or the phone numbers listed below.
Thanks,
Lisa Sorg
Environmental investigative reporter
NC Policy Watch
224 S Dawson St
Raleigh NC 27601
919-861-1463 (office)
919-536-2341 (cell)

INTEGRATED CONTINGENCY PLAN
AMERICAN ZINC PRODUCTS LLC FACILITY
MOORESBORO, NORTH CAROLINA
MAY 2017
4.0 STORMWATER POLLUTION PREVENTION PLAN
This section of the ICP provides information regarding the Stormwater Pollution Prevention Plan (SPPP)
required by the facility's Stormwater NPDES Permit No, NCS000562. This SPPP has been developed
and implemented at the facility in accordance with the NPDES Permit requirements. A copy of this SPPP
is maintained at the facility. This section of the ICP is formatted and numbered to coincide with the SPPP
requirements listed in the stormwater permit, beginning at Part 11, Section A.
4.1 Site Overview [Permit Part II, Section A.1]
The following subsections provide a description of the facility and potential pollutant sources and controls.
4.1.1 General Location Map [Permit Part 11, Section A.1.(a)]
A general location map is provided as Figure 1.
4.1.2 Narrative Description [Permit PartU, Section A.1.(b)]
A narrative description of the manufacturing areas is provided in Section 2.3.
Storage Practices: Chemicals used in the process will be stored in tanks or containers designed for the
product and within contained areas for control of spills. Tanks and process equipment will be inspected
on a regular basis by trained operators and serviced by maintenance technicians trained in their area of
expertise. Gypsum will be stored in a contained area. Rainwater that falls in a contained area is
collected and pumped to the process water system. Stormwater may be tested and, if within the limits of
the permit, can be discharged into the stormwater system.
May be tested_????? The RO needs to verify procedures are in place and records are maintained for
five years.
Loading and Unloading Activities: Trained operations personnel are responsible for overseeing the
offloading of tank trucks and railcars of incoming materials and chemicals used in the manufacturing
process. Tank trucks of chemical are unloaded in contained areas within the SXIEW manufacturing
facility. WOX and limestone will be offloaded via the pneumatic displacement (PD) system under roof at
the rail yard.
Sulfuric acid is offloaded from tank cars at the rail yard. A catch pan is located beneath the area to
capture incidental spills. This work area is closely monitored to ensure the activity is shut down if
significant leaks occur.
Outdoor Process Areas: The Solvent Extraction (SX) area contains manufacturing equipment associated
with the processing of high grade zinc. This area is within containment and rainwater is controlled for use
in the manufacturing process. This area will be monitored continuously and spills/leaks addressed
immediately.
35

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AREA 900
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AREA 500 CASTING
AREA 1100 WAREHOUSE
E = 1148795.8489'
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AREA
SQ.FT.
CONTAMINATED SVI
TESTED AND CONFIRMED
CLEAN SW
= TRANSFORMER CONTAINMENT
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5118
402434
= HELD FOR
= RECYCLED
DISPOSAL
BACK TO
PROCESS
=CONTROLLED
=CONTROLLED
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RELEASE
TO
TO
STORM
STORM
SEWER
SEWER
= AREA 0600 CONTAINMENT
67222
= RECYCLED
BACK
TO
PROCESS
=CONTROLLED
RELEASE
TO
STORM
SEWER
= AREA 0100/0300 CONTAINMENT
184578
= RECYCLED
BACK
TO
PROCESS
=CONTROLLED
RELEASE
TO
STORM
SEWER
= GYPSUM CONTAINMENT
40245
= RECYCLED
BACK
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=N/A
X =SULFURIC ACID CONTAINMENT
5520
= RECYCLED
BACK
TO
PROCESS
=N/A
= EW PROCESS ROOF
48503
= RECYCLED
BACI<
TO
PROCESS
=N/A
= ELECTROLYTE TANK CONTAINMENT
20214
= RECYCLED
BACK
TO
PROCESS
=N/A
\
= HCL PROCESS AREA
17066
= RECYCLED
BAC<
TO
PROCESS
=N/A
= PERIMETER OF DRAINAGE AREA TO 60"0 OUTFALL (TOTAL AREA = 2,223,605 SQ. FT)
= IMPERVIOUS SURFACE INSIDE OF DRAINAGE AREA TO 60"0 OUTFALL (AREA = 1,658,104 SO. FT)
= PERVIOUS SURFACE INSIDE OF DRAINAGE AREA TO 60"0 OUTFALL (AREA = 358,831 SQ. FT)
= BUILDING ROOF SURFACE — NON CONTAMINATED AREA (AREA = 206,670 SO. FT)
= STORM SEWER/CATCH BASIN = FLOW RUNOFF DIRECTION
0 70' y 140' 210'
I I I I I ! I I I I I
10, 50' 10o' 150' 200'
N = 536025.8834'
E = 1148914.0960'
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Response Equipment List
E ui Tent
Location
_
Communication Equipment
Hand-held two-way radios to notify employees,
_
Two-way radios and cellular phones carried by
emergency coordinators, or security of an
facility personnel. Radio charging stations are in
emer ency_ _ — .....__......... ........
the SX/EW control room.
- - -_.-
Spill Response Equipment
_
Spill kits for acids and oils to clean smaller spills
Areas 100, 200, 300, Maintenance Store Room,
and help contain larger spills until further
Guard House, nearby the diesel fuel tank, fire
assistance is available
pump house, -and at Basin 1.
Respiratory protection to protect employees from
PPE storage at the SX/EW control rooms and
chemical exposure to various acidic and organic
storage room near the acid offloading area
compounds
Additional PPE is available in the main Store
Room area.
Absorbent material to absorb spilled liquids (empty
-Tank truck offloading areas
55-gallon drums are kept in the Waste Storage
-Basin 1
Area
-Areas 100, 200, and 700
-Maintenance Area
Shovels and brooms to collect spilled and/or
absorbent material
-Waste Storage Area
-Near the 5,000-aIlon diesel fuel tank
Front end loader to create a dam or berm, or
Gypsum Storage Pad
removespilled materials
Vacuum truck to collect material from the surface
Used throughout the facility and parked near the
I sumps or other material and WqX spills
Maintenance Area
maintained b Advanced Environmental O bons
Track mobile to move railcars
Railcar Offloading Area.
_ _
PPEto protect employees during response actions
Typical PPE in use and/or available includes
PPE supplies are located in the PPE room,
hardhat, metatarsal work boots, safety glasses,
located in the Bain Storage Room and the
hearing protection, chemical protective suits, '/�SX/EW
control rooms.
face and full -face respirators; SCBAs, fully
encapsulated acid suits, and reflective clothing
(vests or Velcro strips)
Fire Equipment —
— — —
Portable fire extinguishers are located throughout
the facility (the locations are depicted on a map of
Portable fire extinguishers and foam cans
the facility utilized as a part of the fire extinguisher
inspections). Foarn carts are located on the east
and vuest side of the settlers in the SX area.
Fire hydrants are located throughout the facility (the
Fire hydrants for fire department use and 1 1/t"
locations are depicted on a map of the facility
hose lines for incipient fire fighting
utilized as a part of the fire extinguisher
inspections), Fire hoses are in the fire boxes near
the settlers in the SX area.
Sprinkler protection in the:
-Administration Building (offices, lab, maintenance
Fixed fire protection systems
shops, storage room, locker rooms)
-SX/EW control rooms
-Cardox system over the settlers
First Aid Eq�Ipment
-Medical Office
First aid kit to treat minor injures
-SX Control Room
EW Controi Room
Security Office
Strategically located throughout the SX/EW facility..
C-.F..1.. n4..-... ... .....1 .. .. L... L..4'i...... F... (....... r.
,-F..-III.• �I
Objects or chemicals in eyes a-Medica3 Office
FIREHOUSE
AREA
600
PLINT
6
AREA
800
UTILITIES
2
1
2
STORE
ROOM
AREA M&P I&E AED
1100 SHOPS
LUNCH
LOCKER
ROOMS
AED
C> ADM I N
OFFICES
44/
'S
0 % MAIN PARKING LOT
T`V
1 GUARD HOUSE
9
BASIN 1
2
AREA
400
CELL
HOUSE
AREA AREA9Q0
500 GRINDING
CASTING SYSTEM
AREA
1100
WAREHOUSE 1
0
a..
1V O R TH
SCALE F-EET
REFLRENCE:
1
-
SITE PLAN BY
CARNEGIE DESIGN
ENGINEERS, L! C,
—
0 200 40
PROJECT N0,
10 4283, D'I/'IG. N0. E—OOaO—G
100G—�,
RELEASED FOR
CONSTRUCTKON 9-2 1 — 2.
PREPARED BY:
PREPARED r""R:
PROJECT:
DRAWI^�G TITLE:
KU RESOURCES,
INC.
22 SOUTH LINDEN STREET
HORSEHEAD ��ORPDRAT�DN
�J �J
TOWN OF MOORESBORO
❑UQUESNE, PA 15110
RESPONSE EQUIPMENT
MOORESBORO, I\ORTH CAROLINA
RUTHERFORD COUNTY, NORTH CAROLINA
FAX:( 12)461
FAX: [phone]
wwv�.kuresources.corn

INTEGRATED CONTINGENCY PLAN
AMERICAN ZINC PRODUCTS LLC FACILITY
MOORESBORO, NORTH CAROLINA
MAY 2017
4.2.1 Feasibility Study [Permit Part11, Section A.2.(a)]
See Section 1.6 for a discussion of the feasibility study.
4.2.2 Secondary Containment Requirements and Records [Permit Part 11, Section
A.2.(b)J
See Table 2 for a listing of stored materials and secondary containment areas. All secondary
containment requirements for bulk storage of materials will be met in order to prevent leaks and spills
from contaminating stormwater runoff. Table 2 is a summary of all tanks and stored materials and their
associated secondary containment. There are no secondary containment areas that are connected to
stormwater conveyance systems. O needs to veri A portable hose will be used to transfer water
from the secondary containment to the stormwater system if needed. Stormwater that accumulates in the
containment areas will be visually observed and tested to ensure contaminants are below permit limits
before being released to the stormwater conveyance system. ,Records documenting the observations
and analyses will be retained for the required time period (5 years). JR0 needs to vefiN
4.2.3 BMP Summary[Permit Part11, Section A.2.(c)]
A following provides a discussion and listing of structural and non-structural BMPs. The installation and
implementation of BMPs is based on the assessment of the potential sources to contribute significant
quantities of pollutants to stormwater discharges and stormwater monitoring data. The BMP summary will
be reviewed annually and updated as needed by facility management. Rationale for these selected
BMPs is prioritized based on the following criteria:
• No exposure. Storing or transferring materials within buildings or process lines and equipment,
not exposed to stormwater
• Secondary containment. All processing and materials transfers are conducted within secondary
containments. What about process containment areas??? — facility needs to verify the integrity a
the liners.
• Stormwater controls. individual areas are provided with passive secondary containments with
manually operated controls to manage any stormwater or materials present in containments.
Additionally, the entire facility has stormwater controls to manage both contained and
uncontained areas. ,
• Training and inspections. Training is provided for all employees in operational areas, as well as
those who implement the monitoring for the stormwater discharge permit. Also, frequent formal
and informal inspections are conducted throughout the facility.
38

INTEGRATED CONTINGENCY PLAN
AMERICAN ZINC PRODUCTS LLC FACILITY
MOORESBORO, NORTH CAROLINA
MAY 2017
4.4. t Preventative Maintenance
Maintenance and preventive maintenance requirements will be identified through the inspections
described in Section 2.9, and will be addressed on a schedule appropriate for each situation.
Preventative maintenance is conducted by the facility personnel to enable timely inspection and repairs in
areas and or on equipment that may result in environmental degradation or endangerment of workers
and/or the general public. The facility's routine inspections are designed to correct minor problems before
they become significant, and to discover leaks, drips, etc. that have occurred inside and outside
containment areas. By inspecting these areas and removing the released material in a timely manner,
potential impacts to stormwater will be minimized.
Maintenance is an ongoing matter performed by experienced operators and tradesmen. The operation
includes a maintenance department capable of making most repairs, while more specialized maintenance
is contracted to outside personnel. Most production operators are expected to make minor repairs.
Adequate spare parts are maintained to handle critical repair situations. Where equipment repair or
replacement histories have been developed, preventive maintenance will be scheduled before failure
occurs.
The preventive maintenance program includes the unloading equipment and mobile equipment, as well
as the buildings themselves. Periodic formalldocumented inspections are scheduled, in addition to daily
visual informal/undocumented inspections.
Testing and calibration of environmental monitoring equipment will be performed on a timely basis;
eeds to very test areas mandated by manufacture and records are maintaine All equipment will be
properly calibrated before being placed in use. Records of inspections and calibrations will be maintained
at the facility.
4.4.2 Good Housekeeping
Housekeeping inspections are discussed in Section 2.9. Housekeeping procedures are implemented by
the facility personnel to reduce the potential for stormwater pollution, accidental spills, and to eliminate
safety hazards. Housekeeping procedures include orderly material storage and prompt cleanup of any
spills or leaks. Housekeeping practices also include ensuring sufficient aisle space is available for the
movement of spill or emergency response equipment through the facility, as required.
Additional good housekeeping activities at the facility include the following.
• Employees will be instructed and trained on the subject of good housekeeping techniques.
• Periodic safety inspections of all work areas include monitoring of housekeeping.
• Informal / undocumented, daily visual inspections will be conducted by employees in each
area to help ensure proper good housekeeping procedures are practiced.
• No flammable or combustible materials will be stored in or around electrical equipment.
• Trash will be placed into the trash dumpsters to help ensure that debris is not deposited
outside of the dumpsters and that the dumpster is free of liquids.
40

Pat McCrory
Governor
North Carolina Department of Environmental Quality
September 24, 2015
CERTIFIED MAIL
RETURN RECEIPT REQUESTED 7014 0510 0000 4466 2374
Anthony K. Staley
Horsehead Corporation
484 Hicks Grove Road
Mooresboro, N.C. 28114
Subject: NOTICE OF VIOLATION/NOTICE OF INTENTTO ENFORCE
NOV-2025-DV-0288 (BIMS Inc. #201502152)
Horsehead Corporation
Rutherford County
Dear Mr. Staley:
Donald R. van der Vaart
Secretary
On September 9, 2015, the Division of Water Resources (DWR) visited your facility In response to notification that a
release of low pH solution was occurring. The low pH solution had infiltrated into the stormwater system through
subsurface soils and/or stone base material at,the cell house. The solution was actively discharging from your
stormwater system to'the Broad River when DWR staff arrived onsite. The discharge to the Broad River did not cease
completely until September 12' according to site personnel; it is unclear when the discharge to the Broad River began
and the rate of discharge.throughout the release period. A water sample of the solution being discharged Indicated
elevated concentrations of metals such as cadmium, lead and zinc at levels above surface water standards.
Violations
As a'result of the above -referenced release, the following violations are noted:
(1) Illegal discharge
(2) oil Pollution and Hazardous Substances Control Act — Unlawful Discharge
Violation I. Discharge Without a Valid Permit
G.S. 143-215.1 (a) (1)'- "Activities for Which Permits Required. — No person shall do any of the following things or carry
out any of the following activities unless that person has received a permit from the Commission and has complied with
all conditions'set forth in that permit.
(1) Make any outlet into the Water s of the State."
Violation 2. Unlawful Discharge
G.S. 143-215.83 — states that "It shall be unlawful, except as otherwise provided in this Part, for any person to discharge,
or cause to be discharged, oil or other hazardous substances into or upon any waters, tidal'flats, beaches, or lands within
this State, or into any sewer, surface water drain or other waters that drain into the waters of this State, regardless of
the fault of the person having control over the oil or other hazardous substances, or regardless of whether the discharge
was the result of intentional or negligent conduct, accident or other cause."
Water Quality Regional Operations —Asheville Regional Office
2090 U.S. Highway 70, Swanrwm, North Carolina 28778
Phone: [phone] FAX: [phone]
lntemet httplJ".ncdenr.oWNebtwq
An Equal Opportunity 1 Aftlmiative Adlon E aVloyer

Anthony K, Staley
September24, 2015
Page 2 of 2
Required Response
This Office requests that you respond to this letter In writing within 15 days of receipt of this Notice. Your response
should be sent to this Office at the letterhead address. Your response should address the following items:
� � Q
1. Please submit a report assessing the cause, sienl IcanM and extent of the release. The report should contain
details of the estimated quantity of solution released (i.e., amount of product loss, estimated discharge rate
to Broad River, etc.), conditions under which the solution Was released and chemical composition of the -
solution. Please include specific details as to why secondary containment and spill prevention measures
failed during the release. You are to include a narrative describing the operational condition of the -
containment structures (i.e., seal between tank and cell house floor, etc.) prior to and during the release. -
You are to identify other areas within the plant with similar seals as well as providing a narrative describing
in detail the construction specifications of secondary containment structures at the facility. You are also to --
submit a timeline of events associated with the release (i.e., time discharge first observed, time discharge to
Broad River observed, notification times, etc.).
2. Please submit 6 plan listing all actions you will take to prevent future releases including any enhancements ;
to containment structures, changes in operation and maintenance of existing containment structures or
how similar seals will be evaluated for Integrity, Your comments should address but are not limited to the
following issues: spill response plan, preventative maintenance on your containment structures, monitoring
of secondary containment integrity, etc. E^ I G d kfiid�•� Gonscd�7'm�aC�rr, Ufa
o60 acl��io/, dr G/✓�IR'4d/ties ��ac eNJ27-; y fe ;rsh hJQ-S
Fines may be imposed -underLNCGS 143-215.6A(a)(1)_pf not more than,$25,000 per violation of any classification,
standard, limitation or management practice established pursuant to �143-214.1. Additional action may include the
issuance of a special order against you under the authority of .S. 14a request to the Attorney General to i
institute an action for injunctive relief. If. any failure to act is continuous, penalties may be assessed not to exceed a
maximum penalty of $25,000 per day per violation under CGS 143-215:6A(f;j o long as the violation continues. Your
response to this correspondence will be considered in any civil penalty assessment process that may occur.
This office requires that the violations, as detailed above, be abated immediately and properly resolved. Thank you
for your attention to this matter. This Office is considering sending a recommendation for enforcement to the Director
of the Division of Water Resources regarding these issues and any future/continued violations that may be encountered.
If you have any question regarding this Notice, please feel free to contact me direct at 928-296-4680 or via email at
[e-mail].
Sincerely,L //
_ �EC� �ca76t7"arGnn71,,L'4 _
��� P���J�i.�s. on G ��u.:�g• t/iA/d �id�
V
G. Landon Davidson, P.G., Regional Supervisor
Water Quality Regional Operations _
Asheville Regional Office
cc: Jim Harris, Environmental Manager (via email)
Brent Burch —NCDEQ DWM HWS (via email)
Stan Aiken — NCDEQ DEMLR (via email)
Bradley Bennett — NCDEQ DEMLR (via email)
WQAsheville Files
MSC 1617-Central Files -Basement
WQ Enforcement

D. i,fied Bli Rrarh
LeadlSiluer
_.._.._..—.._.._.._.._--1 I Area 600 i Concentrate
i
Waelz Oxide Wash/Leach 1 E FLINT I PLINT
Skimmings Neutralization Feed I Process Zinc Concentrate
.. i
1 Area 100 i r.._.._.._.._.._.._.._.._.._.._.._.._.._..—..—.._.._.._.,_.._.._.._..� .._..,
I
I...... ......
k
SX Extraction SX Washing SX Stripping !
Cadmium i
Concentrate �.._._.._.._.._.._.._.._.._.._.._.._.._.._
Gypsum Gypsum Cementation J ! SX Depletion
Precipitation I
! I Area 200 ! 1 1
. i Bleed ; ._.._.._.._. .._.._.._.._.._.._.._.._.._ i Ee:ctrowinning i
i
I
i Treatment
i Area 400 i
i
Finali 1.—.._.._....._. ...............
Effluent 4 Treatment
Area 300
i._.._.._.._.._.._.._.._.._.......
i Melting i
Zinc Concentrate
SHG Zinc i i
CGG Zinc Casting i
P.W Zinc i
Area 500
15

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

NCS000562
AIV
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Pat McCrory Charles Wakild, P.E. John E. Skvarla, III
Governor Director Secretary
STAFF REVIEW AND EVALUATION
NPDES Stormwater Permit, revised 1/8i2013
Facility Name:
NPDES Permit Number:
Facility Location:
Type of Activity:
SIC Code:
Receiving Streams:
River Basin:
Stream Classification & condition
Proposed Permit Requirements:
Monitoring Data:
Response Requested by:
Central Office Staff Contact:
Special Permitting Issues:
Horsehead Metal Products, Inc., Horsehead Corporation owner
NCS000562
484 Hicks Grove Road, Mooresboro, NC, Rutherford County
High purity zinc production from zinc oxide
3341
Broad River, see Figure 1
Broad River Basin, Sub -basin 03-08-02
Class C, no TMDL, no 303(d)
See attached draft permit.
New permit, no historical data exists.
July 16, 2012
Return to: Ken Pickle [phone]
Risk considerations
Rating Scale: 1 minimal risk)_to 10 risk factors resent
Compliance History
No history: rate 1
Benchmark exceedance
A new site. with no past measurements: rate l
Location (TMDL, T&E species, etc)
Downstream benthos impaired; downstream WS-IV and WS-IV CA:
rate 6
Other factors:
Other factors in aggregate present normal risks for most industrial sites:
• Zinc solutions, lead, and acids
rate 6
present.
• Industry is unique in NC, no other
similar facilities.
• A start-up facility.
• Multiple tanks, rail unloading,
potential for process fluids to be
exposed.
• Avoiding heavy metal solutions
discharges depends on proper
operator actions assisted by
extensive containments.
Risk and DWQ scrutiny rating:
14/40 - moderate stormwater pollution risks
Page 1 of 4

NCS000562
Description of Onsite Activities:
• Horsehead receives zinc oxide material, and refines it into a high purity product. Byproducts are
secondary in importance, including minor amounts of lead and silver production.
Documents Reviewed:
• NPDES stormwater permit application materials, received in final form May 8, 2012.
• US Fish and Wildlife Service threatened and endangered species inventory for Rutherford County
• Natural Heritage Program staff reports no rare aquatic species in the Broad River in this vicinity.
• EPA Sector -Specific Permit, 2008. SIC 3341 covered, but no benchmarks assigned.
• Integrated Report 303(d) List, 2010 final: upstream WS-IV and downstream WS-IV and CA impaired
for aquatic life, but the actual receiving reach is classified C and is not listed.
• July 2008 Broad River Basinwide Plan: no comment on this site (didn't exist); in 2008 the receiving
water is shown as supporting its classified uses.
History:
• First time stormwater permit application.
• First time NPDES wastewater permit issued Nov. 1], 2011, NC0089109.
Figure 1: Map of Facility
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1, i S i.F`. � �� ` `'.�i . I l�'r �- _ :�~r': �. }.' I ^f • ��'; T-�.J��1 �, 1���'t`.� r.
1 ,i I�14 j L' I,' ;j� �� .Ftpe ;fy�`` r. .-.\ F C/.. '•y.. y' 7j f.' �,,�'i`•�
2 1y
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S�1 .1 i• ; . 1 '1 11II,7�7 L ,a', �.f e`I �� it - r! n;w''I + T , ,. Ai1d+
' =a' .r. �' , :J i •':�.'' t'�. 'f.-,:�r'1 :.�.•. ' 1�C f e sc
�
t
it
1 Horsehead Corporation
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fir' + + 1. 1 •�1 -��,sr - �„ �( 4 I� -`..� - : z,-;7 ,I: �. ;w,_, �'� I "( '�
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..ti �2.11li',T�✓7f�r
Page 2 of 4

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

NCS000562
Recommendations: Based on application materials received oil March 28, 2012; and again on April 2; and again on
May 8, SPU considers the cobibined application materials Sufficient to issue an individual Stormwater Permit. We
are requesting Regional Office review comments, and full or qualified c011curt•ence.
Prepared by (Signature) Signature of Ken Pickle Date
Stormwater-Permitting Unit -Supervisor
for Bradley Bennett
Date
Concurrence by Regional Office a, Date '/ I4 111-1_
RO Water Quality Supervisor Date
/1 E
Regional Office Staff Comments (attach additional pages as necessary)
The ARO/S1417-S offers the fnlloi ing comments on the draft permit:
1. Require Horsehead Corporation to have the Stormi-vaterPollution Prevention Plan (,V-VPPP).in place prior to start
-
V of operations. Due to the complexity of'the operations (and that the operation does riot fall under a generalperinit
for a known industrial sector), the ARO believes it is prudent to have the.SK"PPP in place at the time of industrial
operations.
2. The "back up " plan for potential failures/problems with the detention basins/recycle loop system should be stated
within the SYYPPP. If a failure occurs, will this be a pump and haul situation? Will this be an operational.shw down."
Ilorsehead needs to state ivhcat actions will be taken should these problems occur.
This is e.speciully important to the ARO because, dare to state legislation passed in 2011 [ref. Session Law 2011-394,
Sec. 91, it is ARO 's understanding that the requirements for Authorization to Construct Permitting were repealed for
industrial perimits of this nature. Ther(fore, ive cannot re uire the c•ompcanv to provide specific information on
Iefenlion timesfor the various basins proposed.
3. Upon review of the wasteivater permit, and.sub.sequent review of the storrnwater draft perrrait, ARO recommends that
:hlorides be added to the quarterly monitoring. Chlorides are toxic to aquatic life, difficult to treat, and may be present
in the siormwater as well.
1. ARO reconmends that quarterly acute toxicity testing (or the most appropriate toxicity testing) be required in the
)ermit (please contact Carol Hollenkamp of ATU for specific language to use in the pernnit). TVs testing it
Tcornmended as it mimics the synergistic effects of the stornnvater discharge and its potential effect on the receiving
trearn.
5. ARO ivould not object to conditional language being placed in the permit to state (basically), that, after 3 years of
tuccessfitl quarterly data has been collected (under bench marks and toxicity gasses ), monitoring rimy be reduced to
wmi-annually. Three years of data, after the beginning of process operations, should he sufficient to determine
neasures are working successfully.
Page 4 of 4

DRAFT NCS000562
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE STORMWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTIEM
In compliance with the provisions of North Caroling General Statue 143-215.1, other
lawful standards and regulations promulgated and adopted by -the North Carolina
Environmental Management Commission, and theFederal Water Pollution Control Act, as
amended,
HorseheAd C6rpoi-ation
is hereby authorized to discharge industriall stormwater from a facility located at
,Horsehe d Metal Products, Inc.
484`Hicks Grove Road
/ Mooresboro, North Carolina
gam/ Rutherford County
to receiving waters designated as the Broad River, a class C water in the Broad River Basin,
in accordance with the discharge limitations, monitoring requirements, and other
conditions set forth in Parts I, II, 111, and IV hereof.
Note: Draft Permit Dates are Approximate
This permit becomes effective April 1, 2013.
This permit and the authorization to discharge expire at midnight on March 31, 2018.
Signed this day March 25, 2013.
for Charles Wakild, P.E., Director
Division of Water Quality
By the Authority of the Environmental Management Commission

DRAFT Permit No. NCS000562
TABLE OF CONTENTS
PART I INTRODUCTION
Section A: Individual Permit Coverage
Section B: Permitted Activities
Section C: Location Map
PART II MONITORING, CONTROLS, AND LIMITATIONS FOR PERMITTED
DISCHARGES
Section A: Stormwater Pollution Prevention`Plan
Section B: Analytical Monitoring Requirements /
Section C: Qualitative Monitoring Require tints
PART III STANDARD CONDITIONS FOR NPDES STORMWATER INDIVIDUAL PERMITS
r }}
l
Section A: Compliance and Liabi" Iity
1. Compliance Schedule
2. Duty to Comply
3. Duty to Mitigate
4. Civil and Criminal Liability
S. Oil and Hazardous Substance Liability
6. Property Rights
7. Severability
8. Duty to Provide Information
9. Penalties for Tampering
10. Penalties for Falsification of Reports
11. Onshore or Offshore Construction
12. Duty to Reapply
Section 13: General Conditions
1. Permit Expiration
2. Transfers
3. Signatory Requirements
i

DRAFT Permit No. NC50o0562
4. Permit Modification, Revocation and Reissuance, or Termination
5. Permit Actions
6. Annual Administering and Compliance Monitoring Fee
Requirements
Section C: Operation and Maintenance of Pollution Controls
1. Proper Operation and Maintenance
2. Need to gait or Reduce Not a Defense
3. Bypassing of Stormwater Control,Facilities
Section D: Monitoring and Records
1.
Representative Sampling
2.
Recording Results
3.
Flow Measurements
4.
Test Procedures
S.
Representative\Outfall
6.
11
Records Retention
7.
Inspection.and.E
try
Section E: Reporting Requireff nts
Monitoring Reports
1.
Discharge'
2.
Submitting Reports
3.
Availability of Reports
4.
Non-Stormwater Discharges
S.
Planned Changes
6.
Anticipated Noncompliance
7.
Spills
8.
Bypass
9.
Twenty-four Hour Reporting
10.
Other Noncompliance
11,
Other Information .
PART IV DEFINITIONS
M

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

SECTION C: LOCATION MAP
DRAFT Permit No. NCS000562
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Map Scale 1:24,000
Horsehead Corporation
Rutherford County Facility
Latitude: 350 11' 36' N
Longftude:811 50' 59" W
County: Rutlpuft-d County
Receiving Stream: Broad River -
Stream Class: C
Sub -basin: 03-OB-02 Broad River Basin
Facility Location
Part I Page 2 of 2

DRAFT Permit No. NCS000562
PART II MONITORING, CONTROLS, AND LIMITATIONS FOR
PERMITTED DISCHARGES
SECTION A: STORMWATER POLLUTION PREVENTION PLAN
The permittee shall develop and implement a Stormwater Pollution Prevention Plan
(SPPP). The SPPP shall be maintained on site. The SPPP is public information in
accordance with Part II1, Standard Conditions, Section E, paragraph 3 of this permit. The
SPPP shall include, at a minimum, the following items:
Site Overview. The Site Overview shall provide a description of the physical facility
and the potential pollutant sources that have the potential?to contribute to
contamination of stormwater discharges. The Site Overview shall contain the following:
(aA g g ) general location map (USGS quadrangle ma or appropriately drafted equivalent
map) showing the facility's location in relation to transportation routes and surface
waters; the name of the receiving waters'to which,,the stormwater outfalls
discharge; and accurate latitude and.longitudeof the points of stormwater discharge
associated with industrial activity, The,general location map (or alternatively the
site map) shall identify whether`any receiving waters are impaired (on the state s
303 (d) list of impaired\aters) or�if thi -site is located in a watershed for which a
TMDL has been established. and
at the parameters of concern are.
b A narrative descri ti�ora e practices, loading and unloading activities
() p� g P � g g
outdoor process areas, dust or particulate generating or control processes, and
waste disposal practices: AJnarrative description of the potential pollutants that
could be expected to be present in the stormwater discharge from each outfall, and a
discussion of failure modes that may impact the risk for polluted stormwater
discharges.
(c) A site map drawn at a scale sufficient to clearly depict: the site property boundary;
the stormwater discharge outfalls; all on -site and adjacent surface waters and
wetlands; industrial activity areas (including storage of materials, disposal areas,
process areas, loading and unloading areas, and haul roads); site topography and
finished grade; all drainage features and structures; drainage area boundaries and
total contributing area for each outfall; direction of flow in each drainage area;
industrial activities occurring in each drainage area; buildings; stormwater Best
Management Practices (BMPs); and impervious surfaces. The site map must
indicate the percentage of each drainage area that is impervious, and the site map
must include a graphic scale indication and north arrow.
(d) A list of significant spills or leaks of pollutants during the previous three (3) years
and any corrective actions taken to mitigate spill impacts.
Part II Page 1 of 11

DRAFT Permit No. NC5000562
(e) Certification that the stormwater outfalls have been evaluated for the presence of
non-stormwater discharges. The permittee shall re -certify annually that the
stormwater outfalls have been evaluated for the presence of non-stormwater
discharges. The certification statement will be signed in accordance with the
requirements found in Part III, Standard Conditions, Section B, Paragraph 3.
2. Stormwater Management Strategy. The Stormwater Management Strategy shall
contain a narrative description of the materials management practices employed which
control or minimize the stormwater exposure of significant materials, including
structural and nonstructural measures. The Stormwater Management Strategy, at a
minimum, shall incorporate the following:
(a) Feasibility Study. An annual review by site management of the technical and
economic feasibility of changing the methods,of operations and/or storage practices
to eliminate or reduce exposure of materialsand�pr cess_es,to rainfall and run-on
flows. Wherever practical, the permittee shall�prevent.exposure of storage areas,
nd material handling operations, manufacturin -,,afueling operations. In areas
where elimination of exposure and/or prevention of run-on contact are not
practical, the Feasibility Study shall document-the'basis for the management
decision that such controls are not feasible.
(b) Secondary Containment Requirements and Records. Secondary containment is
required for: bulk storage of.liquid'materials including petroleum products; storage
Reauthorization Act (SAA) water priority chemicals; and storage in any amount of
hazardous substances, in order to prevent leaks and spills from contaminating
stormwater runoff. A�table•or summary of all such tanks and stored materials and
their associated secondary containment areas shall be maintained. If the secondary
containment devices are connected to stormwater conveyance systems, the
connection shall be controlled by manually activated valves or other similar devices,
which shall be secured closed with a locking mechanism.' Prior to release into the
stormwaters conveyance system, any stormwater that accumulates in containment
areas shall be at a minimum visually observed for color, foam, outfall staining,
visible sheens, and dry weather flow. Accumulated stormwater may be released if
found to be uncontaminated by any material. Records documenting the individual
making the observation or analyses, the visual and analytical description.of the
accumulated stormwaters, and the dates and times of the releases shall be kept for a
period of five (5) years.
(c) BMP Summary. A listing of site structural and non-structural Best Management
Practices (BMPs) shall be provided. The installation and implementation of BMPs
shall be based on the assessment of the potential for sources to contribute
significant quantities of pollutants to stormwater discharges and on data collected
through monitoring of stormwater discharges. The BMP Summary shall include a
written record of the specific rationale for installation and implementation of the
Part II Page 2 of 11

DRAFT Permit No. NCS000562
selected site BMPs. The BMP Summary shall be reviewed by site management and
updated annually.
3. Spill Prevention and Response Procedures. The Spill Prevention and Response
Procedures (SPRP) shall incorporate an assessment of potential pollutant sources based
on a materials inventory of the facility. The SPRP shall address spill response and
failure mode preparations and responses. Site management shall identify facility,
personnel responsible for implementing the SPRP in a written list incorporated into the
SPRP along with dated signatures by each individual acknowledging his or her
responsibilities under the SPRP. A responsible person shall be on -site at all times
during facility operations that have the potential to contaminate stormwater runoff
through spills or exposure of materials associated with the facility operations. The
SPRP must be site stormwater specific. Therefore, an,oil Spill Prevention Control and
Countermeasure plan (SPCC) may be a component of the SPRP, but may not be
sufficient to completely address the stormwater aspects of,the•SPRP. The common
elements of the SPCC with the SPRP may be incorp/p atedsby reference into the SPRP.
4. Preventative Maintenance and Good Housekeeping�Program. A preventative
maintenance and good housekeeping program shall.be developed and implemented.
The program shall address all stormwater control -systems, stormwater discharge
outfalls, all on -site and adjacent surfa/ e waters and wetlands, industrial activity areas
11
(including material storage.areas; material handling areas, disposal areas, process
areas, loading and unloading areas`and,haul roads), all drainage features and
structures, and structural BMPs. The program shall establish schedules of inspections,
maintenance, and housekeeping activities of stormwater control systems, as well as
facility equipment, facility areas,,and facility systems that present a potential for
stormwater exposure or stormwater pollution where not already addressed under
another element of the PIRP Inspection of material handling areas and regular
cleaning schedules of these areas shall be incorporated into the program. Timely
compliance with the established schedules for inspections, maintenance, and
housekeeping shall be recorded and maintained in the SPPP.
S. Facility Inspections. Inspections of the facility and all stormwater conveyance and
control systems shall occur as part of the Preventative Maintenance and Good
Housekeeping Program at a minimum on a semi-annual schedule, once during the first
half of the year (January to June), and once during the second half (July to December),
with at least 60 days separating inspection dates (unless performed more frequently
than semi-annually). These facility inspections are different from, and in addition to,
the stormwater discharge characteristic monitoring at the outfall required in Part II
Sections B and C of this permit.
6. Employee Training. Training programs shall be developed and training provided at a
minimum on an annual basis for facility personnel with responsibilities for: spill
response and cleanup, preventative maintenance activities, and for any of the facility's
operations that have the potential to contaminate stormwater runoff. The facility
Part II Page 3 of 11 ..

DRAFT Permit No. NCS000562
personnel responsible for implementing the training shall be identified, and their
annual training shall be documented by the signature of each employee trained.
7. Responsible Party. Site management shall identify, and the SPPP shall document, a
specific position or positions responsible for the overall coordination, development,
implementation, and revision of the SPPP. Responsibilities for all components of the
SPPP shall be documented and position assignments provided.
B. SPPP Amendment and Annual Update. The permittee shall amend the SPPP
whenever there is a change in design, construction, operation, site drainage,
maintenance, or configuration of the physical features which may have a significant
impact on the potential for the discharge of pollutants to surface waters. All aspects of
the SPPP shall be reviewed and updated on an annualbasis. The annual update
shall include all the aspects required immediately aboven items 1 -7; and a review and
comparison of monitoring analytical data to benchmarkvalues.over the pastyear,
including a discussion about Tiered Response status The,permittee shall use the
Division's Annual Summary Data Monitoring Re'por\ form, available from the
Stormwater Permitting Unit's website here:,
The Director may notify the permittee-when the`SPPP does not meet one or more of the
minimum requirements of,,the permit. Within�30 days of such notice, the permittee
shall submit a time schedul'e.�-the for modifying the SPPP to meet minimum
requirements. The permittee.shall,provide certification in writing (in accordance with
Part I11, Standard Conditions, Sectio �B, Paragraph 3) to the Director that the changes
have been made.
9. SPPP Implementation. The permittee shall implement the Stormwater Pollution
Prevention Plan and all appropriate BMPs to prevent contaminants from entering
surface waters via stormwater. Among other actions identified herein, implementation
of the SPPP shall include the documentation of: all monitoring, measurements,
inspections, maintenance activities, and training provided to employees, including the
log of the sampling data and of actions taken to implement BM Ps associated with the
industrial activities. Such documentation shall be kept on -site for a period of five (5)
years and made available to the Director or the Director's authorized representative
immediately upon request.
Part ll Page 4 of 11

DRAFT Permit No. NCS00O562
SECTION B: ANALYTICAL MONITORING REQUIREMENTS
Analytical monitoring of stormwater discharges shall be performed as specified in Table 1.
All analytical monitoring shall be performed during a measureable storm event at each
stormwater discharge outfall (SDO). Only SDOs discharging stormwater associated with
industrial activity must be sampled (See Definitions).
A measurable storm event is a storm event that results in an actual discharge from the
permitted site outfall. The previous measurable storm event must have been at least 72
hours prior. See Definitions.
Table 1 Analytical Monitoring Requirements R /%
Discharge
Measurement
Sample
Sample
Characteristics .
Units
Fre uenc 1
Type2
Location3
Total Suspended Solids
mg1L
�q"uarterly)
Grab
SDO
Total Nitrogen
m L ,
-� ~quarterly
Grab
SDO
Total Phosphorus
m L
^ quarterly
Grab
SDO
Zinc, Total Recoverable
m �L
) quarterl Y
Grab
SDO
Lead, Total Recoverable /\
rg /'rLi` `;
quarterly
Grab
SDO
Cadmium, Total Recoverable
m g,L,
quarterly
Grab
SDO
Chlorides
m \ L
quarterly
Grab
SDO
Non -polar Oil & Grease/TPH
Grab
SDO
mg/L
quarterly
EPA Method 1664 SGT-H1• .- EM-
H �`
standard
quarterly
Grab
SDO
Total Rainfal14
inches
quarterly
Rain Gauge
-
Footnotes@
1 Measurement Frequency: Four times per year during a measureable storm event. The permittee may
petition DWQ to reduce the analytical monitoring frequency to twice peryear after eight consecutive quarterly
monitoring results all within benchmark values. Subsequently, two consecutive benchmark exceedances for any
parameter re -institute quarterly monitoring for all parameters.
2 Grab samples shall be collected within the first 30 minutes of discharge.
3 Sample Location: Samples shall be collected at each stormwater discharge outfall (SDO).
4 For each sampled measureable storm event, the total precipitation must be recorded. An on -site rain gauge
reading must be recorded.
The permittee shall complete the analytical samplings in accordance with the schedule
specified below in Table 2; unless adverse weather conditions prevent sample collection
(see Adverse Weather in Definitions). A minimum of 30-days must separate successive
sample events. Inability to sample because of adverse weather conditions must be
documented in the SPPP and recorded on the DMR. The permittee must report the results
from each sample taken within the monitoring period (see Part III, Section E).
Part ll Page 5 of 11

DRAFT Permit No. NCS000562
Table 2 Monitoring Schedule
Monitoring periodl,z
Sample Number
Start
End
Year 1 - Period 1
1
April 1, 2013
June 30, 2013
Year 1- Period 2
2
July 1, 2013
September 30, 2013
Year 1 - Period 3
3
October 1, 2013
December 31, 2013
Year 1- Period 4
4
January 1, 2014
March 31, 2014
Year 2 - Period 1
5
April 1, 2014
June 30, 2014
Year 2 - Period 2
6
July 1, 2014
September 30, 2014
Year 2 - Period 3
7.-
October 1, 2014
December 31, 2014
Year 2 - Period 4
8
January 1, 2015
March 31, 2015
Year 3 - Period 1
9
April 1, 2015
June 30, 2015
Year 3 - Period 2
10
July 1, 20.15
September 30, 2015
Year 3 - Period 3
11
October l,,2Q15
7 December 31, 2015
Year 3 - Period 4
12
Januaryl, 2016�%
March 31, 2016
Year 4 - Period 1
13
Aprilt1,,2016
June 30, 2016
Year 4 - Period 2
14
JulyY 1,,2b,16
September 30, 2016
Year 4 - Period 3
15
Q,el:_oberjl; 2016
December 31, 2016
Year 4 - Period 4
16
/Jana ry 1, 2017
March 31, 2017
Year 5 - Period 1
„17 ,��%
L- April 1, 2017
June 30, 2017
Year 5 - Period 2
i8 ,�,
``' July 1, 2017
September 31, 2017
Year 5 - Period 3
119
October 1, 2017
December 31, 2017
Year 5 - Period 4
/f 20'�
January 1, 2018
March 31, 2018
Footnotes: !j ,
1 Maintain quarterly monitoring until either another permit is issued for this facility or until this permit
is revoked or rescinded.�The permittee must submit an application for renewal of coverage before the
submittal deadline (180 days before expiration) to be considered for renewed coverage under the
permit. The permittee must continue analytical monitoring throughout the permit renewal process,
even if a renewal permit is not issued until after expiration of this permit.
2 If no discharge occurs during the sampling period, the permittee must submit a monitoring report
indicating "No Flow" within 30 days of the end of the sampling period. For the first term of this
permit, the new facility start-up date is uncertain. Permittee need not sample for the listed
monitoring periods until the facility comes into operation. Accordingly, the "No Flow" monitoring
report is not required during the time before the facility comes into operation.
Failure to monitor quarterly per the permit terms may result in the Division requiring
monthly monitoring for all parameters for a specified time period. "No discharge" from
an outfall, or inability to collect a sample because of adverse weather conditions during a
monitoring period does not constitute failure to monitor, as long as it is properly reported.
The permittee shall compare monitoring results to the benchmark values in Table 3. The
benchmark values in Table 3 are not permit limits, but should be used as management
guidelines for the permittee's responsive implementation of the Stormwater Pollution
Prevention Plan (SPPP).
Part Il Page 6 of 11

DRAFT Permit No. NCS000562
Table 3 Benchmark Values for Analvtical Monitoring
Discharge Characteristics
Units
Benchmark'
Total Suspended Solids
m /L
100
Total Nitrogen
mg/L
30
Total Phosphorus
mg/L
2
Zinc, Total Recoverable
mg/L
0.067
Lead, Total Recoverable
mg/L
0.03
Cadmium, Total Recoverable
mg/L
0.001
Chlorides
mg/L
/;> 860
Non -polar Oil & Grease/TPH
[EPA Method 1664 (SGT-HEM)]
mg/L
15
pH
standardIN
6-9
Footnote
1. Analytical results must not be reported vidany of th'e.notations, "BDL. ND, BRL, <M DL, <P.QL,
non -detect" or any similar non -quantitative notafion.)Instead, analytical results below method or
reporting limits must be reported on the,DMR,in the,format, "<XV, where XX is the specific numerical
value descriptive of the method or reporting limitr�l -
m a `, it Requiremeal
During the first term of this permit, and far the period beginning with the on -site initiation of
industrial activity and continuing for �two years nominal duration thereafter, Horsehead shall
sample quarterly as provided in Table 2, shall tabulate and interpret the collected data
(minimum eight data points) ,Within 30 months of start-up Horsehead shall present DWQ with
a summary report that uses the collected data to support any proposed alternative monitoring,
benchmark, and response action scheme for the purpose of maintaining site management
awareness and responsiveness to potential pollutant discharges from the site. For the first
term of this permit, benchmark exceedances will not activate DWQ's standard Tiered Response
actions which are shown below for reference only.
The summary report shall specifically consider and interpret the collected data with respect
to the benchmarks identified in this permit, and shall identify the Tiered Response action
status that would have been triggered by the data collected.
While DWQ is considering Horsehead's summary report and determining what revisions to the
permit, if any, may be reasonable and protective, and continuing on for the remainder of the
permit term until any such changes in the permit requirements may be established by DWQ,
Horsehead shall be subject to the full provisions of sampling, comparison to the benchmarks,
and reporting contained in Part 11 Section B. All other provisions of the permit remain in effect
from the effective date of the -permit until expiration.
Part ll Page 7 of 11

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

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

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

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

DRAFT Permit No. NCS000562
PART III STANDARD CONDITIONS FOR NPDES STORMWATER INDIVIDUAL PERMITS
SECTION A: COMPLIANCE AND LIABILITY
1. Compliance Schgule
The permittee shall comply with Limitations and Controls specified for stormwater discharges in
accordance with the following schedule:
Existing Facilities already operating but applying for permit coverage for the first time: The
Stormwater Pollution Prevention Plan shall be developed and implemented within 12 months of the
effective date of the initial permit and updated thereafter on an annual basis. Secondary containment,
as specified in Part 11, Section A, Paragraph 2(b) of this permit, shall be accomplished within 12
months of the effective date of the -initial permit issuance. 1 /9
New Facilities applying for coverage for the first time: The Stormwater Pollution Prevention Plan
shall be developed and implemented prior to the beginning of discharges from the operation of the
industrial activity and be updated thereafter on an annual basis. Secondary containment, as specified
in Part 11, Section A, Paragraph 2(b) of this permit shall -be accomplished prior to the beginning of
discharges from the operation of the industrial activity.yfol
Existing facilities previously permitted and paplyinnewal: All requirements, conditions,
limitations, and controls contained in this permit (except revised SPPP elements in a permit renewal)
shall become effective immediately upon,issuance-of this permit. New elements of the Stormwater
Pollution Prevention Plan for this pe`rmit�renewal shall be developed and implemented within 6
months of the effective date of this,pemit and updated thereafter on an annual basis. Secondary
containment, as specified in Part.11I; Paragraph 2(b) of this permit shall be accomplished prior to the
beginning of discharges from the operation of the industrial activity.
V
12uty to Com&
The permittee must comply with all conditions of this permit. Any permit noncompliance constitutes
a violation of the Clean Water Act (CWA) and is grounds for enforcement action; for permit
termination, revocation and reissuance, or modification; or denial of a permit upon renewal
application [40 CFR 122.41].
a. The permittee shall comply with standards or prohibitions established under section 307(a) of
the CWA for toxic pollutants within the time provided in the regulations that establish these
standards or prohibitions, even if the permit has not yet been modified to incorporate the
requirement.
The CWA provides that any person who violates section[s] 301, 302, 306, 307, 308, 318 or 405 of
the Act, or any permit condition or limitation implementing any such sections in a permit issued
under section 402, or any requirement imposed in a pretreatment program approved under
sections 402(a)(3) or 402(b)(8) of the Act, is subject to a civil penalty not to exceed $37,500 per
day for each violation. [33 USC 1319(d) and 40 CFR 122.41(a)(2)]
c. The CWA provides that any person who negligently violates sections 301, 302, 306, 307, 308,
318, or 405 of the Act, or any condition or limitation implementing any of such sections in a
permit issued under section 4.02 of the Act, or any requirement imposed in a pretreatment
program approved under section 402(a)(3) or 402(b)(8) of the Act, is subject to criminal
penalties of $2,500 to $25,000 per day of violation, or imprisonment of not more than 1 year, or
both. In the case of a second or subsequent conviction for a negligent violation, a person shall be
Part III Page 1 of 9

DRAFT Permit No. NCS000562
subject to criminal penalties of not more than $50,000 per day of violation, or by imprisonment of
not more than 2 years, or both. [33 USC 1319(c)(1) and 40 CFR 122.41(a)(2)]
d. Any person who knowingly violates such sections, or such conditions or limitations is subject to
criminal penalties of $5,000 to $50,000 per day of violation, or imprisonment for not more than 3
years, or both. In the case of a second or subsequent conviction for a knowing violation, a person
shall be subject to criminal penalties of not more than $100,000 per day of violation, or
imprisonment of not more than 6 years, or both. [33 USC 1319(c)(2) and 40 CFR 122.41(a)(2)]
e. Any person who knowingly violates section 301, 302, 303, 306, 307, 308, 318 or 405 of the Act, or
any permit condition or limitation implementing any of such sections in a permit issued under
section 402 of the Act, and who knows at that time that he thereby places another person in
imminent danger of death or serious bodily injury, shall, upon conviction, be subject to a fine of
not more than $250,000 or imprisonment of not more than 15,years, or both. In the case of a
second or subsequent conviction for a knowing endangerment violation, a person shall be subject
to a fine of not more than $500,000 or by imprisonment of not mare than 30 years, or both. An
organization, as defined in section 309(c)(3)(B)(iii) ofahe CWA;.shall, upon conviction of
violating the imminent danger provision, be subject'to a fine of.not more than $1,000,000 and can
be fined up to $2,000,000 for second or subsequent convictions. [40 CFR 122.41(a)(2)]
f. Under state law, a civil penalty of not more'than $25,000 per violation may be assessed against
any person who violates or fails to act iAccordance with the terms, conditions, or requirements
of a permit. [North Carolina General Statutes'§ 143 215.6A]
g. Any person may be assessed an.;administra_tive penalty by the Administrator for violating section
301, 302, 306, 307, 308�,318�or 405.of this Act, or any permit condition or limitation
implementing any of such sections in,a.permit issued under section 402 of this Act.
Administrative penalties•for Class I'violations are not to exceed $16,000 per violation, with the
maximum amount of any Class I penalty assessed not to exceed $37,500. Penalties for Class I I
violations are not to exceed $16,000 per day for each day during which the violation continues,
with the maximum amount of any Class II penalty not to.exceed $177,500. [33 USC 1319(g)(2)
and 40 CFR 122.41(a)(3)]�
Duty to Mitigate
The permittee shall take all reasonable steps to minimize or prevent any discharge in violation of this
permit which has a reasonable likelihood of adversely affecting human health or the environment [40
CFR 122.41(d)].
4. Civil and Criminal Liability
Except as provided in Part III, Section C of this permit regarding bypassing of stormwater control
facilities, nothing in this permit shall be construed to relieve the permittee from any responsibilities,
liabilities, or penalties for noncompliance pursuant to NCGS 143-215.3, 143-215.6, or Section 309 of the
Federal Act, 33 USC 1319. Furthermore, the permittee is responsible for consequential damages, such
as fish kills, even though the responsibility for effective compliance may be temporarily suspended.
5. Oiiand liazardous-Substance Liability
Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the
permittee from any responsibilities, liabilities, or penalties to which the permittee is or may be
subject to under NCGS 143-215.75 et seq. or Section 311 of the Federal Act, 33 USC 1321.
6. Proper&y Rights
The issuance of this permit does not convey any property rights in either real or personal property, or
any exclusive privileges, nor does it authorize any injury to private property or any invasion of
Part III Page 2 of 9

DRAFT Permit No. NCS000562
personal rights, nor any infringement of Federal, State or local laws or regulations [40 CFR
122.41(g)]. _
$everability
The provisions of this permit are severable, and if any provision of this permit, or the application of
any provision of this permit to any circumstances, is held invalid, the application of such provision to
other circumstances, and the remainder of this permit, shall not be affected thereby [NCGS 150B-23].
8. Day to Provide Information
The permittee shall furnish to the Permit Issuing Authority, within a reasonable time, any information
which the Permit Issuing Authority may request to determine whether cause exists for modifying,
revoking and reissuing, or terminating the permit issued pursuant to this permit or to determine
compliance with this permit The permittee shall also furnish to the Permit Issuing Authority upon
request, copies of records required to be kept by this permit [40 CF,R 122.41(h)].
9. Penalties for Tamperine //
The Clean Water Act provides that any person who falsifies,, tampers -with, or knowingly renders
inaccurate, any monitoring device or method required to'be maintained under this permit shall, upon
conviction, be punished by a fine of not more than $10;000 per violation, or by imprisonment for not
more than two years per violation, or by both. If a -conviction of a person is for a violation committed
after a first conviction of such person under this paragrap punishment is a fine of not more than
$20,000 per day of violation, or by imprisonment of hot more than 4 years, or both [40 CFR 122.411.
10. Penalties for Falsificatio-n-9f_gep2rt�
The Clean Water Act provides that any person -who knowingly makes any false statement,
representation, or certification in any`record or other document submitted or required to be
mg m aintained under this permit,.includinonitoring reports or reports of compliance or
noncompliance shall, upon.c`onvictkon, be punished by a fine of not more than $10,000 per violation, or
by imprisonment for not more thantwo years per violation, or by both [40 CFR 122.41].
11. Onshore or Offshore Construction
This permit does not authorize or approve the construction of any onshore or offshore physical
structures or facilities or the undertaking of any work in any navigable waters.
12. Duty to Reapply
If the permittee wishes to continue an activity regulated by this permit after the expiration date of
this permit, the permittee must apply for and obtain a new permit [40 CFR 122.41(b)].
SECTION B: GENERAL CONDITIONS
Permit Expiration
ation
The permittee is not authorized to discharge after the expiration date. In order to receive automatic
authorization to discharge beyond the expiration date, the permittee shall submit forms and fees as
are required by the agency authorized to issue permits no later than 180 days prior to the
expiration date, unless permission for a later date has been granted by the Director. (The Director
shall not grant permission for applications to be submitted later than the expiration date of the
existing permit.) [40 CFR 122.21(d)]. Any permittee that has not requested renewal at least 180 days
prior to expiration, or any permittee that does not have a permit after the expiration and has not
requested renewal at least 180 days prior to expiration, will be subjected to enforcement procedures
as provided in NCGS §143-215.36 and 33 USC 1251 et. seq.
Part III Page 3 of 9

DRAFT Permit No. NCS000562
�s rs
This permit is not transferable to any person without prior written notice to and approval from the
Director in accordance with 40 CFR 122.61. The Director may condition approval in accordance with
NCGS 143-215.1, in particular NCGS 143-215.1(b)(4)b.2., and may require modification or revocation
and reissuance of the permit, or a minor modification, to identify the new permittee and incorporate
such other requirements as may be necessary under the CWA [40 CFR 122.41(1)(3), 122.61] or state
statute. The Permittee is required to notify the Division in writing in the event the permitted
facility is sold or closed.
Signatory Requirements
Ail applications, reports, or information submitted to the Permitting Issuing Authority shall be signed
and certified [40 CFR 122.41(k)].
a. All permit applications shall be signed as follows:
(1) For a corporation: by a responsible corporate offic(Fr)For the purpose of this Section, a
responsible corporate officer means: (a) a president, secretary,,treasurer or vice president of
the corporation in charge of a principal busuiess,fuinction, or -any other person who performs
similar policy or decision making functionsf r the corporation, or (b) the manager of one or
more manufacturing, production, or operating.facilities, provided, the manager is authorized
to make management decisions which govern the operation of the regulated facility including
having the explicit or implicit duty of making mar capital investment recommendations,
and initiating and directing other comprehensive -measures to assure long term
environmental compliance with environmental laws and regulations; the manager can
ensure that the necessary systems are established or actions taken to gather complete and
accurate information for permitapplicationrequirements; and where authority to sign
documents has been,assignr delegated to the manager in accordance with corporate
procedures.
(2) For a partnership or so�eppNroprieo.torship: by a general partner or the proprietor, respectively;
or /J�
(3) For a municipality-, State,,Federal, or other public agency: by either a principal executive
officer or ranking elected official [40 CFR 122.221.
b. All reports required by the permit and other information requested by the Permit Issuing
Authority shall be signed by a person described in paragraph a. above or by a duly authorized
representative of that person. A person is a duly authorized representative only if:
(1) The authorization is made in writing by a person described above;
(2) The authorization specified either an individual or a position having responsibility for the
overall operation of the regulated facility or activity, such as the position of plant manager,
operator of a well or well field, superintendent, a position of equivalent responsibility, or an
individual or position having overall responsibility for environmental matters for the company.
(A duly authorized representative may thus be either a named individual or any individual
occupying a named position.); and
(3) The written authorization is submitted to the Permit Issuing Authority [40 CFR 122.221
c. Changes to authorization: If an authorization under paragraph (b) of this section is no longer
accurate because a different individual or position has responsibility for the overall operation of
the facility, a new authorization satisfying the requirements of paragraph (b) of this section must
be submitted to the Director prior to or together with any reports, information, or applications to
be signed by an authorized representative [40 CFR 122.22]
Part III Page 4 of 9

DRAFT Permit No. NCS000562
d. Certification. Any person signing a document under paragraphs a. or b. of this section shall make
the following certification [40 CFR 122.22). NO OTHER STATEMENTS OF CERTIFICATION WILL
BE ACCEPTED:
"1 certify, under penalty of law, that this document and all attachments were prepared under my
direction orsupervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible forgathering the information,
the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. 1
am aware that there are significant penalties for submitting false information, including the
possibility of f nes and imprisonment for knowing violations."
4. Permit M12diflcation
The issuance of this permit does not prohibit the Permit Issuing Authority from reopening and
modifying the permit, revoking and reissuing the permit, or terminating the permit as allowed by the
laws, rules, and regulations contained in Title 40, Code -of Federal Regulations, Parts 122 and 123;
Title 15A of the North Carolina Administrative Code„Subchapter 2H .0100; and North Carolina
General Statute 143-215.1 et al.
S. Permit Actions
The permit may be modified, revoked and reissued, or terminated for cause. The notification of
planned changes or anticipated noncompliance does\not stay any permit condition [40 CFR
6. I' n " n' ' r' u'
rements
The permittee must pay the•a`dihinistering and-coinpliance monitoring fee within 30 (thirty) days
after being billed by the Division.- Failure to pay the fee in timely manner in accordance with 15A
NCAC 2H .0105(b)(2) may cause •this Division to initiate action to revoke the permit.
SECTION C: OPERATION AND MAINTENANCE OF POLLUTION CONTROLS
1. Proper Operation and Maintenance
The permittee shall at all times properly operate and maintain all facilities and systems of treatment
and control (and related appurtenances) which are installed or used by the permittee to achieve
compliance with the conditions of this permit. Proper operation and maintenance also includes
adequate laboratory controls and_appropriate quality assurance procedures. This provision requires
the operation of back-up or auxiliary facilities or similar systems which are installed by a permittee
only when the operation is necessary to achieve compliance with the conditions of this permit [40
CFR 122.41(e)].
Need to Halt or Reduce Not a Defense
it shall not be a defense for a permittee in an enforcement action that it would have been necessary to
halt.or reduce the permitted activity in order to maintain compliance with the condition of this permit
[40 CFR 122.41(c)].
3. Bypassing of Stormwater Control Eacilities
Bypass is prohibited and the Director may take enforcement action against a permittee for bypass
unless:
a. Bypass was unavoidable to prevent loss of life, personal injury or severe property damage; and
b. There were no feasible alternatives to the bypass, such as the use of auxiliary control facilities,
retention of stormwater or maintenance during normal periods of equipment downtime or dry
weather. This condition is not satisfied if adequate backup controls should have been installed in
Part Ill Page 5 of 9

DRAFT Permit No. NCS000562
the exercise of reasonable engineering judgment to prevent a bypass which occurred during
normal periods of equipment downtime or preventive maintenance; and
c. The permittee submitted notices as required under, Part 1I1, Section E of this permit.
If the Director determines that it will meet the three conditions listed above, the Director may
approve an anticipated bypass after considering its adverse effects.
SECTION D: MONITORING AND RECORDS
Repre5entative Sampling
Samples collected and measurements taken, as required herein, shall be characteristic of the volume
and nature of the permitted discharge. Analytical sampling shall be performed during a measureable
storm event. Samples shall be taken on a day and time that is characteristic of the discharge. All
samples shall be taken before the discharge joins or is diluted,by any other waste stream, body of
water, or substance. Monitoring points as specified in this permit shall not be changed without
notification to and approval of the Permit Issuing Authority[40`CFR-122.41(j)].
2. Recording Results
For each measurement or sample taken pursuant.to•the requirements of this permit, the permittee
shall record the following information [40 CFR-122.41']: U
a. The date, exact place, and time of sampling or measurements;
b. The individual(s) who performed the sampling.or�measurements;
C. The date(s) analyses were performed; Cz
d. The individual(s) who performed the analyses;
e. The analytical tech niques;or-methods,u" ed; and
X'/
f. The results of such analyses.
3. Flow Measurements
Where required, appropriate•flow measurement devices and methods consistent with accepted
scientific practices shall be selected and used to ensure the accuracy and reliability of measurements
of the volume of monitored discharges.
4. Test Procedures
Test procedures for the analysis of pollutants shall conform to the EMC regulations published
pursuant to NCGS 143-215.63 et. seq, the Water and Air Quality Reporting Acts, and to regulations
published pursuant to Section 304(g), 33 USC 1314, of the Federal Water Pollution Control Act, as
Amended, and Regulation 40 CFR 136.
To meet the intent of the monitoring required by this permit, all test procedures must produce
minimum detection and reporting levels and all data generated must be reported down to the
minimum detection or lower reporting level of the procedure. If no approved methods are
determined capable of achieving minimum detection and reporting levels below permit discharge
requirements, then the most sensitive (method with the lowest possible detection and reporting
level) approved method must be used.
5. Kuresentative OutEall
If a facility has multiple discharge locations with substantially identical stormwater discharges that
are required to be sampled, the permittee may petition the Director for representative outfall status.
If it is established that the stormwater discharges are substantially identical and the permittee is
granted representative outfall status, then sampling requirements may be performed at a reduced
number of outfalls.
Part III Page 6 of 9

DRAFT Permit No. NCS000562
6. Records Retention
Visual monitoring shall be documented and records maintained at the facility along with the
Stormwater Pollution Prevention Plan. Copies of analytical monitoring results shall also be
maintained on -site. The permittee shall retain records of all monitoring information, including
o all calibration and maintenance records,
o all original strip chart recordings for continuous monitoring instrumentation,
o copies of all reports required by this permit,
o copies of all data used to complete the application for this permit
These records or copies shall be maintained for a period of at least 5 years from the date of the
sample, measurement, report or application. This period may be extended by request of the Director
at any time [40 CFR 122.41].
7. Inspection and Entry
The permittee shall allow the Director, or an authorized representative (including an authorized
contractor acting as a representative of the Director); or in the case of a facility which discharges
through a municipal separate storm sewer system, an authorized zed representative of a municipal
operator or the separate storm sewer system receiving'the discharge upon the presentation of
credentials and other documents as may be requireft law, to:
a. Enter upon the permittee's premises where a; r g lated;facility or activity is located or conducted,
or where records must be kept under the,conditions of this permit;
b. Have access to and copy, at reasonableftimes/�any records that must be kept under the conditions
of this permit; ^
c. Inspect at reasonable times any facilities, equipment (including monitoring and control
equipment), practices, or operations regulated or required under this permit; and
d. Sample or monitor at reasonable times; for the purposes of assuring permit compliance or as
otherwise authorized by -the Clean -Water Act, any substances or parameters at any location [40
CFR 122.41(i)].
SECTION E: REPORTING REQUIREMENTS
- 1E•� • �.
Samples analyzed in accordance with the terms of this permit shall be submitted to the Division on
Discharge Monitoring Report (DMR) forms provided by the Director. DMR forms are available on the
Division's website (hLtp://poi,tal-iicdenr,orawebJwq/ws/su/nl2dessw). Jwgfws/su/nodessw). Submittals shall be
delivered to the Division no later than 30 days from the date the facility receives the sampling
results from the laboratory.
When no discharge has occurred from the facility during the report period, the permittee is required
to submit a discharge monitoring report, within 30 days of the end of the specified sampling period,
giving all required information and indicating "NO FLOW" as per NCAC T15A 0213 .0506.
If the permittee monitors any pollutant more frequently than required by this permit using test
procedures approved under 40 CFR Part 136 and at a sampling location specified in this permit or
other appropriate instrument governing the discharge, the results of such monitoring shall be
included in the data submitted on the DMR.
The permittee shall record the required qualitative monitoring observations on the SDO Qualitative
Monitoring Report form provided by the Division and shall retain the completed forms on site.
Qualitative monitoring results should not be submitted to the Division, except upon DWQ's specific
requirement to do so. Qualitative Monitoring Report forms are available at the website above.
Part III Page 7 of 9

DRAFT Permit No. NCS000562
Submitting Reports
Two signed copies of Discharge Monitoring Reports (DMRs) shall be submitted to:
Central Files
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
3. Availability of,RQports
Except for data determined to be confidential under NCGS 143-215.3(a)(2) or Section 308 of the
Federal Act, 33 USC 1318, all reports prepared in accordance with the terms shall be available for
public inspection at the offices of the Division. As required by the Act, analytical data shall not be
considered confidential. Knowingly making any false statement on any such report may result in the
imposition of criminal penalties as provided for in NCGS 143-215"613 or in Section 309 of the Federal
Act.
4. Non-StormwaterDisc arges
If the storm event monitored in accordance with this permit coincides with a non-stormwater
discharge, the permittee shall separately monitor,all parameters as required under all other
applicable discharge permits and provide this,i formationfwith the stormwater discharge monitoring
report.
S. Planned Changes
The permittee shall give notice to the Director as,soon as possible of any planned changes at the
permitted facility which could.significantly-alter the nature or quantity of pollutants discharged [40
CFR 122.41(1)]. This notification requirement includes pollutants which are not specifically listed in
the permit or subject to notification�req irements under 40 CFR Part 122.42 (a).
6. Anticipated NQcomphanc/c1l//e
The permittee shall give advance notice to the Director of any planned changes at the permitted
facility which may result in•noncompliance with the permit [40 CFR 122.41(1)(2)].
7, aauh
The permittee shall report to the local DWQ Regional Office, within 24 hours, all significant spills as
defined in Part IV of this permit. Additionally, the permittee shall report spills including: any oil spill
of 25 gallons or more, any spill regardless of amount that causes a sheen on surface waters, any oil
spill regardless of amount occurring within 100 feet of surface waters, and any oil spill less than 25
gallons that cannot he cleaned up within 24 hours.
8. Bypass
Notice [40 CFR 122.41(m)(3)1:
a. Anticipated bypass. If the permittee knows in advance of the need for a bypass, it shall submit
prior notice, if possible at least ten days before the date of the bypass; including an evaluation of
the anticipated quality and affect of the bypass.
b. Unanticipated bypass. The permittee shall submit notice within 24 hours of becoming aware of
an unanticipated bypass.
9. Twenty-four Hour Reporting
a. The permittee shall report to the central office or the appropriate regional office any
noncompliance which may endanger health or the environment. Any information shall be
provided orally within 24 hours from the time the permittee became aware of the circumstances.
A written submission shall also be provided within 5 days of the time the permittee becomes
aware of the circumstances.
Part III Page 8 of 9

DRAFT Permit No. NCS000562
10.
11
The written submission shall contain a description of the noncompliance, and its causes; the
period of noncompliance, including exact dates and times, and if the noncompliance has not
been corrected, the anticipated time compliance is expected to continue; and steps taken or
planned to reduce, eliminate, and prevent reoccurrence of the noncompliance [40 CFR
122.41(1)(6)1.
b. The Director may waive the written report on a case -by -case basis for reports under this section
if the oral report has been received within 24 hours.
c. Occurrences outside normal business hours may also be reported to the Division's Emergency
Response personnel at [phone], [phone] or [phone].
Other NQnromniiance
The permittee shall report all instances of noncompliance not reported under 24 hour reporting at
the time monitoring reports are submitted [40 CFR 1,2Z,41(l)(7)_ ]\
Other Information
Where the Permittee becomes aware that it failed to,submitany relevant facts in a permit application,
or submitted incorrect information in a permit application.or in any report to the Director, it shall
promptly submit such facts or information [40�CF11-12141(1)(8)).
Part III Page 9 of 9

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

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

DRAFT Permit No. NCS000562
21. Point Source Discharge of Stormwater
Any discernible, confined and discrete conveyance including, but not specifically limited to, any pipe,
ditch, channel, tunnel, conduit, well, or discrete fissure from which stormwater is or may be
discharged to waters of the state.
22. Representative Oulfall Status
When it is established that the discharge of stormwater runoff from a single outfall is representative of the
discharges at multiple outfalls, the DWQ may grant representative outfall status. Representative outfall status
allows the permittee to perform analytical monitoring at a reduced number of outfalls.
23. SecondatyCQntainment
Spill containment for the contents of the single largest tank within the containment structure plus
sufficient freeboard to allow for the 25-year, 24-hour storm event
24. Section 313 Water iority Chemical
A chemical or chemical category which:
b. Is listed in 40 CFR 372.65 pursuant to Section 313 of Tit e III ofthe'S perfund Amendments and
Reauthorization Act (SARA) of 1986, also titled 'the'Emergency-Planning and Community Right -
to -Know Act of 1986;
c. Is present at or above threshold levels at a facility subjectto SARA title III, Section 313 reporting
requirements; and
d. Meets at least one of the following crite ri
i. Is listed in appendix D of 40 CFR.pa211/2r2l Table 11 (organic priority pollutants), Table III
(certain metals, cyanides, and�phenols).or Table IV (certain toxic pollutants and hazardous
v
substances
ii. Is listed as a hazard ous•subst nce,pursuant to section 311(b)(2)(A) of the CWA at 40 CFR
116.4; or
iii. Is a pollutant forrw` hick EPA has published acute or chronic water quality criteria.
25.
Substantial physical dainaee.to,prbperty, damage to the control facilities which causes them to
become inoperable, or substantial and permanent loss of natural resources which can reasonably be
expected to occur in the absence of a bypass. Severe property damage does not mean economic loss
caused by delays in production.
26. Significant Materials
Includes, but is not limited to: raw materials; fuels; materials such as solvents, detergents, and plastic
pellets; finished materials such as metallic products; raw materials used in food processing or
production; hazardous substances designated under section 101(14) of CERCLA; any chemical the
facility is required to report pursuant to section 313 of Title III of SARA; fertilizers; pesticides; and
waste products such as ashes, slag and sludge that have the potential to be released with stormwater
discharges.
27. SigniEcant S12ills
Includes, but is not limited to: releases of oil or hazardous substances in excess of reportable
quantities under section 311 of the Clean Water Act (Ref: 40 CFR 110.3and 40 CFR 117.3) or section
102 of CERCLA (Ref: 40 CFR 302.4).
28. StormwatQr Dischargef DO
The point of departure of stormwater from a discernible, confined, or discrete conveyance, including
but not limited to, storm sewer pipes, drainage ditches, channels, spillways, or channelized collection
areas, from which stormwater flows directly or indirectly into waters of the State of North Carolina,
Part IV Page 3 of 4 Pages

DRAFT Permit No. NCS000562
29. Stormwater Runoff
The flow of water which results from precipitation and which occurs immediately following rainfall
or as a result of snowmelt.
30. Stormwater AssociatQd_vyiLh Indpstrial Activity
The discharge from any point source which is used for collecting and conveying Stormwater and
which is directly related to manufacturing, processing or raw material storage areas at an industrial
site. Facilities considered to be engaged in "industrial activities" include those activities defined in 40
CFR 122.26(b)(14). The term does not include discharges from facilities or activities excluded from
the NPDES program.
31. 510r0}wgICE Pollution Prevention Plan
A comprehensive site -specific plan which details measures and practices to reduce Stormwater
pollution and is based on an evaluation of the pollution potential of the site.
32. Total Maximum Daily Load (TMDQ /�, / \
TMDLs are written plans for attaining and maintaining water qualit ndards, in all seasons, for a
specific water body and pollutant. A list of approved TMDLs for the,state of North Carolina can be
found at httn;llportal.ncdenr;orglweb/wa Ills /mtuItmdl
33. Toxic Pollutant
Any pollutant listed as toxic under Section 307(a) (I) of_the Clean Water Act.
34. Vehicle Maintenance Activity^ /
Vehicle rehabilitation, mechanical repairs, painting, fueling, lubrication, vehicle cleaning operations,
or airport deicing operations.
35. Visible Sedimentation
Solid particulate matter,�both miner Tand organic, that has been or is being transported by water, air,
gravity, or ice from its site�of origin�vvhich can be seen with the unaided eye.
36.
The maximum 24-hour precipitation event expected to be equaled or exceeded, on the average, once
in 25 years.
Part IV Page 4 of 4 Pages

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October 9, 2015
Via Electronic Mail andon.davidson (a7ncdenngy) and U.S. Mail
Mr. G. Landon Davidson
North Carolina Department of Environment and Natural Resources
Water Quality Regional Operations
Asheville Regional Office
2090 U.S. Highway 70
Swannanoa, NC 28778
Re: Notice of Violation/Notice of Intent to Enforce
NOV-2015-DV-0188 (BIMS Inc. 4201501151)
Rutherford County
Dear Mr. Davidson:
On September 24, 2015, Horsehead Metal Products, LLC (Horsehead) received the above -
referenced Notice of Violation/Notice of Intent to Enforce (NOV) related to a release of low pH, iL- i n C - a J4 n
solution at the Mooresboro facility. As requested, this letter provides a report assessing the
d cause, significance, and extent of the release and a plan listin all actions to prevent future
releases. Q
With respect to the allegation of discharge in violation of G.S. 143-215.83, the release of the
solution from the cellhouse containment was mitigated such that any discharge to the Broad
River would not have resulted in a violation of G.S. 143-215.83. Specifically, the definition. of
"discharge" in Article 21 a of Chapter 143 provides in relevant part as follows:
"Discharge" shall mean, but shall not be limited to, any emission, spillage,
leakage, pumping, pouring, emptying, or dumping of oil or other hazardous
substances into waters of the State or into waters outside the territorial limits of
the State which affect lands, waters or uses related thereto within the territorial
limits of the State, or upon land in such proximity to waters that oil or other
hazardous substances is reasonably likely to reach the waters, but shall not
include amounts less than quantities which may be harmful to the public health or
welfare as determined pursuant to G.S. 143-215.77A;
G.S. 143-215.77(4). Section 143-215.77a provides that quantities of designated hazardous
substances for putWscs of this Article are the quantities of designated hazardous substances as
established by, the EPA pursuant to Section 311 of the Clean Water Act. The EPA has
promulgated the quantities for designated hazardous substances at 40 C.F.R. § 117.3. The
regulatory quantity for sulfuric acid is 1,000 pounds. Given the concentration of sulfuric acid in
the released process solution and the subsequent efforts to mitigate any portion of the release
q��

HORSEHEAb METAL PR66d&rs, INC —I i� �
x. 4B4'HICKS.C3iiOV ROA>a _. .......- I )l<J,P� J``�/J
MOORESB012o, 11IOFi7H CAROL[NA 8114 ETAJ-'PFi4 DUC'x St 1i�TC
which reached the stormwater system, there is no reasonable potential that the regulatory
quantity for a "discharge" under G.S. 143-215.77a could have been released to the Broad River.
Upon discovery of the lower than typical pH in the energy dissipater on September 5, 2015, plant
personnel closed the main gate valve at the outfall to the Broad River and the gate valve on the
energy dissipater at Basin 1. The energy dissipater is the first structure in the Basin 1 system and
serves to slow stormwater as it enters Basin 1. Since there had been an extended period without
any substantial rainfall prior to September 5, 2015, Basin 1 was empty and no discharge to the
Broad River occurred to that point in time. The gate valves at the energy dissipater and Basin 1
remained closed throughout the investigation of the source of the lower than typical pH.
Following a rain event on September 9, 2015, approximately 200,000 gallons of water was
removed by vacuum truck from Basin 1. This water was recycled for use in the plant process.
Additionally, sediment in the energy dissipater and sediment in Basin 1 with any visible impacts
from the solution release were removed and placed in roll -off containers. Although the gate
valve at Basin 1 remained closed, a leak near the gate valve in the discharge structure was
discovered which allowed water from the basin to be discharged to the Broad River. While the
leak continued until a repair was completed at 7 p.m. on September 11, the remediation of the
sulfuric acid solution released to the stormwater system was concluded on September 9tt' and
thus mitigated any impacts to the stormwater in Basin 1 such that the quantity of sulfuric acid
discharges would not have reached the regulatory quantity for a "discharge" in violation of G.S.
143-215.83.
Additionally, despite any elevated concentrations of cadmium, lead and zinc in the water sample
referenced in the NOV, these elevated concentrations do not constitute an unlawful discharge
pursuant to G.S. 143-215.83. These metals are covered by the benchmark sampling
requirements under NPDES Stormwater Permit No. NCS000562, and therefore any elevated
levels of these metals would be addressed under the terms of that Permit. As such, any discharge
with these elevated metals would not be a discharge in violation of G.S. 143-215,83.
1. Report on the Release
On the evening of September 5, 2015, plant personnel identified a potential problem during the
course of routine inspection at Basin 1 of the facility stormwater system. Using a basic pH
testing strip, testing indicated a pH less than 6.0 Standard Units in the stormwater entering the
energy dissipater which is the first structure in the Basin 1 systems Further investigation
indicated that the source of the subject water may have been material inadvertently making its
way into the storm drain system from a malfunctioning pump in the vicinity of the cellhouse
earlier that day. On September 6, 2015, testing of water entering the energy dissipater again
indicated a lower than typical pH. A subsequent investigation was undertaken to identify the
source of water entering the stormwater system. This investigation revealed water entered the
1 Basin 1 is a sedimentation basin, and the energy dissipater serves to slow stormwater entering Basin 1.
Business Confidential Information

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

HORS>=MEAb META1 PRODUCTS, INC.
MOORESSORO, NORTH CAR 6Ni A' 281 14
Although plant personnel could not determine whether a reportable quantity of sulfuric acid had
been released, Horsehead called the NRC as a precautionary measure on September 9, 2015 at
3:30 pm, to advise the agency of the apparent release of process solution from the base of
secondary containment structure. After the call to the NRC, Horsehead notified the DENR
Regional Office by telephone. We understand that DENR notified the Forest City Fire
Department.
All secondary containment structures in the facility are constructed of reinforced concrete with
containment sizing based on 110% of the largest tank in the containment. Following the
discovery of the unsealed joint in the containment area under the cellhouse, Horsehead engineers
and maintenance personnel confirmed that no other areas in the facility have similar seal
problems.
Based on the available information, any discharge of the solution from the cellhouse containment
area to the Broad River was minimized through mitigation efforts following the initial discovery
of low pH at. the energy dissipater. As soon as the low pH condition of water entering the energy
dissipater was detected on September 5, 2015, plant personnel closed the main gate valve at the
outfall to the Broad River and the gate valve on the energy dissipater at Basin 1. Since there had
been an extended period without any substantial rainfall prior to September 5, 2015, Basin 1 was
empty and no discharge to the Broad River occurred to that point in time.
As noted above, on September 9th and loth, a rain event of approximately 0.7 inches of
precipitation occurred and stormwater entered Basin 1. At the time, the main gate valve on the
stormwater discharge outfall was closed and the water was retained in the basin. On September
9, 2015, a leak near the gate valve in the discharge structure was discovered which allowed water
from the basin to be discharged. Water discharged from the discharge structure was tested for
pH and found to be below 6.0 Standard Units. Vacuum trucks were mobilized to remove water
from Basin 1. Removed water was recycled for use in the plant process.
The small leak that allowed water to enter the Broad River resulted from a crack in the concrete
box that serves as the housing for the main gate valve. Hydraulic cement was used to seal the
crack and stop water from leaking through the concrete wall. These repairs were completed on
Friday, September 11, 2015, at approximately 7 p.m.
We determined that water at the concrete discharge structure entered the Broad River from mid-
day on September 9th until 7 p.m. on September 11. The duration of the leak was 55 hours. We
estimated the flow rate from the leak to be 10-15 gallons per minute (GPM). Sample analytical
results showed water discharged to the Broad River contained 3.36 mg(L cadmium, 0.541 mg/L
lead and 695 mg/L of zinc.
Business Confidential information

HORSEHEAD METAL PRODUCTS, INC.
�•RQVE-ROAD .>:.. - .:,,:...-..-._...., _.................... ?-=��
MOORE8BDR0, NORTH CAROUNA 28114 [w3`T AT: R.Oq, li' c l
2. Plan to Prevent Future Releases in Containment Areas
The following actions have been implemented to prevent a future releases:
As noted above, the defective joint in the containment area under the cellhouse in Area
200 has been repaired. Inspections will be performed on the containment areas for
cracks and repairs will be made as required.
A high level alarm will be installed on the cellhouse contaitunent to alert personnel if
liquid levels are elevated so action can be taken to draw the level down.
Weekly inspections have been initiated at the inlet and outlet of Basin 1, including
field tests for pH.
Horsehead remains committed to operating in a manner protective of the environment and
appreciates the Department's continued assistance as we continue through the startup phase at
the Mooresboro facility. If additional information is needed in support of this request, please call
me at 828-919-3139.
Sincere, ,
Jim Harris
Environmental Manager
Business Confidential Information

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

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Mr. Ken Pickle
March 16, 2012
Page 2
In addition, please find the following
included for your convenience:
information required in the application and
• Figure 1, Site Area Map, Stormwater NPDES Discharge Permit, Horsehead Corporation,
Rutherford County, North Carol a. dated February 2012.
X • DWG. No. E-0000-G-10046 Forest City N.C. SX/EW Plant, General Arrangement,
Storm Water Management Plan, Horsehead Corporation, prepared by Carnegie Strategic
Design Engineers, LLC, Release date March 1, 2012.
* Narrative describing the facility's operation, feedstock materials, reagents and products
and by-products.
• Letter from Horsehead Corporation to Mr. Charles Wakild, Deputy Director, North
Carolina Division of Water Quality, dated June 13, 2011.
• E-mail correspondence between yourself and Forrest Westall with McGill Associates,
P.A. dated November 30, 2011 and December 8, 2011, respectively.
✓ • Copy of the State of North Carolina, Division of Water Quality, Permit to Discharge
Wastewater under the National Pollutant Discharge Elimination System, Permit No.
NC0089109.
The objective of the proposed plan is to manage all stormwater for discharge from the facility
through a single monitored outfall to the Broad River. Stormwater from various areas of the
facility will be managed according to the following scheme:
1. Stormwater falling into various operating/production areas will be collected in segregated
collection basins underlying or adjacent to these areas, as designated, will be analyzed for
likely pollutants to determine its disposition. Based on analytical results, the water will
be discharged to the stormwater system, used in production process operations, or
possibly treated prior to discharge. This water is referred to as "discretionary storm
water" for discussion purposes.
2. Stormwater drainage from standard commercial or landscaped areas and perimeter
roadways,� roofed areas having no contact with industrial processes. This water will be
discharged directly to the stormwater system leading directly to the stormwater outfall.
This water is referred to as "non -discretionary storm water", and
CStormwater falling into a few designated operation areas will be collected in segregated
collection basins underlying the designated area(s) and used for production process
operations at all times, and not discharged to the stormwater system:
Cndeveloped areas (fil� and vegetated areas not affected by plant
C Stormwater from
activities) will be discharged through energy dissipation into natural drainage channels.
74i/174 unc% rc91aAtel

Mr. Ken Pickle
March 16, 2612
Page 3
i
Stormwater from described areas 1 and 2 above will discharge to the single monitored outfall for
the facility. Stormwater drainage from described areas in 3 above will not be discharged but will
be used in the production process. Stormwater drainage from described areas in 4 above,
including unaffected surrounding property, will discharge into natural drainage channels.
We appreciate your guidance and assistance on this important project. [n meetings over the past
year with you, permitting,in p lac as quickly as a7�cee.r
possible and well before the facility is scheduled for start up We anticipate that you will stand
by the commitment made by the Division of Water Quality to provide a quick review and action
on this permit application. If there is any aspect of this permit package thatVneeds clarification
lease contact me immediatelyko that the issue can be resol ied without delay. In addition, the
Division had indicated that a pre -draft of the permit (before notice) would be provided for our
review before a draft permit is directed to public notice.
If you have any questions please do not hesitate to contact
Sincerely,
HORSEHEAD CORPORATION
Timothy . Basilone
Vice President, Environmental Affairs
Enclosures
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cc: Forrest Westall, PE, McGill Associates, P.A. wr-Y ' .1
�' � rot LJ►'�/1 .f 'i� '

s\� cs o D C) "Su r
Please print or type in the unshaded areas only. Form Approved. OMB No. 2040-0086.
FORM U.S. ENVIRONMENTAL PROTECTION AGENCY I. EPA I.D. NUMBER
1 -.EPA GENERAL INFORMATION S =x
Consolidated Permits Program F p
GENERAL {Read the "Genervllnstrvctiow" before siarring,)
1 1, 13 1� 1R
LABEL ITEMS
I. EPA I.D. NUMBER
III. FACILITY NAME
GENERAL INSTRUCTIONS
if a preprinted label has been provided, affix it in the
designated space. Review the infDnna5on carefulty; if any of it
is incorrect, cross through it and enter the correct data in the
appropriate fill-in area below. Also, if any of the preprinted data
is absent (rhe area to the left of the label space lists the
information that should appear), please provide it in the proper
fill-in area(s) below. If the label is complete and correct, you
V. FACILITY MAILING need not complete Items I, III, V, and VI (except W-8 which
ADDRESS must be completed regardless). Complete all items if no label
has been provided. Refer to She instructions for detailed item
VI. FACILITY LOCATION descuiptians and for the legal authorizations under which this
data is collected.
II. POLLUTANT CHARACTERISTICS
INSTRUCTIONS: Complete A through J to determine whether you need to submit any permit application forms to the EPA. If you answer `yes' to any questions, you must
submit this form and the supplemental form listed in the parenthesis following the question, Mark 'X' in the box in the third column if the supplemental form is attached. If
you answer -no- to each question, you need not submit any of these forms. You may answer "no' if your activity is excluded from permit requirements; see Section C of the
instructions. See also, Section D of the instructions for definitions of bold-faced terms.
PLEASE PLACE LABEL IN THIS SPACE
Mark
W
Merk'x'
YES
No
Forth
ATfACHEp
YES
No
A FORM
SPECIFIC QUESTIONS
SPECIFIC QUESTIONS
A. Is this facility a publicly owned treatment works which
B. Does or will this facility (either exis5'ng or proposed)
results in a discharge to waters of the U.S.? (FORM 2A)
X
induce a concentrated animal feeding operation or
X
aquatic animal production facility which results in a
,e
v
,a
10
m
r
discharge to waters of the U.S.? (FORM 23)
C. Is this a facility which currently results in discharges to
waters of the U.S. other than those described in A or B
X
D. Is this a proposed facility (other than those described in A
or B above) which will result in a discharge to waters of
X
X
above? (FORM 2C)
the U.S.? (FT GXZD[ Form 2F
n
n
14
xs
m
n
E. Does or will this facility treat, store, or dispose of
F. 'Do you or will you inject at this facility industrial or
hazardous wastes? (FORM 3)
X
municipal effluent below the lowermost stratum
X
containing, within one quarter mile of the well bore,
20
ro
m
underground sources of drinking water? (FORM 4)
„
w
w
G. Do you or will you inject at this facility any produced water
H. Do you or will you inject at this facility fluids for special
or other fluids which are brought to the surface in
connection with conventional oil or natural gas production,
X
processes such as mining of sulfur by the Frasch process,
solution mining of minerals, in situ combustion of fossil
X
inject fluids used for enhanced recovery of oil or natural
fuel, or recovery of geothermal energy? (FORM 4)
gas, or inject fluids for storage of liquid hydrocarbons?
(FORM 4)
„
„
m
3]
3!
3➢
I. Is this facility a proposed stationary source which is one
J. Is this facility a proposed stationary source which is
of the 28 industrial categories listed in the instructions and
X
NOT one of the 28 industrial categories listed in the
�/
X
which will potentially emit 100 tons' per year of any air
instructions and which will potentially emit 250 tons per
pollutant regulated under the Clean Air Act and may affect
year of any air pollutant regulated under the Clean Air Act
40
*
a
'3
u
'�
or be located in an attainment area? (FORM 5)
and may affect or be located in an attainment area?
(FORM 5)
Ill. NAME OF FACILITY
1 SKIP Rut er ord County Pro uction Facility
17
es
EPA Form 3510-1 (8-90) CONTINUE ON REVERSE

enNITIN11Fr1 FROAA THF: FRnNr
VII. SIC CODES 4 14 to order of bri
FIRST
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OIL OPERATOR INFORMATION
A NAME
B.Is the name jisled In Vern
h lioree ea Corporation
Vill-Aalsomaowner?
0 YES fl NO
la ,.
C. STATUS OF OPERATOR (F.'ntrr the appropYarefeirer faro the a war box.,1 "Other," ec )
D. PHONE orra ro1.le & 110
F FEDERAL M a PUBLIC (otherthanfederal orstate)
S= STATE
(spat fj)
P
H.
(724) ' 7 73 - 2 2 2 3
O= OTHER (speck)
P =PRIVATE
is n
aI
tsthe far�ilylocated onIndian lands4
B
Fittsburgh
PA 151205 AYES 19NO
W Il . l
tl le
X- EXJSTiNG ENVIRONMENTAL PERMITS
D, PSD AVE�+rfsrbrrr roar Pro
dSorrrrrs
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A. NPOES lrrha Sorer
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B. UIC Urr irr rerradlrr ec!!a1 Fhdds
E. OTHER s rci •
T 1
g U
C
9
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N 1©000
(IaKfh1
IrPOEe 6tois Bier Colwtruction
aativitlea
t is I if is
C. RCRA frararrlora trkutesl
E. OTHER s
T
1I I I t I I
I
T
f[ntr1hr rreafon and Sediseatation control
SR
$
RUTHE-2o12-002
and 0�3 ■as - Phase t IRUnit-2012-002J and
Qhasa 7 fRVCa6-2a12-013)
is to
it t, ]I
13
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Attach to this application it topograpMe map of the area extending to at least one mile beyond property boundaries, The map must show the oughe of [he fiub'ty, the
location of each of Its aldslfng and proposed Intake and discharge strictures, each of Its hazardous waste treatment, storage, or disposal faalfitles, and each well where It
Injects fluids underground, tndude all springs, rivers, and outer surface weterbodies in the map area. Sae Instructions for precise mqutrements.
This newly constructed facility upon startup in the future will apply a proprietary hydroutetallurgical process
(solvent extraction / alectro winning) for producing high grade zinc metal frem two primary feed materials
including waelz oxide (a.k.a. crude zinc oxide) and zinc metal drosses and skims recovered from galvanizing
3perations. The production process includes use of feed materials in an aqueous and hydrocarbon based solvent
extraction process to produce a zinc rich electrolyte solution for use in a cell house where an eleotro winning
irocess in applied to produce metalic zinc. Similar technology is commonly used to produce metalic copper from
dined copper ore feed material in the western United Staten.
X111. CERTIFICATION {sea instructions)
l ceWy under penalty of taw that I have personalty examthed and am famldar 41h the Information submllled In this eppkcadan end al effachments and iha4 based an my
bV vhy of those persons Immedretely tespanstble for phfatrft the tnkrmagon confalnadin the appffca9oa4 1 belavo that the fnformadan is frlre, a_ccurafe, and compbfe. l
am aware that thera are slgnlffcant penaf6es forsubmIldng false fnrormaMap including the possWiy of tine andlmpdsonmont
A. NAME ti OFFICIAL TITLE (qpc orprhrri B. SIGNATUR C. DATE SIGNED
Timothy R. Saailoner Vice -President
Environmental Affairs dse.+• /2. -/01-
OF
EPA Form 3510-1 (8-90)

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

FIRST CITIZENS BANK
12MCGill
�V (� s O D fl 5 4 firstcitizens.com 052030
A S S O C I A T E S 66-30/531
DATE
RO. BOX 2259 : ASHEVILLE, NC 28802
PH: [phone]
March 29, 2012
f
PAY AMOUNT
Eight Hundred Sixty and 00/100 Dollars j
TO oeR 860.00
OF N.C. DENR
1633 Mail Service Center OPERATING ACCOUNT
Raleigh, NC 27699-1633
UTRORMED SIGNATURE V

IcGILL ASSOCIATES, RA.
Check Date: 3/29/2012
052030
Invoice Number
I Date
Voucher
Amount
Discounts
Previous Pay
Net Amount
I-lorsehead NPDES
3/29h012
1000000016892
860.00
860.0
N.C. DENR TOTAj_.
first Citizens Bank 2 NCDENR
860.00
860.0
F
APR Zd12

EPA ID Number (copy from Item I of Form 1) i Form Approved. OMB No. 2040-0085
Please print or type in the unshaded areas only. II f Approval expires 5-31-92
U.S. Environmental Protection Agency
FORM E PA Application for Washington, DC 20460
ZF Oto Permit to Discharge Storm Water
NPDES Discharges Associated with Industrial Activity
Paperwork Reduction Act Notice
Public reporting burden for this application is estimated to average 28.6 hours per application, induding time for reviewing instructions, searching existing data sources,
gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding the burden estimate; any other aspect
of this collection of information, or suggestions for improving this form, including suggestions which may increase or reduce this burden to: Chief, Information Policy
Branch, PM-223, U.S. Environmental Protection Agency, 1200 Pennsylvania Avenue, NW, Washington, DC 20460, or Director, Office of Information and Regulatory
Affairs, Office of Management and Budget, Washington, DC 20503.
11. Outfall Location
For each outfall, list the latitude and longitude of its location to the nearest 15 seconds and the name of the receiving water.
A. Outfall Number
(fist)
B. Latitude
C. Longitude
D. Receiving Water
(name)
1
N35
12
00
W81
51
06
Broad River
II. Improvements
A, Are you now required by any Federal, State, or local authority to meet any implementation schedule for the construction, upgrading or operation of wastewater
treatment equipment or practices or any other environmental programs which may affect the discharges described in this application? This includes, but is not limited
to, permit conditions, administrative or enforcement orders, enforcement compliance schedule letters, stipulations, court orders, and grantor loan conditions.
1. identification of Conditions,
Agreements, Etc,
2. Affected Outfalls
3. Brief Description of Project
4. Final
Compliance Date
number
source of discharge
a. req.
b, proj,
N/A - New Facility
N/A -New
N/A -New Facility
N/A - New Facility
Facility
B: You may attach additional sheets describing any additional water pollution (or other environmental projects which may affect your discharges) you now have under
way or which you plan. Indicate whether each program is now under way or planned, and indicate your actual or planned schedules for construction.
11. Site Drai
Attach a site map showing topography (or indicatin a outline of drama a areas served by the outfalls(s) covered in the application 0 a topographic map is unavailable)
depicting the facility including: each of its intake nd disc arge s ruc ures the drainage area of each storm water outfall; paved areas and buildings within the drainage
area of each storm water outfall, each known pas press as u—sFdTbr outdoor storage of disposal of significant materials, each existing structural control measure
to reduce pollutants in storm water runoff, materials loading and access areas, areas where pesticides, herbicides, soil conditioners and fertilizers are applied; each of
its hazardous waste treatment, storage or disposal units (including each area not required to have a RCRA permit which is used for accumulating hazardous waste
under 40 CFR 262.34); each well where fluids from the facility are injected underground; springs, and other surface water bodies which received storm water discharges
from the facility.
EPA Form 3510-21' (1-92) Page 1 of 3 Continue on Page 2

Continued from the Front
lV. Narrative Descrfptlon of Pollutant Sources
A For each autfal, provWs an oilknale of the area (induda uhds) of trihpodeus surfe m prrhaAng paved gross endq rods) drokied to Ow outfol, and an ssimets of the told sufsca area
drained by the oWas-
Outraa Area of kapervlaus Surface
ToW Area Grahed
owd
Area of krhFarNous Sufaca
TaalArea Drsloed
M"tcr 0XV0901 tsJ
0ovicla UAW
Number
42VON WW4Q
( MWO VMS)
1 acres
acras
B. Provide a narrative description of significant mater(ats that are currently or In the past three years hoia been treated, atoned or disposed In a manner to alloy axposufa
to storm water; method of (reatmant, storage, or disposal; past erid present rnatertals management praclfces employed to minimize contact by these mstodals with
storm viater runoff; materials loading and access areas, and the location, manner, and frequency In Wfhirh past(cldes, herbicides, sop conditioners, and Fertilizers we
applied.
This to a new facility under construction. A variety of liquid and solidaratertals will be used in the production porcese.
Process materials will be managed in tanks or containers, and will be transported via pipes throughout the operation. Rateria
exposed to stardwater Drill be minimized, and when necessary will bernanaged to avoid potential impact to atormwater discharged
from the facility. A SPCC plan and SWPPP will be developed and implemented, and employees iwll be trained to properly menage
materials prior to startup of the facility. Visual inspections and housekeeping requirements will be defined in the StiPPP and
SPC plans.
Feed materials include tfaelt oxide (crude zinc oxide) and zinc metal droaees and ekima recovered from galvanising operations.
(See attached sheet for addition information) .
C. For each outfall, provide the location and a descdpWn of extating structural and nonstructural control measures to reduce pollutants In storm water runoM and a
description of the treatment the storm water receives, irduding the sehedula and type of maintenance for control and treatment measures and the ultimate disposal
of any solid or euld wastes other than by discharge.
Outfall I I List Codes from
Number I Treatment Table 2F-1
lection basins. All. storm water captured in the containment basins will be analyzed prior to
:see to the atormwater system, rise in the production proceao, or treated and discharged, This
eme for managing atormwater in the production area of the facility and other areas of the
party will ninimfza the potential for polutants to enter stormwater that is discharged from the
e.
Nonstormwater
A. I certify under penalty of law hat the outfall(s) covered by this application have been tested or evolua(ed for the presence of nonstom'wialer discharges, and 'hot all
nonstormwater discharged from these outfail(s) are Identified In either an accompanying Form 2C or From 2E application for the ouVall.
Name and Official TItle (flee orpfnr) ISIgnaiure Data Signed
'imothy R. Hasilone, Vice -President
B. Provide a description of the method used, the date of any testing, and the onsite drainage points that were directly observed during a lest.
his is a new facility that is currently under construction. The facility will be designed and, constructed in a manner to
inimime the potential for entry of process materials in atormwater that In discharged.
t Leaks or
Provide exiatfng tnfarmation regarding the history of slgnff)cant leak$ or spills of toxic or hazardous paduiants at the facility In the last three years, including fha
approximate date and location of the spaf or leak, and the type and amount of material rateasad.
N/A - New Facility
EPA Form 3510-2F (1-92) Page 2 of 3 Continue on

Continued from Page 2
EPA 11) Number (copy from ffem 1 orFoan 1)
_
11. Discharge Information
A, B, C, & D: Sao Instfuctlons before proceeding. Complete one set of tables for each oulial. Annotate the oudal number In 9w* apace provided,
Table Vll-A, VII-B, VII-C are Included on saperate sheets numbers VII.1 and VII.2.
E. Potentlal discharyes not covered by analysts — Is any torch pollutant Wad In table 2F-2, 2F-0, or 2F-4. a substance or a component of a eubstanee which you
currently use ormanufaclure as an Intermediate or final product or byproduct?
© Yes (irsl al vch pollutants below) ❑ No (ga to Section N
Seo attached background information describing feadotock matarialy, process chemicals/reagents; and pollutants that will be
monitored in the process wastewater affluent. materials utilized and produced at the facility will be managed by personnel Chat
are trained In procedures daveloped to minimize the potential for release of materials to the environment, Materials will be
I managed to prevent the potential for entry in stormwater that is discharged from the facility.
111. Biological Toxicity Testing Data
Do you have any knoWedga or reason to baltave that any biological test for acute or chronic Welty has been mad* on any of your discharges or on a raceMng wafer in
relation to your discharge within (he last 3 years?
Q Yes (fist so such pollutant, belonv) Q No (go to Secllon DO
N/A vex ra❑ility
IX. Contract Analysts Information
Were any ofthe analyses reported to Item V11 pa rformed by a contract laboratory or consulting rum?
Yes (4sl the name, address and telephone num6erof, end poflutants ❑ No (go to Section X)
an, by, each such laboratory orfirm below)
A. Maine B. Address C. Area Code & Phone No. 0. Pollutants Analyzed
Tecnicas Reunidas Cl. Arapiles 13-14 [phone] Provided the background
29015 Madrid -Spain information for the
feedstock material,
anticipated process
chemicals/reagents and the
expected process Wastewater
affluent characteristics.
X. Certification
I eerfify under penally of lase that this document and ail eltachrnonls ivem propared under my cirectlon ar4upen4slon In accordance with a sysfem dcslgned to essuro
that quaRlod personnel property gather end evaruate the kwfw tOon subaAW Based W my htqufry of Ne person or persons who manage mo ayalom or chose, krsons
oirecfly responslbfe for gathering the Informafon, the rn1arma9m submrded 14 to the best of my knowledge and bel'of, true, a=wate, and complete. I am mvarm trial
!hero era sfgnf6cant penaftles for submilf&ng false Infomsad oiL ihcAOM;r Alrie possWily of r&te and hnpdsonmeW ter M/o OV vlalatims.
A. Name & Official We (Type Or P&O B. Area Code and Phone No.
Timothy R, Rasilone, Vice -President, Env.Rffairs [phone]
C. Slgnatura O, Mile Srgned
J-4A4 -IA-
EPA Form 3510.2F (1-92) Pago 3 of 3

EAA ID Number (copy from Item 1 o(Fonn 1)
r
Form Approved, OMB No. 2040-0086
Approval expires 5-31-92
VII. Discharge information (Continued from page 3 of Form 2F9
Part A — You must provide the results of at least one analysis for every pollutant in this table. Complete one table for each outfall. See instructions for additional details.
Maximum Values
Average Values
(include units)
(include units)
Number
Pollutant
of
Grab Sample
Grab Sample
and
Taken During
Taken During
Storm
CAS Number
First 20
Flow -Weighted
First 20
Flow -Weighted
Events
(ifavailable)
Minutes
Composite
Minutes
Composite
Sampled
Sources of Pollutaits
Oil and Grease
New Facility
NIA
Facility is under construction
Biological Oxygen
Demand (BODS)
New Facility
Facility is under construction
Chemical Oxygen
Demand (COD)
New Facility
Facility is under construction
Total Suspended
Solids(TSS)
New Facility
Facility is under construction
Total Nitrogen
New Facility
Facility is under construction
Total Phosphorus
New Facility
Facility is under construction
PH
Minimum New Facil
Maximum
Minimum
Maximum
Facility is under construction
IPart B — List each pollutant that is limited in an effluent guideline which the facility is subject to or any pollutant listed in the facility's NPDES permit for its process
wastewater (if the facility is operating under an existing NPDES permit). Complete one table for each outfall, See the instructions for additional details and
requirements.
Pollutant
and
CAS Number
(ifavailable)
Maximum Values
(include units)
Grab Sample
Taken During
First 20 Flow -Weighted
Minutes Composite
Average Values
(include units)
Grab Sample
Taken During
First 20 Flow -Weighted
Minutes Composite
Number
of
Storm
Events
Sampled
Sources of Pollutarts
TSS
Manufacturing
Process
NH3-N
Manufacturing
Process
Total Aluminum
Manufacturing
Process
Antimony
Manufacturing
Process
Arsenic
Manufacturing
Process
Total Cadmium
Manufacturing
Process
Chlorides
Manufacturing
Process
Total Chromium
Manufacturing
Process
Total Cobalt
Manufacturing
Process
Total Copper
Manufacturing
Process
Fluoride
Manufacturing
Process
Total Iron
Manufacturing
Process
Total Lead
Manufacturing
Process
Total Nickel
Manufacturing
Process
Total Tin
Manufacturing
Process
Total Zinc
Manufacturing
Process
PH
Manufacturing
Process
ChronicTexicity
Manufacturing
Process
Turbidity
Manufacturing
Process
EPA Form 3510-2F (1-92) Page VII-1 Continue on Reverse

Continued from the Front
Part C - List each pollutant shown in Table 2F-2, 2F-3, and 2F-4 that you know or have reason to believe is present. See the instructions for additional details and
requirements. Complete one table for each outfali.
Mapmum Values Average Values
(include units) (include units)
Pollutant Grab Sample Grab Sample
and Taken During Taken During
CAS Number First20 Flow -Weighted First20 Flow -Weighted
(ifavailabfe) Minutes Composite Minutes Composite
Number
of
Storm
Events
Sampled
Sources of Pollutants
The facil ty is designed and will be constructed and operated in
I manner to
minimize the potential for
materials to enter sto mwater that is discharged The production
area will
le underlain by containment
basins for capturing s ormwater. Sto mwater in he basins will b
analyzed
lefore being discharged to the
stormwater system, used for production processes, or treated and
discharged.
fPart D — Provide data for the storm event(s) which resulted 'n the maximum values for the flow weighted composite sample. J
4.
5.
1.
2.
3.
Number of hours between
Matamum flow rate during
6.
Date of
Duration
Total rainfall
beginning of storm measured
rain event
Total flow from
Storm
of Storm Event
during storm event
and end of previous
(gallonshninute or
rain event
Event
(in minutes)
(in inches)
measurable rain event
specify units)
(gallons or specify units)
N/A - New
Facility
7. Provide a description of the method of flow measurement or estimate.
stormwater system is designed to manage a 100-year storm event.
EPA Form 3510.2F (1.92) Page VI 1-2

TIMOTHY R. BASELONE
Vice Aesidrnl - briniourverifal Affairs
4955 STEu BENv11.1.E PEKE
SUJTE 405
PITTSBURGH, PA 15205
March 26, 2012
WWW.HORSEHEAO.NET 724.773.2223
TBIl5r1.ONE0H0R9EHEAQ.NET 412.788.4526
Mr. Ken Pickle
Environmental Engineer
North Carolina Department of Environment
and Natural Resources
Division of Water Quality
Stormwater Permitting Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Re: NPDES Stormwater Permit Application
Horsehead Corporation
Rutherford County, North Carolina
CORPORATION
bradirig 7hr Warfel in Zinc Recycling
!2
v � f/� 6as p��� a �►�r� �lln
'�� di5�uss
MAR ?82012
Dear Mr. Pickle:
,CIPv.�osc a� f�iis Ph�aJe '2
(in accordance with our prior discussions with you occ_ rring over the past year an NPDES
Stormwater Permit .Application has been completed or the new Horsehead Corporation
(Horsehead) facility that is currently under development Rutherford County. As described in
the attached application, a stormwater management system has been developed(that is integral to
the operation of this facility and) that is designed to m nrmlze the potential for discharge of
pollutants in stormsw�ater from the site.
�,,Y�%ldfdaeJ T/7�S 'n�BiJ ,� G�-S%pi�•T.L�nC'e
Please find enclosed three (3) copies of the following docients:
+ ✓i
y
EPA Form 3510-1,
General Information and EPA Form 3510-2F, and
The Application for Permit to Discharge Storm W ter associated with Industrial Activity
for the Rutherford County Production Facility presently being constructed by the
Horsehead Corporation.
j11fia/ su6Mr#a/ J/2-�/:Z
Chem dn� �arrr°cl alre"'I ,rece�r�� ��laoly
41SI.2o/Z
r
r

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

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Aug. 2, 2015 ~
PUBLIC NOTICE
N.C. DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES INTENT TO ISSUE
NPDES STORMWATER DISCHARGE PERMIT #NCS000574
Public comment on the draft permit is invited. All comments received by Sept. 10, 2015 will be
considered in the final determination regarding permit issuance and permit provisions.
PERMIT APPLICATION i 1.
Duke Energy Carolinas, LLC, 526 South Church St., Charlotte, N.C., has appiied for an NPDES
stormwater permit for the Rogers Energy Complex (formerly known as the Cliffside Steam Station), 573
Duke Power Rd., Mooresboro, N.C., Cleveland and Rutherford counties. The facility is a coal-fired
power plant, which discharges industrial stormwater.to.Suck Creek and the Broad River.
The draft stormwater permit and related documents are available online at:
http:/Iportal.ncdenr.org/web/guest/duke-npdes-permits. Printed copies of the draft permit and related
documents may be reviewed at the department's Mooresville Rdgional Office, 610 East Center Ave.
Suite 301, Mooresville, N.C. To make an appointment to review the documents, please call 704-663-
1699.
Public comment on the draft permit should be mailed to: Stormwater Permitting, 1612 Mail Service
Center, Raleigh, N.C., 27699-1612.
Public comments may also be submitted by email to: Publiccommerits &ficdenr.gov. Please be sure to
include "Cliffside" in the email's subject line.
PUBLIC HEARING
The N.C. Department of Environment and Natural Resources will hold a public hearing to accept
comments on the draft permit on Thursday, Sept. 10 at 6 p.m. at Boiling Springs City Hall, 114 East
College Ave., Boiling Springs, N.C. Registration for speakers begins at 5 p.m.

LUdUVU veydlllt;
Pregnant Leach Solution
Recycles:
Hf R�1; HI E;A
METAL PRODUCTS, INC.

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Pickle, Ken
From: Forrest Westall <[e-mail]>
Sent: Wednesday, January 27, 2016 7:02 AM
To: Belnick, Tom; Chernikov, Sergei; Pickle, Ken
Subject: FW: Horsehead Idling Mooresboro Facility
Hello,
I thought you may be interested in this development. I have had no contact with them for quite a while. We parted
ways over their approach to compliance.
FYI.
Forrest
http://rccatalyst.com/?p=3 575 5

Horsehead putting Mooresboro facility on idle I RC Catalyst Page 1 of 2
Home Search in site... Q
L RC Datalyst Cor Rut"u,theerfnr riews
uraf Carunty"
HOME BUSINESS DAYTRIPS EVENTSCALENDAR OPINION OBITUARIES SUBMITYOURSPORY
Horsehead putting Mooresboro facility on idle
Added by Staff Reporter on 02/25/2o16.
Saved under Business, News
MOORESBORO — Horsehead Holding Corp.
(NASDAQ: ZINC) today announced that it is
temporarily idling its Mooresboro, North
Carolina zinc production facility.
The Company stated that the decision to
temporarily idle the facility is the result of many
factors, including a depressed zinc price which
recently has languished near its seven year low
and the Company's current liquidity situation.
A small workforce will be retained to manage the facility during this period.
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4b 0
Aiken, Stan E
From: Pickle, Ken
Sent: Friday, February 26, 2016 10:46 AM
To: Aiken, Stan E
Cc: Bennett, Bradley; Walker, Fred
Subject: Horsehead spill and Stormwater Permitting Program wrap up for now
Hi Stan,
It's Friday, and I'm trying to wrap-up/nail-down a few issues that crossed my desk over the last couple of weeks,
including our comments on the February spill at Horsehead and the suspension of start-up and manufacturing
activities. I've spoken with Bradley (programmatic concerns) and with Mike Lawyer (experienced in
enforcement/implementation of our permits from a Regional Office perspective.) Most of this we have already covered,
but just in case it comes up again in ARO, here's where I think we should be (based on what I think we know about the
site and spill):
• They have not applied for rescission of the stormwater permit yet, but if they do it would not be automatic for
us. I think there's a reasonable case to be made that we would require them to clean up the site (remove
potential stormwater exposure to our satisfaction) before we would rescind the permit. We have the authority
in federal rule to require continuing permit coverage and compliance even if the plant shuts down. Continuing
on this idea, ARO or RCO should advise HH that the permit is still in effect until we officially rescind it. Do you
guys want to do that, or would you prefer me to?
• The "Storm Pond" should never discharge directly to surface waters based on our understanding of its use and
contents. Discharge of the fluids in that basin is not authorized under the our stormwater permit, NCSOOOS62.
• With respect to the February 2016 spill:
o The text of the permit requires HH to provide secondary containment. Arguably leaking secondary
containment is no secondary containment, and results in a violation of permit conditions. So, yes there
has been a permit violation. However, I have the impression that their response was pretty good, and
that no zinc solution reached the receiving waters. ARO can decide if issuing an NOV/NOD is
appropriate.
o On the same topic, the text of the permit requires the permittee to properly operate and maintain all
systems for pollution control at all times. Again, leaking secondary containment is evidence of the
permittee's failure to properly operate and maintain that control system. Again, again --your call on
how much to make out of this.
o Summary: Yes, the circumstances of the spill amount to a permit violation. The appropriate level of our
response to the violation deserves careful consideration.
know you all have been out to the site several times during construction and start up, but I don't see a BIMS
entry for a permit compliance inspection. If HH is high on your radar, consider if it's time for a compliance
inspection. The fact that they are shutting down operations might ease our concerns a little, but imo reduced
staff and management attention to the physical plant along with atypical operations (shut down procedures)
would increase our concerns to an even greater degree.
o It might be worthwhile to get copies and review all their stormwater monitoring results as part of the
inspection. (I'd like to see those, too.)
o After the big spill in 2015 HH promised to go around to all the containments and
inspect/repair/revise/address the failure mechanism (seam between tank wall and containment wall)
identified in that spill. Can they provide work orders/logs/ physical evidence that indeed they did that
to a substantial extent?
o Do they intend to do the same thing for the failure mechanism in this second spill (I mean both the
water line break and the containment failure.)

Ken 0
Ken Pickle
Stormwater Program Specialist
DEMLR Stormwater Permitting Program
Department of Environmental Quality
919 807 6376 office
ken. pickleCa ncdenr.gov
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury St, Raleigh, NC 27604
Nothing Compares--,,
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

•
•
Aiken, Stan E
From: Harris James <[e-mail]>
Sent: Thursday, February 25, 2016 3:32 PM
To: Aiken, Stan E; Walker, Fred
Cc: Staley Anthony; Hoenecke Scott; Howell Charles; Ali Alavi
Subject: Basin 1
We detected a small flow of stormwater entering Basin 1 today with a pH of 4.5 and we closed the Basin 1 outlet gate to
ensure that none entered the river. We dispatched a vacuum truck to the basin to remove the stormwater.
We inspected the SX/EW area and believe the source was the stormwater from the roof of the EW building. While the
majority of this stormwater is already being redirected to the SX area for use in the process, we have a few downspouts
that need to be included in this recycling process. These downspouts are being redirected to flow into the containment
and pumped to the SX area.
If you have any questions, please let me know.
Jim Harris I Environmental Manager
Horsehead Metal Products Inc.
NiCTAL PRODUCTS, INC.
484 Hicks Grove Road, Mooresboro i North Carolina 28114
C: 828-748-5283 1 P: 828-919-3139
IharrisCoMorsehead. net

0
0
Aiken, Stan E
From: Harris James <[e-mail]>
Sent: Friday, February 19, 2016 4:24 PM
To: Aiken, Stan E
Cc: Staley Anthony; Belland, Greg
Subject: Water Discharge from the Final Zinc Concentrate Area
Stan,
Today at 830 am, a small flow of storm water (estimated to be 1 gallon per minute) left the final zinc concentrate
containment and pooled near the storm drain located north of the cellhouse. This storm drain flows to the energy
dissipater at Basin 1. We estimated that the water flowed for about 3 hours. The valve on the energy dissipater was
closed and water collected inside this concrete containment. A vacuum truck was dispatched promptly to Basin 1 to
remove this material and return it to the production process. This water stream did not enter the river.
If you have any questions, please advise.
.dim Harris I Environmental Manager
Horsehead Meta! Products Inc.
*;/� R
1�- :0R.S. E; �H' , D,
METAL PRODUCTS, INC.
484 Hicks Grove Road, Mooresboro North Carolina 28114
C: 828-748-5283 1 P: 828-919-3139
jharris(c�horsehead.net
1

•
Aiken, Stan E
From: Pickle, Ken
Sent: Friday, February 19, 2016 1:47 PM
To: Davidson, Landon; Menzel, Jeff; Burch, Brent; Heim, Tim
Cc: Bennett, Bradley; Aiken, Stan E
Subject: FW: Description of Ponds
Hi guys,
Thanks for bringing us up to speed. I'll talk with Bradley a little more about this over the next few days to see what/if
this may mean under our permit coverage of Horsehead.
Ken
Ken Pickle
Stormwater Program Specialist
DEMLR Stormwater Permitting Program
Department of Environmental Quality
919 807 6376 office
ken. [e-mail]
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury St, Raleigh, NC 27604
Nothing Compares--,,—,,
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Davidson, Landon
Sent: Friday, February 19, 2016 1:26 PM
To: Menzel, Jeff <[e-mail]>; Burch, Brent <[e-mail]>; Aiken, Stan E
<[e-mail]>; Pickle, Ken <[e-mail]>
Cc: Heim, Tim <[e-mail]>
Subject: RE: Description of Ponds
To all,
Thanks Jeff. This is a good revision or correction to my email from yesterday. This sentence regarding the stormwater
pond: Most likely there is zinc and other constituents within this sediment the concentrations are not known at this time.
could suggest a potential violation of the stormwater permit? Does there need to be more investigation into how the
ponds, or at least the SW capture pond, is being used and its connection to stormwater outlets? I just don't have the
background on the SW side for this type of facility where SW is captured in ponds that are bled into a process and if
recycling occurs in that same pond.

•
G. Landon Davidson, P.G.
Regional Supervisor — Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4680 office
828 230 4057 mobile
Landon, Davidson(aDncdenr.g ov
2090 U.S. Hwy. 70
Swannanoa, N.C. 28711
�r'Nothing Compares.. --,-
Email correspondence to and from this address is subject to the
!North Carolina Public Records Law and may be disclosed to third parties.
From: Menzel, Jeff
Sent: Friday, February 19, 2016 11:39 AM
To: Burch, Brent <brent.burch ncdenr. ov>
Cc: Davidson, Landon <[e-mail]>; Aiken, Stan E <[e-mail]>
Subject: Description of Ponds
On the West side of the HH property there is a series of 4 lined ponds. Starting south and going north the ponds are
called the following names; Storm pond, West Maintenance Pond, Raffinate Pond, and Depleted Solution Pond.
I. Storm Pond. Collects storm water from the road ways on the western half of the property. Collected storm
water than can be introduced into the process as needed or if there is a surplus after a storm event the water is
routed through bleed treatment and discharged as wastewater: There is approximately 3 to 4 feet of material in
the bottom of this pond consisting of sediment introduced during construction and process materials
introduced through spills, tracked materials washing off roadways, etc. Most likely there is zinc and other
constituents within this sediment the concentrations are not known at this time.
2. West Maintenance Pond. This pond was designed to collect storm water and process materials
within secondary containment units on the west side of the property. This water can be introduced back into
the process to recover process materials.
I am unsure the extent of sedimentation within this pond.
3. Raffinate Pond. Collects water from the 200 Area Raffinate secondary containment. Can be introduced back into
process.
4. Depleted Solution Pond. Spent electrolyte solution can be introduced back into process to be combined with
organic solvent to hold the purified zinc in solution or can be routed through bleed treatment to remove built
up impurities or contaminants.
During this idling period the facility will have to continue to process storm water on the west side of the property. They
will do this by collecting the water from west roadways and containment units, routing storm water to the Storm and
West maintenance ponds, and then processing in the bleed treatment process to be discharged from their 001

wastewater outfall. Other parts of facility which will also have to remain active during this time included units which
process the organic solvent solution and the zinc furnace.
There was a release this week to storm water Basin 1. The spill was contained in the energy dispersion unit. A 2" city
water line broke around 5 am this water flowed into the WOX silos containment. A leaked then occurred in the WOX
silo containment wall seam and the water made its way into the storm water system on the east side of the property.
The concrete energy dispersion unit collected the water and they were able to pump and haul from this unit so there
was no discharge to the other parts of the storm water basin.
Jeff Menzel
Western Region Environmental Specialist
Hazardous Waste Section
Division of Waste Management
828 419 5034 office
919 270 1967 cell
[e-mail]
PO Box 1568
Black Mountain, NC 28711
N .1 -
"Nothing Compares
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

•
Aiken, Stan E
From:
Harris James <[e-mail]>
Sent:
Friday, February 19, 2016 12:04 PM
To:
Aiken, Stan E
Cc:
Staley Anthony; Ali Alavi; Belland, Greg
Subject:
Water Pipe Break at the WOX Silo Area
Stan,
Per your request, I am sending this email to provide a summary of the water pipe failure that
occurred yesterday.
A 2 inch water pipe broke inside the WOX silo containment area and some of this water leaked
out at a concrete seam in the containment wall. This water leaked into the storm drain and
was captured in the concrete -lined energy dissipater at Basin 1. We sent a vacuum truck
immediately to Basin i and removed this water solution and placed it in the SX production
plant. In addition, we have installed hydraulic cement in the containment crack and this
repair will prevent leakage at that point in the future.
If you have any questions, let me know.
Jim Harris I Environmental Manager
Horsehead Metal Products Inc.
R
MFTAL. PnonuCTS, INC.
484 Hicks Grove Road, Mooresboro 1 North Carolina 28114
C: 828-748-5283 1 P: 828-919-3139
0harris(cDhorsehead.net

0
Aiken, Stan E
From: Menzel, Jeff
Sent: Friday, February 19, 2016 11:39 AM
To: Burch, Brent
Cc: Davidson, Landon; Aiken, Stan E
Subject: Description of Ponds
On the West side of the HH property there is a series of 4 lined ponds. Starting south and going north the ponds are
called the following names; Storm pond, West Maintenance Pond, Raffinate Pond, and Depleted Solution Pond.
Storm Pond. Collects storm water from the road ways on the western half of the property. Collected storm
water than can be introduced into the process as needed or if there is a surplus after a storm event the water is
routed through bleed treatment and discharged as wastewater. There is approximately 3 to 4 feet of material in
the bottom of this pond consisting of sediment introduced during construction and process materials
introduced through spills, tracked materials washing off roadways, etc. Most likely there is zinc and other
constituents within this sediment the concentrations are not known at this time.
2. West Maintenance Pond. This pond was designed to collect storm water and process materials
within secondary containment units on the west side of the property. This water can be introduced back into
the process to recover process materials.
i am unsure the extent of sedimentation within this pond.
3. Raffinate Pond. Collects water from the 200 Area Raffinate secondary containment. Can be introduced back into
process.
4. Depleted Solution Pond. Spent electrolyte solution can be introduced back into process to be combined with
organic solvent to hold the purified zinc in solution or can be routed through bleed treatment to remove built
up impurities or contaminants.
During this idling period the facility will have to continue to process storm water on the west side of the property. They
will do this by collecting the water from.west roadways and containment units, routing storm water to the Storm and
West maintenance ponds, and then processing in the bleed treatment process to be discharged from their 001
wastewater outfall. Other parts of facility which will also have to remain active during this time included units which
process the organic solvent solution and the zinc furnace.
There was a release this week to storm water Basin 1. The spill was contained in the energy dispersion unit. A 2" city
water line broke around S am this water flowed into the WOX silos containment. A leaked then occurred in the WOX
silo containment wall seam and the water made its way into the storm water system on the east side of the property.
The concrete energy dispersion unit collected the water and they were able to pump and haul from this unit so there
was no discharge to the other parts of the storm water basin.
Jeff Menzel
Western Region Environmental Specialist
Hazardous Waste Section
Division of Waste Management
828 419 5034 office
919 270 1967 cell
[e-mail]
PO Box 1568
Black Mountain, NC 28711

<%'Nothing Compares,,,,.,,,,
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

0 0
Aiken, Stan E
From: Pickle, Ken
Sent: Friday, February 19, 2016 8:32 AM
To: Aiken, Stan E
Subject: RE: Horse Head process ponds area
Thanks Stan, that's also my recollection of our conversations with the Horsehead folks.
Ken Pickle
Stormwater Program Specialist
DEMLR Stormwater Permitting Program
Department of Environmental Quality
919 807 6376 office
ken. [e-mail]
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury St, Raleigh, NC 27604
Nothing Compares_
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Aiken, Stan E
Sent: Wednesday, February 17, 2016 5:19 PM
To: Pickle, Ken <[e-mail]>; Menzel, Jeff <[e-mail]>; Walker, Fred
<fred.walker@ ncdenr.gov>
Cc: Bennett, Bradley <bradley. [e-mail]>
Subject: RE: Horse Head process ponds area
Ken,
Just to confirm our conversation, it is my recollection that the basins on the northwest were the ones that Horsehead
claimed they had capability of discharge but they had never discharged and did not intend to but instead chose to use as
process water. Also, per our conversation, we thought it might have been listed as a wastewater discharge outfall.
Thank You,
Stanley E Aiken
Regional Engineer
Land Quality Section
North Carolina Department of Environmental Quality
828 296-4500 main
828 296-4610 office
stan.aiken ncdenr. ov
1

2090 US70 Highway
Swannanoa, NC 28778-8211
!� Nothing Compares...
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Pickle, Ken
Sent: Wednesday, February 17, 2016 2:31 PM
To: Menzel, Jeff<[e-mail]>; Aiken, Stan E <stan.a![e-mail]>; Walker, Fred
<[e-mail]>
Cc: Bennett, Bradley <bradle [e-mail]>
Subject: RE: Horse Head process ponds area
Bradley,
I think you're right. I assume they are part of either the process water or wastewater systems.
can report that the basins on the north west were never part of our considerations for coverage under the stormwater
permit. Whether they were contemplated in the wastewater permit development or not I do not know.
As is typical with our industrial NPDES stormwater permits, the Horsehead stormwater permit authorizes iusi t the
discharge of stormwater.
• We didn't "permit" any basins: not as to construction, or operation, or the discharge from any
specifically identified basin;
• Any discharge from the site other than a stormwater discharge is not authorized by our permit.
Ken
Ken Pickle
Stormwater Program Specialist
DEMLR Stormwater Permitting Program
Department of Environmental Quality
919 807 6376 office
ken. [e-mail]
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury St, Raleigh, NC 27604
—fNothing Compares
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
2

•
U
Aiken, Stan E
From: Pickle, Ken
Sent: Wednesday, February 17, 2016 2:31 PM
To: Menzel, Jeff; Aiken, Stan E; Walker, Fred
Cc: Bennett, Bradley
Subject: RE: Horse Head process ponds area
Bradley,
I think you're right. I assume they are part of either the process water or wastewater systems.
I can report that the basins on the north west were never part of our considerations for coverage under the stormwater
permit. Whether they were contemplated in the wastewater permit development or not I do not know.
As is typical with our industrial NPDES stormwater permits, the Horsehead stormwater permit authorizes just t the
discharge of stormwater.
• We didn't "permit" any basins: not as to construction, or operation, or the discharge from any
specifically identified basin;
• Any discharge from the site other than a stormwater discharge is not authorized by our permit.
Ken
Ken Pickle
Stormwater Program Specialist
DEMLR Stormwater Permitting Program
Department of Environmental Quality
919 807 6376 office
[e-mail]
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury St, Raleigh, NC 27604
Nothing Compares„-,,
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Bennett, Bradley
Sent: Wednesday, February 17, 2016 12:27 PM
To: Pickle, Ken <[e-mail]>
Subject: FW: Horse Head process ponds area
Ken
See question below. If I recall, I think these all end up being part of the process wastewater system?
E

Bradley Bennett
Stormwater Permitting Program Phone: [phone]
NC Division of Energy, Mineral and Land Resources Fax: [phone]
1612 Mail Service Center Email: brad ley. bennettncdenr. ov
Raleigh, NC 27699-1612 Web: http://portal.ncdenr,orgtweb/Ir/stormwater
Email correspondence to and from this address may be subject to public records laws
From: Menzel, Jeff
Sent: Wednesday, February 17, 2016 12:06 PM
To: Aiken, Stan E <[e-mail]>
Cc: Bennett, Bradley <bradley. ben [e-mail]>; Walker, Fred <[e-mail]>
Subject: FW: Horse Head process ponds area
Afternoon Stan,
I am interested in knowing what the process ponds on the north west side of the Horsehead property are permitted for?
Are they permitted to receive material/process storm water?
See you guys tomorrow.
Thanks,
Jeff
Jeff Menzel
Western Region Environmental Specialist
Hazardous Waste Section
Division of Waste Management
828 419 5034 office
919 270 1967 cell
Jeff.menzel @ ncden r.gov
PO Box 1568
Black Mountain, NC 28711
L
Nothing Compares.-,,,__
M
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Burch, Brent
Sent: Wednesday, February 17, 2016 11:20 AM
To: Menzel, Jeff <'eff.menzel ncdenr. ov>
Subject: RE: Horse Head WOX area
Jeff can you find out what permits have been issued on the process ponds (what EPA is referring to as surface
impoundments). Check with Stan Aiken to find out if they were permitted to receive process materials. It may be Bradley
Bennett's group with DMLR in Raleigh but Stan should know.
Brent G. Burch
Compliance Branch Head
K

Hazardous Waste Section
Division of Waste Management
828 321 9585 office
919 270 2049 mobile
[e-mail]
PO Box 1427
Andrews, NC 28901
Download pictures
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed
to third parties.

•
Aiken, Stan E
From: Menzel, Jeff
Sent: Wednesday, February 17, 2016 12:06 PM
To: Aiken, Stan E
Cc: Bennett, Bradley; Walker, Fred
Subject: FW: Horse Head process ponds area
Afternoon Stan,
I am interested in knowing what the process ponds on the north west side of the Horsehead property are permitted for?
Are they permitted to receive material/process storm water?
See you guys tomorrow.
Thanks,
Jeff
Jeff Menzel
Western Region Environmental Specialist
Hazardous Waste Section
Division of Waste Management
828 419 5034 office
919 270 1967 cell
[e-mail]
PO Box 1568
Black Mountain, NC 28711
Nothing Compares..--,
w
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Burch, Brent
Sent: Wednesday, February 17, 2016 11:20 AM
To: Menzel, Jeff <[e-mail]>
Subject: RE: Horse Head WOX area
Jeff can you find out what permits have been issued on the process ponds (what EPA is referring to as surface
impoundments). Check with Stan Aiken to find out if they were permitted to receive process materials. It may be Bradley
Bennett's group with DMLR in Raleigh but Stan should know.
Brent G. Burch
Compliance Branch Head
Hazardous Waste Section
Division of Waste Management
1

828 3219585 office
919 270 2049 mobile
[e-mail]
PO Box 1427
Andrews, NC 28901
Download pictures
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed
to third parties.

0
0
From: Bennett, Bradley
Sent: Wednesday, February 17, 2016 12:27 PM
To: Pickle, Ken <[e-mail]>
Subject: FW: Horse Head process ponds area
Ken
See question below. If I recall, I think these all end up being part of the process wastewater system?
M.
Bradley Bennett
Stormwater Permitting Program Phone: [phone]
NC Division of Energy, Mineral and Land Resources Fax: [phone]
1612 Mail Service Center Email: bradley.bennett(c�ncdenr.gov
Raleigh, NC 27699-1612 Web: http:llportal.ncdenr.org/web/Ir/stormwater
Email correspondence to and from this address may be subject to public records taws
From: Menzel, Jeff
Sent: Wednesday, February 17, 2016 12:06 PM
To: Aiken, Stan E <[e-mail]>
Cc: Bennett, Bradley <[e-mail]>; Walker, Fred <[e-mail]>
Subject: FW: Horse Head process ponds area
Afternoon Stan,
1 am interested in knowing what the process ponds on the north west side of the Horsehead property are permitted for?
Are they permitted to receive material/process storm water?
See you guys tomorrow.
Thanks,
Jeff
Jeff Menzel
Western Region Environmental Specialist
Hazardous Waste Section
Division of Waste Management
828 419 5034 office
919 270 1967 cell
[e-mail]
PO Box 1568
Black Mountain, NC 28711
—Nothing Compares--,... -
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Burch, Brent
Sent: Wednesday, February 17, 2016 11:20 AM
3

To: Menzel, Jeff <leff.menzel�ncdenr gov>
Subject: RE: Horse Head WOX area
Jeff can you find out what permits have been issued on the process ponds (what EPA is referring to as surface
impoundments). Check with Stan Aiken to find out if they were permitted to receive process materials. It may be Bradley
Bennett's group with DMLR in Raleigh but Stan should know.
Brent G. Burch
Compliance Branch Head
Hazardous Waste Section
Division of Waste Management
828 3219585 office
919 270 2049 mobile
[e-mail]
PO Box 1427
Andrews, NC 28901
Download pictures
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed
to third parties.

•
•
Aiken, Stan E
From:
Sent:
To:
Cc:
Subject:
Thanks for your help, Melissa!
Munger, Bridget
Wednesday, February 10, 2016 11:01 AM
King, Melissa
Aiken, Stan E; Walker, Fred
RE: Horsehead email 3/3
Bridget Munger
Public Information Officer
N.C. Department of Environmental Quality
Division of Energy, Mineral and Land Resources
Division of Water Resources
919-807-6363 office
919-268-0069 mobile
bridget. munger(aD_ncdenr.gov
1612 Mail Service Center
Raleigh, NC 27699-1612
i s - Nothing Compares.,,
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: King, Melissa
Sent: Wednesday, February 10, 2016 10:42 AM
To: Munger, Bridget
Cc: Aiken, Stan E; Walker, Fred
Subject: Horsehead email 3/3
Bridget,
Find below an email exchange that was too large to send so I cut and pasted — seems to have worked,
Melissa
From: Davidson, Landon
To: Pickle, Ken; Kucken, Darlene
Cc: Bennett, Bradley; Georgoulias, Bethany; Herbert, Laura C; Walker, Fred; Menzel, Jeff; Burch, Brent; Day, Collin;
Allen, Spring
Subject: RE: Horsehead release/Horsehead Stormwater Inspection NCS000562
Date: Tuesday, May 19, 2015 2:12:26 PM
Attachments: 05192015140046-D00051915. pdf
05192015 NRC 1116915.pdf
Attached is our NOV for the April 25th release. Horsehead has finalized a remediation plan based on
soil sampling etc. with regard to the release on the 25th. Jeff Menzel (DWR WQROS) is planning on

visiting the site this Friday. I understand from Horsehead that they have a remediation plan
complete and soil results are available. DWM HW is overseeing the remediation aspect for the 25th
release and DWR is assisting.
For today's release, DWR is not planning on issuing an NOV or enforcement unless information
regarding the release changes. Based on the current site report, today's release is outside the
jurisdiction of DWR and will likely reside with DWM for soil remediation etc. Attached is the spill
report for today's release.
Based on observed site conditions, reported spills, etc., I think we need a holistic regulatory
approach for the facility. DWR WQROS is willing to participate in any inspections or meetings
relating to the facility. We may need a conference call or other means of assessing which agencies
need to participate and if we wish to include or need any federal agencies to be involved.
Please let me know if we can help and in the interim, DWR will continue to share information as it
becomes available.
Landon
G. Landon Davidson, P.G.
NCDENR - Division of Water Resources
Water Quality Regional Operations Section
Regional Supervisor - Asheville Regional Office
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
ph.: 828-296-4500
fax: [phone]
email: landon.davidson ncdenr. ov
website: www.ncwaterguality.or6
Need help with other DENR permits? http://portal.ncdenr.org/web/deao/permit-directory
Notice: Per Executive Order No. 150, all emails sent to and from this account are subject to the North Carolina Public
Records Law and may be disclosed to third parties.
From: Pickle, Ken
Sent: Tuesday, May 19, 2015 1:52 PM
To: Kucken, Darlene; Davidson, Landon
Cc: Bennett, Bradley; Georgoulias, Bethany; Herbert, Laura C; Walker, Fred
Subject: RE: Horsehead release/Horsehead Stormwater Inspection NCS000562
Hi Darlene,
We can participate in a visit to this site. Just let us know when with some advance notice, please.
Landon, can you send us a copy of any NOV letters or other enforcement documents?
Thanks,
Ken
From: Herbert, Laura C
Sent: Tuesday, May 19, 2015 1:06 PM
To: Walker, Fred; Kucken, Darlene; Georgoulias, Bethany; Pickle, Ken
Cc: Bennett, Bradley
Subject: FW: Horsehead release/Horsehead Stormwater Inspection NCS000562
All,
As we have previously discussed, I would like to suggest that RCO and ARO plan an industrial
stormwater permit inspection of this facility in the near future. Because of the complexity of this
facility and the fact that they hold an individual stormwater permit (NCS000562) I think it would be
beneficial to ARO to have RCO expertise available during the inspection. Also note that they have
had a couple of recent releases from this facility. We did a construction/general industrial
stormwater inspection on September 24, 2013 however, the facility at the time was at limited
production. I, unfortunately, will not be available after the end of May (see note below), however
will refer you to Darlene Kucken and Fred Walker for coordination of this inspection with RCO and
the facility.
2

Thanks, S
Laura
Please note that I will be retiring at the end of May (2015). After the end of May, please contact
either Mr. Fred Walker, PE (Burke, Clay, Graham, Haywood, Jackson, Macon, Polk, Rutherford,
Swain, or Yancey County) or Ms. Melissa King, PE (Avery, Buncombe, Caldwell, Cherokee,
Henderson, Madison, McDowell, Mitchell, or Transylvania), depending on the subject county. You
can reach them by phone at [phone] or by email ( [e-mail] or
[e-mail] ) Thank you.
Laura Herbert, P.E.
Regional Engineer
Division of Energy, Mineral, and Land Resources - Land Quality Section
NCDENR-Asheville Regional Office
2090 US Highway 70
Swannanoa, NC 28778
Tel: [phone] Fax: [phone]
http://Portal.ncdenr.org/web/Ir
Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and
therefore may be disclosed to third parties unless the content is exempt by statute or other regulation.
From: Davidson, Landon
Sent: Tuesday, May 19, 2015 12:36 PM
To: Herbert, Laura C
Subject: Horsehead release
See attached. No solution went to creek, 50-100 gallons left secondary containment. Same solution
and same line as April 25th release. Thanks
Landon
PS -I've forwarded to Brent Burch as well.
G. Landon Davidson, P.G.
NCDENR - Division of Water Resources
Water Quality Regional Operations Section
Regional Supervisor- Asheville Regional Office
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
ph.: 828-296-4500
fax: [phone]
email:landon.davidson ncdenr. ov
website: www.ncwaterguality.org
Need help with other DENR permits? http://portal.ncdenr.org/webldeao/permit-directorV
Notice: Per Executive Order No. 150, all emails sent to and from this account are subject to the North Carolina Public
Records Law and may be disclosed to third parties.
ESSE QUAM VIDERI
Melissa 7. King, PE - Melissa.King(@ncdenr.gov
North Carolina Dept. of Environmental Quality
Asheville Regional Office
Division of Energy, Mineral and Land Resources - Land Quality
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Notice: E-mail correspondence to and from this address may be subject to the North Carolina
Public Records Law and therefore may be disclosed to third parties.
3

• 0
Aiken, Stan E
From: King, Melissa
Sent: Wednesday, February 10, 2016 10:42 AM
To: Munger, Bridget
Cc: Aiken, Stan E; Walker, Fred
Subject: Horsehead email 3/3
Attachments: NCS000562 Signed Fact Sheet 7 2012.pdf
Bridget,
Find below an email exchange that was too large to send so I cut and pasted — seems to have worked,
Melissa
From: Davidson, Landon
To: Pickle, Ken; Kucken, Darlene
Cc: Bennett, Bradley; Georgoulias, Bethany; Herbert, Laura C; Walker, Fred; Menzel, Jeff; Burch, Brent; Day, Collin;
Allen, Spring
Subject: RE: Horsehead release/Horsehead Stormwater Inspection NCS000562
Date: Tuesday, May 19, 2015 2:12:26 PM
Attachments: 05192015140046-D00051915.pdf
05192015 NRC 1116915.pdf
Attached is our NOV for the April 25th release. Horsehead has finalized a remediation plan based on
soil sampling etc. with regard to the release on the 25th. Jeff Menzel (DWR WQROS) is planning on
visiting the site this Friday. I understand from Horsehead that they have a remediation plan
complete and soil results are available. DWM HW is overseeing the remediation aspect for the 25th
release and DWR is assisting.
For today's release, DWR is not planning on issuing an NOV or enforcement unless information
regarding the release changes. Based on the current site report, today's release is outside the
jurisdiction of DWR and will likely reside with DWM for soil remediation etc. Attached is the spill
report for today's release.
Based on observed site conditions, reported spills, etc., I think we need a holistic regulatory
approach for the facility. DWR WQROS is willing to participate in any inspections or meetings
relating to the facility. We may need a conference call or other means of assessing which agencies
need to participate and if we wish to include or need any federal agencies to be involved.
Please let me know if we can help and in the interim, DWR will continue to share information as it
becomes available.
Landon
G. Landon Davidson, P.G.
NCDENR - Division of Water Resources
Water Quality Regional Operations Section
Regional Supervisor- Asheville Regional Office
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
ph.: 828-296-4500
fax: [phone]
email: [e-mail]
website: www.ncwaterquality.org
Need help with other DENR permits? http://portal.ncdenr.org/web/deao/permit-directory
Notice: Per Executive Order No. 150, all emails sent to and from this account are subject to the North Carolina Public

Records Law and may be disclosed toTfiird parties. •
From: Pickle, Ken
Sent: Tuesday, May 19, 2015 1:52 PM
To: Kucken, Darlene; Davidson, Landon
Cc: Bennett, Bradley; Georgoulias, Bethany; Herbert, Laura C; Walker, Fred
Subject: RE: Horsehead release/Horsehead Stormwater Inspection NCS000562
Hi Darlene,
We can participate in a visit to this site. Just let us know when with some advance notice, please.
Landon, can you send us a copy of any NOV letters or other enforcement documents?
Thanks,
Ken
From: Herbert, Laura C
Sent: Tuesday, May 19, 2015 1:06 PM
To: Walker, Fred; Kucken, Darlene; Georgoulias, Bethany; Pickle, Ken
Cc: Bennett, Bradley
Subject: FW: Horsehead release/Horsehead Stormwater Inspection NCS000562
All,
As we have previously discussed, I would like to suggest that RCO and ARO plan an industrial
stormwater permit inspection of this facility in the near future. Because of the complexity of this
facility and the fact that they hold an individual stormwater permit (NCS000562) I think it would be
beneficial to ARO to have RCO expertise available during the inspection. Also note that they have
had a couple of recent releases from this facility. We did a construction/general industrial
stormwater inspection on September 24, 2013 however, the facility at the time was at limited
production. I, unfortunately, will not be available after the end of May (see note below), however
will refer you to Darlene Kucken and Fred Walker for coordination of this inspection with RCO and
the facility.
Thanks,
Laura
Please note that I will be retiring at the end of May (2015). After the end of May, please contact
either Mr. Fred Walker, PE (Burke, Clay, Graham, Haywood, Jackson, Macon, Polk, Rutherford,
Swain, or Yancey County) or Ms. Melissa King, PE (Avery, Buncombe, Caldwell, Cherokee,
Henderson, Madison, McDowell, Mitchell, or Transylvania), depending on the subject county. You
can reach them by phone at [phone] or by email ( [e-mail] or
[e-mail] ) Thank you.
Laura Herbert, P.E.
Regional Engineer
Division of Energy, Mineral, and Land Resources - Land Quality Section
NCDENR-Asheville Regional Office
2090 US Highway 70
Swannanoa, NC 28778
Tel: [phone] Fax: [phone]
http://portal.ncdenr.org/web/Ir
Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and
therefore may be disclosed to third parties unless the content is exempt by statute or other regulation.
From: Davidson, Landon
Sent: Tuesday, May 19, 2015 12.36 PM
To: Herbert, Laura C
Subject: Horsehead release
See attached. No solution went to creek, 50-100 gallons left secondary containment. Same solution
and same line as April 25th release. Thanks
Landon

PS -I've forwarded to Brent Burch as well.
G. Landon Davidson, P.G.
NCDENR - Division of Water Resources
Water Quality Regional Operations Section
Regional Supervisor- Asheville Regional Office
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
ph.: 828-296-4500
fax:[phone]
email: [e-mail]
website: www.ncwaterquality.org
Need help with other DENR permits? http://portal.ncdenr.org/web/deao/permit-directory
Notice: Per Executive Order No. 150, all emails sent to and from this account are subject to the North Carolina Public
Records Law and may be disclosed to third parties.
ESSE gum VIOEHI
Melissa 1. King, PE - [e-mail]
North Carolina Dept. of Environmental Quality
Asheville Regional Office
Division of Energy, Mineral and Land Resources - Land Quality
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Notice: E-mail correspondence to and from this address may be subject to the North Carolina
Public Records Law and therefore may be disclosed to third parties.
3

Aiken, Stan E
From:
King, Melissa
Sent:
Wednesday, February 10, 2016 10:41 AM
To:
Munger, Bridget
Cc:
Aiken, Stan E; Walker, Fred
Subject:
Horsehead email 2/3
Attachments:
05192015 NRC 1116915.pdf; Copy of Horsehead draft accept changes NCS000562.docx;
Copy of Horsehead-Staff Report accept changes.doc; DWQ Spill Incident Report 2015
04 25 201500668t.pdf
ESSE QUAM VIDERT
Melissa J. King, PE - [e-mail]
North Carolina Dept. of Environmental Quality
Asheville Regional Office
Division of Energy, Mineral and Land Resources - Land Quality
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Notice: E-mail correspondence to and from this address may be subject to the North Carolina
Public Records Law and therefore may be disclosed to third parties.
t

0
Aiken, Stan E
From: King, Melissa
Sent: Wednesday, February 10, 2016 10:38 AM
To: Munger, Bridget
Cc: Aiken, Stan E; Walker, Fred
Subject: Horsehead File information
Attachments: CEI-Horsehead.04-05-13.doc; CEI-Horsehead.04-05-13.doc; Horsehead Cover Letter
5-3-13.0f; Horsehead Inspection 4-1-13.pdf; NCS000562.pdf
Bridget
As requested, please find attached file information on Horsehead.
This is email 1 of 3 emails with info.
Melissa
ESSE QUAM VIDERI
Melissa ]. King, PE - [e-mail]
North Carolina Dept. of Environmental Quality
Asheville Regional Office
Division of Energy, Mineral and Land Resources - Land Quality
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Notice: E-mail correspondence to and from this address may be subject to the North Carolina
Public Records Law and therefore may be disclosed to third parties.
1

•
Aiken, Stan E
From:
Davidson, Landon
Sent:
Wednesday, February 10, 2016 9:32 AM
To:
Young, Sarah; Chernikov, Sergei
Cc:
Bennett, Bradley; Aiken, Stan E
Subject:
Horsehead Metals
Sarah/Sergei-
FYl and to retain for use if there is inquiry or interest in the issue. No response necessary. Thanks.
On February 5, 2016 Tim Heim, Landon Davison and Rob Topolski (new ARO WQROS employee) of the Asheville Regional
Office traveled to the Horsehead Metals Facility and met with Horsehead Plant Manager Anthony Staley, Environmental
Manager Jim Harris, and Environmental Staff member Charlie Howell and performed an inspection of the facility.
The meeting and visit were initiated by DWR ARO staff to address concerns related to the recent declaration of Chapter
11 bankruptcy, decision to idle the Horsehead facility for an unspecified amount of time, and layoffs of a significant
number of plant staff. Specific concerns included whether qualified staff would remain at the facility during the idle
period and potential impacts to industrial wastewater treatment and discharge.
Mr. Staley and Mr. Harris stated that all contract workers and approximately 100 temporary employees were included in
the layoff. Approximately 80 employees of the plant are considered "intellectual capital" and will continue to be
employed full time throughout the idle period. These employees include all of the engineering staff, environmental
staff, plant management, operations and maintenance leads, and lead positions in the chemistry laboratory.
During the idle period, the focus will be on repairing known problems and issues, process optimization, and cleaning.
Most of the major plant processes will be suspended, but the bleed treatment process will continue (only storm water
will be processed).
Mr. Harris stated that all monitoring, testing and analytical work associated with the discharge permits will continue,
and no change to the permits or permit conditions will be requested. The request to increase permitted discharge for
the industrial wastewater permit in the Fall of 2015 was related to greater than anticipated storm water which required
processing through "bleed treatment". Process water being circulated during this period of idle should be lower in
metals (Pb, Cd, etc.).
DWR staff and Mr. Harris reviewed major elements of the facility and the storm water and industrial wastewater
discharge outfalls on the Broad River. No violations of the permit conditions or items requiring correction were observed
during this review. Mr. Harris stated that he was aware of the Town of Forrest City Riverstone WWTP's application to list
the Horsehead facility as an Industrial User (IU).
Tim Heim, P.E.
Environmental Engineer — Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
G. Landon Davidson, P.G.
Regional Supervisor — Asheville Regional Office

Water Quality Regional Operations Sefion
NCDEQ — Division of Water Resources
828 296 4680 office
828 230 4057 mobile
Landon.Davidson@ncdenr.g_ov
2090 U.S. Hwy. 70
Swannanoa, N.C. 28711
—�'-"Nothing Compares, -
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

0 0
Aiken, Stan E
From: Davidson, Landon
Sent: Tuesday, February 02, 2016 11:52 AM
To: Young, Sarah
Cc: Chernikov, Sergei; Menzel, Jeff; Aiken, Stan E; Walker, Fred; Bennett, Bradley
Subject: Horsehead
fyi
http://www.reuters.com/article/harsehead-hldg-bankruptcy-idUSL2N15HIGA
G. Landon Davidson, P.G.
Regional Supervisor — Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4680 office
828 230 4057 mobile
Landon.Davidson(cr cdenr.gov
2090 U.S. Hwy. 70
Swannanoa, N.C. 28711
''Nothing Compares--,-,
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

• 0
Aiken, Stan E
From: Pickle, Ken
Sent: Wednesday, January 27, 2016 8:39 AM
To: Bennett, Bradley; Aiken, Stan E; Davidson, Landon
Subject: FW: Horsehead Idling Mooresboro Facility
FYI, No Action
Ken Pickle
Stormwater Program Specialist
DEMLR Stormwater Permitting Program
Department of Environmental Quality
919 807 6376 office
ken. [e-mail]
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury St, Raleigh, NC 27604
-"/'Nothing Compares.
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Forrest Westall [mailto:[e-mail]]
Sent: Wednesday, January 27, 2016 7:02 AM
To: Belnick, Tom <[e-mail]>; Chernikov, Sergei <[e-mail]>; Pickle, Ken
<[e-mail]>
Subject., FW: Horsehead Idling Mooresboro Facility
Hello,
I thought you may be interested in this development. I have had no contact with them for quite a while. We parted
ways over their approach to compliance.
FYI
Forrest
http://recatalyst.com/?p=35755

•
•
Aiken, Stan E
From:
Davidson, Landon
Sent:
Tuesday, December 22, 2015 9:22 AM
To:
Bennett, Bradley; Aiken, Stan E
Subject:
FW: Horsehead Metals letter
Attachments:
SKM_454e15122108570.pdf
Fyi. Please let me know if their SW permit monitoring requirements have changed (tier). We are reviewing some
possible changes in the NPDES permit monitoring as well. Thx
Sent from my Windows Phone
From: Menzel, Jeff
Sent: 12/22/2015 7:38 AM
To: Davidson Landon; Heim, Tim
Subject: FW: Horsehead Metals letter
From: Galantis, Kelly
Sent: Monday, December 21, 2015 8:02 AM
To: Burch, Brent <[e-mail]>; Menzel, Jeff<[e-mail]>; Wilkins, Mark
<[e-mail]>;'[e-mail]' <[e-mail]>
Subject: Horsehead Metals letter
From: scanner.2nd [e-mail] [mailto:scanner.2nd [e-mail]]
Sent: Monday, December 21, 2015 8:58 AM
To: Galantis, Kelly <[e-mail]>
Subject: Message from KMT454e

Aiken, Stan E
From: Harris James <[e-mail]>
Sent: Wednesday, October 05, 2016 8:06 AM
To: Davidson, Landon; Aiken, Stan E; Condrey Neil; Burch, Brent; Scott, Chris; Menzel, Jeff,
Heim, Tim; Jeff Dotson; Sonny Penson; Bennett, Bradley; Morris, Richard
Subject: Horsehead Emergence from Bankruptcy
Here is an announcement that I wanted to share with you regarding our company. We are looking forward to the
implementation of engineering projects that will improve the production process at our Mooresboro facility.
If you have questions, please let me know.
Thanks,
Jim Harris I Environmental Manager
Horsehead Meta! Products, LLC
METAL PRODUCTS. INC.
484 Hicks Grove Road, Mooresboro I North Carolina 28114
C: 828-748-5283 1 P: 828-919-3139
iharris(c�horsehead.net
From: Ali Alavi
Sent: Monday, October 03, 2016 12:04 PM
To: All Subscribers
Subject: Emergence from Bankruptcy
HORSEHEAD RESTRUCTURING COMPLETE
PITTSBURGH, September 30, 2016 -- HORSEHEAD HOLDING LLC, together with certain of its subsidiaries (collectively,
"Horsehead" or the "Company") announced today that it has emerged from chapter 11 as a private company after
successfully consummating its plan of reorganization (the "Plan"), which was confirmed by the United States Bankruptcy
Court for the District of Delaware on September 9, 2016.
Horsehead's Plan eliminates substantially all of the Company's debt, converts approximately $205 million of senior
secured debt into equity in the reorganized Company and, among other things, provides for the repayment of its debtor -
in -possession credit facility, provides for repayment, in full, of creditors at Zochem Inc. ("Zochem"), its Canadian
subsidiary, and provides for distributions of cash , equity and warrants for its other prepetition creditors, in each case, as
set forth more fully in the Plan. Additionally, Horsehead's new equity owners have committed to fund additional equity
capital to support the repair and restart of Horsehead's zinc production facility located in Mooresboro, North Carolina,
subject to certain terms and conditions, including the approval of Horsehead's board of directors. Under the Plan,
Horsehead also converted its corporate form from a Delaware corporation to a Delaware limited liability company, and
its name was changed from "Horsehead Holding Corp." to "Horsehead Holding LLC" ("Horsehead Holding"). The names
and structures of Horsehead's major operating subsidiaries: Horsehead Corporation; Horsehead Metal Products, LLC;
The International Metals Reclamation Company, LLC ("INMETCO"); and Zochem remain unchanged.

James M. Hensler, Chief Executive Officce of Horsehead, stated "I'm pleased to announce that our plan of reorganization,
which was confirmed by the U.S. Bankruptcy court on September 9, 2016, became effective today and we have emerged
from bankruptcy with a capital structure free of long-term debt."
Hensler added: "With the bankruptcy process behind us, we can now turn our full attention to our operations and
strategic plans, including finalizing the plans to repair and restart our Mooresboro, North Carolina facility to provide high
quality zinc to the North American market."
Horsehead Holding is the parent company of Horsehead Corporation, a leading U.S. producer of specialty zinc and zinc -
based products and a leading recycler of electric arc furnace dust; INMETCO, a leading recycler of metals -bearing wastes
and a leading processor of nickel -cadmium (NiCd) batteries in North America; and Zochem, a zinc oxide producer located
in Brampton, Ontario. Horsehead, headquartered in Pittsburgh, Pa., employs approximately 700 people and has seven
facilities throughout the U.S. and Canada. Visit http://www.horsehead.net for more information.
Lazard Middle Market LLC and RAS Management Advisors, LLC served as investment bankers and financial advisors,
respectively, to the Company, and Kirkland & Ellis LLP, Aird & Berlis LLP, and Pachulski Stang Ziehl & Jones LLP served as
legal counsel to the Company.
Moelis & Company LLC served as financial advisor and investment banker to the Plan Sponsors, and Akin Gump Strauss
Hauer & Feld, LLP, Ashby & Geddes, P.A., and Cassels Brock & Blackwell LLP served as legal counsel to the Plan Sponsors.

0 •
Aiken, Stan E
From: Harris James <[e-mail]>
Sent: Thursday, September 29, 2016 11:46 AM
To: Aiken, Stan E
Cc: Bennett, Bradley
Subject: Stormwater Permit NCS000562 - Horsehead Metal Products, LLc
Stan,
I would like to meet with you and discuss our stormwater permit in relation to the current business
Our Mooresboro facility has been in the "idle" mode without production since January 2016. As you are aware, our
company filed for bankruptcy protection on February 2, 2016. The bankruptcy court gave approval for the company to
come out of bankruptcy recently and we are in the process of completing the paperwork to support this decision.
Is there a good time when you can meet with me to review our current permit and the status of our business?
Thanks,
Jim Harris I Environmental Manager
Horsehead Metal Products, LLC
KO .-
METAL PnODUCT.S'i, I NC:_
484 Hicks Grove Road, Mooresboro I North Carolina 28114
C: 828-748-5283 1 P: 828-919-3139
IharrisCcDhorsehead. net

Aiken, Stan E
From: Davidson, Landon
Sent: Thursday, March 10, 2016 3:44 PM
To: Aiken, Stan E; Walker, Fred; Bennett, Bradley
Cc: Menzel, Jeff; Heim, Tim
Subject: FW: Cellhouse Investigation Report
Attachments: 3-8-16 Cover Letter to Jeff Menzel - Cellhouse Inv Report.pdf; 3-8-16 Mooresboro Cell
House Investigation Report.pdf
FYI
From the report:
"Dry soil below the asphalt surface, the absence of a permeable layer facilitating contaminant migration, and
the soil analytical results showing very low levels of heavy metals, all suggest that the preferential pathway of
the release was to the storm water system, which mitigated impacts in the area of the release."
G. Landon Davidson, P.G.
Regional Supervisor — Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4680 office
828 230 4057 mobile
Landon. David son(d�ncdenr.gov
2090 U.S. Hwy. 70
Swannanoa, N.C. 28711
c; -:�>^Nothing Compares.
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Menzel, Jeff
Sent: Thursday, March 10, 2016 3:23 PM
To: Davidson, Landon <[e-mail]>; Heim, Tim <[e-mail]>
Subject: FW: Cellhouse Investigation Report
From: Harris James [mailto.iharris horsehead.net]
Sent: Thursday, March 10, 2016 3:12 PM
To: Menzel, Jeff <[e-mail]>; Burch, Brent <[e-mail]>; Wilkins, Mark
<mark.wilki [e-mail]>
Cc: Staley Anthony <[e-mail]>
Subject: Cellhouse Investigation Report

Attached for your review is the cover otter and report of findings on the recent 110dinvestigation completed in the
cellhouse area at the Horsehead Metal Products, LLC facility in Mooresboro, NC.
A hard copy of this letter and report will be sent to you via certified mail.
Thanks,
Jim Harris I Environmental Manager
Horsehead Meta! Products Inc.
H:C� R: ' E, I �: AP
tvt TAL PrltanucTS. INC.
484 Hicks Grove Road, Mooresboro I Forth Carolina 28114
C: 828-748-5283 j P: 828-919-3139
iharris(cD-horsehead.net

0
0
Aiken, Stan E
From: Harris lames <[e-mail]>
Sent: Monday, February 29, 2016 4:S9 PM
To: Aiken, Stan E; Walker, Fred
Cc: Staley Anthony
Subject: Basin 1 Stormwater
We detected a small flow of stormwater entering the energy dissipater at Basin 1 today with a pH of 4.5. We closed the
Basin 1 outlet gate to ensure that none entered the river. The stormwater was contained in the concrete energy
dissipater and we dispatched a vacuum truck to the basin to remove it.
We inspected the SX/EW area and believe that a very small flow of residual stormwater is draining off from the previous
rain. We will continue to inspect the stormwater piping system this week.
If you have any questions, please let me know.
Jim Harris I Environmental Manager
Horsehead Metal Products Inc.
H- R S E; F�: E:A DJ
METAL F'ROMCT`_:, INC.
484 Hicks Grove Road, Mooresboro North Carolina 28114
C: 828-748-5283 1 P: 828-919-3139
Iharris(c�horsehead.net

90
ri
Permit: NCS000562 Owner - Facility: Horsehead Holding Corporation
Inspection Date: 04/05/2013 Inspection Type: Compliance Evaluation
Reason for Visit:
Routine
Stormwater Pollution Prevention Plan
Yes
No
NA
NE
Does the site have a Stormwater Pollution Prevention Plan?
■
D
D
D
# Does the Plan include a General Location (USGS) map?
■
D
D
D
# Does the Plan include a "Narrative Description of Practices"?
■
D
D
D
# Does the Plan include a detailed site map including outfall locations and drainage areas?
■
D
D
Q
# Does the Plan include a list of significant spills occurring during the past 3 years?
0
❑
❑
■
# Has the facility evaluated feasible alternatives to current practices?
n
n
D
■
# Does the facility provide ail necessary secondary containment?
D
D
D
# Does the Plan include a BMP summary?
❑
0
D
■
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
■
D
Q
❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
■
0
❑
D
# Does the facility provide and document Employee Training?
D
D
D
■
# Does the Plan include a list of Responsible Party(s)?
D
D
D
■
# Is the Plan reviewed and updated annually?
❑
Q
D
■
# Does the Plan include a Stormwater Facility Inspection Program?
D
D
D
■
Has the Stormwater Pollution Prevention Plan been implemented?
D
D
D
■
Comment: DWQ staff met with Jim Harris (Environmental Manager) and Charles
Howell with Horsehead Corporation. Mr. Harris presented an overview of the SWPPP
and its components for the facility.
The Industrial Stormwater permit went into effect on April 1, 2013 and Industrial
stormwater discharge is not anticipated until plant start up near September, 2013.
Qualitative Monitoring)
Yes
No
NA
NE
Has the facility conducted its Qualitative Monitoring semi-annually?
D
D
D
■
Comment:
Analytical Monitoring
Yes
No
NA
NE
Has the facility conducted its Analytical monitoring?
D
D
D
■
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
D
D
D
■
Comment:
Permit and Outfalls
Yes
No
NA
NE
# Is a copy of the Permit and the Certificate of Coverage available at the site?
# Were all outfalls observed during the inspection?
■DDD
■DDD
Page: 3

Permit: NCS000562 Owner -Facility: Horsehead Holding Corporation
Inspection Date: 04/05/2013 Inspection Type: Compliance Evaluation Reason for Visit: Routine
# If the facility has representative outfall status, is it properly documented by the Division?
# Has the facility evaluated all illicit (non stormwater) discharges?
Comment:
0Cl0M
■000
Page: 4

Permit: NCS000562 Owner - Facility: Horsehead Holding Corporation
Inspection Date: 04/05/2013 Inspection Type: Compliance Evaluation Reason far Visit: Routine
Inspection Summary:
DWQ staff met with Jim Harris (Environmental Manager) and Charles Howell with Horsehead Corporation. Mr. Harris
presented an overview of the SWPPP and its components for the facility.
The Industrial Stormwater permit went into effect on April 1, 2013 and Industrial stormwater discharge is not anticipated
until plant start up near September, 2013.
Horsehead Corporation is doing an outstanding job starting the implementation of the SWPPP and meeting permit
requirements.
Page: 2

0
f�
Permit: NCS000562
SOC:
County: Rutherford
Region: Asheville
Compliance Inspection Report
Effective: 04/01/13 Expiration: Owner: Horsehead Holding Corporation
Effective: Expiration: Facility: Rutherford County Production Facility
State Rte 221
Contact Person: Jim Harris Title:
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 04/05/2013 EntryTime: 10:00 AM
Primary Inspector: Timothy R Fox
Secondary Inspector(s):
Jonathan Stepp
Reason for Inspection: Routine
Permit Inspection Type: Stormwater Discharge, individual
Facility Status: ■ Compliant ❑ Not Compliant
Question Areas:
■ Storm Water
(See attachment summary)
Forest City NC 28043
Phone: [phone]
Certification:
Exit Time: 01:00 PM
Phone:
Phone: [phone]
Phone:
Inspection Type: Compliance Evaluation
Page: 1

•
North Carolina
Pat McCrory
Governor
May 3, 2013
Jim Harris
Environmental Manager
Horsehead Corporation
484 Hicks Grove Road
Mooresboro, NC 28114
ILI;A
NCDENR
Department of Environment and Natural Resources
Division of Water Quality
Charles Wakild, P.E.
Director
SUBJECT: NPDES Stormwater Permit Compliance Inspection
Horsehead Corporation
Permit No: NCS000562
Rutherford County
John E. Skvarla, III
Secretary
Dear Mr. Harris:
This letter is in follow-up to the NPDES Stormwater Permit Compliance Inspection conducted on
April 5, 2013. The facility was found to be in compliance with permit NCS000562.
Enclosed is a copy of the Compliance Inspection Report, which contains additional observations
and comments for your reference.
Please contact me at [phone] or Tim.Foxnncdenngov, if I can be of any further assistance.
Sincerely,
Tim Fox
Environmental Specialist
Surface Water Protection
Enclosure
cc: Central Files
Asheville Files
s:ISWPIRulherfordlStonnwaterl2- Ind ividuaAHorsehead NCS000562\Horsehead inspections\CEl_Horsehead.04-05-13.doc
Location: 2090 U.S. Hl hway 70, Swannanoa, North Carolina 28778
Phone: [phone] FAX: [phone]
Internet: www.ncwate;quality.org
An Equal Opportunity t Affirmalive Action Employer
NorthCarolina
Aatura!!y

1�(f S 06,6 3- G 2, 7� �� 3 V ehAr; -// "4wa
tj,c �` �. p' � �.�'�,b-� �lu v+1�5 I `�" (� 4c Y{ � � so � - us•..� ��� � ch V,�rf iI � { cac� I Lt �� w tz^ lr✓ c!�-�, r�--Pr�,
Permit: NC5000562 Owner - Facility: Horsehead Holding Corporation
Inspection Date: 04/05/2013 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Stormwater Pollution Prevention Plan Yes No NA NE
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"?
j� # Does the Plan include a detailed site map including outfall locations and drainage areas?
C # 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: DWQ staff met with Jim Harris (Environmental Manager) and Charles
Howell with Horsehead Corporation. Mr. Harris presented an overview of the SWPPP
and its components for the facility.
The Industrial Stormwater permit went into effect on April 1, 2013 and Industrial
stormwater discharge is not anticipated until plant start up near September, 2013.
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?
Comment:
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?
Yes No NA NE
n
n
n
■
Yes
No
NA
NE
n
n
❑
■
nnn■
Yes
No
NA
NE
■nnn
■nnn
Page: 3

6 0
Permit: NCS000562 Owner - Facility: Horsehead Holding Corporation
Inspection Date: 04/05/2013 Inspection Type: Compliance Evaluation
# If the facility has representative outfall status, is it properly documented by the Division?
# Has the facility evaluated all illicit (non stormwater) discharges?
Comment: Sup
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•
Herbert, Laura C
From: Herbert, Laura C
Sent: Wednesday, June 18, 2014 3:06 PM
To: Pickle, Ken; Kucken, Darlene; Menzel, Jeff; Randall, Mike
Cc: Fox, Tim; Scott, Chris
Subject: RE: Start-up Notification - Air Permit # 10248ROl Horsehead Rutherford County
All,
I talked to Spring Allen (Haz Waste) today and she indicated that her inspection with EPA of the subject facility went
well. She indicated that the facility is at about 15 percent production and will probably be at about 50 percent by the
end of the summer. They produced their first metal on May 22, 2014. During start-up they did have some pipe
leakage/spills, but they have removed the soils in these area and are disposing of appropriately. She indicated that
they reported that two Canadian Geese had landed in the process ponds (this was the reported complaint that we
received earlier this year) and that they are flagging the ponds (wire and flags above the ponds) to prevent this situation
in the future.
Based on Spring's report, I recommend that we schedule an inspection (NPDES WW and NPDES SW?) in the fall when
production has picked up (and it is cooler in Rutherford County). Let me know if this is agreeable to you all.
Thanks,
Laura
Laura Herbert, P.E.
Regional Engineer
Division of Energy, Mineral, and Land Resources - land Quality Section
NCDENR-Asheville Regional Office
2090 US Highway 70
Swannanoa, NC 28778
Tel:[phone] Fax:[phone]
http://portal,ncdenr.org/web/Ir
Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and therefore may be disclosed to
third parties unless the content is exempt by statute or other regulation.
From: Herbert, Laura C
Sent: Monday, June 16, 2014 11:44 AM
To: Pickle, Ken
Subject: RE: Start-up Notification - Air Permit # 10248ROl Horsehead Rutherford County
Ken,
Let me follow up with Spring and see how their inspection went. I'll get back to everyone on scheduling an inspection.
Thanks,
Laura
Laura Herbert, P.E.
Regional Engineer
Division of Energy, Mineral, and Land Resources - Land Quality Section

': J .
NCDENR-Asheville Regional Office • •
2090 US Highway 70
Swannanoa, NC 28778
Tel:[phone] Fax.[phone]
http://Portal.ncdenr.org/web/Ir
Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public Records Latin and therefore may be disclosed to
third parties unless the content is exempt by statute or other regulation.
From: Pickle, Ken
Sent: Monday, June 16, 2014 11:05 AM
To: Herbert, Laura C; Kucken, Darlene; Wait, Jeff; Allen, Spring; Randall, Mike; Georgoulias, Bethany
Cc: Bennett, Bradley
Subject: RE: Start-up Notification - Air Permit # 10248R01 Horsehead Rutherford County
Hi Laura,
I'm also available the week of June 23, and would like to attend since I worked with Horsehead on the stormwater
permit.
Ken Pickle
Environmental Engineer
NCDENR I DEMLR I Stormwater Permitting Program
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. [e-mail]
Website: http://portal.ncdenr.org/web/Ir/stormwater
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Herbert, Laura C
Sent: Wednesday, June 04, 2014 1:33 PM
To: Kucken, Darlene; Wait, Jeff; Allen, Spring; Pickle, Ken; Randall, Mike; Georgoulias, Bethany
Subject: RE: Start-up Notification - Air Permit # 10248R01 Horsehead Rutherford County
I just talked to Spring and she indicated that EPA and she are doing an inspection next week. That's probably enough for
the facility_ I thought that I would touch basis with Spring after their inspection and she at what stage of start-
up/production they are. Based on what she tells me, we can go from there —so stay tuned. I too am available the week
of June 23, so we can keep this in mind.
Laura Herbert, P.E.
Regional Engineer
Division of Energy, Mineral, and Land Resources - Land Quality Section
NCDENR-Asheville Regional Office
2090 US Highway 70
Swannanoa, NC 28778
Tel:[phone] Fax:[phone]
http://portal.ncdenr.org/web/ir

,s . .
•
Notice: E-mail correspondence to and from this address may be subject to the Forth Carolina Public Records Law and therefore may be disclosed to
third parties unless the content is exempt by statute or other regulation.
From: Kucken, Darlene
Sent: Wednesday, June 04, 2014 9:51 AM
To: Herbert, Laura C; Wait, Jeff; Allen, Spring; Pickle, Ken; Randall, Mike; Georgoulias, Bethany
Subject: RE: Start-up Notification - Air Permit # 10248R01
I think for this facility a multi -divisional inspection would be a good use of everyone's time.
I have open: June 19, 20, and any day the following week but not the 27.
Darlene Kucken - Darlene. Kucken @ncdenr.9ov
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Energy, Mineral, and Land Resources
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and
may be disclosed to third parties.
`A. Go Green! Print this email only when necessary. Thank you for helping NCDENR be environmentally responsible.
From: Herbert, Laura C
Sent: Wednesday, June 04, 2014 8:17 AM
To: Wait, Jeff; Allen, Spring; Kucken, Darlene; Pickle, Ken; Randall, Mike; Georgoulias, Bethany
Subject: FW: Start-up Notification - Air Permit # 10248R0l
would like to suggest a multi -divisional inspection in the near future when we can coordinate everyone's schedule? Or
at least a DWR-DEMLR inspection. Let me know what you think about this?
Thanks,
Laura
Laura Herbert, P.E.
Regional Engineer
Division of Energy, Mineral, and Land Resources - Land Quality Section
NCDENR-Asheville Regional Office
2090 US Highway 70
Swannanoa, NC 28778
Tel:[phone] Fax:[phone]
http://portal.ncdenr.org/web/I r
Notice: E-mail correspondence to and from this address may he subject to the North Carolina Public Records Law and therefore may be disclosed to
third parties unless the content is exempt by statute or other regulation.
From: Harris James [mailto:[e-mail]]
Sent: Tuesday, June 03, 2014 4:01 PM

To: Muller, Paul; Scott, Chris • 0
Cc: Herbert, Laura C; Allen, Spring; Menzel, Jeff
Subject: Start-up Notification - Air Permit # 10248R01
On March 28, 20141 notified you that Horsehead Metal Products, Inc. started up the two natural gas fired boilers, WOX silos,
limestone silo, storage silo building, soda ash silo and the lime silo.
Today, I've mailed a letter of notification to you that indicates that we have started up the following equipment:
+ Electrowinning cellhouse and cooling towers
• 200 Area Solvent Extraction
• 300 Area Bleed Treatment
• 500 Area Melt -Cast
+ 800 Area Stand-by Generators
The following equipment has not been started at this time and is still in the construction phase:
• HCL Recovery Reactor
• 100 Area Oxidic Fines
+ 600 Area PLINT
The Air Permit contains reference to Area 900 — Physical Classification and Grinding. This area has been removed from our
construction plan and will not be built at this location. Please remove it from the air permit.
As we bring the other plant equipment on-line for production, we will notify you in writing.
If you need additional information, please contact me at 828-748-5283.
Thanks,
Jim Harris I Environmental Manager
Horsehead Metal Products Inc.
484 Hicks Grove Road
Mooresboro, North Carolina 28114
C: 828-748-5283 1 P: 828-919-3139
harris horsehead.net

t _. 0
Herbert, Laura C
From: Fox, Tim
Sent: Friday, May 02, 2014 8:06 AM
To: Harris James
Cc: Herbert, Laura C; Kucken, Darlene
Subject: RE: Wildlife Complaint
Jim,
Thanks for the communication. The caller left a message on my machine indicating it was near the facility and not down
by the river. They were very vague and indicated that they would call back with more detailed information when I was
back in the office and they never did.
If I hear any more I will be sure to pass the information on to everyone.
Thanks,
Tim
Tim Fox - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Resources — Water Quality Programs
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Notice: Email correspondence to and from this address may be subject to the NC Public Records Law and may be
disclosed to third parties.
From: Harris James [mailto:[e-mail]]
Sent: Thursday, May 01, 2014 11:39 AM
To: Herbert, Laura C
Cc: Fox, Tim; Kucken, Darlene
Subject: RE: Wildlife Complaint
Are you sure the caller was referring to Basin 1? To be clear, Basin 1 is the pond (next to the river) that receives our
stormwater prior to discharge at the river. I believe that the caller is referring to the ponds in the SX production area and
not Basin 1.
As I mentioned in the previous email, we have experienced wildlife getting into the retention tanks (ponds in the SX
production area) but not Basin 1 stormwater pond. There are retention tanks in the SX production area that receives
stormwater but this water is recycled back to the SX production process.
We have experienced some spills within the plant, none of which are reportable. Our response team members are
trained to contain the material quickly and the on -site vacuum truck will collect it for recycle in our process area. These
spills have not reached the discharge to the river.

•
Let me know if you have any other questions.
Thanks,
Jim Harris I Environmental Manager
Horsehead Meta! Products Inc.
HORS E-KEA.D
rvrTAi t-'rtQOU s'�:, INC.
484 Hicks Grove Road
Mooresboro, North Carolina 28114
C: 828-748-5283 1 P: 828-919-3139
Iharris(a�horsehead. net
From: Herbert, Laura C[maiIto: Iaura. herbertancdenr.gov]
Sent: Wednesday, April 30, 2014 2:14 PM
To: Harris James
Cc: Fox, Tim; Kucken, Darlene
Subject: RE: Wildlife Complaint
•
Have you all had any spills that would have gotten into this basin? We are following up on the complaint about the
wildlife and the basin.
Thanks,
Laura
Laura Herbert, P.E.
Regional Engineer
Division of Energy, Mineral, and Land Resources - Land Quality Section
NCDENR-Asheville Regional Office
2090 US Highway 70
Swannanoa, NC 28778
Tel: [phone] Fax: [phone]
http://portal.ncdenr.org/web/ir
Notice: h-mail correspondence to and from this address may he subject to the North Carolina Public Records Law and therefore may he disclosed to
third parties unless the content is exempt by statute or other regulation.
From: Harris James [ma ilto:iharrisahorsehead.net]
Sent: Wednesday, April 30, 2014 2:12 PM
To: Herbert, Laura C
Cc: Fox, Tim; Kucken, Darlene
Subject: RE: Wildlife Complaint
Laura,
We haven't started sampling the SDO at Basin 1. We are in the process of finishing the construction phase of this project
and starting up the production units. I envision the construction to continue through the 2"d quarter and part of the 3`'
quarter of this year.

Thanks, •
Jim Harris I Environmental Manager
Horsehead Meta! Products Inc.
H.0 R.S E. H E: A D
METAL PRO rKICT , I�-¢r.
484 Hicks Grove Road
Mooresboro, North Carolina 28114
C: 828-748-5283 1 P: 828-919-3139
net
From: From: Herbert, Laura C[maiIto: laura.herbert(&ncdenr.gov]
Sent: Tuesday, April 29, 2014 1:49 PM
To: Harris James
Cc: Fox, Tim; Kucken, Darlene
Subject: RE: Wildlife Complaint
Jim,
Have you all pulled any samples from the stormwater pond?
Thanks,
Laura
Laura Herbert, P.E.
Regional Engineer
Division of Energy, Mineral, and Land Resources - Land Quality Section
NCDENR-Asheville Regional Office
2090 US Highway 70
Swannanoa, NC 28778
Tel: [phone] Fax: [phone]
http://Portal.ncdenr.org/web/I
Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and therefore may be disclosed to
third parties unless the content is exempt by statute or other regulation.
From: Harris ]ames [mailto:[e-mail]]
Sent: Friday, April 25, 2014 5:43 PM
To: Herbert, Laura C; Cranford, Chuck
Cc: Fox, Tim; Staley Anthony; Ali Alavi; Kucken, Darlene
Subject: RE: Wildlife Complaint
Laura,
We are getting close to starting the full process for making zinc at our facility but there are several parts of the plant that
are still in the commissioning phase.
3

In regards to the ground level retention tanks in the SX production area, we use thettanks to hold the process
solutions that are used to manufacture zinc. These solutions are made up of acids, metals, hydrocarbons and water. We
don't expect these tanks to be empty but the levels will vary based on the needs of the process.
If you have further questions, let me know.
Thanks,
Jim Harris I Environmental Manager
Horsehead Metal Products Inc.
H' . Ft'S'E: K E A D
NIFTAf PRQQ.IC7 . INC.
484 Hicks Grove Road
Mooresboro, North Carolina 28114
C: 828-748-5283 1 P: 828-919-3139
jharris(?horsehead.net
From: Herbert, Laura C[mailto:[e-mail]]
Sent: Friday, April 25, 2014 9:50 AM
To: Harris James; Cranford, Chuck
Cc: Fox, Tim; Staley Anthony; Ali Alavi; Kucken, Darlene
Subject: RE: Wildlife Complaint
Jim,
What material is stored in the ground level retention tanks at the SX production area? Are you all operating yet?
Thanks,
Laura
Laura Herbert, P.E.
Regional Engineer
Division of Energy, Mineral, and Land Resources - Land Quality Section
NCDENR-Asheville Regional Office
2090 US Highway 70
Swannanoa, NC 28778
Tel: [phone] Fax: [phone]
http://portal.ncdenr.org/web/Ir
Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and therefore may be disclosed to
third parties unless the content is exempt by statute or other regulation.
From: Harris James [mailto:[e-mail]]
Sent: Friday, April 25, 2014 9:44 AM
To: Herbert, Laura C; Cranford, Chuck
Cc: Fox, Tim; Staley Anthony; Ali Alavi
Subject: Wildlife Complaint
Laura, Chuck,

1 received a call from Tim Fox yesterday Od he stated that DENR received a complaint from a Horsehead employee regarding
wildlife at the pond area within the Mooresboro facility. I informed Tim that we have not experienced any wildlife related issues at
our Basin 1 stormwater pond but we did detect wildlife getting into the ground level retention tanks at the SX production area.
Plans have been in place for quite some time to install fencing around the retention tank areas. The fencing is scheduled for
installation after the road paving is completed and currently, we are at the paving stage.
If you have any questions, please let me know.
Thanks,
Jim Harris I Environmental Manager
Horsehead Metal Products Inc.
IND
484 Hicks Grove Road
Mooresboro, North Carolina 28114
C: 828-748-5283 1 P: 828-919-3139
jharris(a)_horsehead. net

0 0
Herbert, Laura C
From:
Harris James <[e-mail]>
Sent:
Friday, April 25, 2014 9:44 AM
To:
Herbert, Laura C; Cranford, Chuck
Cc:
Fox, Tim; Staley Anthony; Ali Alavi
Subject:
Wildlife Complaint
Laura, Chuck,
I received a call from Tim Fox yesterday and he stated that DENR received a complaint from a Horsehead employee regarding
wildlife at the pond area within the Mooresboro facility. I informed Tim that we have not experienced any wildlife related issues at
our Basin 1 stormwater pond but we did detect wildlife getting into the ground level retention tanks at the 5X production area.
Plans have been in place for quite some time to install fencing around the retention tank areas. The fencing is scheduled for
installation after the road paving is completed and currently, we are at the paving stage.
If you have any questions, please let me know.
Thanks,
Jim Harris I Environmental Manager
Horsehead Metal Products Inc.
6 40 W 111-i-RHME
:i
484 Hicks Grove Road
Mooresboro, North Carolina 28114
C: 828-748-5283 j P: 828-919-3139
9harris horsehead.net

•
Herbert, Laura C
From: Harris James <[e-mail]>
Sent: Tuesday, February 25, 2014 1:43 PM
To: Herbert, Laura C
Subject: Stormwater Contact
Hello Laura,
s
I hope that you made it through the recent ice/snow without problems. The weather has been a significant factor
affecting our schedule to start the new plant. We are looking at March 2014 now to begin our production process. I
hope that we can make this target date.
We have our contract for sample analysis and the sampling schedule for Stormwater developed and ready to go. Once
we convert over from construction to industrial, we will start our sampling strategy.
As we move forward, who is our contact for industrial stormwater within your group?
Thanks,
Jim Harris
Environmental Manager
Horsehead Metal Products, Inc.
484 Hicks Grove Road
Mooresboro, NC 28114
C 828.748.5283
O 828.919.3139
F 828.245.4237
jharris(c�horsehead.net
"You can't think your way into Right Actions, but you can act your way into Right Thinking".
From: Herbert, Laura C [maiIto: [e-mail]]
Sent: Wednesday, October 16, 2013 12:05 PM
To: Harris James
Cc: Kucken, Darlene; Stepp, Jonathan
Subject: RE: Basin 1 at Horsehead Facility
Jim,
I talked to both Kevin Barnett and William Elliot about the bank stabilization issue at Horsehead. They both indicated
that they would be happy to visit the site and discuss with you options to address this issue. Unfortunately, William is
furloughed.... Maybe when he is allowed back to work you all can set up a site visit.
Thanks,
Laura
Laura Herbert, P.E.
Regional Engineer
Division of Energy, Mineral, and Land Resources - Land Quality Section
NCDENR-Asheville Regional Office
2090 US Highway 70
Swannanoa, NC 28778

Tel:[phone] Fax:[phone]
http://portal.ncdenr.org/web/Ir
Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and therefore may be disclosed to
third parties unless the content is exempt by statute or other regulation.
From: Herbert, Laura C
Sent: Thursday, September 26, 2013 4:10 PM
To: 'Harris James'
Cc: Kucken, Darlene; Stepp, Jonathan
Subject: RE: Basin 1 at Horsehead Facility
Jim,
As we discussed during our site visit, there were a few items for which we requested follow-up. One item, as discussed
in the attached email, you have already addressed. We appreciate your quick response on this. The other items are as
follows:
Slopes and ditch line on access road to the basin —These need to be permanently stabilized per the plan as soon as
possible. As we noted during the site visit, erosion is evident in these areas and continues to contribute to the
sedimentation load to the basin.
As we discussed, the basin's downstream slope of the berm/dam, which shows evidence of slumping, should be
evaluated for structural stability by a licensed engineer with geotechnical expertise. In addition, the stability of the river
bank which is downstream of this structure should also be evaluated and addressed as needed, again by a qualified
engineer. The US ACE (William Elliot at 828/271-7980) and Division of Water Resources may can provide guidance on
this and should be contacted regarding any permitting requirements.
We also discussed the transition of the sediment basin from a temporary control to a permanent structure, Sediment
basins for sediment and erosion control are temporary measures that have a design basin life of three or less
years. Permanent basins are beyond the scope of the erosion and sedimentation control plan and review. If this basin is
to be used as a permanent stormwater basin it should be designed as a permanent structure and pond by a qualified
professional engineer experienced in the design of dams. In addition, the basin should be cleaned out and permanently
stabilized before being used as a stormwater basin.
Jim, we appreciate all the effort that Horsehead has made regarding sediment and erosion control and stormwater
planning. We look forward to continuing to work with you all and appreciate your continued efforts to address these
items that we discussed during the site visit. If you have any questions or would like to discuss, please let me know.
Thanks,
Laura
Laura Herbert, P.E.
Regional Engineer
Division of Energy, Mineral, and Land Resources - Land Quality Section
NCDENR-Asheville Regional Office
2090 US Highway 70
Swannanoa, NC 28778
Tel:[phone] Fax:[phone]
http://portal.ncdenr.org/webjlr

Herbert, Laura C
From:
Herbert, Laura C
Sent:
Thursday, September 26, 2013 4:10 PM
To:
'Harris James'
Cc:
Kucken, Darlene; Stepp, Jonathan
Subject:
RE: Basin 1 at Horsehead Facility
Jim,
As we discussed during our site visit, there were a few items for which we requested follow-up. One item, as discussed
in the attached email, you have already addressed. We appreciate your quick response on this. The other items are as
follows:
Slopes and ditch line on access road to the basin —These need to be permanently stabilized per the plan as soon as
possible. As we noted during the site visit, erosion is evident in these areas and continues to contribute to the
sedimentation load to the basin.
As we discussed, the basin's downstream slope of the berm/dam, which shows evidence of slumping, should be
evaluated for structural stability by a licensed engineer with geotechnical expertise. In addition, the stability of the river
bank which is downstream of this structure should also be evaluated and addressed as needed, again by a qualified
engineer. The US ACE (William Elliot at 828/271-7980) and Division of Water Resources may can provide guidance on
this and should be contacted regarding any permitting requirements.
We also discussed the transition of the sediment basin from a temporary control to a permanent structure. Sediment
basins for sediment and erosion control are temporary measures that have a design basin life of three or less
years. Permanent basins are beyond the scope of the erosion and sedimentation control plan and review. If this basin is
to be used as a permanent stormwater basin it should be designed as a permanent structure and pond by a qualified
professional engineer experienced in the design of dams. In addition, the basin should be cleaned out and permanently
stabilized before being used as a stormwater basin.
Jim, we appreciate all the effort that Horsehead has made regarding sediment and erosion control and stormwater
planning. We look forward to continuing to work with you all and appreciate your continued efforts to address these
items that we discussed during the site visit. If you have any questions or would like to discuss, please let me know.
Thanks,
Laura
Laura Herbert, P.E.
Regional Engineer
Division of Energy, Mineral, and Land Resources - Land Quality Section
NCDENR-Asheville Regional Office
2090 US Highway 70
Swannanoa, NC 28778
Tel:[phone] Fax:[phone]
http://portal.ncdenr.org/web/­I
Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and therefore may be disclosed to
third parties unless the content is exempt by statute or other regulation.

Herbert, Laura C 0 .
From: Davidson, Landon
Sent: Tuesday, May 19, 2015 4:39 PM
To: Herbert, Laura C; Menzel, Jeff
Subject: FW: Rutherford County - Hazmat/NRC
fyi
G. Landon Davidson, P.G.
NCDENR - Division of Water Resources
Water Quality Regional Operations Section
Regional Supervisor - Asheville Regional Office
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
ph.: 828-296-4500
fax: [phone]
email: [e-mail]
website: www.ncwaterguality.or�
Need help with other DENR permits? http://portal.ncdenr,org/web/deao/permit-directory
Notice: Per Executive Order No. 150 all emails sent to and from this account are subject to the North Carolina Public Records Low and
may be disclosed to third parties.
From: Burch, Brent
Sent: Tuesday, May 19, 2015 4:39 PM
To: Davidson, Landon
Subject: RE: Rutherford County - Hazmat/NRC
Thanks Landon. I spoke with Mike Williford. We will provide oversight on the clean up and have them submit another plan
or amend the last one.
Brent G. Burch
Western Region Compliance Supervisor
Hazardous Waste Section - Division of Waste Management
NC Department of Environment & Natural Resources
PO Box 1427
Andrews, NC 28901
828-321-9585
Brent.Burchpncdenr.gov
NOTICE: E-mail correspondence to and from this address may be subject to the North Carolina
Public Records Law and may be disclosed to third parties unless the content is exempt by statute
or other regulation.
From: Davidson, Landon
Sent: Tuesday, May 19, 2015 12:08 PM
1

To: Burch, Brent
Subject: RE: Rutherford County - Hot/NRC
Linda talked with Jim, I have calls into him as well. He states did not go to surface water so we will not be involved unless
that changes. Still waiting NOV response from April's release. Please let me know if you all go to site as we are not planning
on responding at this point unless sit. changes.
BIMS # 201500716
Jim Harris called. The line broke again. They turned off pumps but—300-500 gallons was released. He has vac truck onsite, he
built berms, he called NRC to report also.
He stated they have it contained and none has reached creek, just soil.
Jeff I left you a voice message to see how you wanted to proceed.
Landon, are you ok with Jims actions?
G. Landon Davidson, P.G.
NCDENR - Division of Water Resources
Water Quality Regional Operations Section
Regional Supervisor- Asheville Regional Office
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
ph.: 828-296-4500
fax: [phone]
email: [e-mail]
website: www.ncwaterguality.org
Need help with other DENR permits? http://portal.ncdenr.org/web/deao/permit-directory
Notice: Per Executive Order No. 150, all emails sent to and from this account are subject to the North Carolina Public Records Low and
may be disclosed to third parties.
From: Burch, Brent
Sent: Tuesday, May 19, 2015 12:05 PM
To: Davidson, Landon
Subject: RE: Rutherford County - Hazmat/NRC
Thanks. I'll let Robin know to expect another plan
Brent G. Burch
Western Area Compliance Supervisor
Hazardous Waste Section - Division of Waste Management
NC Department of Environment & Natural Resources
PO Box 1427
Andrews, NC 28901
828-321-9S85
Brent.Burch@?ncdenr.gov
NOTICE: E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may
be disclosed to third parties unless the content is exempt by statute or other regulation.

From: Davidson, Landon Ip Now
Sent: 5/19/2015 11:45 AM
To: Burch, Brent
Subject: FW: Rutherford County - Hazmat/NRC
Fyi
G. Landon Davidson, P.G.
NCDENR - Division of Water Resources
Water Quality Regional Operations Section
Regional Supervisor - Asheville Regional Office
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
ph.: 828-296-4500
fax: [phone]
email: [e-mail]
website: www.ncwaterguality.org
Need help with other DENR permits? http://portal.ncdenr.org/web/deao/permit-directory
Notice: Per Executive Order No. 150, all emails sent to and from this account are subject to the North Carolina Public Records Caw and
may be disclosed to third parties.
From: Gore, Deborah
Sent: Tuesday, May 19, 2015 11:42 AM
To: Davidson, Landon; Menzel, Jeff
Subject: FW: Rutherford County - Hazmat/NRC
Similar situation at this facility on April 25, 2015.
Deborah Gore
PERCS Unit Supervisor
NCDENR-Division of Water Resources
Pretreatment Emergency,Response & Collection Systems Unit PERCS
1617 Mail Service Center
Raleigh, NC 27699-1617
Phone: [phone]
Pax: [phone]
Deborah, GoreCcDncdenr.gov
Subscribe to Collection System Updates
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulation.
From: NCEOC [mailto:[e-mail]]
Sent: Tuesday, May 19, 2015 11:34 AM
To: Cook, Mike (NCEM); Gore, Deborah
Subject: Rutherford County - Hazmat/NRC
This occurred this morning at 1100 at Horsehead Metals Products 484 Hicks Grove Rd in Mooresboro.
NRC forwarded a report from a private metal products company of a release of 500 gallons of a depleted solution from a
pipe that went out of the containment area due to equipment failure. No waterways were reported to be affected. Cleanup
operations were conducted. No state resources were requested.

Michael Rowell
Emergency Management Officer
NC Deportment of Public Safety
Division of Emergency Management — 24-Hr Ops Center
4236 Mail Service Center
Raleigh, NC 27699-4236
Phone: [phone]
Fax: [phone]
1636 Gold Star Dr.
Raleigh, NC 27607-3371
michael.rowel IQncdps.gov
www.ncdps.gov
Readf(NC.Org
Plan. Prepare. Stay informed.
Download the Rea dyNC opp — it's free!
www.reodync.org
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized state
official.

4-
Herbert, Laura C
From: Davidson, Landon
Sent: Tuesday, May 19, 2015 2:12 PM
To: Pickle, Ken; Kucken, Darlene
Cc: Bennett, Bradley; Georgoulias, Bethany; Herbert, Laura C; Walker, Fred; Menzel, Jeff; Burch,
Brent; Day, Collin; Allen, Spring
Subject: RE: Horsehead release/Horsehead Stormwater Inspection NCS000562
Attachments: 05192015140046-D00051915.pdf; 05192015 NRC 1116915.pdf
Attached is our NOV for the April 25`h release. Horsehead has finalized a remediation plan based on soil sampling etc. with
regard to the release on the 25`h. Jeff Menzel (DWR WQROS) is planning on visiting the site this Friday. I understand from
Horsehead that they have a remediation plan complete and soil results are available. DWM HW is overseeing the
remediation aspect for the 25`h release and DWR is assisting.
For today's release, DWR is not planning on issuing an NOV or enforcement unless information regarding the release
changes. Based on the current site report, today's release is outside the jurisdiction of DWR and will likely reside with DWM
for soil remediation etc. Attached is the spill report for today's release.
Based on observed site conditions, reported spills, etc., I think we need a holistic regulatory approach for the facility. DWR
WQROS is willing to participate in any inspections or meetings relating to the facility. We may need a conference call or
other means of assessing which agencies need to participate and if we wish to include or need any federal agencies to be
involved.
Please let me know if we can help and in the interim, DWR will continue to share information as it becomes available.
Landon
G. Landon Davidson, P.G.
NCDENR - Division of Water Resources
Water Quality Regional Operations Section
Regional Supervisor - Asheville Regional Office
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
ph.: 828-296-4500
fax: [phone]
email: [e-mail]
website: www.ncwaterguality.org
Need help with other DENR permits? http://portal.ncdenr.org/web/deao/permit-directory
Notice: Per Executive Order No. 150, all emails sent to and from this account are subject to the North Carolina Public Records Law and
may be disclosed to third parties.
From: Pickle, Ken
Sent: Tuesday, May 19, 2015 1:52 PM
To: Kucken, Darlene; Davidson, Landon
Cc: Bennett, Bradley; Georgoulias, Bethany; Herbert, Laura C; Walker, Fred
Subject: RE: Horsehead release/ Horsehead Stormwater Inspection NCS000562
Hi Darlene,
We can participate in a visit to this site. Just let us know when with some advance notice, please.

Landon, can you send us a copy of ar00V letters or other enforcement documee
Thanks,
Ken
From: Herbert, Laura C
Sent: Tuesday, May 19, 2015 1:06 PM
To: Walker, Fred; Kucken, Darlene; Georgoulias, Bethany; Pickle, Ken
Cc: Bennett, Bradley
Subject: FW: Horsehead release/Horsehead Stormwater Inspection NCS000562
All,
As we have previously discussed, I would like to suggest that RCO and ARO plan an industrial stormwater permit inspection
of this facility in the near future. Because of the complexity of this facility and the fact that they hold an individual
stormwater permit (NC5000562) I think it would be beneficial to ARO to have RCO expertise available during the
inspection. Also note that they have had a couple of recent releases from this facility. We did a construction/general
industrial stormwater inspection on September 24, 2013 however, the facility at the time was at limited production. I,
unfortunately, will not be available after the end of May (see note below), however will refer you to Darlene Kucken and
Fred Walker for coordination of this inspection with RCO and the facility.
Thanks,
Laura
Please note that I will be retiring at the end of May (2015). After the end of May, please contact either Mr. Fred Walker, PE
(Burke, Clay, Graham, Haywood, Jackson, Macon, Polk, Rutherford, Swain, or Yancey County) or Ms. Melissa King, PE (Avery,
Buncombe, Caldwell, Cherokee, Henderson, Madison, McDowell, Mitchell, or Transylvania), depending on the subject
county. You can reach them by phone at [phone] or by email ( [e-mail] or [e-mail]
} Thank you.
Laura Herbert, P.E.
Regional Engineer
Division of Energy, Mineral, and Land Resources - Land Quality Section
NCDENR-Asheville Regional Office
2090 US Highway 70
Swannanoa, NC 28778
Tel:[phone] Fax:[phone]
http://Portal.ncdenr.org/web/Ir
Notice E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and therefore may be disclosed to third
parties unless the content is exempt by statute or other regulation.
From: Davidson, Landon
Sent: Tuesday, May 19, 2015 12:36 PM
To: Herbert, Laura C
Subject: Horsehead release
See attached. No solution went to creek, 50-100 gallons left secondary containment. Same solution and same line as April
251h release. Thanks
Landon
PS —I've forwarded to Brent Burch as well.

G. Landon Davidson, P.G. . •
NCDENR - Division of Water Resources
Water Quality Regional Operations Section
Regional Supervisor - Asheville Regional Office
2090 U.S. Hwy, 70
Swannanoa, N.C. 28778
ph.: 828-296-4500
fax: [phone]
email: [e-mail]
website: www.ncwaterpuality.or�
Need help with other DENR permits? http://portal.ncdenrr.org/web/deao/permit-directory
Notice: Per Executive Order No. 150, all emoils sent to and from this account are subject to the North Carolina Public Records Law and
may be disclosed to third parties.

ifCDENIi
North Carolina Department of Environment and Natural Resources
)t McCrory. Donald R. van der Vaart
Governor Secretary
May 812015
CERTIEIED MAIL. .
RETURN RECEIPT REQUESTED 7014-0510 0000 4466 6099
Anthony K. Staley
Horsehead Corporation
484 Hicks Grove Road
Mooresboro, N.C. 28114
Subject: NOTICE OF VIOLATION/NOTICE OF INTENT TO ENFORCE
NOV-2015-DV-6106 (Incident # 201500668)
Horsehead Corporation
Rutherford County,
Dear Mr. Staley:
`.JSaturday, April 25, 2015, depleted aqueous electrolyte solution was'released due to failure of an elevated process
eline.at the site. Reportedly, the majority.of.the release was contained onsite during recovery efforts; however, an
estimated 4000 gallons of this solution mixed.with storm water reached,a dirt road, approximately 100 feet to the north,
and an adjacent earthen drainage ditch. Solution reaching the earthen ditch was conveyed offsite to an unnamed,
intermittent stream leading'to the Broad River'Aased on ah initial review of chemical information associated with the
depleted aqueous electrolyte solution, primary constituents of concern consist of metals, especially cadmium, lead, and
zinc. Additionally, the aqueous solution -contained sulfuric acid with a pH range of i to 3 standard units.
Instream pH was monitored by the Division of Water Resources in both the unnamed tributary and the Broad river
upstream and downstream of'the spill. The unnamed tributary displayed low pH both upstream and downstream of the
spill. The Broad River pH was within normal ranges both upstream and down of the confluence with the unamed
tributary. Samples for the analyses of metals were not collected at the time of the spill response.
Violations
As a result of the above -referenced observations on April 25, 2015, the following violations are noted.
.(1) illegal discharge
Violation I. Discharge Without a Valid Permit
G.S. 143-215.1(a) states that no person shall do any of the following things or carry out any of the following activities
unless that person has received a permit from the Commission and has complied with all conditions set forth in the:
permit: G:S. 143-215,1(a)(1) Make any outlets into the waters of the State.
Water Quality Regional Operations — Asheville Regional Of'lce
2090 U.S. Highway 70, &vannanoa, North Carolina 28778
Phone: [phone] FAX: [phone]
Internet httpllportal.ncdenr.orgAvetvwq
An Equal Opportunity 1 Affirmative Actlan Employer

Anthony K. Staley
�.
May g, 2015
Page 2 of 2 .
Required Response
This Office requests that you respond to this letter in writing within 30 days of recent of this Notice. Your response
should be sent to this Office at the letterhead address. Your response should address the following items:
I. Please submit a report assessing the cause, significance, and extent of the release. In this report, include
when you ceased discharging to the waters of the State. The report should contain details of estimated
solution released, conditions under which the solution was released and chemical composition of the
solution. Please. include specific details as to why secondary containment and spill prevention measures 4
failed during the release. You are to include a narrative describing the operational condition of the ;
containment structures (e.g., pond, grates, etc.) prior to and during the release. You are also'to submit a
timeline of events that occurred on April 25, 2015 associated with the release.
2. Please submit a plan listing all actions you will take to prevent future releases including any enhancements .
to secondary containment structures or changes in operation and maintenance of existing containment
structures. Your comments should address but are not limited to the following issues: secondary
containment issues within the plant, spill response plan, preventative. maintenance on your piping system
and storm drains, etc.
Remedial actions should betaken to correct this problem. The Division of Water Resources is considering pursuing
enforcement action for this violation. The violations.are subject to civil penalties up to $25,000.00 per day for "each -
violation as per G.S.143-215.6A.
This office requires that the violations, as detailed above, be abated Immediately and properly resolved. Thank you l
for your attention Ito this matter.;This Office is considering sending a'recommendation.for enforcement to the Director )
of the Division of Water Resources -regarding these issues_ and any future%continued violatlons that may be encountered. '
Your above -mentioned response to this oorrespondence' will be considered in this process.
If you have any question. regarding this policy please contact your Asheville Regional- Staff, or Jeff Menzel at 828-296-
4500 or [e-mail].
Sincerely,
G. Landon Davidson, P.G., Regional Supervisor
Water Quality Regional Operations
Asheville Regional Office
cc: Jim Harris, Environmental Manager (via email)
Brent Burch—14CDENR DWIVI HW5 (via email)
WQ Asheville Files
MSC 1617-Central Files -Basement
WQ Enforcement

Herbert, Laura C • •
From: Herbert, Laura C
Sent: Tuesday, May 19, 2015 1:06 PM
To: Walker, Fred; Kucken, Darlene; Georgoulias, Bethany; Pickle, Ken
Cc: Bennett, Bradley
Subject: FW: Horsehead release/Horsehead Stormwater Inspection NCS000562
Attachments: 05192015 NRC 1116915.pdf
All,
As we have previously discussed, I would like to suggest that RCO and ARO plan an industrial stormwater permit inspection
of this facility in the near future. Because of the complexity of this facility and the fact that they hold an individual
stormwater permit (NCS000562) I think it would be beneficial to ARO to have RCO expertise available during the
inspection. Also note that they have had a couple of recent releases from this facility. We did a construction/general
industrial stormwater inspection on September 24, 2013 however, the facility at the time was at limited production. 1,
unfortunately, will not be available after the end of May (see note below), however will refer you to Darlene Kucken and
Fred Walker for coordination of this inspection with RCO and the facility.
Thanks,
Laura
Please note that I will be retiring at the end of May (2015). After the end of May, please contact either Mr. Fred Walker, PE
(Burke, Clay, Graham, Haywood, Jackson, Macon, Polk, Rutherford, Swain, or Yancey County) or Ms. Melissa King, PE (Avery,
Buncombe, Caldwell, Cherokee, Henderson, Madison, McDowell, Mitchell, or Transylvania), depending on the subject
county. You can reach there by phone at [phone] or by email ( [e-mail] or [e-mail]
) Thank you.
Laura Herbert, P.E.
Regional Engineer
Division of Energy, Mineral, and Land Resources - Land Quality Section
NCDENR-Asheville Regional Office
2090 US Highway 70
Swannanoa, NC 28778
Tel:[phone] Fax:[phone]
http://portal.ncdenr.org/web/Ir
Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and therefore may be disclosed to third
parties unless the content is exempt by statute or other regulation.
From: Davidson, Landon
Sent: Tuesday, May 19, 2015 12:36 PM
To: Herbert, Laura C
Subject: Horsehead release
See attached. No solution went to creek, 50-100 gallons left secondary containment. Same solution and same line as April
251h release. Thanks
Landon
P5 —I've forwarded to Brent Burch as well.

G. Landon Davidson, P.G. NCDENR - Division of Water Resource •
Water Quality Regional Operations Section
Regional Supervisor - Asheville Regional Office
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
ph.: 828-296-4500
fax: [phone]
email: landon.davidson ncdenr. ov
website: www.ncwatercluality.org
Need help with other DENR permits? http://portal.ncdenr.org/webldeao/permit-directory
Notice: Per Executive Order No. 150, all emails sent to and from this account are subject to the North Carolina Public Records Caw and
may be disclosed to third parties.

4 - ~
NATIONAL RESPONSE CENTER 1-800-424-8802
***GOVERNMENT USE ONLY* "GOVERNMENT USE ONLY***
Information released to a third party shall comply with any
applicable federal and/or state Freedom of Information and Privacy Laws
Incident Report # 1116915
INCIDENT DESCRIPTION
*Report taken by: E5 RUSSELL POST at 11:13 on 19-MAY-15
Incident Type: FIXED
Incident Cause: EQUIPMENT FAILURE
Affected Area:
Incident occurred on 19-MAY-15 at 11:00 local incident time.
Affected Medium: LAND /CONTAINMENT AND GROUND
REPORTING PARTY
Name: JIM HARRIS
Organization: HORSEHEAD METALS PRODUCTS
Address: 484 HICKS GROVE ROAD
MOORESBORO, NC 28114
PRIMARY Phone: [phone]
Type of Organization: PRIVATE ENTERPRISE
SUSPECTED RESPONSIBLE PARTY
Name: JIM HARRIS
Organization: HORSEHEAD METALS PRODUCTS
Address: 484 HICKS GROVE ROAD
MOORESBORO, NC 28114
PRIMARY Phone: [phone]
INCIDENT LOCATION
484 HICKS GROVE ROAD County: RUTHERFORD
City: MOORESBORO State: NC Zip: 28114
RELEASED MATERIAL(S)
CHRIS Code: NCC Official Material Name: NO CHRIS CODE
Also Known As: DEPLETED SOLUTION
Qty Released: 500 GALLON(S)
DESCRIPTION OF INCIDENT
CALLER STATED THAT PIPE RUPTURED THAT ALLOWED THE RELEASE OF A
DEPLETED SOLUTION THAT OVERFLOWED OUT OF THE CONTAINMENT AREA. THE
MATERIAL LEFT THE ORIGINATING SITE.

SENSITIVE INFORMATION
INCIDENT DETAILS
Package: NO
Building ID:
Type of Fixed Object: MANUFACTURING FACILITY
Power Generating Facility: NO
Generating Capacity:
Type of Fuel:
NPDES:
NPDES Compliance: UNKNOWN
IMPACT
Fire Involved: NO Fire Extinguished: UNKNOWN
INJURIES: NO Hospitalized: Empl/Crew: Passenger:
FATALITIES. NO Empl/Crew: Passenger: Occupant:
EVACUATIONS:NO Who Evacuated: Radius/Area:
Damages: NO
Hours Direction of
Closure Type Description of Closure Closed Closure
N
Air:
N Major
Road: Artery:N
N
Waterway:
N
Track:
Environmental Impact: UNKNOWN
Media Interest: UNKNOWN Community Impact due to Material:
REMEDIALACTIONS
A VACUUM TRUCK IS BEING USED TO COLLECT THE MATERIAL.
Release Secured: YES
Release Rate:
Estimated Release Duration:
WEATHER
Weather: UNKNOWN, °F

ADDITIONAL AGENCIES NOTIFIED
Federal:
State/Local:
State/Local On Scene:
State Agency Number:
NOTIFICATIONS BY NRC
CENTERS FOR DISEASE CONTROL (GRASP)
19-MAY-15 11:18 (770)4887100
DHS I&A STATE AND LOCAL PRGM OFFICE (RALEIGH, NC FUSION CENTER)
19-MAY-15 11:18 (202)5575179
DHS SOUTH CAROLINA FUSION CENTER (LE SENSITIVE ADVISORS & LIASON PROGRA
19-MAY-15 11.18 (866)4728477
DOT CRISIS MANAGEMENT CENTER (MAIN OFFICE)
19-MAY-15 11:18 (202)3661863
U.S. EPA IV (MAIN OFFICE)
(404)6504955
U.S. EPA IV (NC/SC INCIDENTS)
19-MAY-15 11:18 (404)6504955
NC DEPT OF EMERGENCY MGMT (MAIN OFFICE)
19-MAY-15 11:18 (800)8580368
NC OCCUPATIONAL ENVMTL EPIDEMIOLOGY (COMMAND CENTER)
19-MAY-15 11:18 (919)7075950
NC PUBLIC HEALTH PREPARE AND RESPNS (PHPR COMMAND CENTER)
19-MAY-15 11:18 (919)7150919
NATIONAL INFRASTRUCTURE COORD CTR (MAIN OFFICE)
19-MAY-15 11:18 (202)2829201
NOAA RPTS FOR NC (MAIN OFFICE)
19-MAY-15 11:18 (206)5264911
NATIONAL RESPONSE CENTER HQ (AUTOMATIC REPORTS)
19-MAY-15 11:18 (202)2671136
PIPELINE & HAZMAT SAFETY ADMIN (OFFICE OF PIPELINE SAFETY (AUTO))
19-MAY-15 11:18 (202)3660568
DOI FOR REGION 4 (MAIN OFFICE)
19-MAY-15 11:18 (404)3314524
SC EMERGENCY MANAGEMENT DIVISION (MAIN OFFICE)
19-MAY-15 11:18 (803)7378500
SEAHAWK IOC (INTER -AGENCY OPERATIONS CENTER)
19-MAY-15 11:18 (803)2060971
STATE OF NORTH CAROLINA DENR (MAIN OFFICE)
19-MAY-15 11:18 (919)8076300
SC DEPT OF ENV CNTL ATTN: ERS (MAIN OFFICE)
19-MAY-15 11:18 (803)2536488
USCG DISTRICT 5 (D5 DRAT)
19-MAY-15 11:18 (757)3986231
ADDITIONAL INFORMATION

*** END INCIDENT REPORT #1116915 ***
Report any problems by calling 1-800-424-8802
PLEASE VISIT OUR WEB 51TE AT http:/(www.nrc.uscg.mil E-mail correspondence sent to and from
this address may be subject to the provisions of G.S. 132-1, the North Carolina Public Records Law, and
may be subject to monitoring and disclosed to third parties, including law enforcement personnel, by an
authorized state official.

1 l��
7 ,
Incident Rep ort
DWR
Dlvlsion of Water Resources Report Number: 201500668
Incident Type :
Spill (Oil, Chemical, non -sewage)
On -Site Contact
Category
Incident
First/Mid/Last Name
Incident Started :
04/25/2015
Company Name
Country :
Rutherford
Phone:
City:
Pager/Mobile Phone :
1
Farm A
Responsible Party
Owner
Reported By
Permit
First/Mid/Last Name :
Jim Harris
Facility
Company Name
First Name
Address :
484 Hicks Grove Rd
Middle Name:
Last Name
City/State/Zip :
Mooresbaro NC 28114
Address
Phone
Page/Mobile Phone:
1 828748528
City/State/Zip
Phone:
Material Category:
Estimated Qty: UOM:
Chemical Name
Reportable Qty.lbs. Reportable Qty.kgs.
DD:MM:SS Decimal
Position Method
Latitude :
Position Accuracy:
Longtitude :
Position Datum :
Location of Incident
: The Site is approximately 196 acres in size and is located at 484 Hicks Grove Road in Mooresb4
Address :
484 Hicks Grove Rd
City/State/Zip:
Mooresboro
NC 28114
Report Created 516115 4:31 pm Page : 1

r
0
Cause/Observation :
Directions :
At approximately 3:46 a.m. (EDT) on Saturday, April 25, 2015,
depleted
aqueous electrolyte solution was released due to failure of an
elevated process pipeline at the
Site. The majority of the release was contained onsite during
recovery efforts; however, appro 4000 gallons moved offsite via a
storm channel and contact surface waters.
Action Taken
Instream pH was monitored in both the Crib and the Broad river
upstream and downstream of the spill. The tributary displayed very
low pH both upstream and downstream of the spill. The Broad River
pH was within normal ranges both upstream and down.
Incident Questions :
Did the Material reach the surface Water?
Surface Water Name ? BROAD RIVER
Yes
Did the Spill result in a Fish Kill? Unknown
If the Spill was from a storage tank indicate type :
Containment? Unknown
Cleanup Complete? Unknown
Water Supply Wells within 1500ft : Unknown
484 Hicks Grove Road
Comments
Based on information provided by Horsehead facility personnel, the
release occurred along a
pipeline located above a paved access road positioned between two
process areas near the
northwestern border of the facility. The majority of the release was to
pavement within and
outside of an area equipped with secondary containment. As a result
of pooling in the area
outside of secondary containment, the depleted aqueous electrolyte
solution may have reached
a dirt road, approximately 100 feet to the north, and an adjacent
earthen drainage ditch.
Any solution reaching the earthen ditch may have been conveyed
offsite to an unnamed,
intermittent stream leading to the Broad River. As a result, potentially
impacted media includes soil in the vicinity of the dirt road and along
the earthen ditch and sediment and surface water
associated with the unnamed, intermittent stream. Based on an
initial review of chemical
information associated with the depleted aqueous electrolyte
solution, primary constituents of
concern (COCs) consist of metals, especially cadmium, lead, and
zinc. Additionally, the aqueous
solution contained sulfuric acid with a pH range of 1 to 3 standard
units.
Conveyance: Ditch
Estimated Number of fish?
(Above Ground or Under Ground)
Groundwater Impacted : Unknown
Report Created 516115 4:31 pm Page: 2

Event type
Event Date
due Date Comment
Report Entered
2015/05/06
4:15:44
Referred to Regional Office - Primary Contact
2015/04/25
11A0:00
Report Received
2015/04/25
11:00:00
Incident Start
2015/04/25
3:45:00
Standard Agencies Notified
Agency Name Phone
First Name
M.I.
Last Name Contact date
Other Agencies Notified
Agency Name Phone First Name M.I. Last Name Contact Date
DWQ Information:
Report Taken By: Report Entered By:
Deborah Gore Jeff Menzel
Phone:
DatelTime: 2015/04/25 11:00:OOAM 2015/05/06 04:15:44PM
Referred Via: Phone
Did DWQ request an additional written report?
If yes, What additional information is needed?
Regional Contact:
Kevin H Barnett
2015/04/25 11 10:00AM
Phone
Report Created 516115 4:31 pm Page ; 3

Herbert, Laura C S
From: Georgoulias, Bethany
Sent: Thursday, May 07, 2015 9:43 AM
To: Herbert, Laura C�J�
Cc: Pickle, Ken
Subject: RE: Investigation Work Plan
Hi Laura,
Yes, to answer your question down there. It also sounds like the appropriate procedure was followed in this case. Let me
know if you have any other questions since Ken is away until next week.
Bg
Bethany Georgoulias, Environmental Engineer
NCDENR / Division of Energy, Mineral, and Land Resources
Stormwater Permitting Program
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury Street, Raleigh, NC 27604
919 / 807-6372 (phone); 919 / 807-6494 (fax)
Website: hrtp://portal.nedenr.orOweb/lr/stormwater
E-mail correspondence io and from this address mm be subject to the :North Carolina Public Records loin and may be disclosed to third parties.
From: Menzel, Jeff
Sent: Wednesday, May 06, 2015 3:44 PM
To: Herbert, Laura C; Burch, Brent
Cc: Davidson, Landon; Kenneth Teague; Georgoulias, Bethany; Pickle, Ken; Kucken, Darlene; Walker, Fred
Subject: RE: Investigation Work Plan
Laura,
Yes they reported the spill within 24 hours.
Depleted Sulfuric Acid spill — 04/25/2015
Deborah Gore from Central Office called at 11:10AM to notify ARO Emg Staff that Horsehead had had a spill of depleted sulfuric acid
inside the plant.
Depleted electrolyte solution is stored in west pond until routed back into bleed treatment to extract metals. The spill occurred when an
elevated pipe broke sending this material into a secondary containment area during a rain event . Depleted solution mixing with rain
overtook the secondary containment because the storm water drains leading to west pond had been blocked. According to the facility
the amount released outside of containment was approx. 4000 gallons which flowed offsite via a storm channel to a trib to the Broad
River. Instream pH was monitored in both the trib and the Broad river upstream and downstream of the spill. The tributary displayed
very low pH both upstream and downstream of the spill. The Broad River pH was within normal ranges both upstream and down.
Jim Harris has been in contact with Haz Waste and according to Jim they have approved Horse Head's investigation work plan.
Please let me know if I can provide any additional info.
Jeff

Jeff Menzel - [e-mail]
North Carolina Dept. of Environment and Natural Resources
DWR
Division of Water Resources
NCDENR Asheville Water Quality Regional Operations Section
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
E-mail correspondence to and from this address may be subject to
the North Carolina Public Records Law and may be disclosed to third parties.
From: Herbert, Laura C
Sent: Wednesday, May 06, 2015 11:25 AM
To: Menzel, Jeff
Cc: Davidson, Landon; Kenneth Teague; Georgoulias, Bethany; Pickle, Ken; Kucken, Darlene; Walker, Fred
Subject: RE: Investigation Work Plan
Jeff,
Did they report this spill to DWR within 24 hours? They are required under their stormwater permit to report all significant
spills as defined in Part IV (release of oil or hazardous substances in excess of reportable quantities under section 311 of the
CWA or section 102 of CERCLA)? Did they provide the details on what this solution of "depleted aqueous electrolyte
solution" is and what amount was released? Given that it consists of cadmium, lead, and zinc, I would think that they
needed to have reported this within 24 hours. We need to know this information in order to evaluate the spill? Also, Haz
Waste (Brent Burch) should also be copied on this in case this involves them? If you would like to discuss let me know.
(Bethany and Ken, the language in the permit requires notification to DWQ. Will this suffice if they contacted the spill
hotline or the ARO DWR office?).
Thanks,
Laura
Laura Herbert, P.E.
Regional Engineer
Division of Energy, Mineral, and Land Resources - Land Quality Section
NCDENR-Asheville Regional Office
2090 US Highway 70
Swannanoa, NC 28778
Tel:[phone] Fax:[phone]
http://portal.ncdenr.orp/web/Ir
Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public Records Latin and therefore may be disclosed to third
parties unless the content is exempt by statute or other regulation.
From: Menzel, Jeff
Sent: Tuesday, May 05, 2015 8:17 AM

T;o: Herbert, Laura C
Subject: FW: Investigation Work Plan
La ura,
Please see the attachment regarding soil remediation out at the Horse Head facility and provide comment or suggestions.
Thanks,
Jeff
From: Basilone Tim(ma ilto:tbasiloneCa)horsehead.net]
Sent: Monday, May 04, 2015 5:08 PM
To: Menzel, Jeff
Cc: Harris James; Ali Alavi
Subject: Investigation Work Plan
Jeff,
This will confirm several discussions with you and Horsehead personnel following the incident involving the pipe rupture
during the early morning on Saturday, April 25.
Please find enclosed a proposed Work Plan prepared by EnSafe on behalf of Horsehead to assess potential impact resulting
from the incident. We are prepared to authorize EnSafe to proceed with the implementation of the Work Plan as early as
Wednesday morning.
Please let me know if you have any comments or suggestions prior to our proceeding.
Thank you,
Tim
Timothy R. Basilone
Vice President - Environmental Affairs
Horsehead Corporation
4955 Steubenville Pike
Suite 405
Pittsburgh, PA 15205
P 724.773.2223
F 412.788.4526
C 412287.9871
TBasilone(cDHorsehead.net
3

Herbert, Laura C • •
From:
Herbert, Laura C
Sent:
Wednesday, May 06, 2015 11:25 AM
To:
Menzel, Jeff
Cc:
Davidson, Landon; 'Kenneth Teague'; Georgoulias, Bethany; Pickle, Ken; Kucken, Darlene;
Walker, Fred
Subject:
RE: Investigation Work Plan
Attachments:
FW: Investigation Work Plan
Jeff,
Did they report this spill to DWR within 24 hours? They are required under their stormwater permit to report all significant
spills as defined in Part IV (release of oil or hazardous substances in excess of reportable quantities under section 311 of the
CWA or section 102 of CERCLA)? Did they provide the details on what this solution of "depleted aqueous electrolyte
solution" is and what amount was released? Given that it consists of cadmium, lead, and zinc, I would think that they
needed to have reported this within 24 hours. We need to know this information in order to evaluate the spill? Also, Haz
Waste (Brent Burch) should also be copied on this in case this involves them? If you would like to discuss let me know.
(Bethany and Ken, the language in the permit requires notification to DWQ. Will this suffice if they contacted the spill
hotline or the ARO DWR office?).
Thanks,
Laura
Laura Herbert, P.E.
Regional Engineer
Division of Energy, Mineral, and Land Resources - Land Quality Section
NCDENR-Asheville Regional Office
2090 US Highway 70
Swannanoa, NC 28778
Tel:[phone] Fax:[phone]
http://Portal.ncdenr.org/web/Ir
Notice: ) -mail correspondence to and from this address may be subject to the North Carolina Public Records Law and therefore may be disclosed to third
parties unless the content is exempt by statute or other regulation.
From: Menzel, Jeff
Sent: Tuesday, May 05, 2015 8:17 AM
To: Herbert, Laura C
Subject: FW: Investigation Work Plan
Laura,
Please see the attachment regarding soil remediation out at the Horse Head facility and provide comment or suggestions.
Thanks,
Jeff

From: Basilone Tim[rnailto:tbasilone(&horsehead.net]
Sent: Monday, May 04, 2015 5:08 PM
To: Menzel, Jeff
Cc: Harris James; Ali Alavi
Subject: Investigation Work Plan
Jeff,
This will confirm several discussions with you and Horsehead personnel following the incident involving the pipe rupture
during the early morning on Saturday, April 25.
Please find enclosed a proposed Work Plan prepared by EnSafe on behalf of Horsehead to assess potential impact resulting
from the incident. We are prepared to authorize EnSafe to proceed with the implementation of the Work Plan as early as
Wednesday morning.
Please let me know if you have any comments or suggestions prior to our proceeding.
Thank you,
Tim
Timothy R. Basilone
Vice President - Environmental Affairs
Horsehead Corporation
4955 Steubenville Pike
Suite 405
Pittsburgh, PA 15205
P 724.773.2223
F 412.788.4526
C 412.287.9871
TBasilone(cr7.Horsehead.net

EusnFE
a global professional services company creative thinking. custom solutions.®
5724 Summer Trees Drive j Memphis, Tennessee 381341 Telephone [phone] Facsimile 901-372-2454 1 www.ensafe.com
May 4, 2015
Mr. Timothy R. Basilone
Vice President, Environmental Affairs
Horsehead Corporation
4955 Steubenville Pike, Suite 405
Pittsburgh, Pennsylvania 15205
Re: Limited Investigation Work Plan
Horsehead Metal Products — Mooresboro Facility
484 Hicks Grove Road
Mooresboro, North Carolina 28114
Dear Mr. Basilone:
EnSafe Inc. is pleased to provide Horsehead Corporation (Horsehead) with this limited
investigation work plan for proposed sampling and analysis at the Horsehead facility in
Mooresboro (Site), Rutherford County, North Carolina. The work plan, as outlined herein, is
based on observations and information obtained during EnSafe's April 27, 2015, site visit, and
subsequent correspondence between Horsehead and EnSafe.
BACKGROUND
The Site is approximately 196 acres in size and is located at 484 Hicks Grove Road in
Mooresboro, North Carolina. A site location map has been included as Figure 1. Primary
operations at the Site consist of zinc processing via solvent extraction and electrowinning. It is
our understanding that at approximately 3:46 a.m. (EDT) on Saturday, April 25, 2015, depleted
aqueous electrolyte solution was released due to failure of an elevated process pipeline at the
Site. The majority of the release was contained onsite during recovery efforts; however, an
initial investigation is necessary to evaluate potential impacts to onsite and offsite environmental
media.
CONCEPTUAL SITE MODEL
Based on information provided by Horsehead facility personnel, the release occurred along a
pipeline located above a paved access road positioned between two process areas near the
northwestern border of the facility. The majority of the release was to pavement within and
outside of an area equipped with secondary containment. As a result of pooling in the area
outside of secondary containment, the depleted aqueous electrolyte solution may have reached
a dirt road, approximately 100 feet to the north, and an adjacent earthen drainage ditch.
Any solution reaching the earthen ditch may have been conveyed offsite to an unnamed,
intermittent stream leading to the Broad River. As a result, potentially impacted media includes
engineering I environment I health & safety I technology

•
Limited In vestigation Work Plan
Horsehead Metal Products — Mooresboro Facility, Mooresboro, North Carolina
May 4, 2015
Pace 2
soil in the vicinity of the dirt road and along the earthen ditch and sediment and surface water
associated with the unnamed, intermittent stream. Based on an initial review of chemical
information associated with the depleted aqueous electrolyte solution, primary constituents of
concern (COCs) consist of metals, especially cadmium, lead, and zinc. Additionally, the aqueous
solution contained sulfuric acid with a pH range of 1 to 3 standard units.
DATA QUALITY OBJECTIVES
Activities, as described herein, will be performed in order to confirm COCs and evaluate the
presence/absence of resulting contamination to environmental media. In the event that
environmental media is determined to be impacted, the proposed sampling and analysis plan will
also provide information with regards to the extent of impacted soil, sediment, and surface
water in the downgradient direction.
FIELD SAMPLING AND ANALYSIS
Field activities and data validation will be performed in general conformance with United States
Environmental Protection Agency Region 4, Science and Ecosystem
Support Division Field Branches Quality System, and Technical Procedures available at
http://www.epa.gov/region4/sesd/fbqstp/index.html. Additionally, field sampling will be
performed in accordance with a site -specific Health and Safety Plan to ensure that onsite EnSafe
employees are properly trained in accordance with Occupational Safety and Health
Administration 29 CFR 1910.120. The Health and Safety Plan will include operating procedures
to address site specific hazards and will make recommendations on appropriate personal
protective equipment and associated action levels.
Characterization of Depleted Electrolyte Solution
To confirm COCs associated with the release, EnSafe will collect one sample consistent with the
released aqueous solution. This sample will be collected from the nearest discharge port on the
main process line associated with the release. The sample will be submitted for laboratory
analysis of Total Analyte List (TAL) Metals and pH. Analytical results, to be requested under a
48-hour turnaround time, will be used to develop the analyte list for subsequent field sampling
activities as described below.
Background Soil Characterization
To provide information on native levels of naturally occurring elements in soil, EnSafe will collect
four background soil samples for analysis of TAL Metals and pH. These background soil samples
will be collected from areas unaffected by facility operations. A site map depicting proposed
sample locations has been included as Figure 2.
Soil Sampling
EnSafe will collect up to 40 soil samples to evaluate conditions in the vicinity of the dirt road and
earthen ditch. Soil samples will be collected from two depth intervals at each
location: 0 - 6 inches below ground surface (bgs) and 6 - 12 inches bgs. The surficial samples
will be analyzed for primary COCs and pH, as identified via analytical results associated with the
released material characterization sample above. The 6 - 12 inch samples will be held by the
lab, pending results of the surficial samples. If deemed necessary, laboratory analysis of
MSAFF

Limited investigation Work Plan
Horsehead Metal Products — Mooresborc Facility; Mooresboro, North Carolina
May 4, 2015
Pace 3
the 6 — 12 inch samples will be requested to provide limited information on the vertical extent of
impacts.
Surface Water/Sediment Sampling
EnSafe will collect up to four surface water samples and three sediment samples to evaluate
potential downgradient impacts along the unnamed stream. Surface water samples will be
collected from upstream, midstream, and downstream locations along the unnamed stream and
at the unnamed stream's confluence with the Broad River, approximately 2,000 feet to the north
of the Site. Concurrent with sample collection, the following field parameters will be collected at
each surface water sampling location: pH, dissolved oxygen, oxidation reduction potential,
temperature, conductivity, and turbidity. Additionally, EnSafe will collect three composite
sediment samples, to be co -located with surface water sampling locations along the unnamed
stream. Each composite sediment sample will consist of three discrete samples collected along a
perpendicular transect to the unnamed stream. To account for spatial variability, the three
discrete samples will be composited into a single sample for each of the three transects via
decontaminated, stainless steel spoons and bowls. Results associated with upstream surface
water and sediment sampling locations will facilitate comparison to background conditions. In
addition, two soil samples will be collected at each transect, one from each side of the adjacent
bank. These soil samples, to be collected from a depth of 0 — 6 inches bgs along the banks, will
provide additional background information to be considered in the evaluation process. All
samples will be analyzed for primary COCs and pH, as identified via analytical results associated
with the initial characterization sample.
Quality Assurance/Quality Control
Analytical samples will be submitted to a North Carolina certified laboratory. All analytical results
will be requested under a rush, 48-hour turnaround time. For quality assurance/quality control
purposes, one equipment blank will be collected for each media sampled. Additionally, duplicate
samples will be collected at a frequency of one per every 10 primary samples.
Global Positioning System
To the extent feasible, sample locations will be recorded via a handheld global positioning
system tracking device. Such coordinates will be used to produce site maps and summary
figures.
Investigation Derived Waste
Investigation derived waste will be limited to minimal decontamination fluids generated during
field activities. Decontamination fluids will be containerized in a 55-gallon steel drum, and will
be temporarily staged at an agreed upon location onsite. One characterization sample will be
collected from the 55-gallon drum and submitted for laboratory analysis of TAL Metals. This
technical approach includes estimated costs for the transportation of one 55-gallon drum of
nonhazardous waste to an appropriately certified disposal facility.
DATA EVALUATION
Following data validation efforts, EnSafe will prepare summary tables and figures and will
present findings and recommendations to Horsehead. Analytical data will be screened against
ENSAFF

•
Limited Investigatlon Work Plan
Horsehead Metal Products — Mooresboro Facility; Mooresbo% North Carolina
May 4,1015
Paoe 4
human health and ecological screening levels per North Carolina Division of Environment and
Natural Resources guidance. We anticipate that findings can be presented within 10 days of
data validation efforts.
EnSafe sincerely appreciates the opportunity to work with Horsehead on this project. We are
confident that our knowledge, skills, and experience will ensure the successful completion of this
important project in a timely manner.
Sincerely,
EnSafe Inc.
0�
By: Phil Coop
Senior Project Manager
Attachments: Figure 1 —Site Location Map
Figure 2 — Proposed Sample Location Map
ENSAFE

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��� . �� •�` 1 1 . i • :3'1 1 1 I �'`f I:� ~�}, tit}� �!y1:7ULlln1`J `Ual'^�l'w�ll.L'J� %= '-„\\..� -:51�• Iri'l�i-)r Limited Investigation
Mooresboro, North Carolina
lam' 4�'•

•
Herbert, Laura C
From: Davidson, Alison
Sent: Friday, August 29, 2014 8:31 AM
To: Herbert, Laura C; Menzel, Jeff; Burch, Brent; Ballard, Patrick; Scott, Chris
Subject: FW: Permit Transfers
Attachments: Horsehead Permit Transfers.pdf
Good morning all,
I have been assisting Horsehead with transferring their permits to another entity name and have provided them with the
attached information. Their attorney's office is asking what are they looking at in regard to a projected timeline for the
name/ownership application processing? This transition may occur on or about September 30. Please let me know the
projected timeframe for the processing in your division.
Thanks,
-Alison
Akson ❑&viCition - [e-mail]
Environmental Assistance Coordinator
NCDENR, Division of Environmental Assistance & Customer Service (DEACS)
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
ncenvironmenta lassistance.org
Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and
therefore may be disclosed to third parties.
From: Davidson, Alison
Sent: Tuesday, August 26, 2014 4:49 PM
To: '[e-mail]'
Subject: Permit Transfers
Hello Ashley,
As requested, I have put together the permit transfer information for the Horsehead facility in Rutherford County. Also,
the facility has an individual NPDES stormwater permit that wasn't listed below and I have added this information at the
bottom of the attachment.
Please let me know if you have any questions or if I may assist further. I can be reached directly at 828.296.4698.
Best Always,
-Alison
From: Wooten, Ashley T. [mailto:[e-mail]]
Sent: Tuesday, August 26, 2014 9:36 AM
To: Ballard, Patrick
Subject: Permit Transfers

Mr. Ballard:
I was given your name by Cathy Teulings, in your Raleigh office. I need to have the permits listed below transferred to
another entity name. Can you help me and direct me to the applications needed, please?
• Hazardous Waste Generator EPA ID and Fee to NC DENR: Horsehead Metal Products, Inc.
• Air Permit No. 102481301: Horsehead Metal Products, Inc.
• Process Effluent Discharge NPDES Permit NC0089109: Horsehead Metal Products, Inc.
• Certificate of Coverage Boiler -Cooling tower Blowdown NCG500667: Horsehead Metal Products, Inc.
• Construction Stormwater Discharge Permit NCG 010000: Horsehead Corporation
• Sanitary Discharge Permit WQ0035840: Horsehead Corporation
Thanks in advance.
Best regards,
Ashley T. Wooten, NCCP
North Carolina Certified Paralegal
Nexsen Pruet, PLLC
4141 Parklake Avenue, Suite 200
Raleigh, NC 27612
T: 919.653.7837, F: 919,653,0435
[e-mail]
www.nexsenpruet.com
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Akl an jD w1,A_,o.n - alison.davidson a ncdenr.gov
Environmental Assistance Coordinator
NCDENR, Division of Environmental Assistance & Customer Service (DEACS)
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
ncenvironmentalassistance.org

•
Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and
therefore may be disclosed to third parties.

0
Hazardous Waste Generator EPA ID (Handler ID: NCROOO1 59038): Horsehead Metal Products, Inc.
No fee. A subsequent notification is required for facility owner/operator changes for a Large Quantity
Generator. Please use the following form: EPA Form 8700-12: RCRA Subtitle C Site Identification Form
December 2011. If you have questions about completing this form, contact Brent Burch at 828.321.9585.
Upon completion, mail to the following:
Hazardous Waste Section
Attn: Ray Strawbridge
1646 Mail Service Center
Raleigh, North Carolina 27699-1646
• Air Permit No. 10248R01: Horsehead Metal Products, Inc.
Asheville Regional Office, Air Quality Staff will be processing this request — Patrick Ballard: 828.296.4545 and
Chris Scott: 828.296.4542.
• Process Effluent Discharge NPDES Permit NCO089109: Horsehead Metal Products, Inc.
No fee. Please use the following form: Name — Ownership Change Form. If you have questions about completing
this form, contact Jeff Menzel at 828.296.4658.
Upon completion, mail to the following:
Division of Water Resources
Water Quality Permitting Section
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Certificate of Coverage Boiler -Cooling tower Blowdown NCG500667: Horsehead Metal Products, Inc.
No fee. Please use the following form: Name — Ownership Change Form. If you have questions about completing
this form, contact Jeff Menzel at 828.296.4658.
Upon completion, mail to the following:
Division of Water Resources
Water Quality Permitting Section
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Construction Stormwater Discharge Permit NCG 010000: Horsehead Corporation
No fee. Please use the following form: Financial Responsibility Ownership Form. If you have questions about
completing this form, contact Laura Herbert at 828.296.4610.
Upon completion, mail to the following:
Division of Energy, Mineral and Land Resources
Attn: Laura Herbert
2090 US Highway 70
Swannanoa, North Carolina 28778
Sanitary Discharge Permit WQ0035840: Horsehead Corporation
Permit expired upon tie -on to the regional Publicly Owned Treatment Works (POTW).
NPDES Stormwater Permit NCS000562 (Individual Pe", it): Horsehead Holding Corporation
No Fee. Please use the following form: Permit Name/Ownership Change Form. If you have questions about
completing this form, contact Laura Herbert at 828.296.4610.
Upon completion, mail to the following:
Division of Energy, Mineral and Land Resources
Stormwater Permitting Program
1612 Mail Service Center
Raleigh, North Carolina 27699-1612

a
ft
Herbert, Laura C
From: Pickle, Ken
Sent: Tuesday, September 02, 2014 11:31 AM
To: Davidson, Alison
Cc: Herbert, Laura C; Bennett, Bradley; Georgoulias, Bethany
Subject: RE: Permit Transfers - Horsehead
Alison,
Two stormwater permits concern us at this site, and it looks like you have provided sufficient information in both cases
for the permittee to initiate that change with us. I don't see any further actions required until we receive the paper
applications.
For the construction general permit, NCG01: As far as ! know, your directions are sufficient. NCG01 is written to
reference 'the permittee', not Horsehead; also, the permit is written so that it is tied to the approved Sediment
and Erosion Control Pion. So, the corrected permittee name is procedurally accomplished via the Sediment
Program documents that you already reference, as far as 1 know. When construction is completed and the site is
stabilized and DEMLR's Sediment and Erosion Control plan is no longer applicable, we consider that the coverage
under DEMLR's NCGO1 also lapses concurrently.
For the industrial discharge permit, NCS0090562: Your directions are sufficient, if the permittee reads the
form. Most do. Some don't. For those that don't read the form closely, the tricky bits include:
o If these proposed permit coverage changes are the result of a simple name change without an
ownership change, only one signature is required, and there is no requirement to provide substantiating
documentation of the name change. For example, if Arthur B. Charles Company wants to change their
name to ABC Company with no change in ownership, we view that as a simple name change.
o On the other hand, if ABC Company sells out to a different entity, Toxic Metals Galactic, LLC, then we
expect two signatures (one from each party to the transaction), and we want the supporting documents
required by the form. Please note that the supporting documents requirement is not met by providing
articles of incorporation from the Secretary of State, but rather by the specific documents that are the
vehicle for the direct transaction.
o Please note that we will not implement an ownership change in advance of the transaction between the
parties. The transaction must be already accomplished before we will consider transferring permit
coverage. This might be imagined to establish a short awkward period where the old party is still on the
permit, but the new party owns the site. We have never had any difficulties because of this awkward
sequence.
Please contact me if any follow-up questions arise.
Ken
From: Davidson, Alison
Sent: Friday, August 29, 2014 9:42 AM
To: Pickle, Ken; Georgoulias, Bethany
Cc: Herbert, Laura C
Subject: RE: Permit Transfers - Horsehead
Ken/Bethany,
Thus far, I have provided the attached info. to Horsehead.

ft
so
Your guidance is greatly appreciated.
Thanks,
-Alison
Alison Davidson - [e-mail]
Environmental Assistance Coordinator
NCDENR, Division of Environmental Assistance & Customer Service (DEACS)
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
ncenvironmentalassistance.orR
Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and
therefore may be disclosed to third parties.
From: Herbert, Laura C
Sent: Friday, August 29, 2014 9:38 AM
To: Pickle, Ken; Georgouiias, Bethany
Cc: Davidson, Alison
Subject: FW: Permit Transfers - Horsehead
Ken/Bethany,
See below question about ownership change processing for NPDES stormwater permits? Horsehead is an individual
permit. Would you let Alison know (she is copied on this email), because I am out of the office the rest of the day.
Thanks,
Laura
Laura Herbert, P.E.
Regional Engineer
Division of Energy, Mineral, and Land Resources - Land Quality Section
NCDENR-Asheville Regional Office
2090 US Highway 70
Swannanoa, NC 28778
Tel:[phone] Fax:[phone]
http://Portal.ncdenr.or./web/Ir
Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and therefore may be disclosed to
third parties unless the content is exempt by statute or other regulation.
From: Davidson, Alison
Sent: Friday, August 29, 2014 9:35 AM
To: Herbert, Laura C
Subject: RE: Permit Transfers
Would this apply to the construction stormwater permit as well as the individual NPDES stormwater permit? And I
apologize, but I'm a little confused would the name/ownership change be handled as a "revision"?
Thanks,

s
o •
Waelz off- loading area- Rail cars are off-loaded under roof and pneumatically transferred into six silos.
Pneumatically transported to the 100 area.
100 area — Waelz Oxide Leaching feeds the SX- Solvent Extraction area with PLS- pregnant leach solution
which has high levels of Zinc, Lead and Cadmium
200 area —Solvent Extraction takes PLS and through Organic chemistry concentrates Zinc to the
Electrolyte solution. PLINT solution —high in Lead will eventually be processed in the PLINT area.
Currently it is
300 area — bleed off of .5% of organic raffinate to waste treatment
400 area- Loaded Electrolyte solution goes to the cell house where it is plated onto Aluminum sheets
500 area — 99.99 % pure Zinc plates are moved to the furnace for casting into 25 lb ingots or 2000 lb
jumbos and warehoused for shipping. An additional furnace is being installed for production of three (3)
grades of Zinc products —Special High Grade 99.9% Zinc
Prime Western as up to 15 Lead content
-- Continuous Galvanizing Grade ma have up to 1.5%Aluminum content

0 0
RCRA INSPECTION REPORT
x= VIOLATION NOTED NA= NOT APPLICABLE
Facility Name: Horsehead Metal Products, Inc.
Location/ Mailing Address: 484 Hicks Grove Road, Mooresboro, NC 28114
EPA ID#: NCR 000 159 038 Phone Number: 828-919-3139 (c- 748-5283)
Contact/ Title: Jim Harris Inspection Date: August 13, 2014
jharrisCaD_horsehead.net
Last Inspection: June 10, 2014 CMP Status: Large Quantity Generator
Type of Inspection: CMP Inspector(s): Spring Alien, Brent Burch NCDENR
Paula Whiting — US EPA
Present at Inspection: Jim Harris, Scott Hoenecke, Diego_ Rojas
Report: On August 13, 2014, Spring Allen, Brent Burch and Paula Whiting conducted a site visit
at Horsehead Metal Products to investigate a complaint received through the NC Department of
Labor concerning releases within process containment areas that remain in containment instead
of being properly cleaned up. The facility identified the ponds as process ponds, and storm
water ponds. They have responded to of the issue of migratory birds landing on the ponds and
being killed by the installation of a fla system above the ponds investiq ated on June 10 2014.
Type of Business: Horsehead Metal Products Inc. operates a Zinc recoveprocess. The
are in the start-up process of the state-of-the-art facility. Currently the facility is at 11 % of
operation. Plans are to be at 50% operations by the end of the summer. They operate on a 196
acre tract in Rutherford County NC. 225,000 sf of the operations is under roof. The facilit
operates 24 hours per day, seven days per week, with four shifts, and support 230 employees
currently. Both potable and production water is supplied by the Forest City Water Department.
Process: The facility received WAELZ Oxide WOX in rail cars from sister facilities. It is in
powder form at this point. Their sister plants recover WOX by "cooking" K061 waste into 70%
Zinc in granular form. WOX is moved pneumatically from rail cars to storage _tanks. This takes
lace inside the off-loading building. (photos) WOX clarifiers mix WOX with Sulfuric Acid and
transported the Leaching Area (100). At this -point the material is known as PLS (Pregnant
Leach Solution) due to its -high Zinc content. PLS is introduced into the Solvent Extraction SX
Stage. It is very low pH at this point and Zn is concentrated. The "loaded organic" phase of the
cycle removes Zn into the "loaded electrolyte" phase which is introduced into the cell house
where Zn is plated onto Aluminum plates by simple anode — cathode response under current.
Zinc plates are cut from the Al plates and fed into a specially designed furnace to melt
and cast into 25 Ib. ingots or 2000 lb. jumbos. They produce three grades of Zinc. Special
High Grade is 99.9 % Zinc. Prime Western can contain up to 1 % lead. Continuous galvanize_
grade may contain up to 1.5% Aluminum.
When PLS is depleted of its Zn during solvent extraction it is returned to the WOX cycle.
When SX is depleted in the Organic i2hase it is returned to the PLS cycle.
When loaded electrolyte is depleted in the cell house it is returned to the organiccphase for
reloading. A small amount about 5% oes to bleed treatment from the SX phase. This
generates secondary products of metallic cement, gypsum and liquid effluent.
Leaching residue from the PLS cycle has a lead/ silver concentrate and gypsum and is currently
shipped off -site for further refinement. When at full operation it will be refined on -site in the
PLINT process. This process is in the planning stage.

Ir
A records review and facility inspection were conducted.
Wastes Generated: hazardous or regulated waste streams generated on -site:
F003/ D001 solids containing liquids (Xylene/MEK _ F0031 D001 Acetone
F003/ D0011 D035 liquid (Xylenel MEK) F003/ D001 Acetone/ Methanol
D008 Lead contaminated super -sacs from sandblasting_ Non-HW Oily debris
Non-HW gypsum
Manifests: 'Approved Transporters? yes_ Approved TSDF? yes
Filled out correctly? yes Signed Copies? yes LDR Notification Attached? yes
Comments - Manifests are in good order. LDR notification is included with the manifests. LDR
and waste profiles are kept in the manifest binder.
Transporters: FCC Environmental TXR 000 078 094
Dart Acquisitions NCD 121 700 777
Advanced Environmental Options _ SCR 000 074 575
Palmetto Landfill
TSDF's: Eco Flo, Inc. NCD 980 842 132
Mountain Environmental Svs. flamps & non-HW
All Bright (non-HW gypsum)
Inspection Records: Inspections are conducted and results are kept in a log book and are
available for review.
Contingency Plan: The facility contingency plan has been sent to emergency responders.
Emergency coordinators are Jim Harris primary and Charlie Howell alternate.
Training Records: Certified Training Records Available?
The facilitv conducts training for all personnel in 5-S processes and environmental concerns.
Only Jim Harris and Charlie Howell handle hazardous waste. Their training records were
available for review.
Emergency Preparedness:
Facility Maintained and Operated to Prevent Releases? yes
Internal Communications or Alarm Present? yes
Portable Fire Extinguishers and/ or Fire Control Equipment? yes
Spill Control Equipment: yes
Adequate Water Volume, Foam Equipment or Sprinkler System? yes
All equipment 1 alarms tested/ maintained? yes
All Personnel Handling HW have access to Alarm/ Device? yes, cellular phones and radios
Adequate Aisle Space in operation areas? yes
Satellite Accumulation Area(s): There are no satellite accumulation areas.
Storage Areas): The storage area is located in a 25 X 25' fenced and locked area in the
warehouse portion of the furnace/ warehouse buildina. At the time of inspection there were 4
(four) 55-gallon containers holdinq soil and spill residues. Each was labeled and dated as
required. Additionally, there were 8 (eight) 55- allon containers holdinc
i used oil. Spill equipment
was available. Aisle space was discussed to assure proper storage requirements.

•
Containers closed? yes Aisle Space? yes
Evidence of Release? no <90 days? yes
Labeled? yes
Good Condition? yes
1. 40 CFR 262.34(a)(1) D008 Lead contaminated waste from a release from the carbon
filter system was not kept in containers as required. Waste from the failed carbon filter
tanks was stored in an open three sided containment and in roll off containers. However,
waste was on the outside of the containers and on the ground outside of the
containment as well as inside the containment.
Spring Denise Allen August 13, 2014 by mail
Inspector (Date) Facility Contact (Date)

TIMOTHY R. BASILONM
Vice President - Enurinlrrnul7niAffairs
4955 STEUBENVILLE PIXF WWw.HDRSEHEAp.NEY 724.773,2223
SUITE 405 TBASILONE®HORSEHEAD.NET 412.788.4526
PITTSBURGm, PA 15205
September 19, 2012
Mr. Ken Pickle, Environmental Engineer
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Stormwater Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: Draft Industrial Stormwater NPDES Permit
Horsehead Corporation Zinc Production Facility
Rutherford County, North Carolina
Dear Mr. Pickle:
Er xrL- --;,���
CORPORATION
Lending the World in Zirrc Recycling
Thank you for the opportunity to comment on the Draft Industrial Stormwater NPDES
Permit (Draft Permit) you provided on June 29, 2012. Furthermore, thank you for your
continuing effort in working with us to develop this permit, and providing time for
meetings and telephone conferences to discuss our permit application and the subject
permit. Our comments on the Draft Permit, the Staff Review and Evaluation Form (Staff
Review'Form), and the Regional Office comments are provided below. These comments
summarize our discussions, and are responsive to your requests from the conference call
with you and the Regional Office on September 14,2012, and comments provided earlier
in e-mails to you.
The overriding storm water management concept is to capture and control the disposition
of all storm water falling into the operating area. This system is to prevent the
uncontrolled discharge of potential pollutants to the discharge stream. The physical
facility is being designed to support this concept, and operating procedures will be
developed to ensure management controls are documented and implemented. The first
preference is to use the water in the operation, and as a second preference, only as
necessary, to direct the water to the site storm water discharge.
The facility is designed to capture and contain all storm water that falls within the
operating area of the site, This design will contain rainwater falling in this area during
the 100 year 24 hour storm event. Water captured in the area will be managed in one of
three ways, as follows:
If part of an individual (isolated) basin, water will be placed directly into the
process or a tank within that production area,

0
• Routed to the process water management system, or used to partially displace
process water (finished water provided by the Town.) used by the operation,
■ Sampled and analyzed before discharge to the storm water outfall system.
Storm water falling in areas outside the operating area and from rooftops, parking areas
and landscaped areas will be discharged directly to the storm water outfall during the
storm event.
Details of this system are being developed and will be incorporated as part of the site
operating procedures, and the Storm Water Pollution Prevention Plan (SWPPP). A map
and table describing this system will be provided once the system design is completed.
Comments on the Draft Permit, Staff Review Form and the Regional Office Comments
are addressed below.
Comments on the Staff Review Form
Page 1, Type of Activity and Page 2 Description of Activity
The reference to receiving waste is incorrect. The facility will receive zinc oxide
as raw material for the process which is a product manufactured at other
Horsehead facilities. Zinc oxide feed materiat contains some lead and cadmium,
in addition to zinc. The reference to silver should be eliminated, since it is a very
minor component of zinc oxide.
Page 1, Special Permitting Issues, Risk Considerations, Location
The assigned rating b is excessive for risk due to the site location. Since this is a
new facility, the existing impairment mentioned in this section is a pre-existing
condition located downstream and cannot be, attributed to the new facility. Based
on the actual conditions, the rating should be in the low range of the risk scale.
Page 1, Special Permitting_ Issues, Risk Considerations, Other Factors
The assigned rating 10 is excessive for risk considering other factors. This is a
new facility that is specifically designed, as described above, to prohibit
stormwater contamination. To the contrary of the statement "proper operator
actions to a larger than normal degree" and other factors mentioned, during our
discussions you indicated design of the stormwater management systems for this
plant are exceptional. The design includes a stormwater management system
whereby discharge of storm water from the operating area is not possible without
specific action based on management authorization to release the water. If the
agency's risk determination is to be used as a basis for permit decisions, the true
risk of stormwater pollution fi•om the site needs to be described. Our design
presents less than normal risks for most industrial sites. Based on the actual
conditions, the rating should be. in the low range of the risk scale.
2

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

0
in the section above. We propose the permit be written to require "monitoring
only" for the first two years of the operation.
Information obtained for the first eight quarters of operation should be recorded
and summarized in a report to support a recommendation for either a stormwater
permit containing benchmark levels established based on potential impact to the
Broad River, or a "no exposure" application and site status. The report would be
submitted to the agency following the two year period of evaluation for review by
DWQ. Based on this report the permit can be revised accordingly, or eliminated
if the "no exposure" scenario is justified.
The report would provide the raw data, an evaluation of the potential impact to
the receiving waters based on the monitoring data and the conditions of the Broad
River at the time of sampling, a recommendation on the need for benchmarks at
Ns site, if appropriate a recommendation for the benchmark parameters and
levels, and an evaluation of the site for "no exposure" status. If the "no exposure"
scenario applies, an application for this status will be provided with the report.
Since this is a new plant with no prior history available, and the design of the
plant is such that stormwater is contained and controlled in areas of the operation,
we believe the proposed approach allows for information to be gathered after the
plant begins operating that will serve as a basis for developing a permit for the
operation or justifying a "no exposure" scenario.
Comments on the Draft Permit
Part II, Page 2 of 1_l, f b) Secondary Containment Requirements and Records
The later portion of this section should be eliminated beginning on the seventh
line and following the words "areas shall be maintained." You have indicated
during prior meetings, calls and communications that the permit will not require
anything on internal monitoring, but will rely entirely on discharge point
monitoring for regulatory purposes. Specific conditions provided on internal
monitoring for captured water are inconsistent with these prior discussions.
Pail II Page 5 of:11, Section B: Analytical Monitoring Re
quii;ements
Please see the above sections in the Staff Evaluation discussing the Analytical
Monitoring Requirements.
Benchmarks and their use in the permit should be eliminated, including the tiered
approach for monitoring. Instead, Horsehead is proposing a "Monitor Only"
status for the facility for two years {eight quarters} following startup. Monitoring
will be conducted at the discharge point to the Broad River and include collection
and analysis of samples for Zinc, Lead, Cadmium, Oil & Grease, TSS, and pH.
Monitoring results over this period of time will be used to evaluate the
effectiveness of the facility design and stormwater management scheme, which is
.19

based on a strategy to prohibit stormwater discharge containing contaminants
from the operation.
As noted, the monitoring results obtained over the eight quarters will be
summarized in a report for submittal to the DWQ, and in support of a revised
stormwater permit with benchmark levels established based on potential impact to
receiving waters, or a "no exposure" status.
Part II Page 10 of 11, Section D: On -site Vehicle Maintenance Monitoring Requirements
Please eliminate this section; there is no vehicle maintenance facility or activity
that will be conducted on site,
Comments on the Relzional Office Comments
Require SWPPP to be developed for startup —
An SWPPP will be developed for the site prior to startup of the facility.
Address failure modes with a back-upj2lan identifying management actions in response
to atypical operating conditions —
The SWPPP to be developed prior to plant startup will address this matter.
Add chlorides to the sampling scheme —
Based on the proposed approach for stormwater management and the sampling
scheme and parameters described above, this monitoring will provide sufficient
data to assess stormwater from the facility site. Monitoring for chlorides will add
no additional benefits and is not justified.
Add quarterly acute toxicity testing to the sampling scheme —
The level of stormwater management on this site is extensive and well beyond
anything required under any other permit for facilities in North Carolina. Aquatic
Whole Effluent Testing is not a standard industrial stormwater requirement.
Application to a site with control systems as described above is not reasonable.
The inclusion of toxicity testing is unsupportable and inappropriate.
Provide a "step-down" in anal3lical testing from uarterl to.2/X after 3 years,
conditional on results --
In consideration of the proposed approach to monitoring, this should be evaluated
based on results from the quarterly sampling over two years, along with the
evaluation of a "no exposure" status for the site.

Per your request during our telephone conference on September 14, 2412, I have attached
a site plan showing the stormwater route to the River, including the stormwater basin
adjacent to the River.
We appreciate the opportunity to review the permit and the agency's supporting
documentation and comments. We are available to meet at your office to discuss this
permit application with you at your convenience. We look forward to discussing this
information with you and to reviewing a revised draft of the permit, based on our
comments.
As discussed on many occasions it is to our best interest to have this permit issued in the
shortest timeframe possible. Thank you for your continued support and consideration.
Sincerely, �J
Timothy R. Basilone
Enc.
cc Forest Westall, McGill Associates
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SCALE: NTS I RUTHERFORD COUNTY, NORTH CAROLINA I DATE: SEPTEMBER 2012 13DROADS-MUMT As,MYELLFL NC

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Permit No. NCS000562
PART III STANDARD CONDITIONS FOR NPDES STORMWATER INDIVIDUAL PERMITS
SECTION A: COMPLIANCE AND LIABILITY
Compliance Schedule
The permittee shall comply with Limitations and Controls specified for Stormwater discharges in
accordance with the following schedule:
Existing Facilities already operating but applying for permit coverage for the first time: The
Stormwater Pollution Prevention Plan shall be developed and implemented within 12 months of the
effective date of the initial permit and updated thereafter on an annual basis. Secondary containment,
as specified in Part I1, Section A, Paragraph 2(b) of this permit, shall be accomplished within 12
months of the effective date of the initial permit issuance.
New Facilities applying for coverage for the first time: C Stormwater Pollution Prevention Plan
shall be developed and implemented prior to the beginning of�dis` harges from the operation of the
industrial activity and be updated thereafter on an annual basis. Secondary containment, as specified
in Part I1, Section A, Paragraph 2(b) of this permit shilbbe accomplished prior to the beginning of
discharges from the operation of the industrial activity.
Existing facilities previously permitted �an"d pply1ng orf renewal: All requirements, conditions,
limitations, and controls contained in th� %rmft (kept revised SPPP elements m a permit renewal)
shall become effective immediately uponlissuance-o{this permit. New elements of the Stormwater
Pollution Prevention Plan fo-fthis pe`rmitrenewal shall be developed and implemented within 6
months of the effective date of this -perms and updated thereafter on an annual basis. Secondary
containment, as specified in Part.11l, Paragraph 2(b) of this permit shall be accomplished prior to the
beginning of discharges from the operation of the industrial activity.
2. Duty to Comply ~�
The permittee must comply with all conditions of this permit. Any permit noncompliance constitutes
a violation of the Clean Water Act (CWA) and is grounds for enforcement action; for permit
termination, revocation and reissuance, or modification; or denial of a permit upon renewal
application [40 CFR 122.41).
a. The permittee shall comply with standards or prohibitions established under section 307(a) of
the CWA for toxic pollutants within the time provided in the regulations that establish these
standards or prohibitions, even if the permit has not yet been modified to incorporate the
requirement
b. The CWA provides that any person who violates section[s] 301, 302, 306, 307, 308, 318 or 40S of
the Act, or any permit condition or limitation implementing any such sections in a permit issued
under section 402, or any requirement imposed in a pretreatment program approved under
sections 402(a)(3) or 402(b)(8) of the Act, is subject to a civil penalty not to exceed $37,500 per
day for each violation. [33 USC 1319(d) and 40 CFR 122.41(a)(2)]
c. The CWA provides that any person who negligently violates sections 301, 302, 306, 307, 308,
318, or 405 of the Act, or any condition or limitation implementing any of such sections in a
permit issued under section 402 of the Act, or any requirement imposed in a pretreatment
program approved under section 402(a)(3) or 402(b)(8) of the Act, is subject to criminal
penalties of $2,500 to $25,000 per day of violation, or imprisonment of not more than 1 year, or
both. In the case of a second or subsequent conviction for a negligent violation, a person shall be
Part III Page 1 of 9

Permit No. NCS000S62
subject to criminal penalties of not more than $50,000 per day of violation, or by imprisonment of
not more than 2 years, or both. [33 USC 1319(c)(1) and 40 CFR 122.41(a)(2)]
d. Any person who knowingly violates such sections, or such conditions or limitations is subject to
criminal penalties of $5,000 to $50,000 per day of violation, or imprisonment for not more than 3
years, or both. In the case of a second or subsequent conviction for a knowing violation, a person
shall be subject to criminal penalties of not more than $100,000 per day of violation, or
imprisonment of not more than 6 years, or both. [33 USC 1319(c)(2) and 40 CFR 122.41(a)(2)]
Any person who knowingly violates section 301, 302, 303, 306, 307, 308, 318 or 405 of the Act, or
any permit condition or limitation implementing any of such sections in a permit issued under
section 402 of the Act, and who knows at that time that he thereby places another person in
imminent danger of death or serious bodily injury, shall, upon conviction, be subject to a fine of
not more than $250,000 or imprisonment of not more than 15%years, or both. In the case of a
second or subsequent conviction for a knowing endangerment violation, a person shall be subject
to a fine of not more than $500,000 or by imprisonmeribof not more than 30 years, or both. An
organization, as defined in section 309(c)(3)(B)(iii) of;the CW. shall, upon conviction of
violating the imminent danger provision, be sdje\ t'to a fine of not more than $1,000,000 and can
be fined up to $2,000,000 for second or subsequent convictions. [40 CFR 122.41(a)(2)]
f. Under state law, a civil penalty of not more -than $25,000 per violation may be assessed against
any person who violates or fails to act in accordance with the terms, conditions, or requirements
/7 //, ,
of a permit. [North Carolina General Sfitutgs § 143-215.6A]
g. Any person may be assessed an`dm'inistbtive penalty by the Administrator for violating section
301, 302, 306, 307, 308�,318 or 405 ofthis Act, or any permit condition or limitation
implementing any of such sections in -a permit issued under section 402 of this Act.
Administrative penalties' or Class I'violations are not to exceed $16,000 per violation, with the
maximum amount oany Class I`penalty assessed not to exceed $37,500. Penalties for Class Il
violations are not to exceed $1si,000 per day for each day during which the violation continues,
with the maximum amount of any Class 11 penalty not to exceed $177,500. [33 USC 1319(g)(2)
and 40 CFR 122.41(a�G3�l�
3. Duty to Mitigate
The permittee shall take all reasonable steps to minimize or prevent any discharge in violation of this
permit which has a reasonable likelihood of adversely affecting human health or the environment [40
CFR 122.41(d)].
4. Civil and Criminal Liability
Except as provided in Part III, Section C of this permit regarding bypassing of stormwater control -
facilities, nothing in this permit shall be construed to relieve the permittee from any responsibilities,
liabilities, or penalties for noncompliance pursuant to NCGS 143-215.3, 143-215.6, or Section 309 of the
Federal Act, 33 USC 1319. Furthermore, the permittee is responsible for consequential damages, such
as fish kills, even though the responsibility for effective compliance may be temporarily suspended.
S. Oil and Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the institution -of any legal action or relieve the
permittee from any responsibilities, liabilities, or penalties to which the permittee is or may be
subject to under NCGS 143-215.75 et seq. or Section 311 of the Federal Act, 33 USC 1321.
6. Property Rights
The issuance of this permit does not convey any property rights in either real or personal property, or
any exclusive privileges, nor does it authorize any injury to private property or any invasion of
Part III Page 2 of 9

Permit No. NCS000562
personal rights, nor any infringement of Federal, State or local laws or regulations [40 CFR
122.41(g)],
7. SeverabilitX
The provisions of this permit are severable, and if any provision of this permit, or the application of
any provision of this permit to any circumstances, is held invalid, the application of such provision to
other circumstances, and the remainder of this permit, shall not be affected thereby [NCGS 15013-23].
8. Duty to Provide Information
The permittee shall furnish to the Permit Issuing Authority, within a reasonable time, any information
which the Permit Issuing Authority may request to determine whether cause exists for modifying,
revoking and reissuing, or terminating the permit issued pursuant to this permit or to determine
compliance with this permit. The permittee shall also furnish to the Permit Issuing Authority upon
request, copies of records required to be kept by this permit [40 CER 122.41(h)].
Penalties for Tampering /�
The Clean Water Act provides that any person who falsifies�mpers_wfth, or knowingly renders
inaccurate, any monitoring device or method required'tdbe maintained under this permit shall, upon
conviction, be punished by a fine of not more than $1 000 per violation, or by imprisonment for not
more than two years per violation, or by both. If a.eonvictionpf a person is for a violation committed
after a first conviction of such person under this paragraph, unishment is a fine of not more than
$20,000 per day of violation, or by imprisonpienL,of not more than 4 years, or both [40 CFR 122.41].
10.
The Clean Water Act provides that a6y,, person_who knowingly makes any false statement,
representation, or certificatRon in any record or other document submitted or required to be
maintained under this permit„including monitoring reports or reports of compliance or
noncompliance shall, upon conviction, be punished by a fine of not more than $10,000 per violation, or
by imprisonment for not more than two years per violation, or by both [40 CFR 122.41].
11. Onshore or Offshore Constructio
This permit does not authorize or approve the construction of any onshore or offshore physical
structures or facilities or the undertaking of any work in any navigable waters.
12. Duty to Reapply
If the permittee wishes to continue an activity regulated by this permit after the expiration date of
this permit, the permittee must apply for and obtain a new permit [40 CFR 122.41(b)].
MEN III [Blom :3W01:401NI". IM11►1111111[11► I
1. Permit Expiration
The permittee is not authorized to discharge after the expiration date. In order to receive automatic
authorization to discharge beyond the expiration date, the permittee shall submit forms and fees as
are required by the agency authorized to issue permits no later than 180 days prior to the
expiration date, unless permission for a later date has been granted by the Director. (The Director
shall not grant permission for applications to be submitted later than the expiration date of the
existing permit) [40 CFR 122.21(d)]. Any permittee that has not requested renewal at least 180 days
prior to expiration, or any permittee that does not have a permit after the expiration and has not
requested renewal at least 180 days prior to expiration, will be subjected to enforcement procedures
as provided in NCGS §143-215.36 and 33 USC 1251 et. seq.
Part Il l Page 3 of 9

Permit No. NCS000562
3.
Transfers
This permit is not transferable to any person without prior written notice to and approval from the
Director in accordance with 40 CFR 122.61. The Director may condition approval in accordance with
NCGS 143-21S.1, in particular NCGS 143-215.1(b)(4)b.2., and may require modification or revocation
and reissuance of the permit, or a minor modification, to identify the new permittee and incorporate
such other requirements as may be necessary under the CWA [40 CFR 122.41(l)(3), 122.61] or state
statute. The Permittee is required to notify the Division in writing in the event the permitted
facility is sold or closed.
Signatory Requirements
All applications, reports, or information submitted to the Permitting Issuing Authority shall be signed
and certified [40 CFR 122.41(k)].
a. All permit applications shall be signed as follows:
(1) For a corporation: by a responsible corpor
responsible corporate officer means: (a) a
the corporation in charge of a principal bus
similar policy or decision making functions
more manufacturing, production, or operat
to make management decisions which gove
having the explicit or implicit duty of makir
and initiating and directing other coniprehl
n rr
environmental compliance with envira me
ensure that the necessary systems are Ltal
accurate information"forr permitlappic�atior
documents has beemassigneN&or�elegated
procedures. ' \ \%
(2) For a partnershr'sole
ip��
or //
ate offic`e`r�
piesFor the purpose of this Section, a
id d-L secTary,,treasurer or vice president of
iness function, or -any other person who performs
Ifor i e corporation, or (b) the manager of one or
ing,facctlities, provided, the manager is authorized
,r` the operation of the regulated facility including
`g major capital investment recommendations,
msiveimeasures to assure long term
Mal laws and regulations; the manager can
dished or actions taken to gather complete and
i requirements; and where authority to sign
to the manager in accordance with corporate
by a general partner or the proprietor, respectively;
(3) For a municipality, State Federal, or other public agency: by either a principal executive
officer or ranking elbcted official [40 CFR 122.22],
b. All reports required by the permit and other information requested by the Permit issuing
Authority shall be signed by a person described in paragraph a. above or by a duly authorized
representative of that person. A person is a duly authorized representative only if:
(1) The authorization is made in writing by a person described above;
(2) The authorization specified either an individual or a position having responsibility for the
overall operation of the regulated facility or activity, such as the position of plant manager,
operator of a well or well field, superintendent, a position of equivalent responsibility, or an
individual or position having overall responsibility for environmental matters for the company.
(A duly authorized representative may thus be either a named individual or any individual
occupying a named position.); and
(3) The written authorization is submitted to the Permit Issuing Authority [40 CFR 122.22]
c. Changes to authorization: If an authorization under paragraph (b) of this section is no longer
accurate because a different individual or position has responsibility for the overall operation of
the facility, a new authorization satisfying the requirements of paragraph (b) of this section must
be submitted to the Director prior to or together with any reports, information, or applications to
be signed by an authorized representative [40 CFR 122.22]
Part III Page 4 of 9

Permit No. NCS000562
d. Certification. Any person signing a document under paragraphs a. or b. of this section shall make
the following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION WILL
BE ACCEPTED:
"1 certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properlygather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible forgathering the information,
the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I
am aware that there are significant penalties for submitting false information, including the
possibility offnesand imprisonmentfor knowing violations."
4. Permit Modification, Revocation and Reissuance, or Termination
The issuance of this permit does not prohibit the Permit Issuing Authority from reopening and
modifying the permit, revoking and reissuing the permit, or terminating the permit as allowed by the
Al
laws, rules, and regulations contained in Title 40, Code.of F derl Regulations, Parts 122 and 123;
Title 15A of the North Carolina Administrative Code lSubchapter 2H .0100; and North Carolina
General Statute 143-215.1 et al. f ( 1// '\1 \
S. Permit Actions
The permit may be modified, revoked and reissued; or terminated for cause. The notification of
planned changes or anticipated noncompliance does not stay any permit condition [40 CFR
122.41[f)].
6. Annual Administering and Complianc_Iyonitor g'Pee Requirements
The permittee must pay the`dr iinistering and -compliance monitoring fee within 30 (thirty) days
after being billed by the Division Failure to,pay the fee in timely manner in accordance with 15A
NCAC 2H .0105(b)(2) may cause this Division to initiate action to revoke the permit.
SECTION C: OPERATION AND MAINTENANCE OF POLLUTION CONTROLS
1.
The permittee shall at all times properly operate and maintain all facilities and systems of treatment
and control (and related appurtenances) which are installed or used by the permittee to achieve
compliance with the conditions of this permit. Proper operation and maintenance also includes
adequate laboratory controls and appropriate quality assurance procedures. This provision requires
the operation of back-up or auxiliary facilities or similar systems which are installed by a permittee
only when the operation is necessary to achieve compliance with the conditions of this permit [40
CFR 122.41(e)].
2. Need to Halt or Reduce Not a Defense
It shall not be a defense for a permittee in an enforcement action that it would have been necessary to
halt or reduce the permitted activity in order to maintain compliance with the condition of this permit
[40 CFR 122.41(c)].
Bypassing of Stormwater Control Facilities
Bypass is prohibited and the Director may take enforcement action against a permittee for bypass
unless:
a. Bypass was unavoidable to prevent loss of life, personal injury or severe property damage; and
b. There were no feasible alternatives to the bypass, such as the use of auxiliary control facilities,
retention of stormwater or maintenance during normal periods of equipment downtime or dry
weather. This condition is not satisfied if adequate backup controls should have been installed in
Part III Page 5 of 9

Permit No. NCS000562
the exercise of reasonable engineering judgment to prevent a bypass which occurred during
normal periods of equipment downtime or preventive maintenance; and
c. The permittee submitted notices as required under, Part ill, Section E of this permit.
If the Director determines that it will meet the three conditions listed above, the Director may
approve an anticipated bypass after considering its adverse effects.
SECTION D: MONITORING AND RECORDS
Representative Sampling
Samples collected and measurements taken, as required herein, shall be characteristic of the volume
and nature of the permitted discharge. Analytical sampling shall be performed during a measureable
storm event. Samples shall be taken on a day and time that is characteristic of the discharge. All
samples shall be taken before the discharge joins or is diluted,by any other waste stream, body of
water, or substance. Monitoring points as specified in rliis permit shall not he changed without
notification to and approval of the Permit Issuing Authority [40`CFR 122.41(j)).
2. Rec_grding Results
For each measurement or sample taken pursuant.to.`he requirements of this permit, the permittee
shall record the following information [40 CFR;1-22.411
a. The date, exact place, and time of sampling of'measufements;
b. The individuals) who performed the�samp[ing,nr measurements;
c. The date(s) analyses w`e pe foeh%U;
d. The individual(s) who performed the analyses;
e. The analytical techniques 13 orjrnethods-used; and
f. The results of such and]
3. Flow Measurements
Where required, appropriate flow measurement devices and methods consistent with accepted
scientific practices shall be selected and used to ensure the accuracy and reliability of measurements
of the volume of monitored discharges.
4. Test Procedures
Test procedures for the analysis of pollutants shall conform to the EMC regulations published
pursuant to NCGS 143-215.63 et. seq, the Water and Air Quality Reporting Acts, and to regulations
published pursuant to Section 304(g), 33 USC 1314, of the Federal Water Pollution Control Act, as
Amended, and Regulation 40 CFR 136.
To meet the intent of the monitoring required by this permit, all test procedures must produce
minimum detection and reporting levels and all data generated must be reported down to the
minimum detection or lower reporting level of the procedure. If no approved methods are
determined capable of achieving minimum detection and reporting levels below permit discharge
requirements, then the most sensitive (method with the lowest possible detection and reporting
level) approved method must be used.
S. Re rruentative Outfall
If a facility has multiple discharge locations with substantially identical stormwater discharges that
are required to be sampled, the permittee may petition the Director for representative outfall status.
If it is established that the stormwater discharges are substantially identical and the permittee is
granted representative outfall status, then sampling requirements may be performed at a reduced
number of outfalls.
Part III Page 6 of 9

Permit No. NCS000562
6. Records Retention
Visual monitoring shall be documented and records maintained at the facility along with the
Stormwater Pollution Prevention Plan. Copies of analytical monitoring results shall also be
maintained on -site. The permittee shall retain records of all monitoring information, including
o all calibration and maintenance records,
o all original strip chart recordings for continuous monitoring instrumentation,
o copies of all reports required by this permit,
o copies of all data used to complete the application for this permit
These records or copies shall be maintained for a period of at least 5 years from the date of the
sample, measurement, report or application. This period may be extended by request of the Director
at anytime [40 CFR 122.41].
Inspection and Entey
The permittee shall allow the Director, or an authorized representative (including an authorized
contractor acting as a representative of the Director) 4p� in the case of a facility which discharges
V/ ... . ..
through a municipal separate storm sewer system, an authorized representative of a municipal
operator or the separate storm sewer system receiving -the discharge upon the presentation of
credentials and other documents as may be required°by, law, to:
a. Enter upon the permittee's premises w
or where records must be kept under t]
b. Have access to and copy, at reasonable,
of this permit; ^ ^ If
c. Inspect at reasonable times any faciliti(
equipment), practices, or perations re
d. Sample or monitor at reasonable times
otherwise authorized bythe Clean Wat
CFR 122.41(i)]. i1
SECTION E: REPORTING
Discharge Monitoring Reports
regulated�facility or activity is located or conducted,
A ons o��this permit,
any, ce ords that must be kept under the conditions
equipment (including monitoring and control
lated or required under this permit, and
r the purposes of assuring permit compliance or as
Act, any substances or parameters at any location [40
Samples analyzed in accordance with the terms of this permit shall be submitted to the Division on
Discharge Monitoring Report (DMR) forms provided by the Director. DMR forms are available on the
Division's website (http://portal.ncdenr.org/web/wq/ws/su/npdessw). Submittals shall be
delivered to the Division no Iater than 30 days from the date the facility receives the sampling
results from the laboratory.
When no discharge has occurred from the facility during the report period, the permittee is required
to submit a discharge monitoring report, within 30 days of the end of the specified sampling period,
giving all required information and indicating "NO FLOW" as per NCAC T15A 02B .0506.
If the permittee monitors any pollutant more frequently than required by this permit using test
procedures approved under 40 CFR Part 136 and at a sampling location specified in this permit or
other appropriate instrument governing the discharge, the results of such monitoring shall be
included in the data submitted on the DMR.
The permittee shall record the required qualitative monitoring observations on the SDO Qualitative
Monitoring Report form provided by the Division and shall retain the completed forms on site.
Qualitative monitoring results should not be submitted to the Division, except upon DWQ's specific
requirement to do so. Qualitative Monitoring Report forms are available at the website above.
Part III Page 7 of 9

Permit No. NCS000562
2. Submitting Reports
Two signed copies of Discharge Monitoring Reports (DMRs) shall be submitted to:
Central Files
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
3. Availability of Reports
Except for data determined to be confidential under NCGS 143-215.3(a)(2) or Section 308 of the
Federal Act, 33 USC 1318, all reports prepared in accordance with the terms shall be available for
public inspection at the offices of the Division. As required by the Act, analytical data shall not be
considered confidential. Knowingly making any false statement on.any such report may result in the
imposition of criminal penalties as provided for in NCGS 143°215.6B or in Section 309 of the Federal
Act. /> '�-_ \ n
4. Non-Stormwater Discharges V"C .
If the storm event monitored in accordance with this•permit coincides with a non-stormwater
discharge, the permittee shall separately monitor all 'para ers as required under all other
applicable discharge permits and provide this inf rmationwith the stormwater discharge monitoring
report.
S. Planned Changes
The permittee shall give notice to the Directoras•soon as possible of any planned changes at the
permitted facility which couid,significantly-alter the nature or quantity of pollutants discharged [40
CFR 122.41(l)]. This notification requireement includes pollutants which are not specifically listed in
r� , \
the permit or subject to notiflcationtregpirements under 40 CFR Part 122.42 (a).
A
The permittee shall give advance notice to the Director of any planned changes at the permitted
facility which may result in -noncompliance with the permit [40 CFR 122.41(1)(21].
7. Snills
The permittee shall report to the local DWQ Regional Office, within 24 hours, all significant spills as
defined in Part IV of this permit. Additionally, the permittee shall report spills including: any oil spill
of 25 gallons or more, any spill regardless of amount that causes a sheen on surface waters, any oil
spill regardless of amount occurring within 100 feet of surface waters, and any oil spill less than 25
gallons that cannot be cleaned up within 24 hours.
8. Bypass
Notice [40 CFR 122.41(m)(3)]:
a. Anticipated bypass. If the permittee knows in advance of the need for a bypass, it shall submit
prior notice, if possible at least ten days before the date of the bypass; including an evaluation of
the anticipated quality and affect of the bypass.
b. Unanticipated bypass. The permittee shall submit notice within 24 hours of becoming aware of
an unanticipated bypass.
9. Twenty-four Hour ReDortin
a. The permittee shall report to the central office or the appropriate regional office any
noncompliance which may endanger health or the environment. Any information shall be
provided orally within 24 hours from the time the permittee became aware of the circumstances.
A written submission shall also be provided within 5 days of the time the permittee becomes
aware of the circumstances.
Part III Page 8 of 9

Permit No. NCS000562
The written submission shall contain a description of the noncompliance, and its causes; the
period of noncompliance, including exact dates and times, and if the noncompliance has not
been corrected, the anticipated time compliance is expected to continue; and steps taken or
planned to reduce, eliminate, and prevent reoccurrence of the noncompliance [40 CFR
122.41(I)(6)].
b. The Director may waive the written report on a case -by -case basis for reports under this section
if the oral report has been received within 24 hours.
c. Occurrences outside normal business hours may also be reported to the Division's Emergency
Response personnel at [phone], [phone] or [phone].
10. Other Noncompliance
The permittee shall report all instances of noncompliance
the time monitoring reports are submitted [40 CFR 1,22.4
11. Other Information
Where the Permittee becomes aware that it failed
or submitted incorrect information in a permit ap
promptly submit such facts or information [40-�CF
11
rted under 24 hour reporting at
;y relevant facts in a permit application,
,in any report to the Director, it shall
(8)].
Part III Page 9 of 9

NCS000S62
4.
PART IV DEFINITIONS
Act
See Clean Water Act.
Adverse Weather
Adverse conditions are those that are dangerous or create inaccessibility for personnel, such as local
flooding, high winds, or electrical storms, or situations that otherwise make sampling impractical.
When adverse weather conditions prevent the collection of samples during the sample period, the
permittee must take a substitute sample or perform a visual assessment during the next qualifying
storm event. Documentation of an adverse event (with date, time and written narrative) and the
rationale must be included with your SPPP records. Adverse weather does not exempt the permittee
from having to file a monitoring report in accordance with�the,sampling schedule. Adverse events and
failures to monitor must also be explained and reported on the relevant DM R.
Allowable Nan-Stormwater Discharges
This permit regulates stormwater disch
the stormwater conveyance system are:
a. All other discharges that are author
b. Uncontaminated groundwater, four
chemicals, springs, discharges of un
flushings, water from footing�dralw
c. Discharges resulting fromjire-fight
as a result of use in the event of an f
ter discharges which shall be allowed in
!d by//'a non-stormwater NPDES permit.
itiow a). s, air -conditioner condensate without added
ntaminated potable water, waterline and fire hydrant
ows from riparian habitats and wetlands.
4r fire -fighting training, or emergency shower or eye wash
mergency.
Measures or practices used-to•reduce the amount of pollution entering surface waters. BMPs may
take the form of a process, -activity, or physical structure. More information on BMPs can be found at:
httl2://cfpub.eia.gov/npdes/stormwater/nienuofbmps/index.cfm.
S. Bypass
A bypass is the known diversion of stormwater from any portion of a stormwater control facility
including the collection system, which is not a designed or established operating mode for the facility.
6. Bulk Storage of Liquid Products
Liquid raw materials, manufactured products, waste materials or by-products with a single above
ground storage container having a capacity of greater than 660 gallons or with multiple above ground
storage containers located in close proximity to each other having a total combined storage capacity
of greater than 1,320 gallons.
7. Certificate of Coverage
The Certificate of Coverage (COC) is the cover sheet which accompanies a General Permit upon
issuance and lists the facility name, location, receiving stream, river basin, effective date of coverage
under the permit and is signed by the Director.
$. Clean Water Act
The Federal Water Pollution Control Act, also known as the Clean Water Act (CWA), as amended, 33
USC 1251, et. seq.
Division or DWO
The Division of Water Quality, Department of Environment and Natural Resources.
Part IV Page 1 of 4

Permit No. NCS000562
10. Director
The Director of the Division of Water Quality, the permit issuing authority.
11. EMC
The North Carolina Environmental Management Commission.
12. Grab Sample
An individual sample collected instantaneously. Grab samples that will be analyzed (quantitatively or
qualitatively) must be taken within the first 30 minutes of discharge.
13. Hazardous 5ul7stancg
Any substance designated under 40 CFR Part 116 pursuant to Section 311 of the Clean Water Act.
14. Landfill
A disposal facility or part of a disposal facility where waste is ged in or on land and which is not a
land treatment facility, a surface impoundment, an in/jectiomwe�Il;,a hazardous waste long-term
storage facility or a surface storage facility. r f
is, Measureable Storm Event
A storm event that results in an actual discharge
16.
measurable storm event must have been at leasf
apply if the permittee is able to document that a
events during the sampling period, and obtainsla
copies of this information and a written request
After authorization by the DfWQ,\ice a1�Office,.
permittee's SPPP.
tted site outfall. The previous.
The 72-hour storm interval may not
�r interval is representative for local storm
gal from the local DWQ Regional Office. Two
shall be sent to the local DWQ Regional Office.
ten approval letter must be kept on site in the
A stormwater collection sy"stem within an incorporated area of local self-government such as a city or
town.
17. No Exposure
A condition of no exposure means that all industrial materials and activities are protected by a storm
resistant shelter or acceptable storage containers to prevent exposure to rain, snow, snowmelt, or
runoff. Industrial materials or activities include, but are not limited to, material handling equipment
or activities, industrial machinery, raw materials, intermediate products, by-products, final products,
or waste products. DWQ may grant a No Exposure Exclusion from NPDES Stormwater Permitting
requirements only if a facility complies with the terms and conditions described in 40 CFR
§122.26(g).
18. Notice of Intent
The state application form which, when submitted to the Division, officially indicates the facility's
notice of intent to seek coverage under a General Permit.
19. Permit Issuing Authority
The Director of the Division of Water Quality (see "Director" above).
20. Permittee
The owner or operator issued this permit.
Part IV Page 2 of 4 Pages

Permit No. NCS000562
21, Point Source Discharge of Stormwater
Any discernible, confined and discrete conveyance including, but not specifically limited to, any pipe,
ditch, channel, tunnel, conduit, well, or discrete fissure from which stormwater is or may be
discharged to waters of the state.
22. Representative Outfall Status
When it is established that the discharge of stormwater runoff from a single outfall is representative of the
discharges at multiple outfalls, the DWQ may grant representative outfall status. Representative outfall status
allows the permittee to perform analytical monitoring at a reduced number of outfalls.
23. SecondaU Containment
Spill containment for the contents of the single largest tank within the containment structure plus
sufficient freeboard to allow for the 25-year, 24-hour storm event.
24. Section 313 Water Priority Chemical
A chemical or chemical category which:
b. Is listed in 40 CFR 372.65 pursuant to Section 313 of
Reauthorization Act (SARA) of 1986, also titled the-17
to -Know Act of 1986;
C. Is present at or above threshold levels at a facility sul
requirements; and
d. Meets at least one of the following crit ri
25.
leIII of theL perfund Amendments and
11
ergency-Planning and Community Right-
SARA title I11, Section 313 reporting
i. Is listed in appendix D of 40 CFR.pa22 on Table II (organic priority pollutants), Table III
(certain metals, cyanides, and phenols).or Table IV (certain toxic pollutants and hazardous
substances);
ii. Is listed as a hazardpus,substanee,pursuant to section 311(b) (2)(A) of the CWA at 40 CFR
116.4; or ��
iii. Is a pollutant fop-,w"hich EPA has published acute or chronic water quality criteria.
Substantial physical dainaec,tooy-roperty, damage to the control facilities which causes them to
become inoperable, or substantial and permanent loss of natural resources which can reasonably be
expected to occur in the absence of a bypass. Severe property damage does not mean economic loss
caused by delays in production.
26. Significant Materials
Includes, but is not limited to: raw materials; fuels; materials such as solvents, detergents, and plastic
pellets; finished materials such as metallic products; raw materials used in food processing or
production; hazardous substances designated under section 101(14) of CERCLA; any chemical the
facility is required to report pursuant to section 313 of Title III of SARA; fertilizers; pesticides; and
waste products such as ashes, slag and sludge that have the potential to be released with stormwater
discharges.
27. Significant Spills
Includes, but is not limited to: releases of oil or hazardous substances in excess of reportable
quantities under section 311 of the Clean Water Act (Ref: 40 CFR 110.3and 40 CFR 117.3) or section
102 of CERCLA (Ref: 40 CFR 302.4).
28. Stormwater Discharge Outfall $DQ)
The point of departure of stormwater from a discernible, confined, or discrete conveyance, including
but not limited to, storm sewer pipes, drainage ditches, channels, spillways, or channelized collection
areas, from which stormwater flows directly or indirectly into waters of the State of North Carolina.
Part IV Page 3 of 4 Pages

Permit No. NCS000562
24. Stormwater Runoff
The flow of water which results from precipitation and which occurs immediately following rainfall
or as a result of snowmelt.
30, Stormwater Associated with Industrial Activity
The discharge from any point source which is used for collecting and conveying stormwater and
which is directly related to manufacturing, processing or raw material storage areas at an industrial
site. Facilities considered to be engaged in "industrial activities" include those activities defined in 40
CFR 122.26(b)(14). The term does not include discharges from facilities or activities excluded from
the NPDES program.
31
32.
91191
34.
Stormwater Pollution Prevention Plan
A comprehensive site -specific plan which details measures and practices to reduce Stormwater
pollution and is based on an evaluation of the pollution potential of the site.
Total Maximum -Daily Lad TMDLrq:Uali
TM DLs are written plans for attaining and maintaining watty-standards, in all seasons, for a
specific water body and pollutant. A list of approved TMDLs for the•siate of North Carolina can be
found athttD://uortal.ncdenr.ore/web/wu/ns/mt n/tmdl.
Toxic Pollutant
Any pollutant listed as toxic under Section
Vehicle Maintenance Activity
Vehicle rehabilitation, mecha
or airport deicing operations
Water Act.
ting, fueling, lubrication, vehicle cleaning operations,
35, Visible Sedimentation �/
Solid particulate matter, both mineral'and organic, that has been or is being transported by water, air,
gravity, or ice from its site of origin -which can be seen with the unaided eye.
36. 25-year. 24 hour Storm Event
The maximum 24-hour precipitation event expected to be equaled or exceeded, on the average, once
in 25 years.
Part IV Page 4 of 4 Pages

Wilson, Susan A
From: Pickle, Ken
Sent: Friday, November 02, 2012 4:06 PM
To: Wilson, Susan A; Fox, Tim
Subject: FW: Answers to Permit questions
Importance: High
FYI,
Horsehead
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, INC 27604
Phone: [phone]
Fax: [phone]
Email: ken. pickleCalncdenr.gov
Website: http://portal.ncdenr.org/web/wq/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Basilone Tim [ma [e-mail]]
Sent: Friday, November 02, 2012 4:00 PM
To: Pickle, Ken
Cc: forrest.westall me illen ineers.com; Staley Anthony
Subject: Answers to Permit questions
Importance: High
Ken,
Per our conversation yesterday, I am providing the following information in response to questions raised in your e-mail
concerning the subject draft stormwater permit:
Answer to F.I. The stormwater basin adjacent to the river is being provided primarily for energy dissipation. Its
inclusion in the stormwater discharge system is not required and is being provided to assure that all of the energy of the
discharged water is effectively transferred into the Broad River with no impact to the River Bank or the River
Bottom. The basin is constructed of compacted earth and isn't lined. A "fore -bay" area at the outlet of the site
stormwater pipe includes a large concrete dissipation structure and a transition area for flow to move into the main part
of the basin.
Answer to E.2. Stormwater from the containment areas will be monitored for relevant analytical parameters including
those to be monitored at the outfall and as listed in the NPDES stormwater permit. Procedures for managing the subject
water will be described in the SWPPP, and will include BMP's for minimizing contaminant levels from entering water
that is captured in containment. This plan will be completed prior to startup of the facility, and will include thresholds as
to whether the water will be placed into process or released to stormwater. Be advised that our line of thinking at this
point is that the rule is to place all water back to process, and the exception is to release the water to the stormwater
outfall provided analytical results warrant such.

Please advise me if you need any additional information. i look forward to receiving the draft permit from you
sometime next week.
Thanks Ken, have a nice weekend.
Tim
Timothy-R. Basilone
Vice President - Environmental Affairs
Horsehead Corporation
4955 Steubenville Pike
Suite 405
Pittsburgh, PA 15205
P 724.773.2223
F 412.788.4526
C 412.287.9871
TBasilone Horsehead.net

Wilson, Susan A
From:
Pickle, Ken
Sent:
Friday, November 09, 2012 11:44 AM
To:
Basilone Tim
Cc:
[e-mail]; Bennett, Bradley; Wilson, Susan A; fox, Tim
Subject:
in -progress draft permit and staff report
Hi Tim,
Here are the two documents we have been working on together. My next step is to send these out to public notice in a
local newspaper and the NC register, and to EPA Region IV. I'll be working on the public notice next week. Not a big
task.
I have made the changes indicated in our last correspondence with a couple of exceptions. Overall there are three
things I want to especially call your attention to, and solicit your comments.
1. See Part II page 9 of 11 for the new permit provision that allows de -coupling the sampling results from the
benchmark values and Tiered response actions for two years. I've written this up for eight data points
minimum plus Horsehead's summary report, presumably proposing revisions to the monitoring activities under
the permit conditions. Because this is an individual permit (not one of our General Permits), we have the
authority to revise the elements of any monitoring requirements without the additional administrative
procedures and delay involved in a complete permit re -issuance.
In my last note to you, I reported that we would be writing the permit for a shorter than usual duration, three
years instead of five years. As I got down to actually making the changes in other parts of the permit that were
time -dependent, it just seemed to me that the shorter duration was not necessary. So, I'm intending to go with
the standard 5-year duration on the permit. Two aspects of the permit were on my mind, plus an administrative
consideration:
o As far as my administrative consideration, we're all looking for ways to stretch ourselves to fit the
amount of work in our unit. That's not going to change in the foreseeable future. I'd rather the
Stormwater Permitting Unit address the renewal of this permit in five years, rather than three years.
o We agreed to a step-down, step-up provision in the sampling frequency that would allow semi-annual
sampling rather than quarterly sampling. I base the step-down provision on eight consecutive results
below benchmarks. Well, the provision hardly makes any sense if we stick with a 3-yr term for the
permit. (This may be moot, since the next item below speaks to the summary report that we will act on
in year 3.)
o You suggested a two year data gathering ("monitor -only") period without benchmarks and Tiers, and
DWQ agreed. So, we are already in agreement to review the monitoring provisions during the third year
and make the changes to the permit that seem prudent. It's easier administratively (no public notice,
for one example) for us to make the monitoring changes than it is to go through a permit renewal
process. Presently I don't see the need to go through a re -issuance with the extra administrative
requirements and comparatively longer time frame, when North Carolina rules allow us to make
monitoring changes essentially unilaterally.
I have revised the secondary containment language to be consistent with the standard language in all other
North Carolina stormwater permits. Please take a look at that in Part 11 Section A.

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

Wilson, Susan A
From:
Pickle, Ken
Sent:
Friday, November 09, 2012 11:44 AM
To:
Basilone Tim
Cc:
[e-mail]; Bennett, Bradley; Wilson, Susan A; Fox, Tim
Subject:
in -progress draft permit and staff report
Hi Tim,
Here are the two documents we have been working on together. My next step is to send these out to public notice in a
local newspaper and the NC register, and to EPA Region IV. I'll be working on the public notice next week.. Not a big
task.
I have made the changes indicated in our last correspondence with a couple of exceptions. overall there are three
things I want to especially call your attention to, and solicit your comments.
See Part 11 page 9 of 11 for the new permit provision that allows de -coupling the sampling results from the
benchmark values and Tiered response actions for two years. I've written this up for eight data points
minimum plus Horsehead's summary report, presumably proposing revisions to the monitoring activities under
the permit conditions. Because this is an individual permit (not one of our General Permits), we have the
authority to revise the elements of any monitoring requirements without the additional administrative
procedures and delay involved in a complete permit re -issuance.
2. In my last note to you, I reported that we would be writing the permit for a shorter than usual duration, three
years instead of five years. As I got down to actually making the changes in other parts of the permit that were
time -dependent, it. just.seemed-to-me-that-the-shorter-duration-was-not-necessary-So,-!'m-intending-to go with
the standard 5-year duration on the permit. Two aspects of the permit were on my mind, plus an administrative
consideration:
o As far as my administrative consideration, we're all looking for ways to stretch ourselves to fit the
amount of work in our unit. That's not going to change in the foreseeable future. I'd rather the
Stormwater Permitting Unit address the renewal of this permit in five years, rather than three years.
o We agreed to a step-down, step-up provision in the sampling frequency that would allow semi-annual
sampling rather than quarterly sampling. I base the step-down provision on eight consecutive results
below benchmarks. Well, the provision hardly makes any sense if we stick with a 3-yr term for the
permit. (This may be moot, since the next item below speaks to the summary report that we will act on
in year 3.)
o You suggested a two year data gathering ("monitor -only") period without benchmarks and Tiers, and
DWQ agreed. So, we are already in agreement to review the monitoring provisions during the third year
and make the changes to the permit that seem prudent. It's easier administratively (no public notice,
for one example) for us to make the monitoring changes than it is to go through a permit renewal
process. Presently I don't see the need to go through a re -issuance with the extra administrative
requirements and comparatively longer time frame, when North Carolina rules allow us to make
monitoring changes essentially unilaterally.
3. 1 have revised the secondary containment language to be consistent with the standard language in all other
North Carolina stormwater permits. Please take a look at that in Part 11 Section A.

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

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

Permit No. NCS000562
If the permittee's qualitative monitoring indicates that existing stormwater BMPs are
ineffective, or that significant stormwater contamination is present, the permittee shall
investigate potential causes, evaluate the feasibility of corrective actions, and implement
those corrective actions within 60 days, per the Qualitative Monitoring Response, below.
A written record of the permittee's investigation, evaluation, and response actions shall be
kept in the SPPP.
Qualitative Monitoring Response'
Qualitative monitoring is for the purposes of evaluating the effectiveness of the permittee's
implementation of the SPPP, and assessing new sources of stormwater pollution, and prompting the
permittee's response to pollution. If the permittee repeatedly fails to respond effectively to correct
problems identified by qualitative monitoring, or if they ischa ge causes or contributes to a water
quality standard violation, DWQ may, but is not limited to�� `-\ /j
• require that the permittee revise, increase, o
(analytical or qualitative) for the remainder
• require the permittee to install structural_s c
• require the permittee to implement
• require the permittee to perform u f
impacts on receiving waters; or
�
• require the permittee implgment sli
the monitoring frequency
controls;
control measures;
am monitoring to characterize
ons to qualify for a No Exposure Exclusion.
Part II Page 11 of 11

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

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

Permit No. NCS000562
4. Permit Modification, Revocation and Reissuance, or Termination
5. Permit Actions
6. Annual Administering and Compliance Monitoring Fee
Requirements
Section C: Operation and Maintenance of Pollution Controls
1. Proper Operation and Maintenance
2. Need to Halt or Reduce Not a Defense
3. Bypassing of Stormwater Control Facilities
Section D: Monitoring and Records
1.
Representative Sampling
2.
Recording Results
3.
Flow Measurements
4.
Test Procedures
5.
Representative Outfall
6.
Records Retention
7.
Inspection and Entry
Section E: Reporting
Requirements
1.
Discharge Monitoring Reports
2.
Submitting Reports
3.
Availability of Reports
4.
Non-Stormwater Discharges
5.
Planned Changes
6.
Anticipated Noncompliance
7.
Spills
8.
Bypass
9.
Twenty-four Hour Reporting
10.
Other Noncompliance
11.
Other information
PART IV DEFINITIONS
M

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

SECTION C: LOCATION MAP
Permit No. NCS000562
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Horsehead Corporation V
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NCS000562
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Map Scale 1:24,000
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Horsehead Corporation
Rutherford County Facility
Latitude: 350 11'36' N
Longftu&:8 10 50' 59" W
County: Ruffie&rd County
Receiving Stream: Broad River
Stream Class: C
Sub -basin: 03-08-02 Broad River Basin
Facility Location
Part I Page 2 of 2

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

Permit No. NCS000562
(e) Certification that the stormwater outfalls have been evaluated for the presence of
non-stormwater discharges. The permittee shall re -certify annually that the
stormwater outfalls have been evaluated for the presence of non-stormwater
discharges. The certification statement will be signed in accordance with the
requirements found in Part 1I1, Standard Conditions, Section B, Paragraph 3.
2. Stormwater Management Strategy. The Stormwater Management Strategy shall
contain a narrative description of the materials management practices employed which
control or minimize the stormwater exposure of significant materials, including
structural and nonstructural measures. The Stormwater Management Strategy, at a
minimum, shall incorporate the following:
(a) Feasibility Study. An annual review by site management of the technical and
economic feasibility of changing the methods of operations and/or storage practices
to eliminate or reduce exposure of materials and processes to rainfall and run-on
flows. Wherever practical, the permittee shall prevent exposure of storage areas,
material handling operations, manufacturing, and fueling operations. In areas
where elimination of exposure and/or prevention of run-on contact are not
practical, the Feasibility Study shall document the basis for the management
decision that such controls are not feasible.
(b) Secondary Containment Requirements and Records. Secondary containment is
required for: bulk storage of liquid materials including -petroleum products; storage
-in any amount of Section 313 of Title III of the Superfund Amendments and
Reauthorization Act (SARA) water priority chemicals; and storage in an_y amount of
hazardous substances, in order to prevent leaks and spills from contaminating
stormwater runoff. A table or summary of all such tanks and stored materials and
their associated secondary containment areas shall be maintained. If the secondary
containment devices are connected to stormwater conveyance systems, the
connection shall be controlled by manually activated valves or other similar devices,
which shall be secured closed with a locking mechanism. Prior to release into the
stormwaters conveyance system, any stormwater that accumulates in containment
areas shall be at a minimum visually observed for color, foam, outfall staining,
visible sheens, and dry weather flow. Accumulated stormwater may be released if
found to be uncontaminated by any material. Records documenting the individual
making the observation or analyses, the visual and analytical description of the
accumulated stormwaters, and the dates and times of the releases shall be kept for a
period of five (S) years.
(c) BMP Summary. A listing of site structural and non-structural Best Management
Practices (BMPs) shall be provided. The installation and implementation of BMPs
shall be based on the assessment of the potential for sources to contribute
significant quantities of pollutants to stormwater discharges and on data collected
through monitoring of stormwater discharges. The BMP Summary shall include a
written record of the specific rationale for installation and implementation of the
Part 11 Page 2 of 11

Permit No. NCS000562
selected site BMPs. The BMP Summary shall be reviewed by site management and
updated annually.
3. Spill Prevention and Response Procedures. The Spill Prevention and Response
Procedures (SPRP) shall incorporate an assessment of potential pollutant sources based
on a materials inventory of the facility. The SPRP shall address spill response and
failure mode preparations and responses. Site management shall identify facility
personnel responsible for implementing the SPRP in a written list incorporated into the
SPRP along with dated signatures by each individual acknowledging his or her
responsibilities under the SPRP. A responsible person shall be on -site at all times
during facility operations that have the potential to contaminate stormwater runoff
through spills or exposure of materials associated with the facility operations. The
SPRP must be site stormwater specific. Therefore, an oil Spill Prevention Control and
Countermeasure plan (SPCC) may be a component of the SPRP, but may not be
sufficient to completely address the stormwater aspects of the SPRP. The common
elements of the SPCC with the SPRP may be incorporated by reference into the SPRP.
4. Preventative Maintenance and Good Housekeeping Program. A preventative
maintenance and good housekeeping program shall be developed and implemented.
The program shall address all stormwater control systems, stormwater discharge
outfalls, all on -site and adjacent surface waters and wetlands, industrial activity areas
(including material storage areas, material handling areas, disposal areas, process
areas, loading and unloading areas, and haul roads), all drainage features and
structures, and structural BMPs. The program shall establish schedules of inspections,
maintenance, and housekeeping activities of stormwater control systems, as well as
facility equipment, facility areas, and facility systems that present a potential for
stormwater exposure or stormwater pollution where not already addressed under
another element of the SPPP. Inspection of material handling areas and regular
cleaning schedules of these areas shall be incorporated into the program. Timely
compliance with the established schedules for inspections, maintenance, and
housekeeping shall be recorded and maintained in the SPPP.
5. Facility Inspections. Inspections of the facility and all stormwater conveyance and
control systems shall occur as part of the Preventative Maintenance and Good
Housekeeping Program at a minimum on a semi-annual schedule, once during the first
half of the year (January to June), and once during the second half (July to December),
with at least 60 days separating inspection dates (unless performed more frequently
than semi-annually). These facility inspections are different from, and in addition to,
the stormwater discharge characteristic monitoring at the outfall required in Part I1
Sections B and C of this permit.
6. Employee Training. Training programs shall be developed and training provided at a
minimum on an annual basis for facility personnel with responsibilities for: spill
response and cleanup, preventative maintenance activities, and for any of the facility's
operations that have the potential to contaminate stormwater runoff. The facility
Part it Page 3 of 11

Permit No. NCS000562
personnel responsible for implementing the training shall be identified, and their
annual training shall be documented by the signature of each employee trained.
7. Responsible Party. Site management shall identify, and the SPPP shall document, a
specific position or positions responsible for the overall coordination, development,
implementation, and revision of the SPPP. Responsibilities for all components of the
SPPP shall be documented and position assignments provided.
8. SPPP Amendment and Annual Update. The permittee shall amend the SPPP
whenever there is a change in design, construction, operation, site drainage,
maintenance, or configuration of the physical features which may have a significant
impact on the potential for the discharge of pollutants to surface waters. All aspects of
the SPPP shall be reviewed and updated on an annual basis. The annual update
shall include all the aspects required immediately above in items 1 -7; and a review and
comparison of monitoring analytical data to benchmark values over the pastyear,
including a discussion about Tiered Response status. The permittee shall use the
Division's Annual Summary Data Monitoring Report form, available from the
Stormwater Permitting Unit's website here:
http:/Iportal.ncdenr.org/­weblwq /ws/su/npdessw).
The Director may notify the permittee when the SPPP does not meet one or more of the
minimum requirements of the permit. Within 30 days of such notice, the permittee
shall submit a time schedule to the Director for modifying the SPPP to meet minimum
requirements. The permittee shall provide certification in writing (in accordance with
Part I11, Standard Conditions, Section B, Paragraph 3) to the Director that the changes
have been made.
9. SPPP Implementation. The permittee shall implement the Stormwater Pollution
Prevention Plan and all appropriate BMPs to prevent contaminants from entering
surface waters via stormwater. Among other actions identified herein, implementation
of the SPPP shall include the documentation of: all monitoring, measurements,
inspections, maintenance activities, and training provided to employees, including the
log of the sampling data and of actions taken to implement BMPs associated with the
industrial activities. Such documentation shall be kept on -site for a period of five (5)
years and made available to the Director or the Director's authorized representative
immediately upon request.
Part I I Page 4 of ll

Permit No. NCS000562
SECTION B: ANALYTICAL MONITORING REQUIREMENTS
Analytical monitoring of stormwater discharges shall be performed as specified in Table 1.
All analytical monitoring shall be performed during a measureable storm event at each
stormwater discharge outfall (SDO). Only SDOs discharging stormwater associated with
industrial activity must be sampled (See Definitions).
A measurable storm event is a storm event that results in an actual discharge from the
permitted site outfall. The previous measurable storm event must have been at least 72
hours prior. See Definitions
Table 1 Analytical Monitoring Requirements
Discharge
Characteristics
Units
Measurement
Frequencyl
Sample
Type2
Sample
Location3
Total Suspended Solids
m L
quarterly
Grab
SDO
Total Nitrogen
m L
quarterly
Grab
SDO
Total Phosphorus
m L
quarterly
Grab
SDO
Zinc, Total Recoverable
m L
quarterly
Grab
SDO
Lead, Total Recoverable
m L
quarterly
Grab
SDO
Cadmium, Total Recoverable
m L
quarterly
Grab
SDO
Chlorides
m L
quarterly
Grab
SDO
Non -polar Oil & Grease/TPH
EPA Method 1664 SGT-HEM
mg/L
quarterly
Grab
SDO
H
standard
quarterly
Grab
SDO
Total Rainfall4
inches
quarterly
I Rain Gauge
1-
Footnotes:
1 Measurement Frequency: Four times per year during a measureable storm event. The permittee may
petition DWQ to reduce the analytical monitoring frequency to twice peryear after eight consecutive quarterly
monitoring results all within benchmark values. Subsequently, two consecutive benchmark exceedances for any
parameter re -institute quarterly monitoring for all parameters.
2 Grab samples shall be collected within the first 30 minutes of discharge.
3 Sample Location: Samples shall be collected at each stormwater discharge outfall (00).
4 For each sampled measureable storm event, the total precipitation must be recorded. An on -site rain gauge
reading must be recorded.
The permittee shall complete the analytical samplings in accordance with the schedule
specified below in Table 2, unless adverse weather conditions prevent sample collection
(see Adverse Weather in Definitions). A minimum of 30 days must separate successive
sample events. Inability to sample because of adverse weather conditions must be
documented in the SPPP and recorded on the DMR. The permittee must report the results
from each sample taken within the monitoring period (see Part III, Section E).
Part II Page 5 of 11

Permit No. NCS000562
Table 2 Monitoring Schedule
Monitoring period1,2
Sample Number
Start
End
Year 1 - Period 1
1
April 1, 2013
June 30, 2013
Year 1- Period 2
2
July 1, 2013
September 30, 2013
Year 1- Period 3
3
October 1, 2013
December 31, 2013
Year 1- Period 4
4
January 1, 2014
March 31, 2014
Year 2 - Period 1
5
April 1, 2014
June 30, 2014
Year 2 - Period 2
6
July 1, 2014
September 30, 2014
Year 2 - Period 3
7
October 1, 2014
December 31, 2014
Year 2 - Period 4
8
January 1, 2015
March 31, 2015
Year 3 - Period 1
9
April 1, 2015
June 30, 2015
Year 3 - Period 2
10
July 1, 2015
September 30, 2015
Year 3 - Period 3
11
October 1, 2015
December 31, 2015
Year 3 - Period 4
12
January 1, 2016
March 31, 2016
Year 4 - Period 1
13
April 1, 2016
June 30, 2016
Year 4 - Period 2
14
July 1, 2016
September 30, 2016
Year 4 - Period 3
15
October 1, 2016
December 31, 2016
Year 4 - Period 4
16
January 1, 2017
March 31, 2017
Year 5 - Period 1
17
April 1, 2017
June 30, 2017
Year 5 - Period 2
18
July 1, 2017
September 31, 2017
Year 5 - Period 3
19
October 1, 2017
December 31, 2017
Year 5 - Period 4
20
January 1, 2018
March 31, 2018
Footnotes:
1 Maintain quarterly monitoring until either another permit is issued for this facility or until this permit
is revoked or rescinded. The permittee must submit an application for renewal of coverage before the
submittal deadline (180 days before expiration) to be considered for renewed coverage under the
permit. The permittee must continue analytical monitoring throughout the permit renewal process,
even if a renewal permit is not issued until after expiration of this permit.
2 If no discharge occurs during the sampling period, the permittee must submit a monitoring report
indicating "No Flow" within 30 days of the end of the sampling period. For the first term of this
permit, the new facility start-up date is uncertain. Permittee need not sample for the listed
monitoring periods until the facility comes into operation. Accordingly, the "No Flow" monitoring
report is not required during the time before the facility comes into operation.
Failure to monitor quarterly per the permit terms may result in the Division requiring
monthly monitoring for all parameters for a specified time period. "No discharge" from
an outfall, or inability to collect a sample because of adverse weather conditions during a
monitoring period does not constitute failure to monitor, as long as it is properly reported.
The permittee shall compare monitoring results to the benchmark values in Table 3. The
benchmark values in Table 3 are not permit limits, but should be used as management
guidelines for the permittee's responsive implementation of the Stormwater Pollution
Prevention Plan (SPPP).
Part I I Page 6 of 11

Permit No. NCS000562
Table 3 Benchmark Values for Analytical Monitoring
Discharge Characteristics
Units
Benchmarkt
Total Suspended Solids
mg/L
100
Total Nitrogen
mg/L
30
Total Phosphorus
mg/L
2
Zinc, Total Recoverable
mg/L
0.067
Lead, Total Recoverable
mg/L
0.03
Cadmium, Total Recoverable
mg/L
0.001
Chlorides
mg/L
860
Non -polar Oil & Grease/TPH
[EPA Method 1664 (SGT-HEM)]
mg/L
15
pH
standard
6-9
Footnote
1. Analytical results must not be reported via any of the notations, "BDL. ND, BRL, <MDL, <PQL,
non -detect" or any similar non -quantitative notation. Instead, analytical results below method or
reporting limits must be reported on the DMR in the format, "<XX", where XX is the specific numerical
value descriptive of the method or reporting limit.
Summary Report Requirement
During the first term of this permit, and for the period beginning with the on -site initiation of
industrial activity and continuing for two years nominal duration thereafter, Horsehead shall
sample quarterly as provided in Table 2, shall tabulate and interpret the collected data
(minimum eight data points). Within 30 months of start-up Horsehead shall present DWQ with
a summary report that uses the collected data to support any proposed alternative monitoring,
benchmark, and response action scheme for the purpose of maintaining site management
awareness and responsiveness to potential pollutant discharges from the site. For the first
term of this permit, benchmark exceedances will not activate DWQ's standard Tiered Response
actions which are shown below for reference only.
The summary report shall specifically consider and interpret the collected data with respect
to the benchmarks identified in this permit, and shall identify the Tiered Response action
status that would have been triggered by the data collected.
While DWQ is considering Horsehead's summary report and determining what revisions to the
permit, if any, may be reasonable and protective, and continuing on for the remainder of the
permit term until any such changes in the permit requirements may be established by DWQ,
Horsehead shall be subject to the full provisions of sampling, comparison to the benchmarks,
and reporting contained in Part 11 Section B. All other provisions of the permit remain in effect
from the effective date of the permit until expiration. _
Part 11 Page 7 of 11

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

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

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

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

Permit No. NCS000562
PART III STANDARD CONDITIONS FOR NPDES STORMWATER INDIVIDUAL PERMITS
SECTION A: COMPLIANCE AND LIABILITY
1. Compliance Schedule
The permittee shall comply with Limitations and Controls specified for stormwater discharges in
accordance with the following schedule:
Existing Facilities already operating but applying for permit coverage for the first time; The
Stormwater Pollution Prevention Plan shall be developed and implemented within 12 months of the
effective date of the initial permit and updated thereafter on an annual basis. Secondary containment,
as specified in Part 11, Section A, Paragraph 2(b) of this permit, shall be accomplished within 12
months of the effective date of the initial permit issuance.
New Facilities applying for coverage for the first time: The Stormwater Pollution Prevention Plan
shall be developed and implemented prior to the beginning of discharges from the operation of the
industrial activity and be updated thereafter on an annual basis. Secondary containment, as specified
in Part II, Section A, Paragraph 2(b) of this permit shall be accomplished prior to the beginning of
discharges from the operation of the industrial activity.
Existing facilities previously permitted and applying for renewal: All requirements, conditions,
limitations, and controls contained in this permit (except revised SPPP elements in a permit renewal)
shall become effective immediately upon issuance of this permit. New elements of the Stormwater
Pollution Prevention Plan for this permit renewal shall be developed and implemented within 6
months of the effective date of this permit and updated thereafter on an annual basis. Secondary
containment, as specified in Part III, Paragraph 2(b) of this permit shall be accomplished prior to the
beginning of discharges from the operation of the industrial activity.
2. Duty to Comply
The permittee must comply with all conditions of this permit. Any permit noncompliance constitutes
a violation of the Clean Water Act (CWA) and is grounds for enforcement action; for permit
termination, revocation and reissuance, or modification; or denial of a permit upon renewal
application [40 CFR 122.411.
a. The permittee shall comply with standards or prohibitions established under section 307(a) of
the CWA for toxic pollutants within the time provided in the regulations that establish these
standards or prohibitions, even if the permit has not yet been modified to incorporate the
requirement.
b. The CWA provides that any person who violates section[s] 301, 302, 306, 307, 308, 318 or 405 of
the Act, or any permit condition or limitation implementing any such sections in a permit issued
under section 402, or any requirement imposed in a pretreatment program approved under
sections 402(a)(3) or 402(h)(8) of the Act, is subject to a civil penalty not to exceed $37,500 per
day for each violation. [33 USC 1319(d) and 40 CFR 122.41(a)(2)]
c. The CWA provides that any person who negligently violates sections 301, 302, 306, 307, 308,
318, or 405 of the Act, or any condition or limitation implementing any of such sections in a
permit issued under section 402 of the Act, or any requirement imposed in a pretreatment
program approved under section 402(a)(3) or 402(b)(8) of the Act, is subject to criminal
penalties of $2,500 to $25,000 per day of violation, or imprisonment of not more than 1 year, or
both. In the case of a second or subsequent conviction for a negligent violation, a person shall be
Part Il l Page 1 of 9

Permit No. NCS000S62
subject to criminal penalties of not more than $50,000 per day of violation, or by imprisonment of
not more than 2 years, or both. [33 USC 1319(c)(1) and 40 CFR 122.41(a)(2)]
d. Any person who knowingly violates such sections, or such conditions or limitations is subject to
criminal penalties of $5,000 to $50,000 per day of violation, or imprisonment for not more than 3
years, or both. In the case of a second or subsequent conviction for a knowing violation, a person
shall be subject to criminal penalties of not more than $100,000 per day of violation, or
imprisonment of not more than 6 years, or both. [33 USC 1319(c)(2) and 40 CFR 122.41(a)(2)]
e. Any person who knowingly violates section 301, 302, 303, 306, 307, 308, 318 or 405 of the Act, or
any permit condition or limitation implementing any of such sections in a permit issued under
section 402 of the Act, and who knows at that time that he thereby places another person in
imminent danger of death or serious bodily injury, shall, upon conviction, be subject to a fine of
not more than $250,000 or imprisonment of not more than 15 years, or both. In the case of a
second or subsequent conviction for a knowing endangerment violation, a person shall be subject
to a fine of not more than $500,000 or by imprisonment of not more than 30 years, or both. An
organization, as defined in section 309(c)(3)(B)(iii) of the CWA, shall, upon conviction of
violating the imminent danger provision, be subject to a fine of not more than $1,000,000 and can
be fined up to $2,000,000 for second or subsequent convictions. [40 CFR 122.41(a)(2)]
f. Under state law, a civil penalty of not more than $25,000 per violation may be assessed against
any person who violates or fails to act in accordance with the terms, conditions, or requirements
of a permit. [North Carolina General Statutes § 143-215.6A]
g. Any person may be assessed an administrative penalty by the Administrator for violating section
301, 302, 306, 307, 308, 318 or 405 of this Act, or any permit condition or limitation
implementing any of such sections in a permit issued under section 402 of this Act.
Administrative penalties for Class I violations are not to exceed $16,000 per violation, with the
maximum amount of any Class 1 penalty assessed not to exceed $37,500. Penalties for Class I I
violations are not to exceed $16,000 per day for each day during which the violation continues,
with the maximum amount of any Class 11 penalty not to exceed $177,500. [33 USC 1319(g)(2)
and 40 CFR 122.41(a)(3)]
3. Duty to Mitigate
The permittee shall take all reasonable steps to minimize or prevent any discharge in violation of this
permit which has a reasonable likelihood of adversely affecting human health or the environment [40
CFR 122.41(d)].
4. Civil and Criminal Liability
Except as provided in Part 111, Section C of this permit regarding bypassing of stormwater control
facilities, nothing in this permit shall be construed to relieve the permittee from any responsibilities,
liabilities, or penalties for noncompliance pursuant to NCGS 143-215.3,143-215.6, or Section 309 of the
Federal Act, 33 USC 1319. Furthermore, the permittee is responsible for consequential damages, such
as fish kills, even though the responsibility for effective compliance may be temporarily suspended.
S. Oil and Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the
permittee from any responsibilities, liabilities, or penalties to which the permittee is or may be
subject to under NCGS 143-215.75 et seq. or Section 311 of the Federal Act, 33 USC 1321.
6. Property Rights
The issuance of this permit does not convey any property rights in either real or personal property, or
any exclusive privileges, nor does it authorize any injury to private property or any invasion of
Partill Page 2 of9

Permit No. NCS000562
personal rights, nor any infringement of Federal, State or local laws or regulations [40 CFR
122.41(g)].
Severi3bility
The provisions of this permit are severable, and if any provision of this permit, or the application of
any provision of this permit to any circumstances, is held invalid, the application of such provision to
other circumstances, and the remainder of this permit, shall not be affected thereby [NCGS 15013-23].
8. Duty to Provide Information
The permittee shall furnish to the Permit Issuing Authority, within a reasonable time, any information
which the Permit Issuing Authority may request to determine whether cause exists for modifying,
revoking and reissuing, or terminating the permit issued pursuant to this permit or to determine
compliance with this permit. The permittee shall also furnish to the Permit Issuing Authority upon
request, copies of records required to be kept by this permit [40 CFR 122.41(h)].
9. Penalties for Tampering
The Clean Water Act provides that any person who falsifies, tampers with, or knowingly renders
inaccurate, any monitoring device or method required to be maintained under this permit shall, upon
conviction, be punished by a fine of not more than $10,000 per violation, or by imprisonment for not
more than two years per violation, or by both. If a conviction of a person is for a violation committed
after a first conviction of such person under this paragraph, punishment is a fine of not more than
$20,000 per day of violation, or by imprisonment of not more than 4 years, or both [40 CFR 122.41].
10. Penalties for F 1 if
The Clean Water Act provides that any person who knowingly makes any false statement,
representation, or certification in any record or other document submitted or required to be
maintained under this permit, including monitoring reports or reports of compliance or
noncompliance shall, upon conviction, be punished by a fine of not more than $10,000 per violation, or
by imprisonment for not more than two years per violation, or by both [40 CFR 122.41].
11. Onshore or Offshore Construction
This permit does not authorize or approve the construction of any onshore or offshore physical
structures or facilities or the undertaking of any work in any navigable waters.
12. Duty to Reapply-
If the permittee wishes to continue an activity regulated by this permit after the expiration date of
this permit, the permittee must apply for and obtain a new permit [40 CFR 122.41(b)].
SECTION B: GENERAL CONDITIONS
Permit Expiration
The permittee is not authorized to discharge after the expiration date. In order to receive automatic
authorization to discharge beyond the expiration date, the permittee shall submit forms and fees as
are required by the agency authorized to issue permits no later than 180 days prior to the
expiration date, unless permission for a later date has been granted by the Director. (The Director
shall not grant permission for applications to be submitted later than the expiration date of the
existing permit.) [40 CFR 122.21(d)]. Any permittee that has not requested renewal at least 180 days
prior to expiration, or any permittee that does not have a permit after the expiration and has not
requested renewal at least 180 days prior to expiration, will be subjected to enforcement procedures
as provided in NCGS §143-215.36 and 33 USC 1251 et. seq.
Part Ill Page 3 of 9

Permit No. NCSOOOS62
2. Transfers
This permit is not transferable to any person without prior written notice to and approval from the
Director in accordance with 40 CFR 122.61. The Director may condition approval in accordance with
NCGS 143-215.1, in particular NCGS 143-215.1(b)(4)b.2., and may require modification or revocation
and reissuance of the permit, or a minor modification, to identify the new permittee and incorporate
such other requirements as may be necessary under the CWA [40 CFR 122.41(1)(3), 122,61] or state
statute. The Permittee is required to notify the Division in writing in the event the permitted
Facility is sold or closed.
3. $jgnatory Requirements
All applications, reports, or information submitted to the Permitting issuing Authority shall be signed
and certified [40 CFR 122.41(k)].
a. All permit applications shall he signed as follows:
(1) For a corporation: by a responsible corporate officer. For the purpose of this Section, a
responsible corporate officer means: (a) a president, secretary, treasurer or vice president of
the corporation in charge of a principal business function, or any other person who performs
similar policy or decision making functions for the corporation, or (b) the manager of one or
more manufacturing, production, or operating facilities, provided, the manager is authorized
to make management decisions which govern the operation of the regulated facility including
having the explicit or implicit duty of making major capital investment recommendations,
and initiating and directing other comprehensive measures to assure long term
environmental compliance with environmental laws and regulations; the manager can
ensure that the necessary systems are established or actions taken to gather complete and
accurate information for permit application requirements; and where authority to sign
documents has been assigned or delegated to the manager in accordance with corporate
procedures.
(2) For a partnership or sole proprietorship: by a general partner or the proprietor, respectively;
or
(3) For a municipality, State, Federal, or other public agency: by either a principal executive
officer or ranking elected official [40 CFR 122.22].
b. All reports required by the permit and other information requested by the Permit Issuing
Authority shall be signed by a person described in paragraph a. above or by a duly authorized
representative of that person. A person is a duly authorized representative only if:
(1) The authorization is made in writing by a person described above;
(2) The authorization specified either an individual or a position having responsibility for the
overall operation of the regulated facility or activity, such as the position of plant manager,
operator of a well or well field, superintendent, a position of equivalent responsibility, or an
individual or position having overall responsibility for environmental matters for the company.
(A duly authorized representative may thus be either a named individual or any individual
occupying a named position.); and
(3) The written authorization is submitted to the Permit Issuing Authority [40 CFR 122.221
c. Changes to authorization: If an authorization under paragraph (b) of this section is no longer
accurate because a different individual or position has responsibility for the overall operation of
the facility, a new authorization satisfying the requirements of paragraph (b) of this section must
be submitted to the Director prior to or together with any reports, information, or applications to
be signed by an authorized representative [40 CFR 122.22]
Part III Page 4 of 9

Permit No. NCS000562
d. Certification. Any person signing a document under paragraphs a. or b. of this section shall make
the following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION WILL
BE ACCEPTED:
7 certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properlygather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible forgathering the information,
the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. l
am aware that there are significant penalties for submitting false information, including the
possibility offrnes and imprisonmentfor knowing violations. "
4. Permit Modification, Revocation and Reissuance, or Termination
The issuance of this permit does not prohibit the Permit Issuing Authority from reopening and
modifying the permit, revoking and reissuing the permit, or terminating the permit as allowed by the
laws, rules, and regulations contained in Title 40, Code of Federal Regulations, Parts 122 and 123;
Title 15A of the North Carolina Administrative Code, Subchapter 2H .0100; and North Carolina
General Statute 143-215.1 et at.
5. Permit Actions
The permit may be modified, revoked and reissued, or terminated for cause. The notification of
planned changes or anticipated noncompliance does not stay any permit condition [40 CFR
122.41(f)].
6. Annual Administering and Compliance Monitoring _Fee Requirements
The permittee must pay the administering and compliance monitoring fee within 30 (thirty) days
after being billed by the Division. Failure to pay the fee in timely manner in accordance with 15A
NCAC 2H .0105(b)(2) may cause this Division to initiate action to revoke the permit
SECTION C: OPERATION AND MAINTENANCE OF POLLUTION CONTROLS
1. Proper Operation and Maintenance
The permittee shall at all times properly operate and maintain all facilities and systems of treatment
and control (and related appurtenances) which are installed or used by the permittee to achieve
compliance with the conditions of this permit. Proper operation and maintenance also includes
adequate laboratory controls and appropriate quality assurance procedures. This provision requires
the operation of back-up or auxiliary facilities or similar systems which are installed by a permittee
only when the operation is necessary to achieve compliance with the conditions of this permit [40
CFR 122.41(e)].
Need to Halt or Reduce Not a Uefense
It shall not be a defense for a permittee in an enforcement action that it would have been necessary to
halt or reduce the permitted activity in order to maintain compliance with the condition of this permit
[40 CFR 122.41(c)].
3. Bypassing of Stormwater Control Facilities
Bypass is prohibited and the Director may take enforcement action against a permittee for bypass
unless:
a. Bypass was unavoidable to prevent loss of life, personal injury or severe property damage; and
b. There were no feasible alternatives to the bypass, such as the use of auxiliary control facilities,
retention of stormwater or maintenance during normal periods of equipment downtime or dry
weather. This condition is not satisfied if adequate backup controls should have been installed in
Part III Page 5 of 9

Permit No. NCS000562
the exercise of reasonable engineering judgment to prevent a bypass which occurred during
normal periods of equipment downtime or preventive maintenance; and
c. The permittee submitted notices as required under, Part III, Section E of this permit.
If the Director determines that it will meet the three conditions listed above, the Director may
approve an anticipated bypass after considering its adverse effects.
SECTION D: MONITORING AND RECORDS
Representative Sampling
Samples collected and measurements taken, as required herein, shall be characteristic of the volume
and nature of the permitted discharge. Analytical sampling shall be performed during a measureable
storm event. Samples shall be taken on a day and time that is characteristic of the discharge. All
samples shall be taken before the discharge joins or is diluted by any other waste stream, body of
water, or substance. Monitoring points as specified in this permit shall not be changed without
notification to and approval of the Permit Issuing Authority [40 CFR 122.41(j)].
Recording Results
For each measurement or sample taken pursuant to the requirements of this permit, the permittee
shall record the following information [40 CFR 122.41]:
a. The date, exact place, and time of sampling or measurements;
b. The individual(s) who performed the sampling or measurements;
c. The date(s) analyses were performed;
d. The individual(s) who performed the analyses;
e. The analytical techniques or methods used; and
f. The results of such analyses.
3. Flow Measurements
Where required, appropriate now measurement devices and methods consistent with accepted
scientific practices shall be selected and used to ensure the accuracy and reliability of measurements
of the volume of monitored discharges.
4. Test Procedures
Test procedures for the analysis of pollutants shall conform to the EMC regulations published
pursuant to NCGS 143-215.63 et seq, the Water and Air Quality Reporting Acts, and to regulations
published pursuant to Section 304(g), 33 USC 1314, of the Federal Water Pollution Control Act, as
Amended, and Regulation 40 CFR 136..
To meet the intent of the monitoring required by this permit, all test procedures must produce
minimum detection and reporting levels and all data generated must be reported down to the
minimum detection or lower reporting level of the procedure. If no approved methods are
determined capable of achieving minimum detection and reporting levels below permit discharge
requirements, then the most sensitive (method with the lowest possible detection and reporting
level) approved method must be used.
Representative Outfall
If a facility has multiple discharge locations with substantially identical stormwater discharges that
are required to be sampled, the permittee may petition the Director for representative outfall status.
If it is established that the stormwater discharges are substantially identical and the permittee is
granted representative outfall status, then sampling requirements may be performed at a reduced
number of outfalls.
Part III Page 6 of 9

Permit No. NCS000562
6. Records Retention
Visual monitoring shall be documented and records maintained at the facility along with the
Stormwater Pollution Prevention Plan. Copies of analytical monitoring results shall also be
maintained on -site. The permittee shall retain records of all monitoring information, including
o all calibration and maintenance records,
o all original strip chart recordings for continuous monitoring instrumentation,
o copies of all reports required by this permit,
o copies of all data used to complete the application for this permit
These records or copies shall be maintained for a period of at least 5 years from the date of the
sample, measurement, report or application. This period may be extended by request of the Director
at any time [40 CFR 122.41].
Inspection and Entry
The permittee shall allow the Director, or an authorized representative (including an authorized
contractor acting as a representative of the Director), or in the case of a facility which discharges
through a municipal separate storm sewer system, an authorized representative of a municipal
operator or the separate storm sewer system receiving the discharge, upon the presentation of
credentials and other documents as may be required by law, to;
a. Enter upon the permittee's premises where a regulated facility or activity is located or conducted,
or where records must be kept under the conditions of this permit;
b. Have access to and copy, at reasonable times, any records that must be kept under the conditions
of this permit;
c. Inspect at reasonable times any facilities, equipment (including monitoring and control
equipment), practices, or operations regulated or required under this permit; and
d. Sample or monitor at reasonable times, for the purposes of assuring permit compliance or as
otherwise authorized by the Clean Water Act, any substances or parameters at any location [40
CFR 122.41(i)].
SECTION E: REPORTING REQUIREMENTS
Discharge Monitoring R
Samples analyzed in accordance with the terms of this permit shall be submitted to the Division on
Discharge Monitoring Report (DMR) forms provided by the Director. DMR forms are available on the
Division's website (httR//aortal.ncdenr.org/web/wq/ws/emu/n dp essw). Submittals shall be
delivered to the Division no later than 30 days from the date the facility receives the sampling
results from the laboratory.
When no discharge has occurred from the facility during the report period, the permittee is required
to submit a discharge monitoring report, within 30 days of the end of the specified sampling period,
giving all required information and indicating "NO FLOW" as per NCAC T15A 0213.0506.
If the permittee monitors any pollutant more frequently than required by this permit using test
procedures approved under 40 CFR Part 136 and at a sampling location specified in this permit or
other appropriate instrument governing the discharge, the results of such monitoring shall be
included in the data submitted on the DMR.
The permittee shall record the required qualitative monitoring observations on the SDO Qualitative
Monitoring Report form provided by the Division and shall retain the completed forms on site.
Qualitative monitoring results should not be submitted to the Division, except upon DWQ's specific
requirement to do so. Qualitative Monitoring Report forms are available at the website above.
Part III Page 7 of 9

Permit No. NCS000562
Submitting Reports
Two signed copies of Discharge Monitoring Reports (DMRs) shall be submitted to:
Central Files
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
3. Availability of Report
Except for data determined to be confidential under NCGS 143-215.3(a)(2) or Section 308 of the
Federal Act, 33 USC 1318, all reports prepared in accordance with the terms shall be available for
public inspection at the offices of the Division. As required by the Act, analytical data shall not be
considered confidential. Knowingly making any false statement on any such report may result in the
imposition of criminal penalties as provided for in NCGS 143-215.613 or in Section 309 of the Federal
Act
4. Non-Stormwater Discharges
If the storm event monitored in accordance with this permit coincides with a non-stormwater
discharge, the permittee shall separately monitor all parameters as required under all other
applicable discharge permits and provide this information with the stormwater discharge monitoring
report.
5. Planned Changes
The permittee shall give notice to the Director as soon as possible of any planned changes at the
permitted facility which could significantly alter the nature or quantity of pollutants discharged [40
CFR 122.41(1)]. This notification requirement includes pollutants which are not specifically listed in
the permit or subject to notification requirements under 40 CFR Part 122.42 (a).
6. Anticipated Noncompliance
The permittee shall give advance notice to the Director of any planned changes at the permitted
facility which may result in noncompliance with the permit [40 CFR 122.41(1)(2)].
7. ills
The permittee shall report to the local DWQ Regional Office, within 24 hours, all significant spills as
defined in Part IV of this permit. Additionally, the permittee shall report spills including: any oil spill
of 25 gallons or more, any spill regardless of amount that causes a sheen on surface waters, any oil
spill regardless of amount occurring within 100 feet of surface waters, and any oil spill less than 25
gallons that cannot he cleaned up within 24 hours.
8. Bypass
Notice [40 CFR 122.41(m)(3)1:
a. Anticipated bypass. If the permittee knows in advance of the need for a bypass, it shall submit
prior notice, if possible at least ten days before the date of the bypass; including an evaluation of
the anticipated quality and affect of the bypass .
b. Unanticipated bypass. The permittee shall submit notice within 24 hours of becoming aware of
an unanticipated bypass.
Twenty-four Hour Reporting
a. The permittee shall report to the central office or the appropriate regional office any
noncompliance which may endanger health or the environment. Any information shall be
provided orally within 24 hours from the time the permittee became aware of the circumstances.
A written submission shall also be provided within 5 days of the time the permittee becomes
aware of the circumstances.
Part Il l Page 8 of 9

Permit No. NCS000562
The written submission shall contain a description of the noncompliance, and its causes, the
period of noncompliance, including exact dates and times, and if the noncompliance has not
been corrected, the anticipated time compliance is expected to continue; and steps taken or
planned to reduce, eliminate, and prevent reoccurrence of the noncompliance [40 CFR
122.41(1)(6)].
b. The Director may waive the written report on a case -by -case basis for reports under this section
if the oral report has been received within 24 hours.
c. Occurrences outside normal business hours may also be reported to the Division's Emergency
Response personnel at [phone], [phone] or [phone].
10. Other Noncompliance
The permittee shall report all instances of noncompliance not reported under 24 hour reporting at
the time monitoring reports are submitted (40 CFR 122.41(l)(7)].
11. Other Information
Where the Permittee becomes aware that it failed to submit any relevant facts in a permit application,
or submitted incorrect information in a permit application or in any report to the Director, it shall
promptly submit such facts or information [40 CFR 122.41(1)(8)].
Part Il I Page 9 of 9

NCS000562
PART IV DEFINITIONS
1. Act
See Clean Water Act.
2. Adverse Weather
Adverse conditions are those that are dangerous or create inaccessibility for personnel, such as local
flooding, high winds, or electrical storms, or situations that otherwise make sampling impractical.
When adverse weather conditions prevent the collection of samples during the sample period, the
permittee must take a substitute sample or perform a visual assessment during the next qualifying
storm event. Documentation of an adverse event (with date, time and written narrative) and the
rationale must be included with your SPPP records. Adverse weather does not exempt the permittee
from having to file a monitoring report in accordance with the sampling schedule. Adverse events and
failures to monitor must also be explained and reported on the relevant DMR.
Allowable Non-Stormwater Discharges
This permit regulates stormwater discharges. Non-stormwater discharges which shall be allowed in
the stormwater conveyance system are:
a. All other discharges that are authorized by a non-stormwater NPDES permit.
b. Uncontaminated groundwater, foundation drains, air -conditioner condensate without added
chemicals, springs, discharges of uncontaminated potable water, waterline and fire hydrant
flushings, water from footing drains, flows from riparian habitats and wetlands.
c. Discharges resulting from fire -fighting or fire -fighting training, or emergency shower or eye wash
as a result of use in the event of an emergency.
4. Best Management Practices fBMPs
Measures or practices used to reduce the amount of pollution entering surface waters. BMPs may
take the form of a process, activity, or physical structure. More information on BMPs can be found at:
http: //cfpub.epa.gov/npdes/stormwater/menuofbmp2s/index.cfm.
S. Bypass
A bypass is the known diversion of stormwater from any portion of a stormwater control facility
including the collection system, which is not a designed or established operating mode for the facility.
6. Bulk Storage of Liquid Products
Liquid raw materials, manufactured products, waste materials or by-products with a single above
ground storage container having a capacity of greater than 660 gallons or with multiple above ground
storage containers located in close proximity to each other having a total combined storage capacity
of greater than 1,320 gallons.
7. Certificate of Coverage
The Certificate of Coverage (COC) is the cover sheet which accompanies a General Permit upon
issuance and lists the facility name, location, receiving stream, river basin, effective date of coverage
under the permit and is signed by the Director.
8, Clean Water Act
The Federal Water Pollution Control Act, also known as the Clean Water Act (CWA), as amended, 33
USC 1251, et. seq.
9. Division or DWO
The Division of Water Quality, Department of Environment and [Natural Resources.
Part IV Page 1 of 4

Permit No. NCSOOOS62
10. Director
The Director of the Division of Water Quality, the permit issuing authority.
11. EM
The North Carolina Environmental Management Commission.
12. Grab Sample
An individual sample collected instantaneously. Grab samples that will be analyzed (quantitatively or
qualitatively) must be taken within the first 30 minutes of discharge.
13. Hazardous Substance
Any substance designated under 40 CFR Part 116 pursuant to Section 311 of the Clean Water Act.
14. Landfill
A disposal facility or part of a disposal facility where waste is placed in or on land and which is not a
land treatment facility, a surface impoundment, an injection well, a hazardous waste long-term
storage facility or a surface storage facility.
15. Measureable Storm Event
A storm event that results in an actual discharge from the permitted site outfall. The previous
measurable storm event must have been at least 72 hours prior. The 72-hour storm interval may not
apply if the permittee is able to document that a shorter interval is representative for local storm
events during the sampling period, and obtains approval from the local DWQ Regional Office. Two
copies of this information and a written request letter shall be sent to the local DWQ Regional Office.
After authorization by the DWQ Regional Office, a written approval letter must be kept on site in the
permittee's SPPP.
16, Municipal parate Storm Sewer System
A stormwater collection system within an incorporated area of local self-government such as a city or
town.
17. No Exposure
A condition of no exposure means that all industrial materials and activities are protected by a storm
resistant shelter or acceptable storage containers to prevent exposure to rain, snow, snowmelt, or
runoff. Industrial materials or activities include, but are not limited to, material handling equipment
or activities, industrial machinery, raw materials, intermediate products, by-products, final products,
or waste products. DWQ may grant a No Exposure Exclusion from NPDES Stormwater Permitting
requirements only if a facility complies with the terms and conditions described in 40 CFR
§122.26(g).
18. Notice f Intent
The state application form which, when submitted to the Division, officially indicates the facility's
notice of intent to seek coverage under a General Permit.
19. Permit Issuing Authority
The Director of the Division of Water Quality (see "Director" above).
20. Permittee
The owner or operator issued this permit.
Part IV Page 2 of 4 Pages

Permit No. NCS000562
21. Point Source Discharge of Stormwater
Any discernible, confined and discrete conveyance including, but not specifically limited to, any pipe,
ditch, channel, tunnel, conduit, well, or discrete Fissure from which stormwater is or may be
discharged to waters of the state.
22. Representative Outfall Status
When it is established that the discharge of stormwater runoff from a single outfall is representative of the
discharges at multiple outfalls, the DWQ may grant representative outfall status. Representative outfall status
allows the permittee to perform analytical monitoring at a reduced number of outfalls.
23. Secondary Containment
Spill containment for the contents of the single largest tank within the containment structure plus
sufficient freeboard to allow for the 25-year, 24-hour storm event.
24. Section 313 Water Priority Chemical
A chemical or chemical category which:
b. Is listed in 40 CFR 372.65 pursuant to Section 313 of Title III of the Superfund Amendments and
Reauthorization Act (SARA) of 1986, also titled the Emergency Planning and Community Right -
to -Know Act of 1986;
c. Is present at or above threshold levels at a facility subject to SARA title 11I, Section 313 reporting
requirements; and
d. Meets at least one of the following criteria:
i. Is listed in appendix D of 40 CFR part 122 on Table 11 (organic priority pollutants), Table III
(certain metals, cyanides, and phenols) or Table IV (certain toxic pollutants and hazardous
substances);
ii. Is listed as a hazardous substance pursuant to section 311(b)(2)(A) of the CWA at 40 CFR
116.4; or
iii. Is a pollutant for which EPA has published acute or chronic water quality criteria.
25. Severe Property Damage
Substantial physical damage to property, damage to the control facilities which causes them to
become inoperable, or substantial and permanent loss of natural resources which can reasonably be
expected to occur in the absence of a bypass. Severe property damage does not mean economic loss
caused by delays in production.
26. Significant Materials
Includes, but is not limited to: raw materials; fuels; materials such as solvents, detergents, and plastic
pellets; finished materials such as metallic products; raw materials used in food processing or
production; hazardous substances designated under section 101(14) of CERCLA; any chemical the
facility is required to report pursuant to section 313 of Title III of SARA; fertilizers; pesticides; and
waste products such as ashes, slag and sludge that have the potential to be released with stormwater
discharges.
27. Significant Spills
Includes, but is not limited to: releases of oil or hazardous substances in excess of reportable
quantities under section 311 of the Clean Water Act (Ref: 40 CFR 110.3and 40 CFR 117.3) or section
102 of CERCLA (Ref: 40 CFR 302.4).
28. Stormwater Discharge Outfall CaDO
The point of departure of stormwater from a discernible, confined, or discrete conveyance, including
but not limited to, storm sewer pipes, drainage ditches, channels, spillways, or channelized collection
areas, from which stormwater flows directly or indirectly into waters of the State of North Carolina.
Part 1V Page 3 of 4 Pages

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

TIMOTHY R. BASILONE
Vice President - Enuhconrentnl Affairs
4955 STEUBENVILLE PINE WWW.HoR5EHEAD.NET 724.773.2223
SUITE 405 YGASILONE®HORSEHEAD.NET 412.788.4526
LPITTv BUROH, PA 15203
September 19, 2012
Mr. Ken Pickle, Environmental Engineer
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Stormwater Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: Draft Industrial Stormwater NPDES Permit
Horsehead Corporation Zinc Production Facility
Rutherford County, North Carolina
Dear Mr. Pickle:
r t' r 1 =��
CORPORATION
Lending the World ire Zinc Recycling
Thank you for the opportunity to comment on the Draft Industrial Stormwater NPDES
Permit (Draft Permit) you provided on June 29, 2012. Furthermore, thank you for your
continuing effort in working with us to develop this permit, and providing time for
meetings and telephone conferences to discuss our permit application and the subject
permit. Our comments on the Draft Permit, the Staff Review and Evaluation Form (Staff
Review Form), and the Regional Office comments are provided below. These comments
summarize our discussions, and are responsive to your requests from the conference call
with you and the Regional Office on September 14,.2012, and comments provided earlier
in e-mails to you.
The overriding storm water management concept is to capture and control the disposition
of all storm water falling into the operating area. This system is to prevent the
uncontrolled discharge of potential pollutants to the discharge stream. The physical
facility is being designed to support this concept, and operating procedures will be
developed to ensure management controls are documented and implemented. The first
preference is to use the water in the operation, and as a second preference, only as
necessary, to direct the water to the site storm water discharge.
The facility is designed to capture and contain all storm water that falls within the
operating area of the site. This design will contain rainwater falling in this area during
the 100 year 24 hour storm event. Water captured in the area will be managed in one of
three ways, as follows:
If part of an individual (isolated) basin, water will be placed directly into the
process or a tank within that production area,

Routed to the process water management system, or used to partially displace
process water (finished water provided by the Town) used by the operation,
■ Sampled and analyzed before discharge to the storm water outfall system.
Storm water falling in areas outside the operating area and from rooftops, parking areas
and landscaped areas will be discharged directly to the storm water outfall during the
storm event.
Details of this system are being developed and will be incorporated_ as part of the site
operating procedures, and the Storm Water Pollution Prevention Plan (SWPPP). A map
and table describing this system will be provided once the system design is completed.
Comments on the Draft Permit, Staff Review Form and the Regional Office Comments
are addressed below.
Comments on the Staff Review Form
Page 1 Type of Activity and Pa e 2 Description of Activity
The reference to receiving waste is incorrect. The facility will receive zinc oxide
as raw material for the process which is a product manufactured at other
Horsehead facilities. Zinc oxide feed material contains some lead and cadmium,
in addition to zinc. The reference to silver should be eliminated, since it is a very
minor component of zinc oxide.
Page 1, Special Permitting Issues, Risk Considerations, Location
The assigned rating b is excessive for risk due to the site location. Since this is a
new facility, the existing impairment mentioned in this section is a pre-existing
condition located downstream and cannot be attributed to the new facility. Based
on the actual conditions, the rating should be in the low range of the risk scale.
Pa eg 1, Special Permitting Issues, Risk Considerations, Other Factors
The assigned rating 10 is excessive for risk considering other factors. This is a
new facility that is specifically designed, as described above, to prohibit
stormwater contamination. To the contrary of the statement "proper operator
actions to a larger than normal degree" and other factors mentioned, during our
discussions you indicated design of the stormwater management systems for this
plant are exceptional. The design includes a stormwater management system
whereby discharge of storm water from the operating area is not possible without
specific action based on management authorization to release the water. If the
agency's risk determination is to be used as a basis for permit decisions, the true
risk of stormwater pollution from the site needs to be described. Our design
presents less than normal risks for most industrial sites. Based on the actual
conditions, the rating should be in the low range of the risk scale.
2

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

in the section above. We propose the permit be written to require "monitoring
only" for the first two years of the operation.
Information obtained for the first eight quarters of operation should be recorded
and summarized in a report to support a recommendation for either a stormwater
permit containing benchmark levels established based on potential impact to the
Broad River, or a "no exposure" application and site status. The report would be
submitted to the agency following the two year period of evaluation for review by
DWQ. Based on this report the permit can be revised accordingly, or eliminated
if the "no exposure" scenario is justified.
The report would provide the raw data, an evaluation of the potential impact to
the receiving waters based on the monitoring data and the conditions of the Broad
River at the time of sampling, a recommendation on the need for benchmarks at
this site, if appropriate a recommendation for the benchmark parameters and
levels, and an evaluation of the site for "no exposure" status. If the "no exposure"
scenario applies, an application for this status will be provided with the report.
Since this is a new plant with no prior history available, and the design of the
plant is such that stormwater is contained and controlled in areas of the operation,
we believe the proposed approach allows for information to be gathered after the
plant begins operating that will serve as a basis for developing a permit for the
operation or justifying a "no exposure" scenario.
Comments on the Draft Permit
Part II Page 2 of 11 b Secondary Containment Requirements and Records
The later portion of this section should be eliminated beginning on the seventh
line and following the words "areas shall be maintained." You have indicated
during prior meetings, calls and communications that the permit will not require
anything on internal monitoring, but will rely entirely on discharge point
monitoring for regulatory purposes. Specific conditions provided on internal
monitoring for captured water are inconsistent with these prior discussions.
Pail It Page S of 11, Section B: Analytical Monitoring Requirements
Please see the above sections in the Staff Evaluation discussing the Analytical
Monitoring Requirements.
Benchmarks and their use in the permit should be eliminated, including the tiered
approach for monitoring. Instead, Horsehead is proposing a "Monitor Only"
status for the facility for two years (eight quarters) following startup. Monitoring
will be conducted at the discharge point to the Broad River and include collection
and analysis of samples for Zinc, Lead, Cadmium, Oil & Grease, TSS, and pH.
Monitoring results over this period of time will be used to evaluate the
effectiveness of the facility design and stormwater management scheme, which is
4

based on a strategy to prohibit stormwater discharge containing contaminants
from the operation.
As noted, the monitoring results obtained over the eight quarters will be
summarized in a report for submittal to the DWQ, and in support of a revised
stormwater pern-At with benchmark levels established based on potential impact to
receiving waters, or a "no exposure" status.
Part II Page 10 of 11 Section D: On -site Vehicle Maintenance Monitoring Requirements
Please eliminate this section; there is no vehicle maintenance facility or activity
that will be conducted on site.
Comments on the Regional Office Comments
Require SWPPP to be developed for startup —
An SWPPP will be developed for the site prior to startup of the facility.
Address failure modes with a back-up plan identifying management actions in res once
to atypical operating conditions —
The SWPPP to be developed prior to plant startup will address this matter.
Add chlorides to the sampling scheme —
Based on the proposed approach for stormwater management and the sampling
scheme and parameters described above, this monitoring wilt provide sufficient
data to assess stormwater from the facility site, Monitoring for chlorides will add
no additional benefits and is not justified.
Add quarterly acute toxicity testing to the sampling scheme —
The level of stormwater management on this site is extensive and well beyond
anything required under any other permit for facilities in North Carolina. Aquatic
Whole Effluent Testing is not a standard industrial stormwater requirement.
Application to a site with control systems as described above is not reasonable.
The inclusion of toxicity testing is unsupportable and inappropriate.
Provide a "step-down" in analyticat testing from quarterly to 2/yr after 3 years,
conditional on results —
In consideration of the proposed approach to monitoring, this should be evaluated
based on results from the quarterly sampling over two years, along with the
evaluation of a "no exposure" status for the site.
5

Per your request during our telephone conference on September 14, 2012,1 have attached
a site plan showing the stormwater route to the River, including the stormwater basin
adjacent to the River.
We appreciate the opportunity to review the permit and the agency's supporting
documentation and comments. We are available to meet at your office to discuss this
permit application with you at your convenience. We look forward to discussing this
information with you and to reviewing a revised draft of the permit, based on our
comments.
As discussed on many occasions it is to our best interest to have this permit issued in the
shortest timeframe possible. Thank you for your continued support and consideration.
Sincerely,
Timothy R. Basilone
Enc.
cc Forest Westall, McGill Associates

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NCS000562
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE STORMWATER UNDER THE
In compliance with the provisions of North Carolina'General'Statute 143-215.1, other
lawful standards and regulations promulgated and'adopted by the North Carolina
Environmental Management Commission, and,the,Federal'Water Pollution Control Act, as
amended,
Horselieadporation
is hereby authorized to disch�rge�stormwater from a facility located at
Ruth�cl,County Production Facility
L/ State Route 221
Forest City, North Carolina
Rutherford County
to receiving waters designated as the Broad River, a class C water in the Broad River Basin,
in accordance with the discharge limitations, monitoring requirements, and other
conditions set forth in Parts I, II, Ili, and IV hereof.
Note: Draft Permit Dates are Approximate
This permit shall become effective September 4, 2012.
This permit and the authorization to discharge shall expire at midnight on August 31, 2017.
Signed this day September 4, 2012.
for Charles Wakild, P.E., Director
Division of Water Quality
By the Authority of the Environmental Management Commission

Permit No. NCS000562
PART I
Section A:
Section B:
Section C:
Fg.-Tiffiff
Section A:
Section B:
Section C:
Section D;
TABLE OF CONTENTS
INTRODUCTION
Individual Permit Coverage
Permitted Activities
Location Map
MONITORING, CONTROLS, AND LIMIT -AT
DISCHARGES
Stormwater Pollution PreventioWPlan,
Analytical Monitoring Requirements
Qualitative M onitorin-gaRe, qut`r_efinents
PERMITTED
On -Site Vehicle Maintenance Monitoring Requirements
PART III STANDARD CONDITIONS FOR NPDES STORMWATER INDIVIDUAL PERMITS
Section A: Compliance and Liability
1.
Compliance Schedule
2.
Duty to Comply
3.
Duty to Mitigate
4.
Civil and Criminal Liability
5.
Oil and Hazardous Substance Liability
6.
Property Rights
7.
Severability
8.
Duty to Provide Information
9.
Penalties for Tampering
10.
Penalties for Falsification of Reports
11.
Onshore or Offshore Construction
12.
Duty to Reapply

Permit No. NCS000562
Section B: General Conditions
1.
Permit Expiration
2.
Transfers
3.
Signatory Requirements
4.
Permit Modification, Revocation and Reissuance, or Termination
S.
Permit Actions
6.
Annual Administering and Compliance Monitoring Fee
Requirements
Section C: Operation
Maintenance Pollutio C'
1.
and of ontrols
Proper Operation and Main to lAce
2.
Need to Halt or Reduce Not;a Defense
el\ -\,
3.
Bypassing of Stormwater'Control Facilities
Section D: Monitoring
and Records
1.
Representative., ampling
2.
Record
g,Results� V
n�
3.
Flow Measurements
4.
Test,Procedures
5.
Representative Outfall
6.
Recoi ds•Retention
7.
Inspection and Entry
Section E: Reporting
Requirements
1.
Discharge Monitoring Reports
2.
Submitting Reports
3.
Availability of Reports
4.
Non-Stormwater Discharges
S.
Planned Changes
6.
Anticipated Noncompliance
7.
Spills
8.
Bypass
9.
Twenty-four Hour Reporting
10.
Other Noncompliance
11.
Other Information
PART IV DEFINITIONS
Ill

Permit No. NCS000562
PART I INTRODUCTION
SECTION A: INDIVIDUAL PERMIT COVERAGE
During the period beginning on the effective date of the permit and lasting until expiration,
the permittee is authorized to discharge stormwater associated with industrial activity.
Such discharges shall be controlled, limited, and monitored as specified in this permit.
If industrial materials and activities are not exposed to precipitation or runoff as described
in 40 CFR §122.26(g), the facility may qualify for a No Exposure Exclusion from NPDES
stormwater discharge permit requirements. Any ovne`or` perator wishing to obtain a No
Exposure Exclusion must submit a No Exposure Certification,Notice of Intent (N1) form to
If // \ N//
m
the Division; must receive approval by the Division;ust mantain no exposure conditions
unless authorized to discharge under a valid NP E- stormwater permit; and must recertify
the No Exposure Exclusion annually.
SECTION B: PERMITTED ACTIVITIES/
Until this permit expires or is•modified or.`evoked, the permittee is authorized to discharge
stormwater to the surface waters of North,Carolina that has been adequately treated and
managed in accordance with,the erms and conditions of this permit. All stormwater
discharges shall be in accordance with the conditions of this permit.
Any other point source discharge to surface waters of the state is prohibited unless it is an
allowable non-stormwater discharge or is covered by another permit, authorization, or
approval. The stormwater discharges allowed by this permit shall not cause or contribute
to violations of Water Quality Standards.
This permit does not relieve the permittee from responsibility for compliance with any
other applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or
decree.
Part] Pagel of 2

SECTION C: LOCATION MAP
Permit No. NCSOOOS62
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NCS000562
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Horsehead Corporation
Rutherford County Facility
Latitude: 35" 11'36N
Longffijde:81* 50'59"W
CoLuty: Ruftwford County
Receiving Stream: Broad River
Seam Class: C
Sub4kk9n: 03-08-02 Broad Rjww Basin
Facility Location
Part I Page 2 of 2

Permit No. NCSOOOS62
PART II MONITORING, CONTROLS, AND LIMITATIONS FOR
PERMITTED DISCHARGES
SECTION A: STORMWATER POLLUTION PREVENTION PLAN
The permittee shall develop and implement a Stormwater Pollution Prevention Plan
(SPPP). The SPPP shall be maintained on site. The SPPP is public information in
accordance with Part III, Standard Conditions, Section E, paragraph 3 of this permit. The
SPPP shall include, at a minimum, the following items:
Site Overview. The Site Overview shall provide a description of the physical facility
and the potential pollutant sources that have the potent \to c n tribute to
contamination of stormwater discharges. The Site O,v _iew shall contain the following:
(a) A general location map (USGS quadrangle4rnap o `ppropriately drafted equivalent
map) showing the facility's location in relation`to transportation routes and surface
waters; the name of the receiving waters ro�whieh the stormwater outfalls
discharge; and accurate latitude andilongitude of the points of stormwater discharge
associated with industrial activity/The(general location map (or alternatively the
site map) shall identify w"`hethe� any receiving waters are impaired (on the state's
303(d) list of impaired waters) o ifthe site is located in a watershed for which a
TMDL has been established and'wb_at the parameters of concern are.
(b) A narrative description of brage practices, loading and unloading activities,
outdoor process areas, dust -or particulate generating or control processes, and
waste disposal practices. narrative description of the potential pollutants that
could be expected to be present in the stormwater discharge from each outfall.
(c) A site map drawn at a scale sufficient to clearly depict: the site property boundary;
the stormwater discharge outfalls; all on -site and adjacent surface waters and
wetlands; industrial activity areas (including storage of materials, disposal areas,
process areas, loading and unloading areas, and haul roads); site topography and
finished grade; all drainage features and structures; drainage area boundaries and
total contributing area for each outfall; direction of flow in each drainage area;
industrial activities occurring in each drainage area; buildings; stormwater Best
Management Practices (BMPs); and impervious surfaces. The site map must
indicate the percentage of each drainage area that is impervious, and the site map
must include a graphic scale indication and north arrow.
(d) A list of significant spills or leaks of pollutants during the previous three (3) years
and any corrective actions taken to mitigate spill impacts.
(e) Certification that the stormwater outfalls have been evaluated for the presence of
non-stormwater discharges. The permittee shall re -certify annually that the
Part II Page 1 of 11

Permit No. NCSOOOS62
a
A-
stormwater outfalls have been evaluated for the presence of non-stormwater
discharges. The certification statement will be signed in accordance with the
requirements found in Part III, Standard Conditions, Section B, Paragraph 3.
2. Stormwater Management Strategy. The Stormwater Management Strategy shall
contain a narrative description of the materials management practices employed which
control or minimize the stormwater exposure of significant materials, including
structural and nonstructural measures. The Stormwater Management Strategy, at a
minimum, shall incorporate the following:
(a) Feasibility Study. An annual review by site management of the technical and
economic feasibility of changing the methods of operations and/or storage practices
to eliminate or reduce exposure of materials and processes to rainfall and run-on
flows. Wherever practical, the permittee shall prevent exposure of storage areas,
I // \ \�/
material handling operations, manufacturing, -and fueling.operations. In areas
where elimination of exposure and/or preventibn of run-on contact are not
practical, the Feasibility Study shall document the basis for the management
decision that such controls are not feasible. V
(b) Secondary Containment Requiritnetrts a6d Records. Secondary containment is
required for: bulk storage of liquid materials; storage in any amount of Section 313
of Title III of the Superfund`gmendme t and Reauthorization Act (SARA) water
priority chemicals; and storage in any amount of hazardous substances, in order to
prevent leaks and spills'fromcontaminating stormwater runoff. A table or summary
of all such tanks and/stored materials and their associated secondary containment
areas shall be maintained. If -the secondary containment devices are connected to
stormwater conveyanc se ystems, the connection shall be controlled by manually
activated valves or other similar devices (which shall be secured closed with a
locking mechanism). Any stormwater that accumulates in containment areas shall
L be at a minimum visually observed for color, foam, outfall staining, visible sheens
and dry weather flow, prior to release of the accumulated stormwaters. In addition,
for containment installed for areas with the potential far metal solutions or petroleum
hydrocarbons, the permittee shall conduct analytical monitoring to detect the
unanticipated presence of such materials. Accumulated stormwater maybe released
if found to be uncontaminated by any material. Records documenting the individual
making the observation or analyses, the visual and analytical description of the
accumulated stormwaters, and the dates and times of the releases shall be kept for a
period of five (S) years.
(c) BMP Summary. A listing of site structural and non-structural Best Management
Practices (BMPs) shall be provided. The installation and implementation of BMPs
shall be based on the assessment of the potential for sources to contribute
significant quantities of pollutants to stormwater discharges and on data collected
through monitoring of stormwater discharges. The BMP Summary shall include a
written record of the specific rationale for installation and implementation of the
Part 11 Page 2 of 11

Permit No. NCS000562
selected site BMPs. The BMP Summary shall be reviewed by site management and
updated annually.
3. Spill Prevention and Response Procedures. The Spill Prevention and Response
Procedures (SPRP) shall incorporate an assessment of potential pollutant sources based
• on a materials inventory of the facility. Site management shall identify facility personnel
responsible for implementing the SPRP in a written list incorporated into the SPRP
along with dated signatures by each individual acknowledging his or her
responsibilities under the SPRP. A responsible person shall be on -site at all times
during facility operations that have the potential to contaminate stormwater runoff
through spills or exposure of materials associated with the facility operations. The
SPRP must be site stormwater specific. Therefore, an oil Spill Prevention Control and
Countermeasure plan (SPCC) may be a component oPthe` RP, but may not be
sufficient to completely address the stormwater aspectsof the SPRP. The common
elements of the SPCC with the SPRP may be ineorporated.b e�ference into the SPRP.
4. Preventative Maintenance and Good Ho
maintenance and good housekeeping pr
The program shall address all stormwa i
discharge outfalls, all on -site and adjace!
activity areas (including material storag
process areas, loading andlunloading ap
structures, and existing structural,BM;Ps
inspections, maintenar
as well as facility equip
for stormwater exposu
h
pbig,Program. A preventative
Il be developed and implemented.
systems (if applicable), stormwater
waters and wetlands, industrial
=_'yeas, material handling areas, disposal areas,
gas, and haul roads), all drainage features and
� The program shall establish schedules of
ping activities of stormwater control systems,
t, facility areas, and facility systems that present a potential
stormwater pollution where not already addressed under
another element of the - SPPP.!Inspection of material handling areas and regular
cleaning schedules of these areas shall be incorporated into the program. Timely
compliance with the established schedules for inspections, maintenance, and
housekeeping shall be recorded and maintained in the SPPP.
Facility Inspections. Inspections of the facility and all stormwater systems shall occur
as part of the Preventative Maintenance and Good Housekeeping Program at a
minimum on a semi-annual schedule, once during the first half of the year (January to
June), and once during the second half (July to December), with at least 60 days
separating inspection dates (unless performed more frequently than semi-annually).
These facility inspections are different from, and in addition to, the stormwater
discharge characteristic monitoring at the outfall required in Part lI B, C, and D of this
permit.
6. Employee Training. Training programs shall be developed and training provided at a
minimum on an annual basis for facility personnel with responsibilities for: spill
response and cleanup, preventative maintenance activities, and for any of the facility's
operations that have the potential to contaminate stormwater runoff. The facility
personnel responsible for implementing the training shall be identified, and their
annual training shall be documented by the signature of each employee trained.
Part II Page 3 of 11

Permit No. NCS000562
7. Responsible Party. Site management shall identify, and the SPPP shall document, a
specific position or positions responsible for the overall coordination, development,
implementation, and revision of the SPPP. Responsibilities for all components of the
SPPP shall be documented and position assignments provided.
8. SPPP Amendment and Annual Update. The permittee shall amend the SPPP
whenever there is a change in design, construction, operation, site drainage,
maintenance, or configuration of the physical features which may have a significant
impact on the potential for the discharge of pollutants to surface waters. All aspects of
the SPPP shall be reviewed and updated on an annual�basis. The annual update
h 11' 1 d llth ' ' ' t � �
a inc u e a I-- aspects require d�mme d�a e
The Director may notify the.I
minimum requirements of'th
shall submit a time schedule
requirements. The permitte(
Part III, Standard Condit -ions,
have been made.
)ermittee wlie�tlie SPPP does not meet one or more of the
e permit�Within 30 days of such notice, the permittee
to the Director for modifying the SPPP to meet minimum
hs a`ll provide certification in writing (in accordance with
Section B, Paragraph 3) to the Director that the changes
11
9. SPPP Implementation. The permittee shall implement the Stormwater Pollution
Prevention Plan and all appropriate BMPs to prevent contaminants from entering
surface waters via Stormwater. Among other actions identified herein, implementation
of the SPPP shall include the documentation of: all monitoring, measurements,
inspections, maintenance activities, and training provided to employees, including the
log of the sampling data and of actions taken to implement BMPs associated with the
industrial activities, including vehicle maintenance activities. Such documentation shall
be kept on -site for a period of five (5) years and made available to the Director or the
Director's authorized representative immediately upon request.
Part II Page 4 of 11

Permit No. NCSOOOS62
SECTION B: ANALYTICAL MONITORING REQUIREMENTS
Analytical monitoring of stormwater discharges shall be performed as specified in Table 1.
All analytical monitoring shall be performed during a measureable storm event at each
stormwater discharge outfall (SDO). Only SDOs discharging stormwater associated with
industrial activity must be sampled (See Definitions).
A measurable storm event is a storm event that results in an actual discharge from the
permitted site outfall. The previous measurable storm event must have been at least 72 hours
prior. See Definitions.
Table 1. Anal Y g q tical Monitorin Re uiremeiits
Discharge
Characteristics
Units
Measurement
Fre uenc 1
Sample
Type2
Sample
Location3
Total Suspended Solids
m L
rterly
Grab
SDO
Total Nitrogen
mg f //
)f quarterly
Grab
SDO
Total Phosphorus
/rri � Lp_
�// quarterly
Grab
SDO
Zinc, Total Recoverable
\gym_ L_ V
quarterly
Grab
SDO
Lead, Total Recoverable �
� �in\
quarterly
Grab
SDO
Silver, Total Recoverable
)f m L
quarterly
Grab
SDO
Non -polar Oil & Grease/TPffl�
EPA Method 1664 SGT-HEMI -
m L
g�
quarterly
Grab
SDO
H
standard
quarterly
Grab
SDO
Total Rainfall4
inches
quarterly
Rain Gauge
-
Footnotes:
1 Measurement Frequency: Four times per year during a measureable storm event
2 Grab samples shall be collected within the first 30 minutes of discharge.
3 Sample Location: Samples shall be collected at each stormwater discharge outfall (SDO).
4 For each sampled measureable storm event, the total precipitation must be recorded. An on -site rain gauge
or local rain gauge reading must be recorded.
The permittee shall complete the analytical samplings in accordance with the schedule
specified below in Table 2, unless adverse weather conditions prevent sample collection
(see Adverse Weather in Definitions). A minimum of 30 days must separate successive
sample events, unless monthly monitoring has been instituted under a Tier Two response.
Inability to sample because of adverse weather conditions must be documented in the
SPPP and recorded on the DMR. The permittee must report the results from each sample
taken within the monitoring period (see Part III, Section E).
Part II Page S of 11

Permit No. NC5000562
Table 2. Monitoring Schedule
Monitoring periodl,2
Sample Number
Start
End
Year 1- Period 1
1
September 4, 2012
December 31, 2012
Year 1 - Period 2
2
January 1, 2013
March 31, 2013
Year 1- Period 3
3
April 1, 2013
June 30, 2013
Year 1 - Period 4
4
July 1, 2013
September 30, 2013
Year 2 - Period 1
5
October 1, 2013
December 31, 2013
Year 2 - Period 2
6
January 1, 2014
March 31, 2014
Year 2 - Period 3
7
April 1, 2014
June 30, 2014
Year 2 - Period 4
8
July 1, 2014,,>
September 30, 2014
Year 3 - Period 1
9
October 1, 2'614
December 31, 2014
Year 3 - Period 2
10
January/ 2-Q15✓
March 31, 2015
Year 3 - Period 3
11
April', 2015--"
June 30, 2015
Year 3 - Period 4
12
1KRy�j,`2015
September 30, 2015
Year 4 - Period 1
13
/October`,/Z015
December 31, 2015
Year 4 - Period 2
14
,Jan`uary 1, 2016
March 31, 2016
Year 4 - Period 3
15
1, 2016
June 30, 2016
Year 4 - Period 4
/16
(_;-Zjuly 1, 2016
September 30, 2016
Year 5 - Period 1
\17\ �,
October 1, 2016
December 31, 2016
Year 5 - Period 28
v
January 1, 2017
March 31, 2017
Year 5 - Period 3
%I 19 }/✓
April 1, 2017
June 30, 2017
Year 5 - Period 4
20 '
July 1, 2017
August 31, 2017
Footnotes: �;�
1 Maintain quarterly monitoring until either another permit is issued for this facility or until this permit
is revoked or rescinded. The permittee must submit an application for renewal of coverage before the
submittal deadline (180 days before expiration) to be considered for renewed coverage under the
permit. The permittee must continue analytical monitoring throughout the permit renewal process,
even if a renewal permit is not issued until after expiration of this permit.
2 If no discharge occurs during the sampling period, the permittee must submit a monitoring report
indicating "No Flow" or "No Discharge" within 30 days of the end of the sampling period.
Failure to monitor quarterly per the permit terms immediately institutes monthly
monitoring for all parameters, upon the next measureable storm event. After six (6)
months of monthly monitoring, the permittee may return to a quarterly sampling
monitoring schedule, unless DWQ requires continued monthly monitoring or benchmark
exceedances prompt a "Tier Two" response. "No discharge" from an outfall during a
monitoring period does not constitute failure to monitor, as long as it is properly reported.
The permittee shall compare monitoring results to the benchmark values in Table 3. The
benchmark values in Table 3 are not permit limits, but should be used as management
guidelines for the permittee's responsive implementation of the Stormwater Pollution
Prevention Plan (SPPP). Exceedances of benchmark values require the permittee to increase
monitoring, and/or increase management actions, and/or increase record keeping, and/or
Part II Page 6 of 11

Permit No. NCS000562
install stormwater Best Management Practices (BMPs) in a tiered program. See the
descriptions of Tier One, Tier Two, and Tier Three response actions below.
Table 3. Benchmark Values for Analvtical Monitorine
Discharge Characteristics
Units
Benchmark
Total Suspended Solids
mg/L
100
Total Nitrogen
mg/L
30
Total Phosphorus
mg/L
2
Zinc, Total Recoverable
mg/L
0.067
Lead, Total Recoverable
mg/L
0.03
Silver, Total Recoverable
Non -polar Oil & Grease/TPH
[EPA Method 1664 (SGT-HEM)]
mg/re
mg/�
0.001
15
pH
,stQnd'ard
6-9
Tier One
If: The first valid sampling results ar\ee above\benchmark value, or outside of the benchmark range,
for anv Darameter at anv outfall:/ \
Then: The permittee shall: dnagemk�inspection
1. Conduct a stormwater
of the facility within two weeks of receiving
sampling results.
2. Identify and evaluate possible causes of the benchmark value exceedance.
3. Identify potential and select the specific: source controls, operational controls, or physical
improvements to reduce concentrations of the parameters of concern, and/or to bring
concentrations within the benchmark range.
4. Implement the selected actions within two months of the inspection.
5. Record each instance of a Tier One response in the SPPP. Include the date and value of the
benchmark exceedence, the inspection date, the personnel conducting the inspection, the
selected actions, and the date the selected actions were implemented.
Part II Page 7 of l l

Permit No. NCS000562
Tier Two
If: During the term of this permit, the first valid sampling results from two consecutive monitoring
periods are above the benchmark values, or outside of the benchmark range, for any specific
meter at a specific discharge outfall;
Then: The permittee shall:
1. Repeat all the required actions outlined above in Tier One.
2. Immediately institute monthly monitoring for all parameters. The permittee shall conduct
monthly monitoring at every outfall where a sampling result exceeded the benchmark value for
two consecutive samples. Monthly (analytical and qualitative) monitoring shall continue until
three consecutive sample results are below the benchmark values or within benchmark range.
3. If no discharge occurs during the sampling period, the permittee is required to submit a
monthly monitoring report indicating "No Flow" to comply with reporting requirements.
4. Benchmark exceedances for a different parameter se arately jigger a tiered response.
5. Maintain a record of the Tier Two response in the,SPP,P.
Tier Three
During the term of this permit, if the valid sampling �esuits.required for the permit monitoring periods
exceed the benchmark value, or are outside the,benchmark range, for any specific parameter at any
specific outfall on four occasions, the permittee shali,notify the DWQ Regional Office Supervisor in
writing within 30 days of receipt of the fourth analytical results. DWQ may, but is not limited to:
• require that the permittee revise, e, increase, or decrease the monitoring frequency for the
remainder of the permit; 1
+ require the permittee tojinstall structural stormwater controls;
require the permittee,td implement other stormwater control measures;11
require the permitteelto perform upstream and downstream monitoring to characterize
impacts on receiving waters or
require the permittee implement site modifications to qualify for a No Exposure Exclusion.
If a Total Maximum Daily Load (TMDL) is approved for this segment of the Broad River, the
permittee may be required to monitor- for the pollutant(s) of concern in the future and
submit results to the Division of Water Quality. The Division will consider the monitoring
results in determining whether additional BMPs are needed to control the pollutant(s) of
concern to the maximum extent practicable.
If additional BMPs are needed to achieve the required level of control, the permittee will be
required to (1) develop a strategy for implementing appropriate BMPs, and (2) submit a
timetable for incorporation of those BMPs into the Stormwater Pollution Prevention Plan.
SECTION C: QUALITATIVE MONITORING REQUIREMENTS
The purpose of qualitative monitoring is to evaluate the effectiveness of the Stormwater
Pollution Prevention Plan (SPPP) and assess new sources of stormwater pollution.
Part it Page 8 of 11

Permit No. NCS000562
Qualitative monitoring of stormwater outfalls must be performed during a measurable
storm event.
Qualitative monitoring requires a visual inspection of each stormwater outfall regardless of
representative outfall status. Qualitative monitoring shall be performed quarterly as
specified in Table 4, and during required analytical monitoring events if any are
subsequently imposed (unless the permittee is required to perform further qualitative
sampling per the Qualitative Monitoring Response, below). Inability to sample because of
adverse weather conditions must be documented in the SPPP and recorded on the DMR (see
Adverse Weather in Definitions). Only SDOs discharging stormwater associated with
industrial activity must be monitored (See Definitions).
In the event an atypical condition is noted at a stormwater-di" charge outfall, the permittee
shall document the suspected cause of the condition and any actions taken in response to
the discovery. This documentation will be mainta nedith�the SPPP.
Table 4. Qualitative Monitoring Requirements
Discharge Characteristics
Frequencyl
Monitoring
Location2
Color U:�/
uarterl
SDO
Odor
quarterly
SDO
Clarity /! 1 _
uarterl
SDO
Floating Solids
quarterl
SDO
Suspended Solids
quarterly
SDO
Foam
quarterly
SDO
Oil Sheen
uarterly
SDO
Erosion or deposition at the outfall
quarterly
SDO
Other obvious indicators
of stormwater pollution
quarterly
SDO
Footnotes:
1 Measurement Frequency: Four times per year during a measureable storm event See Table 2 for
schedule of monitoring periods through the end of this permitting cycle. The permittee must continue
qualitative monitoring throughout the permit renewal process until a new permit is issued.
2 Monitoring Location: Qualitative monitoring shall be performed at each stormwater discharge outfall
(SDO) regardless of representative outfall status.
A minimum of 30 days must separate monitoring dates, unless additional sampling has
been instituted as part of other analytical monitoring requirements in this permit.
If the permittee's qualitative monitoring indicates that existing stormwater BMPs are
ineffective, or that significant stormwater contamination is present, the permittee shall
investigate potential causes, evaluate the feasibility of corrective actions, and implement
Part it Page 9 of 11

Permit No. NCS000562
those corrective actions within 60 days, per the Qualitative Monitoring Response, below.
A written record of the permittee's investigation, evaluation, and response actions shall be
kept in the Stormwater Pollution Prevention Plan.
ve Monitoring Response
Qualitative monitoring is for the purposes of evaluating SPPP effectiveness, assessing new sources
of stormwater pollution, and prompting the permittee's response to pollution. If the permittee
repeatedly fails to respond effectively to correct problems identified by qualitative monitoring, or if
the discharge causes or contributes to a water quality standard violation, DWQ may, but is not
limited to:
• require that the permittee revise, increase, or decreaseA e monitoring frequency
(analytical or qualitative) for the remainder o fthe permit;
require the permittee to install structural stormwater controls;
require the permittee to implement other stormwater control measures;
• require the permittee to perform upstream and'downstream monitoring to characterize
impacts on receiving waters; or ��
• require the permittee implement site mod` ifications to qualify for a No Exposure Exclusion.
SECTION D: ON -SITE VEHICLE MAINTENANCE MONITORING REQUIREMENTS
Facilities that have any vehicle -maintenance activity occurring on -site which uses more
than 55 gallons of new motor oil per month when averaged over the calendar year
shall perform analytical monitoring as specified below in Table 5. All analytical
monitoring shall be performed during a measureable storm event at all stormwater
discharge outfalls (SDOs) that discharge stormwater runoff from vehicle maintenance areas,
and in accordance with the schedule presented in Table 2 (Section B).
Table S. Analytical Monitoring Requirements for On -Site Vehicle Maintenance
Discharge Characteristics
Units
Measurement
Fre uenc 2
Sample
T e2
Sample
Location3
H
standard
quarterly
Grab
SDO
Non -Polar Oil & Grease /
TPH
EPA Method 1664 SGT-HEM
mg/L
quarterly
Grab
SDO
Total Suspended Solids
m L
quarteHy
Grab
SDO
Total Rainfa114
inches
quarterly
Rain au e
New Motor Oil Usage
I gallons/month
I quarterlyEstimate
I-
Part II Page 10 of 11

Permit No. NCS000562
Footnotes:
1 Measurement Frequency: Four times year during a measureable storm event, until either another permit
is issued for this facility or until this permit is revoked or rescinded. See Table 2 for schedule of
monitoring periods through the end of this permitting cycle.
2 Grab samples shall be collected within the first 30 minutes of discharge.
3 Sample Location: Samples shall be collected at each stormwater discharge outfall (SDO) that discharges
stormwater runoff from area(s) where vehicle maintenance activities occur.
4 For each sampled measureable storm event the total precipitation must be recorded. An on -site or local
rain gauge reading must be recorded.
Failure to monitor semi-annually per permit terms immediately institutes monthly
monitoring for all parameters, upon the next measureable storm event, as provided in Part
II Section B.
Monitoring results shall be compared to the bencl
values in Table 6 are not permit limits, but shoul(
the permittee's responsive implementation of the
(SPPP). Exceedances of benchmark values requiir_
and/or increase management actions, and/olancl
stormwater Best Management Practices (BM-Ps),A
in Table 6. The benchmark
ianagement guidelines for
ter Pollution Prevention Plan
rmittee to increase monitoring,
cord keeping, and/or install
ded in Part II Section B.
Table 6. Benchmark Val eu s,for Vehicle Maintenance Analytical Monitoring
Discharge Characteristics
Units
Benchmark
pH )f">
standard
6-9
Non -Polar Oil & Grease / TPH�
[EPA Method 1664 (SGT-HEM)]
mg/L
15
Total Suspended Solids
mg/la
100
Part Il Page 11 of 11

Permit No. NCS000562
PART III STANDARD CONDITIONS FOR NPDES STORMWATER INDIVIDUAL PERMITS
SECTION A: COMPLIANCE AND LIABILITY
1. Compliance Schedule
The permittee shall comply with Limitations and Controls specified for stormwater discharges in
accordance with the following schedule:
Existing Facilities already operating but applying for permit coverage for the first time: The
Stormwater Pollution Prevention Plan shall be developed and implemented within 12 months of the
effective date of the initial permit and updated thereafter on an annual basis. Secondary containment,
as specified in Part 1I, Section A, Paragraph 2(b) of this permit, shall be accomplished within 12
months of the effective date of the initial permit issuance. /,>
New Facilities applying for coverage for the first
shall be developed and implemented prior to the be
industrial activity and be updated thereafter on an
in Part I1, Section A, Paragraph 2(b) of this permit sk
discharges from the operation of the industrial activ
The Stormwater Pollution Prevention Plan
o€ discharges from the operation of the
basis. Secondary containment, as specified
accomplished prior to the beginning of
Existing facilities previously permitted aril ap0l3ingX6r renewal: All requirements, conditions,
limitations, and controls contained in this permit (except new SPPP elements in this permit renewal)
shall become effective immediately uponlissuance,of this permit. New elements of the Stormwater
Pollution Prevention Plan for this pe`rmit,renewal shall be developed and implemented within 6
months of the effective date of this,permit and updated thereafter on an annual basis. Secondary
containment, as specified in Part 111, Paragraph 2(b) of this permit shall be accomplished prior to the
beginning of discharges frgm the peration of the industrial activity.
Duty to Comply ~�
The permittee must comp y with all conditions of this permit. Any permit noncompliance constitutes
a violation of the Clean Water Act (CWA) and is grounds for enforcement action; for permit
termination, revocation and reissuance, or modification; or denial of a permit upon renewal
application [40 CFR 122.41].
a. The permittee shall comply with standards or prohibitions established under section 307(a) of
the CWA for toxic pollutants within the time provided in the regulations that establish these
standards or prohibitions, even if the permit has not yet been modified to incorporate the
requirement.
b. The CWA provides that any person who violates section[s] 301, 302, 306, 307, 308, 318 or 405 of
the Act, or any permit condition or limitation implementing any such sections in a permit issued
under section 402, or any requirement imposed in a pretreatment program approved under
sections 402(a)(3) or 402(b)(8) of the Act, is subject to a civil penalty not to exceed $37,500 per
day for each violation. [33 USC 1319(d) and 40 CFR 122.41(a)(2)]
c. The CWA provides that any person who negligently violates sections 301, 302, 306, 307, 308,
318, or 40S of the Act, or any condition or limitation implementing any of such sections in a
permit issued under section 402 of the Act, or any requirement imposed in a pretreatment
program approved under section 402(a)(3) or 402(b)(8) of the Act, is subject to criminal
penalties of $2,S00 to $2S,000 per day of violation, or imprisonment of not more than 1 year, or
both. In the case of a second or subsequent conviction for a negligent violation, a person shall be
Part III • Page 1 of 9

Permit No. NCS000562
subject to criminal penalties of not more than $50,000 per day of violation, or by imprisonment of
not more than 2 years, or both. [33 USC 1319(c)(1) and 40 CFR 122.41(a)(2)]
d. Any person who knowingly violates such sections, or such conditions or limitations is subject to
criminal penalties of $5,000 to $50,000 per day of violation, or imprisonment for not more than 3
years, or both. In the case of a second or subsequent conviction for a knowing violation, a person
shall be subject to criminal penalties of not more than $100,000 per day of violation, or
imprisonment of not more than 6 years, or both. [33 USC 1319(c)(2) and 40 CFR 122.41(a)(2)]
Any person who knowingly violates section 301, 302, 303, 306, 307, 308, 318 or 405 of the Act, or
any permit condition or limitation implementing any of such sections in a permit issued under
section 402 of the Act, and who knows at that time that he thereby places another person in
imminent danger of death or serious bodily injury, shall, upon conviction, be subject to a fine of
not more than $250,000 or imprisonment of not more than 15.years, or both. In the case of a
second or subsequent conviction for a knowing endangerment violation, a person shall be subject
to a fine of not more than $500,000 or by imprisonment�of not more than 30 years, or both. An
organization, as defined in section 309(c)(3)(B)(iiii) of the CWA,.shall, upon conviction of
violating the imminent danger provision, be suhjecrto a fine ofnotmore than $1,000,000 and can
be fined up to $2,000,000 for second or subsequentcanvictions. (40 CFR 122.41(a)(2)]
f. Under state law, a civil penalty of not more•than $25,000 per violation may be assessed against
any person who violates or fails to act Waccord'ance with the terms, conditions, or requirements
of a permit [North Carolina General Statutes§ 143 2215.6A]
g. Any person may be ass` 9ed an`din `nisfrative' penalty by the Administrator for violating section
301, 302, 306, 307, 308, 318 or 405 of -this Act, or any permit condition or limitation
implementing any of such sections m,a permit issued under section 402 of this Act.
Administrative penalties,for Class [`violations are not to exceed $16,000 per violation, with the
maximum amount of any Class I�penalty assessed not to exceed $37,500. Penalties for Class if
violations are not to exceed $1d,000 per day for each day during which the violation continues,
with the maximum amount df any Class II penalty not to exceed $177,500. [33 USC 1319(g)(2)
and 40 CFR 122.41(a}(3)]
3. Duty to Mitigate
The permittee shall take all reasonable steps to minimize or prevent any discharge in violation of this
permit which has a reasonable likelihood of adversely affecting human health or the environment [40
CFR 122.41(d)].
4. Civil and Criminal Liability
Except as provided in Part III, Section C of this permit regarding bypassing of stormwater control
facilities, nothing in this permit shall be construed to relieve the permittee from any responsibilities,
liabilities, or penalties for noncompliance pursuant to NCGS 143-215.3,143-215.6, or Section 309 of the
Federal Act, 33 USC 1319. Furthermore, the permittee is responsible for consequential damages, such
as fish kills, even though the responsibility for effective compliance may be temporarily suspended.
5. Oil and Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the
permittee from any responsibilities, liabilities, or penalties to which the permittee is or may be
subject to under NCGS 143-215.75 et seq. or Section 311 of the Federal Act, 33 USC 1321.
6. Property Rights
The issuance of this permit does not convey any property rights in either real or personal property, or
any exclusive privileges, nor does it authorize any injury to private property or any invasion of
Part III Page 2 of 9

Permit No. NCS000562
personal rights, nor any infringement of Federal, State or local laws or regulations [40 CFR
122.41(g)].
Severability
The provisions of this permit are severable, and if any provision of this permit, or the application of
any provision of this permit to any circumstances, is held invalid, the application of such provision to
other circumstances, and the remainder of this permit, shall not be affected thereby [NCGS 1506-231.
8. Duty to Provide Information
The permittee shall furnish to the Permit Issuing Authority, within a reasonable time, any information
which the Permit Issuing Authority may request to determine whether cause exists for modifying,
revoking and reissuing, or terminating the permit issued pursuant to this permit or to determine
compliance with this permit The permittee shall also furnish to the Permit Issuing Authority upon
request, copies of records required to be kept by this permit [40 CFR 122.41(h)],
9. Penalties for Tampering
The Clean Water Act provides that any person who
inaccurate, any monitoring device or method requi
conviction, be punished by a fine of not more than
more than two years per violation, or by both. If a.4
after a first conviction of such person under this -pa
$20,000 per day of violation, or by imprison ment;4
tampers -with, or knowingly renders
maintained under this permit shall, upon
er violation, or by imprisonment for not
Hof a person is for a violation committed
punishment is a fine of not more than
-e than 4 years, or both [40 CFR 122,41],
10. Penalties for Falsification of Reports Ili(
The Clean Water Act provides' -that any person who knowingly makes any false statement,
representation, or certification inany record or other document submitted or required to be
maintained under this permit„ ncluding monitoring reports or reports of compliance or
noncompliance shall, upon,convictlon,.be punished by a fine of not more than $10,000 per violation, or
by imprisonment for notjmore than two years per violation, or by both [40 CFR 122.41].
11.
This permit does not authorize or approve the construction of any onshore or offshore physical
structures or facilities or the undertaking of any work in any navigable waters.
12. Duty to Reapply
If the permittee wishes to continue an activity regulated by this permit after the expiration date of
this permit, the permittee must apply for and obtain a new permit (40 CFR 122.41(b)].
SECTION B: GENERAL CONDITIONS
1. Permit Expiration
The permittee is not authorized to discharge after the expiration date. In order to receive automatic
authorization to discharge beyond the expiration date, the permittee shall submit forms and fees as
are required by the agency authorized to issue permits no later than 180 days prior to the
expiration date, unless permission for a later date has been granted by the Director. (The Director
shall not grant permission for applications to be submitted later than the expiration date of the
existing permit.) [40 CFR 122.21(d)]. Any permittee that has not requested renewal at least 180 days
prior to expiration, or any permittee that does not have a permit after the expiration and has not
requested renewal at least 180 days prior to expiration, will be subjected to enforcement procedures
as provided in NCGS §143-215.36 and 33 USC 1251 et. seq.
Part III Page 3 of 9

Permit No. NCS000562
2. Transfers
This permit is not transferable to any person without prior written notice to and approval from the
Director in accordance with 40 CFR 122.61. The Director may condition approval in accordance with
NCGS 143-21S.1, in particular NCGS 143-215.1(b)(4)b.2., and may require modification or revocation
and reissuance of the permit, or a minor modification, to identify the new permittee and incorporate
such other requirements as may be necessary under the CWA [40 CFR 122.41(1)(3), 122.61] or state
statute. The Permittee is required to notify the Division in writing in the event the permitted
facility is sold or closed.
3. Si nato Re uirements
All applications, reports, or information submitted to the Permitting Issuing Authority shall be signed
and certified [40 CFR 122.41(k)].
a. All permit applications shall be signed as follows:
(1) For a corporation: by a responsible corpora
responsible corporate officer means: (a) a
the corporation in charge of a principal bus
similar policy or decision making functions
more manufacturing, production, or opera
to make management decisions which gone
having the explicit or implicit duty of makir
and initiating and directing other compre i(
environmental compliance with environme
ensure that the necessary systems are 4stal
accurate information for pern3itlapplicati6"T
documents has been•assignedlor delegated
procedures.
ite offi `r",F` r the purpose of this Section, a
)resident, secr`tary,,treasurer or vice president of
lnessfunction, or -any other person who performs
for the corporation, or (b) the manager of one or
irig.failities, provided, the manager is authorized
r` t' 0� -ration of the regulated facility including
`g ma�o� capital investment recommendations,
:nsive•measures to assure long term
nt'al laws and regulations; the manager can
dished or actions taken to gather complete and
i requirements; and where authority to sign
to the manager in accordance with corporate
(2) For a partnership pr��etorship: by a general partner or the proprietor, respectively;
or [// //rr
(3) For a municipality, State, Federal, or other public agency: by either a principal executive
officer or ranking elected official [40 CFR 122.22].
b. All reports required by the permit and other information requested by the Permit Issuing
Authority shall be signed by a person described in paragraph a. above or by a duly authorized
representative of that person. A person is a duly authorized representative only if:
(1) The authorization is made in writing by a person described above;
(2) The authorization specified either an individual or a position having responsibility for the
overall operation of the regulated facility or activity, such as the position of plant manager,
operator of a well or well field, superintendent, a position of equivalent responsibility, or an
individual or position having overall responsibility for environmental matters for the company.
(A duly authorized representative may thus be either a named individual or any individual
occupying a named position.); and
(3) The written authorization is submitted to the Permit Issuing Authority [40 CFR 122.22]
c. Changes to authorization: If an authorization under paragraph (b) of this section is no longer
accurate because a different individual or position has responsibility for the overall operation of
the facility, a new authorization satisfying the requirements of paragraph (b) of this section must
be submitted to the Director prior to or together with any reports, information, or applications to
be signed by an authorized representative [40 CFR 122.22]
Part III Page 4 of 9

Permit No. NCS000562
a
d. Certification. Any person signing a document under paragraphs a. or b. of this section shall make
the following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION WILL
BE ACCEPTED:
"1 certify, under penalty of law, that this document and all attachments were prepared under my
direction orsupervision in accordance with a system designed to assure that qualified personnel
properlygather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible forgathering the information,
the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I
am aware that there are significant penalties forsubmitting false information, including the
possibility of fines and imprisonment far knowing violations. "
Permit Modification, evocatiQnand Reissuance. or Termination
The issuance of this permit does not prohibit the Permit Issuing Authority from reopening and
modifying the permit, revoking and reissuing the permit, or termiriating the permit as allowed by the
laws, rules, and regulations contained in Title 40, Code.of Federa Regulations, Parts 122 and 123;
Title 15A of the North Carolina Administrative Code lSubchapter 2H.010 0; and North Carolina
General Statute 143-215.1 et al.
Permit Action
The permit may be modified, revoked and reissued -,or terminated for cause. The notification of
planned changes or anticipated noncompliance does\not stay any permit condition [40 CFR
122.41(0]- _ /
The permittee must pay the`
after being billed by the Divis
NCAC 2H .0105(b)(2) may ca
�3Xill�fl (iP►[1W17»11M.NNU110F.1►111d►;1 ImP
1.
and•cpmpliance monitoring fee within 30 (thirty) days
J,pay the fee in timely manner in accordance with 15A
ion to initiate action to revoke the permit.
CE OF POLLUTION CONTROLS
The permittee shall at all times properly operate and maintain all facilities and systems of treatment
and control (and related appurtenances) which are installed or used by the permittee to achieve
compliance with the conditions of this permit. Proper operation and maintenance also includes
adequate laboratory controls and appropriate quality assurance procedures. This provision requires
the operation of back-up or auxiliary facilities or similar systems which are installed by a permittee
only when the operation is necessary to achieve compliance with the conditions of this permit [40
CFR 122.41(e)].
Need to Halt or Reduce Not a Defense
It shall not be a defense for a permittee in an enforcement action that it would have been necessary to
halt or reduce the permitted activity in order to maintain compliance with the condition of this permit
[40 CFR 122.41(c)].
Bypassing of.StQrmwater Control Facilities
Bypass is prohibited and the Director may take enforcement action against a permittee for bypass
unless:
a. Bypass was unavoidable to prevent loss of life, personal injury or severe property damage; and
b. There were no feasible alternatives to the bypass, such as the use of auxiliary control facilities,
retention of stormwater or maintenance during normal periods of equipment downtime or dry
weather. This condition is not satisfied if adequate backup controls should have been installed in
Part III Page 5 of 9

Permit No. NCS000S62
the exercise of reasonable engineering judgment to prevent a bypass which occurred during
normal periods of equipment downtime or preventive maintenance; and
c. The permittee submitted notices as required under, Part III, Section E of this permit.
If the Director determines that it will meet the three conditions listed above, the Director may
approve an anticipated bypass after considering its adverse effects.
�Wwtl[elm IAS[1]01 IFTi Il:il►[el�►l7:�xKil:��y
Representative Sampling
Samples collected and measurements taken, as required herein, shall be characteristic of the volume
and nature of the permitted discharge. Analytical sampling shall be performed during a measureable
storm event. Samples shall be taken on a day and time that is characteristic of the discharge. All
samples shall be taken before the discharge joins or is diluted,by any other waste stream, body of
water, or substance. Monitoring points as specified in this pe tbt� hall not be changed without
notification to and approval of the Permit Issuing Authority[40,CFR>122.41(j)].
Recording Results
For each measurement or sample taken pursuant.to,the requirements of this permit, the permittee
shall record the following information [40 CF114-2-2.4t].
a. The date, exact place, and time of sampling ormeasurements;
b. The individual(s) who performed the sampling,or measurements;
C. The date(s) analyses were performed;
1-1 \ \ \
d. The individual(s) who performed the analyses;
e. The analytical tech niq for m`ethods•used; and
f. The results of such ana'lvses. 1
Flow Measurements
Where required, appropriate flow measurement devices and methods consistent with accepted
scientific practices shall be selected and used to ensure the accuracy and reliability of measurements
of the volume of monitored discharges.
4. Test Procedures
Test procedures for the analysis of pollutants shall conform to the EMC regulations published
pursuant to NCGS 143-215.63 et seq, the Water and Air Quality Reporting Acts, and to regulations
published pursuant to Section 304(g), 33 USC 1314, of the Federal Water Pollution Control Act, as
Amended, and Regulation 40 CFR 136.
To meet the intent of the monitoring required by this permit, all test procedures must produce
minimum detection and reporting levels and all data generated must be reported down to the
minimum detection or lower reporting level of the procedure. If no approved methods are
determined capable of achieving minimum detection and reporting levels below permit discharge
requirements, then the most sensitive (method with the lowest possible detection and reporting
level) approved method must be used.
Representative Outfall
If a facility has multiple discharge locations with substantially identical stormwater discharges that
are required to be sampled, the permittee may petition the Director for representative outfall status.
If it is established that the stormwater discharges are substantially identical and the permittee is
granted representative outfall status, then sampling requirements may be performed at a reduced
number of outfalls.
Part III Page 6 of 9

Permit No. NCS000562
6. Records Retention
Visual monitoring shall be documented and records maintained at the facility along with the
Stormwater Pollution Prevention Plan. Copies of analytical monitoring results shall also be
maintained on -site. The permittee shall retain records of all monitoring information, including
o all calibration and maintenance records,
o all original strip chart recordings for continuous monitoring instrumentation,
o copies of all reports required by this permit,
o copies of all data used to complete the application for this permit
These records or copies shall be maintained for a period of at least 5 years from the date of the
sample, measurement, report or application. This period may be extended by request of the Director
at any time [40 CFR 122.41].
Inspection and Entry
The permittee shall allow the Director, or an authorized representative (including an authorized
contractor acting as a representative of the Director); or in the case of a facility which discharges
through a municipal separate storm sewer system, an authorized representative of a municipal
operator or the separate storm sewer system receiving'the discharge upon the presentation of
credentials and other documents as maybe require_d_'by, laaw, to:
a. Enter upon the permittee's premises whe
or where records must be kept under the,
b. Have access to and copy, at reasonable`tiifr
of this permit; ^01,
cility or activity is located or conducted,
s permit;
that must be kept under the conditions
c. Inspect at reasonable times any facilities, equipment (including monitoring and control
equipment), practices, or operations regulated or required under this permit; and
d. Sample or monitor at reas cable times, for the purposes of assuring permit compliance or as
otherwise authorized by/,the Clean Water Act, any substances or parameters at any location [40
CFR 122.41(i)].
SECTION E: REPORTING RE
1. Discharge Monitoring Reports
Samples analyzed in accordance with the terms of this permit shall be submitted to the Division on
Discharge Monitoring Report (DMR) forms provided by the Director. DMR forms are available on the
Division's website (http://portal.ncdenr.org/web/wq/ws/su/npdessw). Submittals shall be
delivered to the Division no later than 30 days from the date the facility receives the sampling
results from the laboratory.
When no discharge has occurred from the facility during the report period, the permittee is required
to submit a discharge monitoring report, within 30 days of the end of the specified sampling period,
giving all required information and indicating "NO FLOW" as per NCAC T1SA 02B .0506.
if the permittee monitors any pollutant more frequently than required by this permit using test
procedures approved under 40 CFR Part 136 and at a sampling location specified in this permit or
other appropriate instrument governing the discharge, the results of such monitoring shall be
included in the data submitted on the DMR.
The permittee shall record the required qualitative monitoring observations on the SDO Qualitative
Monitoring Report form provided by the Division and shall retain the completed forms on site.
Qualitative monitoring results should not be submitted to the Division, except upon DWQ's specific
requirement to do so. Qualitative Monitoring Report forms are available at the website above.
Part III- Page 7 of 9

Permit No. NCS000562
Submitting Reports
Two signed copies of Discharge Monitoring Reports (DMRs) shall be submitted to:
Central Files
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
3. Availability of Reports
Except for data determined to be confidential under NCGS 143-215.3(a)(2) or Section 308 of the
Federal Act, 33 USC 1318, all reports prepared in accordance with the terms shall be available for
public inspection at the offices of the Division. As required by the Act, analytical data shall not be
considered confidential. Knowingly making any false statement on -any such report may result in the
imposition of criminal penalties as provided for in NCGS 143'215�'613 or in Section 309 of the Federal
Act.
4. Non-stormwater Discharges
If the storm event monitored in accordance with this, permit coincides with a non-stormwater
discharge, the permittee shall separately monitor all.parame ers as required under all other
applicable discharge permits and provide this in ormation With the stormwater discharge monitoring
report.
S. Planned Changes
The permittee shall give notice to the Directoras,soon as possible of any planned changes at the
permitted facility which could,significantly-alter the nature or quantity of pollutants discharged [40
CFR 122.41(1)]. This notification requirement includes pollutants which are not specifically listed in
the permit or subject to notification�requirements under 40 CFR Part 122.42 (a).
11
The permittee shall give advanc6�notice to the Director of any planned changes at the permitted
facility which may resulE ln•noncompliance with the permit [40 CFR 122.41(1)(2)].
7. Spills
The permittee shall report to the local DWQ Regional Office, within 24 hours, all significant spills as
defined in Part IV of this permit. Additionally, the permittee shall report spills including: any oil spill
of 25 gallons or more, any spill regardless of amount that causes a sheen on surface waters, any oil
spill regardless of amount occurring within 100 feet of surface waters, and any oil spill less than 2S
gallons that cannot be cleaned up within 24 hours.
8. pass
Notice [40 CFR 122.41(m)(3)1:
a. Anticipated bypass. If the permittee knows in advance of the need for a bypass, it shall submit
prior notice, if possible at least ten days before the date of the bypass; including an evaluation of
the anticipated duality and affect of the bypass .
b. Unanticipated bypass. The permittee shall submit notice within 24 hours of becoming aware of
an unanticipated bypass.
Twenty-four Hour Reporting
a. The permittee shall report to the central office or the appropriate regional office any
noncompliance which may endanger health or the environment. Any information shall be
provided orally within 24 hours from the time the permittee became aware of the circumstances.
A written submission shall also be provided within 5 days of the time the permittee becomes
aware of the circumstances.
Partill Page 8 of 9

Permit No. NCS000562
The written submission shall contain a description of the noncompliance, and its causes; the
period of noncompliance, including exact dates and times, and if the noncompliance has not
been corrected, the anticipated time compliance is expected to continue; and steps taken or
planned to reduce, eliminate, and prevent reoccurrence of the noncompliance [40 CFR
122.41(1)(6)].
b. The Director may waive the written report on a case -by -case basis for reports under this section
if the oral report has been received within 24 hours.
c. Occurrences outside normal business hours may also be reported to the Division's Emergency
Response personnel at [phone], [phone] or [phone].
10, Other N2ncompliance
The permittee shall report all instances of noncompliance not 4ported under 24 hour reporting at
the time monitoring reports are submitted [40 CFR 1,22 41(I)[7}].
11. Other Inf rmati n
� v/
Where the Permittee becomes aware that it failed to submit -any relevant facts in a permit application,
or submitted incorrect information in a permit applitation,op n any report to the Director, it shall
promptly submit such facts or information [4,OICFR 122AJ:{I)[8}].
Part III Page 9 of 9

NCS000562
4.
PART IV DEFINITIONS
Act
See Clean Water Act.
Adverse Weather
Adverse conditions are those that are dangerous or create inaccessibility for personnel, such as local
flooding, high winds, or electrical storms, or situations that otherwise make sampling impractical.
When adverse weather conditions prevent the collection of samples during the sample period, the
permittee must take a substitute sample or perform a visual assessment during the next qualifying
storm event. Documentation of an adverse event (with date, time and written narrative) and the
rationale must be included with your SPPP records. Adverse weather does not exempt the permittee
from having to file a monitoring report in accordance witli the•sampling schedule. Adverse events and
failures to monitor must also be explained and reported on the relevant DMR.
Allowable Non-Stormwater Discharges
This permit regulates stormwater discharge,. on-stormwater /St'0'rmwaterNPDES
discharges which shall be allowed in
the stormwater conveyance system are: J� �
a. All other discharges that are authorized by,nonpermit.
b. Uncontaminated groundwater, foundationldrains, air -conditioner condensate without added
chemicals, springs, discharges of uncontaminated potable water, waterline and fire hydrant
flushings, water from f) ngdralris, flaws from riparian habitats and wetlands.
c. Discharges resulting fro m,fire-fighting or fire -fighting training, or emergency shower or eye wash
as a result of use in the even of an emergency.
Measures or practices used'to-Ceduce the amount of pollution entering surface waters. BMPs may
take the form of a process; activity, or physical structure. More information on BMPs can be found at:
http;//cfpub.epa.gov/npdes/stormwater/menuofbmps/index.cfm.
S. Bypass
A bypass is the known diversion of stormwater from any portion of a stormwater control facility
including the collection system, which is not a designed or established operating mode for the facility.
6. Bulk Storage of Liquid Products
Liquid raw materials, manufactured products, waste materials or by-products with a single above
ground storage container having a capacity of greater than 660 gallons or with multiple above ground
storage containers located in close proximity to each other having a total combined storage capacity
of greater than 1,320 gallons.
7. Certificate of Coverage
The Certificate of Coverage (COC) is the cover sheet which accompanies a General Permit upon
issuance and lists the facility name, location, receiving stream, river basin, effective date of coverage
under the permit and is signed by the Director.
8. Clean Water Act
The Federal Water Pollution Control Act, also known as the Clean Water Act (CWA), as amended, 33
USC 1251, et. seq.
9. Division or DWO
The Division of Water Quality, Department of Environment and Natural Resources.
Part IV Page 1 of 4

Permit No. NCS000562
10. Directo
The Director of the Division of Water Quality, the permit issuing authority.
11. EMC
The North Carolina Environmental Management Commission.
12. Grab Sample
An individual sample collected instantaneously. Grab samples that will be analyzed (quantitatively or
qualitatively) must be taken within the first 30 minutes of discharge.
13. Hazardous Substance
Any substance designated under 40 CFR Part 116 pursuant to Section 311 of the Clean Water Act.
14, Landfill
A disposal facility or part of a disposal facility where waste is pdd in or on land and which is not a
land treatment facility, a surface impoundment, an injectiomwell;,a hazardous waste long-term
storage facility or a surface storage facility. �{
15. Measureable Storm Event
101
A storm event that results in an actual discharge
measurable storm event must have been at least
apply if the permittee is able to document that a
events during the sampling period, and obtains,a
copies of this information and a written:reques&
After authorization by the D,WQ \i\1,Office,..
permittee's SPPP. K
the,peimitted site outfall. The previous
�Urs prior. The 72-hour storm interval may not
�r interval is representative for local storm
@ from the local DWQ Regional Office. Two
shall be sent to the local DWQ Regional Office.
ten approval letter must be kept on site in the
A stormwater collectio system wit ih an incorporated area of local self-government such as a city or
town.
17. No Exposure
A condition of no exposure means that all industrial materials and activities are protected by a storm
resistant shelter or acceptable storage containers to prevent exposure to rain, snow, snowmelt, or
runoff. Industrial materials or activities include, but are not limited to, material handling equipment
or activities, industrial machinery, raw materials, intermediate products, by-products, final products,
or waste products. DWQ may grant a No Exposure Exclusion from NPDES Stormwater Permitting
requirements only if a facility complies with the terms and conditions described in 40 CFR
§122.26(g).
1& Notice of Intent
The state application form which, when submitted to the Division, officially indicates the facility's
notice of intent to seek coverage under a General Permit.
19. Permit Issuing Authority
The Director of the Division of Water Quality (see "Director" above).
20. Permittee
The owner or operator issued this permit.
Part IV Page 2 of 4 Pages

Permit No, NCS000562
21. Point Source Discharge of Stormwater
Any discernible, confined and discrete conveyance including, but not specifically limited to, any pipe,
ditch, channel, tunnel, conduit, well, or discrete fissure from which stormwater is or may be
discharged to waters of the state.
22. Representative Outfall Status
When it is established that the discharge of stormwater runoff from a single outfall is representative of the
discharges at multiple outfalls, the DWQ may grant representative outfall status. Representative outfall status
allows the permittee to perform analytical monitoring at a reduced number of outfalls.
23. Secondary Containment
Spill containment for the contents of the single largest tank within the containment structure plus
sufficient freeboard to allow for the 25-year, 24-hour storm event.
24. Section 313 Water Priority Chemical
A chemical or chemical category which:
b. Is listed in 40 CFR 372.65 pursuant to Section 313 of Title III of -the S perfund Amendments and
Reauthorization Act (SARA) of 1986, also titled the'Emergency-Planning and Community Right -
to -Know Act of 1986; %
25.
c. Is present at or above threshold levels at a
requirements; and
d. Meets at least one of the following criteria
i. Is listed in appendix D of 40 CFR,Oai
(certain metals, cyanides, any phei
substances); � ��
ii. Is listed as a hazar-daus,sub�ln e o
116.4, or
iii. Is a pollutant
SARA title I11, Section 313 reporting
Table II (organic priority pollutants), Table III
ble IV (certain toxic pollutants and hazardous
rsuant to section 311(b)(2)(A) of the CWA at 40 CFR
published acute or chronic water quality criteria.
Substantial physical dar'nage-to-property, damage to the control facilities which causes them to
become inoperable, or substantial and permanent loss of natural resources which can reasonably be
expected to occur in the absence of a bypass. Severe property damage does not mean economic loss
caused by delays in production.
26. Significant Materials
Includes, but is not limited to: raw materials; fuels; materials such as solvents, detergents, and plastic
pellets; finished materials such as metallic products; raw materials used in food processing or
production; hazardous substances designated under section 101(14) of CERCLA; any chemical the
facility is required to report pursuant to section 313 of Title III of SARA, fertilizers; pesticides; and
waste products such as ashes, slag and sludge that have the potential to be released with stormwater
discharges.
27. Significant Spills
Includes, but is not limited to: releases of oil or hazardous substances in excess of reportable
quantities under section 311 of the Clean Water Act (Ref: 40 CFR 110.3and 40 CFR 117.3) or section
102 of CERCLA (Ref: 40 CFR 302.4).
28. Stormwater Discharge Outfall (SDO)
The point of departure of stormwater from a discernible, confined, or discrete conveyance, including
but not limited to, storm sewer pipes, drainage ditches, channels, spillways, or channelized collection
areas, from which stormwater flows directly or indirectly into waters of the State of North Carolina.
Part IV Page 3 of 4 Pages

Permit No. NCS000562
29, Stormwater Runoff
The flow of water which results from precipitation and which occurs immediately following rainfall
or as a result of snowmelt.
30. Stormwater Associated with Industrial Activity
The discharge from any point source which is used for collecting and conveying stormwater and
which is directly related to manufacturing, processing or raw material storage areas at an industrial
site. Facilities considered to be engaged in "industrial activities" include those activities defined in 40
CFR 122.26(b)(14). The term does not include discharges from facilities or activities excluded from
the NPDES program.
31. Stormwater Pollution Prevention Plan
A comprehensive site -specific plan which details measures and practices to reduce Stormwater
pollution and is based on an evaluation of the pollution potential of the site.
32. Total Maximum Daily Load (TMDQ � �,_, �
TMDLs are written plans for attaining and maintaining water quality -standards, in all seasons, for a
specific water body and pollutant. A list of approved TMDLs for the,s{ate of North Carolina can be
found at htto://nortaimcdenr.ore/web/wa/ns/M[U/t,tdl.
33. Toxic Pollutant �v
Any pollutant listed as toxic under Section 307(a)(1) or the Clean Water Act.
34. Vehicle Maintenance Activity ��
Vehicle rehabilitation, mech`mcal repairs, painting, fueling, lubrication, vehicle cleaning operations,
or airport deicing operations.
3S. Visible Sedimentation
Solid particulate matter, both mine �/11 'and organic, that has been or is being transported by water, air,
gravity, or ice from its site of origin -which can be seen with the unaided eye.
36. 25-year. 24 hour Storm -Event
The maximum 24-hour precipitation event expected to be equaled or exceeded, on the average, once
in 25 years.
Part IV Page 4 of 4 Pages

NCS000562
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles WakiId, P.E.
Governor Director
Facility Name:
NPDES Permit Number:
Facility Location:
Type of Activity:
SIC Code:
Receiving Streams:
River Basin:
Stream Classification & condition
Proposed Permit Requirements:
Monitoring Data:
Response Requested by:
Central Office Staff Contact:
Special Permitting Issues:
STAFF REVIEW AND EVALUATION
NPDES Stormwater Permit
Dee Freeman
Secretary
Rutherford County Production Facility, Horsehead Corporation owner
NCS000562
US 221, south of Forest City, NC, Rutherford County
High purity zinc recovery from waste material
3341
Broad River, see Figure l
Broad River Basin, Sub -basin 03-08-02
Class C, no TMDL, no 303(d)
See attached draft permit.
New permit, no historical data exists.
July 16, 2012
Return to: Ken Pickle, [phone]
Risk considerations
Rating Scale: 1 minimal risk to 10 risk factors resent
Compliance history
No history: rate 1
Benchmark exceedance
A new site, with no past measurements: rate 1
Location (TMDL, T&E species, etc)
Downstream benthos impaired; downstream WS-1V and WS-1V CA:
rate 6
Other factors:
Other factors in aggregate present larger than normal risks for most
• Zinc solutions, lead, and acids
industrial sites: rate 10
present.
• Industry is unique in NC, no other
similar facilities.
• A start-up facility.
• Multiple tanks & containments,
rail unloading, potential for
process fluids to be exposed.
• Avoiding heavy metal solutions
discharges depends on proper
operator actions to a larger than
normal degree.
Risk and DWQ scrutiny rating:
18/40 - moderate stormwater pollution risks
Page 1 of 4

NCS000562
Description of Onsite Activities:
• Horsehead receives waste zinc material, and refines it into a high purity product. Byproducts are
secondary in importance, including -minor amounts of lead and silver production.
Documents Reviewed:
• NPDES stormwater permit application materials, received in final form May 8, 2012.
• US Fish and Wildlife Service threatened and endangered species inventory for Rutherford County
• Natural Heritage Program staff reports no rare aquatic species in the Broad River in this vicinity.
• EPA Sector -Specific Permit, 2008. SIC 3341 covered, but no benchmarks assigned.
• Integrated Report 303(d) List, 2010 final: upstream WS-IV and downstream WS-IV and CA impaired
for aquatic life, but the actual receiving reach is classified C and is not listed.
• July 2008 Broad River Basinwide Plan: no comment on this site; in 2008 the receiving water is shown
as supporting its classified uses.
History:
• First time stormwater permit application.
• First time NPDES wastewater permit issued Nov. 11, 2011, NC0089109.
Figure l: Map of Facility
A� r •�' c Fes•
1{"F Horsehead Corporation I i,Sr�r,
'r . r� 1 rt. . r's.� � �• s�� r � r �t` �_ 1 � �
rill
} cfi� � �`• 1� 9 : � � }
\ � r'�• ��€gyp', �! � ` .� .r:
Page 2 of 4

' r
NCS000562
Recommendations: Based on application materials received on March 28, 2012; and again on April 2; and again on
May 8, SPU considers the combined application materials sufficient to issue an individual Stormwater Permit. We
are requesting Regional Office review comments, and full or qualified concurrence.
Prepared by (Signature) Signature of Ken Pickle Date
Stormwater Permitting Unit Supervisor ditto Date
for Bradley Bennett
Concurrence by Regional Office &4— Date i
RO Water Quality Supervisor Date ! a
Regional Office Staff Comments (attach additional pages as necessary)
The ARO/SWPS offers the following comments on the draft permit:
1. Require Horsehead Corporation to have the Stormwater Pollution Prevention Plan (SWPPP) in place prior to start-
upof operations. Due to the complexity of the operations (crud that the operation does not fall under a general permit
for a known industrial sector), the ARO believes it is prudent to have the SWPPP in place at the time of industrial
operations.
2. The "back up " plan for potential fail ureslproblems with the detention basins/recycle loop system should be stated
within the SWPPP. If a failure occurs, will this be a pump and haul situation? Will this bean operational shut down?
Horsehead needs to state what actions will be taken should these problems occur.
This is especially important to the ARO because, due to state legislation passed in 2011 fref. Session Law 2011-394,
Sec. 9], it is ARO's understanding that the requirements for Authorization to Construct Permitting were repealed for
industrial peromits of this nature. Therefore, we cannot require the company to provide specific information on
detention times for the various basins proposed.
3. Upon review of the wastewater permit, and subsequent review of the stormwater draft permit, ARO recommends that
chlorides be added to the quarterly monitoring. Chlorides are toxic to aquatic life, difficult to treat, and may be present
in the stormwater as well.
4. ARO recommends that quarterly acute toxicity testing (or the most appropriate toxicity testing) be required in the
permit (please contact Carol Hollenkamp of ATU for specific language to use in the permit). This testing is
recommended as it mimics the synergistic effects of the stormwater discharge and its potential effect on the receiving
stream.
5. ARO would not object to conditional language being placed in the permit to state (basically), that, after 3 years of
successful quarterly data has been collected (under bench marks and toxicity passes ), monitoring may be reduced to
semi-annually. Three years of data, after the beginning ofprocess operations, should be sufficient to determine if
measures are working successfully.
Page 4 of 4

NCS000562
Central Office Review Summary:
1. Owner's Other Permits:
o NCO089109 issued for wastewater discharges. Permit limits on Q, Cd, F, Pb, pH. Monitoring w/o
limits on TSS, NH3, Al, Sb, As, Cl, Cr, Co, Cu, Fe, Ni, Sri, Zn. Also Chronic Toxicity and NTU.
2. General Observations: New, large site with no history. On -site zinc solutions are materials of primary concern.
3. Impairment: Receiving water not listed as impaired on 303(d) IR.
4. Threatened and Endangered: None identified by USF&WS website; NHP staff contact reports no rare aquatic
species in the Broad River in this vicinity. ti
S. Location: Close to Brice in southern Rutherford County, on the south bank of the Broad River. Site elevation
relative to the Broad River discharge point suggests encrgy dissipation concerns for stormwater flows.
6. Industrial Changes Since _Previous Permit: New permit, no changes.
7. Analytical Monitoring Notes: Quarterly monitoring.
8. Qualitative Monitoring Notes: Quarterly visual monitoring.
Permit Recommendations: Analytical Monitoring
1. Analytical monitoring has been set to quarterly during a measurable storm event as defined in Part I1 Section B.
The recommended quarterly monitoring is more frequent than most standard industrial stormwater permits.
This facility handles heavy metal solutions, and is without a track record of performance in North Carolina.
Quarterly sampling is recommended in response to the increased risk factors noted above. DWQ can consider
reducing the sampling frequency later in the permit term if supported by subsequently collected data.
2. The permittee must document the total precipitation for each sampled event. If no discharge occurs during the
sampling period, the permittee must submit a monitoring report indicating "No Flow" within 30 days of the end
of the three-month sampling period.
3. Analytical monitoring parameters:
a. Metals: Zinc, lead, silver. Based on Zn solutions on site; based on identification of Pb as a secondary
byproduct; Ag chosen for very low benchmarks and as a surrogate for all other heavy metals potentially
present. Ag reported as expected to be present and recovered in very small amounts.
b. Organics: TPH, based on significant on -site presence of kerosene or kerosene -like petroleum product as
the solvent vehicle for DEHPA, a key process ingredient.
c. Conventional pollutants: TSS, pH, TN, TP. Nutrients based on N and P compounds reported as
present in the manufacturing process.
4. Benchmarks are included for all analytical parameters. Exceedances of benchmark values require a response
action from the permittee in a tiered program. If the sampling results are above a benchmark value, then the
facility shall follow the Tier 1 guidelines which require a facility inspection within two weeks and if feasible,
implementation of a mitigation plan within two months. If during the term of this permit, the sampling results
are above the benchmark values, or outside of the benchmark range, for any specific parameter at the discharge
outfall two times in a row (consecutive), then the facility shall follow the Tier 2 guidelines which require a
repetition of the steps listed for Tier I and shall also immediately institute monthly monitoring for all parameters
at every outfall where a sampling result exceeded the benchmark value for two consecutive samples.
5. Qualitative monitoring also must be accomplished during a measureable storm event.
6. Vehicle maintenance area monitoring is not applicable since this facility will have only one stormwater outfall.
7. The permittee is required to continue monitoring until the permit is renewed. See Footnote I of Table 2.
Discussions with permittee: DWQ met with Tim Basilone, Horsehead Vice President, and with Forrest Westall,
consultant, in an initial meeting, a follow-up meeting prior to application submittal, and a meeting subsequent to the
initial submittal of application materials. In addition, email correspondence was used to request additional
information on the proposed project.
Page 3 of 4

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vi�,5 IV C 4o 09109
Individual Permits eview Process
1) Individual Permit Applications:
dale
a) Review (Application, s , company contact info, old-permit-€rout-Ster-fflveatei�
P his -Unit-�SPI�}-Fileg correspondence, ` -`� d Files; Basinwide Plan,-4n+i6r-
pe its; -etc-). See the flags table in Appendix D for guidance. Cp/al,,�, t
b) Permit Types:
i) Renewal: �a�d-a-rertewa-l-applicatiort—. �" �P "� !� �d �ou.,�e�
for �ur6,�i�y G�
ii) New: The applicant should fill out EPA Form 1 and EPA Form 2F. These orms ✓✓
(http://h2o.enr.state.nc.us/su/Forms Documents.litm) require composite sampling, but
the State does not. Also,
inform the applicant to send the form to us, rather than to the address listed on the
form itself.
2) Update BIMS* (and later steps with *).
3) Request additional information from applicant if necessary (allow 2 weeks). (*)
4) Mark front of folder if permit includes wastewater discharge to SA or WS waters. �
S) Draft permit using the guidance about items to look for Appendix D and appropriate
benchmarks to set in Appendix E. (*)
6) Send draft to peer review, then to SPU Supervisor (or delegated SPU member) for Staff
Report Request signature.
7) Request a Staff Report from Regional Office by mail or email. Attach draft permit and copy
of application. Allow about 30 days. (*)
8) For major permits, send draft permit to EPA at same time as Staff Report Request. Major
permits are only Phase I municipalities. All others are minor.
9) For SA waters (when WW discharge), request DEH (Shellfish Sanitation) input at same time
as Staff Report Request.
10) For WS waters (when WW discharge), request DEH (Regional WS Supervisor) input after
comments received from Region. (DEH may consult the regional staff).
11) After response(s) received, consider comments and revise draft as appropriate. Update BIMS
and print Permit Tracking Sheet. (*)
12) Prepare draft permit for Notice and permittee's review (See attached Notice schedule). Public
notice and permittee review should happen simultaneously. Prepare a cover letter that
identifies/explains reasons for any monitoring (or other significant) changes from the
previous permit. Give to Processing Assistant no later than internal `To Notice' deadline and
r [ 1✓ �
W 51 V

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

< < is
4
Issue/Flag
Action/ Guidance-
_ for Renewal-,
Analytical Monitoring:
nsure Semi -Annual monitoring (schedule over calendar year) during
General
storm event. No longer Spring and Fall (change in 2007),3
sip r
Analytical Monitoring:
For each parameter (except pH), if
contam4t Lien-5Al�-es� (See-Benthrn�rl
all values < benchmark
ATpendWE:) 1 i ific-rnorriterir�g-(but lot A
concentration.
_.bc=hrn and Basinwide Plan recommendations, ion-
' really-precess-�ast�water (e-g--elevetEd
ammonia); even-t#tbelow-benchmarks: Why -was -parameter a-POGin-the.fmsL
*4ee2-
� eep� pH monitoring regardless ecause (1) pH is important to
interp�rettng other data(s_ulch as ammonia), and (2) pH is a useful indicator of
contaminants that may not be monitored. pH also easy to monitor.
EPA -Sector -Specific Guidance:
• Determine the type of business that the facility (talk to the applicant if
it is notin the files).
■ Determiner at the SIC code would be and look it up online:
http://www.osh-a-.sov/pls/imis/siesearch.html
■ Use this EPA list as gui a tential chemicals that they may
need to monitor. This is only a guide, the Statehas its own
benchmarks. (Note that this link is the 2000 version 2006 version
is proposed.): http://www.epa.gov/npdes/pubs/msgp2 _aII-
propose d. df
�eal�Vlorrttarin�
LQ-aLat-the-uaozitQring_requirements-Rg-the-ge a ernnne-i€
1A ,�idaal+pe x-is similar_tc�
thexe- re-any-of-these•that-may-be•pertinent•to-add-to-the individual -permit -for
_a-general.pexmiLcategory but -does—
the.facility..These•parameters-are-often-diffe-rentYfrom-the -Fi,,P-A parafneters:
AaLEXAZPL-rY-ftt.: .
Ktep-rrroWi ortn� gin (revise to Seuu=Annuall): Typically-teo•few-samples-
-For-each-parameter; if
collected.during-the•permit-term-remove-monitoring'ba"sed on` an average,
-any-values>-benchmark.(or_beiow,
par6cu arl-y-given-sporadic-nature-of-rainfall-(See-Benchmdrk'ConceT n' ations
as•in•case-df pH)—
in A endix.E.. Increase-fre uene -if Jelin uent or -other roblenr—
-A-nalyriraf *fon tering-and-Secondary
TRl-Sites:
snm nt:
• Geogle T-RI-•Maps:-htt ://_t,%,�vw.turbo eri.com/goo.u-IeLTRI NC.htm
-check-the TRl-(toxie-release
. r„Ep.A pTIS h t wvvw.e a- s- otis
-inventoryy)•databases.to.check
9�—TOX-ma P
-permits -for -each-facility,(CAA,
htfip:l�toxmaa'fltm'rlihwctov/toxmap/.combo%triEden#E#v.do
-GWA;-RGRA EEC-
PRA permits);,
. e-EPA Envi ofacts•Site:.htt p : p www:e a ov envirofw
.S.ICcodes, lat/Iong,-address; and
,—Environ- mentaf Defense fund's-Chemical -Scorecard:
ireteases ofcfiemicals by'facility
w w scoreeard:orq
andLor loeatior},r
•—See'documem: S'\Guidance\Seeondary,Containment.�How to ggt�d, ata
-
r' from TRI-databases
D-1

Issue/Flag '
Action/Guidance
for Renewal
Analytical Monitoring and Secondary
. We require secondary containment of chemicals in this,lisrin a y amount.
Containment;
0 See: http://ecfr.gpoaccess.gov/cgi/t/text/.text+
Check these lists see if you have
idx?t e=sim le c=ecfr•cc=ecfr id= 576cd105ef93e5 Oc 45c2d4a 249ff-,
re ion=DIV1 l=EPC r n=div5 view=text•idno=40•node=40° 3A27.
TRI chemicJals' ound on the
0.1.1.13
PCRA Water Priority
SAEtion
ChList (EPCRA, 40 CFR,
• _See S;\Guidance\Secondary Containment\SARA EPCRA Water
13, Part 372.65)
PriorityChemicals List.xls
Analytical Monitoring and Sec �ry
• We require secondary containment of chemicals in this -list in any amount.
Containment.'
. See: http://ecfr.P-poaccess.gov/cgi/t/text/`text"'
Check these lists t ee if you have
idx?c=ecfr&sid=fOOfdbec43cb0605b6t7742a5785e419&ran=div5&view=t
ext&node=40:2I.0.1.1.9&idno=40
chemicals lisle on the Clean
Water Act -Hazardous Substance
A spreadsheet- of ihese chemicals can be found at:
List (CaWA, 40 CFR, Section 311,
cS:\Guidance\Secondary Containment\CWA Hazardous Substances.xls
Part 116.4
Hazardous Waste.- Haz Waste
You may want to check and see what hazardous wastes have been reported -to
Spill Information Report'
local Fire Departments, and if there have been any spills.reported
Please see contact list S:\Guida�econdary Containment\Fire
Departments with Haz Waste' nfP� ormation.doc
Pleasd-to'[his FD list as you get more contact information.
-Discharge to NSW (except Neuse
f site has not monitored for nutrients in the past, ensure TN•&'TP monitoring
for TN and Tar -Pamlico for
(Semi -Annual). If TN/TP already in permit and nurtibers don't indicate
and TP waters)
nutrient problem (see Benchma�Conc rtof ns for guidance, Appendix E),
consider removing.
if is menite-." beeause it dFains te NSW, de
site only net
Revision on 3/5/08:
Bench s arguably still be appropriate - SPU will likely revise benchmark
J
ante on this.
Neuse NSW
Ensure TN monitoring if Hate. See above for guidance.
Tar -Pamlico NS
Ensure TN/TP moni�ing ' propriate. See above for guidance.
Is stream segment impaired (on
Check the Inteeggrraated 343(b)-& 303Wreport:
303(d) Iist), and is there a TMDL?
jit4ir/1h2e:enr, n�.us.Gtmdl-430-3d-Archive7htm
•—Impaired-waters-with-Draft-or Approved TMDL_-: Add-monitoring'for~
-pollutant(s)•of concern (POC)-M y`consuit-w/TM•DLUnit•te-determin
�whays-appropriate.
IV&7—
Impaired waters (no TMDL yet): Add language re: potential for future
TMDL and possibility of asking for future monitoring (See permit
templates). Ensure TMDL definition is in boiler plate, Part VI.
Significant process changes
Look for new chemicals and/or necessity for keeping monitoring`of old ones
in the permit. Add monitoring for neW_P,O@-or remove monitoring for old
POC (unless residual potential)!-Aiso, check for new applicable SIC.
Do Stormwater Eflluerii Guidelines
apply?
Check 40 CFR Subchapter N (See Appendix-H). n some cases, limits may
apply, but often those aren'tpn sa�ause of the SPPP/BMP
requirements in our ern2its. [40 CFR 122.44(k)(3) authorizes use of BMPS in
lieu of numeric-nt limitations in NPDES permits when limits are
D-2

r__
Issue/Flag
Action/Guidance
for Renewal
infeasible.]
Threatened or Endangered Species?
-Th atural-Her.itage-Frog ham treated=a alias ties.
�" `` t
Current Proce s: eteirrime if there are any Federal T&E (not state). ee the
NHP Manual in the uidance the s aced server, needs
q �4:4e,_ S�PC1e1
o er on
� � `n ','/ r I�
� (tJ
to discuss this interim process. is this going to be our final process?
yi`
This-website-fte4ongerexists-3'/28f 1'2—
list :/hih eb.. nra state-tic-tisf artner/virtuai—workrooni. p Litml---
r�
user name: -partner
Pass d r-Bau8*P­�
J � �
Grr��i14b ms -ar / ton J >� �C7 "li9 'r
Other:
Check:
• ntiiing ct{mgtiance
• Notices-oPholatian-tN(DVs)•and'tither-eorrespun-d ce-Check-with--
issue�Faiher conic ns
Regkmal-011lee. C-enaidef-monitoring.revisions.
ecific sub -basin concerds,
• :rerpQmrnendations,.ctc.___'
4 Basinwide Plan: http://h2o.enr.state.nc.us/basinwidc/index.htm
• _DataManitoring-Reports-(D-MRs), if-not-all•data-reported in renewal
• -Site moni correctly—
application.-Check.if parameters•with-BDL-or_ND-(below
dete-ctlno.detect.) values.have.suffic4ent M•DL (minimum de ection
tJS Iry
revel).
.
Copy Draft to DEH/Shellfish Sanitation per 2H .0126. (Example -Memo
s
attached.)
Contact:
7toSA
Lee Sabo
DEH, Shellfish Sanitation
Moorehead City_-"_�!
Courier I-I=I'2-10
Discharge includes wastewater,-'-'
CEpy Draft to Regional Office DEH WS Supervisor. (Example Memo
and is to WS waters
attached.)
Contacts:
ARO - Harold Setzer
FRO - Debra Benoy
MRO - Britt Setzer
RRO - Mich ea 1 Douglas
WaRO and WiRO - Fred Hill, WaRO
WSRO - Lee Spencu_
Past -due a= .feed
Chec�JM
All-major* Individual renewals----
Copy Draft to EPA.
Contact: _� •-�
Mike Mitchell
*Currently includes only Phase I
U.S. EP_A.Region IV
MS4•permits and DOT permit:
6,1,-Fc sr yth Street
Atlanta, GA 30303
All minor IndLviduai-renewals
Copy Final permit to.EPA-(see•above)" `
-Permit is in Wake County**
Copy Wake County on Final Permit:
Wake County Environmental Services.'""..._
Attn: Eric Green
P.O. Box ssa��
Raleigh -,-NC 27602
FYI - phone #: [phone], email: eric. green(cbwake ov.com
-I-
D-3

Issue/Flag
Action/Guidance
f enewal
Permit is in Mecklenburg C t
Copy Mecklenburg Coun ina1 Permit:
Mecklenburg Co EP
Water QU!Lpy-
700 Tryon Street
rlotte, NC 28202
**A Memorandum of Agreement (MQA) exists between DENR and these counties, which perform the
inspections of these facilities. Therefore, these counties need to know when a permit is issued.
Interim Benchmark Guidance List
(Benchmarks to be added or corrected at next revision)
Last revised 612412010
See .Interim Benchmark Revision Document located:
S:\Stormwater Permitting Unit\Guidance\Benchmark Concentrations
About Metals in Permits
Note that metals benchmarks are based on Total Recoverable metals. All permits should specify "Total
Recoverable" for each metal in the monitoring and benchmark tables. (Acute standards for dissolved metals
are pending with 2010 Triennial Review, and implementation of metal benchmarks will be revisited soon.) ,,
D-4

A
Pickle, Ken
From: Pickle, Ken
Sent: Tuesday, November 22, 2011 3:27 PM
To: Georgoulias, Bethany; Bennett, Bradley
Subject: RE: Horsehead zinc reclamation plant
FYI. No Action
Read further only if you have a special interest.
Just took a look at Sergei's permit for Horsehead. Here's the issue for Forrest, I think, that stormwater benchmarks are
lower than wastewater limits:
C So
Parameter
NCO089109 Wastewater ZS -OVI
discharge limits WQS
Potential NCS benchmark
Apparent
discrepancy?
Comment
Flow
0.62 MGD mo. avg.
-
TSS
Monitor only
100 mg/L
Ammonia-N
itit7.2
mg/L
Aluminum
0.75 mg/L
Antimony
0.09 mg/L
Arsenic
" " p"5,,,
0 g/L
Cadmium
350 ug/L mo. avg : 2143 u L
daily max 2 L
1 ug/L
x
3 orders of
magnitude
Chlorides
Monitor only 235M,,/L
860 mg/L
Chromium
" 4 a
1 mg/L
Cobalt
0.03 mg/L
Copper
,ao7
0.007 mg/L
Fluoride
315.8 mg/L : 315.8 mg/
`J
I
6 mg/L
x
2 orders of
magnitude
Iron
Monitor only
i , o u� c
1 mg/L
Lead
4386 ug/L : 4829 ug/L
2 4.
30 ug/L
x
2 orders of
magnitude
Nickel
Monitor only
:Og$M
0.26 mg/L
Tin
-
Zinc
;.nSOra
0.067 mg/L
pH
6-9
6-9
Chronic Toxicity
Monitor only
-
Turbidity
Instream < 50 NTU, or n
increase
SOt4t- l
Instream < 50 NTU, or no
increase
Considering the above, and based on recollection of our phone call, it wouldn't surprise me for Forrest to highlight the
following aspects of the currently proposed site design:
+ There are three natural drainage features on the property, but converting all that pasture and woodland to an
effectively impermeable plant site means that the three features are not hydraulically equipped to handle the

increased flow; with the result that trying to utilize the three features would result in significant erosion and
head cutting. There is a 90' steep slope from the terraced plant site to the flat ground around the river. The
combination of topography and increased flow argues against trying to use the existing features for stormwater
conveyance.
Instead, Horsehead will capture all the excess site runoff and direct it to a single outfall pipe directly into the
Broad River. (`Excess site runoff, because a portion of the site runoff will be utilized in the process. So, there
may be discharges only in large events, or when the facility is not operating --I'm not exactly clear on when
discharges would occur.) Given the great dilution in the Broad River, even at low flow, and as reflected in the
relatively high wastewater limits above, does it make sense to have such low benchmarks for the stormwater
discharges? Essentially Forrest's argument may be: If Sergei's analysis quantifies the pollutant limits necessary
to protect the Broad River for a 36Sd/yr discharge, shouldn't the less frequent, more diluted stormwater
benchmarks be at least as high, if not higher?
The facility has already been through the DAQ, and the emissions into the atmosphere are ok with our brothers
and sisters in DAQ. So, if it's already authorized to be in the environment, then DWQ shouldn't double count
those heavy metals just because some of them fall out on the plant site and are washed off in the runoff.
NOTE; It sounds like Horsehead and Forrest will be coming forward with a site plan that makes no attempt at BMPs or
any stormwater treatment. The primary raw material here is EAFD(?) Electric Arc Furnace Dust - - it's chockfull of heavy
metals — obviously, because zinc and plumbum are their products. Our assessment for the potential for polluted runoff
should consider the hazardous nature of heavy metals.
The first counters that come to mind are:
• The benchmarks are not permit limits. They are flags for the site manager so that he can be vigilant in insuring
that pollutants from industrial sites do not accidentally slip off his site in stormwater runoff. it makes sense for
us to require response actions as outlined in our individual permit template in order to have site managers
serious about the discharge of pollutants from their sites.
• For intractable conditions DWQ can grant relief from the benchmarks.
• Where accumulated data can show that pollutants are not present and not discharged from the site, DWQ can
easily re -open the individual permit and amend the monitoring requirements as to frequency and parameter.
First let's characterize the discharges from this unusual industrial facility (there are none exactly like it in the
world, and only a few even reclaiming EADF by any process), and let's err on the side of protecting the
environment, and then let's back off where accumulated data shows that we have been overly cautious.
• If the site is indeed clean, there shouldn't be a problem meeting these benchmark values.
If there is a problem, then perhaps street sweepers, or additional roofing, or bioretention cells in hot spot
sources, or grassed conveyances could help. At least try to do something if heavy metals are leaving your site.
We acknowledge that for some, it may be counterintuitive that stormwater benchmarks would be lower than
wastewater limits. But each program has their own set of procedures and rules that determine how we permit
industrial facilities. An attempt to reconcile the two programs is a programmatic endeavor that we don't have
the resources to attempt at this point in time.
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. [e-mail]

Ideas for Copper and Zinc Monitoring in 2012 General Permit Renewals
Analytical Monitoring
Table 1. Analytical Monitoring Requirements
arge
NNO
easuremen
p1ehS_amlea�it1b
H
standard
semi-annual
Grab
SDO
Copper (Cu), Total Recoverable3
mg/L
semi-annual
Grab
SDO;
U,D3 opt
Zinc (Zn), Total Recoverable3
mg/L
semi-annual
Grab
SDO;
U,D3 opt
Total Rainfal14 I
inches I
semi-annual
Rain Gauge
-
Footnotes:
1 Measurement Frequency: Twice per year during a measureable storm event
2 Grab samples shall be collected within the first 30 minutes of discharge.
3 Sample Location: Samples shall be collected at each stormwater discharge outfall (SDO) unless
representative outfall status (ROS) has been granted. A copy of the letter granting ROS shall be kept on site.
The permittee may elect to sample Cu and Zn upstream (U) and downstream (D) of all stormwater outfalls
instead of at each SDO with representative status (no benchmark applies). See also footnote 3 in Table 3.
4 For each sampled measureable storm event, the total precipitation must be recorded. An on -site rain gauge
or local rain gauge reading must be recorded.
Associated Benchmarks
Table I Benchmark Values for Analytical Monitoring
pH1
standard
6 - 91
Copper (Cu)2 3
mg/L
r 0.007 (Tier One),
` 0.014 (Tiers Two and Three)Z
Zinc (Zn)2 3
mg/L
0.067 (Tier One],
0.13 (Tiers Two and Three)2
Footnotes:
1if pH values outside range are recorded -in sampli� stormwater discharges, but am ient rainfall
data indicate precipitation pH levels are within ± 0.1 standard units of the measured discharge
values or lower, then the lower threshold of this benchmark range does not apply. Readings from an on -
site or local rain gauge (or local precipitation data) must be documented to demonstrate background
concentrations were below the benchmark pH range.
2 These benchmarks are hardness dependent and are based on a default hardness of 50 mg/l. Tiers Two
and Three are prompted by values exceeding twice the initial benchmark.

3 TIneu of benchmarks for Cu and Zn, the permittee may monitor up- and downstream of the
ulative stormwater discharges From the site where feasible and demonstrate that the stormwater
discharges subject to this permit do not significantly increase in -stream concentrations of these metals.
%._ That demonstration may take into account total dissolved levels of these metals at ambient conditions.
Alternatively, in lieu of benchmarks, the permittee may identify likely sources of Cu and Zn and devise a
site -specific Monitoring and BMP Plan to address how the facility will assess and reduce or eliminate
these metals from stormwater discharges. The Monitoring and BMP Plan shall be submitted to the
Division's Regional Office for approval and shall be incorporated into the SPPP.
That last alternative - a site -specific Monitoring and BMP plan - comes from a concept
included in the Action Levels water quality standard in 15A NCAC 02B.0211(4). Here's
what that says:
(4) Action Levels for Toxic Substances:
(a)
Copper: 7 ug/I;
(b)
Iron: 1.0 mg/I;
(c)
Silver: 0.06 ug/l;
(d)
Zinc: 50 ug/I;
(e)
Chloride: 230 mg/I;
If the Action Levels for any of the substances listed in this Subparagraph (which are generally
not bioaccumulative and have variable toxicity to aquatic life because of chemical form,
solubility, stream characteristics or associated waste characteristics) are determined by the
waste load allocation to be exceeded in a receiving water by a discharge under the specified
low flow criterion for toxic substances (Rule .0206 in this Section), �e ischaiallrlgri
Those substances for which Action
Levels are listed in this Subparagraph shall be limited as appropriate in the NPDES permit based
on the Action Levels listed in this Subparagraph if sufficient information (to be determined for
metals by measurements of that portion of the dissolved instream concentration of the Action
Level parameter attributable to a specific NPDES permitted discharge) exists to indicate that
any of those substances may be a causative factor resulting in toxicity of the effluent. NPDES
permit limits may be based on translation of the toxic form to total recoverable metals. Studies
used to determine the toxic form or translators must be designed according to "Water Quality
Standards Handbook Second Edition" published by the Environmental Protection Agency (EPA
82—_B_-94-0Q5a)_or "The Metals Translator: Guidance_For Calculating_a Total_fiecoAerab_le_Permit
Limit From a Dissolved Criterion" published by the Environmental. Protection Agency (EPA 823-
B-96-007) which are hereby incorporated by reference including any subsequent amendments.
The Director shall consider conformance to EPA guidance as well as the presence of
environmental conditions that limit the applicability of translators in approving the use of metal
translators.

d
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WI
Pickle, Ken
From: Palmer, Lisa M
Sent: Wednesday, January 30, 2013 12:29 PM
To: Pickle, Ken
Subject: FW: Public Notice for Stormwater Ashville Citizen -'times 1-30-2013
This ad will run on 1-31 in the Ashville Citizen times cost is 117.50 1 will forward the one from the other newspaper
when I get it.
L Csa,, M . fPC,t.Zi'Yi.PX
NCDENRIDWQ/Point Source Branch
1617 Mail Service Center
Raleigh, NC 27699-1617
[phone] .
From: Casiano, Summer[maiIto: scsmithO)ashevili.gannett.com]
Sent: Wednesday, January 30, 2013 12:21 PM
To: Palmer, Lisa M
Subject: RE: Public Notice for Stormwater Ashville Citizen -Times 1-30-2013
$117.50

'w a
PoynterAgateOne-BrI;- 5.5 �� 15[1 �'�'" B I^U
IQ File Edit View Format Functions Schedule Administration Display Tools Window tie
1p
PUBLIC NOTICE
TATE OF NORTH GAROj
INA ENVIRONMENTAL;
MANAGEMENT COM-1
MISSION
ALEIGH, NORTH GAROj
INA 27699-1617
orsehead Metal Prod
cts, log., I+OpAre b_Q�a
14 C has �or
applied an7
I?PF_j x91Jl�yvgiI~r Per
1
it to ischargestorm-I
tit r associatedwrff,
n ustrialactivitie
rom a facility located,
t 484 Hicks Grove-
oad, Moorq_5 NG,I
u� effibc County. The.
acility will dischargel
o waters designated
as the Broad River with I
n the Broad River Ba;
in.
opPies of the draft per:
it, No.
NCS000562 arel
vaiIable of the Tbltow,,
ng vt=gbsite as of Feb
u a r y 1 2 0 1 3
ttp_:// ortal.ncdenr.or
wA!ilwgJvrsjsu[pti5T1
= nsiti ces.
I
rby con#acting:
Ken Pickle
G Division of Water,
u ality
617 Mail Service Cen�
er
aleigh, NG 27(399-1617 1
3
elephone Number::
919) 80 7-63 76 1
en .p1 ck a@orAe oc.QQv ;
arsons wishing to!
omment upon or ob-1
ect to DWQ s proposed)
eterminatFon to issue
he requested permij
re invited to submit;
heir comments in writ,
ng to the above ad,
ress no later than'
March 6, 2013. All coma
ants received priortc
4—:hat
date will be cony
idered in the final de
ermi nation regardinggl
issuance.
ermit AII-
omments and re'
uests should refer
nce draft ppermit num-
I
-
er NCS00W2
anuary2I,2b13
99411---_--____----!
- -- ]F
-
9 2 3 4
I I I I
2

_;F:
Summer Casiano
Legal Advertising Coordinator
ASRE S1Y- 1--,
CITIZEN -TIMES
Imediagroup •C.hvIrT C6-r.0r
office 828-232-59251 1 fax [phone]
14 O.Henry Avenue I PO Box 2090 1 Asheville, NC 28801
(cDAshevilleB2B I AVLne.ws -
» Glick here to sign up for Marketing Minute, our monthly e-newsletter featuring news and insights to help you prow your business!
Think Greenl Please Consider Before Printing This Email. Ask me how you can sign up for E-lnvoicing!
From: Palmer, Lisa M fmaiIto -Lisa. Pal mer(d)ncdenr,govj
Sent: Wednesday, January 30, 2013 10:40 AM
To: Asheville- Legals
Subject: Public Notice for Stormwater Ashville Citizen -Times 1-30-2013
Please publish the HIGHLIGHTED public notice as a line advertisement in the Legal Section of your
paper ONE TIME as soon as possible. Please verify receipt of this email, and send proof/cost/day
AD will run before printing.
Feel free to contact me'with any questions, Thanks!
PUBLIC NOTICE
STATE OF NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
RALEIGH, NORTH CAROLINA 27699-1617
Horsehead Metal Products, Inc., Mooresboro, NC has applied for an NPDES Stormwater Permit to discharge
stormwater associated with industrial activities from a facility located at 484 Hicks Grove Road, Mooresboro, NC,
Rutherford County. The facility will discharge to waters designated as the Broad River within the Broad River Basin.
Copies of the draft permit, No. NCS000562, are available at the following website as of February 1, 2013:
http:lZiportal.ncdenr,org/web/­wq/ws/su/]2ublic-notices
Or by contacting:
Ken Pickle
NC Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617.
Telephone Number: [phone]
ken. [e-mail]
Persons wishing to comment upon or object to DWQ's proposed determination to issue the requested permit are
invited to submit their comments in writing to the above address no later than March 6, 2013. All comments received
prior to that date will be considered in the final determination regarding permit issuance. All comments and requests
should"reference draft permit number NCS000562

Pickle, Ken m
From: Palmer, Lisa M
Sent: Thursday, January 31, 2013 9:13 AM
To: Pickle, Ken
Subject: FW: Public Notice Daily Courier 1-30-2013
Attachments: 30347997_00000129.pdf
Good Morning Ken,
See attached for your proof for the other newspaper. It will run 2-1 and cost 96.00.
Have a great day!
LAM. Patmer
NCDENR/DWQ/Point Source Branch
1617 Mail Service Center
Raleigh, NC 27699-1617
[phone]
From: Erika Meyer fmailto:[e-mail]]
Sent: Thursday, January 31, 2013 9:03 AM
To: Palmer, Lisa M
Subject: Re: Public Notice Daily Courier 1-30-2013
Good Morning Lisa, I have attached a proof for your review. I have the legal scheduled to publish tomorrow,
Friday, 2/1, Please let me know if you see any changes that need to be made before 1:30pm today. Total cost is
$96,00, Thanks, Erika 828-202-2924
On Jan 30, 2013, at 10:42 AM, Palmer, Lisa M wrote:
Acct# 04104850-000
Please publish the HIGHLIGHTED public notice as a line advertisement in the Legal Section of your
paper ONE TIME as soon as possible. Please verify receipt of this email, and send proof/cost/day
AD will run before printing.
Feel free to contact me with any questions, Thanks!
PUBLIC NOTICE
STATE OF NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
RALEIGH, NORTH CAROLINA 27699-1617

0--,
Horsehead Metal Products, Inc., Mooresboro, NC has applied far an NPDES Storrnwater Permit to discharge
stbrmwater associated with industrial activities from a facility located at 484 Hicks Grove Road, Mooresboro, NC,
Rutherford County. The facility will discharge to waters designated as the Broad River within the Broad River Basin.
Copies of the draft permit, No. NCS000562, are available at the following website as of February 1,
2013. http:Uportal.ncdenr.orci/web/wgLs/su(public-notices
Or by contacting:
Ken Pickle
NC Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Telephone Number: [phone]
ken.pickleCcZncdenr.gov
Persons wishing to comment upon or object to DWQ's proposed determination to issue the requested permit are
invited to submit their comments in writing to the above address no later than March 6, 2013. All comments received
prior to that date will be considered in the final determination regarding.permit issuance. All comments_ and requests
should reference draft permit number NCS000562

AFFIDAVIT OF PUBLICATION
STATE OF NORTH CAROLINA
RUTHERFORD COUNTY
Before the undersigned, a Notary Public of said County and State, duly
commissioned, qualified, and authorized by law to administer oaths, personally
appeared
Bobbie Greene
who being first duly sworn, deposes and says: that they are
Customer Sales Representative
(Owner, partner, publisher, or other officer or employee authorized to make this
affidavit) of THE DAILY COURIER, a newspaper published, issued and entered as
second class mail In the town of FOREST CITY, In said County and State; that they
are authorized to make this affidavit and sworn statement; that the notice or other
legal advertisement, a true copy of which is attached hereto, was published in THE
DAILY COURIER on the following date:
February 1, 2013
and that said newspaper in which such notice, paper, document, or legal
advertisement was published was, at the time of each and every such publication, a
newspaper meeting all of the requirements and qualifications of Section 1-597 of the
General Statutes of North Carolina and was a qualified newspaper within the meaning
of Section 1-597 of the General Statutes of North Carolina.
This the 1st day of February, 2013
Bobbie Greene, Customer Sales Represen ve
Sworn to and subscribed before me this the 1 st day of February, 2013
Cindy D. Branch, (Notary Public)
My commission expires: February 18, 2017.

STATE :OFNbRTH GAR '-INA
ENVIRONMENTAL MANAGEMEN�7COMMISSION
RALEIGH; NORTH CAROLINA;27699-1617
Horsehead Metal Products, Inc., Mooresboro, NC has
applied for an NPOES Stormwater Permit to discharge
stormwater associated with industrial activities from.a facility
located; at 484. Hicks.Grove Road, Mooresboro, NC,
th Ruerford Co_Uhty. the facility will discharge to waters
designated as the Broad River within the Broad River Basin.
Copies of the draft permit, No. NCS000562, are available
at the`following website as of February 1, 2013:
http://portal.ncdent.org/webANq/wo/su/public-notices
Or by contacting:
Ken Pickle
NC Division of Water Quality
1617 Mail Service Center, Raleigh, NC 27699-1617
Telephone Number: [phone] .
[e-mail]
Persons wishing to comment upon or object to DWQ's
proposed determination to issue the requested, permit are
invited,to-submit their comments in writing to the above
address no later than March 6, 2013. All comments received
prior to that date will be considered in the final determination
regarding permit issuance. All comments and requests should
reference draft permit number NCS000562.

ASI-1.EV1I .i .F
CMZEN T N ES
VOICE OF ` VIE MOUNT AIN5 • CMZEN F11`v1 S.Con1
AFFIDAVIT OF PUBLICATION
BUNCOMBE COUNTY
PIALLIC NOTICE -
SS.
PUBLIC NOTICE
5TATE01 j
NORTH CAROLINA
NORTH CAROLINA
ENVIRONMENTAL '
MANAGEMENT
COMMIS51014
CARORALLINA§7UR 617
Before the undersip-ned, a Notary Public of said Countv and
ucotsehln. Mo Lei,
State, duly commissioned, qualified and authorized by law
NC has applied for an
NPDEo Slschalter per.
mlt to discharge storm•
to administer oaths personally appeared Velene Fagan +
water assoclaed with
fromstHal
who, being first duly sworn, deposes and says: that she is
tlityalToeeied
at Hicks Grove
Road,. M,
the Legal Billing Clerk of The Asheville Citizen -Times,
Rutherfordd County. y. ThNCe
facility will discharge
to owaters designated
engaged in publication of a newspaper known as The
I the Broad River with-
rinthe Broad River ea.
Asheville Citizen -Times, published, issued, and entered as
Co les of the draft per-
mit, Np. NC50g0562
first class mail in the City of Asheville, in said County and
are
available at the foYlow-
Ing website as of Feb.
State; that she is authorized to make this affidavit and
►fnuary 1. 2013:
hN b'iwq w sWpuP�i1
sworn statement; that the notice or other legal
c-notices
R nm tacting:
advertisement, a true copy of which is attached hereto, was
NC Division of Water
R1 7t%ail Service Cen-
published in The Asheville Citizen -Times on the
Raleigh, NC276"-1617
following date: January 3151, 2013. And that the said
Telepphone Number•
t919)-newspaper
in which said notice paper, document or legal
P P g
ken.plckBp7le�6376ncdenr.gov
D �
Persons "wishing ' to
advertisement was published was, at the time of each and
comment Von or ob-
ct to, DW 'S roposed
determination 1'o issue;
every publication, a newspaper meeting all of the
the re nested permit:
are invied to submit'
their comments in writ-,
requirements and qualifications of Section 1-597 of the
ing to the above ad.,
dress later than
March 6. 2013.
General Statues of North Carolina and was a qualified
All eom-:
`rents received rior to
that date will �e con-
newspaper within the meaning of Section 1-597 of the
;idered In the final de-'
erminarion re
hmit erIssuances Adinli
General Statues of North Carolina.
Signed this 31" day of January, 2013
2
(Signature of person making
Sworn to and subscribed before me the 3151 day of January,
2013.
expires the 51h day of October, 2013
[phone] 1 [phone] FAX
14 O. HENRY AVE. I P.O. SOX 2090 I ASHEVILLE, NC 28802
G,

y-�
-24/3
Pickle, Ken
From:
Basilone Tim [[e-mail]]
Sent:
Monday, January 14, 2013 1:56 PM
To:
Pickle, Ken
Cc:
[e-mail]
Subject:
RE: Comments on Draft Stormwater Permit
Importance: High
Ken,
COrr�s�on
Below I am providing comments on the latest Draft Permit and Staff Review Form. These same comments
were made earlier, so nothing new — you've seen these, and we discussed some of them in prior meetings. We
believe several of these comments merit specific attention; however we do not want to see the permit process
stalled at this point in time. We anticipate the permit will be issued in draft for public comment, since our
comments, provided below, were submitted once before and were not addressed in the latest draft.
As before, please call me to discuss these comments, or if you'd like I am willing to come to Raleigh to meet
with you. I look forward to hearing from you by the end of this week.
Thank you for this opportunity to comment on the permit,
Tim
Staff Review Form Page 3, Permit Recommendations, Item 1 Analytical Monitoring —
Although we agree with quarterly sampling, and note that this is more frequent monitoring than most standard
industrial stormwater permits, we do not agree with the reasons cited for proposing the frequency. The risk
factors are actually less than most industrial sites based on the design of the facility to prohibit stormwater
pollution, and the potential for discharge of entrained contaminants from the operation. The facility should be a
candidate for "no exposure" status based on the design for stormwater control. Quarterly sampling is
appropriate within the context of an evaluation monitoring period; however, we believe that once a baseline is
established and the plant begins operating the monitoring will demonstrate the effectiveness of the stormwater
controls.
Staff Review Form Page 3. Permit Recommendations, Item 3. Analytical Monitoring Parameters —
a. Metals: The description provided should be eliminated and replaced with the following:
Zinc, lead and cadmium are the most appropriate metals for monitoring purposes since
these are the most abundant of the metals in the operation's feedstock. If there is an
impact from process materials on stormwater, these metals are the most likely to be
detected.
b. Conventional Pollutants:rTN and TP"are excessive with respect to the operation. Please eliminate
these parameters.
Staff Review Form Page 2_Description of Actives
I suggest replacing the information provided in this section with the following:

_k
Horsehead receives zinc oxide material, and refines it into high purity zinc metal. Byproducts
include solid materials containing zinc, lead and cadmium, and very minor amounts of silver.
Staff Review and Evaluation: Permit Recommendations: Analytical Monitoring, 44, and Page 9 of the Draft
Permit.
Please delay the application of the Tiered response actions until after completion of the evaluation period
following the submittal of the summary report to the NCDENR. I believe this has merit because as part of the
summary report a proposed alternative monitoring scheme, if applicable, will be provided — as described in the
current language on page 9 of the draft permit. This alternative monitoring scheme will be based on the eight
quarters of monitoring results that have been acquired, and may include but not necessarily be limited to, any or
all of the following:
■ a recommendation for alternate benchmark levels based on characterization of stream impacts on
receiving waters,
■ a recommendation for a No Exposure Exclusion
■ alteration of the required sampling frequency
■ alteration of the tiered activities required if a benchmark limit is exceeded
In light of information provided above, we recommend that the NCDENR hold off on the establishment or
application of any benchmarks until the monitoring and evaluation period is over, the report has been submitted
for evaluation by NCDENR, and the permit is modified accordingly at that point in time. Using this approach
the monitoring period would be used to establish benchmarks for use in a permit.
The basis for this comment is consistent with our discussions and prior comments submitted to the NCDENR,
(benchmark -levels are not related to stream impact or environmental .impairment in this. particular case, but are
more so arbitrarily assigned. This being the case using benchmark levels such as 0.001. mg/L or 1 ug/L for
cadmium, and 0.030 mg/L or 30 ug/L lead, 0.067 mg/L or 67 ug/L zinc, and 860 mg/L chlorides it is well
within the realm of possibilities that metal and other concentrations at levels exceeding the benchmark originate
from indigenous / natural sources and not the operating facility.
In other words the benchmark levels are below levels that may exist under natural conditions. If this is the case,
the tiered levels of activities, which are required, would likely prove to be fruitless in attempting to understand a
cause at the facility, and consequently this would likely result in a waste of valuable resources in the attempt to
mitigate the cause (to below benchmark levels). As discussed with you earlier, we believe benchmark levels if
used, should be established with an appropriate buffer based on the potential for environmental harm to the
receiving stream, and not set at arbitrary low levels that cannot be explained with respect to their relationship to
any potential environmental impairment.
General comment on Benchmarks ---
We discussed benchmarks and their use during our last teleconference on September 14, 2012. The use of
benchmarks is not appropriate for this new facility, which is designed to prohibit stormwater pollution from the
operation. Instead, we propose quarterly monitoring with samples collected at the stormwater outfall to the
Broad River and analyzed for parameters as mentioned in the section above. We propose the permit be written
to require "monitoring only" for the first two years of the operation.
Information obtained for the first eight quarters of operation should be recorded and summarized in a report to
support a recommendation for either a stormwater permit containing benchmark levels established based on
potential impact to the Broad River, or a "no exposure" application and site status. The report would be

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

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

Pickle, Ken
From:
Pickle, Ken
Sent:
Tuesday, December 18, 2012 11 A4 AM
To:
'Basilone Tim'
Cc:
'[e-mail]'; Bennett, Bradley; Wilson, Susan A; Fox, Tim
Subject:
RE: follow up
Hello Tim,
I apologize for the delay in responding to your previous attempts to contact me. I've been in and out of the office some,
and I've been focused on other tasks some, since we last spoke a month ago. I had moved Horsehead to second priority
while I tended to some other obligations, and based on our conversation that the realistic plant start-up would be in
September.
To answer your question, I see no remaining problems in the permit text; and am still intending to proceed as we
discussed in our last couple of exchanges.
I'll move back to Horsehead as the highest priority tomorrow, and I will have the final draft this week incorporating the
items we agreed to on our last contact. I'll send that to you as soon as it's done, this week.
I'll get the public notice into the required local paper in the first week in January. As mandated by North Carolina rule,
we have a mandatory 30-day public notice period, followed by a mandated 15-day waiting period (45 days total).
• Assuming no substantive public comment, there should be only minor, if any, changes to the permit text based
on the public comment. I think we have been over the permit text to such a degree that I don't expect to
incorporate any public comments, but anything is possible in that arena. Under this scenario, with public
notice in the first week in January, I would anticipate final issuance of the permit by the end of February_.
• if there is sufficient substantive public comment, the Director may determine that a public hearing is required. If
so, our time frame would be extended by 2 -3 months_ I have no reason to anticipate that degree of public
interest, and I think a public hearing is unlikely to be required by the Director. Have you had any indication of
public interest in the facility?
• Both scenarios appear to be well within the projected start-up date of September.
Again, my apologies for failing to return your earlier contacts. You will have the final draft permit version for review by
the end of the week.
Best Regards,
Ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. [e-mail]
Website: htto://portal.ncdenr.org/web/wg/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**

From: Basilone Tim [mailto:tbasilone(a horsehead.ne]
Sent: Tuesday, December 18, 2012 10:54 AM
To: Pickle, Ken
Subject: follow up
Ken,
I left you a voice mail and sent an e-mail last week. I'm getting pressure regarding the status of the stormwater permit,
and have no answers other than you are going to issue the permit. I told this to my management last month. I expected
to have the permit done and out for public review by now. Please advise if there are any problems with our comments
and we need to discuss anything. I advised you a while back that I'd come to Raleigh to do this if necessary.
Please provide a status update and a schedule for getting this permit issued. Thanks.
Merry Christmas to you and yours, wishing you all the best,
Tim
Timothy R. Basilone
Vice President - Environmental Affairs
Horsehead Corporation
4955 Steubenville Pike
Suite 405
Pittsburgh, PA 15205
P 724.773.2223
F 412.788.4526
C 412.287,9871
TBasilone(a)Horsehead.net

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

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

If I can be of any assistance, please let me know. If you can at feast shoot Tim a note on status that would at least let
him know where you are.
Thanks,
Forrest
Forrest R. Westall, Sr., PE
Principal
McGill Associates, P.A.
38 Orange Street I Asheville, NC 28801
Phone, 828.252.0575 1 Fax: [phone]
Email: forrest.westall mcgillengineers.com I Website: www.mcgillengineers.com

TIMOTHY R. BASILONIE
Vice President - Environmental Affairs
4955 STEUBENVILLE PIKE WWW,HORSEHEAD.NET
SUITE 405 TBASILONEOHORSEHEAU.NET
PITTSBURGH, PA 15205
September 19, 2012
r��rd poi �
412.788.4526 �(� J �Sjl�'IJ rJ E.IJs
4t2.788.4526 r I ���_'J' I
CORPORATION
Leading the World in Zinc Recycling
Mr. Ken Pickle, Environmental Engineer
North Carolina Department of Environment and Natural Resources
Be Division of Water Quality
Stormwater Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: Draft Industrial Stormwater NPDES Permit
Horsehead Corporation Zinc Production Facility 1
Rutherford County, North Carolina
.-�+�nY�'i4Fr7 CFI l�•.ttii 1-r�.'
Dear Mr. Pickle: �...:.:_�..:,�.....-..a..�W_,-_�..._....��_x
Thank you for the opportunity to comment on the Draft Industrial Stormwater NPDES
Permit (Draft Permit) you provided on June 29, 2012" Furthermore, thank you for your
continuing effort in working with us to develop this permit, and providing time for
meetings and telephone conferences to discuss our permit application and the subject
permit.'Our comments on the Draft Permit, the Staff Review and Evaluation Form (Staff
Review Form), and the Regional Office comments are provided below. —These comments
summarize our discussions, and are responsive to your requests from the conference call
with you and the Regional Office on September 14, 2012, and comments provided earlier
in e-mails to you."
The overriding storm water management concept is to capture and control the disposition
of all storm water falling into the operating area' This system is to prevent the
uncontrolled discharge of potential pollutants to the discharge stream.The physical
f �-_ facility is being designed to support this concept, and operating procedures will be
developed to ensure management controls are documented and implemented. The first
preference is to use the water in the operation, and as a second preference, only as
necessary, to erect the water to the site storm water discharg�
The facility is designed td&pture and contairi all storm water hat falls within the
operating area of the site. This design will contain rainwat r alling in this area during
the 100 year 24 hour storm event. Water captured in the area will be managed in one of
three ways, as follows:
If part of an individual (isolated) basin, water will be placed directly into the3
process or a tank within that production area,
;Y r d,p.

r' ,k
aRouted to the process water management system, or used to partially displacel
process water (finished water provided by the Town) used by the operation,
• amp ed 'and before discharge to the storm water outfall system.
Storm water falling in areas outside the operating area and from rooftops, parking areal
and landscaped areas will be discharged directly to the storm water outfall during the
storm event.
Details of this system are being developed and will be incorporated as part of the site
operating procedures, and the Storm Water Pollution Prevention Plan (SWPPP). A map
and table describing this system will be provided once the system design is completed. --
Comments on the Draft Permit, Staff Review Form and the Regional Office Comments
are addressed below.
Comments on the Staff Review Form
Gy Page 1, Type of Activity and Page 2 Description of Activity_
The reference to receiving waste is incorrect. The facility will receive zinc oxide
QrsPoe as raw material for the process which is a product manufactured at other
�v�5'C Fa�f 5ls Horsehead facilities. Zinc oxide feed material contains some lead and cadmium,
in addition to zinc. The reference to silver should be eliminated, since it is a very
minor component of zinc oxide.
® Page 1, Special Permitting Issues, Risk Considerations, Location
A! o 1 SG ; The assigned rating 6 is excessive for risk due to the site location. Since this is a
rate 5�2 ��s new facility, the existing impairment mentioned in this section is a pre-existing
condition located downstream and cannot be attributed to the new facility. Based
s
--t on the actual conditions, the rating should be in the low range of the risk scale.
Raf,o��e . a r►aPa�.
Axs w� nov 40 r
&Page 1, Special Permitting Issues, Risk Considerations, Other Factors
Rc 0n The assigned rating 10 is excessive for risk considering other factors. This is a
Hoag) rdnew facility that is specifically designed, as described above, to prohibit
stormwater contamination. To the contrary of the statement "proper operator
0 actions to a larger than normal degree" and other factors mentioned, during our
discussions you indicated design of the stormwater management systems for this
plant are exceptional. The design includes a stormwater management system
whereby discharge of storm water from the operating area is not possible without
specific action based on management authorization to release the water. If the
agency's risk determination is to be used as a basis for permit decisions, the true
risk of stormwater pollution from the site needs to be described. Our design
presents less than normal risks for most industrial sites. Based on the actual
conditions, the rating should be in the low range of the risk scale.

Page 3, General Observations
It would be appropriate to mention the level of stormwater control, and design of
t� the facility to manage stormwater, which reduces and possibly eliminates risk of
stormwater pollution from the operation.
0 Page 3, Permit Recommendations
Item 1 Analytical Monitoring —
Although we agree with quarterly sampling, and note that this is more frequent
monitoring than most standard industrial stormwater permits, we do not agree
with the reasons cited for proposing the frequency. The risk factors are actually
ess than most industrial sites based on the design of the facility to prohibit
stormwater pollution, and the potential for discharge of entrained contaminants
Ju i2„�u from the operation. The facility should be a candidate for "no exposure" status
based on the design for stormwater control. Quarterly sampling is appropriate
within the context of an evaluation monitoring period; however, we believe that
once a baseline is established and the plant begins operating the monitoring will
demonstrate the effectiveness of the stormwater controls.
Item 3, Analytical Monitoring Parameters —
T) Fa Metals: The description provided should be eliminated and replaced with the
following statement - Zinc, lead and cadmium are the most appropriate metals
for monitoring purposes since these are the most abundant of the metals in the
operation's feedstock. If there is an impact from process materials on
stormwater these metals are the most likely to be detected.
b. Organicslease eliminate the reference to kerosene or kerosene -like
petroleum product. More appropriately, please reference the hydrocarbon
material used in the process as ``hydrocarbon solution". The hydrocarbon
solution is a key process ingredient. Monitoring for it & Grease is
appropriate.
c. Conventional Pollutants: TSS and pH are appropriate; TN and TP seem,
No re�sa�
excessive with respect to the operation. Please eliminate these parameters.
Item 4, Benchmarks —
We discussed benchmarks and their use during our last teleconference on
O September 14, 2012. The use of benchmarks is not appropriate for this new
.-� facility, which is designed to prohibit stormwater pollution from the operation.
Instead, we propose quarterly monitoring with samples collected at the
stormwater outfall to the Broad River and analyzed for parameters as mentioned
3

+ r�
in the section above. We propose the permit be written to require "monitoring
only" for the first two years of the operation.
Information obtained for the first eight quarters of operation should be recorded
and summarized in a report to support a recommendation for either a stormwater
permit containing benchmark levels established based on potential impact to the
Broad River, or a "no exposure" application and site status. The report would be
submitted to the agency following the two year period of evaluation for review by
DWQ. Based on this report the permit can be revised accordingly, or eliminated
if the "no exposure" scenario is justified.
The report would provide the raw data, an evaluation of the potential impact to
the receiving waters based on the monitoring data and the conditions of the Broad
River at the time of sampling, a recommendation on the need for benchmarks at
this site, if appropriate a recommendation for the benchmark parameters and
levels, and an evaluation of the site for "no exposure" status. If the "no exposure"
scenario applies, an application for this status will be provided with the report.
Since this is a new plant with no prior history available, and the design of the
plant is such that stormwater is contained and controlled in areas of the operation,
we believe the proposed approach allows for information to be gathered after the
plant begins operating that will serve as a basis for developing a permit for the
operation or justifying a "no exposure" scenario.
Comments on the Draft Permit
,/ Part II Page 2 of 11 b Secondary Containment Re uirements and Records
The later portion of this section should be eliminated beginning on the seventh
dine -and following the words "areas shall be maintained." You have indicated
during prior meetings, calls and communications that the permit will not require
anything on internal monitoring, but will rely entirely on discharge point
monitoring for regulatory purposes. Specific conditions provided on internal
monitoring for captured water are inconsistent with these prior discussions.
Part II Page 5 of 11, Section B: Analytical Monitoring Requirements
Please see the above sections in the Staff Evaluation discussing the Analytical
Monitoring Requirements.
Benchmarks and their use in the permit should be eliminated, including the tiered
approach for monitoring. Instead, Horsehead is proposing a' -Monitor Only"
status for the facility for two years (eight quarters) following startup. Monitoring
will be conducted at the discharge point to the Broad River and include collection
and analysis of samples for Zinc, Lead, Cadmium, Oil & Grease, TSS, and pH.C-
Monitoring results over this period of time will be used to evaluate the
effectiveness of the facility design and stormwater management scheme, which is
0

based on a strategy to prohibit stormwater discharge containing contaminants
from the operation.
As noted, the monitoring results obtained over the eight quarters will be
summarized in a report for submittal to the DWQ, and in support of a revised
stormwater permit with benchmark levels established based on potential impact to
receiving waters, or a "no exposure" status.
Part II Page 14of 11, Section D: On -site Vehicle Maintenance Monitoring Requirements
Please eliminate this section; there is no vehicle maintenance facility or activity
that will be conducted on site.
Comments on the Regional Office Comments
Require SVNTPPP to be developed for startup —
An SWPPP will be developed for the site prior to startup of the facility.
Address failure modes with a back-up plan identifying management actions in response
to atypical operating conditions —
The SWPPP to be developed prior to plant startup will address this matter.
Add chlorides to the sampling scheme —
Based on the proposed approach for stormwater management and the sampling
scheme and parameters described above, this monitoring will provide sufficient
data to assess stormwater from the facility site. Mnitoring for chlorides will add 7
ono -additional -benefits and is not justified. 7
Add Auarterly acute toxicity testing to the sampling scheme —
The level of stormwater management on this site is extensive and well beyond
anything required under any other permit for facilities in North Carolina. Aquatic
Whole Effluent Testing is not a standard industrial stormwater requirement.
Application to a site with control systems as described above is not reasonable.
The inclusion of toxicity testing is unsupportable and inappropriate.
Provide a "step-down" in analytical testing from Quarterly to 2/yr after 3 years,
conditional on results —
In consideration of the proposed approach to monitoring, this should be evaluated
based on results from the quarterly sampling over two years, along with the
evaluation of a "no exposure" status for the site.
5

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

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

4 , -1
Phone: [phone]
Fax: [phone]
Email: ken. picklePncdenr.gov
Website: htto://i)ortal.ncdenr.ora/web/wq/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Basilone Tim [mailto:[e-mail]]
Sent: Monday, October 01, 2012 11:22 AM
To: Pickle, Ken
Cc: [e-mail]
Subject: status update '
Ken,
Hope all is well. Please advise me as to where things stand with our Stormwater Permit. It's been nearly two weeks
since we provided comments to you, this after discussing these with you by telephone. Please advise when you would
like to meet to finalize the draft, as I indicated I will come to Raleigh to work with you on this. Please advise me as to your
schedule for getting the permit issued.
Thanks.
Tim
Timothy R. Basilone
Vice President - Environmental Affairs
Horsehead Corporation
4955 Steubenville Pike
Suite 405
Pittsburgh, PA 15205
P 724,773,2223
F 412.788,4526
C 412.287.9871
TBasilone(c�Horsehead.net

Pickle, Ken
From: Pickle, Ken
Sent: Friday, November 02, 2012 4:06 PM
To: Wilson, Susan A; Fox, Tim
Subject: FW: Answers to Permit questions
Importance: High
FYI,
Horsehead
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. picklePncdenr.gov
website: http://portal.ncdenr.org/web/wq/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Basilone Tim[ma ilto:tbasiloneCalhorsehead.net]
Sent: Friday, November 02, 2012 4:00 PM
To: Pickle, Ken
Cc: forrest.westallC�mcgillengineers.com; Staley Anthony
Subject: Answers to Permit questions
Importance: High
Ke n,
Per our conversation yesterday, i am providing the following information in response to questions raised in your e-mail
concerning the subject draft stormwater permit:
Answer to E.1. The stormwater basin adjacent to the river is being provided primarily for energy dissipation. Its
inclusion in the stormwater discharge system is not required and is being provided to assure that all of the energy of the
discharged water is effectively transferred into the Broad River with no impact to the River Bank or the River Bottom.
The basin is constructed of compacted earth and isn't lined. A "fore -bay" area at the outlet of the site stormwater pipe
includes a large concrete dissipation structure and a transition area for flow to move into the main part of the basin.
Answer to E.2. Stormwater from the containment areas will be monitored for relevant analytical parameters including
those to be monitored at the cutfall and as listed in the NPi7ES stormwater permit. Procedures for managing the subject
water will be described in the SWPPP, and will include BMP's for minimizing contaminant levels from entering water
that is captured in containment. This plan will be completed prior to startup of the facility, and will include thresholds as
to whether the water will be placed into processor released to stormwater. Be advised that our line of thinking at this
point is that the rule is to place all water back to process, and the exception is to release the water to the stormwater
outfall provided analytical results warrant such.
Please advise me if you need any additional information. I look forward to receiving the draft permit from you
sometime next week.

Thanks Ken, have a nice weekend.
Tim
Timothy R. Basilone
Vice President - Environmental Affairs
Horsehead Corporation
4955 Steubenville Pike
Suite 405
Pittsburgh, PA 15205
P 724.773,2223
F 412.788.4526
C 412.287.9871
TBasilone(a-)Horsehead. net

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

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

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Pickle, Ken
From:
Basilone Tim [[e-mail]]
Sent:
Monday, November 12, 2012 1:03 PM
To:
Pickle, Ken
Cc:
[e-mail]; Staley Anthony; Harris James
Subject:
Comments on the latest draft permit
Importance: High
Thank you for the opportunity to comment on the draft permit. I appreciate your evaluation and response to our
prior comments on the former draft which were submitted to you and discussed in meetings with you.
Your comments in your e-mail regarding the permit duration are fine, 1 have no specific comment on this item
or any comments on other matters in your e-mail concerning alteration of the sampling frequency (step down or
step up), and the administrative aspects associated with permit modifications, with the exception of comments
provided below to the degree they relate to these matters.
Our comments:
1. Please use the following description of the facility on the first page of the permit:
Horsehead Metal Products, Inc.
484 Hicks Grove Rd.
Mooresboro, NC 28114
2. The facility will not commence operations until September 2013 or possibly later. This being the case,
please adjust the effective date of monitoring under this permit to the date which the operation of the
facility commences, adjust the language on Page 9 to reflect the eight quarters of monitoring will begin
after startup, and-adjusfthe schedule.on PagLb-to`reflect the same:
3. Please consider delaying the application of the Tiered response actions until after completion of the
evaluation period following the submittal of the summary report to the NCDENR. I believe this has
merit because as part of the summary report a proposed alternative monitoring scheme, if applicable,
will be provided — as described in the current language on page 9. This alternative monitoring scheme
will be based on the eight quarters of monitoring results that have been acquired, and may include but
not necessarily be limited to, any or all of the following:
■ a recommendation for alternate benchmark levels based on characterization of stream impacts on
receiving waters.
■ a recommendation for a No Exposure Exclusion
■ alteration of the required sampling frequency
■ alteration of the tiered activities required if a benchmark limit is exceeded
4. In light of our comment in 43 above, we recommend that the NCDENR consider holding off on the
establishment or application of any benchmarks until the monitoring and evaluation period is over, the
report has been submitted for evaluation by NCDENR, and the permit is modified accordingly at that
point in time. Using this approach the monitoring period would be used to establish benchmarks for use
in a permit.
The basis for this comment is consistent with our discussions and prior comments submitted to the
NCDENR, benchmark levels are not related to stream impact or environmental impairment in this

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

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

Al
Thanks Ken. I am in contact with Tim and we are working on some comments. One issue that I noted in reading your e-
mail is EPA review. We had not discussed this previously. Due to the NPDES Process WW permit, the facility is classified
as a minor facility and a review by EPA of the process WW permit was not required. My understanding is that because
the facility is classified as a minor, EPA review isn't required. Please clarify.
Tim will be in touch concerning any comments we may have on the draft package.
Take care,
Forrest
Forrest R. Westall, Sr., PE
Principal
McGill Associates, P.A.
38 Orange Street I Asheville, NC 28801
Phone: 828.252,0575 1 Fax: [phone]
Email: forrest.westall@a mceillengineer_s.com 1 Website: www.mcgilleneineers.com
From: Pickle, Ken fmailto:ken. l2ickleCd)ncdenr.gov]
Sent: Friday, November 09, 2012 11:44 AM
To: Basilone Tim
Cc: [e-mail]; Bennett, Bradley; Wilson, Susan A; Fox, Tim
Subject: in -progress draft permit and staff report
Hi Tim,
Here are the two documents we have been working on together. My next step is to send these out to public notice in a
local newspaper and the NC register, and to EPA Region IV. I'll be working on the public notice next week. Not a big
task.
have made the changes indicated in our last correspondence with a couple of exceptions. Overall there are three
things I want to especially call your attention to, and solicit your comments.
1. See Part II page 9 of 11 for the new permit provision that allows de -coupling the sampling results from the benchmark
values and Tiered response actions for two years. I've written this up for eight data points minimum plus Horsehead's
summary report, presumably proposing revisions to the monitoring activities under the permit conditions. Because this
is an individual permit (not one of our General Permits), we have the authority to revise the elements of any monitoring
requirements without the additional administrative procedures and delay involved in a complete permit re -issuance.
In my last note to you, I reported that we would be writing the permit for a shorter than usual duration, three years
instead of five years. As I got down to actually making the changes in other parts of the permit that were time -
dependent, it just seemed to me that the shorter duration was not necessary. So, I'm intending to go with the standard
5-year duration on the permit. Two aspects of the permit were on my mind, plus an administrative consideration:
As far as my administrative consideration, we're all looking for ways to stretch ourselves to fit the amount of work in our
unit. That's not going to change in the foreseeable future. I'd rather the•Stormwater Permitting Unit address the
renewal of this permit in five years, rather than three years.
We agreed to a step-down, step-up provision in the sampling frequency that would allow semi-annual sampling rather
than quarterly sampling. I base the step-down provision on eight consecutive results below benchmarks. Well, the

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Pickle, Ken
From: Basilone Tim [[e-mail]]
Sent: Wednesday, July 25, 2012 2:07 PM
To: Pickle, Ken
Cc: [e-mail]
Subject: RE: Draft permit, staff report
Ok Ken, plan on this meeting. I'll get an agenda to you beforehand and other information that applies.
Thanks.
Tim
Timothy R. Basilone
Vice President - Environmental Affairs
Horsehead Corporation
4955 Steubenville Pike
Suite 405
Pittsburgh, PA 15205
P 724.773.2223
F 412,788,4526
C 412.287.9871
TBasiloneCcDHorse head. net
From: Pickle, Ken [mailto:[e-mail]]
Sent: Wednesday, July 25, 2012 1:29 PM
To: Basilone Tim
Cc: [e-mail]; Wilson, Susan A; Bennett, Bradley
Subject: RE: Draft permit, staff report
Hi Tim,
That's good for me, and Asheville confirms they will participate via conference call.
Thanks & see you then. Anything you can send in advance will help us have a productive meeting.
Ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. r)[e-mail]
Website: htto://cortal.ncdenr.org/web/wci/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Basilone Tim [mailto:[e-mail]]
Sent: Wednesday, July 25, 2012 1:00 PM
To: Pickle, Ken

Cc: [e-mail]
Subject: RE: Draft permit, staff report
Ken,
How does Monday the 6"' work for you to meet at your offices? I'll plan on coming in on the morning flight from Pittsburgh
scheduled to arrive at 10:30 AM. The flight in the afternoon is at 3:21 PM'. Could we plan to meet at around 11-30 AM
and reserve two hours for the meeting? I know this is lunch time, but thought maybe we could grab a sandwich and work
through. I'll need to depart around 1:30 PM to catch my flight back to Pittsburgh.
Please advise if this works for you.
Thanks.
Tim
Timothy R. Basilone
Vice President - Environmental Affairs
Horsehead Corporation
4955 Steubenville Pike
Suite 405
Pittsburgh, PA 15205
P 724.773.2223
F 412,788.4526
C 412.287,9871
TBasilonea,Horse head, net
From: Pickle, Ken [ma ilto:ken. [e-mail]]
Sent: Monday, July 23, 2012 8:00 AM
To: Basilone Tim
Subject: RE: Draft permit, staff report
Hi Tim,
Both of those are good for me.
Ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. [e-mail]
Website: http://portal.ncdenr_orQ/web/wci/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Basilone Tim[ma ilto:tbasilone(&horsehead.net]
Sent: Saturday, July 21, 2012 5:51 PM
To: Pickle, Ken
Subject: RE: Draft permit, staff report
Ken,
It's looking like August 6 or August B. Are both of these dates available for you to meet in Raleigh? Please advise.
Tim

r • 1
Timothy R. Basilone
Vice President - Environmental Affairs
Horsehead Corporation
4955 Steubenville Pike
Suite 405
Pittsburgh, PA 15205
P 724,773.2223
F 412.788.4526
C 412.287.9871
TBasilone _Horsehead. net
From: Pickle, Ken [ma ilto:ken. gicklePncdenr.gov]
Sent: Thursday, July 19, 2012 1:42 PM
To: Forrest Westall; Basilone Tim
Cc: Wilson, Susan A; Bennett, Bradley
Subject: FW: Draft permit, staff report
Hi Tim, Hi Forrest,
received commen from the Asheville Regional Office on the proposed draft permit for Horsehead. Please see p.
4 of 4, attache .
Spe A recommendations:
• uire SPPP to be developed before start up. Note this is already required in the boilerplate (Part Ill Section A
). Oops, my oversight: during the discussion with ARO, I forgot that the draft permit already requires that the
SPPP be in place on day one. ARO's comment emphasizes the importance that we attach to implementing the
SPPP at this site. I'm not inclined to withhold the permit issuance for the completion of the SPPP, however.
SPPP to address potential failure modes with a back-up Ian identifying management actions in response to
atypical operating conditions. I like it. One path for us would be to revise the draft permit text to require some
form of ARO prior revie and approval of the SPPP. Let's discuss.
• Add chlorides to the monitoring suite. Reasonable, I like it. Draft permit to be revised to include chlorides.
• Add quarterly acute tox testing. Reasonable given that heavy metals are of concern, I like it. Draft permit to be
revised to include tox testing.
• Provide a 'step-down' in analytical testing from quarterly to 2/yr after 3 years, conditional on results. I like it.
Draft permit to be revised to include step-down provisions, conditional on results. After three years, ARO and
Central Office to jointly evaluate results in response to a petition from the permittee for reduced monitoring.
Gentlemen, we talked about a meeting in Raleigh to go over your comments on the draft permit, and on ARO
comments. ARO will participate in the discussion, either by conference call, or in person. I know you're anxious to
expedite our process, so let's have the meeting ASAP. Whatever you can supply as far as any pre -meeting outline of
the topics and supporting ideas would help us prepare for an effective meeting.
Over the next month, I'm available the remainder of July, except for July 26. I'm also available up through August 16,
but not Friday, August 17 — Thursday, August 23. If you will suggest a couple of dates, we can see about ARO
participation.
Thanks,
Ken
Ken Pickle

Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: [e-mail]
Website: http:I/I)ortal.ncdenr.org/web/wgLws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations."
From: Wilson, Susan A
Sent: Wednesday, July 18, 2012 11:58 AM
To: Pickle, Ken
Subject: RE: Draft permit, staff report
Ken — here's the signed staff report/ARO comments. Thanks!
Susan A. Wilson - Susan.A.Wifson ncdenr.Fzov
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Surface Water Protection
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and
therefore may be disclosed to third parties.
From: Pickle, Ken
Sent: Wednesday, July 18, 2012 11:51 AM
To: Wilson, Susan A
Subject: RE: Draft permit, staff report
Ok, will let you know.
kbp
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken.pickle2ncdenr.gov
Website: htto://oortal.ncdenr.org/web/wa/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**

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

To: 'Basilone Tim'
Cc: Forrest Westall; Bennett, Bradley
Subject: RE: Draft permit, staff report
Hi Tim,
Thanks for noting the issues. We'll be glad to meet with you on these items. I'll let you know ASAP after I have
comments in hand from the Regional Office.
See below my attempt to pare back the items that I don't think we have any disagreement on. My comments in red.
I114wi
Ken Pickle
Environmental Engineer
NCDENR i DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken.pickle(c�ncdenr,gov
Website: http lll)ortal.ncdenr.org/weblwg/`ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Basilone Tim[mailto:tbasiloneCcbhorsehead.net]
Sent: Monday, July 09, 2012 4:13 PM
To: Pickle, Ken
Cc: Forrest Westall
Subject: RE: Draft permit, staff report
Ken,
After you receive comments from the4'ne would like to meet with you to discuss our comments. At #his point you
shed be advised of the following.
1 The facility will not process abut raw material that is a product "zinc oxide". My mistake. Not
significant to my evaluatioapplication�ll change the Fact Sheet accordingly.
2. We need a more complete understanding of the risk evaluation and the basis for benchmark levels. Let's talk.
It is not kerosene that is the carrier hydrocarbon but a product that has less aromatics than kerosene. We'll get
the specific name for you. Probably not an issue for me whether it is kerosene, or kerosene -like. Is it a
riws-'r-10
petroleum hydrocarbon? Probably not significant in the resulting elements of the permit text. I'll adjust
the Fact Sheet accordingly.
4. Benchmark values - we need to discuss these because of specific discOL
a characteristics for the site. Let's
talk. Q
5. It appears as though the amount of monitoring in addition to the tiered levels is overly restrictive. Let's talk.
6. Described internal monitoring for water in secondary containment features is inconsistent with our prior
discussions. OK, let's go over this again.
We'd like to meet with you in Raleigh after you receive other comments. Thanks for the opportunity to review the drat
permit at this early stage.
Tim
Timothy R. Basilone
Vice President - Environmental Affairs
Horsehead Corporation

4955 Steubenville Pike
Suite 405
Pittsburgh, PA 15205
P 724.773.2223
F 412788.4526
C 412.287.9871
TBasilone aC7,Horsehead.net
From: Pickle, Ken [ma ilto:ken. pickle(&ncdenr.gov]
Sent: Friday, June 29, 2012 3:06 PM
To: Basilone Tim; Forrest.westall2mcgillen4ineers.com
Subject: Draft permit, staff report
Hi Tim, Hi Forrest,
Here is the draft permit, and our staff report, which is an abbreviated rationale document in support of the permit
conditions. The staff report makes a condensed record of how we view the site and the application, and serves as the
key communication tool between the initial application reviewers (me) and our Regional Office staff. Our standard step
now is to solicit comments from the Regional Office. I've asked for comments back from the Asheville Regional Office by
mid -July.
By transmittal of this advance courtesy copy, I'm also soliciting your comments on the draft permit.
Sorry for the delay beyond my most recent promise date: COB Friday, instead of COB Thursday.
Best Regards,
Ken
Ken Pickle
Environmental Engineer
NCDENR i DWQ j Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken, picklencclenr. ciov
Website: htti)://i)ortal.ncdenr.org/w.eb/wq/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**

Pickle, Ken
From: Pickle, Ken
Sent: Tuesday, June 05, 2012 3:23 PM
To: Ratcliffe, Judith
Cc: Gadd, Laura; Georgoulias, Bethany; Bennett, Bradley
Subject: RE: Broad River, Rutherford County
J udy,
Thanks for the help, I really appreciate it.
Our stormwater permitting program typically would want to know about aquatic T&E species maybe 20 — 30 times per
year. Would you be the best entry point into NHP information? How would we do that most conveniently for you all?
Ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service, Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. picklePncdenr.00v
Website: http://portal.ncdenr.org/web/wq/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Ratcliffe, Judith
Sent: Tuesday, June 05, 2012 3:14 PM
To: Pickle, Ken
Cc: Gadd, Laura
Subject: Broad River, Rutherford County
Hi Ken,
checked our records for aquatic species in the Broad River, Rutherford County, vicinity of the project and there are no
records for any rare aquatic species.
The site of the project itself appears to overlie one of our Programs Significant Natural Heritage Areas, Brice Rare Plant
Site. This site provides habitat for a Federal Threatened. plant, Dwarf -flowered heartleaf (Hexastylis naniflora). The
applicant may already be aware of this as our Program provided comments on this project in October 2011. If they
have not already done so, they may wish to consult directly with Mara Alexander with the US Fish and Wildlife Service
(828-258-3939 x238) and/or Rob Evans with the NC Plant Conservation Program (919-218-5774).
I've cc: Laura Gadd, our Program Botanist, as she is responsible for our rare plant records. Please let me know if I can be
of further assistance...
Judy
Judith Ratcliffe
Freshwater Ecologist, Eastern Region

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

. +l.
Hi Judy, thanks for your help. OK, here is Google Map's email capability. I hope this works for us. The
site is the cleared area centered in the photo, and on the south bank of the Broad River in Rutherford
County. One-half mile north of the NC -SC state line; one -quarter mile west of US 221. Two powerline
ROWs run east -west in the vicinity, with the southern ROW cutting through the site. The site is
located in the curl of the railroad where it turns from a northeast direction to a northwest direction. I've
never used this from Google Maps so I'll follow up with another email to see if you received this one.
Thanks again for your help! Ken
Hi, I'd like to share a Google Maps link with you. Link: <http://maps.google.com/mays?hl=en&ie=UTF8&11=35.192784,-
81.850805&s n=0.025216 0.038409&t=h&z=15&vsrc=6>
9

'i
Picyle, 4n
From: Forrest Westall [[e-mail]]
Sent: Monday, April 02, 2012 2:56 PM
To: Pickle, Ken
Cc: Bennett, Bradley
Sub;-cct: RE: Horsehead application
Thanks Ken. I will check with Tim Basilone so we can set a date and time.
Forrest
Forrest R. Westall, Sr., PE
Principal
McGill Associates, P.A.
38 Orange Street I Asheville, NC 28801
Phone:[phone] Fax: [phone]
Email: [e-mail] I Website: www.mcgillengineers.com
From: Pickle, Ken [ma ilto:ken. [e-mail]]
Sent: Monday, April 02, 2012 2:10 PM
To: [e-mail]
Cc: Bennett, Bradley
Subject: RE: Horsehead application
Hi Forrest,
Yes, after I return might be a pretty good arrangement. Either the first or second week of May?
Ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. pickleCa ncdenr.gov
Website: http://portal.ncdenr.org/web/wq/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Forrest Westall [mailto:[e-mail]]
Sent: Monday, April 02, 2012 1:23 PM
To: Pickle, Ken
Subject: RE: Horsehead application

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

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

Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken, ncdenr.gov
Website: htti)://portal.ncdenr.org/web/wo/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Pickle, Ken
Sent: Thursday, March 29, 2012 12.55 PM
To:'[e-mail]'
Cc: Bennett, Bradley; Chernikov, Sergei
Subject: RE: Horsehead application
Hi Forrest,
The Horsehead package was stamped in yesterday. Upon first review this afternoon, I note that there is no permit
application fee.
The fee is $860, payable to NCDENR.
We are aware of our promise to you and to Horsehead to expedite processing of the application. But, we cannot even
enter the application into the tracking system and assign an application number, or otherwise process the application
without the fee. Under most circumstances we send such submittals back to the applicant with a form letter noting the
missing fee.
Please send the check to me ASAP. Overnight would be best if you can manage that. I note that there was some
confusion in delivery address for the package (initially directed to Mike Randall, I believe).
Use this street address for me:
NC Division of Water Quality
Archdale Building
512 North Salisbury Street
Raleigh, North Carolina 27604
Attention: Ken Pickle, Stormwater Permitting Unit
Thanks,
Ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604

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

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

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

Pickle, Ken
From: Pickle, Ken
Sent: Thursday, May 17, 2012 12:16 PM
To:'[e-mail]'
Cc: 'Basilone Tim'; Bennett, Bradley; Georgoulias, Bethany
Subject: RE: SW Template
Attachments: Individual Permit_Template_FINAL_1Mar2012,docx
Hi Forrest,
Here's the template we're using now. Some background on how I will convert this template into Horsehead's permit:
• We start with the template and then Parts I and II are subsequently crafted/edited to be site specific, and to
address DWQ's assessment of the nature and degree of the pollutant risk on the.site. The anticipation of
crafting this part of the permit is what fuels our seemingly unrelated questions about processes, operations, and
site conditions - - we want a comprehensive picture of what happens on a site so that we can assess the risk of
the potential of pollutant releases via stormwater discharges.
• Parts III and IV are the boilerplate provisions which we edit less frequently since the conditions contained
therein are generally considered to be applicable for all of our stormwater permittees, regardless of site -specific
conditions.
• Note that the file is dated March 2012: this template evolves overtime as our experience grows implementing
it. It is updated irregularly as we feel the need, usually based on our crisper understanding of exactly what
federal rule requires of the agency (us) and the permittee, and how we might more effectively protect the water
quality of North Carolina.
• Although our work on an individual permit is based on the template, we typically review every sentence in the
document to be sure there are no internal inconsistencies. Out of respect for the continuing reuse of the
boilerplate in other permits, we may leave in boilerplate provisions that don't apply for the site conditions of a
particular permittee, as long as they're not contradictory to other portions of the text.
I'm scheduled to complete my first, internal, draft tomorrow. I'll contact you with any questions, but realistically, I don't
expect to have any. I should have a courtesy early -review copy early next week. If you have comments on that version,
I'll consider/incorporate/reject them and then start the 'Staff Report' step with the Regional Office. The RO will review
the pre -draft version and comment on it. I'll then publish the official 'Draft' permit and send it to you for any other
comments.
Ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken, [e-mail]
Website: httr)://iportal.ncdenr.org/web/wq/­ws/­su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**

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

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

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

my part (the stormwater permit) is consistent with all the rest of the site conditions. At this point, I need to drop back to
strictly what are the application review points. My interest in all the surrounding knowledge is at an end. So, I don't
need further explanation of their process, their site, their operations. Hence my uncertainty as to why we need to meet.
(Of course, real world conditions can always present circumstances that don't fit my nice neat compartmentalization.)
ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: [e-mail]
Website: htto://i)ortal.ncdenr.ora/web/wq/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Pickle, Ken
Sent: Tuesday, March 27, 2012 11.16 AM
To:'[e-mail]'
Cc: Bennett, Bradley
Subject: Horsehead application
Hi Forrest,
I listened to your voice message this morning.
It's good to know that the application is either in the mail, or already here. Thanks for the heads -up. We will
attend to it quickly.
Yes, a meeting shortly after we receive the application might be helpful. I suggest we tentatively schedule it,
and allow DWQ the prerogative of calling it off if we don't see any need to meet. Early the week of April 9 might
be best.
o Do you think we will need to meet? I think we talked through the concepts pretty well. I guess the
details will show how well we communicated with each other on the concepts.
o If you think now that we certainly will need to meet, my question would be, why? Let us know in
advance why so that the meeting can be as productive as possible.
o I mean, unless there is something peculiar, we don't need Horsehead to talk us through their
application. Do we?
We have a couple of complicating issues wrt our time to meet that week.
o We were scheduled to be moving personnel and office furniture all. around Archdale the week of April 9-
13. But, as soon as Bradley sent around the move schedule this week, we got news of a delay based on
another agency's constraints. Now we are not sure when we will be moving. It may be.that the week
will be totally free from moving activities. It may not.
o Bradley and Dave Goodrich are coordinating the move for multiple units in DWQ. So, Bradley's
availability during that week is uncertain, in part because the actual date of the move is now uncertain.

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

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

1
As we discussed, permit acquisition is still on the critical path for finalizing construction and commencing operations in a
timely manner. The Department's cooperation, timely review and action on the NPDES permit for process discharge
water was a very important factor in Horsehead's selection of this site. Similarly, we appreciate your commitment to work
with us in providing a timely review of our application, and issuing a NPDES stormwater permit for the facility without
delay.
We plan to provide a draft of our permit application to you for comment. Based on comments from your review, the permit
application will be revised and finalized for submittal to the Department for review. We believe this approach will result in
a complete and accurate permit application, and that following submittal will enable the Department to analyze the
application and issue a permit promptly.
Thanks again. Please let me know if you have any questions.
Forrest
Forrest R. Westall, Sr., PE
McGill Associates, P.A.
PO Box 2259
Asheville, NC 28802
Physical Location: 38 Orange Street, Asheville
Phone [phone]
Fax [phone]
forrest. we stall kmcgillen ineers.com
From: Pickle, Ken [mailto:[e-mail]]
Sent: Wednesday, November 30, 2011 9:53 AM
To: [e-mail]
Cc: Bennett, Bradley; Chernikov, Sergei
Subject: Horsehead meeting yesterday
Hi Forrest,
Good meeting yesterday from my perspective. I hope you and your client feel the same. Thanks for taking the trouble
to go over the physical facts with me.
A few things occurred to me that were not addressed, or not completely addressed, yesterday:
As presented yesterday, Horsehead will have a lab on site, and they will be doing their own analyticals for the NPDES
stormwater permit. Please note: for the permit reporting their lab must use the EPA Methods. I assume that for
internal process QA/QC Horsehead might intend to use analytical methods other than EPA Methods. That's OK for their
internal process QA/QC, but it doesn't satisfy the NPDES requirement under federal regulation for the water quality
analyses undertaken in direct response to permit requirements.
However, there is a provision in the federal rule that will allow us to accept alternative methods. They just need to
come forward and request our approval in advance if methods other than the EPA Methods are contemplated. We will
pass the request on to our inorganic lab folks for review.
Of course, it goes without saying that an acceptable method must go down to an MDL/PQL that will be below the
benchmarks.
• On the issue of lab certification, two aspects are of note here.
If they will be running analyticals for Sergei's wastewater permit, then the lab must be state certified for the analyses
related to the wastewater permit limit parameters.
However, for NPDES stormwater permit testing, DWQ certification is not required. Stormwater analyticals are a
special case, and are not required to be by certified labs/staff. However, however - - Even if not certified, the lab must

. - --`
still use the EPA Methods for stormwater analyses, as required by federal rule - - or they must have our approval of
alternative methods.
Just chatted with Bradley, and we think that the substation east of the railroad is not dart of he industrial activity, and
would not have stormwater discharges regulated under the NPDES stormwater program. We had already reached this
tentative conclusion in our meeting,' but I had promised to check on it for us. The substation will not be subject to the
stormwater permit.
• Just to reiterate the point about the perimeter site roads: Drainage from the site roads is considered stormwater from
industrial activity. Yesterday Horsehead related their intent to capture that runoff. Just to clarify: Roads are typically
designed with a crowned cross-section - - It appears that Horsehead must either design a sloped but un-crowned cross
section draining to the inboard side, or must include runoff capture features on the outboard side of the road to capture
that runoff and direct it back to the inside. It's my impression that an un-crowned road is an unusual feature, and
typically must be the subject of deliberate focus during the site design process.
kbp
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken.Qickle@ncdenr.00v
Website: httR://portal.ncdenr.org/web/wg/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
3

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

Permit NC001109
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked. As of this permit issuance, any previously issued permit bearing this number is no longer
effective, Therefore, the exclusive authority to operate and discharge from this facility arises under the
permit conditions, requirements, terms, and provisions included herein.
Horsehead Corporation is hereby authorized to:
1. • After constructing the wastewater treatment facility, operate it in accordance
with th existing wastewater treatment system onsisting of the following
components: 7
Automatic sampler
low Instrumented flow measurement, and
A, Diffuser
The facility is located near Forest City, Rutherford County; and
2. Discharge from said treatment works at the location specified on the attached
map into the Broad River which is classified C waters in the Broad River Basin.

Permit NCO089109
A (1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee
is authorized to discharge from outfall(s) serial number 001. Such discharges shall be limited and
monitored by the Permittee as specified below:
EUVI ENT
CHARACTERISTICS
LIT �S''
MONITORING
REQUrREMENT$
.,
Monthly
Average
Daily
Maximum
Measurement
Frequency
Sample
r+ype
S ple M
Loeation;__
Flow (MGD)
0.62
rContinuous
-/Recording
I or E
Total Suspended Solids
Monthly
Composite
E
NH3-N
Quarterly
Composite
E
Total Aluminum
Quarterly
Composite
E
Antimony
Quarterly
Composite
E
Arsenic
Quarterly
Composite
E
otal Cadmium
350 ug/L
2,143 ug/L
Monthly
Composite
E
Chlorides
Quarterly
Composite
E
Total Chromium
Quarterly
Composite
E
Total Cobalt
Quarterly
Composite
E
Total Copper
Quarterly
Composite
E
Fluoride
315.8 mg/L
315.8 mg/L
Monthly
Composite
E
Total Iron
Quarterly
Composite
E
notal Lead
4,386 ug/L
4,829 ug/L
Monthly
Composite
E
Total Nickel
Monthly
Composite
E
Total Tin
Quarterly
Composite
E
Total Zinc
Quarterly
Composite
E
pH2
Weekly -I
Grab
E
Chronic Toxicity-
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 Q 0.57%; Jan., April, July and October; See
condition A(2) of the Supplement to Effluent Limitations and Monitoring Section of this
permit.
4 The discharge from this facility shall not cause turbidity in the receiving stream to
exceed 50 NTU. If the instream turbidity exceeds 50 NTU due to natural background
conditions, the discharge cannot cause turbidity to increase in the receiving stream.
THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR FOAM VISIBLE IN OTHER THAN
TRACE AMOUNTS.

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

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

Pickle, Ken
From: Forrest Westall([e-mail]]
Sent: Tuesday, July 05, 2011 7:18 AM
To:. Pickle, Ken
Cc: Bennett, Bradley; Chernikov, Sergei; Karoly, Cyndi; 'Basilone Tim'; 'Cooper Darin';
[e-mail]
Subject: RE: Horsehead
Hi Ken,
Thanks for the note. I was out last week and didn't get a chance to respond.
We appreciate the offer to review preliminary permit packages for he SW permit. We will certainly take you up on that and
agree that we want to avoid any delay due to not including information needed for your review. The term "final site facility
layout plan" as used in Mr. Basilone's letter describes a full civil/utilities layout including all site drainage and any
storwmater retention/capture/treatment facilities planned, showing each drainage area and the associated point of
discharge to surface waters. All outfalls from the site would be shown. In addition, using the review process you outline
will give us the opportunity to identify any additional information on the detailed site plan that you will need to complete the
permit review.
Thanks again,
Forrest
Forrest R. Westall, Sr., PE
McGill Associates, P.A.
PO Box 2259
Asheville, NC 28802
Physical Location: 38 Orange Street, Asheville
Phone [phone]
Fax [phone]
[e-mail]
✓ From: Pickle, Ken[maiIto: ken. pickle(-Oncdenr.govl
Sent: Thursday, June 30, 2011 7:46 AM
To: forrest.westall mcgillengineers.com
Cc: Bennett, Bradley; Chernikov, Sergei; Karoly, Cyndi
Subject: Horsehead
Hi Forest,
I just reviewed Mr. Basilone's letter of 6/13/2011. 1 have a comment on one bullet item, as follows:
"Horesehead will submit a storm water permit application for the site as soon as the final site facility layout plan
is completed. This is expected to occur in the early fall"
I'd be glad to do a courtesy review of the site plan earlier, at maybe 50% or 75% or 90% complete, whatever is
convenient for the consultant developing the site layout. You may be familiar with a common dynamic in a design
house, where the least important aspect of the project delays it because no one did an early review. Why wait until the
"final site facility layout plan is completed"? Please consider coming to see me early, and bringing progress drawings on
every aspect that you think may have a Bearing on our eventual review in support of the stormwater permit application.

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

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

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

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

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

Fax: [phone]
Email: [e-mail]
Website: httR://[)ortal.ncdenr.org/web/wq/­ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Forrest Westall [mailto:[e-mail]]
Sent: Monday, November 21, 2011 2:34 PM
To: Pickle, Ken
Cc: Bennett, Bradley; Georgoulias, Bethany; Chernikov, Sergei
Subject: RE: Horsehead zinc reclamation plant
Thanks Ken. This information is helpful. You indicated you are available the week of the 28th. I'm trying to check the
schedule of the company representative, but if you are available the 29th could you tentatively set aside some time late
morning or early afternoon to go over the site plan and discuss our approach to SW management on the site?
Just let me know,
Have a good afternoon,
Forrest
Forrest R. Westall, Sr., PE
McGill Associates, P.A.
PO Box 2259
Asheville, NC 28802
Physical Location: 38 Orange Street, Asheville
Phone [phone]
Fax [phone]
forrest.westall cr,mcgillengineers.com
From: Pickle, Ken [mailto:[e-mail]]
Sent: Monday, November 21, 2011 11:10 AM
To: [e-mail]
Cc: Bennett, Bradley; Georgoulias, Bethany; Chernikov, Sergei
Subject: Horsehead zinc reclamation plant
Hi Forrest, nice to speak with you this morning.
Just to restate: As we discussed, I am not aware of any instance in which the NPDES industrial stormwater program
identified a design storm approach in our permitting. Our permit has benchmark values that serve to alert the site
manager when pollutants at a level of concern are being discharged. The permit calls on the site manager to react
when he becomes aware of those levels of concern. Our approach might be considered a performance spec —'Just
meet the numbers, however you can.'
As you requested, please see attached below the narrative discussion and the tabulation of the benchmarks that could
appear in any of our stormwater permits.

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

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

Pickle, Ken
From:
Pickle, Ken
Sent:
Tuesday, November 29, 2011 6:07 PM
To:
Georgoulias, Bethany; Bennett, Bradley
Subject:
RE: Horsehead zinc reclamation plant
FYI, No Action:
Met this afternoon with Forrest and the folks from Horsehead. No problems, as far as I can see.
• We did touch on the topic of dilution in the Broad River, and the fact that stormwater benchmarks are lower
than some of the wastewater limits. i first acknowledged that it could be viewed as an inconsistency, and began
a defense of this aspect of our program. However, Forrest was enthusiastic about the acceptability of our end of
pipe benchmark approach, and was not interested in my beginning defense: point resolved acceptably to all,
apparently, without me having to get into it. I'm not sure what misapprehension was active here, but we were
all smiling after a while.
He stated that a permit application would be forthcoming, and I did not detect any residual objection to the
`end -of -pipe' approach in our program. He challenged us to beat Sergei's 30-day turnaround time which, with
suitable bravado, I sniffed at.
I went over NCG17, as an example of the SPPP and the Tiered approach. They seemed content with their
obligations under any similarly constructed permit (an NCS, in their case.)
ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: [e-mail]
Website: http://portal.ncdenr.org/web/wcl/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Pickle, Ken
Sent: Tuesday, November 22, 2011 3:27 PM
To: Georgoulias, Bethany; Bennett, Bradley
Subject: RE: Horsehead zinc reclamation plant
FYI, No Action
Read further only if you have a special interest.
Just took a look at Sergei's permit for Horsehead. Here's the issue for Forrest, I think, that stormwater benchmarks are
lower than wastewater limits:

Parameter
NCO089109 Wastewater
discharge limits
Potential NCS benchmark
Apparent
discrepancy?
Comment
Flow
0.62 MGD mo. avg.
-
T55
Monitor only
100 mg/L
Ammonia-N
"
7.2 mg/L
Aluminum
0.75 mg/L
Antimony
0.09 mg/L
Arsenic
0.36 mg/L
Cadmium
350 ug/L mo. avg : 2143 ug/L
daily max
1 ug/L
x
3 orders of
magnitude
Chlorides
Monitor only
860 mg/L
Chromium
" "
1 mg/L
Cobalt
0.03 mg/L
Copper
0.007 mg/L
Fluoride
315.8 mg/L : 315.8 mg/L
6 mg/L
x
2 orders of
magnitude
Iron
Monitor only
1 mg/L
Lead
4386 ug/L : 4829 ug/L
30 ug/L
x
2 orders of
magnitude
Nickel
Monitor only
0.26 mg/L
Tin
-
Zinc
0.067 mg/L
pH
6-9
6-9
Chronic Toxicity
Monitor only
-
Turbidity
Instream < 50 NTU, or no
increase
Instream < 50 NTU, or no
increase
Considering the above, and based on recollection of our phone calk, it wouldn't surprise me for Forrest to highlight the
following aspects of the currently proposed site design:
• There are three natural drainage features on the property, but converting all that pasture and woodland to an
effectively impermeable plant site means that the three features are not hydraulically equipped to handle the
increased flow; with the result that trying to utilize the three features would result in significant erosion and
head cutting. There is a 90' steep slope from the terraced plant site to the fiat ground around the river. The
combination of topography and increased flow argues against trying to use the existing features for stormwater
conveyance.
Instead, Horsehead will capture all the excess site runoff and direct it to a single outfall pipe directly into the
Broad River. (`Excess site runoff, because a portion of the site runoff will be utilized in the process. So, there
may be discharges only in large events, or when the facility is not operating -- I'm not exactly clear on when
discharges would occur.) Given the great dilution in the Broad River, even at low flow, and as reflected in the
relatively high wastewater limits above, does it make sense to have such low benchmarks for the stormwater
discharges? Essentially Forrest's argument may be: If Sergei's analysis quantifies the pollutant limits necessary

to protect the Broad River for a 365d/yr discharge, shouldn't the less frequent, more diluted stormwater
benchmarks be at least as high, if not higher?
The facility has already been through the DAQ, and the emissions into the atmosphere are ok with our brothers
and sisters in DAQ. So, if it's already authorized to be in the environment, then DWQ shouldn't double count
those heavy metals just because some of them fall out on the plant site and are washed off in the runoff.
NOTE: It sounds like Horsehead and Forrest will be coming forward with a site plan that makes no attempt at BMPs or
any stormwater treatment. The primary raw material here is EAFD(?) Electric Arc Furnace Dust - - it's chockfull of heavy
metals — obviously, because zinc and plumbum are their products. Our assessment for the potentiol for polluted runoff
should consider the hazardous nature of heavy metals.
The first counters that come to mind are:
• The benchmarks are not permit limits. They are flags for the site manager so that he can be vigilant in insuring
that pollutants from industrial sites do not accidentally slip off his site in stormwater runoff. It makes sense for
us to require response actions as outlined in our individual permit template in order to have site managers
serious about the discharge of pollutants from their sites.
• For intractable conditions DWQ can grant relief from the benchmarks.
• Where accumulated data can show that pollutants are not present and not discharged from the site, DWQ can
easily re -open the individual permit and amend the monitoring requirements as to frequency and parameter.
First let's characterize the discharges from this unusual industrial facility (there are none exactly like it in the
world, and only a few even reclaiming EADF by any process), and let's err on the side of protecting the
environment, and then let's back off where accumulated data shows that we have been overly cautious.
• If the site is indeed clean, there shouldn't be a problem meeting these benchmark values.
• If there is a problem, then perhaps street sweepers, or additional roofing, or bioretention cells in hot spot
sources, or grassed conveyances could help. At least try to do something if heavy metals are leaving your site.
• We acknowledge that for some, it may be counterintuitive that stormwater benchmarks would be lower than
wastewater limits. But each program has their own set of procedures and rules that determine how we permit
industrial facilities. An attempt to reconcile the two programs is a programmatic endeavor that we don't have
the resources to attempt at this point in time.
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: [e-mail]
Website: htto://Rortal.ncdenr.org/web/wq/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Georgoulias, Bethany
Sent: Tuesday, November 22, 2011 7:49 AM
To: Pickle, Ken; Bennett, Bradley
Subject: RE: Horsehead zinc reclamation plant

.- , k4'
If he can tell us a way to do it consistently for everybody, I'm all ears.
Bethany Georgoulias
Environmental Engineer
NCDEN^ i DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
NEW Website: http://portal.ncdenr.org/web/wq/ws/su
E-mail correspondence to and from this address may be subject to the North Carolina Public
Records Law and may be disclosed to third parties.
From: Pickle, Ken
Sent: Monday, November 21, 2011 1:42 PM
To: Bennett, Bradley; Georgoulias, Bethany
Subject: FW: Horsehead zinc reclamation plant
FYI, No Action, Heads up:
The perspective that if there is no resulting WQS violation, it's ok to discharge pollutants crept into the discussion today
with Forrest.
It sounds like it's tied to his thoughts about the dilution capacity in the Broad River, and the RPA procedure.
We have previously rebuffed this approach in other circumstances.
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: [e-mail]
Website: http://yortal.ncdenr.org/web/wq/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Pickle, Ken
Sent: Monday, November 21, 2011 11:10 AM
To: '[e-mail]'
Cc: Bennett, Bradley; Georgoulias, Bethany; Chernikov, Sergei
Subject: Horsehead zinc reclamation plant
Hi Forrest, nice to speak with you this morning.

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

industrial stormwater. We do not have the same history or authority as the NPDES wastewater program, as far
as considering the dilution factor into the Broad River, and back -calculating wastewater permit limits based on a
Reasonable Potential Analysis. Please let us know early if you see a need to explore further the Broad River
dilution approach. This idea takes us out of just a routine permitting approach, and calls on us to evaluate
programmatic consistency and impact, as well as equitable treatment of other permittees, as well as consistency
with the federal NPDES stormwater rules and whether we have authority to act based on dilution. If you choose
to pursue it, conclusive discussion of this idea must include those up the chain from me.
• Here are the two attachments and the link to a General Permit to show you roughly how we would write up a
Tiered structure for Horsehead.
«File: Individual Permit Benchmarks Final.doc>> «File: Individual Permit Benchmarks Rationale Fina1.doc
http:/Iportal.ncdenr.org/cldocument library/get file?uuid=fde771c4-fe8e-44ad-ab70-323334845d33&groupId=38364
Forrest, I'm here through Wednesday this week, and back in the office on Monday next week if we need to talk, or to
schedule a site plan review together.
Thanks,
Ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. pickle(a)ncdenr.gov
Website: http:/Zportal.ncdenr.org/web/wcl/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**

r:� W
TIMOTHY R. BASILONE
Vice President - Ernlirorrrnental Affiairs
4955 STEUBENVILLE PIKE WWW.HORSEHHAO.NET 724.773.2223
SUITE 405 TBASILONE@HORSEHEA4-NET 412.788.4526
PITTSBURGH, PA 15205
June 13, 2011
Mr. Charles Wakild, Deputy Director
North Carolina Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Ve ✓1
0 �S'iE� IEAD�
CORPORATION
Leadixy the World in Zinc Recycfins
ii JUN 1 5 2011 -
RE: May 9, 2011 Meeting— ---� -_,
Division of Water Quality
Horsehead Corporation, Proposed Production Facility, Rutherford County
Stormwater NPDES Permitting and 401 Certification Processes
Dear Mr, Wakild-,
I'd like to thank you and others from NCDWQ, including Mr. Matt Matthews, Ms Cyndi
Karoly, Mr. Bradley Bennett, Dr. Sergei Chernikov and Mr. Ken Pickle, for giving
Horsehead Corp. (Horsehead) the opportunity to meet with you on May 9, 2011 and
discuss the potential plans for constructing a zinc production facility in Rutherford
County, North Carolina. Horsehead and our consultant, McGill Associates, appreciate
information you provided concerning stormwater NPDES permit issues and the 401
certification processes. You provided valuable information with regard to requirements
dealing with these subject areas that would apply to Horsehead's proposed facility.
At the meeting.. Horsehead provided a summary of the company's business, a description
of the new plant and processes invo ved to produce zinc metal, and noted the importance
of this new production facility to our business plan. As we indicated in our meeting,
understanding the permittmg_process and securing necessary permits in a.timely manner
for the sites under consideration is a critical component in making a decision as to the site
that will be selected for this facility.
The PowerPoint presentation provided at the meeting contains business confidential
information. A copy of the presentation was not provided to you, but we request that ke
production process design information for the facility and site be protected under State
and Federal law, and that this informationbe treated as Business Confidential. 7 "5tns1�ess
L., inuSf refe�fo c�nftCPe�N�f Peawro,nt l p^ �Pn� lc'
P 117fl the/-e/i7,
As we pointed out during the meeting, the information provided about the facility and the
site is preliminary and represents a general description of the operation of this proposed
facility. We are continuing with our facility design efforts and establishment of the final
operating criteria for the plant. Horsehead and associated consultants for this project are
available to answer any questions that you may have and welcome the opportunity to
discuss stormwater and 401 permitting requirements for the proposed facility.

Discussions during the meeting were beneficial for our understandin of the State's
stormwater and Section 401 permitting processes, and provided information required to
obtain these permits. Furthermore, we gained valuable insight as to the time required by
fhe agw ency for review of the permit applications, and the decisions the agenc must make
to process the permit requests. Below is a summary of information obtainer
meeting to clarify our understanding of points made during our discussions.
y �erpi r.J�tdt
♦ Horsehead currently plans to configure the site in such a way that any we �binF
precipitation on the site that may be exposed to feedstock or final product/co- said.
product materials will be managed and used for the facility's production process.
[The NCDNR indicated that the permit for this stormwater would be evaluated
under the NPDES process wastewater permit and not under a stormwater permit,
♦ NCDWQ characterized this approach generally as a site with a ormwater �n N Pv�S''sfp�MWaT"«
drainage are having two separate collections terns: a "clean' side and a �`�noFs `'�S�"wale
nod' re gt2fC�
r"potentiall�ontaminated" side. The "clean" rtion of the facility drainage � p p�
would include drainage from the impervious non -process surfaces on the site
dc�ua/ c.Jo%�S
the MP��ing
(rooftops, non -process holding areas, and parking areas) and the landscaped areas
related to the site development, of including the areas of the property left in a `3
♦ NCDWQ indicated that a stormwater NPDES permit would be required for the
"clean" drainage and that this permit would essentially be directed at
S d y r ! spp k e
rPDUtre r+ei S wt t,
� rftirwTeh.a45
characterization of the_drainage systems identification of outfalls and provisions
-for the qualitative periodic monitoring of stormwater runoff from included areas
over the permit period, and development of a stormwater management plan for
the areas draining to the "clean" collection system,
Because there is currently no general permit for the Non -Ferrous Metals
production SIC, the NCDWQ would be required to process a permit application
under the individual NPDES Stormwater Permit portion of the program,
�w, ,�-I / tell :<ip.n k,hi Io sa6,,,,f f J• w.l�
♦ Horsehead and consultant representatives' will work in conjunctio with the
NCDWQ to develop alll o t e mformation requiredjto provide a complete NPDES
permit application for the facility's stormwater discharges that fal under this
program, '�ar�'nolarl.f.�
♦ LHorsehead and NCDWQ will coordinate activities to manage information
development for the compilation o.f_a cones 1p ete permit application,; and to develop
a schedule for securing a permit in the timeliest manner possible,
J�
♦ NCDWQ agreed to provide direct and quick communication by phone and e-mail
to address any questions related to the application and to resolve any issues in a
timely manner and to keep the review_process moving, tine w i 3 do a kf- p rT_), ,�' �rMe%, lgrooe s5� Iq /5 /I
r9 -Course
1-�[rSC��C°�c� � MtErii! aS�' do -�i�ei� par'
ach)r°���

r
♦ NCDWQ appointed Mr. Ken Pickle as the primary point of contact for 4K 411- n Ou1• 0775ersr
communication on the stormwater permit application process, "'aJ de /01'&'
♦ Horsehead will submit a stormwater permit application for the site as soon as the
final site facility layout plan is completed. This is expected to occur in the early
fall,
♦ Following submittal of a complete application NCDWQ advised that three to four "
T2nt
Jis would be required for the development of a final draft permit for public
notice under State requirements,
♦ Horsehead anticipates that the only stream/wetland impacts under Sections 404
and 401 of the Clean Water Act to be for an effluent dischar e utfall structure on
the Broad River and possibly a water intake structure for process water on the
River both of which likely can be covered under the Corps of Engineers
Nationwide Permit for utility activities and North Carolina's General Certification
for these activities,
♦ It is understood that a complete site evaluation for waters and wetlands will need
to be performed, and Horsehead will obtain such information before finalization
of any applications,
♦ NCDWQ agreed to work in coordination with Horsehead to secure a complete
401 Certification application once final proposed impacts can be established,
♦ Based on the identified impacts, NCDNR and Horsehead will establish quick
response lines of communication by e-mail and phone to resolve any questions
about the application and the processing of a final 401 Certification,
♦ Ms. Cyndi Karoly, NCDWQ Branch Chief for the stormwater and 401 programs
will be the initial point of contact, the review process will be assigned to the
appropriate staff for the stream/wetland impacts that are planned,
♦ NCDWQ indicated that all communication with Horsehead related to any
comments received from staff or the public would occur in a timely manner, and
that if further public review was required, the Division would move this process
along as quickly as possible to a final determination
� /on pending approvals and
permits. 9 n/Q cs.�/t✓o our fJZ�f: fuf r7ar�dOr d�`- /�C �r %� c�c�tans-.,Can d/Se
�✓���rm�rr� Z7 we ram.!/ have in dTf� iqq �o `mev� %s �rocp,tS
Mr. Ken Pickle has already provided several pieces of information and feed -back a/o� �$5� u,ck- ar
TAankJ following our meeting. We appreciate his responsiveness in helping us to develop our �o si61e
approach to stormwater management on the site.
scfs �h�
sr`a Commitments made by the NCDNR during our meetin provide information that is
critical or completing our site evaluation process. Horsehead looks forward to working
with the NCDNR on this important project. As you are aware this new production
saIs 74e hook

�a�.f�Rs �►vQ o� fhc 6'/"/ #'e' Rofs
fh� SPri%�q o� fie
facilit re resents a tar a commitment of resources and technology by Horsehead or the {7aar�
production of zinc and other non-ferrous metal products. ,
A1411 sire we knorJ o11�er r" &fa %s.
In relation to permitting requirements under the stormwater program, McGill Associates
will serve as our primary resource for development and submittal of a complete it
application. Mr. Forrest Westall at McGill Associates will assist in coordinating
R&mation flow between Horsehead and the NCDNR. Mr. Westall can be contacted at
828.231.6840 (cell) or 828.252.0575 (office).
We appreciate your assistance and that of NCDWQ's staf in helpin us t define the
stormwater permitting re uirements fort is sitgj Please feel free to contact me with any
questions you may have.
Sincerely,
�f� ��d►i`�ts✓ t 5 p eC[-1 � t a < . C:1�� [� c,�5n' �' d � tie• -f'�
Timothy R. Basilone VA e e d dam` f d"`� t� Pig ES re v j" w'e�
et 4.aC �at `� o 'I u1'� Sco�G o r �u41 © r4rfose.. �nd -tie con wGr5 a 1 i o w {� le t 4-
w 2 i ou r
cc Forrest Westall, McGill Associates best �x� �ora"��'" ^f°r "" 4-i
Darin Cooper, Horsehead Corp. t OLLr Verba(
t to
P o{rl- G o� l� n o+ b� -�- a it.e r
PerrnlLf,v.c3 p19roC2ss -r,f i4�+�5
�� ,�41� Servt as cur Pr-Erna<�i Tr°soare e` � ra3en ar �e�e�Z�-ion side.
` w'o� dSSit}- in �ocx �rtt3� �utQ Im4� rma4�ton -t-�o� a enc`f or aleje�a� tan
Gan'7of- S•/�°c'% foi�seh�z�

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

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

From: Forrest Westall[mailto:[e-mail]]
Sent: Thursday, December 08, 20117:47 AM
To: 'Pickle, Ken'
Cc: 'Bennett, Bradley'; 'Chernikov, Sergel'; 'Karoly, Cyndl'; 'Matthews, Matt; 'Wakild, Chuck'; 'Basilone
Tim'; 'Cooper Darin';'[e-mail];'[e-mail]'
Subject: RE: Horsehead Meeting November 29, 2011
Hello Ken,
Thanks for the follow-up and the confirmation on the substation and the distinction about stormwater
originating within the production area. We will be sure to address your comments about the access and
perimeter roads In the final site layout and design.
We appreciate the time you provided last Tuesday to meet with Darin, Tim and me so we could review the
site stormwater considerations for this new facility In Rutherford County. As we noted, the NPDES
process waste water permit has been issued and construction of the facility has commenced. The
meeting last week served as a follow-up to our preliminary discussions in May when Horsehead
Corporation was completing the site selection process. We left the May meeting with a general
agreement with DWQ on a conceptual approach for managing stormwater. At that time we also
committed to return to DWQ with a more specific site plan once production layout was completed: At
yesterday's meeting we provided detail as to the site layout and our approach for development of an
NPDES stormwater permit application for the facility.
Your input has been and continues to be very helpful In guiding our development of a permit application.
In follow-up to our recent discussion and In addition to the comments you have already made In your
follow-up, I am providing this summary to highlight important observations and conclusions that were
reached. We will now proceed with development of an application package with the clear direction you
provided, confident that the information submitted will be consistent with our understanding. We believe
that this will lead to a quick review.
During the meeting a copy of the production layout design plan was provided foryour use. The plan
provided highlighted areas and facility activities. In addition we described our approach for managing
stormwater from Individual and collective areas of the facility. We appreciate your comments and
agreement with our overall approach for managing stormwater at the facility. We plan to develop a draft
of the application for your review, and then finalize the application based on your comments for submittal
to the Department.
Key points we agreed to during our discussion are as follows:
■ You advised that all stormwater from within production areas (the area referred to in this
correspondence as the "developed site"), would need to be included under the NPDES
stormwater permit and monitored accordingly
■ We agreed that stormwater will be managed under an established management plan to meet the
requirements of the permit. The management plan will include provisions for managing
stormwater from production areas, including capability for accumulating and using this water for
production processes or discharging it based on results of sample analyses. Stormwater
managed in these areas was referred to during our discussions as being "discretionary water" for
process use or discharge.
■ Stormwater will be routed to one point of discharge, which will be the sole discharge monitoring
point in the NPDES stormwater permit. Discharge baselines for various parameters will be
established for performance monitoring
■ After discussing the general plan for managing storm water at the site, you advised that the
following Information should be Included with the NPDES stormwater permit application:

A site plan showing the production layout, stormwater collection and containment areas,
and stormwater channels leading to the discharge point
A map delineating the area(s) of stormwater generation regulated under the NPDES
permit
A site stormwater management plan describing details as to how storm water on the site
will be managed, Including process and non -process areas. Provisions described in the
plan will be Included In a stormwater PPP developed following finalization of the permit
and before commencement of facility operations
As we discussed, permit acquisition is still on the critical path for finalizing construction and commencing
operations in a timely manner. The Department's cooperation, timely review and action on the NPDES
permit for process discharge water was a very Important factor in Horsehead's selection of this site.
Similarly, we appreciate your commitment to work with us In providing a timely review of our application,
and Issuing a NPDES stormwater permit for the facility without delay.
We plan to provide a draft of our permit application to you for comment. Based on comments from your
review, the permit application will be revised and finalized for submittal to the Department for review. We
believe this approach will result In a complete and accurate permit application, and that following
submittal will enable the Department to analyze the application and Issue a permit promptly.
Thanks again. Please let me know if you have any questions.
Forrest
Forrest R. Westall, Sr., PE
McGill Associates, P.A.
PO Box 2259
Asheville, NC 28802
Physical Location: 38 Orange Street, Asheville
Phone [phone]
Fax [phone]
forrest.westall _ me ig Ilengineers.com
From: Pickle, Ken [mailto:[e-mail])
Sent: Wednesday, November 30, 2011 9:53 AM
To: [e-mail]
Cc: Bennett, Bradley; Chernikov, Sergel
Subject: Horsehead meeting yesterday
H1 Forrest,
Good meeting yesterday from my perspective. I hope you and your client feel the same. Thanks for
taking the trouble to go over the physical facts with me.
A few things occurred to me that were not addressed, or not completely addressed, yesterday:
As presented yesterday, Horsehead will have a lab on site, and they will be doing their own analyticals
for the NPDES stormwater permit. Please note: for the permit reporting their lab must use the EPA
Methods. i assume that for internal process QA/QC Horsehead might Intend to use analytical methods
other than EPA Methods. That's OK for their internal process QA/QC, but it doesn't satisfy the NPDES

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

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

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

a
r
Horsehead Corporation
NPDES Stormwater Permit
Rutherford County, North Carolina
Horsehead Corporation is the leading recycler of zinc bearing waste generated by
North American steel mini -mills, and the largest producer of zinc in the United
States. Construction is underway on a new zinc production facility located in
Rutherford County, just south of the Town of Forest City. The facility will have
limited air emissions and will discharge a clean brine process waste water.
This newly constructed facility upon startup in the future will apply a proprietary
hydrometallurgical process (solvent extraction / electro winning) for producing high
grade zinc metal from two primary feed materials including waelz oxide (a.k.a.
crude zinc oxide) and zinc metal drosses and skims recovered from galvanizing
operations. The production process includes use of feed materials in an aqueous
and hydrocarbon based solvent extraction process to produce a zinc rich electrolyte
solution for use in a cell house where an electro winning process is applied to
produce metallic zinc. Similar technology is commonly used to produce metallic
copper from mined copper ore feed material in the western United States. The
facility will have the capacity to produce approximately 148,000 tons of Special High
Grade (SHG) Zinc metal annually.
The following tables provide information on Feedstock Materials, Reagents, and
Products and By-product Materials that will be used and produced at the facility:
FEEDSTOCK MATERIALS
FEEDSTOCK
MATERIALS
QUANTITY
(tons/year)
Zinc Oxide (Zn0)
228,000
Galvanizer Skimmings
28,500
REAGENTS
REAGENT
QUANTITY
tons/year)
REAGENT
QUANTITY
(tons/year)
Limestone
36,000
2
(De ha
150
111.1
(Self i-ricaci&
41,300
Carbon
58
14.
i�__,NaCIO (12%) >
5,825
3
cNH�CI
44
Ic
z HCL _)
3,900
NaOH
11
Lime
1,608
NaHS
4
1j
Peroxide
975
Mn Sulphate
2,218
6
Kerosene
600
iQ
NaCl
1,200
g
Sr Carbonate,
165
NaCO3
4,400
Floe )
86
1
So
CIO
. €ems

PRODUCTS 1 BY-PRODUCTS
PRODUCT
QUANTITY
(tons) ear)
PRODUCT
QUANTITY
(tons) ear
Zn SHG
148,000
Final Residue
2,800
Zn CGG/PW
8,000
Non -Zinc Bearing
Metallics
1,132
Gypsum
61,000
Metallic Cement
536
Lead Concentrate
9,200
Crud Residue
156
Glaubers Salt
13,000
PLINT Residue
32,000
I_W42.104-10A(,a
The objective of the proposed storm water management plan is to manage all storm
water for discharge from the facility through a single monitored outfall to the Broad
River. Storm water from various areas of the facility will be managed according to
the following scheme:
1. Storm water falling into various operating/production areas will be collected
in segregated collection basins underlying or. adjacent to these areas, as
designated, will be analyzed for likely pollutants to determine its disposition.
Based on analytical results, the water will be discharged to the storm water
system, used in production process operations, or possibly treated prior to
discharge. This water is referred to as "discretionary storm water" for
discussion purposes.
2. Storm water drainage from standard commercial or landscaped areas and
perimeter roadways, roofed areas having no contact with industrial
processes. This water will be discharged directly to the storm water system
leading directly to the storm water outfall. This water is referred to as "non -
discretionary storm water", and
3. Storm water falling into a few designated operation areas will be collected in
segregated collection basins underlying the designated area(s) and used for
production process operations at all times, and not discharged to the storm
water system.
4. Storm water from undeveloped areas (fill and vegetated areas not affected by
plant activities) will be discharged through energy dissipation into natural
drainage channels.
Storm water from described areas 1 and 2• above will discharge to the single
monitored outfall for the facility. Storm water drainage from areas described in
item 3 above will not be discharged but will be used in the production process, and
storm water drainage from areas described in item 4 above, including unaffected
surrounding property, will discharge into natural drainage channels.

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American Zinc Products
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NCS000562 American Zinc Products LLC
N
Latitude: 350 11' 36" N
w E Longitude: -810 50' 59" W
County: Rutherford
S Receiving Stream: Broad River
Stream Class: C
Map Scale 1:24,000 Index Number: 9-(36.5) (Broad River Basin)
ME9116 4,
Facility Location

From: Belnick, Tom
Sent: Wednesday, May 04, 2011 1:39 PM
To: Bennett, Bradley; Karoly, Cyndi
Cc: Chernikov, Sergei
Subject: FW: Horsehead Corporation, Rutherford County Site
✓ Just to double check that a stormwater permitting rep can attend this meeting that was requested by Forrest and
Horsehead Corp. It's been set for Monday May 9, 1pm, 9fcr, and will be focused on whether there are any stormwater
permitting needs. We already covered wastewater permitting during a previous meeting with the applicant. Sergei will
still plan to attend from the wastewater side, just in case there is need for a combined SW/WW permit.
Tom Belnick
Supervisor, Complex NPDES Permitting Unit
NC DENR/Division of Water Quality
1617 Mail Service Center, Raleigh, NC 27699-1617
[phone]; fax [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
From: Forrest Westail[mailto:[e-mail]]
Sent: Monday, April 18, 2011 5:40 PM
To: Belnick, Tom; Bennett, Bradley Chernikov, Sergei
Cc: Matthews, Matt; Karoly, Cyndi; Poupart, Jeff; Wakild, Chuck
Subject: Horsehead Corporation, Rutherford County Site
Hello, W
As a follow-up to our discussion on this proposed facility, the Company would like to discuss the(stormwater implications)
of the plant. As we noted in our meeting on the 7th the site drains to a section of the Broad River that is class C waters
and is outside of any Phase II area. The company is looking atiseveral options concerning stormwater management We
very briefly discussed at our meeting how DWQ might address stormwater permitting and if that process will be a
separate permit r incorporated into the process discharge. We would like to schedule something the week of May 9 in
sleigh to review this issue. The best days for me are Monday the 91h and Friday 131h, but we would like to work within
your schedule.
Please let me know of your availability that week.
Thanks,
Forrest
Forrest R. Westall, Sr., PE
McGill Associates, P.A.
PO Box 2259
Asheville, NC 28802
Physical Location: 38 Orange Street, Asheville
Phone [phone]
Fax [phone]
forrest.westall@mc ilg lengineers.com

wJ _
Sergei — what does this facility make? Presumably not Horseheads — that would be agricultural, not industrial activity,
and outside of our authority.
Ken
From: Georgoulias, Bethany
Sent: Friday, May 06, 2011 10.27 AM
To: Bennett, Bradley; Pickle, Ken
Subject: RE: Horsehead Corporation, Rutherford County Site
Bradley,
I can be there if I'm back by 1 PM that day. I'll do my best, but will have to let you know that morning. Unfortunately
I'm typically gone between 12:30-1:30. -Bg
Bethany Georgoulias
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
NEW Website: http://portal.ncdenr.org/web/wq/ws/su
E-mail correspondence to and from this address may be subject to the North Carolina Public
Records Law and may be disclosed to third parties.
✓ From: Bennett, Bradley
Sent: Wednesday, May 04, 2011 1:44 PM
To: Pickle, Ken; Georgoulias, Bethany
Subject: FW: Horsehead Corporation, Rutherford County Site
Hey Guys,
I think I neglected to forward this around to anyone earlier. I am planning to attend, but if one of you is also available it
would be very useful. I think NPIDES Industrial issues may be the most important ones for the project. It may be
worthwhile for us to talk to Forrest before the meeting also.
Thanks
BB
Bradley Bennett
Stormwater Permitting Unit
NC Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Phone: [phone]
Fax: [phone]
Email: [e-mail] (New Email Address)
Web: http://portal.ncdenr.org/web/wq/ws/su
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third
parties.

C
Fox,`Tim
From: Harris James <[e-mail]>
Sent: Friday, June 28, 2013 2:25 PM
To: Fox, Tim
Cc: Herbert, Laura C; Kucken, Darlene; Howell Charles
Subject: RE: Utility Corridor Inspection Report
Tim,
I spoke with our project engineer in Pittsburgh and obtained dates for the actions shown below. Please review.
1. Develop the Sediment Removal Plan for the wetlands and obtain approval from Tim Fox to implement.
(Complete)
2. Finish the installation of the underground utility pipes on the corridor road (complete by July 5, 2013)
3. Scoop out the sediment in front of the silt fence at the pinchpoint (complete by June 28, 2013)
4. Begin vacuuming the sediment from the wetland on July 8, 2013 (complete by July 31, 2013)
5. Install the process effluent diffuser in the river by Basin 1. (Start date: July 15, 2013 - Completion date: August 15,
2013)
6. Seed and mat the slopes on the corridor road to establish permanent ground cover (August 31, 2013)
7. Activate usage of the 54 inch stormwater drain pipe to Basin 1 (July 11, 2013)
Let me know if you have questions. All of these dates could be extended if we experience adverse weather conditions. If
the weather holds, we plan on completing the jobs by the date indicated.
I will be in the office on Monday, Tuesday and Wednesday of next week. If you have questions, let me know.
Thanks,
Jim Harris
Environmental Manager
Horsehead Metal Products, Inc.
484 Hicks Grove Road
Mooresboro, NC 28114
C 828.748.5283
F 828,245.8931
[e-mail]
From: Fox, Tim [mailto:tim.foxOncdenr.gov]
Sent: Wednesday, June 26, 2013 2:53 PM
To: Harris James
Cc: Herbert, Laura C; Kucken, Darlene
Subject: Utility Corridor Inspection Report
Jim,
Attached is my inspection report regarding the issues along the Utility Corridor.
would like to discuss storm water management (Utility Corridor), Sediment removal deadline dates, and approve a plan
of action regarding stability and ground cover along the corridor road to ensure that this does not occur again.

0
9
'`i
Thank you for reporting the issue and responding quickly. Darlene and I will be back out in the near future.
If you can respond to these issues we can discuss during are next inspection.
As I discussed with you I will not write a Notice of Violation for this event unless the Sediment Removal is not executed
and final cleanup is not resolved.
If there are any changes or deviations to the Sediment Removal Plan please let me know for approval.
If you have any further questions let me know.
Thanks,
Tim
[phone]
Tim Fox - tim.fox ncdenr. ov
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Surface Water Protection
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Notice: Email correspondence to and from this address may be subject to the NC Public Records Law and may be
disclosed to third parties.

0
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Site Inspection Report
Site Number: WT000681
Site Name: Horsehead Utility Corridor
Site Address:
County: Rutherford
Directions:
Latitude:
Site Owner Name: Horsehead Holding Corporation
Inspection Date: 06/11/13
Reason for Inspection: Routine
Inspection Type: Site Inspection (non -DOT)
Inspection Contact Person:
On -Site Representative(s):
Primary Inspector: Timothy R Fox
Secondary Inspector(s):
Facility compliance Status: ❑ Compliant
Program Area: Construction SW (NCG010000)
Question Areas:
0 NCG010000 Permit
Inspection Summary:
Region: Asheville
Longitude:
Not Compliant
Phone:
Phone: [phone]
The Division of Water Quality was notified on May 23, 2013 of a large rainfall event (2.9 inches) that occurred at The Horsehead
Project Site.
Sediment deposition occurred to approximately 1500 plus feet of stream and a wetland area.
Erosion Control measures were in place but were compromised during the event.
A Sediment Removal Plan has been submitted and approved since the date of this report.
Further evaluation of storm water control on the site (Corridor Roadway), Sediment Removal Plan deadline dates, and further
conversation of stability and ground cover along the corridor roadway is needed to ensure that further damage does not occur.
Please provide appropriate response to issues listed above.
Page: 1

0
Site Number: WT000681 Owner: Horsehead Holding Corporation
Inspection Date: 06/11/13 Inspection Type: Site Inspection (non -DOT) Reason for Visit: Routine
NCGO10000 Permit
# Is this inspection related to a DLRldelegated program inspection?
If Yes, what was the DLR/delegated program inspection date?
Is the site following its E&SC Plan as per DLR or delegated program?
Is the site maintaining their E&SC measures as per DLR or delegated program?
Is a copy of the approved E&SC plan on site?
Is a rain gauge present on -site or is MPE in use for the site?
Is rain gauge data or MPE data recorded?
Are inspection records complete?
Is the site compliant with other conditions of the NCG010000 permit?
Comment: Evaluation of Storm Water Mangement is needed onsite (See Summary).
Vn Mn MA IUC
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0611 112013
■n❑❑
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Page: 2

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Fox, Tim
From: Forrest Westall [[e-mail]]
Sent: Monday, May 28, 2012 2:32 PM
To: Fox, Tim; [e-mail]; Cranford, Chuck; Herbert, Laura C
Cc: mark. [e-mail]-, 'Jeff Bishop'; ben. [e-mail];
[e-mail]; [e-mail];
[e-mail]
Subject: Meeting With Horsehead Corporation
Hello,
In talking with Tim Fox and Laura Herbert, we have scheduled a meeting to discuss the Horsehead site in Rutherford
County for June 7 at 1 PM at cur Offices on 55 Broad Street. Mr. Tim Basilone the VP for Environmental Relations will be
present. The meeting follows discussions that Mark Cathy and I had with Tim Fox and a brief discussion I had with Laura
Herbert on Friday May 16. The general objective of the meeting will be to discuss the steps that have been taken to
increase the level of construction site environmental coordination. If there are any questions about this meeting please let
me know.
Thank you,
Forrest
Forrest R. Westall, Sr., PE
Principal
McGill Associates, P.A.
38 Orange Street I Asheville, NC 28801
Phone: [phone] Fax: [phone]
Email: [e-mail] I Website: www.mcgillengineers.com

0 •
Fox, Tim
From: Pox, Tim
Sent: Thursday, May 17, 2012 12:27 PM
To:'[e-mail]'
Cc: Cranford, Chuck; Wilson, Susan A
Subject: Horse Head NOV
Mr. Westall,
I just wanted to clarify and communicate some issues and concerns that we discussed regarding the NOV that was sent
by our agency on May 9, 2012.
First we have been notified that there was previous sediment damage witnessed to the stream in question in the past
from a utility line
Running across the property. If you have additional pictures or information that would help with our evaluation we
would welcome to review.
The NOV that was sent out in May will only address new or fresh sediment that occurred from a breach in the silt fence
along the roadway above the wetland area on the project. This will not include pre-existing historic sediment damage.
There was fresh sediment damage from the breached silt fence that deposited in the wetland area and stream. As I
have discussed I would like to re-evaluate the area again to determine if a cleanup of the new sediment will be required
and the area remediated.
During our meeting yesterday we determined that there was no approved plan for a small section of the plan above the
wetland area.
It is my understanding that Odom engineering will provide a revision for this area to Land Quality which will hopefully
correct any further issues.
Please let me know if you need further clarification or have further questions. Obviously with a project of this size
improving coordination and
Communication is vital.
Thank you for your continued professionalism and if you would like to meet on -site to look at the area in question that
would be great.
If anyone has any further questions please let me know.
Tim
Tim Fox - tim.fox(@ncdenr.gov
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Surface Water Protection
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Notice: Email correspondence to and from this address may be subject to the NC Public Records Law and may be
disclosed to third parties.

0
r_1
LJ
Fox, Tim
From:
Fox, Tim
Sent:
Wednesday, May 23, 2012 1:18 PM
To:
'[e-mail]'; Herbert, Laura C; 'David Odom';
[e-mail]; [e-mail]; [e-mail]
Cc:
Koontz, Charles; Kucken, Darlene, [e-mail]
Subject:
RE: May 16 Site Meeting Results
All,
just wanted to respond concerning the DWQ Nov and the discussion we had on 5/16/2012.
As Mark already indicated We met with Forrest and discussed the Nov and they provided photo documentation of
previous site and stream conditions for the area in question. I will be re-evaluating the stream over the next couple of
weeks and will let McGill know when that visit will be.
Our requirements would include obtaining a response to the NOV and once the approved plan for this area in question
is approved. Install the proper measures as per the plan and maintain.
I will keep you updated.
Thanks,
Tim
From: Mark Cathey [mailto:[e-mail]]
Sent: Monday, May 21, 2012 8:49 AM
To: Herbert, Laura C; 'David Odom'; [e-mail]; [e-mail]; [e-mail]
Cc: Koontz, Charles; Kucken, Darlene; Fox, Tim; [e-mail]
Subject: RE: May 16 Site Meeting Results
Laura,
Thank you for the summary of our May 16 meeting. I wanted to respond to make sure everyone is on the exact same
page. My comments of clarification follow yours in red text. Please let me know if you have any additional comments.
In addition, Forrest Westall and I met with Tim Fox -on Friday and reviewed the previous documentation that Forrest had
prepared back in the fall of last year relative to the previously impacted stream adjacent to the corridor. McGill will be
responding to the NOV this week and will follow up with scheduling a site visit with Tim and other DWQ representatives
following our response.
Thanks!
Action Items:
1) Revise and submit to our office Phase 1 plans to include the following:
a. Incorporate Odom and McGill Sections together in one plan so that revised plan is a "stand alone" plan.
Per site discussions at conclusion of our meeting, this "stand alone" plan will only be an overall site plan with
all submitted plans identified, but the existing naming convention of submitted phases will remain
unchanged. Future submittals for any new disturbed areas will be stand alone plans, but will be added to
overall site plan to keep everyone informed.

9
0
b. Include "gap" area (with appropriate measures) for the section between the McGill plan area and the
Odom plan area.
Odom Engineering will be submitted revised plans this week to include this area.
c. Include the connector roads with appropriate measures between Phase 1 and "The Additional Grading"
plan across the railroad.
Odom Engineering will be submitted revised plans this week to include this area.
d. Include any planned changes such as the proposed retaining wall or "on the ground" changes.
All parties are working on a final resolution of the retaining wall currently. Odom Engineering will submit
revisions on retaining wall and/or other changes just as soon as available.
e. Include the soil storage "mountain" with appropriate slope stabilization measures and temporary and
permanent erosion control measures (such as benching and water diversion) as needed.
Odom Engineering is working on a revision for the soil stockpile area and will submit necessary revisions to
Land Quality.
f. Include any changes to the sediment basin by the river, including updated drainage/stormwater
calculations.
McGill has completed draft revisions for the area between the sediment/stormwater pond at the river and
the power line ROW. These will be submitted to Land Quality as soon as they are finalized.
2) Place temporary groundcover on the utility road (McGill section of the plan) as soon as possible. This was being
performed on Friday, completed today if weather allows.
3) Place groundcover on any final slopes as soon as possible and temporary groundcover on non -active areas. The
contractor was working on this Friday as well.
4) Reseed with rye grain all slopes (per the approved plan) that were planted with rye. Will need to cut back the
rye prior to this to allow room for the rye grain to grow. The contractor is aware of this, but I will ask Jay
Stewart to check on the schedule of completing this and report back to you ASAP.
5) Appropriately protect all of the inlets of the storm drains near the construction office trailer. This has been
discussed with the contractor. I will ask Jay Stewart to report back to you on the schedule of completing this as
well.
6) For any future expansions of disturbed area equal to or exceeding 1 acre, submit a new plan to cover this
expansion (not a revision).
Acknowledged.
Mark Cathey, PE
Senior Project Monager
McGill Associates, P.A.
55 Broad Street I Asheville, NC 28801
Phone: [phone] ( Mobile: [phone] E Fax: [phone]
Email: [e-mail] J Website: www.mcgillengineers.com
From: Herbert, Laura C[mailto:laura,[e-mail]]
Sent: Friday, May 18, 2012 11:26 AM
To: David Odom; mark.catheyPmcgillengineers.com; jay.stewart(.amcgillengineers.com; ibalmerO)horseheacl.net;
[e-mail]
Cc: Koontz, Charles; Kucken, Darlene; Fox, Tim
Subject: May 16 Site Meeting Results
Thank you all for your time on Wednesday during the inspection. It was nice to meet all of you. Below is a summary of
our discussions at the site and the action items resulting from these discussions. Let me know if you have any comments
or questions. Please note that these include only the Land Quality items. Tim can update you all with the DWQ follow-
up items.

Action Items:
7) Revise and submit to our office Phase 1 plans to include the following:
a. Incorporate Odom and McGill Sections together in one plan so that revised plan is a "stand alone" plan.
b. Include "gap" area (with appropriate measures) for the section between the McGill plan area and the
Odom plan area.
c. Include the connector roads with appropriate measures between Phase 1 and "The Additional Grading"
plan across the railroad.
d. Include any planned changes such as the proposed retaining wall or "on the ground" changes.
e. Include the soil storage "mountain" with appropriate slope stabilization measures and temporary and
permanent erosion control measures (such as benching and water diversion) as needed.
f. Include any changes to the sediment basin by the river, including updated drainage/stormwater
calculations.
8) Place temporary groundcover on the utility road (McGill section of the plan) as soon as possible.
9) Place groundcover on any final slopes as soon as possible and temporary groundcover on non -active areas.
10) Reseed with rye grain all slopes (per the approved plan) that were planted with rye. Will need to cut back the
rye prior to this to allow room for the rye grain to grow.
11) Appropriately protect all of the inlets of the storm drains near the construction office trailer.
12) For any future expansions of disturbed area equal to or exceeding 1 acre, submit a new plan to cover this
expansion (not a revision).
Once again, thank you for your time and efforts and we look forward to working with you. Please forward onto anyone
I may have missed on the distribution list (I only gathered a few cards).
Sincerely,
Laura Herbert
Laura Herbert, P.E.
Regional Engineer
Division of Land Resources - Land Quality Section
NCDENR-Asheville Regional Office
2090 US Highway 70
Swannanoa, NC 28778
Tel:[phone] Fax:[phone]
Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and therefore may be disclosed to
third parties unless the content is exempt by statute or other regulation.

0
0
Fox, Tim
From:
Fox, Tim
Sent:
Thursday, May 17, 2012 12:27 PM
To:
'[e-mail]'
Cc:
Cranford, Chuck; Wilson, Susan A
Subject:
Horse Head NOV
Mr. Westall,
I just wanted to clarify and communicate some issues and concerns that we discussed regarding the NOV that was sent
by our agency. on May 9, 2012.
First we have been notified that there was previous sediment damage witnessed to the stream in question in the past
from a utility line
Running across the property. If you have additional pictures or information that would help with our evaluation we
would welcome to review.
The NOV that was sent out in May will only address new or fresh sediment that occurred from a breach in the silt fence
along the roadway above the wetland area on the project. This will not include pre-existing historic sediment damage.
There was fresh sediment damage from the breached silt fence that deposited in the wetland area and stream. As I
have discussed I would like to re-evaluate the area again to determine if a cleanup of the new sediment will be required
and the area remediated.
During our meeting yesterday we determined that there was no approved plan for a small section of the plan above the
wetland area.
It is my understanding that Odom engineering will provide a revision for this area to Land Quality which will hopefully
correct any further issues.
Please let me know if you need further clarification or have further questions. Obviously with a project of this size
improving coordination and
Communication is vital.
Thank you for your continued professionalism and if you would like to meet on -site to look at the area in question that
would be great.
If anyone has any further questions please let me know.
Tim
Tim Fox - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Surface Water Protection
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Notice: Email correspondence to and from this address may be subject to the NC Public Records Law and may be
disclosed to third parties.

lqw
------- '-- - ----_------

NPDES STORMWATER CONSTRUCTION COMPLIANCE INSPECTION REPORT
NPDES PERMIT NO: NCG 010000 DATEOF INSPECTION: INSPECTION H:
PROJECT NAME: Horsehead Coporation
PROJECT DESCRIPTION (check one): ❑Residential ®Commercial ❑Other:
1. TYPE OF INSPECTION
❑ 1) At least once every 7 calendar days, or ❑2) At least once ever, 14 calendar days/24 hrs of the end of a storm event 0.5 inches or greater.
IL WEATHER CONDITIONS
1) Weather conditions during inspection: clear
2) Weather conditions since last inspection, including rainfall information:
Ill. SITE AND PLAN REVIEW
Are the following required items available for regulatory review:
❑Y❑N SWPPP ❑Y❑N Copy of the General Permit ❑Y❑N DHEC Coverage Letter
❑Y❑N NOI ❑Y❑N Weekly inspection forms ❑Y❑N Co-permittee agreements or contractor certification statements
IV. BEST MANAGEMENT PRACTICES
❑Y❑N 1) Is construction entrance/exit properly installed? ❑Y❑N 2) Is perimeter silt fence/other controls properly installed?
❑Y❑N 3) Did any 13MPs fail to operate as designed or prove inadequate? * If Yes, Identify BMPs and location(s):
❑Y❑N 4) Are additional BMPs needed? *If Yes, indentify BMI's needed and which location(s):
❑Y❑N 5) Do any 13MPs require maintenance? * If Yes, provide location(s) and description(s):
❑Y❑N 6) Is construction activity following phasing/sequencing plan? ❑Y❑N 7) Has construction activity ceased for 14 days or more?
❑Y❑N 8) If activity has ceased. have temporary stabilization measures been installed within 14 days? If No, identify locations needing
stabilization:
❑VON 4) Are litter, construction debris, oils. fuels, building products. & construction chemicals being properly addressed and/or removed?
*If No. identify locations:
V. FINAL STABILIZATION
❑Y❑N 1) Have land disturbing activities site permanently ceased?
❑Y❑N 2) Are there any areas of active erosion evident? If Yes, identify locations):
❑Y❑N 3) Does the permitted area have 70% permanent vegetative cover (i.e. grass or other cover) OR have equivalent measures installed?
VI. OFFSITE IMPACTS FROM PROJECT
1) Are there any offsite impacts? ❑No ❑Yes, where? ❑Public right of way ❑Adjoining Property ❑Wetlands ❑Creek/River
❑Lake/fond []Other (please specify).
2) If answering "Yes", indicate the location and describe the impact:
VII. DEFICIENCIES/ CORRECTIVE ACTIONS
Were deficiencies noted in this inspection previously listed in a monthly report? ❑ Yes ❑ No If Yes, identify locations):
Vlll. STORM WATER POLLUTION PREVENTION PLAN UPDATES
❑VON 1) Does the SWPPP need to be modified?
❑Y❑N 2) Has the SWPPP been modified since the last inspection? If so, note the date(s):
IN. COMMENTS
Inspector:.lav Stewart Title/Qualifications: CEPSCI 0724

MRM
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