NCG030326_Tier Relief Approval_20190923

ROY COOPER
Governer
MICHAEL S. REGAN
Srcretary
S. DANIEL SMITH
Daet tar
W&WIARCO Steel
Attn: Roger Breeden
341 Corbett Road
Nashville, NC 27856
NORTH CAROLINA
Environmental Quality
September 23, 2019
SUBJECT: NPDES Stormwater Permit: Request for Regulatory Relief
W&WIAFCO Steel
General Permit No: NCG030000; COC No: NCG030326
Nash County
Mr. Breeden:
In response to your request for Regulatory Relief, NCDENR-Land Quality Section staff
reviewed provided sample reports, site maps and discussed site characteristics with
Tyler Miles and Derr Leonhardt the environmental consultants with Leonhardt
Environmental & Roger Breeden with W&WIAFCO Steel.
Monthly monitoring has been triggered by numerous exceedances of the Zinc
benchmarks at your facility. Please keep in mind that benchmark exceedances are NOT
limit violations or violations of permit conditions; however, you are obligated to follow the
tiered response actions outlined in your permit. W&WIAFCO Steel has been following
the tiered response actions for many consecutive years and therefore is in compliance
with the permit.
Based on the number of additional samples taken around the site, both soil and water,
and the high level of Zinc in all the samples regardless of whether the activities at your
facility drains in that direction, we are granting regulatory relief in the form of a collapsed
Tier 2 — Tier 3 response. Upon receipt of this letter, W&WIAFCO Steel may resume the
permit specified semiannual analytical monitoring for the remainder of your current
permit. Your current permit is set to expire on May 31, 2021. This decision only applies
to the Zinc benchmarks. A benchmark exceedance of any other parameter listed in
your permit will trigger tiered response actions as described in the general permit.
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You must notify this office in writing, within five business days, if you become aware of
any significant source of Zinc at your facility that has the potential to be exposed to
stormwater. The relief granted in this letter is contingent upon the current industrial
practices at W&WIAFCO Steel. If industrial practices change and Zinc does become a
significant stormwater exposure risk then this office reserves the right to withdraw this
decision and reinstate the permit specified tiered response or other actions that may be
warranted by the new set of circumstances.
Please retain and append this letter to your Stormwater Pollution Prevention Plan
(SPPP) or permit. If you have any questions or comments concerning this letter, please
contact Thad Valentine or me at [phone].
Sincerely, >�
William H. Denton, IV, PE
Regional Engineer-RRO