NCS000330_EPA Inspection Report_20190603

Ja��tiv srgrFs UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
a� A Yi REGION 4
A 1� ATLANTA FEDERAL CENTER
y�oz 61 FORSYTH STREET
q< Paoi�°ATLANTA, GEORGIA 30303-8960
MAY 2 8 2019
CERTIFIED MAIL 7017 1450 0000 7973 2762
RETURNED RECEIPT REQUESTED
Mr. Joe Hinkle RE°
EHS Manager JUN 0 3 2019
ATI Allvac — Monroe Plant
2020 Ashcraft Road DENR-LAND QUALITY
Monroe, North Carolina 29110 STQRMWATER RERt4 TING
Re: Compliance Evaluation Inspections
ATI Allvac — Monroe Plant, Monroe, North Carolina
NPDES Permit No. NCS000330
Dear Mr. Hinkle:
On March 21, 2019, the U.S. Environmental Protection Agency Region 4 and North Carolina
Department of Environmental Quality (NCDEQ) conducted a Compliance Evaluation Inspection (CEI)
at the ATI Allvac — Monroe Plant located at 2020 Ashcraft Road in Monroe, NC. The purpose of the
CEI was to evaluate ATI Allvac — Monroe Plant's compliance with the requirements of Sections 301
and 402(p) of the Clean Water Act (CWA), 33 U.S.C. §§ 1311 and 1342(p); the regulations promulgated
thereunder at 40 C.F.R. § 122.26; and, the State of North Carolina's NPDES Stormwater Permit
NCS000330.
The EPA and NCDEQ appreciate your cooperation in conducting this CEI. Enclosed is the EPA's CEI
report, which includes EPA's observations. Please review the report and contact Ms. Lauren Garcia at
the NCDEQ office within 14 days of receiving this letter by calling [phone] or by sending an
email to lauren. arcianncdenr. gov.
There is no need to respond directly to the EPA at this time; however, please note that the EPA will
continue to closely coordinate with NCDEQ to ensure compliance at this facility. If you do happen to
have questions for the EPA, you can contact Mr. Ahmad Dromgoole at the above address, by email at
[e-mail], or at [phone].
Enclosures
cc: Ms. Annette Lucas
NCDEQ
Sincerely,
<`---�/ e
Daniel J. O'Lone, Chief
Surface Water and Ground Water Section
Water Enforcement Branch
intemet Address (URL) • http://www.epa.gov
Recycled/Recyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30 % Postconsumer)

1"'� U.S. Environmental Protection Agency, Region 4
61 Forsyth Street SW, Atlanta, GA 30303
o=
Water Compliance Inspection Report
FACILITY DATA
NPDES ID: NCS000329 Effective Date: 09/01/09 Expiration Date: 08/31/14
Facility Name: Allvac — Monroe Plant ISIC Code: 3356, 3341
Address: 2020 Ashcraft Ave, Monroe, NC 28110
On -Site Representative(s), Title, Phone Number: Responsible Official, Title, Phone Number, Mailing Address:
Joe Hinkle Gary Laney
EHS Manager Plant Manager
2020 Ashcraft Rd 2020 Ashcraft Rd
Monroe, NC 29110 Monroe, NC 28110
704-289-4511 704-289-4511
INSPECTION DATES/TIMES
Entry Date/Time: 03/21/19, 8:25 am Exit Date/Time: 03/21/19, 1:30 pm
NAMES OF EPA AND STATE INSPECTORS
EPA Inspectors: Ahmad Dromgoole and Kenneth Kwan
NCDENR Inspectors: Lily Kay, Chris Graybeal, Angela Lee
AREAS EVALUATED DURING
X Permit Self -Compliance Program Pretreatment
X Records
Compliance Schedule
Pollution Prevention
X Facility Site Review
Laboratory
X Storm Water
X Effluent / Receiving Waters X
Operations & Maintenance
Combined Sewer Overflow
Flow Measurement Sludge Handling/ Disposal Sanitary Sewer Overflow
INSPECTION NOTES
The inspection team, consisting of EPA inspectors and state inspectors from various regional offices, arrived at the facility on March
21, 2019 to perform an unannounced Compliance Evaluation Inspection (CEI). This CEI, which focused on the facility's NPDES
Industrial Stormwater permit, was performed as both a joint inspection with the state and a training opportunity for state inspectors.
Upon arrival at the facility, EPA inspectors checked in at the guard station where they met the appropriate facility personnel. Upon
their arrival, the inspectors presented credentials and facilitated an opening conference. The CEI included both a records review
portion and a facility walk through. At the end of the inspection, a summary of the preliminary findings was provided and facility
personnel were informed that an inspection report will be sent to the facility by EPA.
.♦ REPRESENTATIVES
Inspector Signature/Name Office/Phone Number Date
USEPA Region 4/WPD-CWEB-SRES
404-562-9212
Ahmad Dromgoole, Environmental Engineer
USEPA Region 4/WPD-CWEB-SRES
404-562-9752
Kenneth Kwan, Environmental Engineer
Management Signature/Name
Office/Phone Number
Date
USEPA Region 4/WPD-CWEB-SRES
404-562-9434
Daniel J. O'Lone, Chief
Stormwater and Residuals Enforcement Section
Page 1 of 7

1. FACILITY LOCATION INFORMATION
GPS
Latitude 34059'2.78"N
Longitude 80030'58.57"W
Coordinates
Receiving
Site
Weather
Water(s) or
Richardson Creek
Acreage
65 Acres
Condition
Partly Cloudy,
MS4
Discharge to
Does the site discharge
Permit
02/24/14
SIC
3356
303(d) listed or
No
pollutants contributing
N/A
Application
Code(s)
3341
TMDL waters
to the receiving stream
impairment.
2. BASIC STORMWATER POLLUTION PREVENT PLAN (SPPP) INFORMATION
SPPP TOPICS (Part II)
YES
NO
N/E
SPPP on -site (obtain a copy of the plan) Section A
Copies of the SPPP and SPCC Plans were provided during the inspection in an email response after
X
the inspection.
Site Description Section A(1)(b)
X
A site description was provided in the provided plan.
Identify potential Pollutant Sources and Particular Pollutants Section A(1)(b)
The site description in the plan included information about most of the potential pollutant sources and
X
control measures in place at each of the outfalls. The plan did not identify the locations of the various
dust/particulate control processes, specifically, the locations of the various ba houses.
Site Maps (general location map and site specific map) Sections A(1)(a & c)
X
Spill History (3 year history or spills and corrective actions) Section A(1)(d)
In the plan provided in the subsequent email to the inspection, a completed form with the spill
X
history was provided. This spill history extended back to 10/2009.
SPPP Certification Section A(1)(e)
In the plan provided in the subsequent email to the inspection, a completed form summarizing the
X
annual updates to the plan was provided. The most recent update to the plan was 08/2017.
Stormwater Management Strategy (Feasibility Study) Section A(2)(a)
The provided site plan provided information on when feasibility studies were to be performed. In this
X
section of the plan, a description of the resulting actions from the feasibility study was provided.
Stormwater Management Strategy (Secondary Containment) Section A(2)(b)
The site's SPCC plan included tables of the various above ground tanks, the available secondary
X
containment, and the inspection and testing requirements.
Stormwater BMP Summary Section A(2)(c)
In the plan provided in the subsequent email to the inspection, in addition to the specific section for
BMPs there was information in the section pertaining to the outfalls about the measures in place at
X
the outfalls. During the inspection, additional areas of rip rap were observed in the conveyances
leading to outfall 5 which was not included in the plan.
Spill Prevention & Response Procedures (SPRP) Section A(3)
In the SPCC plan provided during the inspection, spill response procedures were included for above
X
round tanks.
Page 2 of 7

2. BASIC STORMWATER POLLUTION PREVENT INFORMATION
SPPP TOPICS (Part II)
YES
NO
N/E
Preventative Maintenance and Good Housekeeping Program Section A(4)
In the plan provided in the subsequent email to the inspection, there was a section outlining the
housekeeping and maintenance program implemented at the site. Additionally, these measures were
included in the inspection checklist used at the facility. Neither the plan nor checklist included all of
X
the observed BMPs at the site. Specifically, the rip rap drainage features and check dams were not
identified on the checklist. Additionally, the plan did not establish schedules for the required
measures.
Employee Training Section A(5)
X
The site plan requires annual training for facility personnel responsible for oil -handling operations.
Identify the Responsible Party Section (A)(6)
X
SPPP Modified or Update to Current Conditions Section (A)(7)
In the plan provided in the subsequent email to the inspection, a table of the annual updates was
X
provided. The most recent update of the plan appeared to have been from 08/2017.
Schedule and Procedures for Routine Inspections Section A(8)
The SPCC plan provided during the inspection and the SPPP provided in the subsequent email
included the requirement for quarterly inspections and included the checklist that was to be used. This
X
monthly inspection form listed the various areas requiring inspections (which included areas like the
tanks areas and outfalls). The documents did not include all of the observed BMPs at the site.
Specifically, the rip rap drainage features and check dams were not identified on the checklist.
ATI Allvac operates a metal alloy facility in Monroe, NC which produces a variety of nickel and titanium allows. This
facility operates 24 hours per day, seven days per week and employees approximately 1300 employees. These products are
produced through a variety of processes including melting, casting, forging, rolling, sawing, and grinding. Additionally, the
facility performs maintenance operations at this facility. The primary raw material used at the site is raw metal which is
received by 55 gal drum. Products from the process are ingots of various alloys which can be sent either to customers or to
the Bakers facilities for further processing. In addition to the storage of metal materials at the site, there is also fuel and
chemical storage.
The Monroe facility currently operates with three NPDES permits: an industrial stormwater permit, NCS000330; a
conventional wastewater permit for cooling water, NC0045993; and a pretreatment permit, CM-15. For its industrial
stormwater permit, ATI operates six stormwater outfalls which discharge stormwater from six different drainage areas. The
facility has a seventh drainage area which discharges to the stream by way of the cooling water ponds and is covered under
the conventional permit. For its six stormwater outfalls, the facility had identified Outfall 92 as the representative outfall for
which benchmark monitoring is performed.
4. RECORD REVIEW
Record Review
YES
NO
N/E
Representative on -site
X
Records of the Implementation of the SPPP Part II Section A(9), Part III Section D(6)
Samples of records from 2017 and 2018 were available and reviewed.
X
Records of Maintenance and Housekeeping Programs Part II, Section A(9)
X
Page 3 of 7

4. RECORD REVIEW
Record Review
YES
NO
N/E
The facility maintained an electronic database for maintenance activities. Samples of maintenance
and housekeeping measures were requested and provided. The provided records showed the facility
Performing maintenance on drainage features, outfalls, and performing cleaning and debris removal.
Records of Routine Inspections Part II, Section A(9)
Inspection records were reviewed back through 2017 and showed the facility performing monthly
X
inspections. With the exception of the records from 05/2017 and 07/2017, the inspection records were
available for review.
Records of Employee Training Part II, Section A(9)
According the facility personnel, employee training is provided to all plant personnel. A database of
X
the employees and their training status was maintained by the facility. These records were requested
for 2018 and appeared to meet the necessary requirements.
Records for the Approval of Representative Outfalls Part III Section D(5)
During the permit renewal process in 2009, the facility submitted a request to use Outfall 2 as the
X
representative outfall for the 6 stormwater outfalls. This approach was approved by the state in the
cover letter for the permit renewal.
Records of Benchmark Monitoring Part II, Section B & D, Part III Sections D, & E(I)
Benchmark monitoring data was reviewed for 2017 and 2018. The provided data appears to show
sampling being performed quarterly. According to facility personnel, aside from pH sampling which
is performed by facility personnel, the testing of samples is performed by an outside lab. A review of
X
the monitoring records shows the appropriate holding times and analysis methods were being met.
The monitoring data also shows that since 2017 the facility has experienced regular exceedances of
zinc benchmark.
Records of Qualitative Monitoring Part II Section C, Part III Section D
Qualitative monitoring records were included with the periodic benchmark monitoring. Although
benchmark monitoring was only required at Outfall 2 (the representative outfall), quarterly qualitative
X
monitoring was still required for all outfalls. Review of the available monitoring data showed the
facility performing the qualitative monitoring at all of the outfalls at the frequency of the benchmark
monitoring.
Records of Tiered Approach to Benchmark Exceedances Part III Sections B
Benchmark data since 2017 shows single exceedances for COD (07/2017) and nickel (01/2018). For
zinc, benchmarks have been consistently exceeded since 2017 except for the 05/2018 sampling event.
In response to the COD and nickel exceedances, the facility provided its applicable Tier 1 response.
X
For the zinc exceedances, which have not seen two consecutive events without exceedances, there
was no documented tiered response. Additionally, due to the duration of the zinc exceedances, the
facility should have been performing monthly benchmark monitoring (instead of semiannually).
Records of Bypasses Part III Sections E(7)
According to facility personnel, there have been no instances during 2017 and 2018 meeting this
X
requirement.
Records of 24 hr Reporting Part III Sections E(8 &9)
According to facility personnel, there have been no instances during 2017 and 2018 meeting this
X
requirement.
Page 4 of 7

Pollutant Sources
Note location, quantitative description, design issue, O&M deficiencies (including the nature
and extent), and pollutants off -site
According to facility personnel, the majority of the raw materials received at the facility are received
by truck primarily in 55 gal drums. The primary raw material use at the site is raw metal. Once the
material in the drums is used, the drums are retained at the site for use at finished end of the process.
Raw Material and
This includes storage or waste material from the process and the storage of historical process
Product Storage
samples.
Areas
The products from the facility are typically shipped as metal ingots. Product storage areas were
observed in various areas throughout the site including along the west side of the site. Photographs
DSCN1938-DSCNI940 show the outdoor storage area within the Outfall 4 drainage area.
Although the majority of the process operations at the facility are located inside of the various
buildings, there were some process equipment and operations that are performed outdoors.
Outdoor Process
Baghouses were used for the control of particulate air emissions. The baghouses were typically
Operations
located outside of the buildings and collected particulates in either 55 gal drums or sacks (seen in
photos DSCN1954-DSCNI955 and DSCN1957). A washing station was observed near the northwest
corner of the site. This area, seen in photo DSCN1970, had drain inlets used to collect water and
direct it to the wastewater treatment plant.
Stormwater throughout the site could be collected in storm drains throughout the site (seen in photos
Storm drains
DSCN1950-DSCNI954, DSCN1956, and DSCN1959) and directed to the various drainage features
to the outfalls or the wastewater treatment facility.
According to the facility's site plan, periodic inspections of housekeeping measures are performed.
This includes inspecting for accumulated dust, debris, and metal turnings in storage areas. During
the inspection, areas of debris and dust accumulation were observed in a few of the storage areas on
site. Examples of these include the waste storage areas along the south side of the site (seen in photos
DSCN1945 and DSCN1957). In these areas, evidence of dust, metal, and other dumpster material
accumulation was observed accumulated.
Housekeeping
In addition to the storage areas, some of the stormwater managing features were observed in need of
some additional housekeeping measures. One of the storm drain inlets near one of the baghouse
areas, seen in photo DSCN1954, was observed with accumulated sand, gravel, and white powder
material. In the stormwater conveyance through the middle of the site, seen in photo DSCN1968,
significant amounts of sediment/dust debris were observed. The facility was observed as having
installed check dams in this conveyance near the storm drain inlets to help manage sediment.
Sediment around the check dams had accumulated to the height of the check dams resulting in a
reduced effectiveness of the control measure and therefore in need of maintenance.
Several above ground storage tanks were in place at Allvac's Monroe facility. Most of these tanks
were place in areas with secondary containment. One of these areas can be seen in photo DSCN1958.
According to facility personnel, the two containment structures in this area are connected and tied to
Liquid Storage
the wastewater treatment facility. Evidence of past spills were evident in this area. Photo DSCN1969
Tanks
shows a fueling station and the secondary containment around the above ground tank. This
containment structure was observed with a capped drain valve. According to facility personnel,
accumulated liquid in the secondary containment structure can be pumped to either the storm drain
or to the wastewater treatment plant depending on its contents.
Page 5 of 7

Pollutant Sources Note location, quantitative description, design issue, O&M deficiencies (including the nature
and extent), and pollutants off -site
A variety of BMPs were implemented to help manage stormwater runoff from the site. Several of
the stormwater conveyances and outfalls throughout the site were observed with rip rap installed to
minimize erosion and sediment entrainment. Examples of this can be seen in photos DSCN1939-
DSCN1940, DSCN1946, DSCN1961-DSCN1962, and DSCN1964. Some stormwater drainage
Best Management features were observed without any rip rap and erosion prevention measures (see photo DSCN1960
Practices (BMPs) of outfall 3). A few of the drainage features appeared to have been subjected to significant sediment
runoff and as a result had multiple rock check dams installed to better manage the runoff. This was
observed in the drainage feature to Outfall 5 (seen in photo DSCN1967) and concrete conveyance
running cast/west near the middle of the site (seen in photo DSCN1068). These additional BMPs
were not identified in the site plan.
Waste material storage was observed in various locations at the site. Along the south side of the site,
spent furnace rods were observed in one of these storage areas along the south end or the site (seen
in photo DSCN1941). This location was near an erosion feature (seen in photo DSCN1942)
potentially discharging off site and not addressed in the facility's site plan. Additional waste storage
area can be seen in photos DSCN1944-DSCM1945, DSCN1949, and DSCN1966.
Disposal/Waste Some of the waste material at the site was stored in various areas in 55 gal drums. Near the northeast
Handling Areas corner of the site, the facility has a storage area for empty drums that will be utilized for storage (see
photo DSCN1965). Flux material from the furnaces was observed in various areas of the site being
stored in open top 55 gal drums (see photos DSCN1955 and DSCN1957).
Along the south side of one of the furnace buildings, the facility was observed with open top
dumpsters in place receiving spent brink from the furnace rebuilds. One of the dumpsters, seen in
photo DSCN1948, was observed with a cloudy white discharge. No best management practices
appeared in place which the runoff believed to reach one of the facility's unmonitored outfalls.
6. OUTFALL, STORMWATERDISCHARGE
& RECEIVING WATER OBSERVATIONS
Outfall, Stormwater
Discharge &
YES
NO
Receiving Water
Describe: The inspection team observed six external outfalls associated with its
stormwater permit during the inspection. Outfall 1 was located on the east side of
the site and can be seen in photo DSCN1963. Outfall 2, located on the east side of
the property, is the outfall currently designated as the representative outfall for the
Number & location
site. This outfall can be seen in photos DSCN1961-DSCN1962. According to facility
of stormwater
personnel, benchmark samples are pulled towards the end of the rip rap channel.
discharge(s)/outfall(s)
X
Outfall 3 can be seen in photo DSCN1960. Outfall 4 was observed discharging near
consistent with the
the southwest corner of the site. This outfall, seen in photo DSCN1937, was observed
SPPP
discharging water with a distinct red color during the inspection. This appeared to be
qualitatively unique from the other outfalls. The collection ditches leading to Outfall
4 can be seen in photos DSCN1939-DSCN1940. Outfall 5, which is near the
northeast corner of the site, can be seen in photo DSCN1964. Outfall 6 was observed
in photo DSCN1947 and discharged to the south side of the site. This outfall was fed
by the drainage ditch seen in photo DSCNN1946.
Page 6 of 7

6. OUTFALL, STORMWATEROBSERVATIONS
Outfall, Stormwater
Discharge & YES NO
Receiving Water
Evidence of off -site
accumulation of
X
Describe: No evidence of off -site accumulation was observed during the inspection.
pollutants observed
in receiving water
Other potential
Describe: Additional erosion features were observed near the southwest side of the
discharges off -site
site near a waste material storage area. Two erosion feature, seen in photos
(through outfalls not
X
DSCN1942-DSCN1943, were observed leading to the southern property bourder.
included in the
The feature in photo DSCN1942 was observed with rip rap in place signaling that
SPPP)
the facility was aware of discharging from this point implementing best management
practices to manage the discharge.
Non-stormwater
X
Describe: During the inspection, the inspection team did not observe any non -
discharge observed
stormwater discharges discharging to stormwater outfalls.
Additional inspection summary, narrative, findings, comments, photos, and schematic diagram of the facility area
as necessary:
At the end of the site visit, an exit conference was held with facility personnel were the following observations provided:
• SPPP Observations
o The site map included in the site plan did not include all of the potential pollutant sources and BMPs
o The plan provided neither signed nor included documentation of it being reviewed and updated annually
• Records Observations
o The inspection records provided by the facility did not include evaluations of the storm drain inlets
o Records of stormwater BMP maintenance were not available. Specifically, the facility was unable to
provide records of rip rap repair and storm drain cleaning and maintenance.
• Site Observations
o Some housekeeping concerns were observed at the site including sediment trails to storm drain inlets
o A significant difference in appearance was observed between the selected representative outfall (Outfall
92) and Outfall 94 suggesting that there could be pollutants unique to Outfall 4 and therefore not
appropriately represented by Outfall 92.
o There was neither labeling nor information in the site plan pertaining to which outfall the various storm
drains throughout the site drain.
Page 7 of 7

�- -
rL'[: S
t
OP
:restive DipSchool �s� ClipperCut QUEEN
16
AP
r k
.. t
i
tia
n� �nf P._i �hlir.. Maa data 2Q1 G000L- Imaorw @201-9. DtitalGbbe. USDA, Farm S*rvic-ff Az
n c';

DSCN 1937.J PG
` .' :.��3j �...' � �' � - ..', ,� . 'q..' =.:..•rid
48
`� _ •..' ..h lid. •` ^^„r•{: ,I. '•:•' .. - , -+
.. ii .p. i� . It �+, e^��..r 9+wr7. e•S� r•.L�;,}.`..�..i�I�j{r �,
. 4 `5 A RI•� .a}1� �9,' ii :'i ;fi ' -,(,k'. �1- �tY rti':. ;•i'' {�i°:! . , .' .. . -
jr
�: ..L ,v" fir: e•� � ,:'�'• �'• `� � ... _
o. '.. �P`. y �'.• E •r�..�� .41
7g���..,. sib" :•. ;�... � ' - - _ J��- � -- .-•�'. � :F.
_ ai ,� f.. ,i - �. � - •Vial/ t
SLItt011 Park
4 '
0'
r- Q:..'irrk f'C4
Icz .
Attributes
File Name
DSCN1937.JPG
Description
Photograph of Outfall 4. Outfall is not the determined representative and monitored outfall at
this facility. This outfall, which drains the west side of the facility, was observed with a distinct red
color indicative of entrained iron.
Latitude
N 34' 59' 01.06"
Longitude
W 80° 31' 08.73"
SW-NCS000330-032119 Page 2 of 35

qk
fJ'}}1 !J�'�1
USDA Farm Service

DSCN 1939.J PG
Sutton Park '-
Attributes
File Name
DSCN1939.JPG
Description
Photograph of an outdoor storage area in the drainage area for Outfall 4.
Latitude
N 34° 59' 01.21"
Longitude
W 80' 31' 08.63"
SW-NCS000330-032119 Page 4 of 35

DSCN 1940.J PG
Sutton Park
4+4
G
pq
Attributes
File Name
DSCN1940.JPG
Description
Photograph of the rip rap ditches and inlet leading to Outfall 4.
Latitude
N 34° 59' 01.70"
Longitude
W 80° 31' 08.85"
SW-NCS000330-032119 Page 5 of 35

DSCN 1941.J PG
'
y l
5;i1 � �' � 155;4}�x�� �•
'rt41iPark
i, it PV
x .rxs',3
Quarry Rd
Attributes
File Name
DSCN1941.JPG
Description
Photograph of the storage area in the southwest corner of the site. This area was primarily used
for waste and spend furnace rods.
Latitude
N 34° 59' 00.54"
Longitude
W 80' 31' 02.35"
SW-NCS000330-032119 Page 6 of 35

' .� � �,y`-,L:^,�.'�i,i,�,li i 1`i .��"r�x/ � �rrr� / ,:y :r �Y'� • � �
i3 tIrJB.Y,
L
, .9919,talGbbe. USDA Farm Service Agemv

DSCN 1943.J PG
Attributes
File Name
DSCN1943.JPG
Description
Photograph of an erosion feature on the southside of the site resulting in an additional potential
outfall.
Latitude
N 34° 58' 59.99"
Longitude
W 80' 31' 01.02"
SW-NCS000330-032119 Page 8 of 35

DSCN 1944.J PG
Attributes
File Name
DSCN1944.JPG
Description
Paved area on the south in the drainage area to Outfall 6. Some dust and sand accumulation were
observed in this area which is used for waste storage.
Latitude
N 34° 59' 00.02"
Longitude
W 80' 31' 01.01"
SW-NCS000330-032119 Page 9 of 35

DSCN 1945.J PG
Park
Attributes
File Name
DSCN1945.JPG
Description
Photograph of the paved area in the Outfall 6 drainage area used for waste storage. Dust and
metal accumulation were observed in this area around the roll off dumpsters.
Latitude
N 34° 59' 00.17"
Longitude
W 80' 30' 59.41"
SW-NCS000330-032119 Page 10 of 35

DSCN 1946.J PG
P ark
y
O+Aarfy Rd
f.;
Attributes
File Name
DSCN1946.JPG
Description
Photograph of the drainage ditch leading to Outfall 6.
Latitude
N 34° 58' S9.91"
Longitude
W 80' 30' 58.88"
SW-NCS000330-032119 Page 11 of 35

qw-
��� 'i .� •�. r.� _ -ter 1 'J y� �i J J f � .
.talSlobe, USDA FarmSerwwe

DSCN 1948.J PG
Attributes
File Name
DSCN1948.JPG
Description
Photograph of an open dumpster on the southside of the facility. The dumpster was used for
catching spend refractory brick from the furnaces. Some of the refractory material was observed
outside of the dumpster and a liquid stream was observed discharging from the dumpster with
residuals from the spent brick (the white sheen).
Latitude
N 34' 58' 59.68"
Longitude
W 80' 30' 57.37"
SW-NCS000330-032119 Page 13 of 35

DSCN 1949.J PG
Attributes
File Name
DSCN1949.JPG
Description
Area along the south side of the site near the underground storage tank. Some spend material
storage was observed in this area including open buckets (seen at the bottom of the photo) with
accumulated stormwater and process material.
Latitude
N 34' 58' 59.48"
Longitude
W 80' 30' 55.18"
SW-NCS000330-032119 Page 14 of 35

DSCN1950.JPG
Attributes
File Name
DSCN1950.JPG
Description
Photograph of a storm drain along the south side of the site behind the re -melt building.
According to facility personnel, this storm drain discharged to lower pond which was part of the
waste water treatment system.
Latitude
N 34' 58' 59.24"
Longitude
W 80' 30' 53.39"
SW-NCS000330-032119 Page 15 of 35

DSCN1951.JPG
Attributes
File Name
DSCN1951.JPG
Description
Photograph of a storm drain along the south side of the site behind the melt building. According
to facility personnel, this storm drain discharged to lower pond which was part of the waste water
treatment system.
Latitude
N 34' 58' 59.15"
Longitude
W 80' 30' 52.51"
SW-NCS000330-032119 Page 16 of 35

DSCN1952.JPG
Attributes
File Name
DSCN1952.JPG
Description
Photograph of a storm drain along the south side of the site behind the melt building. This drain
appeared to have roof drains and three additional pipes discharging into it. According to facility
personnel, this storm drain discharged to lower pond which was part of the waste water
treatment system.
Latitude
N 34' 58' 59.11"
Longitude
W 80' 30' 52.47"
SW-NCS000330-032119 Page 17 of 35

DSCN 1953.J PG
Attributes
File Name
DSCN1953.JPG
Description
Photograph of a storm drain inlet near the cooling water pumps. According to facility personnel,
this storm drain leads to the lower pond and the wastewater treatment system.
Latitude
N 34° 58' 59.13"
Longitude
W 80' 30' 52.12"
SW-NCS000330-032119 Page 18 of 35

DSCN1954.JPG
Attributes
File Name
DSCN1954.JPG
Description
Photograph of the storm drain inlet on the southside of the building near one of the baghouses.
Sand and white dust accumulation was observed in this area leading to the storm drain which
directs runoff to Outfall 3.
Latitude
N 34' 58' S9.21"
Longitude
W 80' 30' 49.27"
SW-NCS000330-032119 Page 19 of 35

DSCN1955.JPG
4# {
USDA FarmSarwiceAgency
Attributes
File Name
DSCN1955.JPG
Description
Photographs of open top drums with flux from the process. Accumulated water was observed in
the drums potentially commingling with the flux.
Latitude
N 34° 58' 58.86"
Longitude
W 80° 30' 49.11"
SW-NCS000330-032119 Page 20 of 35

DSCN 1956.J PG
'1
Attributes
File Name
DSCN1956.JPG
Description
Photograph of a storm drain inlet near one of the facility baghouses. This storm drain drained the
surrounding area and had sediment and dust accumulation around the storm drain inlet.
Latitude
N 34° 58' 57.97"
Longitude
W 80' 30' 47.59"
SW-NCS000330-032119 Page 21 of 35

DSCN1957.JPG
• r
1
ffT
Attributes
File Name
DSCN1957.JPG
Description
Photograph of an outdoor drum storage area on the south side of the building. Stormwater
accumulation was observed on and in the drums. Some dust/sediment accumulation was
observed in the area around the drums.
Latitude
N 34' 58' 58.61"
Longitude
W 80' 30' 46.68"
SW-NCS000330-032119 Page 22 of 35

DSCN1958.JPG
Attributes
File Name
DSCN1958.JPG
Description
Photograph of a storage tank area on the south side of the site. Some oil accumulation was
observed along the containment structures in this area. There were two secondary containment
structures in this area around the tanks with one draining to the other which was connected to
the wastewater treatment system.
Latitude
N 34' 58' 58.21"
Longitude
W 80' 30' 43.94"
SW-NCS000330-032119 Page 23 of 35

DSCN1959.JPG
Attributes
File Name
DSCN1959.JPG
Description
Photograph of a storm drain inlet near the southeast corner of the site. This inlet was located
near one of the facility baghouse behind the GFM process.
Latitude
N 34° 58' 58.10"
Longitude
W 80' 30' 36.67"
SW-NCS000330-032119 Page 24 of 35

DSCN 1960.J PG
Attributes
File Name
DSCN1960.JPG
Description
Photograph of Outfall 3 near the southeast corner of the site. Rip rap and other erosion control
measures were observed in the drainage ditches leading to the outfall but none located in the
area in the photograph below the outfall.
Latitude
N 34' 58' S7.47"
Longitude
W 80' 30' 33.37"
SW-NCS000330-032119 Page 25 of 35

DSCN1961.JPG
Attributes
File Name
DSCN1961.JPG
Description
Photograph of Outfall 2 on the east side of the site. This outfall is the representative outfall that
has periodic benchmark monitoring. Benchmark samples are pulled from the area at the end of
the rip rap.
Latitude
N 34' 59' 00.23"
Longitude
W 80' 30' 32.96"
SW-NCS000330-032119 Page 26 of 35

DSCN 1962.J PG
r •:
erVwka
4
! 'y, ':S_..�.t•.�_ ,.7 `\. . y�� ..: ,�� ".i�. ram:.
d/ . �Y �!� �l - �. ESL �. _ . � _-/ric,r'.'7` :!Y.,�..� �.....: •,' ...
ti r ry~I.�.^ieY t •_ram_. ,may ia-'�e..,:•.. .� titw .a $. •,� ,. ^.
.14
SIM�.j....
r_
Attributes
File Name
DSCN1962.JPG
Description
Photograph of Outfall 2 on the east side of the site. This outfall is the representative outfall that
has periodic benchmark monitoring. Benchmark samples are pulled from the area at the end of
the rip rap.
Latitude
N 34' 59' 00.11"
Longitude
W 80' 30' 33.22"
SW-NCS000330-032119 Page 27 of 35

\ ` � � 1 �\ \ �\ \ �. \ • 1�'�'�11�7'f RV \ TY �\ I � �.. \; / �i.�y .� �.; ��� I� � r�.y�� .
\ "N
vc
k
_.�,t$#Gbbe, U3d,4Farra'''.,eryice Aq'encv

DSCN 1964.J PG
Attributes
File Name
DSCN1964.JPG
Description
Photograph of Outfall 5 rip rap.
Latitude
N 34' 59' 04.93"
Longitude
W 80' 30' 37.60"
SW-NCS000330-032119 Page 29 of 35

DSCN 1965.J PG
Attributes
File Name
DSCN1965.JPG
Description
Photograph of outdoor drum storage area near Outfall 5.
Latitude
N 34° 59' 07.09"
Longitude
W 80' 30' 38.02"
SW-NCS000330-032119 Page 30 of 35

DSCN 1966.J PG
Attributes
File Name
DSCN1966.JPG
Description
Photograph of an outdoor storage area near Outfall 5.
Latitude
N 34° 59' 07.09"
Longitude
W 80' 30' 37.99"
SW-NCS000330-032119 Page 31 of 35

I
FES
n
CD
7�
�L '.kl
AM
9 9 -1 irt 'M�b. USDA Farm Service'.
-4
-41

DSCN1968.JPG
Attributes
File Name
DSCN1968.JPG
Description
Photograph of a drainage ditch running through the middle of the site. This section of the ditch
was near the inlet to the storm drain inlet. Significant sand and dust was observed along the ditch
and around the storm drain inlet.
Latitude
N 34' 59' 00.32"
Longitude
W 80° 30' 42.61"
SW-NCS000330-032119 Page 33 of 35

DSCN 1969.J PG
Attributes
File Name
DSCN1969.JPG
Description
Photograph of a fueling area near the middle of the site. A secondary containment structure was
observed around the tank with a capped outlet. Accumulated water in the secondary
containment structure can be either pumped to the storm drain or sent to the wastewater
treatment system depending on test results.
Latitude
N 34' 59' 01.34"
Longitude
W 80' 30' 50.75"
SW-NCS000330-032119 Page 34 of 35

DSCN1970.JPG
arks Pq$
f)!..Ife . �{,,
Attributes
File Name
DSCN1970.JPG
Description
Photograph of a miscellaneous washout area along the north side of the site. Wash water from
this area is sent to the wastewater treatment system.
Latitude
N 34° 59' 01.89"
Longitude
W 80' 30' 56.37"
SW-NCS000330-032119 Page 35 of 35