NCS000452_Staff Report_20090417

NCS000452
OF \NA rt- Beverly Eaves Perdue, Governor
G
Dc(, Secretary
`O
G1 North Carolina Department of Environment and Natural Resources
={ Coleen H. Sullins Director
Q Division of Water Quality
STAFF REVIEW AND EVALUATION
NPDES Stormwater Permit
Facility Name:
NPDES Permit Number:
Facility Location:
Type of Activity:
SIC Code:
Receiving Streams:
River Basin:
Stream Classification:
Proposed Permit Requirements
Monitoring Data:
Response Requested by (Date):
Central Office Staff Contact:
Special Issues:
Structural Woods Preserving Co.
NCS000452
4034 Hwy 22 South, Ramseur, NC (Randolph County)
Wood Preserving
2491
See Figure 1
Cape Fear River Basin, Sub -basin 03-06-09
C
See attached draft permit.
No previous analytical monitoring
Return to: Brian Lowther, [phone]
Issue
Rating Scale: 1(easy) to 10(hard)
Compliance history
3
Benchmark exceedance
3
Location (TMDL, TIRE
species, etc)
6
Other Challenges:
• Researching
Treatment
4
Difficulty Rating;
16140
Description of Onsite Activities: Wood Treatment Plant. Used dispersed copper, Changed from copper
azole last February (2008).
Documents Reviewed:
• NPDES Stormwater Permit Application Materials
• National Heritage Program (NHP) Threatened and Endangered Species Database
• SPU File
• Central Files
• EPA Sector -Specific Permit, 2008
• 303(d) List, 2008 draft, 2006 final
• 2005 Cape Fear Basinwide Plan
Page 1 of 7

NCS000452
History:
• August 15, 2003:
• January 25, 2007:
• February 16, 2007
Date permit first issued. The permit does not include any analytical monitoring.
Permit Renewal reminder letter.
Date permittee submitted renewal application.
Page 2 of 7

NCS000452
Figure 1: Map of Facility
Page 3 of 7
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NCS00452
Structural Wood Preserving Company
i l
Lab tude: 350 39' 30" N
Longitude: 790 37' 04" W
County: Randd
ph
Receiving Stream: Deep R ver
Stream Class: C
Sub -basin; 03-06-09 (Cape Fear River Basin)
Facility Luca tion
Map Scale 1.24,000
11
Page 3 of 7

NCS000452
Central Office Review Summary:
1. Owner's Other Permits: None
2, General Observations: Below is the product list for the site from
http://www.coxwood.col-n/about—coxwood—locations—swp.shtml.
Products:
• Wet Lumber
• Boards
• Dimensional Lumber
• Outdoor Wood-KDAT (Kiln dried after treatment)
• Decking (Durapine Decking, Durapine Classic)
• Columns (Square timber and laminated columns)
• Round Posts
• Square Posts, Timbers
• Fencing
• Outdoor Furniture
• Plywood
• Porch Flooring
• Treating and drying services
• All Cox Industries products by special order
Impairment: Deep River 17-(10.5)el is on the 2006 303(d) for turbudity. Basinwide Plan shows stressors for Deep
River 17-(10.5)d that include Chlorophyll a, Turbidity, Habitat Degradation and Fecal Colifrom Bacteria. 2005
recommendations for Deep River (17-(10.5)el and 17-(10.5)d) include DWQ and the UCFRBA will continue to
monitor these segments of the Deep River. The NPDES compliance process will be used to address the significant
permit violations noted above. Segment 17-(10.5e1) will be added to the 303(d) list of impaired waters. TMDLs will
be developed for identified stressors within 8-13 years of listing.
4. Threatened and Endangered: There is one species that is federally protected within a 2 mile radius of the site.
The species is the Cape Fear Shiner, Notropis mekistocholas which is classified as endangered. There are some
species that are state protected and these are included in the permit file.
5. Location: Receiving water is classified as a C stream.
6. Industrial Changes Since Previous Permit: The only significant change in industrial activities was in 2003.
Cbromated copper arsenate (CCA) wood preservative was replaced with a non -arsenical copper amine formula
(Copper Azole).
7. Analytical Monitoring Notes: No analytical monitoring was required in the last permit.
The 2008 EPA Multi -Sector general permit for Sector A recommends monitoring for Total Arsenic and Total
Copper for SIC 2491, Wood Preserving. Copper was added to monitoring since the process being used, MCQ,
contains copper. Arsenic is not in any current processes and not added to the monitoring. TSS was added as a
potential pollutant.
BODS and COD have been added to other timber treated sites in our program because high levels of these
pollutants in surface waters were found along the properties of timber facilities. Therefore, COD and BODS
have been added to the renewal permit.
Qualitative Monitoring Notes: Visual monitoring was done seven times for two different outfalls from 9123103
to 7125106. The monitoring shows no signs of pollutants and is all the same except for the last entry where the
water color is a light tan.
Page 4 of 7

NCS000452
Revised Permit Recommendations: Analytical Monitoring:
1. Adding parameters Cu, TSS, COD, and BODS.
2, pH has been added to the analytical monitoring requirements.
3. All analytical monitoring has been set to semi-annually during a representative storm event as defined in Part 11
Section B. The permittee must also document the total precipitation for each event. If no discharge occurs
during the sampling period, the permittee must submit a monitoring report indicating "No Flow" within 30 days
of the end of the six-month sampling period. Additionally, samples must be taken a minimum of 60 days apart,
as specified in Table 2.
4. Benchmarks for analytical monitoring have been added to this draft permit. Exceedances of benchmark values
require the pennittee to increase monitoring, increase management actions, increase record keeping, and/or
install stormwater Best Management Practices (BMPs) in a tiered program. If the sampling results are above a
benchmark value, or outside of the benchmark range, for any parameter at any outfall then the facility shall
follow the Tier 1 guidelines which require a facility inspection within two weeks and implementation of a
mitigation plan within two months. If during the term of this permit, the sampling results are above the
benchmark values, or outside of the benchmark range, for any specific parameter at a specific discharge outfall
two times in a row (consecutive), then the facility shall follow the Tier 2 guidelines which require a repetition of
the steps listed for Tier 1 and also immediately institute monthly monitoring for all parameters at every outfall
where a sampling result exceeded the benchmark value for two consecutive samples.
5. The permittee is required to collect all of the analytical and qualitative monitoring samples during representative
storm events as defined in Part II Section B. Qualitative monitoring is required regardless of representative
outfall status.
6. The permittee is responsible for all monitoring until the renewal permit is issued. See Footnote 1 of Tables 1, 4,
and 5.
7. The flow reporting requirement has been removed per DWQ revised strategy. (The total rainfall parameter is in
this permit, however.)
8. Vehicle maintenance monitoring has been revised to semi-annually in order to coincide with analytical and
qualitative monitoring.
Other Proposed Changes to the Previous Permit:
1. Additional guidance is provided about the Site Plan requirements. The site map must now identify if the
receiving stream is impaired and if it has a TMDL established. It must also describe potential pollutants in each
outfall. The map requirements are stated more explicitly. And, the site plan must contain a list of significant
spills that have occurred in the past three years and also must certify that the outfalls have been inspected to
ensure that they do not contain non-stormwater discharges. Additional information is provided in Part H Section
A.
2. Additional requirements for the Stormwater Management Plan have been specified in Part H Section A. More
details regarding secondary containment are provided.
3. Additional requirements for the Stormwater Pollution Prevention Plan have been specified in Part H Section A.
The plan must also be updated annually to include a list of significant spills and to certify that the outfalls do not
contain non-stormwater discharges.
4. The facility must now implement a semi-annual Facility Inspection Program of the site's stormwater
management controls as specified in Part 11 Section A.
Infonnation regarding the No Exposure Exclusion has been added to this draft permit. If industrial materials and
activities are not exposed to precipitation or runoff as described in 40 CFR § 122.26(g), the facility may qualify
for a No Exposure Exclusion from NPDES stormwater discharge permit requirements. Additional information
is provided in Part I Section A.
Page 5 of 7

NCS000452
Discussions with permittee; .ferry Pugh, [phone], 1129109
L General description of industrial activities? What wood preservatives are currently being used? Wood
Treatfnent Plant. Used dispersed copper.
2. Have there been, any changes since filing the application? No
3. How many outfalls do you have? 2 Outfalls.
4. Do you have vehicle maintenance onsite? Fork Lift inaintenance.
5. What is you SIC code? 2491
Page 6 of 7

NCS000452
Recommendations: Based on the documents reviewed, the application information submitted on 02/16/07
sufficient to issue an Individual Stormwater Permit.
Prepared by (Signature) Date Z 9 9
Storinwater Pei inining Unit Supciviso 6L Urate `L 9 0-j
for Bradley ennett
Concurrence by Regional Office Date__' v�)' - n
RO Water Quality Supervisor.
Date
Regional Office Staff Comments (attach additional pages as necessary)
m
Page 7 of 7

StrLlCtural Wood Preserving - NCS000452
Subject: Structural Wood Preserving - NCS000452
From: Mike Mickey <[e-mail]>
Date: Wed, 04 Feb 2009 14:31:35 -0500
To: Brian Lowther <[e-mail]>
Brian 1 inspected the above facility yesterday. 'Their SPPP wars excellent and all qualilalive ri1u11iluairrg
had been performed. Since new motor oil usage averages <5 gallons per month, analytical monitoring for
on-site vehicle maintenance is not required. No concerns or problems were noted. WSRO recommends
reissuance. Mike
Mike Mickey
NC DENR Winston-Salem Regional Office
Division of Water Quality, Water Quality Section
585 Waughtown Street
Winston-Salem, NC 27107
Main Office: [phone]
Voice: [phone]
FAX: [phone]
E-mail correspondence to and from this address may be subject to the
North Carolina Public Records Law and may be disclosed to third parties.
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