HomeMy WebLinkAboutNCS000456_Fact sheet binder_20230816 DEQ / DEMLR
FACT SHEET FOR NPDES INDUSTRIAL INDIVIDUAL
STORMWATER PERMIT DEVELOPMENT
Basic Information for Permit Issuance and Renewals:
Permit Writer/Date Brianna Young 8/14/2023
Permit Number NCS000456
Owner/Facility Name Culpeper of Cove City,LLC/Culpeper of Cove City
SIC AICS Code/Category 2491 (321114)/Wood Preservation
Basin Name/Sub-basin number Neuse/03-04-08
Receiving Stream/HUC UT to Core Creek/030202020601
Stream Classification/Stream Segment Q Sw,NSW/27-90
Is the stream impaired on 303 d list]? Yes
Any TMDLs? No
Any threatened and/or endangered species? See Section 2 below
Any compliance concerns? See Section 2 below
Any perinit mods since lastpermit? No
New expiration date 8/31/2028
Comments on Draft Permit? See Section 6(below)
Section 1. Facility Activities and Process:
Culpeper of Cove City, LLC is a wood preservation facility. Treatment consists of chromated copper
arsenate (CCA) (for commercial wood) or micronized copper azole (MCA) (for residential wood).
Waters accumulated inside containment areas are used back in the process. All freshly treated lumber is
kept under cover on a drip pad until drippage has ceased. There are several storage sheds where the
majority of treated lumber is stored, and any remaining lumber is kept on the yard until sold. Oil or
chemicals used at the maintenance department are kept inside the maintenance building or under cover.
Any water accumulated within unloading containment is either pumped out, reused in the wood
treatment process, or shipped for recycling if contaminated with oil.
Outfall SW001:
Drainage area consists of treated wood storage, hazardous waste storage, maintenance shop, treatment
plant, chemical storage, fueling area and storage. Potential pollutants include: CCA, copper azole, diesel
fuel, gasoline, motor oil, and hydraulic oil.
Why Industrial Sites with Stormwater are Subject to a Permit: Federal NPDES regulations define
stormwater discharge associated with industrial activity in 40 CFR §122.26 (b)(14) as: "the discharge
from any conveyance that is used for collecting and conveying storm water and that is directly related to
manufacturing,processing or raw materials storage areas at an industrial plant. The term does not
include discharges from facilities or activities excluded from the NPDES program under this part 122.
For the categories of industries identified in this section, the term includes, but is not limited to, storm
water [sic] discharges from industrial plant yards; immediate access roads and rail lines used or traveled
by carriers of raw materials, manufactured products, waste material, or byproducts used or created by
the facility; material handling sites; refuse sites; sites used for the application or disposal of process
waste waters (as defined at part 401 of this chapter); sites used for the storage and maintenance of
material handling equipment; sites used for residual treatment, storage, or disposal; shipping and
receiving areas; manufacturing buildings; storage areas (including tank farms) for raw materials, and
Page 1 of 6
intermediate and final products; and areas where industrial activity has taken place in the past and
significant materials remain and are exposed to storm water. For the purposes of this paragraph, material
handling activities include storage, loading and unloading, transportation, or conveyance of any raw
material, intermediate product, final product, byproduct or waste product. The term excludes areas
located on plant lands separate from the plant's industrial activities, such as office buildings and
accompanying parking lots as long as the drainage from the excluded areas is not mixed with storm
water [sic] drained from the above described areas."
Section 2. Monitoring Information and Compliance History:
• March 2017 to November 2022, benchmarks exceeded for:
o TSS 3x
o Copper 8x
o pH min not reached 4x
• Per the June 2023 inspection report:
o This facility has several storage tanks of chemicals/pesticides used for its operations.
There's a drainage ditch that wraps around the entire facility and stormwater runoff is
routed through that ditch into a pond.
o This facility also has a horizontal drum to store diesel covered under a shed and with a
dyke wall. Insides of the dyke wall had oil stains up to a height of 2-3 feet all around the
dyke. Outside the dyke oil mixed with mud/soil was found mopped and scraped off to the
side of truck parking bay. It is suspected that there have been several oil spill incidents at
this site evident from above indicators. It is recommended that safety person may be
present during the loading/unloading operation of this diesel tank so as to be able to carry
out necessary mechanical/procedural modifications.
303(d) listing:
re Creek 27-90a2 ;s3nr,N5W FW Miles
8615 From upstream crossing of 5R 1239 to Grape Creek
PARAIIIE7Hi IR CATEGORY CRITERIA STATUS REASON FOR RATING 303DYEAR
Benthos[Nar,AL,FWJ 5-1 Exceed ing Criteria Fair,Poor or Severe Biodmification
Threatened/Endangered Species:
Regal Darner(Coryphaeschna ingens;NC status: SR), Phantom Darner(Triacanthagyna trifida; NC
status: SR), and Banded Sunfish(Enneacanthus obesus;NC status: SR).
Section 3. Proposed Monitoring for Stormwater Discharges:
The Division considered potential pollutants from past and present industrial activities and data was
submitted for March 2017 to November 2022. Quantitative sampling included pH, TSS, arsenic,
chromium, copper, COD, BOD, O&G, phosphorus, TKN, nitrate-nitrite, and hardness.
Parameters are based on potential pollutants in the drainage area, sampling results, and in some cases,
dependent upon future activities (e.g., ash removal through the drainage area). Below is a table of the
proposed monitoring for each outfall at the Culpeper of Cove City, LLC site.
Page 2 of 6
Outfall SW001
Quarterly monitoring
Total Suspended Solids BASIS: Potential pollutant from drainage area and BMP effectiveness
(TSS) indicator.
Quarterly monitoring
H BASIS: Pollutant indicator and important to interpreting toxicity potential
p of metals.
Quarterly monitoring
Total Rainfall BASIS: Discharge potential indicator
Quarterly monitoring
Non-Polar Oil &Grease BASIS: Potential pollutant from lubricants; Method 1664 SGT-HEM
targets petroleum-based O&G
Quarterly monitoring
Monthly Oil Usage BASIS: Potential pollutant from drainage area
Quarterly monitoring
BOD BASIS: Discharge potential indicator
Quarterly monitoring
COD BASIS: Discharge potential indicator
Quarterly monitoring
Total Arsenic BASIS: Potential pollutant from drainage area
Quarterly monitoring
Total Chromium BASIS: Potential pollutant from drainage area
Quarterly monitoring
Total Copper BASIS: Potential pollutant from drainage area
Quarterly monitoring
Total Hardness BASIS: Monitoring for hardness dependent metals present
Stormwater Benchmarks and Tiered Response: Rather than limits,North Carolina NPDES
Stormwater permits contain benchmark concentrations. Stormwater benchmarks are numerical action
levels for stormwater monitoring. Benchmarks are not effluent limits, and benchmark exceedances are
not permit violations. Benchmarks provide facilities a tool for assessing the significance of pollutants in
stormwater discharges and the effectiveness of best management practices (BMPs). Benchmark
concentrations are intended as guidelines for the facility's development and implementation of the
Stormwater Pollution Prevention Plan(SWPPP).
Benchmark exceedances require the permittee to increase monitoring, increase management actions,
increase record keeping, and/or install stormwater BMPs in a tiered program. The permit establishes a
tiered approach to specify actions the permittee must take in response to analytical results above
Page 3 of 6
benchmark concentrations. The tiered structure of the permit provides the permittee and DEMLR wide
flexibility to address issues that may arise with one or more parameters and/or outfalls.
Metals benchmarks are calculated to mimic acute water quality standards and with the guidance of
DWR. NC DWR follows established federal procedures for calculating acute standards when developing
the benchmarks. Just like the acute standards, metals benchmarks normally reflect one half of the
calculated Final Acute Value (the "1/2 FAV"). In most cases, translation into total recoverable values is
based on an assumed hardness of 25 mg/L and a total suspended solids (TSS) concentration of 10 mg/L.
Acute standards protect aquatic life from negative impacts of short-term exposure to higher levels of
chemicals where the discharge enters a waterbody. The Stormwater Permitting Program applies this
approach because of the ephemeral nature of rainfall events.
The Division may evaluate results to determine if a smaller suite of parameters for some outfalls is
adequate to characterize potential pollution or BMP effectiveness. For example, one or more metals or
other parameters may serve as an adequate tracer for the presence of ash pollution during disturbance or
ash removal in specific drainage areas at this site. For parameters that do not have a stormwater
benchmark, the Division may develop a benchmark value if appropriate toxicity data become available
or if rising trends in concentrations suggest a persistent source.
A summary of the benchmarks in the draft permit, and their basis, is below:
Parameter Benchmark Basis
Total Suspended 100 mg/L National Urban Runoff Program(NURP) Study, 1983
Solids TSS
H 6 s.u. —9 s.u. NC Water Quality Standard(Range)
Non-Polar Oil & Review of other state's daily maximum benchmark
Grease 15 mg/L concentration for this more targeted O&G;NC WQS that
EPA Method 1664 does not allow oil sheen in waters
SGT-HEM
BOD 30 mg/L BPJ; Based on Secondary Treatment Regulation(40 CFR
133.03
COD 120 mg/L BPJ; Generally found at levels 4x BOD5 in domestic
wastewaters
Arsenic Total 340 /L Acute Aquatic Criterion, '/2 FAV
'/2 FAV; Based on(Cr III+Cr VI) acute thresholds and
Chromium(Total) 905 µg/L assumption that industrial activities here are not a source of
hexavalent chromium
Copper Total 10 /L I Acute Aquatic Criterion, '/2 FAV
Stormwater Pollution Prevention Plan: The proposed permit conditions reflect the EPA and NC's
pollution prevention approach to stormwater permitting. The Division's maintains that implementation
of Best Management Practices (BMPs) and traditional stormwater management practices that control the
source of pollutants meets the definition of Best Available Technology (BAT) and Best Conventional
Pollutant Control Technology(BCT). The permit conditions are not numeric effluent limitations but are
designed to be flexible requirements for implementing site-specific plans to minimize and control
pollutants in stormwater discharges associated with the industrial activity. Title 40 Code of Federal
Regulations (CFR) §122.44(k)(2) authorizes the use of BMPs in lieu of numeric effluent limitations in
NPDES permits when the agency finds numeric effluent limitations to be infeasible. The agency may
also impose BMP requirements which are "reasonably necessary" to carry out the purposes of the Act
Page 4 of 6
under the authority of 40 CFR 122.44(k)(3). The conditions proposed in this draft permit are included
under the authority of both of these regulatory provisions. In essence, the pollution prevention and BMP
requirements operate as limitations on effluent discharges that reflect the application of BAT/BCT.
Flexibility in Tier Responses: Tier Two actions provide an opportunity for the permittee to propose an
alternative monitoring plan for approval by the Region:
• Alternatively, in lieu of steps 2 and 3, the permittee may, after two consecutive exceedances,
exercise the option of contacting the DEMLR Regional Engineer as provided below in Tier
Three. The Regional Engineer may direct the response actions on the part of the permittee as
provided in Tier Three, including reduced or additional sampling parameters or frequency.
• If pursuing the alternative above after two consecutive exceedances, the permittee may propose
an alternative monitoring plan for approval by the Regional Engineer.
The permit therefore allows the permittee to petition the Regional Office for monitoring changes sooner
than Tier Three (upon any four benchmark exceedances) and gives guidance on one option to take. For
example, the permittee may request that mercury only be monitored semi-annually under the tiers, or
that only parameters over the benchmark be monitored more frequently. In this way, changes to the
monitoring scheme for any outfall could be handled outside of a permit modification.
Other Proposed Requirements:
• It is standard for Stormwater Pollution Prevention Plan(SWPPP)requirements to include an
annual certification that stormwater outfalls have been evaluated for the presence of non-
stormwater discharges, and if any are identified, how those discharges are permitted or otherwise
authorized.
• Requirement to submit a request for permit modification if the facility identifies or creates any
new outfalls, removes outfalls, or alters any drainage area that changes potential pollutants.
• The Division expects the permittee to apply best professional judgment and consider the safety
of its personnel in fulfilling sampling obligations under the permit.
• Federal regulations require electronic submittal of all discharge monitoring reports (DMRs). If a
state does not establish a system to receive such submittals, then permittees must submit DMRs
electronically to the EPA.
• Quarterly QualitativeNisual Monitoring to assure regular observation of outfalls throughout
year.
Section 4. Chances from previous permit to draft:
• Monitoring increased from semi-annually to quarterly for all parameters (qualitative and
quantitative)
• "No discharge" clarifications made
• Feasibility study requirement removed per updated stormwater program requirements
• eDMR requirement added
• Boilerplate language moved into body of the permit; boilerplate no longer attached
• Outfall-specific monitoring been implemented to reflect industrial activity and potential
pollutants specific to each discharge area
• Monitoring added for BOD and COD
o Removed in previous permit as all values were below benchmarks
Page 5 of 6
o These are indicators of issues with stormwater and pollutants of concern for the type of
industry
• Monitoring for total hardness added for outfalls where monitoring for hardness dependent metals
is required
• Benchmarks updated for parameters per guidance from DWR Standards group on stormwater
benchmarks
Section 5. Changes from draft to final:
• None
Section 6. Discussions with the Facility and Regional Office:
• Initial contact with facility: 4/20/2023
• Initial contact with Regional Office: 4/20/2023
• Draft sent to CO peer review: N/A
• Draft sent to Regional Office: 6/30/2023
• Final permit sent for supervisor signature: 8/14/2023
Section 7. Comments received on draft permit:
• None
Page 6 of 6
Affidavit of Publication
STATE OF NORTH CAROLINA PUBLIC NOTICE
NORTH CAROLINA
BEAUFORT & HYDE COUNTIES ENVIRONMENTAL
MANAGEMENT COMMISSION
INTENT TO ISSUE
Ashley Vansant, being duly sworn, says: NPDES STORMWATER
That he is Publisher of the Washington Daily News, DISCHARGE PERMITS
a daily newspaper of general circulation, printed and The North Carolina
published in Washington, Beaufort& Hyde Coun- Environmental Management
ties, North Carolina;that the publication, a copy of Commission proposes to issue
which is attached hereto, was published in the said NPDES stormwater discharge
newspaper on the following dates: betl wi. Pub c p comment or
objection to the draft permits
is invited. Written comments
regarding the proposed permit
07/08/23 will be accepted until 30 days
after the publish date of this
notice and considered in the
That said newspaper was regularly issued and final determination regarding
circulated on those dates. permit issuance and permit
provisions. The Director of the
NC Division of Energy,Mineral,
The sum charged by the Newspaper for said publi- and Land Resources (DEMLR)
cation does not exceed the lowest rate paid by com- may hold a public hearing should
mercial customers for an advertisement of similar there be a significant degree
size and frequency in the same newspaper in which of public interest. Please mail
Q Ycomments and/or information
the public notice appeared. requests to DEMLR at 1612
Mail Service Center, Raleigh,
There are no agreements between the Washington NC 27699-1612. ? Culpeper of
Dail News and the officer or attorney charged with City Cove, City,
,NC 2 Old Hwy
Y y fd 70 W,Cove City,NC 28523)has
the duty of placing the attached legal advertising requested renewal of permit
notices whereby any advantage, gain or profit ac- NCS000456 for the Culpeper
crued to said officer or attorney. county.Cove
facility d 5 harges
to an unnamed tributary to
SIGNED: Core Creek in the Neuse River
Basin. Interested persons
may visit DEMLR at 512 N.
Salisbury Street, Raleigh, NC
27604 to review information on
file. Additional information on
NPDES permits and this notice
may be found on our website:
https://deq.ne.gov/about/
divisions/energy-mineral-and-
Ashley Vansant, Publisher land-resources/stormwater/
stormwater-program/
Subscribed and sworn to before me this stormwater-public-notices, or
8th Da Of July,2023 by contacting Brianna Young at
Y Y bdanna.young@deq.nc.gov or
919-707-3647.
y�o Esw� Washington Daily News:
Jul.8,2023
� 2g NOTARY INTENT
9 NBLIC �r -td E J N E D
rAflGE'
Mary Jo Eskridge, Notary Public JUL 2 2023
State of Alabama at Large
My commission expires 03-02-2026 �R-Sfom)wa#er Program
Account#304614
Ad# 1672424
NCDEQ
1612 MAIL SERVICE CENTER
RALEIGH NC 27699
Compliance Inspection Report
Permit:NCS000456 Effective: 10/01/18 Expiration: 09/30/21 Owner: Culpeper of Cove City LLC
SOC: Effective: Expiration: Facility: Culpepper of Cove City
County: Craven 11065 Old Hwy 70 W
Region: Washington
Cove City NC 28523
Contact Person:Josh Adkins Title: Phone: 803-566-3270
Directions to Facility:
System Classifications: SWNC,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 06/13/2023 Entry Time 01:OOPM Exit Time: 03:OOPM
Primary Inspector:William J Moore Phone: 252-946-6481 Ext.264
Secondary Inspector(s):
Varun Prakash
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page 1 of 3
Permit: NCS000456 Owner-Facility:Culpeper of Cove City LLC
Inspection Date: 06/13/2023 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Inspection was conducted on 06/13/2023. Met with Josh Adkins, Director of Environment and Safety(M:(803)-566-3270,
email:jadkins@culpeperwood.com)at around 1 pm.
This facility has SIC code 2491 and carries out the following wood treatment operations:
1. treats residential wood using a chemical MCA(Micronized CopperAzole), and
2. treats commercial wood using a chemical CCA(Chromated copper arsenate).
This facilty has several storage tanks of chemicals/pesticides used for its operations. There's a drainage ditch that wraps
around the entire facilty and stormwater runoff is routed through that ditch into a pond(has state SW permit SW7040514).
This site has several open wood storage locations,along with vegetative buffer all around the operating area.
This facility also has a horizontal drum to store diesel covered under a shed and with a dyke wall. Insides of the dyke wall
had oil stains upto a height of 2-3 feet all around the dyke. Outside the dyke oil mixed with mud/soil was found mopped and
scraped off to the side of truck parking bay. It is suspected that there have been several oil spill incidents at this site evident
from above indicators. It is recommended that safety person may be present during the loading/unloading operation of this
diesel tank so as to be able to carry out necessary mechancal/procedural modifications.
It is recommended that permit number NCS000456 may be reissued.
Page 2 of 3
Permit: NCS000456 Owner-Facility:Culpeper of Cove City LLC
Inspection Date: 06/13/2023 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? ❑ ❑ ❑
#Does the Plan include a General Location (USGS) map? ❑ ❑ ❑
#Does the Plan include a"Narrative Description of Practices"? ❑ ❑ ❑
#Does the Plan include a detailed site map including outfall locations and drainage areas? ❑ ❑ ❑
#Does the Plan include a list of significant spills occurring during the past 3 years? ❑ ❑ ❑
#Has the facility evaluated feasible alternatives to current practices? ❑ ❑ ❑
#Does the facility provide all necessary secondary containment? ❑ ❑ ❑
#Does the Plan include a BMP summary? ❑ ❑ ❑
#Does the Plan include a Spill Prevention and Response Plan (SPRP)? ❑ ❑ ❑
#Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ❑ ❑ ❑
#Does the facility provide and document Employee Training? 0 ❑ ❑ ❑
#Does the Plan include a list of Responsible Party(s)? 0 ❑ ❑ ❑
# Is the Plan reviewed and updated annually? 0 ❑ ❑ ❑
#Does the Plan include a Stormwater Facility Inspection Program? 0 ❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented? 0 ❑ ❑ ❑
Comment: This facility also has a horizontal drum to store diesel covered under a shed and with a dyke
wall. Insides of the dyke wall had oil stains upto a height of 2-3 feet all around the dyke.
Outside the dyke oil mixed with mud/soil was found mopped and scraped off to the side of truck
Parking bay. It is suspected that there have been several oil spill incidents at this site evident
from above indicators.
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring? 0 ❑ ❑ ❑
Comment:
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? 0 ❑ ❑ ❑
#Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? 0 ❑ ❑ ❑
Comment:
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? ❑ ❑ ❑
#Were all outfalls observed during the inspection? ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ❑
#Has the facility evaluated all illicit(non stormwater)discharges? 0 ❑ ❑ ❑
Comment:
Page 3 of 3
Young, Brianna A
From: Adkins,Josh <jadkins@culpeperwood.com>
Sent: Friday, April 21, 2023 4:10 PM
To: Young, Brianna A
Subject: [External] RE: Culpeper of Cove City, LLC (NCS000456)
Attachments: Cove City Stormwater.xls
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Good afternoon,
See below in red. Please let me know if you have any other questions.
• Payment of the overdue permit annual fee. A copy of the invoice is attached to this email; This has been
taken care of by credit card.
• Description of industrial activity occurring onsite and chemicals used/stored;
Activity: Wood Preservation. Untreated lumber is brought on site for treatment using a copper based
(micronized) amine formula or an inorganic arsenial(CCA). All chemicals used in the treatment process are
kept inside containment areas. Waters accumulated inside these containment areas are used back in the
process. All freshly treated lumber is kept under cover, on a RCRA Subpart W drip pad until drippage has
ceased. There are several storage sheds where we store as much of the treated lumber as possible (around
6501o). Any remaining lumber is kept on the yard until sold.
Chemicals used: (CCA) Chromium Copper Arsenic, Micronized Copper, Diesel Fuel, Gasoline, Motor Oil,
Hydraulic Oil.
Any oil or chemicals used at the maintenance department are kept inside the maintenance building or under
cover. All bulk oil tanks have secondary containment and is roofed, along with drip pans under the nozzles. A
diesel unloading containment area has been installed by the diesel tanks. Any water accumulated within this
unloading containment is either pumped out, reused in our wood treatment process, or if contaminated with oil,
is shipped for recycling.
• Confirmation on the number of outfalls and associated coordinates;
Number of outfalls: 1 Lattitude: 35.189720 Longitude: -77.336390
• Description of industrial activity in each drainage area;
Activity at Drainage area: Lumber storage
• SIC (NAICS) code;
NAICS: 321114
• An electronic spreadsheet summarizing all of the monitoring data that has been collected since the
effective date of the current permit;
See attached spreadsheet
• Verification that the information in the renewal application is still complete and correct;
Everything is still complete and correct.
i
• An explanation of any operational changes since the renewal application was submitted.
No operational changes since renewal application was submitted.
Josh Adkins
Director of Environmental and Safety
CWP - Orangeburg I www.culpeperwood.com
aadkins@culpeperwood.com
P: (803) 534-7467 x4224 I M: (803)-566-3270 1 F: (803)-585-1367
CULPEPER
WOOD PRESERVERS
The Trusted Brand in Pressure Treated Lumber
From: Young, Brianna A<Brianna.Young@ncdenr.gov>
Sent:Thursday,April 20, 2023 3:09 PM
To:Adkins,Josh <jadkins@culpeperwood.com>
Subject: Culpeper of Cove City, LLC (NCS000456)
You don't often get email from brianna.young@ncdenr.gov. Learn why this is important
CAUTION!- [EXTERNAL]-This email originated from outside of the organization. Do not click links or open attachments unless you
recognize the sender and know the content is safe!!!
Good afternoon,
I am working on renewing the individual stormwater permit for Culpeper of Cove City, LLC (NCS000456). I
need additional information in order to 1) confirm that the information I have is correct and 2)make sure the
permit adequately serves the needs of the facility. Please provide the following:
• Payment of the overdue permit annual fee. A copy of the invoice is attached to this email;
• Description of industrial activity occurring onsite and chemicals used/stored;
• Confirmation on the number of outfalls and associated coordinates;
• Description of industrial activity in each drainage area;
• SIC (NAICS) code;
• An electronic spreadsheet summarizing all of the monitoring data that has been collected since the
effective date of the current permit;
• Verification that the information in the renewal application is still complete and correct; and
• An explanation of any operational changes since the renewal application was submitted.
2
Enter your stormwater permit number into the Stormwater Permit Summary Report and you will see a form that
includes the address of the facility, contact information for the permit, and the regulated stormwater outfall(s)for the
facility. Please review the facility information to make sure it is correct. Information can be updated using the links
provided below,where applicable:
• Facility/Company name or ownership: Name/Ownership Change Form
• Owner Affiliation (Legally responsible person; i.e., someone with the company who is designated to
represent the company per signatory requirements or another authorized representative): Permit Contact
Update Request Form
• Delegation of Signature Authority (DOSA): Permit Contact Update Request Form
• Billing contact: Permit Contact Update Request Form
• Permit contact: Permit Contact Update Request Form
• Facility contact: Permit Contact Update Request Form
• Facility address only: Email Bethany og ulias
• Stormwater outfall information: Email Bethany Georgoulias
• Visit the eDMR Six Steps website and complete Steps 1 and 2.
• Pay outstanding permit fees: Stormwater ePgMent website
Once I have the above listed information, I can continue my review. You will receive a draft permit for a 30-day
comment period. During this time we will be able to address any comments or concerns you have. During the
same 30-day period, the draft will be sent to a Regional Office staff member for review as well as out to public
notice. Once all comments and concerns are addressed, you may be issued a final permit.
Please contact me if you have any questions.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
Brianna.Young@ncdenr.gov(e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
e:,,- D E '�7'�
NORTH CAROLINA ClAi
Department of Environmental Quality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
3
4
Young, Brianna A
From: Adkins,Josh <jadkins@culpeperwood.com>
Sent: Friday, April 21, 2023 4:04 PM
To: Young, Brianna A
Subject: RE: [External] RE: Culpeper of Cove City, LLC (NCS000456)
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Thank you. We will submit a modification request once the site layout is complete. I will submit the answers to the
questions in the original email shortly.
Josh Adkins
Director of Environmental and Safety
CWP - Orangeburg I www.culpeperwood.com
jadkins@culpeperwood.com
P: (803) 534-7467 x4224 I M: (803)-566-3270 1 F: (803)-585-1367
CULPEPER
WOOD PRESERVERS
The Trusted Brand in Pressure Treated Lumber
From:Young, Brianna A<Brianna.Young@ncdenr.gov>
Sent: Friday,April 21, 2023 1:54 PM
To:Adkins,Josh <jadkins@culpeperwood.com>
Subject: RE: [External] RE: Culpeper of Cove City, LLC (NCS000456)
CAUTION!- [EXTERNAL]-This email originated from outside of the organization. Do not click links or open attachments unless you
recognize the sender and know the content is safe!!!
As you are not certain at this time what the final plan will be, and the completion date is quite a ways off, I recommend
moving forward with the permit renewal and submitting a modification request later when you know the final site
layout.
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
1
Brlanna.Young@ncdenr.gov(e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From:Adkins,Josh<jadkins@culpeperwood.com>
Sent: Friday,April 21, 2023 1:32 PM
To:Young, Brianna A<Brianna.Young@ncdenr.gov>
Subject: RE: [External] RE: Culpeper of Cove City, LLC (NCS000456)
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
We really won't know for certain until we finish clearing and grading the property, but it looks like we may possibly have
to add at least one more outfall.The only industrial activity will be lumber storage.
Josh Adkins
Director of Environmental and Safety
CWP - Orangeburg I www.culpeperwood.com
jadkins@culpeperwood.com
P: (803) 534-7467 x4224 I M: (803)-566-3270 1 F: (803)-585-1367
,0,00,&PIA06'e"t,4-'001ap'li.
CULPEPER
WOOD PRESERVERS
The Trusted Brand in Pressure Treated Lumber
From:Young, Brianna A<Brianna.Young@ncdenr.gov>
Sent: Friday,April 21, 2023 12:21 PM
To:Adkins,Josh<jadkins@culpeperwood.com>
Subject: RE: [External] RE: Culpeper of Cove City, LLC (NCS000456)
CAUTION!- [EXTERNAL]-This email originated from outside of the organization. Do not click links or open attachments unless you
recognize the sender and know the content is safe!!!
2
Hello Josh,
Thank you for the prompt payment and response. In regards to the land clearing—will this be a new outfall that needs
to be added to the permit?Or will the drainage from the new area go to an existing outfall?Will the only industrial
activity on the site be lumber storage, or will other operations occur as well?
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
Brlanna.Young@ncdenr.gov(e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From:Adkins,Josh<iadkins@culpeperwood.com>
Sent: Friday,April 21, 2023 10:25 AM
To:Young, Brianna A<Brianna.Young@ncdenr.gov>
Subject: [External] RE: Culpeper of Cove City, LLC(NCS000456)
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Good morning,
I have taken care of the permit annual fee by credit card, see attached receipt.Apparently it got submitted to our
accounts payable department but never got paid. I updated the billing address this morning so the bill will be sent
directly to one of our corporate offices. I also have one question before I submit the answers to the questions below. We
are in the process of clearing a parcel of property bordering our current facility.This new parcel of land will be used for
lumber storage. At this point we are still working to clear the property so would it be best to continue the renewal and
submit the modifications at a later date for the new property or should we hold off on the renewal and submit the
changes with the renewal? It's likely to be 6 to 8 months before we are complete with the clearing and grading of the
new property.
Josh Adkins
Director of Environmental and Safety
3
CWP - Orangeburg I www.culpeperwood.com
iadkins@culpeperwood.com
P: (803) 534-7467 x4224 I M: (803)-566-3270 1 F: (803)-585-1367
CULPEPER
WOOD PRESERVERS
The Trusted Brand in Pressure Treated Lumber
From: Young, Brianna A<Brianna.Young@ncdenr.gov>
Sent:Thursday,April 20, 2023 3:09 PM
To:Adkins,Josh<iadkins@culpeperwood.com>
Subject: Culpeper of Cove City, LLC (NCS000456)
Good afternoon,
I am working on renewing the individual stormwater permit for Culpeper of Cove City, LLC (NCS000456). I
need additional information in order to 1) confirm that the information I have is correct and 2)make sure the
permit adequately serves the needs of the facility. Please provide the following:
• Payment of the overdue permit annual fee. A copy of the invoice is attached to this email;
• Description of industrial activity occurring onsite and chemicals used/stored;
• Confirmation on the number of outfalls and associated coordinates;
• Description of industrial activity in each drainage area;
• SIC (NAICS) code;
• An electronic spreadsheet summarizing all of the monitoring data that has been collected since the
effective date of the current permit;
• Verification that the information in the renewal application is still complete and correct; and
• An explanation of any operational changes since the renewal application was submitted.
Enter your stormwater permit number into the Stormwater Permit Summary Report and you will see a form that
includes the address of the facility,contact information for the permit, and the regulated stormwater outfall(s)for the
facility. Please review the facility information to make sure it is correct. Information can be updated using the links
provided below,where applicable:
• Facility/Company name or ownership: Name/Ownership Change Form
• Owner Affiliation(Legally responsible person; i.e., someone with the company who is designated to
represent the company per signatory requirements or another authorized representative): Permit Contact
Update Request Form
• Delegation of Signature Authority (DOSA): Permit Contact Update Request Form
• Billing contact: Permit Contact Update Request Form
• Permit contact: Permit Contact Update Request Form
• Facility contact: Permit Contact Update Request Form
• Facility address only: Email Bethany og ulias
• Stormwater outfall information: Email Bethany Geor og ulias
4
• Visit the eDMR Six Steps website and complete Steps 1 and 2.
• Pay outstanding permit fees: Stormwater ePayment website
Once I have the above listed information, I can continue my review. You will receive a draft permit for a 30-day
comment period. During this time we will be able to address any comments or concerns you have. During the
same 30-day period, the draft will be sent to a Regional Office staff member for review as well as out to public
notice. Once all comments and concerns are addressed, you may be issued a final permit.
Please contact me if you have any questions.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
Brlanna.Young@ncdenr.gov(e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
ID: 7
�E 'A
Orperlm O W E(MronrnaMal 4ualdy
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties-
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
5
Cove City Outfall 001 Permit#NCS000456
LI)Q t _ 06O Y rL O y r= cn
o Q to a
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Benchmrk 1
100 0.36 1 0.007 120 30 6-9 30.00 2 ? 30
mg/I mg/I mg/I mg/I mg/I mg/I mg/I mg/I mg/I mg/I mg/I su mg/I mg/I mg/I mg/I
Mar-17 100 0.043 0.36 0.059 1 0.0820 0.007 46 120 3.4 7.47 BDL 0.44 1 0.15
Dec-17 100 0.026 0.36 0.035 1 0.1300 0.007 38 120 2.8 7.64 BDL 0.28 0.79 5
Jul-18 47 100 0.003 0.36 0.0029 1 0.0150 0.007 54 120 4 8.10 BDL 0.2 1.3 2
Dec-18 14 100 BDL 0.36 0.001 1 0.0049 0.007 BDL 120 BDL 7.96 BDL 0.083 1.1 5.2
May-19 100 0.062 0.34 0.220 1 0.1600 0.01 50 120 20 7.30 2.50 0.23 1.6 0.23 300 BDL = Below detectable level
Aug-19 32 100 BDL 0.34 BDL 1 0.0040 0.01 32 120 BDL 7.10 BDL 0.10 0.61 0.45 110
Mar-20 5.4 100 BDL 0.34 0.0019 1 0.0320 0.01 BDL 120 4.6 7.00 2.20 0.22 3.7 1.8 92
Sep-20 25 100 0.005 0.34 0.003 1 1 0.05201 0.01 27 1 120 4.5 6.90 BDL 0.17 0.70 0.79 76
Sep-20 14 100 BDL 0.34 0.001 1 0.01 0.01 27 120 2.7 5.80 BDL 0.19 1.20 4.8 58 :Monthly DueOct-20 6.8 100 BDL 0.34 BDL 1 0.01 0.01 31 120 2.1 5.60 3.50 0.10 1.40 9 88 HighNov-20 7 100 BDL 0.34 0.001 1 0.0015 0.01 56 120 5.4 5.90 BDL 0.15 1.50 4 46opper
Jun-21 11 100 BDL 0.34 BDL 1 BDL 0.01 36.00 120 BDL 5.90 2.10 0.10 1.60 12 64
Dec-21 18 100 BDL 0.34 0.009 1 1 1 0.002 1 0.01 135.001 120 1 5.70 6.80 4.10 0.23 1.20 3.8 82
4/20/23, 1:13 PM North Carolina Secretary of State Search Results
• File an Annual Report/Amend an Annual Report • Upload a PDF Filing • Order a Document Online -
Add Entity to My Email Notification List • View Filings • Print a Pre-Populated Annual Report form • Print
an Amended a Annual Report form
Limited Liability Company
Legal Name
Culpeper of Cove City, LLC
Information
Sosld: 1668590
Status: Current-Active O
Date Formed: 2/20/2018
Citizenship: Foreign
State of Incorporation: VA
Annual Report Due Date: April 15th
Currentgnnual Report Status:
Registered Agent: Corporation Service Company
Addresses
Reg Office Reg Mailing Mailing
2626 Glenwood Ave Ste 550 2626 Glenwood Ave Ste 550 501 N Main Street
Raleigh, NC 27608 Raleigh, NC 27608 Culpeper, VA 22701
Principal Office
501 N Main Street
Culpeper, VA 22701
Company Officials
All LLCs are managed by their managers pursuant to N.C.G.S. 57D-3-20.
Secretary Chief Executive Officer President
Doris Batiste Joseph R. Daniel Joseph R Daniel Jr
501 N Main Street 501 N Main Street 501 N Main Street
Culpeper VA 22701 Culpeper VA 22701 Culpeper VA 22701
https://www.sosnc.gov/online_services/search/Business_Registration_ResuIts 1/2
4/20/23, 1:13 PM North Carolina Secretary of State Search Results
https://www.sosnc.gov/onIine_services/search/Business_Registration_ResuIts 2/2
Young, Brianna A
From: Young, Brianna A
Sent: Monday, April 10, 2023 2:14 PM
To: jadkins@culpeperwood.com
Subject: Culpepper of Ramseur(NCS000452) and Culpepper of Cove City(NCS000456)
Good afternoon,
The Division of Energy, Mineral, and Land Resources (DEMLR) Stormwater Permitting Program
acknowledges receipt of your renewal applications for coverage under NPDES Permit Number NCS000452 and
NCS000456. Please continue to comply with all conditions and monitoring requirements in your current
NPDES stormwater permits. As long as you have submitted a complete renewal request package and maintain
compliance with those permit conditions, stormwater discharges from these facilities are authorized by that
permit until the Division issues a renewal permit or notifies you of an alternative action. Please let me know if
you have any questions in the interim.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
Brianna.Young@ncdenr.gov(e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
z_..-���D_ E '�&'�
ti ;
NORTH CAROLINA
Department of Environmental Quality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
1
Permit Coverage
Renewal ARDlication Form
National Pollutant Discharge Elimination System NP Permit Number
NCS 000456
Environmental Stormwater Individual Permit
Quality
Please provide your permit number in box in the upper right hand corner, complete the information in the space provided
below and return the completed renewal form along with the required supplemental information to the address indicated.
Owner Information * Address to which permit correspondence will be mailed
Owner/ Organization Name: Culpeper of Cove City,LLC Owner Contact: Josh Adkins P r T I V�C
D
Mailing Address: 11065 Old Hwy 70 W,Cove City,NC 28523 ✓I �.
11065 Old Hwy 70 W,Cove City,NC 28523 MAR 10
2021 .� 1�V-(CCJJ
Phone Number: 803-566-3270 PENR-LAND QUALITY
Fax Number: 4EIRUih!ATER PERilITTING
E-mail address: jadkins@culpeperwood.com
Facility Information
Facility Name: Culpeper of Cove City,LLC
Facility Physical Address: 11065 Old Hwy 70 W,Cove City,NC 28523
Facility Contact: Josh Adkins
Mailing Address: 11065 Old Hwy 70 W,Cove City,INC 28523
Phone Number: 803-566-3270
Fax Number:
E-mail address: jadkins@culpeperwood.com
Permit Information
Permit Contact: Josh Adkins
Mailing Address: 11065 Old Hwy 70 W,Cove City,NC 28523
Phone Number: 803-566-3270
Fax Number:
E-mail address: jadkins@culpeperwood.com
Discharge Information
Receiving Stream: Core creek
Stream Class: C;Sw,NSW
Basin: Neuse
Sub-Basin: 03-04-08
Number of Outfalls: 1
Facility/Activity Changes Please describe below any changes to your facility or activities since issuance of your permit. Attached a
separate sheet if necessary.
No significant changes.
CERTIFICATION
I certify that I am familiar with the information contained in the application and that to the best of my knowledge and belief
such information is true, cplete and accurate.
Signature Date 03/03/2021
4J.shdkins E&S Director
Print or type name of person signing above Title
Please return this completed application form DEMLR- Stormwater ProgramDept. of Environmental Quality
and requested supplemental information to: 1612 Mail Service Center
Raleigh, North Carolina 27699-1612
SUPPLEMENTAL INFORMATION REQUIRED FOR RENEWAL OF INDIVIDUAL
NPDES STORMWATER PERMIT
Two copies of each of the following shall accompany this submittal in order for the application
to be considered complete:
(Do not submit the site Stormwater Pollution Prevention Plan)
Initials
JA 1. A current Site Map from the Stormwater Pollution Prevention Plan. The location of
industrial activities (including storage of materials,disposal areas, process areas and
loading and unloading areas), drainage structures, drainage areas for each outfall,
building locations and impervious surfaces should be clearly noted.
JA 2. A summary of Analytical Monitoring results during the term of the existing permit
(if your permit required analytical sampling). Do not submit individual lab reports.
The summary can consist of a table including such items as outfall number,
parameters sampled, lab results, date sampled,and storm event data.
JA 3. A summary of the Visual Monitoring results. Do not submit individual monitoring
reports. The summary can consist of a table including such items as outfall number,
parameters surveyed, observations,and date monitoring conducted.
J A 4. A summary of the Best Management Practices utilized at the permitted facility.
Summary should consist of a short narrative description of each BMP's in place at
the facility. If the implementation of any BMP's is planned,please include
information on these BMP's.
JA 5. A short narrative describing any significant changes in industrial activities at the
permitted facility. Significant changes could include the addition or deletion of
work processes, changes in material handling practices, changes in material storage
practices, and/or changes in the raw materials used by the facility.
JA 6. Certification of the development and implementation of a Stormwater Pollution
Prevention Plan for the permitted facility(Sign and return attached form).
If the final year analytical monitoring of the existing permit term has not been completed
prior to filing the renewal submittal,then the last years monitoring results should be submitted
within 30 days of receipt of the laboratory reports. (i.e. do not withhold renewal submittal
waiting on lab results)
CULPEPER OF COVE CITY, LLC
Craven County
Permit#NCS000456
Treated Wood StorageHazardous Waste Storage
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(UT—Core Creek)
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► '' ` 35.189895 N 77.336468 W
DCA TP �
Ditch surrounds property. Property has underground drainage system to pond.
Water flows to pond or ditch, which meet at outfall
M = Maintenance Shop Area
TP =Treating Plant, chemical storage
F= Fueling area and storagewy
E= Evacuation Meeting Location
r- f
Cove City Outfall 001 Permit#NCS000456
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mg/I mg/l mg/I mg/l mg/I mg/l mg/I mg/I mg/l mg/I mg/l su mg/I mg/I mg/I mg/l
Jul-18 47 100 0.003 0.36 0.0029 1 t�.C1'd:_b 0.007 54 120 4 8.10 BDL 0.2 1.3 2
Dec-18 14 100 BDL 0.36 0.001 1 0.0049 0.007 BDL 120 BDL 7.96 BDL 0.08 1.1 5.2
May-19 170 100 0.062 0.34 0.220 1 0.1600 0.01 50 120 20 7.30 2.50 0.23 1.6 0.23 300
Aug-19 32 100 BDL 0.34 BDL 1 0.0040 0.01 32 120 BDL 7.10 BDL 0.10 0.61 0.45 110
Mar-20 5.4 100 BDL 0.34 0.0019 1 0.0320 0.01 BDL 120 4.6 7.00 2.20 0.22 3.7 1.8 92
Sep-20 25 100 0.005 0.34 0.003 1 0.0520 0.01 27 120 4.5 6.90 BDL 0.17 0.70 0.79 76
Sep-20 14 100 BDL 0.34 0.001 1 0.01 0.01 27 120 2.7 5.80 BDL 0.19 1.20 4.8 58 Monthly Due
Oct-20 6.8 100 BDL 0.34 BDL 1 0.01 0.01 31 120 2.1 5.60 3.50 0.10 1.40 9 88 to High
Nov-20 7 100 BDL 0.34 0.001 1 0.0015 0.01 56 120 5.4 5.90 BDL 0.15 1.50 4 1 46 Copper
Cove City Visual Inspections
Outfall 01 Permit# NCS000456
Other
Floating Suspended Obvious
Color Odor Clarity Solids Solids Foam Oil Sheen Indicators
07/24/18 None None Clear No No No No None
12/20/18 None None Cloudy No No No No None
05/31/19 None None Clear No No No No None
08/23/19 None None Clear No No No No None
03/23/20 None None Clear No No No No None
09/11/20 None None Clear No No No No None
09/30/20 None None Clear No No No I No I None
10/26/201 None None Clear No No No No None
11/13/201 None None Clear No No No No None
CULPEPER OF COVE CITY, LLC
CRAVEN COUNTY
PERMIT# NCS000456
SIGNIFICANT CHANGES
There have been no significant changes to our process or chemicals over the years with one exception.
Historically this facility operated both treatment areas using an inorganic arsenical wood preservative. One
treatment area has been converted to a non-arsenical copper-based preservative for residential use.
BEST MANAGEMENT PRACTICES
The purpose of the SWPPP is to identify potential sources of pollution or contamination that originate at this
facility, and to select and implement actions which prevent or minimize the release of pollutants into the storm
water. The storm water management controls included in the SWPPP focus on providing adequate control of
pollutant discharges with practical approaches that utilize readily available techniques, expertise, material and
equipment.
The SWPPP is intended to be a flexible, active operations plan to allow incorporation of changes and
management practices. As the plan is implemented and methods to improve the plan are found, or as
regulations change, revisions to the plan must be made. Revisions to the plan must be approved by
management and recorded in all copies of the plan in order to meet the requirements of the storm water permit.
This is a wood preservation facility. Untreated lumber is brought on site for treatment using either an inorganic
arsenical (CCA) or a copper based (copper azole) amine formula. All chemicals used in the treatment process
are kept inside containment areas. Waters accumulated inside these containment areas are used back in the
process. All freshly treated lumber is kept under cover, on a RCRA Subpart W drip pad until drippage has
ceased. There are several storage sheds where we store as much of the treated lumber as possible. Any
remaining lumber is kept on the yard until sold.
Forklifts and other vehicles are regularly inspected and maintained by the maintenance department. All
maintenance work is done under cover. Any oil or chemicals used at the maintenance department are kept
inside the maintenance building or under cover. All bulk oil tanks have secondary containment and is roofed,
along with drip pans under the nozzles. A diesel unloading containment area has been installed by the diesel
tanks. Any water accumulated within this unloading containment is either pumped out, reused in our wood
treatment process, or if contaminated with oil, is shipped for recycling.
At this time, based upon a review of our current procedures for reducing or eliminating exposure of materials to
storm water, we have determined that it is not economically feasible to modify our program. We have our
maintenance area inside a building, all oil tanks in secondary containment, all chemicals in secondary
containment or under cover and numerous sheds to store lumber in. The lumber stored outdoors is dry, stacked
to minimize exposure and inventory controlled to reduce potential exposure to a rain event. Housekeeping
procedures are in place to regularly remove debris in the yard and inspect around our maintenance and treating
plant for chemical contamination.
BEST MANAGEMENT PRACTICES -MEASURES AND CONTROLS
The results of a site assessment indicate that controls are either in place or need to be added to minimize
contaminant releases to storm water runoff. Housekeeping is one area that can be readily controlled to limit the
discharge of wood debris and minimize the generation of dust.
Best Management Practices (BMPs) as well as other controls are used to reduce potential contaminant
releases. Some of our controls are as simple as ensuring that we maintain vegetation, such as grass on slopes
to prevent soil erosion and keeping outfall areas clean and free of debris.
Culpeper of Cove City, LLC—Craven County Page 1 of 5
Permit#NCS000456
All chemical bulk storage tanks are within secondary containment. None of our secondary containment
structures have any type of drainage system. Only personnel placing a pump into the diesel containment area
can remove liquid. This method prevents any release of oil from our containment system due to rain. Our
chemical storage containment areas that are not located inside a building have automatic pumps that will pick
up liquid and place it into a bulk storage tank located within a containment area. This liquid is then used in our
treating processes.
Most hose as well as the trailer connection section is inside a containment area. If any tank or hose
connections would have to be outside the contained area due to an unusual circumstance, each connection
would have a bucket underneath to catch drips and minor leaks. A qualified employee with access to the proper
safety equipment approves the hook up to our tank prior to unloading and monitors the loading and unloading
process.
All non-bulk containers, such as drums, are stored either indoors or within a contained area.
Finished lumber products are stored under sheds or in the yard until shipment. The lumber trucks are loaded
over asphalt or gravel areas. Prior to storing any treated lumber outdoors,verification that there is no drippage
has been documented.
The drip pads are under roof and bermed/sloped to prevent any release. Any liquid generated from drippage or
a rain event flows to a sump and then is automatically picked up and place into an effluent tank. Visual, as well
as some documented Inspections are regularly performed on the drip pad and maintenance, such as sealing or
cracks and coating replacement, is performed as needed.
All cutting of lumber is currently performed outdoors. Since this is a wood preservation facility and not a planer
or sawmill, very little sawdust is generated due to the cutting of lumber. Typically, the total amount generated
during a cutting would be a pile less than 2' by 2'. Frequency of cutting is one or two times weekly. This
operation is pre-scheduled so cutting is not performed during a rain event and the sawdust and debris is picked
up from the Holtech Saw immediately and placed in containers. There is also a small saw operation used once
or twice weekly to cut a few pieces of lumber. The pile generated is generally less than 1' by 1' on a concrete
pad. The sawdust is disposed of as a non-hazardous waste.
Various types of equipment associated with this wood preserving facility include but are not limited to pressure
retorts, mechanical pumps, fueling trucks, maintenance equipment, freight transfer vehicles, construction
equipment and forklifts.
Trucks, trailers, and forklifts are cleaned in an enclosed, roofed area designed for this purpose. The water is
reclaimed through an oil water separator.
It is recognized that maintenance of vehicles can be a significant source of storm water pollutants. Materials
associated with vehicle maintenance include waste oil, solvents and other degreasers, brake fluid, anti freeze,
battery acids, radiator flush, and sludge. The following vehicle maintenance practices are utilized:
- Maintenance is completed in an enclosed area protected from runoff and precipitation whenever
possible. If maintenance has to be performed outside of the enclosed area, all possible means are
used to prevent spillage and approved cleaning methods (oil dry, etc)are used if any spillage
occurs.
- All used products are properly stored until they are sent for recycling or disposal.
- Batteries, used tires, and used solvents are collected and recycled through the appropriate vendors
(Typically batteries are recycled immediately, so there is minimal to no storage).
Culpeper of Cove City,LLC—Craven County Page 2 of 5
Permit#NCS000456
A feasibility review to determine if there is a way to modify or change our operating procedures or install controls
to further reduce chemical exposure indicates the following:
o Non-bulk chemical containment—All non-bulk chemicals are currently stored in secondary containment
areas or under roof.
o Chemical unloading—Chemical unloading is performed under roof or in containment areas that will
allow the end of the trailer to be placed within this containment. Most hose connections at the tanks for
bulk loading or unloading are inside the bulk storage containment area. Any tank or hose connections
outside the contained area would have buckets underneath to catch drips and minor leaks. A qualified
employee with access to the proper safety equipment approves the hook up to our tank prior to
unloading and monitors the loading and unloading process.
o Chemical containment—All chemicals are currently stored in secondary containment systems that
cannot release without manual pumping.
o Particulate containment—Generation of sawdust is currently performed outdoors. Since these
procedures are used infrequently and can be pre-scheduled to ensure we do not release particulates
during a rain event, at this time there is no need to change our procedures or modify the location.
Sometime in the future, if there is an increase in the cutting of lumber, then moving or enclosing the saw
areas will be addressed.
o Diesel storage—The diesel tanks used to fuel lifts and tractors are located within a secondary
containment system that cannot release without manual pumping. Filling the tank and fueling
procedures are performed just outside the containment area. Current procedures and training are in
place to prevent a release on the ground as well as emergency equipment availability at the diesel area
to handle a release immediately to prevent rain event contamination. At some point in the future, we will
look at changing the diesel storage area to prevent rain from accumulating inside the containment area.
o Treated wood storage—Treated lumber is typically stored outdoors. Prior to placing the treated lumber
outdoors, the material is documented that all drippage has ceased. This procedure should ensure that
there is minimal release of chemicals during a rain event from the treated lumber. The lumber is also
not placed directly on the ground, but stored 2-6" above to prevent contact.
To ensure that the BMPs and other controls are in use and working, employees are taught about controls in use
and periodic inspections are performed.
The measures currently in use or to be implemented at our facility to control contaminant releases are found
under section 4.a.
Culpeper of Cove City,LLC-Craven County Page 3 of 5
Permit#NCS000456
4.a. Effective Pollutant control Options for Timber Product Facilities
Activity Associated BMPs In Use Remarks
Lumber, and Divert Storm water around storage areas with ditches, X
other Wood swales and/or berms
Product Storage Locate storage areas on stable,well-drained soils with X 80%of yard
Areas slope of 2-5 percent
(Untreated) Line storage areas with crushed rock, gravel or porous X
pavement to promote infiltration, minimize discharge and
provide sediment and erosion control
Stack materials to minimize surface area of materials X Sheds are in
exposed to precipitation use also
Frequent removal of debris X
Provide collection of runoff with containment basins,
sedimentation ponds and infiltration basins X
Activity Associated BMPs In Use Remarks
Residue Storage Locate storage residues away from drainage pathways X
Areas and surface waters
(such as Avoid contamination of residues with oil,solvents, X
untreated chemically treated wood,trash, etc.
sawdust, chips) Assemble piles to minimize surface area of materials X
exposed to precipitation
Limit storage time of residues to prevent degradation X
and generation of leachates
Place materials on raised pads of compacted earth, clay, X
shale, or stone to collect and drain runoff
Limit slopes of storage areas to minimize velocities of X
runoff which may transport residues
Activity Associated BMPs In Use Remarks
Loading and Provide diversion berms and dikes to limit runon X
Unloading,
Material Provide good housekeeping measures to limit debris and X
Handling Areas to provide dust control
Activity Associated BMPs In Use Remarks
Wood Extend drip time on drip pad (process area) before X
Preservation moving to storage
Activities Pave and berm areas used by equipment that has come in X
contact with treatment chemicals
Locate treatment chemical loading and unloading areas X
away from high traffic areas where tracking of the
chemical may occur.
Provide frequent visual inspections of loading and X
unloading areas during and after activities occur to
identify any spills or leaks needing clean-up
Cover and/or enclose treatment areas X
Elevate stored, treated wood products to prevent contact X Heavy retention
with runon/runoff undershed
Provide collection of runoff with containment basins, X
sedimentation ponds and infiltration basins for treated
wood storage areas
Culpeper of Cove City,LLC—Craven County Page 4 of 5
Permit#NCS000456
Activity Associated BMPs In Use Remarks
Chemical Provide secondary containment around chemical storage X
Storage Areas areas
Provide level gages X
Inventory fluids to identify leakage X
Locate storage areas away from high traffic areas and X
surface waters
Develop spill prevention, containment and X
countermeasure SPCCplans and implement
Cover and/or enclose chemical storage areas X
Provide containment to allow for recycling of spill and X
leaks
Activity Associated BMPs In Use Remarks
Equipment Provide diversion berms and dikes to limit runon X
and/or vehicle
maintenance Preventative maintenance program (cleaning oil/water X
and cleaning separators, catch basins, vehicle mounted drip
containment devices
Minimizing storm water runon and runoff at fueling areas. X
Perform all maintenance activities indoors X
Cover and/or enclose chemical storage areas (used oil, X
oil filters, used solvents, etc.
Locate storage areas away from high traffic areas X
Activity Associated BMPs In Use Remarks
Erosion and Grassed areas to prevent soil erosion X
Sediment
Controls Use of vegetation on sloped areas to prevent sediment X
run-off
Ditches around property to prevent water run on from X
neighboring locations
Sediment Trap(Such as rock,vegetation, etc.) X
Culpeper of Cove City,LLC—Craven County Page 5 of 5
Permit#NCS000456
CULPEPER OF COVE CITY, LLC
COVE CITY, NC
PERMIT# NCS000456
INDUSTRIAL ACTIVITY SIGNIFICANT CHANGES
This facility is still operating with no significant changes from the previous
permit application. They are still using the same wood preservative and have
not added any new equipment.
STORMWATER POLLUTION PREVENTION PLAN
DEVELOPMENT AND IMPLEMENTATION
CERTIFICATION
North Carolina Division of Energy, Mineral, and Land Resources— Stormwater Program
Facility Name: Culpeper of Cove City,LLC
Permit Number: NCS000456
Location Address: 11065 Old Hwy 70 W,Cove City,NC 28523
County:
Craven
"I certify, under penalty of law, that the Stormwater Pollution Prevention Plan (SPPP) document and all
attachments were developed and implemented under my direction or supervision in accordance with a system
designed to assure that qualified personnel properly gather and evaluate the information required by the SPPP.
Based on my inquiry of the person or persons who manage the system, or those persons directly responsible
for gathering the information, the information gathered is, to the best of my knowledge and belief, true,
accurate and complete."
And
"I certify that the SPPP has been developed, signed and retained at the named facility location, and the SPPP
has been fully implemented at this facility location in accordance with the terms and conditions of the
stormwater discharge permit."
And
"I am aware that there are significant penalties for falsifying information, including the possibility of fines and
imprisonment for knowing violations."
Sign (according to permit signatory requirements) and return this Certification. DO NOT
SEND STORMWATER POLLUTION PREVENTION PLAN WITH THIS CERTIFICATION.
Signature 4C Date 03/03/2021
Josh Adkins E&S Director
Print or type name of person signing above Title
SPPP Certification 10/13