NC0089109_Correspondence_20190417

TIMOTHY R. BASILONE
Vice President— Environmental Affairs
,AZ R A M E R I CAN 3000 GSK Drive T 724-773-2223 www azr com
ZINC RECYCLING Site 201 F412-788-4526 [e-mail]
Delivering a Sustainable Future Moon Township, PA 15108
March 4, 2019
Dr. Sergei Chernikov
Complex NPDES Permitting Unit
North Carolina Division of Water Resources
Department of Environmental Quality
1617 Mail Service Center
Raleigh, NC 27699-1611
R.E. Draft NPDES Process Discharge Permit
Permit Number NC 0089109
American Zinc Products, LLC
Rutherford County
North Carolina
Dear Dr. Chernikov:
Thank you for the opportunity to provide comments on the draft NPDES process discharge
permit for the Mooresboro, NC facility. It is our understanding that this draft permit was
provided to coincide with issuance of the formal public notice, as required by NC regulations.
American Zinc Products (AZP) is providing comments herein in advance of the permit being
finalized. We request that information provided in this letter is addressed before the final
permit is issued.
In general, the permit reflects conditions that AZP reviewed and discussed with you previously.
Our comments are primarily related to certain conditions in the draft permit that were not
previously reviewed or discussed with you, in addition to several editorial changes.
Our primary comment relates to the added condition requiring fish tissue monitoring for
arsenic, cadmium and zinc. Our understanding as to the reason for this addition, as cited in your
cover letter, is that the Regional Office indicated concern regarding the potential for
bioaccumulation of these metals in fish, and potential associated ecological impacts.
Based on our preliminary review of this matter, it appears there is limited information available
for monitoring arsenic, cadmium and zinc in fish. In addition, published information regarding
the ecological impact from the presence of these metals in fish is apparently not well
established.
Before proposing a specific monitoring program,
we believe it
would
be best to first understand
the potential for bioaccumulation of the subject
metals in fish.
Once
the potential for

bioaccumulation is understood, the potential ecological effect can be evaluated. Information
gathered as part of this initial step can be used to develop an appropriate monitoring program,
if it is determined to be necessary. The attached Word file provides suggested revisions to this
condition.
The draft permit also includes a priority pollutant analysis monitoring requirement. This
condition is not included in the current permit for the facility. The reason cited for inclusion is
that the Regional Office requested the condition be added. We do not anticipate the presence
of any parameters beyond those already reflected in our application.
There are several suggested editorial revisions provided in the attached electronic Word
document. These are offered only as clarifications or to more accurately reflect the operational
aspects of this facility.
In addition to the
draft permit, we
have also reviewed
the permit Fact Sheet and
have offered
some minor edits.
These changes
are reflected in the
attached electronic Word
document.
If there are
any questions
concerning our comments and proposed
revisions, please let me
know. We
would be glad
to discuss our comments with you.
Sincerely,
Timothy R. Basilone
Encls.

Per nit NC0089109
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
Draft PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1,
other lawful standards and regulations promulgated and adopted by the North Carolina
Environmental Management Commission, and the Federal Water Pollution Control Act, as
amended,
American Zinc Products, LLC
is hereby authorized to discharge wastewater from a facility located at
American Zinc Products, LLC
Forest City
Rutherford County
to receiving waters designated as the Broad River in the Broad River Basin in accordance with
effluent limitations, monitoring requirements, and other applicable conditions set forth in
Parts I, II, III and IV hereof.
This permit modification shall become effective
This permit and authorization to discharge shall expire at midnight on July 31, 2023.
Signed this day
Linda Culpepper, Director
Division of Water Resources
By Authority of the Environmental Management Commission
Page 1 of 10

Permit NC0089109
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked. As of this permit issuance, any previously issued permit bearing this number is no longer
effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the
permit conditions, requirements, terms, and provisions included herein.
American Zinc Products, LLC is hereby authorized to:
effluent discharge system including it ; aeeer-danee with two o ;s+; ^
vastewater treatment system ^^nsist n^ ^r the following components:
➢ Automatic sampler
➢ Instrumented flow measurement, and
➢ Diffuser
The facility is located near Forest City, Rutherford County; and
2. Discharge effluent from a^�a +..aa.man� ..,a.-i.a ..+ +>na this location as specified
on the attached map into the Broad River which is classified WS-IV waters in
the Broad River Basin,
Page 2 of 10

Permit NCO089109
Part I
A. (L) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee
is authorized to discharge from outfall(s) serial number 001. Such discharges shall be limited and
monitored5 by the Permittee as specified below:
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQUREMENTS
Monthly
Average
Daily
Maximum
Measureme
nt
Fre uenc
Sample
Type
Sample
Locationi
Flow (MGD)
0.98
Continuous
Recording
I or E
Total Suspended Solids,
m L
2/Month
Composite
E
NH3-N, mg/L
Quarterly
Composite
E
Total Aluminum, µg/L
Quarterly
Composite
E
Total Antimony, µg/L
Quarterly
Composite
E
Total Arsenic, µg/L
Quarterly
Composite
E
Total Cadmium
90.4 µg/L6
454.4 µg/L6
2/Month
Composite
E
Chlorides, mg/L
Quarterly
Composite
E
Chromium (VI), µg/L
Quarterly
Composite
E
Total Cobalt, µg/L
Quarterly
Composite
E
Total Copper, µg/L
Quarterly
Composite
E
Total Fluoride, mg/L
Quarterly
Composite
E
Total Iron, mg/L
Quarterly
Composite
E
Total Lead, µg/L
2/Month
Composite
E
Total Nickel, µg/L
Monthly
Composite
E
Total Tin, µg/L
Quarterly
Composite
E
Total Zinc, µg/L
2/Month
Composite
E
pH2
6.0 :- pH f< 9.0
Daily
Grab
E
Chronic Toxicity3
Quarterly
Composite
E
Turbidity4
Monthly
Grab
E, U, D
NOTES:
1. Sample Locations: I - Influent, E - Effluent, U -upstream (50 ft. upstream of the
discharge), D - downstream (50 ft. downstream of the discharge).
2. The pH shall not be less than 6.0 standard units or greater than 9.0 standard units.
3. Chronic Toxicity (Ceriodaphnia) P/F @ 0.9%; Jan., April, July, and October; See
condition A. (2.) of the Supplement to Effluent Limitations and Monitoring Section of
this permit.
4. The discharge from this facility shall not cause turbidity in the receiving stream to exceed 50
NTU. If the instream turbidity exceeds 50 NTU due to natural background conditions, the
discharge cannot cause turbidity to increase in the receiving stream. Therefore, if the effluent
measurement exceeds 50 NTU, the Permittee shall sample upstream and downstream
turbidity in the receiving waterbody, within 24 hours, to demonstrate the existing turbidity
level in the receiving waterbody was not increased. All data shall be reported on the DMRs.
(See 15A NCAC 2B .0211 (21)).
NTU - Nephelometric Turbidity Unit.
Page 3 of 10

Permit NCO089109
5. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's
eDMR application system. See Special Condition A. (3.).
6. The limit becomes effective 90 months from the effective date of the permit. Please see A.
(6.) for Compliance Schedule.
THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR FOAM VISIBLE IN OTHER THAN
TRACE AMOUNTS.
A. (2.) CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QUARTERLY)
[15A NCAC 02B .0200 et seq.]
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant
mortality to Ceriodaphnia dubia at an effluent concentration of 0.9 % .
The permit holder shall perform at a minimum, quarterly monitoring using test procedures
outlined in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised
December 2010, or subsequent versions or "North Carolina Phase II Chronic Whole Effluent
Toxicity Test Procedure" (Revised- December 2010) or subsequent versions. The tests will be
performed during the months of January, April, July and October. These months signify the
first month of each three-month toxicity testing quarter assigned to the facility. Effluent
sampling for this testing must be obtained during representative effluent discharge and shall be
performed at the NPDES permitted final effluent discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or
ChV below the permit limit, then multiple -concentration testing shall be performed at a
minimum, in each of the two following months as described in "North Carolina Phase II
Chronic Whole Effluent Toxicity Test Procedure" (Revised -December 2010) or subsequent
versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the months in which tests were performed, using the
parameter code TGP3B for the pass/fail results and THP313 for the Chronic Value. Additionally,
DWR Form AT-3 (original) is to be sent to the following address:
Attention: North Carolina Division of Water Resources
Water Sciences Section/Aquatic Toxicology Branch
1621 Mail Service Center
Raleigh, NC 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section no later
than 30 days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements
and all concentration/response data, and be certified by laboratory supervisor and ORC or
approved designate signature. Total residual chlorine of the effluent toxicity sample must be
measured and reported if chlorine is employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring
s required, the permittee will complete the information located at the top of the aquatic toxicity
(AT) test form indicating the facility name, permit number, pipe number, county, and the
month/year of the report with the notation of "No Flow" in the comment area of the form. The
report shall be submitted to the Water Sciences Section at the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required,
monitoring will be required during the following month. Assessment of toxicity compliance is
Page 4 of 10

Permit NCO089109
based on the toxicity testing quarter, which is the three month time interval that begins on the
first day of the month in which toxicity testing is required by this permit and continues until the
final day of the third month.
Should any test data from this monitoring requirement or tests performed by the or Carolina
Division of Water Resources indicate potential impacts to the receiving stream, this permit may be
re -opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum
control organism survival, minimum control organism reproduction, and appropriate
environmental controls, shall constitute an invalid test and will require immediate follow-up
testing to be completed no later than the last day of the month following the month of the initial
monitoring.
A. (3.) ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS
G.S. 143-215.1(b)]
Federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and
program reports. The final NPDES Electronic Reporting Rule was adopted and became effective on
December 21, 2015.
NOTE: This special condition supplements or supersedes the following sections within Part II of
this permit (Standard Conditions for NPDES Permits):
• Section
B.
(11.)
Signatory Requirements
• Section
D.
(2.)
Reporting
• Section
D.
(6.)
Records Retention
• Section
E.
(5.)
Monitoring Reports
1. Reporting Requirements [Supersedes Section D. (2.1 and Section E. (5.) la)1
The permittee shall report discharge monitoring data electronically using the NC DWR's
Electronic Discharge Monitoring Report (eDMR) internet application.
Monitoring results obtained during the previous month(s) shall be summarized for each
month and submitted electronically using eDMR. The eDMR system allows permitted facilities
to enter monitoring data and submit DMRs electronically using the internet. Until such time
that the state's eDMR application is compliant with EPA's Cross -Media Electronic Reporting
Regulation (CROMERR), permittees will be required to submit all discharge monitoring data to
the state electronically using eDMR and will be required to complete the eDMR submission by
printing, signing, and submitting one signed original and a copy of the computer printed
eDMR to the following address:
NC DEQ /Division of Water Resources /Water Quality Permitting Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the
facility being physically located in an area where less than 10 percent of the households have
broadband access, then a temporary waiver from the NPDES electronic reporting requirements
may be granted and discharge monitoring data may be submitted on paper DMR forms (MR 1,
1.1, 2, 3) or alternative forms approved by the Director. Duplicate signed copies shall be
Page 5 of 10

Permit NCO089109
submitted to the mailing address above. See "How to Request a Waiver from Electronic
Reporting" section below.
Regardless of the submission method, the first DMR is due on the last day of the month
following the issuance of the permit or in the case of a new facility, on the last day of the
month following the commencement of discharge.
Starting on December 21, 2020, the permittee must electronically report the following
compliance monitoring data and reports, when applicable:
• Sewer Overflow/Bypass Event Reports;
• Pretreatment Program Annual Reports; and
• Clean Water Act (CWA) Section 316(b) Annual Reports.
The permittee may seek an electronic reporting waiver from the Division (see "How to Request
a Waiver from Electronic Reporting" section below).
2. Electronic Submissions
In accordance with 40 CFR 122.41(1)(9), the permittee must identify the initial recipient at the
time of each electronic submission. The permittee should use the EPA's website resources to
identify the initial recipient for the electronic submission.
Initial recipient of electronic NPDES information from NPDES-regulated facilities means the
entity (EPA or the state authorized by EPA to implement the NPDES program) that is the
designated entity for receiving electronic NPDES data [see 40 CFR 127.2(b)].
EPA plans to establish a website that will also link to the appropriate electronic reporting tool
for each type of electronic submission and for each state. Instructions on now to access and
use the appropriate electronic reporting tool will be available as well. Information on EPA's
NPDES Electronic Reporting Rule is found at:
https• / /www federalregister gov/ documents/ 2015 / 10 / 22 / 2015-24954 / national-pollutant-
discharge-elimination-system-npde s-electronic-reporting-rule
Electronic submissions must start by the dates listed in the "Reporting Requirements" section
above.
3. How to Request a Waiver from Electronic Reportin¢
The permittee may seek a temporary electronic reporting waiver from the Division. To obtain
an electronic reporting waiver, a permittee must first submit an electronic reporting waiver
request to the Division. Requests for temporary electronic reporting waivers must be
submitted in writing to the Division for written approval at least sixty (60) days prior to the
date the facility would be required under this permit to begin submitting monitoring data and
reports. The duration of a temporary waiver shall not exceed 5 years and shall thereupon
expire. At such time, monitoring data and reports shall be submitted electronically to the
Division unless the permittee re -applies for and is granted a new temporary electronic
reporting waiver by the Division. Approved electronic reporting waivers are not transferrable.
Only permittees with an approved reporting waiver request may submit monitoring data and
reports on paper to the Division for the period that the approved reporting waiver request is
effective.
Information on eDMR and the application for a temporary electronic reporting waiver are
found on the following web page:
itty://deg.nc.gov/about/divisions/water-resources/edm
Page 6 of 10

Permit NCO089109
4. Signatory Requirements 1Supplements Section B (11.1 (b) and Supersedes Section B
11 1,1 (d)l
All eDMRs submitted to the permit issuing authority shall be signed by a person described in
Part II, Section B. (11.)(a) or by a duly authorized representative of that person as described in
Part II, Section B. (11.)(b). A person, and not a position, must be delegated signatory
authority for eDMR reporting purposes.
For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR
user account and login credentials to access the eDMR system. For more information on
North Carolina's eDMR system, registering for eDMR and obtaining an eDMR user account,
please visit the following web page:
http: / /deg.nc.gov/about/divisions/water-resources/edmr
Certification. Any person submitting an electronic DMR using the state's eDMR system shall
make the following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF
CERTIFICATION WILL BE ACCEPTED:
"I certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate,
and complete. I am aware that there are significant penalties for submitting false information,
including the possibility offines and imprisonment for knowing violations."
5. Records Retention (Supplements Section D. (6.11
The permittee shall retain records of all Discharge Monitoring Reports, including eDMR
submissions. These records or copies shall be maintained for a period of at least 3 years from
the date of the report. This period may be extended by request of the Director at any time [40
CFR 122,41],
A. (4.) FISH MONITORING
The facility shall conduct an evaluation of the potential for trace metals in the discharge to
bioaccumulate in fish. This evaluation shall review water quality information on the potential of
arsenic cadmium and zinc to bioaccumulate in fish, monitoring approaches used to assess
potential impact and provide recommendations concerning the most effective
monitoring/evaluation approach for assessing potential impacts below this outfall The facility will
provide this report to the Division within 270 days of the effective date of the permit The Division
will provide comments on the evaluation and based on the comments provided, the permittee will
develop within 90 days an appropriate monitoring program The proposed program shall include
frequency, sample collection protocols and a schedule for conducting the sampling and submittal
of results to the Division The facility shall implement the program following approval by the
Division. fish tissup Menitering once during the permit Gyele and submit the results with the NPDES
permit
renewal appheation.The objective of thismonitoringis to evaluate potential Uptake opollutants by fish tissue near the faeility's discharge. The parameters analyzed in fish tissue Rhall
be arsenie, eadmium,d zine, TV1, 11+ ill be nduete.i in apperdanpe with the sampling.
YTl: isi 1approved h he en The plan should he suhmitte.i tR the Piyi ViG ..:thin. 180 .days f 0m.
tbe. eff e flve date of the permit madifi,.etion Upon approval, the plan becomes an enforceable part
of the permit.
Copies of the evaluation, monitoring program, ,study results, and any other
applicable materials should be submitted to:
Page 7 of 10

Permit NCO089109
1) Electronic Version Only (pdf and CD)
Division of Water Resources
WQ Permitting Section - NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
2) Electronic Version (pdf and CD) and Hard Copy
Division of Water Resources
Water Sciences Section
1621 Mail Service Center
Raleigh, NC 27699-1621
A. (5.) PRIORITY POLLUTANT ANALYSIS
G.S. 143-215.1(b)]
The Permittee shall perform one Effluent Pollutant Scan for all parameters listed below. The analytical
methods shall be in accordance with 40 CFR Part 136 and shall be sufficiently sensitive to determine
whether parameters are present in concentrations greater than applicable standards and criteria.
Unless otherwise indicated, metals shall be analyzed as "total recoverable."
Ammonia (as N)
Chlorine (total residual,
Dissolved oxygen
Nitrate/Nitrite
Kjeldahl nitrogen
Oil and grease
Phosphorus
Total dissolved solids
Hardness
Antimony
Arsenic
Beryllium
Cadmium
Chromium
l2-dichloroethylene
Copper
Lead
Mercury (EPA Method 1631E)
Nickel
Selenium
Silver
Thallium
Zinc
Cyanide
Total p
Acrolein
Acrylonitrile
Benzene
Bromoform
Carbon tetrachloride
Chlorobenzene
Chlorodibromomethane
Chloroethane
2-chloroethylvinylether
1,1,2-trichloroethane
Trichloroethylene
Vinyl chloride
Acid -extractable compounds:
P-chloro-m-cresol
2-chlorophenol
2,4-dichlorophenol
2,4-dimethylphenol
4,6-dinitro-o-cresol
2,4-dinitrophenol
2-nitrophenol
4-nitrophenol
Pe ntachlorophenol
Phenol
2,4, 6-trichlorophenol
Base -neutral
Acenaphthene
Acenaphthylene
Anthracene
Benzidine
Be nzo(a)anthracene
Benzo(a)pyrene
Page 8 of 10
Bi(2-ch1oroethyl) ether

Permit NCO089109
Chloroform
D ichlorobromomethane
l,l-dichloroethane
1,2-dichloroethane
3,4 benzofluoranthene
Be nzo(ghi)perylene
Be nzo(k)fluoranthene
Bis (2-chloroethoxy)
methane
Pyrene
1,2,4-trichlorobenzene
Reporting.
The effluent pollutant scan shall be
performed once
during the
permit cycle and test
results shall
be submitted to the Division within
270 days of the
sampling.
A. (6.) CADMIUM COMPLIANCE SCHEDULE
[G. S. 143-215.1(b) ]
1.
Commence production of Zinc at Mooresboro Facility.
Month 0
2.
Ramp -up production to 75%.
Month 6
3.
Stabilize plant operation and commence evaluation of permit
Month 12
compliance.
4.
Complete evaluation period.
Month 24
5.
Prepare a Preliminary Engineering Report (PER) of process
Month 30
alternatives and/or pollution prevention/waste minimization
(parallel with activity
alternatives designed to achieve compliance. This report would
4)
include the results of the compliance evaluation. Submit to DWR
for review and comment.
6.
Agency review and addressing comments
Month 32
7.
Bench scale test work of process alternatives (start in parallel
Month 34
with Activity 6).
$
Evaluate business case and funding requirements for
Month 34
technically suitable alternative(s).
(parallel with activity
7)
9.
Complete pilot test work for selected technology option(s) and
Month 38
final technology selection. Develop a summary of the results of
this evaluation. Submit summary to DWR for review.
10.
Agency review and addressing comments
Month 40
11.
Detailed engineering and design of selected option. Submit to
Month 44
DWR for comment.
12.
Agency review and addressing comments
Month 46
13.
Prepare capital project application and secure funding for
Month 48
selected option, obtain building permits and all needed
(much of this work
approvals for implementation.
will be done in
parallel with
activities 11,12)
14.
Project implementation, including design completion,
Month 60
procurement and construction.
Page 9 of 10

Permit NCO089109
15.
Commission and ramp -up.
Month 72
16.
Stabilize operation and evaluate performance.
Month 78
17.
Make necessary final modifications to optimize and obtain full
operational status.
Month 86
18.
Achieve full compliance.
Month 90
Page 10 of 10

NCDEQ/DWR
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
MAJOR MODIFICATION/RENEWAL
American Zinc Products, LLC
NCO089109
Facility Information
1. Facility Name:
American Zinc Products, LLC
2. Permitted Flow MGD :
0.98
6. County:
Rutherford
__
3. Facility Class:
II
(7.) Regional Office:
Asheville
4.) Pretreatment Program:
USGS To o Quad: _
F11SW
_
(5.) Permit Status:
_N/A
Major \Modification
9. USGS Quad Name:
Stream Characteristics
(LLReceiyin&SStrearn:
Broad River
P
575 —
_—
(2. Sub -basin__---
"' '
03-08-02
_(7.).DrainageAxea,_(
�8_) Summer 7Q10 (cfs:
167
3. Stream Index Numbet:
9- 36.5)9.
Winter 7Q10 cfs :
334
(4_) Stream Classification:
C
0Q2 cfs :—
403
S5.) 303(d) Status:—_--
Not listed
Flow cfs _
914 --'--------------
-"—""-
(6.) 305(b) Status:
—(no)Average
12.) IWC %:
0.9
Summary
This is a Major Modification and Renewal for the permit for American Zinc Products, LLC.
The facility is located in the southern portion of the Rutherford County. The facility uses the
impure zinc oxide that is generated from the parent company's (AZR) recycle plants which
the -recycled Electric Arc Furnace (EAF) dust. The EAF dust is a zinc containing waste
generated by the North American steel mini mills. The facility will produce approximately
14855,000 tons of high quality pt4ne Westet4n grade Zinc metal. The process
will include zinc oxide leaching, extraction of zinc with an organic ligandy-aftd
electrowinning and casting. The facility will achieve significant degree of recycling of the
reagents that are used in the process. This would be a first facility of this type in the USA,
and there are no effluent guidelines for Zinc recycling facilities.
The original estimates fox the effluent----�.�t� flow were incorrect, the new flow is
estimated to be 0.98 MGD. The Major Modification and Renewal is conducted to
accommodate the flow increase in the permit. The updated FAA was submitted by the
facility on September 6, 2017, The EAA was approved on September 29, 2017, it allows
discharge of 0.98 MGD treated industrial wastewater. The wastewater generated by the
facility is essentially a clean brine solution that has a high concentration of chlorides (17,000
mg/L). Potable water and sanitary sewer service is provided by the Forrest City.
The facility went through a bankruptcy in 2016 and has not produced any zinc since that
time. It is currently undergoing substantial changes and improvements to the production and
effluent process facilities. It is scheduled to re -open in the Spring of 2019.
RPA
The RPA (reasonable potential analysis) was updated to incorporate a new flow limit of 0.98
MGD. The modification application identified the number of pollutants that might be
Page 1 of 2

NPDES Permit Fact Sheet — 03/04/ 190' "'�4-^ American Zinc Products,
LL
Page 2 NC0089109
present in the discharge. The RPA was conducted for these pollutants: arsenic, cadmium,
chlorides, chromium, copper, fluoride, lead, nickel, zinc, tin, and antimony.
The RPA indicated that the limits axe necessary fox total cadmium. Due to the recent
updates to the state standard, the cadmium standard has been significantly decreased. The
facility requested a compliance schedule to design a treatment system for cadmium removal.
The compliance schedule was added to the permit.
PERMIT LIMITS
• The limits fox Total Cadmium were established based on the results of the
Reasonable Potential Analysis of the effluent data. These limits axe necessary to
prevent contravention of the state water quality standards and the EPA criteria in the
receiving water body.
The pH limits and turbidity limits are based on the state water quality standards.
The whole effluent toxicity testing was assigned in accordance with 15A NCAC
2B.0508.
PROPOSED CHANGES
• The flow limit was increased to 0.98 MGD
• The requirement for fish tissue monitoring was added to the permit to address
comment from the Regional Office.
• The requirement for pollutant scan was added to the permit to address comment
from the Regional Office.
• The limits for Total Cadmium were recalculated (reduced) based on the new flow
estimate and the recent update to the North Carolina water quality standards.
Cadmium limit compliance schedule was added to the permit.
• The limits for Total Chromium, Total Lead, and Total Fluoride were removed from
the permit based on the results of the Reasonable Potential Analysis.
• The quarterly monitoring for the Hexavalent Chromium was added to the permit
based on the review of the effluent data.
Proposed Schedule fox Permit Issuance
Draft Permit to Public Notice: January 29, 2019 (est.)
Permit Scheduled to Issue: March 20, 2019 (est.)
State Contact Information
If you have any questions on any of the above information or on the attached permit, please
contact Sergei Chernikov at [phone], or [e-mail].
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