NCS000583_Tier 3 Inspection No Exposure Request_20230526

Prakash, Varun
From: Prakash, Varun
Sent: Friday, May 26, 2023 3:46 PM
To: Dwayne Bailey; [e-mail]; Patrick Fee
Cc: Moore, Bill; Dumpor, Samir
Subject: RE: [External] Metallix- Greenville, NC - Tier 3 Notification for NPDES Permit No NCS000583
Noted. Looking forward to seeing you too.
From: Dwayne Bailey <dwayneb@meta llix.com>
Sent: Friday, May 26, 2023 12:35 PM
To: Prakash, Varun <[e-mail]>; Neal. [e-mail]; Patrick Fee <[e-mail]>
Cc: Moore, Bill <[e-mail]>; Dumpor, Samir <[e-mail]>
Subject: Re: [External] Metallix- Greenville, NC - Tier 3 Notification for NPDES Permit No NCS000583
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Hello Varun,
We look forward to your visit on June 7th
Please also note: Rona Durborow no longer works with Metallix Refining. Please send all correspondence going forward
to the following Metallix contacts:
Patrick Fee (COO): [e-mail]
R. Dwayne Bailey (QEHS Manager): [e-mail]
Thank you,
Dwayne Bailey
QEHS Manager
T: [phone]
M: [phone]
E: dwaynebCameta IIix. com
W: www.metallix.com
251 Industrial Blvd.
Greenville, NC 27834
USA
PRECIOUS
metall'i*x
METALS
RECYCLING
1

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From: "Prakash, Varun" <[e-mail]>
Date: Friday, May 26, 2023 at 11:38 AM
To: Rona Durborow <ronad@meta Ilix.com>, Dwayne Bailey <dwayneb@meta llix.com>,
"Neal. Mcelveen(@terracon.com" <Neal.Mcelveen(@terracon.com>
Cc: "Moore, Bill" <[e-mail]>, "Dumpor, Samir" <[e-mail]>
Subject: RE: [External] Metallix- Greenville, NC - Tier 3 Notification for NPDES Permit No NCS000583
Metallix team,
Following up on my previous email from this morning, there has been a scheduling conflict for this inspection.
Does Wednesday, June 7 from 9 to 11 am work for you?
Best regards,
Varun Prakash, Engineer I
Division of Energy, Mineral and Land Resources
Washington Regional Office
943 Washington Square Mall
Washington, NC 27889
Phone: [phone]
D7 E
Rµwpn�M a EarNanahMMN ouallryr
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties
From: Prakash, Varun
Sent: Friday, May 26, 2023 11:24 AM
To: [e-mail]; [e-mail]; [e-mail]
Cc: Moore, Bill <[e-mail]>; Dumpor, Samir <[e-mail]>
Subject: RE: [External] Metallix- Greenville, NC - Tier 3 Notification for NPDES Permit No NCS000583
Metallix team,

Bill and I are planning an inspection of Metallix facility in Greenville, NC to review the following:
1. Causes of exceedances in permitted benchmarks as given in the Individual Permit (NCS000583)
2. Corrective actions planned by Metallix for controlling the above exceedances
3. Metallix's request for Representative Outfall Status for Outfall OF-3 (NCGNE1019) for the NPDES Stormwater
Permit
4. Any other stormwater related issues at this facility
This inspection is scheduled for Tuesday, May 30, from 9 to 11 am. Please let us know you're your questions and
concerns.
Have a great weekend.
Best regards,
Varun Prakash, Engineer I
Division of Energy, Mineral and Land Resources
Washington Regional Office
943 Washington Square Mall
Washington, NC 27889
Phone: [phone]
D� E
aypaArawnt a Fiw+ranahMhA �uallryr
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North Carolina Public Records Law and may be disclosed to third parties
From: Dumpor, Samir <[e-mail]>
Sent: Wednesday, December 21, 2022 12:17 PM
To: Moore, Bill <[e-mail]>; Prakash, Varun <[e-mail]>
Subject: FW: [External] Metallix- Greenville, NC - Tier 3 Notification for NPDES Permit No NCS000583
Importance: High
Guys, let's talk about this when we get together.
Thanks
Samir
Samir Dumpor, PE
Regional Engineering Supervisor II
Division of Energy, Mineral, and Land Resources
North Carolina Department of Environmental Quality
Office: [phone] 1 Cell: [phone]
samir.dumpor(o)ncdenr.gov
943 Washington Square Mall
Washington, NC 27889

G�parirn•ns•l malty
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From: McElveen, Neal <[e-mail]>
Sent: Wednesday, December 21, 2022 11:02 AM
To: Dumpor, Samir <[e-mail]>
Cc: Rona Durborow <[e-mail]>; Dwayne Bailey <dwayneb@meta llix.com>
Subject: [External] Metallix- Greenville, NC - Tier 3 Notification for NPDES Permit No NCS000583
Importance: High
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Dear Mr. Dumpor:
On behalf of Metallix and as required by Section B: Analytical Monitoring Requirements/Tier 3 Requirements of
Individual Industrial Permit No NCS000583, this email serves as notice that the facility has exceeded the permitted
benchmarks for four consecutive samples. Attached you will find a table summarizing the quantitative monitoring
results at each outfall. Metallix has been proactive in evaluating sources and possible options for BMPs to address the
metals identified. The latest round of stormwater samples was also evaluated for suspended versus dissolved metals so
that a treatment evaluation can be completed. Results indicated the presence of both dissolved and suspended metals
with dissolved levels ranging from 25% to approximately four times less than the suspended metals results (lab report
attached). Below are proposed BMPs and requests for changes associated with the facility's permit:
1) BMPs currently under evaluation and planning for implementation are as follows:
• Based on a review of facility activities and identification of potential sources (tracking of materials outside via
forklifts and deposition of particulate emissions on the roof areas), Metallix plans to install filter media in downspouts
and in drop inlets.
• Design and install an engineered detention basin/wetland at OF- 3 to aide in removal of metals (design and
implementation anticipated in spring 2023). The basin/wetland will likely require media to remove suspended and
dissolved metals.
• Intensify housekeeping/cleaning to limit tracking of dust and particulate by forklift and human activity outside the
building.
2) Request an increase of the benchmark limits for metals due to the potential that any treatment/BMP could still
result in effluent concentrations above the levels currently listed in the permit and because some metal benchmarks
are below the laboratory method detection limit (silver MDL 1.7 ppb compared to benchmark of 0.3 ppb).
3) Metallix is requesting/petitioning for Representative Outfall Status and sampling of Outfall OF-3 only. The request
is based on the following:
• The drainage area for outfall OF-3 is twice as large as OFs 1 and 2 (see attached figure).
• The analytical data supports that the materials identified in samples are generally similar at the outfalls.
• Outfalls 1 and 2 located along the eastern property line are immediately adjacent to an off -site ditch that affects
the facility's capability to obtain representative samples. The off -site ditch/drainage feature reaches capacity quickly

during storm events which results in backflow into the outfall pipes. Many times the back-up occurs within the first 15
minutes of a storm event.
4) Following implementation of BMPs to address the potential sources of metals in stormwater effluent, return
stormwater sampling to semi-annual basis as originally listed in the facility's permit.
Metallix and Terracon appreciate your time and consideration of the requests presented above. Please contact our team
to discuss as needed. We are also available for in person discussions if you would prefer. Please contact our team to
schedule a meeting/discussion. Contact information is as follows:
Neal McElveen (Terracon) — [e-mail]
Dwayne Bailey (Metallix) — [e-mail]
Rona Durborow (Metallix) — [e-mail]
M. Neal McElveen, P.E.
Licensed in the States of AL, MT, NC, ND, SC, TX & VA
Principal/Sr. Environmental Consultant
...ram
OFerracon
2701 Westport Road I Charlotte, NC 28208
D [phone] 1 F [phone] 1 M [phone]
neal.mcelveen(a)terracon.com I Terracon.com
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