Please refer to the Summary of Findings section of the attached inspection reports and provide a written response for each violation that was noted.

Transcription

1 March 6, 2018 Lenore E. Trammell, Chief Compliance Officer Big River Steel, LLC P.O. Box 707 Osceola, AR RE: Big River Steel Inspections AFIN: Permit No.: AR & ARR Dear Ms. Trammell: On July 18 and 19, 2017, I performed Compliance Sampling and Industrial Stormwater Inspections of the above referenced facility in accordance with the provisions of the Federal Clean Water Act, the Arkansas Water and Air Pollution Control Act, and the regulations promulgated thereunder. Copies of the inspection reports are enclosed for your records. Please refer to the Summary of Findings section of the attached inspection reports and provide a written response for each violation that was noted. This response should be mailed to the attention of the Water Division Inspection Branch at the address at the bottom of this letter or e- mailed to Water-Inspection-Report@adeq.state.ar.us. This response should contain documentation describing the course of action taken to correct each item noted. This corrective action should be completed as soon as possible, and the written response with all necessary documentation (i.e. photos) is due by April 1, If I can be of any assistance, please contact me at walker@adeq.state.ar.us or ext.-12. Sincerely, Brent L. Walker District 3 Field Inspector Water Division Page 1 of 18

2 FACILITY INFORMATION NAME: Big River Steel LOCATION: 2027 E. State Hwy. 198 CITY: Osceola Inspection Report: Big River Steel, AFIN: , Permit #: AR RESPONSIBLE OFFICIAL NAME: / TITLE Lenore E. Trammell / Chief Compliance Officer COMPANY: Big River Steel, LLC MAILING ADDRESS: P.O. Box 707 CITY, STATE, ZIP: Osceola AR PHONE & EXT: / FAX: / WATER DIVISION INSPECTION REPORT AFIN: PERMIT #: AR DATE: 7/18/2017 COUNTY: 47 Mississippi PDS #: MEDIA: WN GPS LAT: LONG: LOCATION: Entrance FACILITY TYPE: 2 - Industrial FACILITY EVALUATION RATING: 1 - Unsatisfactory INSPECTION INFORMATION INSPECTOR ID#: S - State DATE(S): ENTRY TIME: EXIT TIME: 7/18/ :10 15:35 7/19/ :20 12:30 FAYETTEVILLE SHALE RELATED: N INSPECTION TYPE: Compliance Sampling PERMIT EFFECTIVE DATE: 7/1/2016 PERMIT EXPIRATION DATE: 6/30/2021 FAYETTEVILLE SHALE VIOLATIONS: N INSPECTION PARTICIPANTS NAME/TITLE/PHONE/FAX/ /ETC.: Michele Vachon/Environmental Manager Joe Hall/Wastewater Treatment Superintendent Kevin Watson/Hot Mill Water Treatment Steve Beck/HSE Manager TMS ltrammell@bigriversteel.com CONTACTED DURING INSPECTION: Yes AREA EVALUATIONS (S=Satisfactory, M=Marginal, U=Unsatisfactory, N=Not Applicable/Evaluated) S PERMIT U FLOW MEASUREMENT N STORMWATER U RECORDS/REPORTS S LABORATORY U FACILITY SITE REVIEW U OPERATION & MAINTENANCE S EFFLUENT/RECEIVING WATER U SELF-MONITORING PROGRAM S SAMPLING S SLUDGE HANDLING/DISPOSAL N PRETREATMENT N OTHER: SUMMARY OF FINDINGS The following violations were noted at the time of the inspection: 1. The flow meter for Outfall 001 is located upstream of the thickener, aeration and sand filter units. This violates Part I, Section A. of the permit which states: Samples shall be taken after sand filtration and prior to the pipeline to Outfall 001. Flow measurements must be taken after the final treatment unit as return flows from the thickener and filter backwash will result in inaccurate flow measurements. 2. Improper Operation and Maintenance; this violates Part III, Section B, Item 1.A. of the permit. a. The vegetation around the pump control structure at the stormwater pond (Outfall 002) was overgrown and in need of mowing and/or other management practices to allow for proper inspection and/or maintenance (Photo 1). Furthermore, a plan should be developed for managing vegetation in and around the stormwater pond since varying water levels will likely allow for the growth of vegetation within the pond. (Overgrown vegetation around the pump control structure was removed by facility personnel during the course of the inspection to allow for access.) b. Main and Cold Mill WWTP (Wastewater Treatment Plant) i. The skimmer/foam collector on the thickener was in need of repair the rubber brush (flap) on the skimmer/foam collector had been replaced with part of a used truck tire and did not appear to be operating efficiently (Photos 2-4). ii. *There was windblown mist and/or minor leakage from the cooling tower to the surrounding concrete (Photos 5-6). iii. *Housekeeping practices need to be improved around the sludge dumpster under the filter press to prevent sludge from being spilled and/or tracked onto the surface of the Inspection Report Page 2 of 18

3 Inspection Report: Big River Steel, AFIN: , Permit #: AR ground (Photo 7). (Minor improvements were made during the course of the inspection and additional information received on 9/7/2017 stated that a concrete berm had been installed and additional corrective action was planned). c. Hot Mill WWTP i. *There was a visibly contaminated (oil/grease) bucket sitting on the wall of the secondary containment at the belt skimmer. There was oil/grease and visible staining on the concrete wall and outside of the secondary containment (Photo 8). ii. *There was water on the concrete around the cooling water pumps indicative of a leak (Photos 9-10). iii. *There was water on the concrete around the ring filters indicative of a leak (Photo 11). iv. *There was significant splash out from the discharge points of the influent lines (Photos 12-14). v. *Housekeeping practices need to be improved around the sludge dumpster under the filter press to prevent sludge from being spilled and/or tracked onto the surface of the ground (Photos 15-16). (Minor improvements were made during the course of the inspection and additional information received on 9/7/2017 stated that a concrete berm had been installed and additional corrective action was planned). d. Laminar WWTP i. *There was oil on the surface of the ground around the roll shop turnings dumpster located near the laminar plant (Photos 17-19). ii. There was a small amount of grass growing in the thickener of laminar plant (Photo 20). iii. There was miscellaneous trash in sludge dumpster of laminar plant. While this is not necessarily a violation of the permit if this sludge is landfilled, it may prevent recycling and/or beneficial reuse of the sludge. e. Continuous Caster WWTP i. * Housekeeping practices need to be improved around the sludge dumpster under the filter press to prevent sludge from being spilled and/or tracked onto the surface of the ground. (Minor improvements were made during the course of the inspection and additional information received on 9/7/2017 stated that a concrete berm had been installed and additional corrective action was planned). ii. *Runoff and/or tracking from the castor scale pit and dry scale dumpsters needs to be managed to prevent the comingling and ultimate discharge of process wastes with stormwater (Photos 21-22). An received from Michele Vachon on September 7, 2017, indicated that preliminary and/or permanent corrective action had been taken for most of the above items. The written response to this inspection should contain specific details of corrective action that has been completed as well as any planned future action. (*Indicates items were also noted in the Industrial Stormwater Inspection Report ARR001578) 3. The following DMR reporting errors were noted during the inspection. Corrected DMRs have since been submitted and no further action is required. a. Flow from Outfall 001 for the January 2017 Monthly Average and Daily Max were mistakenly reported as Gallons per Day instead of Million Gallons per Day. b. Flow from Outfall 002 for the February 2017 Monthly Average was mistakenly reported as Gallons per Day instead of Million Gallons per Day. c. Loading values for TSS, Cr, Pb, Zn and Oil & Grease for Outfall 001 were incorrectly reported for January and February d. Contract lab ph values were being reported on the DMRs. Since these samples did not meet the instantaneous analysis requirements (15 minute maximum holding time) they were not valid for reporting purposes. The instantaneous ph measurements collected by facility personnel must Inspection Report Page 3 of 18

4 Inspection Report: Big River Steel, AFIN: , Permit #: AR be used instead. e. Discrepancies in the species listed in the June 2017 WET Testing reports were corrected. 4. During the course of the inspection, samples were collected from Outfall 001 the full ADEQ Laboratory Report is attached. All parameters required by the NPDES permit were within permit limits. As part of the analysis of volatile organics, both Acetone and Bromoform were detected in the effluent grab sample at a concentration of 14.4 µg/l and Dibromochloromethane at a concentration of 2.41 µg/l. While specific limits are not included in the permit, please identify any potential sources of the pollutants to determine if further review is necessary. GENERAL COMMENTS While not a requirement, it was suggested that the composite sampling point be moved from the outfall structure on the river bank to the location where grab samples are obtained after the final treatment unit within the plant. This will prevent high river levels from interfering with sample collection and prevent accidental comingling of flows between outfalls 001 and 002. The vast majority of the treatment plants, chemical storage area and dosing equipment are uncovered and otherwise unprotected from the weather. This will likely pose problems during extreme cold weather resulting in inadequate treatment and/or overflows from the treatment system(s). The treatment plants should be evaluated and proactive measures taken to allow for uninterrupted and efficient operation during all possible weather conditions. The Melt Shop WWTP was not yet in operation at the time of the inspection. ADEQ Office of Water Quality staff, Jason Bolenbaugh, Compliance Branch Manager and Sarah Frasher, Inspector also participated in this inspection. INSPECTOR S SIGNATURE: Brent L. Walker DATE: 2/27/2018 SUPERVISOR S SIGNATURE: Jason Bolenbaugh DATE: 3/5/2018 Inspection Report Page 4 of 18

5 Inspection Report: Big River Steel, AFIN: , Permit #: AR SECTION A: PERMIT VERIFICATION PERMIT SATISFACTORILY ADDRESSES OBSERVATIONS S M U NA NE DETAILS: 1. CORRECT NAME AND MAILING ADDRESS OF PERMITTEE: Y N NA NE 2. NOTIFICATION GIVEN TO EPA/STATE OF NEW DIFFERENT OR INCREASED DISCHARGES: Y N NA NE 3. NUMBER AND LOCATION OF DISCHARGE POINTS AS DESCRIBED IN PERMIT: Y N NA NE 4. ALL DISCHARGES ARE PERMITTED: Y N NA NE SECTION B: RECORDKEEPING AND REPORTING EVALUATION RECORDS AND REPORTS MAINTAINED AS REQUIRED BY PERMIT S M U NA NE DETAILS: Multiple DMR errors corrected immediately following inspection 1. ANALYTICAL RESULTS CONSISTENT WITH DATA REPORTED ON DMRS: Y N NA NE 2. SAMPLING AND ANALYSES DATA ADEQUATE AND INCLUDE: S M U NA NE a. DATES AND TIME(S) OF SAMPLING: Y N NA NE b. EXACT LOCATION(S) OF SAMPLING: Y N NA NE c. NAME OF INDIVIDUAL PERFORMING SAMPLING: Y N NA NE d. ANALYTICAL METHODS AND TECHNIQUES: Y N NA NE e. RESULTS OF CALIBRATIONS: Y N NA NE f. RESULTS OF ANALYSES: Y N NA NE g. DATES AND TIMES OF ANALYSES: Y N NA NE h. NAME OF PERSON(S) PERFORMING ANALYSES: Y N NA NE 3. LABORATORY EQUIPMENT CALIBRATION AND MAINTENANCE RECORDS ADEQUATE: S M U NA NE 4. PLANT RECORDS INCLUDE SCHEDULES, DATES OF EQUIPMENT MAINTENANCE AND REPAIR: S M U NA NE 5. EFFLUENT LOADINGS CALCULATED USING DAILY EFFLUENT FLOW AND DAILY ANALYTICAL DATA: Y N NA NE SECTION C: OPERATIONS AND MAINTENANCE TREATMENT FACILITY PROPERLY OPERATED AND MAINTAINED S M U NA NE DETAILS: 1. TREATMENT UNITS PROPERLY OPERATED: S M U NA NE 2. TREATMENT UNITS PROPERLY MAINTAINED: Multiple items, see Summary of Findings Section for Details S M U NA NE 3. STANDBY POWER OR OTHER EQUIVALENT PROVIDED: S M U NA NE 4. ADEQUATE ALARM SYSTEM FOR POWER OR EQUIPMENT FAILURES AVAILABLE: S M U NA NE 5. ALL NEEDED TREATMENT UNITS IN SERVICE: S M U NA NE 6. ADEQUATE NUMBER OF QUALIFIED OPERATORS PROVIDED: S M U NA NE 7. SPARE PARTS AND SUPPLIES INVENTORY MAINTAINED: S M U NA NE 8. OPERATION AND MAINTENANCE MANUAL AVAILABLE: Y N NA NE 9. STANDARD OPERATING PROCEDURES AND SCHEDULES ESTABLISHED: Y N NA NE 10. PROCEDURES FOR EMERGENCY TREATMENT CONTROL ESTABLISHED: Y N NA NE 11. HAVE BYPASSES/OVERFLOWS OCCURRED AT THE PLANT OR IN THE COLLECTION SYSTEM IN THE LAST YEAR: Y N NA NE 12. IF SO, HAS THE REGULATORY AGENCY BEEN NOTIFIED: Y N NA NE 13. HAS CORRECTIVE ACTION BEEN TAKEN TO PREVENT ADDITIONAL BYPASSES/OVERFLOWS: Y N NA NE 14. HAVE ANY HYDRAULIC OVERLOADS OCCURRED AT THE TREATMENT PLANT: Y N NA NE 15. IF SO, DID PERMIT VIOLATIONS OCCUR AS A RESULT: Y N NA NE Inspection Report Page 5 of 18

6 Inspection Report: Big River Steel, AFIN: , Permit #: AR SECTION D: SAMPLING PERMITTEE SAMPLING MEETS PERMIT REQUIREMENTS S M U NA NE DETAILS: 1. SAMPLES TAKEN AT SITE(S) SPECIFIED IN PERMIT: Y N NA NE 2. LOCATIONS ADEQUATE FOR REPRESENTATIVE SAMPLES: Y N NA NE 3. FLOW PROPORTIONED SAMPLES OBTAINED WHEN REQUIRED BY PERMIT: Y N NA NE 4. SAMPLING AND ANALYSES COMPLETED ON PARAMETERS SPECIFIED IN PERMIT: Y N NA NE 5. SAMPLING AND ANALYSES PERFORMED AT FREQUENCY SPECIFIED IN PERMIT: Y N NA NE 6. SAMPLE COLLECTION PROCEDURES ADEQUATE: Y N NA NE a. SAMPLES REFRIGERATED DURING COMPOSITING: Y N NA NE b. PROPER PRESERVATION TECHNIQUES USED: Y N NA NE c. CONTAINERS AND SAMPLE HOLDING TIMES CONFORM TO 40 CFR 136: Y N NA NE 7. IF MONITORING IS PERFORMED MORE OFTEN THAN REQUIRED ARE RESULTS REPORTED ON THE DMR: Y N NA NE SECTION E: FLOW MEASUREMENT PERMITTEE FLOW MEASUREMENT MEETS PERMIT REQUIREMENTS S M U NA NE DETAILS: 001 Flow measurement upstream of final treatment unit 1. PRIMARY FLOW MEASUREMENT DEVICE PROPERLY INSTALLED AND MAINTAINED: TYPE OF DEVICE: Y N NA NE 2. FLOW MEASURED AT EACH OUTFALL AS REQUIRED: Y N NA NE 3. SECONDARY INSTRUMENTS (TOTALIZERS, RECORDERS, ETC.) PROPERLY OPERATED AND MAINTAINED: Y N NA NE 4. CALIBRATION FREQUENCY ADEQUATE: Y N NA NE 5. RECORDS MAINTAINED OF CALIBRATION PROCEDURES: Y N NA NE 6. CALIBRATION CHECKS DONE TO ASSURE CONTINUED COMPLIANCE: Y N NA NE 7. FLOW ENTERING DEVICE WELL DISTRIBUTED ACROSS THE CHANNEL AND FREE OF TURBULENCE: Y N NA NE 8. FLOW MEASUREMENT EQUIPMENT ADEQUATE TO HANDLE EXPECTED RANGE OF FLOW RATES: Y N NA NE 9. HEAD MEASURED AT PROPER LOCATION: Y N NA NE SECTION F: LABORATORY PERMITTEE LABORATORY PROCEDURES MEET PERMIT REQUIREMENTS S M U NA NE DETAILS: 1. EPA APPROVED ANALYTICAL PROCEDURES USED (40 CFR FOR LIQUIDS, 503.8(B) FOR SLUDGES) : Y N NA NE 2. IF ALTERNATIVE ANALYTICAL PROCEDURES ARE USED, PROPER APPROVAL HAS BEEN OBTAINED: Y N NA NE 3. SATISFACTORY CALIBRATION AND MAINTENANCE OF INSTRUMENTS AND EQUIPMENT: Y N NA NE 4. QUALITY CONTROL PROCEDURES ADEQUATE: Y N NA NE 5. DUPLICATE SAMPLES ARE ANALYZED >10% OF THE TIME: Y N NA NE 6. SPIKED SAMPLES ARE ANALYZED >10% OF THE TIME: Y N NA NE 7. COMMERCIAL LABORATORY USED: Y N NA NE a. LAB NAME: Waypoint Analytical b. LAB ADDRESS: 2790 Whitten Rd., Memphis, TN c. PARAMETERS PERFORMED: TSS, O&G, Metals, Volatiles, WET 8. BIOMONITORING PROCEDURES ADEQUATE: Y N NA NE a. PROPER ORGANISMS USED: Y N NA NE b. PROPER DILUTION SERIES FOLLOWED: Y N NA NE c. PROPER TEST METHODS AND DURATION: Y N NA NE d. RETESTS AND/OR TRE PERFORMED AS REQUIRED: Y N NA NE Inspection Report Page 6 of 18

7 Inspection Report: Big River Steel, AFIN: , Permit #: AR SECTION G: EFFLUENT/RECEIVING WATERS OBSERVATIONS BASED ON VISUAL OBSERVATIONS ONLY S M U NA NE DETAILS: Observation made at discharge to receiving stream OUTFALL #: OIL SHEEN GREASE TURBIDITY VISIBLE FOAM FLOATING SOLIDS COLOR OTHER 001 None None Very Low None None Clear N/A N/A N/A N/A N/A N/A No Discharge SECTION H: SLUDGE DISPOSAL SLUDGE DISPOSAL MEETS PERMIT REQUIREMENTS S M U NA NE DETAILS: Sludge dewatered and disposed of at landfill and/or recycled as marketable 1. SLUDGE MANAGEMENT ADEQUATE TO MAINTAIN EFFLUENT QUALITY: S M U NA NE 2. SLUDGE RECORDS MAINTAINED AS REQUIRED BY 40 CFR 503: S M U NA NE 3. FOR LAND APPLIED SLUDGE, TYPE OF LAND APPLIED TO: (E.G., FOREST, AGRICULTURAL, PUBLIC CONTACT SITE): N/A SECTION I: SAMPLING INSPECTION PROCEDURES SAMPLE RESULTS WITHIN PERMIT REQUIREMENTS DETAILS: Samples collected from 001 (No discharge from 002 at time of inspection) S M U NA NE 1. SAMPLES OBTAINED THIS INSPECTION: Y N NA NE 2. TYPE OF SAMPLE: GRAB: O&G, Volatiles, ph COMPOSITE: TSS, Metals METHOD: Automated sampler FREQUENCY: minute intervals for 20 hours (12,000 ml total collected) 3. SAMPLES PRESERVED: Samples were not iced during collection Y N NA NE 4. FLOW PROPORTIONED SAMPLES OBTAINED: Y N NA NE 5. SAMPLE OBTAINED FROM FACILITY'S SAMPLING DEVICE: Y N NA NE 6. SAMPLE REPRESENTATIVE OF VOLUME AND NATURE OF DISCHARGE: Y N NA NE 7. SAMPLE SPLIT WITH PERMITTEE: Y N NA NE 8. CHAIN-OF-CUSTODY PROCEDURES EMPLOYED: Y N NA NE 9. SAMPLES COLLECTED IN ACCORDANCE WITH PERMIT: Y N NA NE SECTION J: STORM WATER POLLUTION PREVENTION PLAN STORM WATER MANAGEMENT MEETS PERMIT REQUIREMENTS S M U NA NE DETAILS: Stormwater is covered under the Arkansas IGP ARR see separate inspection report. 1. SWPPP UPDATED AS NEEDED: DATE OF LAST UPDATE: Y N NA NE 2. SITE MAP INCLUDING ALL DISCHARGES AND SURFACE WATERS: Y N NA NE 3. POLLUTION PREVENTION TEAM IDENTIFIED: Y N NA NE 4. POLLUTION PREVENTION TEAM PROPERLY TRAINED: Y N NA NE 5. LIST OF POTENTIAL POLLUTANT SOURCES: Y N NA NE 6. LIST OF POTENTIAL SOURCES AND PAST SPILLS AND LEAKS: Y N NA NE 7. ALL NON-STORM WATER DISCHARGES ARE AUTHORIZED: Y N NA NE 8. LIST OF STRUCTURAL BMPS: Y N NA NE 9. LIST OF NON-STRUCTURAL BMPS: Y N NA NE 10. BMPS PROPERLY OPERATED AND MAINTAINED: Y N NA NE 11. INSPECTIONS CONDUCTED AS REQUIRED: Y N NA NE Inspection Report Page 7 of 18

8 Inspection Report: Big River Steel, AFIN: , Permit #: AR Water Division Photographic Evidence Sheet Location: Big River Steel Photographer: Brent Walker Date: 7/18/2017 Time: 1055 Witness: Jason Bolenbaugh & Sarah Frasher Photo #: 1 Description: Overgrown vegetation around Outfall 002 pump control structure. Photographer: Brent Walker Date: 7/18/2017 Time: 1134 Witness: Jason Bolenbaugh & Sarah Frasher Photo #: 2 Description: Skimmer/foam collector on thickener at Main WWTP. Note rubber brush replaced with part of a used truck tire. Inspection Report Page 8 of 18

9 Inspection Report: Big River Steel, AFIN: , Permit #: AR Water Division Photographic Evidence Sheet Location: Big River Steel Photographer: Jason Bolenbaugh Date: 7/18/2017 Time: 1130 Witness: Brent Walker & Sarah Frasher Photo #: 3 Description: Skimmer/foam collector on thickener at Main WWTP. Note rubber brush replaced with part of a used truck tire. Photographer: Jason Bolenbaugh Date: 7/18/2017 Time: 1134 Witness: Brent Walker & Sarah Frasher Photo #: 4 Description: Skimmer/foam collector on thickener at Main WWTP. Note rubber brush replaced with part of a used truck tire. Inspection Report Page 9 of 18

10 Inspection Report: Big River Steel, AFIN: , Permit #: AR Water Division Photographic Evidence Sheet Location: Big River Steel Photographer: Brent Walker Date: 7/18/2017 Time: 1122 Witness: Jason Bolenbaugh & Sarah Frasher Photo #: 5 Description: Windblown mist and/or minor leakage from the cooling tower to the surrounding concrete at the Main WWTP. Photographer: Brent Walker Date: 7/18/2017 Time: 1124 Witness: Jason Bolenbaugh & Sarah Frasher Photo #: 6 Description: Windblown mist and/or minor leakage from the cooling tower to the surrounding concrete at the Main WWTP. Inspection Report Page 10 of 18

11 Inspection Report: Big River Steel, AFIN: , Permit #: AR Water Division Photographic Evidence Sheet Location: Big River Steel Photographer: Brent Walker Date: 7/18/2017 Time: 1138 Witness: Jason Bolenbaugh & Sarah Frasher Photo #: 7 Description: Poor housekeeping around sludge dumpster at Main WWTP. Photographer: Brent Walker Date: 7/18/2017 Time: 1314 Witness: Jason Bolenbaugh & Sarah Frasher Photo #: 8 Contaminated (oil/grease) bucket sitting on the wall of the secondary containment Description: at the belt skimmer for the Hot Mill WWTP. Note oil/grease and visible staining on the concrete wall and outside of the secondary containment Inspection Report Page 11 of 18

12 Inspection Report: Big River Steel, AFIN: , Permit #: AR Water Division Photographic Evidence Sheet Location: Big River Steel Photographer: Brent Walker Date: 7/18/2017 Time: 1318 Witness: Jason Bolenbaugh & Sarah Frasher Photo #: 9 Description: Water on concrete around cooling water pumps at Hot Mill WWTP indicative of leak. Photographer: Jason Bolenbaugh Date: 7/18/2017 Time: 1316 Witness: Brent Walker & Sarah Frasher Photo #: 10 Description: Water on concrete around cooling water pumps at Hot Mill WWTP indicative of leak. Inspection Report Page 12 of 18

13 Inspection Report: Big River Steel, AFIN: , Permit #: AR Water Division Photographic Evidence Sheet Location: Big River Steel Photographer: Brent Walker Date: 7/18/2017 Time: 1315 Witness: Jason Bolenbaugh & Sarah Frasher Photo #: 11 Description: Water around ring filters at Hot Mill WWTP indicative of a leak. Photographer: Brent Walker Date: 7/18/2017 Time: 1337 Witness: Jason Bolenbaugh & Sarah Frasher Photo #: 12 Description: Splash out from influent lines to Hot Mill WWTP. Inspection Report Page 13 of 18

14 Inspection Report: Big River Steel, AFIN: , Permit #: AR Water Division Photographic Evidence Sheet Location: Big River Steel Photographer: Brent Walker Date: 7/18/2017 Time: 1336 Witness: Jason Bolenbaugh & Sarah Frasher Photo #: 13 Description: Splash out from influent lines to Hot Mill WWTP. Photographer: Brent Walker Date: 7/18/2017 Time: 1335 Witness: Jason Bolenbaugh & Sarah Frasher Photo #: 14 Description: Splash out from influent lines to Hot Mill WWTP. Inspection Report Page 14 of 18

15 Inspection Report: Big River Steel, AFIN: , Permit #: AR Water Division Photographic Evidence Sheet Location: Big River Steel Photographer: Brent Walker Date: 7/18/2017 Time: 1328 Witness: Jason Bolenbaugh & Sarah Frasher Photo #: 15 Description: Tracking/spillage from the sludge dumpster at the Hot Mill WWTP. Photographer: Brent Walker Date: 7/18/2017 Time: 1329 Witness: Jason Bolenbaugh & Sarah Frasher Photo #: 16 Description: Tracking/spillage from the sludge dumpster at the Hot Mill WWTP. Inspection Report Page 15 of 18

16 Inspection Report: Big River Steel, AFIN: , Permit #: AR Water Division Photographic Evidence Sheet Location: Big River Steel Photographer: Brent Walker Date: 7/18/2017 Time: 1356 Witness: Jason Bolenbaugh & Sarah Frasher Photo #: 17 Description: Oil on surface of the ground at the roll shop turnings dumpster. Photographer: Brent Walker Date: 7/18/2017 Time: 1356 Witness: Jason Bolenbaugh & Sarah Frasher Photo #: 18 Description: Oil on surface of the ground at the roll shop turnings dumpster. Inspection Report Page 16 of 18

17 Inspection Report: Big River Steel, AFIN: , Permit #: AR Water Division Photographic Evidence Sheet Location: Big River Steel Photographer: Brent Walker Date: 7/18/2017 Time: 1359 Witness: Jason Bolenbaugh & Sarah Frasher Photo #: 19 Description: Oil stain on surface of the ground at the roll shop turnings dumpster. Photographer: Brent Walker Date: 7/18/2017 Time: 1352 Witness: Jason Bolenbaugh & Sarah Frasher Photo #: 20 Description: Grass growing along weir in thickener of Laminar WWTP. Inspection Report Page 17 of 18

18 Inspection Report: Big River Steel, AFIN: , Permit #: AR Water Division Photographic Evidence Sheet Location: Big River Steel Photographer: Brent Walker Date: 7/19/2017 Time: 1109 Witness: Jason Bolenbaugh & Sarah Frasher Photo #: 21 Description: Continuous caster scale pit containment area with track-out at bottom right. Photographer: Brent Walker Date: 7/18/2017 Time: 1406 Witness: Jason Bolenbaugh & Sarah Frasher Photo #: 22 Description: Continuous caster dry scale dumpsters with residue/staining present on ground. Inspection Report Page 18 of 18

19 From: To: Cc: Subject: Date: Attachments: Michele Vachon Water-Inspection-Report Walker, Brent FW: BRS ADEQ Water Response ( ) Friday, March 30, :45:15 PM BRS ADEQ Water Sampling Inspection Response ( ).pdf Mr. Walker, I corrected the address to the water inspection report general mailbox. Thank you, Michele From: Michele Vachon Sent: Friday, March 30, :27 PM To: 'walker@adeq.state.ar.us' <walker@adeq.state.ar.us> Cc: Lenore Trammell <ltrammell@bigriversteel.com>; Booher, Martin T. <mbooher@bakerlaw.com>; 'water-inspection-report@adeq.ar.us' <water-inspection-report@adeq.ar.us>; Robert Carter <Rcarter@bigriversteel.com> Subject: BRS ADEQ Water Response ( ) Mr. Walker, Please see attached response to ADEQ s Compliance Sampling and Industrial Stormwater Inspection report. If you have any questions or need further information please contact me at (870) or mvachon@bigriversteel.com Thank you. Best, Michele

20 March 30, 2018 VIA Brent L. Walker District 3 Field Inspector Office of Water Quality - Jonesboro Field Office Arkansas Department of Environmental Quality 2212 Fowler Avenue, Suite B Jonesboro, AR RE: Water Division Inspection Report Big River Steel LLC, Osceola, AR AFIN: AR & ARR Dear Mr. Walker, This letter is in response to the Arkansas Department of Environmental Quality s ( ADEQ ) Water Division Inspection Report, dated March 6, 2018 (the Report ) related to the compliance sampling and industrial stormwater inspection of Big River Steel LLC s ( BRS ) facility between July 19, 2017 and July 20, As noted in the Report, BRS addressed many of the inspection items as noted in BRS letter dated September 7, 2017 responding to the ADEQ s preliminary inspection findings (attached hereto). Enclosed is an update on the efforts taken in response to the preliminary findings and to address compliance matters from the Report. 1. The flow meter for Outfall 001 is located upstream of the thickener, aeration and sand filter units. This violates Part I, Section A. of the permit which states: Samples shall be taken after sand filtration and prior to the pipeline to Outfall 001. Flow measurements must be taken after the final treatment unit as return flows from the thickener and filter backwash will result in inaccurate flow measurements. BRS Response: The BRS wastewater treatment system has a flow meter after the sand filter units and prior to the pipeline to Outfall 001 (Photo 1). This flowmeter has been operational since wastewater treatment began. At the time of the inspection, the flowmeter was not capable of totalizing discharge flow. In response, BRS has upgraded this flow meter so that it can perform instantaneous flow measurements as well as totalizing flow measurements. BRS completed these upgrades on March 23, In addition, BRS now collects samples for Outfall 001 after sand filtration and prior to the pipeline to Outfall 001. (Photo 2). The flow meter observed upstream of the thickener, aeration and sand filter units is used to verify proper operation of the wastewater treatment equipment, not to demonstrate compliance State Hwy 198 Osceola, AR

21 March 30, 2018 Page 2 of 6 2. Improper Operation and Maintenance; this violates Part III, Section B, Item 1.A. of the permit. a. The vegetation around the pump control structure at the stormwater pond (Outfall 002) was overgrown and in need of mowing and/or other management practices to allow for proper inspection and/or maintenance (Photo 1). Furthermore, a plan should be developed for managing vegetation in and around the stormwater pond since varying water levels will likely allow for the growth of vegetation within the pond. (Overgrown vegetation around the pump control structure was removed by facility personnel during the course of the inspection to allow for access.) BRS Response: BRS retained a consultant on July 31, 2017 to recommend vegetation control practices for the area in and around the process water pond and outfall structure. BRS now implements a number of practices recommended by the consultant. In addition, the grounds around the pond and pump control structure are included in BRS routine grounds/maintenance activities (Photos 3 and 4). BRS conducts periodic vegetation evaluations to identify any new areas in or around the outfall structures that need to be added to its routine grounds/maintenance activities. b. Main and Cold Mill WWTP (Waste Water Treatment Plant) i. The skimmer/foam collector on the thickener was in need of repair the rubber brush (flap) on the skimmer/foam collector had been replaced with part of a used truck tire and did not appear to be operating efficiently (Photos 2-4). BRS Response: Please see BRS response dated September 7, 2017 (Recommendation #6). As noted, BRS already had ordered a replacement skimmer, which was installed on July 19, ii. *There was windblown mist and/or minor leakage from the cooling tower to the surrounding concrete (Photos 5-6). BRS Response: Please see BRS response dated September 7, 2017 (Recommendation #7). As noted, BRS took immediate steps on July 21, 2017 to implement operational changes to cooling tower systems as part of routine daily and monthly preventative maintenance programs. As a result, mist drift from the cooling towers has been minimized and, if splash out conditions related to mist from the cooling towers is observed during routine inspections, corrective action is taken. iii. *Housekeeping practices need to be improved around the sludge dumpster under the filter press to prevent sludge from being spilled and/or tracked onto the surface of the ground (Photo 7). (Minor improvements were made during the course of the inspection and additional information received on 9/7/2017) state that a concrete berm had been installed and additional corrective action was planned). BRS Response: Please see BRS response dated September 7, 2017 (Recommendation #3). As noted, BRS took immediate action on July 19 and 20, 2017 to improve housekeeping in and around the sludge dumpsters (e.g. sweeping, pressure washing concrete pads, etc.). In addition, the construction of concrete berms at the opening of each filter press storage shelter was completed on August 25, BRS also completed the installation of poly-curtains to enclose the sludge dumpsters on November 1, 2017 (Photos 5, 6and 7) State Hwy 198 Osceola, AR

22 March 30, 2018 Page 3 of 6 c. Hot Mill WWTP i. *There was a visibly contaminated (oil/grease) bucket sitting on the wall of the secondary containment at the belt skimmer. There was oil/grease and visible staining on the concrete wall and outside of the secondary containment (Photo 8). BRS Response: Please see BRS response dated September 7, 2017 (Recommendation #8). ii. *There was water on the concrete around the cooling water pumps indicative of a leak (Photos 9-10). BRS Response: As noted in BRS response dated September 7, 2017 (Recommendations #9 and #11), BRS has installed and continues to maintain pump screens as a preventative measure to remove debris that could adversely impact the operation of the water treatment system. Debris captured by these screens caused some splash out onto the concrete walls and pads at the time of the inspection. To minimize future splash out, BRS modified these screens (completed on September 30, 2017) to reduce splash out onto concrete walls and pads. BRS performs routine inspections to ensure that accumulated debris is removed from these screens. iii. *There was water on the concrete around the ring filters indicative of a leak (Photo 11). BRS Response: At the date of the inspection, the ring filters were off-line for routine maintenance and cleaning. BRS completed this maintenance and cleaning on July 21, 2017 (Photo 8). BRS Response: See item c.ii. above. *There was significant splash out from the discharge points of the influent lines (Photos 12-14). iv. *Housekeeping practices need to be improved around the sludge dumpster under the filter press to prevent sludge from being spilled and/or tracked onto the surface of the ground (Photos 15-16). (Minor improvements were made during the course of the inspection and additional information received on 9/7/2017 stated that a concrete berm had been installed and additional corrective action was planned). BRS Response: Please see BRS response dated September 7, 2017 (Recommendation #3). As noted, BRS took immediate steps to improve housekeeping in and around the sludge dumpsters (e.g. sweeping, pressure washing concrete pads, etc.). In addition, BRS completed the construction of concrete berms at the opening of each filter press storage shelter on August 25, BRS also completed the installation of poly-curtains to enclose the sludge dumpsters on November 1, 2017 (Photo 5). d. Laminar WWTP i. *There was oil on the surface of the ground around the roll shop turnings dumpster located near the laminar plant (Photos 17-19). BRS Response: Please see BRS s response dated September 7, 2017 (Recommendation #10) State Hwy 198 Osceola, AR

23 March 30, 2018 Page 4 of 6 ii. There was a small amount of grass growing in the thickener of laminar plant (Photo 20). BRS Response: BRS wastewater treatment personnel removed the grass from the laminar thickener on July 20, BRS performs routine inspections to monitor for this condition and removes any observed vegetation. iii. There was miscellaneous trash in sludge dumpster of laminar plant. While this is not necessarily a violation of the permit if this sludge is landfilled, it may prevent recycling and/or beneficial reuse of the sludge. BRS Response: BRS personnel removed the trash and wood from the laminar sludge dumpster on July 20, e. Continuous Caster WWTP i. *Housekeeping practices need to be improved around the sludge dumpster under the filter press to prevent sludge from being spilled and/or tracked onto the surface of the ground. (Minor improvements were made during the course of the inspection and additional information received on 9/7/2017 stated that a concrete berm had been installed and additional corrective action was planned). BRS Response: Please see BRS response dated September 7, 2017 (Recommendation #5). In addition, BRS completed the construction of concrete berms at the opening of each filter press storage shelter on August 25, 2017 (Photos 5, 6 and 7). ii. *Runoff and/or tracking from the castor scale pit and dry scale dumpsters needs to be managed to prevent the comingling and ultimate discharge of process wastes with stormwater (Photos 21-22). BRS Response: See response to e. above. In addition, please see BRS s response dated September 7, 2017 (Recommendation #4). In addition, BRS has implemented a preventative maintenance plan to address general routine and unplanned cleanup of any material that accumulates around these dumpsters. (*Indicated items were also noted in the Industrial Stormwater Inspection Report ARR001578) 3. The following DMR reporting errors were noted during the inspection. Corrected DMRs have since been submitted and no further action is required. a. Flow from Outfall 001 for the January 2017 Monthly Average and Daily Max were mistakenly reported as Gallons per Day instead of Million Gallons per Day. b. Flow from Outfall 002 for the February 2017 Monthly Average was mistakenly reported as Gallons per Day instead of Million Gallons per Day. c. Loading values for TSS, Cr, Pb, Zn and Oil & Grease for Outfall 001 were incorrectly reported from January and February d. Contract lab ph values were being reported on the DMRs. Since these samples did not meet the instantaneous analysis requirements (15 minute maximum holding time) they were not 2027 State Hwy 198 Osceola, AR

24 March 30, 2018 Page 5 of 6 valid for reporting purposes. The instantaneous ph measurements collected by facility personnel must be used instead. e. Discrepancies in the species listed in the June 2017 WET Testing reports were corrected. BRS Response: As noted in the Report, BRS completed the updated and submitted corrected DMR s electronically on July 20, 2017 and July 26, During the course of the inspection, samples were collected from Outfall 001 the full ADEQ Laboratory Report is attached. All parameters required by the NPDES permit were within permit limits. As part of the analysis of volatile organics, both Acetone and Bromoform were detected in the effluent grab sample at a concentration of 14.4 µg/l and Dibromochloromethane at a concentration of 2.41 µg/l. While specific limits are not included in the permit, please identify any potential sources of the pollutants to determine if further review is necessary. BRS Response: BRS analytical results from the split sample on July 19, 2017 confirmed parameters were within permit limits. These results were provided to ADEQ on August 24, BRS is investigating potential sources of acetone, bromoform and dibromochloromethane. To date, BRS has confirmed that it does not use these compounds in our steelmaking or wastewater treatment processes. Acetone is present in some of the cleaning and maintenance supplies used in low volumes by BRS. Low volumes of acetone containing products are also used in our steelmaking laboratories for cleaning analytical equipment, however, these minor sources are not introduced into the wastewater treatment system. As a result, BRS believes that the likely source of the acetone in the sample is from the laboratory that analyzed the wastewater sample on behalf of ADEQ. BRS previously sampled for bromoform and dibromochloromethane as part of the priority pollutant (PPS) scan (March 2017) required by Permit No: AR At the time, bromoform was detected at 7.5 ug/l (below ADEQ required MQL 10 ug/l, the lab used the detection limit of 1.0 ug/l) and dibromochloromethane was not detected (the lab used the detection limit of 1 ug/l). Both of these compounds are Tri Halogenated Methanes (THMs), which are disinfection byproducts that results when a halogen (Chlorine, Bromine, Fluorine) reacts with organic matter during the wastewater treatment process. As a result, the generation of small quantities of these byproducts are often unavoidable in wastewater treatment systems at steelmaking facilities. In addition, while bromoform and dibromochloromethane were detected in the ADEQ sample, the concentrations observed are insignificant (and well below EPA s drinking water standards for total THMs of 80 ug/l) State Hwy 198 Osceola, AR

25 March 30, 2018 Page 6 of 6 General Comments: While not a requirement, it was suggested that the composite sampling point be moved from the outfall structure on the riverbank to the location where grab samples are obtained after the final treatment unit within the plant. This will prevent high river levels from interfering with sample collection and prevent accidental comingling of flows between outfalls 001 and 002. BRS Response: Effective, July 21, 2017, BRS water treatment personnel began collecting composite samples from the same location as the grab samples consistent with this recommendation. Samples are collected after sand filtration and prior to pipeline to Outfall 001 (Photo 2). The vast majority of the treatment plants, chemical storage area and dosing equipment are uncovered and otherwise unprotected from the weather. This will likely pose problems during extreme cold weather resulting in inadequate treatment and/or overflows from the treatment system(s). The treatment plants should be evaluated and proactive measures taken to allow for uninterrupted and efficient operation during all possible weather conditions. BRS Response: The majority of chemical storage areas and dosing equipment are located in secondary containment and enclosed with metal sheds at all treatment locations (Photo 9). BRS completed construction of the additional enclosures around used oil storage tank areas at all five wastewater treatment locations, under thickener/clarifier units and non-routine dosing areas between October 2017 and January 2018 (Photo 10). Finally, BRS completed installation of pipe wrap and heat trace wire on critical water treatment piping throughout the site between October 2017 and January 2018 (Photos 11 and 12). If you have any questions pertaining to the content of this letter, please feel free to contact me by phone at (870) or by mvachon@bigriversteel.com. Sincerely Big River Steel LLC Michele Vachon Environmental Manager Attachments 1-2 CC: Lenore Trammell, Big River Steel LLC Robert Carter, Big River Steel LLC Marty Booher, BakerHostetler 2027 State Hwy 198 Osceola, AR

26 ATTACHMENT 1 PHOTOGRAPHS ATTACHMENT 1 PHOTOGRAPHS 2027 State Hwy 198 Osceola, AR

27 ATTACHMENT 1 PHOTOGRAPHS Photograph 1 Photograph State Hwy 198 Osceola, AR

28 ATTACHMENT 1 PHOTOGRAPHS Photograph 3 Photograph State Hwy 198 Osceola, AR

29 ATTACHMENT 1 PHOTOGRAPHS Photograph 5 Photograph State Hwy 198 Osceola, AR

30 ATTACHMENT 1 PHOTOGRAPHS Photograph 7 Photograph State Hwy 198 Osceola, AR

31 ATTACHMENT 1 PHOTOGRAPHS Photograph 9 Photograph State Hwy 198 Osceola, AR

32 ATTACHMENT 1 PHOTOGRAPHS Photograph 11 Photograph State Hwy 198 Osceola, AR

33 ATTACHMENT 2 BRS RESPONSE ATTACHMENT 2 BRS SEPTEMBER 7, 2017 RESPONSE 2027 State Hwy 198 Osceola, AR

34 September 7, 2017 VIA Brent L. Walker District 3 Field Inspector Office of Water Quality Jonesboro Field Office Arkansas Department of Environmental Quality 2212 Fowler Avenue, Suite B Jonesboro, AR RE: Preliminary Inspection Findings Response Big River Steel LLC, Osceola, AR AFIN: Dear Mr. Walker, I am writing as a follow up to your site inspection on July 19 20, The items provided below are based upon our discussions, the notes taken during the site inspection and our conversations and communications since the date of the site inspection. ADEQ Follow up Information / Data Request #1: Provide a copy of the Outfall 002 Pump Curve BRS Response: Pump Curve diagram was ed on 7/20/17. Additional copy is attached hereto. See Attachment #1. ADEQ Follow up Information / Data Request #2: Outfall 001 Split Sampling Results from BRS Contracted Laboratory BRS Response: Analytical results, as received, were ed to you on 8/24/17. Additional copy is attached hereto. See Attachment #2. Follow up Information / Recommendation #3: Housekeeping for and Add Containment to Address Wastewater in Filter Press Areas BRS Response: Installation of five concrete berms at opening of filter press storage shelters was completed on 8/25/17. In addition, BRS has ordered a poly curtain for one of the press areas. This poly curtain as well as the fabrication and installation of stops to consistently position filter cake box inside the curtain is in progress and should be completed by the end of September, After the completion of this work and confirmation that this design performs as expected, BRS will order and install four additional poly curtains at the other press areas. BRS expects to complete this work before December, State Hwy 198 Osceola, AR

35 Follow up Information / Recommendation #4: Housekeeping and Containment in Hotmill Dry Scale Storage Areas 2 P age BRS Response: Installation of two concrete pads to support dry scale storage hoppers, with stem walls, was completed on September 1, Follow up Information / Recommendation #5: Housekeeping In and Around the Caster Scale Pit BRS Response: General housekeeping and cleanup in and around the caster scale pit was completed on July 21, This area has now been included as part of the BRS preventative maintenance program. In addition, BRS: (1) installed a concrete berm added to secondary containment area; (2) has completed design of a new caster scale pit collection bin that will have higher sides as well as a new chute to control scale. BRS has begun construction of the new caster scale pit collection bin and expects to complete this project by November 1, Follow up Information / Recommendation #6: Wastewater Skimmer Not Flush with the Side of the Basin BRS Response: A replacement skimmer addressing this observation/recommendation was installed on July 19, Follow up Information / Recommendation #7: Mist from the Cooling Towers Condensing on Exterior of the Building and Splash Out. BRS Response: BRS took immediate steps to address the conditions identified during the site inspection. In addition, BRS implemented operational changes and added these cooling tower systems to its daily and monthly preventative maintenance program on July 21, 2017 to minimize the drift of mist from the cooling towers. This includes, for example, reducing fan speed to prevent splash out. In addition, BRS has developed a program to ensure that if splash out conditions related to mist from the cooling towers is observed during routine inspections, any needed corrective action is taken and splash out is cleaned up. Follow up Information / Recommendation #8: Bucket of Oil was Observed Outside of the Secondary Containment Basin at Hotmill BRS Response: The bucket of oil was immediately removed from the work area on July 20, Maintenance staff have been directed to ensure that all oil is stored in secondary containment. Follow up Information / Recommendation #9: Wastewater Splash Out Around Wastewater Pumping Area BRS Response: As discussed, BRS has installed and continues to maintain the pump screens as a preventative measure to assist with debris removal associated with construction activities at the site. Debris captured by these screens, however, and may have caused some splash out of

36 water onto concrete walls and pads. Inspection and ensuring that all debris is removed from these screens is now performed as part the daily and weekly maintenance program for the wastewater treatment facility. BRS also has modified the screen design to address wastewater splash out and plans to install these modified screens by the end of September, Follow up information / Recommendation #10: Rollshop Turnings Dumpsters were Not Properly Sealed BRS Response: Loose connections and fittings on the Dumpsters were repaired on July 21, Material observed on the ground was swept and vacuumed up and put in an appropriate waste disposal container. In addition, new dumpsters with new fittings and seals are now at the site and BRS has installed secondary containment (polymer secondary containment berms) in the area of the portable dumpsters. Follow up Information / Recommendation #11: HSM Decanting Basin Splash out at screens BRS Response: As discussed, BRS has installed and continues to maintain the pump screens HSM decant header as a preventative measure to assist with debris removal associated with construction activities at the site. Debris captured by these screens, however, may have caused some splash out of water onto concrete walls and pads. Inspection and ensuring that all debris is removed from these screens is now performed as part the daily and weekly maintenance program for the wastewater treatment facility. BRS also has modified the screen design to address wastewater splash out and plans to install these modified screens by the end of September, Follow up Information / Recommendation #12: Confirm Proper Location of Wastewater Totalizer (i.e., Flow Meter) BRS Response: After the inspection, BRS consulted with its wastewater treatment operator on the proper location for the wastewater totalizer to ensure the most accurate reading. Based upon those discussions, it was concluded that the current location of the wastewater totalizer would overestimate the volume of discharge because the backwash cycle of the sand filters was included in the existing totalizer data. In response, BRS has ordered a new totalizer that will be installed on the exit side of the sand filters. BRS will consult with the permitting division to make any necessary permit modifications prior to installing this new equipment. 3 P age

37 Follow up Information / Recommendation #13: Consider Relocating the Sampling Point for Wastewater Discharges (Outfall #1) from the River to the Discharge Pipe Closer to the Wastewater Treatment Facility BRS Response: Based upon this comment, BRS consulted with its wastewater treatment operator and concluded that a new sampling point for all parameters should be installed at a point just before the wastewater treatment pipe goes underground near the wastewater treatment facilities. BRS will consult with the permitting division to make any necessary permit modifications prior to moving the sampling point. If you have any questions pertaining to the content of this letter, please feel free to contact me by phone at or by mvachon@bigriversteel.com. Sincerely Big River Steel LLC Michele Vachon Environmental Manager Enclosure CC: Lenore Trammel; Big River Steel, LLC; Marty Booher, BakerHostetler 4 P age

38 ATTACHMENT State Hwy 198 Osceola, AR

39

40 September 8, 2017 Page 6 ATTACHMENT 2 6 P age

41 7/26/2017 Big River Steel Ms. Michelle Vachon 1425 Ohlendorf Rd Osceola, AR, Ref: Analytical Testing Lab Report Number: Client Project Description: Outfall ADEQ Split Treated Process Wastewater Permit #AR Dear Ms. Michelle Vachon: Waypoint Analytical, Inc. received sample(s) on 7/19/2017 for the analyses presented in the following report. The above referenced project has been analyzed per your instructions. The analyses were performed in accordance with the applicable analytical method. The analytical data has been validated using standard quality control measures performed as required by the analytical method. Quality Assurance, method validations, instrumentation maintenance and calibration for all parameters (NELAP and non-nelap) were performed in accordance with guidelines established by the USEPA (including 40 CFR 136 Method Update Rule May 2012) and NELAC unless otherwise indicated. Any parameter for which the laboratory is not officially NELAP accredited is indicated by a '~' symbol. These are not included in the scope because NELAP accreditation is either not available or has not been applied for. Additional certifications may be held/are available for parameters, where NELAP accreditation is not required or applicable. A full list of certifications is available upon request. Certain parameters (chlorine, ph, dissolved oxygen, sulfite...) are required to be analyzed within 15 minutes of sampling. Usually, but not always, any field parameter analyzed at the laboratory is outside of this holding time. Refer to sample analysis time for confirmation of holding time compliance. The results are shown on the attached Report of Analysis(s). Results for solid matrices are reported on an asreceived basis unless otherwise indicated. This report shall not be reproduced except in full and relates only to the samples included in this report. Please do not hesitate to contact me or client services if you have any questions or need additional information. Sincerely, Randy Thomas Project Manager Laboratory's liability in any claim relating to analyses performed shall be limited to, at laboratory's option, repeating the analysis in question at laboratory's expense, or the refund of the charges paid for performance of said analysis. Alabama #40750 Louisiana #04015 VA NELAP # Texas #T Arkansas # Mississippi California #2904 NC #415 Oklahoma #9311 Virginia #00106 Kentucky #90047 Tennessee #TN02027 EPA #TN00012 Kentucky UST #41 Page 1 of 6

42 21167 Big River Steel Ms. Michelle Vachon 1425 Ohlendorf Rd Osceola, AR Project Information : Outfall ADEQ Split Treated Process Wastewater Permit #AR Report Date : 07/26/2017 Received : 7/19/2017 Report Number : REPORT OF ANALYSIS Lab No : Matrix: Aqueous Sample ID : Outfall 001 Grab Sampled: 7/19/2017 0:00 Test Results Units MQL DF Date / Time By Analytical Analyzed Method HEM: Oil and Grease 14.1 mg/l /21/17 09:30 KEW 1664A ph 8.4 s.u. 1 07/19/17 16:30 TL1 4500H+B-2011 Qualifiers/ Definitions DF Dilution Factor MQL Method Quantitation Limit Page 2 of 6

43 21167 Big River Steel Ms. Michelle Vachon 1425 Ohlendorf Rd Osceola, AR Project Information : Outfall ADEQ Split Treated Process Wastewater Permit #AR Report Date : 07/26/2017 Received : 7/19/2017 Report Number : REPORT OF ANALYSIS Lab No : Matrix: Aqueous Sample ID : Outfall 001 Grab Sampled: 7/19/2017 0:00 Analytical Method: Prep Method: 624 Prep Batch(es): L /21/17 08:22 EPA-624 (PREP) Test Results Units MQL DF Date / Time By Analytical Analyzed Batch Tetrachloroethylene <1.00 µg/l /21/17 19:27 LAT L Surrogate: 4-Bromofluorobenzene 110 Limits: % 1 07/21/17 19:27 LAT L Surrogate: Dibromofluoromethane 95.0 Limits: % 1 07/21/17 19:27 LAT L Surrogate: 1,2-Dichloroethane - d4 101 Limits: % 1 07/21/17 19:27 LAT L Surrogate: Toluene-d8 108 Limits: % 1 07/21/17 19:27 LAT L Analytical Method: Prep Method: 625 Prep Batch(es): L /25/17 15: Test Results Units MQL DF Date / Time By Analytical Analyzed Batch Naphthalene <2.00 µg/l /25/17 18:14 ATF L Surrogate: 2-Fluorobiphenyl 44.4 Limits: % 1 07/25/17 18:14 L Surrogate: Nitrobenzene-d Limits: % 1 07/25/17 18:14 L Surrogate: 4-Terphenyl-d Limits: % 1 07/25/17 18:14 L Qualifiers/ Definitions DF Dilution Factor MQL Method Quantitation Limit Page 3 of 6

44 21167 Big River Steel Ms. Michelle Vachon 1425 Ohlendorf Rd Osceola, AR Project Information : Outfall ADEQ Split Treated Process Wastewater Permit #AR Report Date : 07/26/2017 Received : 7/19/2017 Report Number : REPORT OF ANALYSIS Lab No : Matrix: Aqueous Sample ID : Outfall 001 Composite Sampled: 7/19/ :16 Test Results Units MQL DF Date / Time By Analytical Analyzed Method Chromium, Hexavalent <10.0 µg/l /19/17 11:00 BHK 3500CrB-2011 Total Suspended Solids 17 mg/l /20/17 15:40 JMP 2540D-2011 Total Chromium 2.45 µg/l /24/17 11:08 BKN EPA Total Lead <0.500 µg/l /24/17 11:08 BKN EPA Total Nickel 15.4 µg/l /24/17 11:08 BKN EPA Total Zinc 25.8 µg/l /24/17 11:08 BKN EPA Qualifiers/ Definitions DF Dilution Factor MQL Method Quantitation Limit Page 4 of 6

45 Customer Number: Customer Name: Big River Steel Report Number: Cooler Receipt Form Shipping Method Fed Ex US Postal Lab Other : UPS Client Courier Thermometer ID: #21 Shipping container/cooler uncompromised? Yes No Number of coolers received 1 Custody seals intact on shipping container/cooler? Yes No Not Required Custody seals intact on sample bottles? Yes No Not Required Chain of Custody (COC) present? Yes No COC agrees with sample label(s)? Yes No COC properly completed Samples in proper containers? Sample containers intact? Sufficient sample volume for indicated test(s)? All samples received within holding time? Cooler temperature in compliance? Cooler/Samples arrived at the laboratory on ice. Samples were considered acceptable as cooling process had begun. Yes Yes Yes Yes Yes Yes Yes No No No No No No No Water - Sample containers properly preserved Yes No N/A Water - VOA vials free of headspace Yes No N/A Trip Blanks received with VOAs Yes No N/A Soil VOA method 5035 compliance criteria met Yes No N/A High concentration container (48 hr) Low concentration EnCore samplers (48 hr) High concentration pre-weighed (methanol -14 d) Low conc pre-weighed vials (Sod Bis -14 d) Special precautions or instructions included? Yes No Comments: Signature: Kristina A. McAdams Date & Time: 07/19/ :43:18 Page 5 of 6

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