NCG030284_MONITORING INFO_20090617

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO.
49
DOC TYPE
❑HISTORICAL FILE
� MONITORING REPORTS
DOC DATE
❑A /0 Oi O 6
YYYYMMDD

n GERDAU AMERISTEEL
June 17, 2009
Division of Water Quality
Attn:DWQ Central Files
1617 Mail Service Center
Raleigh .North Carolina 27699-1617
SUBJECT:Stormwater Discharge Outfall(SDO) Monitoring
Report- Stormwater Permit COC-NCGO30284
Gerdau AmeriSteel Charlotte Fabrication
301 Black Satchel Drive
Charlotte,NC 28216
Gentlemen:
In accordance with Part 11I,Section E,item I of permit no.COC-NC6030284,enclosed are two originals of the subject report.As
documented in the SDO report, the stormwater discharge sample collected on May 15,2009 exceeded the total suspended solids
benchmark concentration of 100 mgll.
In accordance with Part 11,Section B of the permit we have conducted the required Tier I response evaluation,deve loped a
corrective action plan and are in the process of implementing same.The required report documenting the Tier I response is
attached.A copy of the report is also on file with the facility storm water pollution prevention plan.
A copy of this submittal is being provided to Ms. Marcia Allocco at the Mooresville Regional Office.
Your attention to this matter is appreciated;if there are any questions please contact me at 813 207 2200 or via email at
Lnieves rr,eerdauameristeel.com.
Manager Environmental Affairs
Cc:Ms.Marcia Allocco Mooresville Regional Office
it
Executive Offices
4221 W. Boy Scout Boulevard, suite 600 • Tampa, Florida 33607 - P.O. Box 31328 • Tampa, Florida 33631-3328 • [phone] • [phone]

STORMWATER DISCHARGE OUTFALL (SDO)
MONITORING REPORT
GENERAL PERMIT NO. NCG030000 SAMPLES COLLECTED DURING CALENDAR YEAR: 2009
CERTIFICATE OF COVERAGE NO. NCG030284 (This monitoring report is due at the Division no later than 30 days from
the date the facility receives the sampling results from the laboratory.)
FACILITY NAME GerdauAmeristeel Corporation (301 Black Satchel Drive} COUNTY Mecklenburg
PERSON COLLECTING SAMPLES John Lindemann PHONE NO. [phone]/ 7 04 _ 3rt cl _ ri O 2
CERTIFIED LABORATORY Pace Analytical Services, Inc. Lab # 37712 and 40
Lab # PLEASE SIGN ON THE REVERSE
Part A: Specific Monitoring Requirements
Outfall'Datei00530�r•
No.,
Sample Collected,'
.' - molddl uv � ,�
.° t
`» 00400'-
01051
°00556
;; 75141 'i,•;
,TotahSuspeiWi Solids,
, ; " m.:.. L� r ll
', pH,
M Standard:un�ts �
L'e'ad; dig/L
.,.> �� �a' _�,nu
ku0il and ,Grease,
,,•`.. iti L'
'Cotai Toxic Organics.;
� :,, :m.. • L + ; s
Benchmark`:
>. ter, !
1 i'%i100'.d,�::�w„
Witliin 6 0 9 0,
0:033
1
05/15/09
541
8.4
0.0065
ND <5
NA
Note: If you report a sampled value in excess of the benchmark value, or outside the benchmark range for pH, you must implement Tier 1 or Tier 2 responses.
See General Permit text.
Did this facility perform Vehicle Maintenance Activities using more than 55 gallons of new motor oil per month?_ yes Xno
(if yes, complete Part B)
Part B: Vehicle Maintenance Activity onitoring Requirements
•,.,
Outfall :.
No
. LI l" ,yria
Dater
Sampte`Collect
mo/dd/'r,idy
wl °Als
AOO5S6 a ,a
F , 00530 ,
00400.
5,
d�Crease, ". , ., r
�t r,iri . L �' L 4 .•
,Total;Suspend'ed Solids, ,
;" m * L';»
"4 L,pH, } +'
a,' Staiida'rd:units<
:,NewMotoi, Oil Usage,
<,Annual,avera a sllmo:...
Benchmarks0':
-
;;60. ,9. " ••a.,,.
,, -
Note: If you report a sampled value in excess of the benchmark value, or outside the benchmark range for pH, you must implement Tier i or Tier 2 responses.
See General Permit text.
STORM EVENT CHARACTERISTICS:
Date 05/15/19 (first event sampled)
Total Event Precipitation (inches): Approx. 0.5
Date (list each additional event sampled this reporting period, and rainfall amount)
Total Event Precipitation (inches):
Mail Original and one copy to:
Division of Water Quality
Atin: DWQ Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
S WU-245-031308
Page I oft

l Total Toxic Organics sampling is applicable only for those facilities which perform metal finishing operations, manufacture semiconductors, manufacture electronic crystals, or
manufacture cathode ray tubes. For purposes of this permit the definition of Total Toxic Organics is that definition contained in the EPA Effluent Guidelines for the facility subject
to the requirement to sample (for metal finishing use the definition as found in 40 CFR 433.1 I; for semiconductor manufacture use the definition as found in 40 CFR 469.12; for
electronic crystal manufacture use the definition as found in 40 CFR 469.22; and for cathode ray tube manufacture use the definition found in 40 CFR 469.31).
Facilities that incorporate a solvent management plan into the Stormwater Pollution Prevention Plan may so certify, and the requirement for TTO monitoring may be waived. The
solvent management plan shall include a list of the total toxic organic compounds used and the other elements listed in the General Permit. For those facilities electing to employ the
TTO monitoring waiver, the discharger shall sign the following certification statement:
"Based upon my inquiry of the person or persons directly responsible for managing compliance with the permit monitoring requirement for total toxic organics (TTO),
certify that to the best of my knowledge and belief, no dumping of concentrated toxic organics into the stormwater or areas which are exposed to rainfall or stormwater
runoff has occurred since filing the last discharge monitoring report. 1 further certify that this facility is implementing the all the provisions of the solvent management
plan included in the Stormwater Pollution Prevention Plan."
Name (Print name)
Title (Print title)
(Signature)
(Date)
"I certify, under penalty of law, that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the
information submitted. Based on my inquiry of the person or persons who manage the system, or those persons
directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief,
true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including
the possibility of fines and imprisonment for knowing violations."
A
A
(Signature of Permittee) (Date)
SWU-245-031308
Page 2 of 2

GERDAU AMERISTEEL CHARLOTTE FABRICATION SWPP PLAN
TIER 1 RESPONSE REPORT FOR EXCEEDANCE OF TOTAL SUSPENDED
SOLIDS BENCHMARK CONCENTRATION IN STORMWATER EFFLUENT
SAMPLE DATE: MAY 15, 2009
1. Kleinfelder under contract to Gerdau Ameristeel(GNA) collected samples of
stormwater discharged from the Charlotte Fabrication facility during a
qualifying storm event on May 15,2009.
2. The samples were sent to PACE Laboratories for testing;the PACE laboratory
report is attached. The report was received attached to a Kleinfelder email on
June 1.
3. Review of the laboratory report indicates that the total suspended solids(TSS)
benchmark concentration was exceeded in the sample.The sample result was
541 mg/l vs. the benchmark of 100 mg/l specified in the permit in Section
B,Analytical Monitoring Requirements,Table 3,page 6 of 9.
4. Lead and oil and grease were significantly under their respective benchmark
concentration vaiues.Ph was within the range.
5. The TSS benchmark exceedance requires that GNA implement certain
actions:conduct a stormwater inspection of the facility by June 15,2009(no
later than 15 days after receipt of the results),identify potential
sources/activities that caused or contributed to the exceedance,identify
potential and select actions such as source controls,operational controls or
physical improvement to reduce concentrations to the benchmark and
implement the selected measures within 60 days(by August 13,2009)of the
original stormwater inspection deadline( June 15,2009).
6. The activities listed in item 5 must be documented in a report and retained
with the SWPP plan.This report has been prepared to comply with this
requirement.
7. A conference call was held on June 9, 2009 with Luis Nieves,GNA Corporate
Environmental,Tom McDowell Shop Supt and Dave Rosene,Regional
Mariager.These are the key personnel associated with the SWPP plan
development and implementation.The TSS benchmark exceedance was
reviewed including the actions in item 5 above. A summary of the findings
and proposed actions follows.
8. An inspection of the site focusing on areas likely to contribute TSS to
stormwater was performd by Tom and David on Jute 10 and 11.Based on
their knowledge of site operations,site layout and physical features(such as
ground cover and paving) and drainage patterns,the unpaved trailer area to the
south of the fabrication shop,the two storm sewer drains and open ditch
leading from this area to the dry detention pond and the detention pond itself
were selected as areas likely to contribute significant TSS to
stormwater. These areas are shown in the site schematic in attachment 2.
9. Observation of the surface of the trailer staging area shows it is a silty,fine
material which is subject to transport by water.While it is not economically
feasible to pave this area now,drain filters will be installed, regularly

inspected and replaced as needed to reduce transport of silt into the two storm
drains that service this area.These inspections will be incorporated into
regularly scheduled monthly facility inspections.
10. The integral sediment basin in these drains will be cleaned to remove
significant amount of accumulated sediment.The drains will be cleaned twice
per year(or more frequently if needed)to reduce sediment build up.Inspection
and cleanup of the sediment basin will be incorporated into the facility
inspection form.
11. The open ditch leading from the drains servicing the trailer staging area to the
dry detention pond will be equipped with a silt fence/haybale turbidity barrier
at the entry point to the detention pond;this barrier will help to reduce TSS
transport.Tbe turbidity barrier will be inspected monthly and repaired
/replaced as needed.
12. A silt fence/turbidity barrier will be installed in the dry detention pond just
upstream of the discharge outfall;this measure should further reduce TSS
concentrations in the discharge.
13. Sod will be installed in areas of the pond that show obvious signs of
erosion;this should also help reduce TSS levels in the discharge.The sod will
be maintained as part of regularly scheduled facility landscaping activities.
14. Planned implementation dates for Items 9 thru 13 above is August 1,2009
.The actual completion date/comment(if any) for each item is recorded below:
ITEM 9:
ITEM 10
ITEM 11
ITEM 12
ITEM 13
Report signatures:
Luis Nieves, Manager Environmental Proces %
Tom McDowell, Shop Superintendent
Dave Rosene,Regional Manager

1►
NCDENR
North Carolina Department of Environment and Natura
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
April 9, 2009
CERTIFIED MAIL 70071490 0004 4509 9131
RETURN RECEIPT REQUESTED
Mr. Charles C. Sudwischer
Gerdau Ameristeel Corporation
301 Black Satchel Drive
Charlotte, NC 28216
Subject: Notice of Violation
Resources
Tracking Number: NOV-2009-PC-0346
Compliance Evaluation Inspection
Gerdau Ameristeel Corporation
Stormwater Permit Number COC NCG030284
Mecklenburg County, NC
Dear Mr. Sudwischer:
Dee Freeman
Secretary
Enclosed is a copy of the Compliance Evaluation Inspection (CEI) report for the
inspection conducted at the subject facility on March 26, 2009, by Ms- Aliyah Turner of
Charlotte -Mecklenburg Storm Water Services (CMSWS). This inspection was conducted as part
of a cooperative working agreement between Mecklenburg County and the Division of Water
Quality. In addition, the inspection was conducted on behalf of the City of Charlotte in
compliance with the City's NPDES Permit, NCS000240, Part II Section H. Thank you for your
assistance and cooperation during the inspection.
This report is being issued as a Notice of Violation (NOV) due to the permittee's failure
to implement the Stormwater Pollution Prevention Plan in violation of the subject Stormwater
Permit and North Carolina General Statute (G.S.) 143-215.1, as detailed in the Stormwater
Pollution Prevention Plan, Qualitative Monitoring, Analytical Monitoring, and Permit and
Outfalls sections of the enclosed report. Pursuant to G.S. 143-215.6A, a civil penalty of not
more than twenty-five thousand dollars ($25,000.00) may be assessed against any person who
violates or fails to act in accordance with the terms, conditions, or requirements of any permit
issued pursuant to G.S. 143-215.1.
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 One
Phane: [phone] [ Fan', (7C4) 663-60401 Customer Service: 1-877-623-6748 NOtffi Carolina
Internet: www.ncwaterquality.crg `�
An Equal Oppor`zjnkty, , Af;,rma�ve Adon Employer - 0% Recycled)'10% Post Carsumer paper ' ������ {r,
✓

1
Mr. C. Sudwischer, Gerdau Amerisreel Corporation
NOV-2009-PC-0346, Page 2
April 9, 2009
In addition, several housekeeping issues were observed during the inspection and
recommendations regarding these issues are provided in the Industrial Operations/City of
Charlotte Stormwater Review Section of the report.
It is requested that a written response be submitted to this Office by May 8, 2009,
addressing the above -noted violations in the enclosed report. In responding to the violations,
please address your comments to the attention of Ms. Allocco at the letterhead address.
The subject facility will have 90 days from the letterhead date to coarse into compliance
with the above -noted violations. A follow-up evaluation will be conducted by CMSWS after,
July 8, 2009 to ensure compliance with the facility's Stormwater Permit and/or compliance with
the City of Charlotte Stormwater Ordinance.
The enclosed report should be self-explanatory; however should you have any questions
concerning this report or have any questions regarding your permit, please do not hesitate to
contact Ms. Marcia Allocco of this Office at [phone].
Sincerely,
for Robert B. Krebs
Regional Supervisor
Surface Water Protection Section
Mooresville Regional Office
Enclosure
cc: NPS-ACO Unit
Rusty Rozzelle, Mecklenburg County
Craig Miller, City of Charlotte
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MR CHARLES SUDWISCHER
`GERDAU AMERISTEEL CORPORATION
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301 BLACK SATCHEL DRIVE
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swp/ma 4/9/09
PS Form :r+
. August 2006 See Reverse for Instructions

Permit: NCG030284
SOC:
County: Mecklenburg
Region: Mooresville
Compliance Inspection Report
Effective: 11/01/07 Expiration: 10/31/12 Owner: Gerdau Amensteel Corporation
Effective: Expiration: Facility: Charlotte Rebar Division
301 Black Satchel Dr
Contact Person: Scott Cox
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Charlotte NC 28216
Title: Phone: [phone]
Certification: Phone:
Inspection Date: 03f26A2009 Entry Time: 10:00 AM Exit Time: 12 00 P1v1
Primary Inspector: Water Quality Program Meckenburg County Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Metal Fabrication Stormwater Discharge COC
Facility Status: Q Compliant ■ Not Compliant
Question Areas:
Storm Water
■ Cornplete�Items 1, 2, said 3. Also complete
item 4 if Restricted Delivery is desired.
N Print your name and address on the reverse
so that we can return the card to you.
IN Attach this card to the back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
I R CHARLES SUDWISCHER
GERDAU AMERISTEEL CORPORATION
1 301 BLACK SATCHEL DRIVE
CHART OTTE NC 28216
-Mp/ma 4/9/09
AL Signature. I
X ❑ Agent
❑ Addressee I
„B. Received by (Anted Name) C. Date of Delivery I
IV i-�-/)9 ,
D. Is delivery address different from item 17 ❑ Yes
If YES, enter delivery address below: ❑ No
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Certified Mail ❑ Express Mail
❑ Ngistered ❑ Return Receipt for Merchandise E
❑ Insured Mail ❑ C.O.D. I
4. Restricted Deli~ (&t►g Fee) ❑ Yes 1.
7007 :1490, 0004 ; 4509 913.1
PS Form 3811, February 2004 Domestic Return Receipt 102595-aaA&I540' Page: 1

14
Permit: NCGO30284 owner - Facility: Gerdau Arneristeel Corporation
Inspection Date: 03/26/2009 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Facility Description:
The Gerdau Ameristeei facility conducts shearing and bending of reinforcing steel bar to specific lengths for the use in
concrete reinforcement construction projects. All manufacturing activities are conducted indoors and not exposed to
stormwater. The facility temporarily stores raw materials (reinforcing steel bars) and products outdoors until they are
shipped off site.
Compliance History:
The permittee/facility does not have any prior compliance issues with the NC Division of Water Quality or with
Charlotte -Mecklenburg Storm Water Services (CMSWS).
Industrial Operations/City of Charlotte Stormwater Ordinance Review:
Several housekeeping issues were observed during the stormwater inspection. The issues are as follows:
Hydraulic Heat Exchanger —
During the stormwater inspection oil was observed on the ground surface at the base of the facility's hydraulic heat
exchanger. The permittee should install secondary containment that will prevent discharges of oil onto the ground surface.
Drums —
During the inspection, two empty 55-gallon drums were observed outside of the manufacturing building. Empty drums can
contain residual fluids that can possibly contaminate stormwater. The permittee should ensure that empty drums are not
exposed to stormwater that have once contained oil or other industrial fluids. it is recommended the permittee properly
dispose of empty drums.
Storm Drain Inlet —
During the inspection, a storm drain inlet was observed that contained a significant amount of gravel and dirt. According to
facility personnel the permittee is in the process of removing debris from the storm drain inlet. The permittee should
continue to remove and prevent debris from entering into the storm drain inlet.
Old Equipment —
During the inspection abandoned industrial equipment was observed under cover (tarp). The tarp was in bad condition,
exposing oily industrial equipment. The permittee should ensure that leaky/leaking equipment is properly covered to
prevent stormwater contamination. It is recommended the facility use a catch pan to contain leaking oil under any
abandoned equipment.
Forklift —
A leaky forklift was observed on site. The permittee should prevent automotive fluids from leaking to the ground surface
by placing a catch pan underneath the forklift to -contain fluids.
Page 2

Permit: NCG030284 Owner - Facility: Gerdau Ameristeei Corporation
Inspection Date: 03/26/2009 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?
■ n n n
# Does the Plan include a General Location (USGS) map?
o ■ o n
# Does the Plan include a "Narrative Description of Practices"?
■ n n n
# Does the Plan include a detailed site map including outfall locations and drainage areas?
■ 13 n n
# Does the Plan include a list of significant spills occurring during the past 3 years?
■ n n n
# Has the facility evaluated feasible alternatives to current practices?
n ■ o o
# Does the faciiity provide all necessary secondary containment?
■ n n n
# Does the Plan include a BMP summary?
n ■ n n
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
n ■ n n
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
n ■ n n
# Does the facility provide and document Employee Training?
n ■ u n
# Does the Plan include a list of Responsible Party(s)?
n ■ Q Q
# Is the Plan reviewed and updated annually?
n ■ n n
# Does the Plan include a Stormwater Facility Inspection Program?
n ■ n n
Has the Stormwater Pollution Prevention Plan been implemented?
n ■ n n
Comment: The USGS reap in the Stormwater Pollution Prevention Plan .(SPPP) did
not include the longitude and latitude coordinates of the facility's outfall. The permittee's
SPPP has not been fully implemented. The SPPP did not include a Feasibility Study,
BMP Summary, Preventative Maintenance and Good Housekeeping Plan, and a Spill
Prevention and Response Plan (SPRP). The Responsible Party section of the SPPP
needs to be updated. The permittee could not provide documentation for employee
training.
Qualitative Monitoring
Yes
No
NA
NE
Has the facility conducted its Qualitative Monitoring semi-annually?
n
■
n
n
Comment: The permittee did not provide documentation for qualitative monitoring
activities.
Analytical Monitoring
Yes
-No
NA
NE
Has the facility conducted its Analytical monitoring?
n
■
n
n
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
n
n
■
n
Comment: The permittee did not provide documentation for analytical monitoring
activities.
Permit and Outfalls
Yes
No
NA
NE
# is a copy of the Permit and the Certificate of Coverage available at the site?
■
n
n
n
Page:3

1 -1
Permit: NGG030284 Owner - Facility: Gerdau Amensteel Corporation
Inspection Date: 03/26/2009 Inspection Type: Compliance Evaluation Reason for Visit: Routine
# Were all outfails observed during the inspection? ® 0 n n
# If the facility has representative outfall status, is it properly documented by the Division? Q 0 ■ n
# Has the facility evaluated all illicit (non stormwater) discharges?
Comment: The permittee did not provide documentation of an evaluation of the
stormwater outfalls for the presence of non-stormwater discharges in the SPPP.
Page' 4

0 CERDAU AMERISTEEL
May 7. 2009
Ms. Marcia Allocco
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Mooresville Regional Office
610 East Center Avenue Suite 301
Mooresville,NC 28115
SUBJECT:Notice of Violation NOV-2009-PC-0346
Compliance Evaluation Inspection
Gerdau AmeriSteel Corporation
Stormwater Permit COC-NCG030284
Dear Ms. Al loco:
R
FC�����
MAY 8 2009
r ..
DN-Surface Water Pto�e- ,an
Thank you for your letter dated April 9 regarding the inspection at our rebar fabrication facility located at 301 Black Satchel
Road; the inspection was conducted on March 26 by Ms. Turner of the Mecklenburg County Stormwater Department.
During the inspection several deficiencies were identified; our responses including corrective actions implemented and to be
implemented are described below.The responses generally follow the same order as they are presented in your letter of April 9.
1. Housekeeping issues:
Hydraulic heat exchanger:The heat exchanger unit was relocated inside the shop building(southwest comer);this was
completed on March 30.The unit will remain inside the building while in use and is equipped with a metal containment tray to
capture any hydraulic fluid leaks.A small area(estimated at 2 foot radius)around the unit was excavated to remove soil stained
with hydraulic fluid.Approximately 2 cubic yards of soil were excavated and disposed offsite by Heritage Environmental
Services.This activity was completed by the morning of April 3.
Empty drums: The empty drums were repositioned inside the shop; this was completed by March 30.Visual inspection of the
soil around the drums did not reveal the presence of soil staining which might be indicative of spills from the drums.As part of
stormwater training conducted subsequent to the inspection, we have reminded all manufacturing personnel that open drums
cannot be stored outside exposed to precipitation because they present a potential for stormwater pollution.
Storm drain inlets containing significant amounts of gravel and dirt: The inlets inspected by Ms.Tumer are located in an
unpaved trailer staging area located to the south of the fabrication shop; in general we agree with her comments. Subsequent to
the inspection we were able to verify two design features of these drains that help mitigate potential discharges of suspended
solids in stormwater leaving the site:
Each drain incorporates a sump to serve as a settling basin for solids; the bottom of the sump is approximately 3 to 4 feet below
the bottom of the drain discharge pipe thus providing capacity for solids to settle.Second, the drains discharge to an onsite
stormwater dry detention area which provides additional settling capability.
In order to ensure the drains remain functional, they will be inspected monthly and sediment removed from the catch basin sump
every six months (or more frequently if inspections indicate the need). This procedure is already in effect and will be
incorporated into a revised stormwater pollution prevention plan by June 1,2009.
Old equipment with tarp in bad condition:A new tarp was placed over the equipment (a welding machine);this was completed
by April 3.All equipment tarps will be inspected on a monthly basis and replaced/repaired as needed.This procedure is in effect
and will be incorporated into a revised pollution prevention plan by June Lin addition,we will lift the equipment ,determine if
Executive Offices
4221 W. Boy scout Boulevard, Suite 600 - Tampa, Florida 33607 - P.O. sox 31328 - Tampa, Florida 33631-3328 - [phone] - [phone]

there is soil staining under the unit and if so excavate for offsite disposal.Subsequently,we will either store the unit under roof,on
a trailer or on the ground with containment for oil if needed.This task will be completed by June 15.
Leaking forklift: We generally agree with Ms.Tumer's finding; the unit had a very small leak of hydraulic fluid from a failing o-
ring which was subsequently repaired. Our forklift is regularly serviced by Southeast Industrial Equipment Company,an outside
service contractor located in Charlotte -,their services includes checks for leaks and replacement of hoses/seals as needed.The unit
is on a 90 day preventive maintenance schedule .
To minimize leakage onto ground surfaces exposed to precipitation, we have implemented a practice to park the forklift under
roof areas when not in use,check the unit for leaks daily and keep a small drip tray onboard the unit in the event a leak
develops.This practice is in effect now and will be incorporated into a revised pollution prevention plan by June 1.
2.Analytical and qualitative monitoring: We have contracted with local consulting firm Kleinfelder Southeast(formerly Trigon
Engineering) in Charlotte to provide services to conduct the analytical and qualitative monitoring during 2009;samples will be
collected twice per year.Kleinfelder will also prepare the discharge monitoring report for Gerdau submittal to NCDNR and a
report summarizing the qualitative monitoring results.A copy of Kleinfelder's scope of work(edited to exclude confidential
information) authorized by Gerdau is shown in Attachment 1.
3.Stormwater Poflution Prevention Plan
General location(UGGS) map:The general location map/site aerial photo in the plan was obtained from the Charlotte
Mecklenburg GIS Real Estate System;however it does not include the latitude and longitude for the stormwater
outfall.Subsequent to the inspection we obtained this information(using Google Earth):latitude 35 deg. 17 min. 00 sec. north and
longitude 80 deg. 53 min. I 1 sec. west.We will incorporate this information into a USGS location map;the location map will be
part of a revised stormwater pollution prevention plan to be completed by June 1.
Best Management Practices(BMP) summary: A BMP summary will be incorporated into a revised stormwater pollution
prevention plan by June 1.
Spffl Prevention/Response(SPR) Plan: An SPR plan will be incorporated into a revised stormwater pollution prevention plan
byJune I.
Feasibility study:A feasibility study of measures to reduce outside storage area exposure to storm water/reduce transport of
pollutants will be performed and incorporated into the revised pollution prevention plan by June t.Please note that all facility
manufacturing operations(with the exception of stock /fabricated rebar,scrap,equipment storage and a garbage receptacle ) are
performed under roof.There are no stacks, vents or air emission sources at the facility.
Preventive Maintenance and Housekeeping Plan. Existing equipment inspection and maintenance procedures (known as a 5s
program) will be incorporated into a revised stormwater pollution prevention plan by June I .The 5s program covers all
operations including equipment and processes conducted under roof in no exposure conditions; these procedures provide
assurance that equipment maintenance issues inside building areas do not impact outside areas exposed to precipitation.
Employee training: An employee training session was conducted with all fabrication shop personnel on April 3, 2009;copies of
sign up sheets are shown in Attachment 2.The training session was led by Mr. Tom McDowell Shop Superintendent and lead
person for the pollution prevention team. To deliver the training content we used a commercial video titled "Storm
Warnings:Storrnwater Pollution Prevention"purchased from Excal Communications. A training refresher will be conducted after
June I(to reflect the revised stormwater pollution prevention plan) and yearly thereafter or when there are significant changes to
the plan.
Responsible party(s):The current stormwater plan has been revised to reflect up to date information on facility contacts.These
contacts and phone numbers are provided below :
a.Primary/Emergency contact :Mr Tom McDowell Shop Superintendent office:(704-399-9020) cel](813-478-1678)
b.Secondary/Emergency contact: Mr. Charles Sudwischer Operations Manager office(704-399-9020) cell(704491-9340)
The above information will also be incorporated into the revised stormwater pollution prevention plan by June I .
Plan Annual Review:An annual review of the plan which included a detailed site inspection of all facility areas was performed
on April 28,2009 by the writer.The report and a list of corrective actions/schedule to implement were reviewed with
Mr.McDowell and Mr.Sudwischer on April 29.The document will be retained on file with the stormwater pollution prevention
plan.

Facility inspection program: A detailed monthly inspection form has been developed focusing on areas exposed to
precipitation;the inspection procedures will be incorporated into a revised stormwater pollution prevention plan by June Bite
inspections will be performed monthly and documented in this form; the completed forms will be retained with the stormwater
pollution prevention plan.
Evaluation of illicit discbarges:The illicit discharge evaluation was performed by the writer on April 28,2009.The evaluation
was performed using a detailed visual inspection of plant stormwater drains,stormwater detention area,outfall discharge and the
fabrication shop(including fabrication equipment).No illicit discharges were observed;f mhermore there are no drains inside the
fabrication shop.The results of the inspection were documented in the EPA Non-stormwater Discharge Assessment and
Certification form which is retained on file with the stormwater pollution prevention plan.The assessment will be performed on a
yearly basis.
We trust these responses address all the issues in your letter and look forward to reinspection of our facility by Ms. Tumer.lf
there are any questions please contact me at 813-207-2200.
Cc Charles Sudwischer Operations Manager
Tom McDowell Shop Superintendent
Dave Rosene Regional Manager

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KLE/NFEL,DER
Bright People. Right Solutions.
April 23, 2009
File: CLT09P117
Mr. Luis Nieves
Gerdau Ameristeel
Subject: Proposal for Stormwater Outfall Analytical Sampling
Gerdau Ameristeel
301 Black Satchel Drive
Charlotte, NC
Dear Mr. Nieves:
Kleinfelder is pleased to provide you with this proposal to provide environmental
consulting services for the Gerdau Ameristeel (Gerdau)) facility in Charlotte, North
Carolina. The services will consist of collecting stormwater samples and completing
required reporting to maintain compliance with the facility's Stormwater permit issued by
the North Carolina Department of Environment and Natural Resources (NCDENR). The
following sections provide scope of services, schedule, fees, and authorization
procedures.
BACKGROUND
The Gerdau facility is subject to the requirements of the NCDENR General Permit No.
NCG030000 under the National Pollutant Discharge Elimination System (NPDES). The
permit requires semi-annual sampling of the stormwater discharges at each of the
stormwater discharge outfalls during a representative storm event. One sample must
be taken between January and June and the other between July and December. The
permit also requires qualitative monitoring of the discharge in conjunction with the
sampling event.
SCOPE OF SERVICES
The scope of services consists of completing two sampling events during the 2009
calendar year and providing sampling event documentation to Gerdau for signature and
submittal to NCDENR.
Kleinfelder personnel will collect the water samples during a representative storm event.
This sampling event will need to occur no less than 72 hours since the previous
recordable rain event; the sampled rain event must consist of at least 0.1" of
precipitation and the sample must be taken within the first hour of the storm event. This
6200 Harris Technology Blvd, Charlotte, NC 28269 p 1704.598.1049 f 1704.598.1050

task will require communication between Gerdau and Kleinfelder to allow for timely
mobilization for staff to conduct the sampling event on -site. Kleinfelder will monitor local
weather conditions to determine appropriate time for sampling, however, weather
conditions may change quickly, and this proposal does not account for costs incurred
due to changing weather conditions which may alter sampling activities and require
additional mobilization for sampling at additional cost to Gerdau.
The samples will be collected for laboratory analysis and transported under chain -of -
custody protocol to Pace Analytical a North Carolina accredited laboratory for analysis
of oil and grease, lead, total suspended solids, and laboratory pH. Kleinfelder
personnel will analyze and record the temperature and pH of the sample at sampling
time and total rainfall in inches for the sampling period. Kleinfelder personnel will also
perform qualitative analysis for the parameters presented in the following table.
Diseharge Gharaetzfiwes
ti '; Frequency
Color
semi-annual
Odor
semi-annual
Clarity
semi-annual
Floating Solids
semi-annual
Suspended Solids
semi-annual
Foam
semi-annual
Oil Sheen
semi-annual
Erosion or deposition at the
semi-annual
outfall
Other obvious indicators
semi-annual
of stormwater pollution
Kleinfelder will provide Gerdau a completed Discharge Monitoring Report, analytical
data package, and completed qualitative monitoring report within 15 days of receiving
the laboratory results. This will allow Gerdau to review, sign, and submit the Discharge
Monitoring Report to NCDENR within the 30-day time frame established in the permit.
SCHEDULE AND COST BASIS
leinfelder will provide the services on a time and materials basis in accordance with
Kour unit fee schedule. Based on the scope of services outlined above, our estimated
fee is - The total project cost estimate includes travel time, sample bottles,
� �4 sampling apparatus, analysis of outfall samples, report preparation, senior author
review, and administrative support.
This fee estimate is based on completing two sampling events at one stormwater outfall
with no additional site visits or mobilizations. Again, weather conditions may change
quickly, and this proposal does not account for costs incurred due to changing weather
conditions.
DCN No. CLT09P117 Page 2 of 3 April 23, 2009
0 2009 Kleinfelder

AUTHORIZATION
This Proposal is an agreement for our services defined herein. Kleinfelder requires that
the attached Work Order be authorized to provide written authorization to Kleinfelder.
Services provided by Kleinfelder will be performed in accordance with the established
Master Services Agreement between Kleinfelder and Gerdau AmeriSteel US, Inc. This
Proposal is valid for thirty (30) days from the date of issuance.
CLOSING
Thank you for the opportunity to continue to provide consulting services to Gerdau
Ameristeel. Please contact Mr. Michael Sussman at 704.598.1049 if you have any
questions.
Sincerely,
KLEINFELDER SOUTHEAST, INC.
Michael A. Sussman, PE
Senior Engineer
Craig D. Neil, PG
Senior Professional
MAS:CDN:mas
Enclosure
❑CN No. CLT09P117
O 2009 Kfeinfelder
Page 3 of 3
April 23, 2009

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I, the undersigned, acknowledge that on (date) 4131C,10017
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Trainer's name:
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® GERDAU AMERISTEEL
June 17, 2009
Division of Water Quality
Attn:DWQ Central Files
1617 Mail Service Center
Raleigh ,North Carolina 27699-1617
SUBJECT:Stormwater Discharge Outfall(SDO) Monitoring
Report- Stormwater Permit COC-NCGO30284
Gerdau AmeriSteel Charlotte Fabrication
301 Black Satchel Drive
Charlotte,NC 28216
Gentlemen:
J U N 19 2009
g..'it.zgcbr '
In accordance with Part I11,Section E,item I of permit no.COC-NCGO30284,enclosed are two originals of the subject report.As
documented in the SDO report, the stormwater discharge sample collected on May 15,2009 exceeded the total suspended solids
benchmark concentration of 100 mg/l.
In accordance with Part II ,Section B of the permit we have conducted the required Tier I response evaluation,developed a
corrective action plan and are in the process of implementing same.The required report documenting the Tier I response is
attached.A copy of the report is also on file with the facility storm water pollution prevention plan.
A copy of this submittal is being provided to Ms. Marcia Allocco at the Mooresville Regional Office.
Your attention to this matter is appreciated;if there are any questions please contact me at 813 207 2200 or via email at
LnievesafQerdauameristee l.com.
Very trul
uis A.Nieve
Manager Environmental Affairs.
Cc:Ms.Marcia Allocco Mooresville Regional Office
Executive Offices
4221 W. Boy Scout Boulevard, suite 600 • Tampa, Florida 33607 • P.O. Box 31328 • Tampa, Florida 33631-3328 - [phone] • [phone]

STORMWATER DISCHARGE OUTFALL (SDO)
MONITORING REPORT
GENERAL PERMIT NO. NCG030000 SAMPLES COLLECTED DURING CALENDAR YEAR: 2009
CERTIFICATE OF COVERAGE NO. NCG030284 (This monitoring report is due at the Division no later than 30 days from
the date the facility receives the sampling results from the laboratory.)
FACILITY NAME Gerd auAmeristeel Corporation [301 Black Satchel Drive) COUNTY Mecklenburg
PERSON COLLECTING SAMPLES John Lindemann PHONE NO. [phone]/704 -39`� - 9 0 LO
CERTIFIED LABORATORY Pace Analytical Services Inc. Lab # 37712 and 40
Lab # PLEASE SIGN ON THE REVERSE 4
Part A: Specific Monitoring Requirements
0utfall
No
Dates �
E�Sample C61l'cted;
rrib/dd/ r
„ lu>
00530 ,.
W00400
�, 1'
r � .0105 . ,
_';OOS56
Total Suspended Solids,;;
` ' kpH,
Standard units
TDead, mg/L
a Oil°andFGrease,
y m /L`,.
Total Toxic Organks,
m /L
Benchmark.
_, ti�
100 .".
•Within�6:0 9:0's_
1
05/15/09
541
8.4
0.0065
ND <5
NA
Note: If you report a sampled value in excess of the benchmark value, or outside the benchmark range for pH, you must implement Tier 1 or Tier 2 responses.
See General Permit text.
Did this facility perform Vehicle Maintenance Activities using more than 55 gallons of new motor oil per month?_ yes Xno
(if yes, complete Part B)
Part 8: Vehicle Maintenance Activity Monitoring Requirements
Dutfali'
%- No..
' `Date�`,i�
Sample'Collected,i"`
"mo/dd/ i
r'Q055G , .F
:3 a p'00530_'�; "r.
;;t�00400;u
V
,Oil and'Grease,
"',m /L..
yTbtalSuspend.e&Solids,
m IL
" _ r pH,' __ .' :>
'' Standard units s
New Motor Oil Usage,
: Aiiniial.aver a allmo
Benchmark,.
:'
r' ..G„" `30,5.6'0
9.Ox
r"
Note: If you report a sampled value in excess of the benchmark value, or outside the benchmark range for pH, you must implement Tier 1 or Tier 2 responses.
See General Permit text.
STORM EVENT CHARACTERISTICS:
Date 05/15/19 (first event sampled)
Total Event Precipitation (inches): Approx. 0.5
Date (list each additional event sampled this reporting period, and rainfall amount)
Total Event Precipitation (inches):
Mail Original and one copy to:
Division of Water Quality
Attn: DWQ Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
S WU-245-03 1109

1 Total Toxic Organics sampling is applicable only for those facilities which perform metal finishing operations, manufacture semiconductors, manufacture electronic crystals, or
manufacture cathode ray tubes. For purposes of this permit the definition of Total Toxic Organics is that definition contained in the EPA Effluent Guidelines for the facility subject
to the requirement to sample (for metal finishing use the definition as found in 40 CFR 433.11; for semiconductor manufacture use the definition as found in 40 CFR 469.12; for
electronic crystal manufacture use the definition as found in 40 CFR 469.22; and for cathode ray tube manufacture use the definition found in 40 CPR 469.31).
Facilities that incorporate a solvent management plan into the Stormwater Pollution Prevention Plan may so certify, and the requirement for TTO monitoring may be waived. The
solvent management plan shall include a list of the total toxic organic compounds used and the other elements listed in the General Permit. For those facilities electing to employ the
TTO monitoring waiver, the discharger shall sign the following certification statement:
"Based upon my inquiry of the person or persons directly responsible for managing compliance with the permit monitoring requirement for total toxic organics (TTO), I
certify that to the best of my knowledge and belief, no dumping of concentrated toxic organics into the stormwater or areas which are exposed to rainfall or stormwater
runoff has occurred since filing the last discharge monitoring report. I further certify that this facility is implementing the all the provisions of the solvent management
plan included in the Stormwater Pollution Prevention Plan."
Name (Print name)
Title (Print title)
(Signature)
(Date)
"I certify, under penalty of law, that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the
information submitted. Based on my inquiry of the person or persons who manage the system, or those persons
directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief,
true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including
the possibility of fineSwgl imprisonment for knowing violations."
A
2ernr>�
(Signature of Per e) (Date)
curt I InR

ji
qr --- f
GERDAU AMERISTEEL CHARLOTTE FABRICATION SWPP PLAN
TIER 1 RESPONSE REPORT FOR EXCEEDANCE OF TOTAL SUSPENDED
SOLIDS BENCHMARK CONCENTRATION IN STORMWATER EFFLUENT
SAMPLE DATE: MAY 15, 2009
l . Kleinfelder under contract to Gerdau Ameristeel(GNA) collected samples of
stormwater discharged from the Charlotte Fabrication facility during a
qualifying storm event on May 15,2009.
2. The samples were sent to PACE Laboratories for testing;the PACE laboratory
report is attached. The report was received attached to a Kleinfelder email on
June 1.
3. Review of the laboratory report indicates that the total suspended solids(TSS)
benchmark concentration was exceeded in the sample.The sample result was
541 mg/l vs. the benchmark of 100 mg/l specified in the permit in Section
B,Analytical Monitoring Requirements,Table 3,page 6 of 9.
4. Lead and oil and grease were significantly under their respective benchmark
concentration values.Ph was within the range.
5. The TSS benchmark exceedance requires that GNA implement certain
actions:conduct a stormwater inspection of the facility by June 15,2009(no
later than 15 days after receipt of the results), identify potential
sources/activities that caused or contributed to the exceedance,identify
potential and select actions such as source controls, operational controls or
physical improvement to reduce concentrations to the benchmark and
implement the selected measures within 60 days(by August 13,2009)of the
original stormwater inspection deadline( June 15,2009).
6. The activities listed in item 5 must be documented in a report and retained
with the SWPP plan.This report has been prepared to comply with this
requirement.
7. A conference call was held on June 9, 2009 with Luis Nieves,GNA Corporate
Environmental,Tom McDowell Shop Supt and Dave Rosene,Regional
Manager.These are the key personnel associated with the SWPP plan
development and implementation.The TSS benchmark exceedance was
reviewed including the actions in item 5 above. A summary of the findings
and proposed actions follows.
S. An inspection of the site focusing on areas likely to contribute TSS to
stormwater was performd by Tom and David on June 10 and 11.Based on
their knowledge of site operations,site layout and physical features(such as
ground cover and paving) and drainage patterns,the unpaved trailer area to the
south of the fabrication shop,the two storm sewer drains and open ditch
leading from this area to the dry detention pond and the detention pond itself
were selected as areas likely to contribute significant TSS to
stormwater. These areas are shown in the site schematic in attachment 2.
9. Observation of the surface of the trailer staging area shows it is a silty,fine
material which is subject to transport by water.While it is not economically
feasible to pave this area now,drain filters will be installed, regularly

inspected and replaced as needed to reduce transport of silt into the two storm
drains that service this area.These inspections will be incorporated into
regularly scheduled monthly facility inspections.
10. The integral sediment basin in these drains will be cleaned to remove
significant amount of accumulated sediment.The drains will be cleaned twice
per year(or more frequently if needed)to reduce sediment build up.Inspection
and cleanup of the sediment basin will be incorporated into the facility
inspection form.
11. The open ditch leading from the drains servicing the trailer staging area to the
dry detention pond will be equipped with a silt fence/haybale turbidity barrier
at the entry point to the detention pond;this barrier will help to reduce TSS
transport.The turbidity barrier will be inspected monthly and repaired
/replaced as needed.
12. A silt fence/turbidity barrier will be installed in the dry detention pond just
upstream of the discharge outfall;this measure should further reduce TSS
concentrations in the discharge.
13. Sod will be installed in areas of the pond that show obvious signs of
erosion;this should also help reduce TSS levels in the discharge.The sod will
be maintained as part of regularly scheduled facility landscaping activities.
14. Planned implementation dates for Items 9 thru 13 above is August 1,2009
.The actual completion date/comment(if any) for each item is recorded below:
ITEM 9:
ITEM 10
ITEM I 1
ITEM 12
ITEM 13
Report signatures:
Luis Nieves, Manager Environmental Proces /
Tom McDowell, Shop Superintendent
Dave Rosene,Regional Manager