NCS000222_Staff Report_20070726

NCS 000222
\O�OF W AT F9QG
00
� Y
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
STAFF REVIEW AND EVALUATION
NPDES Stormwater Permit
Coleen H. Sullins. Director
Division of Water Quality
Facility Name:
General Wood Preserving Company
NPDES Permit Number:
NCS000222
Facility Location:
Leland, NC (Brunswick County)
Type of Activity:
Wood Preserving
Receiving Streams:
Alligator Branch/Sturgeon Creek, See Figure 1
River Basin:
Cape Fear River Basin, Sub -basin 03-06-17
Stream Classification:
C, SW/ C, SW
Proposed Permit Requirements:
See attached draft permit.
Monitoring Data:
See Table 1
Facility Location:
See Figure 1
Response Requested by (Date):
Central Office Staff Contact:
Kelly Johnson, [phone], ext. 376
Documents Reviewed:
• NPDES Stormwater Permit Application Materials
• Stormwater Permit File
• Cape Fear River Basinwide Plan
• Draft 2006 303(d) List
• EPA Sector -Specific Permit, 2006 draft
• Check 40 CFR Subchapter N, Stormwater Effluent Guidelines
Summary of Industrial Activity:
• Manufactures treated wooden poles and pole cross -arms; logging
History:
• 1 February 1995: Permit originally issued. The following analytical monitoring was required annually, At,
Cu, Cr, pentachlorophenol, phenol, Zn, benzene, toluene, naphthalene, anthracene, total ammonia, total
xylenes, oil and grease, BOD, COD, P, TSS, TKN, and pH. No cut-off concentrations were included.
Visual monitoring was required semi-annually. Vehicle maintenance monitoring was required annually.
• 1 March 2000: Permit was re -issued. Phosphorus monitoring was replaced with total phosphorus.
Monitoring was required annually for years 1-3, and quarterly in year 4.
• 30 July 2004: Permit application received.
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 [phone] Customer Service
1-877-623-6748

NCS000222
• 10 May 2005: Email from Daphne Olszewski (Brownfields Program Manager) on file. Dioxins have been
discovered onsite and two areas will be capped. A prospective purchaser of the site tested for dioxins
downstream and the results showed that the levels were below both environmental and human exposure risk
levels. She requests that we add dioxin as an analytical monitoring requirement when the permit is re -issued
in order to simplify RCRA regulation of this site.
• 16 May 2007: Email with Sandra Moore (Brownfields Program) (Daphne has left the position). She
recommended that in addition to testing for dioxin, to also test for arsenic, copper and chromium because
these parameters were detected in an outfall sample at the site, and samples were above the surface water
standards.
• 21 May 2007: Attempted to call General Wood's President, Karl Boatwright, 910.371.3131 with general
questions. This phone number is for Cox Industries. The receptionist said that Cox is not associated with
General Wood and that Mr. Boatwright did not work there. Yellowpages.com has the same number. EPA
has the same number. Called receptionist twice. Sent Mr. Boatwright a letter requesting updated contact
information.
• 20 July 2007: Talked to the new contact, Mike Rouse.
Central Office Review Summary:
1. General Observations:
o This is a brownfield site.
All required analytical monitoring was not conducted.
The following detection limits need to be altered for the upcoming cycle. They are not sufficient to detect
the compound. (Compound: Detection limit/benchmark):
1. Pentachlorophenol: 30 mg/L: 0.019 mg/L
2. Toluene: 1.0 mg/L: 0.055 mg/L
3. Napthalene: 10 mg/L: 1 mg/L
4. Anthracene: 10 mg/L: 0.005 mg/L
2. Impairment:
o Alligator Branch: Not addressed in the Basinwide Plan. No TMDL.

NCS000222
o Sturgeon Creek: Not addressed in the Basinwide Plan. No TMDL.
3. Threatened and Endangered Species: None found. This facility drains to Alligator Branch and Sturgeon Creek.
Both of these animals appear near this area of the State (as I have learned for permits nearby), but not near this
facility. The American Alligator and the Short Nosed Sturgeon are both endangered, but have not been
identified in the Natural Heritage database as existing in the area near this facility (despite the fact that the
receiving streams are named for these animals.)
4. Chanties Since Previous Permit: No significant changes
5. Analytical Monitoring:
o All of the required samples were not collected.
o At, Cu, Cr, and Zn were not specified in the previous permit to sample for "total recoverable". Need to
specify this for the upcoming permit.
o Copper was high 50% of the time.
Table 1: Analytical Monitoring, Previous Cycle
"Over
Current
Benchmark
No Sample
Collected
Sam
IIng Dates & Re ulred Sampling Date Ranges
Sample
Sample
Sample
Sample
No
No
No
No
Date:
12 Feb 01
Sample
Date:
10 Se 02
Date:
16 Fab 03
Sample
Sample
Sample
Date:
12 Feb 04
Parameter
Benchmark
Reported Units
Notes
Required
Required
Required
Required
Required
Required
Date:
Date:
Required Date:
Date:
Date:
Date:
Date:
1 Maf00-
1Mar 01-
1Mar 02-28 Feb 03
1Mar 03-
1Jun 03-
1Sep 03-
IDec 03-
28 Feb 01
28 Feb 02
30 May 03
31 Aug 03
30 Nov 03
29 Feb 04
Total Recoverable.
Arsenic
0.3
0.073
0.10
0.032
0.01
ppm
'Total Recoverable
not in permi
Total Recoverable.
Copper
0.007
0.006
0.00
ppm
"Total Recoverable
not in permi
Total Recoverable.
Chromium
1
0.119
0.01
0.04
0.01
ppm
'Total Recoverable'
not in permi
Pentachlorophenol
0.019
BOL
<30
<30
<30
ppm
Phenol
4.5
<0.010
0.007
<0.005
<0.005
ppm
Total Recoverable.
Zinc
0.067
0.045
<.005
0.009
0.00
ppm
"Total Recoverable
not in permi
Benzene
6.7
<1.0
<1.0
<0.50
<1.4
ppm
Toluene
0.05
<1.0
<1.0
<0.50
<1.4
ppm
Naphthalene
1
BOL
<10
<10
<101
ppm
QL too high
Anthracene
0,005
BQL
<101
00
<1
ppm
OL too high
Total Ammonia
7.21
0.2
<0.20
<0.10
0.111
ppm
Total xylenes
6.7
<1.0
<1.0
<0.50
<1.
ppm
Oil & Grease
3
2
6.6
<5
<
ppm
BOD
30
6
<2
6
ppm
5 -Day. "5 -Day" not i
permi
COD
12
87
65
54
5
ppm
TP
0.49
0.0
0.12
0.0
ppm
TSS
10
5
17
ppm
TKN
20
1.03
<0.250
<0.10
0.
ppm
PH
fi-
7.5
7.52
7.01
7.4
standard
"Over
Current
Benchmark
No Sample
Collected

NCS000222
Revised Permit Recommendations: Analytical Monitoring:
1. Dioxin has been added per the Brownfields Program's recommendations.
2. Brownfields Program also recommended the following analytical requirements: Arsenic, Copper, and
Chromium. These were already in the facility's testing parameters from the previous permit. "Total
Recoverable" has been specified for these parameters. "Total recoverable" was also specified for Zinc.
3. pH has been added to the analytical monitoring requirements per DWQ's revised strategy.
4. Due to a potential lag time between the expiration of this permit and its renewal, I have specified in the permit
that the permittee is responsible for all monitoring until the renewal permit is issued. See Footnote 1 of Tables
1, 4, and 5. This approach is recommended because there has been a significant lag time since the expiration of
the previous cycle. This will provide testing if there is a lag in future timeframes. "Measurement Frequency: All
analytical monitoring will be performed two times per year for each year until either another permit is issued for
this facility or until this permit is revoked or rescinded. If at the end of this permitting cycle, the permittee has
submitted the appropriate paperwork for a renewal application before the submittal deadline, the permittee will
be considered for a renewal application. The applicant must continue semi-annual analytical monitoring until
the renewed permit is issued. See Table 2 for schedule of monitoring periods through the end of this permitting
cycle."
5. Benchmarks have been added to this draft permit.
6. All analytical monitoring has been set to semi-annually.
7. The flow reporting requirement has been removed per DWQ revised strategy. (The total rainfall and event
duration parameters are in this permit, however.) (There was no flow requirement in the previous permit.)
8. The permittee is required to collect all of the analytical monitoring samples during representative storm events as
defined in this permit. Qualitative monitoring does not have to be performed during a representative storm
event.
Other Proposed Changes to the Previous Permit:
1. I will include in the cover letter that the detection limits for pentachlorophenol, toluene, naphthalene, and
anthracene are not sufficient to detect the compound at the benchmark level. All benchmarks should be
analytically detectable.
2. Part II Section A has been revised. It now specifies all of the items to include on the site map.
3. Vehicle maintenance has been revised to semi-annually in order to coincide with analytical and qualitative
monitoring.
Discussions with permittee: Mike Rouse, 910.371.3131, 20 July 2007
1. Are you under new ownership? If so, will need an ownership change form. When did the change occur?
a. ANSWER: Yes, "Cox Industries" now owns their company, which is "Carolina Pole".
2. What does your company manufacture? Have there been any changes in industrial activity?
a. ANSWER: No changes.
3. Do you do wet -decking at your facility?
a. ANSWER: No wet decking.

NCS000222
Recommendations: Based on the documents reviewed, the application information submitted on 30 July 2004
sufficient to issue an Individual Stormwater Permit.
Prepared by (Signature) Date D CS
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Stormwater Permitting Unit Supervisor — OQxb WQtI �G Nf D �Un Date 3udl py�Tl
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Concurrence by Regional Office J! r NLS KY ?ACBE Date
Water Quality Supervisor �� t{'n�� T�(�,T ��(i� Date
Regional Office Staff Comments
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Re: [Fwd: NCS000222]
Subject: Re: [Fwd: NCS0002221
From: Linda Willis <[e-mail]>
Date: Mon, 19 Nov 2007 09:56:50 -0500
To: Kelly Johnson <[e-mail]
How's this? not the signed copies, but you can see our comments. I'm not sure where
that inspection report went. . let me know if you need a signed copy. The signed
copy also went to central files for the record.
Have a great Tgiving week and holiday Kelly,
Best regards,
Linda
Kelly Johnson wrote:
Linda - I didn't get the report in the mail. (Of course we also moved last week
so maybe that is why.) I just wanted to touch base with you in case you still had
it.
Thanks,
Kelly
nda Willis wrote:
I'll drop the signed copy of the inspection report in interoffice mail to you
today.
Have a great day.
Linda
Kelly Johnson wrote:
Linda,
Would you mind forwarding the signed staff report back to me so that I can
put it in the file?
Thanks,
Kelly
nda Willis wrote:
No issue at will.
Thanks
Linda
illy Johnson wrote:
Great, thanks. Did you have any comments about the permit text in
your staff report? If not, I'll send it to notice this week (so that
it will be issued as far as possible from my due date). If so, then
I'll just wait for your staff report and send it next month. Either
way is fine. I am just trying to anticipate what I'll have done
before he is born!
Thanks,
KJ
Linda Willis wrote:
Sorry so late,
It was good! They have a nasty operation there that is handled
quite effectively. I gave them a thorough inspection and they have
responded in writing to us with an updated SP3 plan that is really
I of 11/19/2007 11:01 AM

Re: [Fwd: NCS0002221
good. They had implemented good BMPs, but their plan needed some
work. I noted their lack of adequate monitoring, but the people on
site are new owners. As a result, they are getting their plan in
the proper names with proper signatures and they should have sent
in or are working on getting you all a change of ownership form.
No problem with these folks. Let me know if you have any specific
questions.
Linda
Kelly Johnson wrote:
Linda,
How was the inspection at General Wood (NCS000222)?
KJ
Subject:
NCS000222
From:
Kelly Johnson <[e-mail]>
Date:
Wed, 08 Aug 2007 10:28:32 -0400
To:
Linda Willis <[e-mail]>
To:
Linda Willis <[e-mail]>
2000 permit attached.
KJ
Linda Willis <linda.willis(n ncmail.neU
Environmental Engineer I
Surface Water Protection Section
Division Of Water Quality
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NC000222 Carolina Pole Inspection Report Aug 07.doc
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NC000222 Carolina Pole (Timber Treating) Aug 07.doc Content -Encoding: base64
to NC000222 from 08 07 inspection.doc I Content -Type: application/msword
of 11/19/2007 11:01 AM

Re: [Fwd: NCS000222]
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NC DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
�A INDUSTRIAL STORM WATER INSPECTION FORM
WILMINGTON REGIONAL OFFICE
Facility:
Carolina Pole
Date: August 8, 2007
Location Address:
1901 Wood Treatment Road, Leland North Carolina
COC #:
Contact Name:
Mike Rouse, Operations Manager
Phone Number: 910-371-3131
Contact Mailing Address:
P.O. Box 370, Leland North Carolina 28451
County: Brunswick
Directions: I On the left on US 74/76 pproximately 4 miles west of Hwy 17 intersection. Located just past last Leland exit.
x
Routine Compliance Inspection
Yes
Rescission Request
N/A
Complaint Investigation
x
Other — Permit renewal inspection
A.
STORM WATER POLLUTION PREVENTION PLAN
Yes
No
N/A
Comments
1.
Is a copy of the signed and certified SWPPP at the facility?
x
Ownership change form
The permittee had sent in a change ownership form to DWQ for the state
needs to be sent in to the
stormwater permit and thought that would suffice for the ownership
Central Office (form
change notification to DWQ for all permits including the NPDES permit.
enclosed). SWPPP
needs to be updated and
signed by Mr. Johnson
The plan should bereviewed
2.
Does the facility's SWPPP address the minimum BMP requirements?
x
3.
Are amendments to the SWPPP clearly documented?
x
4.
Is the current SWPPP complete?
x
and updated to
A yearly review of the plan is required with amendments clearly defined
include the information
at the front of the SWP3. A signature and date on which the review and
requested (see left). The
amendments were made is required. The site transcends two USGS
current site maps require
quadrants. The map provided is not adequate. A map showing the
updating with better
location of tanks, drums, treatment systems, and operating equipment
detail.
under the covered area should be provided. The possible contents for
each should be clearly identified. The volume of each tank should be
identified and total volume in drum storage areas identified. The areas
where hazardous waste and raw materials are stored should be clearly
indicated. Include storage volume of secondary containment. The
Stormwater Management Plan did not contain a feasibility study section.
B.
VEHICLE EQUIPMENT
Yes
No
N/A
1.
Were the vehicle/equipment maintenance areas inspected?
x
2.
Are vehicle/machinery leaks and drips properly managed?
x
3.
Is vehicle/equipment washing done in a designed area so that wash water
x
can be properly managed?
Maintenance is conducted within a containment area. The Spill
Response Plan identified actions required to quickly eliminate and clean
up a petroleum spill.
4.
Was the vehicle fueling area inspected?
x
5.
Are vehicle maintenance activities kept indoors?
x
6.
Were the vehicle/equipment storage areas inspected?
x
7.
Are current BMPs in vehicle/equipment/fueling areas adequate?
x
C.
WASTE MANAGEMENT
Yes
No
N/A

1.
Are containers for temporary storage of wastes labeled?
Yes
No
N/A
2.
Are waste materials recycled?
x
x
3.
Are hazardous wastes properly handled and disposed of?
x
x
4.
Is processed debris removed regularly?
x
in convenient locations?
.
Is there secondary containment for liquid wastes?
x
3.
Are used absorbent materials disposed of in a timely manner?
6.
Are current waste management BMPs adequate?
x
D.
MATERIAL STORAGE
Yes
No
N/A
1.
Are there appropriate BMPs for outdoor storage of raw materials,
products, and byproducts?
x
F.
2.
Are containers for chemical substances labeled?
No
N/A
x
3.
Is there secondary containment for liquid storage?
x
4.
Are current BMPs in material storage areas adequate?
x
site, water and wind
No containers were
observed.
Facility utilizes Safety
Kleen
Facility utilizes Clean
Harbors
Raw materials, products
and byproducts are
stored under roof with
secondary containment
with the exception of
dried treated and
untreated timber.
E.
SPILL CONTROL
Yes
No
N/A
Comments
1.
Are there procedures for spill response and cleanup?
x
2.
Are appropriate spill containment and cleanup materials kept on-site and
x
in convenient locations?
Did not check disposal
3.
Are used absorbent materials disposed of in a timely manner?
x
records or manifests.
Given the nature of the
4.
Are current spill BMPs adequate?
x
F.
EROSION
Yes
No
N/A
1.
Are unpaved outdoor areas protected from water/wind erosion?
x
site, water and wind
erosion is possible,
however it did not
appear to be a significant
problem.
A perimeter ditch
2.
Are drainage ditches or the areas around the outfalls free of erosion?
x
surrounds the 130 acre
site. The ditch shows
signs of some erosion. It
appears the grading at
the site is maintained to
reduce erosion as much
as practical.
The plan indicated no
3.
Do implemented BMPs appear effective in controlling erosion?
x
G.
NON -STORM WATER MANAGEMENT
Yes
No
N/A
1.
Have all illicit water discharges been eliminated or permitted?
x
illicit water discharges
have occurred.
The site has no other
2.
Are BMPs for authorized non -storm water discharges properly
x
discharge than

stormwater.
There is a wastewater
treatment facility, it is
not permitted through
the NPDES permit
system and therefore it's
proper operation was not
commented on by the
inspector.
Access to the discharge
is not accessible since it
is on MOTSU property.
J.
implementea7
In general, all of the operations/activities of concern involving raw material storage, treatment operations, and storage of bulk
materials is under a roof minimizing/eliminating stormwater contact. The site appeared to be very clean, no evidence of spills on
the grounds outside of the containment areas. The site is surrounded by a deep ditch (approximately 4-5 foot deep). It serves as a
3.
Are current BMPs adequate for management of authorized non -storm
water discharges?
not been conducted according to the permit. Annual monitoring was missed during year 2 and the first, second and third quarters of
the fourth year of the permit cycle. Both semi annual qualitative monitoring was missed for year five of the permit cycle. It appears
x
H.
PROCESS WASTEWATER CONTROLS AND MONITORING
Yes
No
N/A
1.
Are wastewater treatment facilities properly maintained?
The site utilizes a biological activated sludge system to reduce organics
in the treatment water. Flocculation and a filter belt press is used to
handle solids which are stored in a 1 cubic yard box for disposal by
Clean Harbors. This system is a non discharge reuse/recycle treatment
system.
Change Form is required (enclosed). Updated maps need to be sent to the Wilmington Regional Office (WiRO) (to the attention of
Linda Willis). The bark and wood debris should be cleaned out from the stormwater conveyance ditch in the vicinity of the outfall
x
2.
Has monitoring been done?
x
I.
STREAM OBSERVATION/IMPACTS
Yes
No
N/A
1.
Were there any stream impacts?
x
2.
Were field parameters taken for pH or DO?
x
3.
Were there any stream standard violations/
x
4.
Were there excessive solids in the stream?
x
5.
Were pictures taken?
x
6.
Were samples taken?
x
stormwater.
There is a wastewater
treatment facility, it is
not permitted through
the NPDES permit
system and therefore it's
proper operation was not
commented on by the
inspector.
Access to the discharge
is not accessible since it
is on MOTSU property.
J.
SUMMARY/ ACTION ITEMS
In general, all of the operations/activities of concern involving raw material storage, treatment operations, and storage of bulk
materials is under a roof minimizing/eliminating stormwater contact. The site appeared to be very clean, no evidence of spills on
the grounds outside of the containment areas. The site is surrounded by a deep ditch (approximately 4-5 foot deep). It serves as a
collection system and conveyance for stormwater runoff to outfall 001. Stormwater collects in the perimeter ditch and exits the site
at one outfall located on the northeast corner of the property. The analytical monitoring required during the past permit cycle has
not been conducted according to the permit. Annual monitoring was missed during year 2 and the first, second and third quarters of
the fourth year of the permit cycle. Both semi annual qualitative monitoring was missed for year five of the permit cycle. It appears
the facility was sold to Carolina Pole Leland, Inc. (president R. Michael Johnson) in 2006. The permit expired February 28, 2005
and was not renewed. The SWP3 and SPRP is quite thorough in addressing any potential on site stormwater contamination and
regular and frequent inspections of all processes and storage areas as well as the entire site is conducted and documented. The
operations manager has been conducting qualitative monitoring even though the permit was not transferred to the new owner by the
Division. The permitee had sent in a DWQ Coastal Stormwater Permit Ownership Change Form (twice, registered receipt) to
request the change in ownership for NCS000222 in May of 2006. The request was (likely) not acknowledged since it was on the
wrong form.
The SWP3 plan needs to incorporate the changeslupdates mentioned in the text of the inspection report (above). The Ownership
Change Form is required (enclosed). Updated maps need to be sent to the Wilmington Regional Office (WiRO) (to the attention of
Linda Willis). The bark and wood debris should be cleaned out from the stormwater conveyance ditch in the vicinity of the outfall
or any other area within the stormwater conveyance ditch where woody debris may collect. Please update the site maps (with
details identified in sections L. and M. of this inspection report) for inclusion in the SWP3 and forward a copy of each to Linda
Willis at WiRO.
K.
RATING LEVEL (CIRCLE ONE: 1-6)
1i.
Indusry in substantial compliance
E]
Minor deficiencies noted. Revist will be scheduled within 6 months. (date).
3.
Major deficiencies or discharges noted and require prompt correction. Revisit scheduled for (date).

4.
Critical deficiencies or discharges noted and require immediate correctioin. Revisit scheduled (date).
for
5.
Rescission is appropriate.
6.
Rescission is not appropriate.
Logged by: Inspected by: Linda Willis
L. Include a Map of the facility. This drawing should depict the building, parking, process, and storage areas.
If you do not have a map, draw one or request that the facility provide you one in your written
correspondence.
A more detailed vicinity map is required including ALL: buildings, storage areas, vehicle maintenance
buildings or areas, heavy equipment maintenance buildings or areas, hazardous waste storage area for
drums and/or bulk waste, wastewater treatment system including storage for treatment chemicals (polymers
for flocculation and/or pH control), settling tanks, aeration basin, storage basins, belt filter press, bulk
storage tanks, storage areas for drums or pails, loading and unloading areas, autoclaves, drip pads, fire
suppression equipment, drying kilns etc. etc. utilize shading where secondary containment is provided and
processes are under roof. Please make sure an arrow depicting North is provided on both maps. Ensure
both maps are to scale and the scale is identified on the maps.
M. Develop a Vicinity Map for the file.
A non cartoon topographical map (USGS) is required with the overlay of the entire site on the
topographical map. The map should include any surface waters in close proximity to the site.
Provide lattitude and longitude for the outfall 001.
N. Identify all records that were reviewed.
Permit file. SWP3 Plan and spill response plan. Inspection records for the outfall and facility operations.
Employee training records. Qualitative and quantitative monitoring records.
O. Explain how Secondary Containment is being used and whether these measures are being properly
maintained. [Did you observe that the secondary containment had release valves (were they open, locked
etc.), was there water, waste product, sheen, etc observed within the secondary containment area? Explain
your observations]
There were no drains in the areas inspected. The contents of secondary containment areas are pumped to
the wastewater treatment facility for treatment. The water in the secondary containment area is not released
to the environment.
P. House keeping and best management practices (maintenance of BMPs) status.
Housekeeping was good. No litter, no excessive junk lying around the property, no evidences of spills of
chemicals or petroleum products to the ground were evident.
Q. Identify outfalls and receiving waters. List any observation or concerns.
Outfall 001 is the only outfall from the site that conveys stormwater to surface waters of the state. The area
around the outfall had an excessive build up of bark and wood debris that should be removed on a regular
basis. It might be prudent to exercize some type of debris control prior to the outfall pipe, but regular
removal of debris may suffice.
R. Take digital photographs to support staff report observations and to provide assistance to future inspectors).
Digital photos available of some of the process area and outfall.
Logged by: Inspector: Linda Willis

August 9, 2007
Mike Rouse
Operations Manager
P.O. Box 370
Leland, North Carolina 28451
SUBJECT: Compliance Evaluation Inspection
Carolina Pole
Permit Number NC000222
County Brunswick
Dear Mr. Rouse:
On August 8, 2007, Linda Willis, of the Division of Water Quality, Wilmington Regional Office, performed an
inspection of the subject facility. As part of the inspection, a tour of your facility was conducted. All observations and
recommendations are noted in the (Summary of findings/Action Items) of this inspection report. Please respond to these
action items in an expedient manner to prevent any future problems. Remember, it is our goal to insure the quality of
the surface waters of this State.
Please review the attached report. If you or your staff have any questions, do not hesitate to contact Linda Willis
or myself at 910-796-7215.
Sincerely,
Edward Beck
Surface Water Protection Section
Water Quality Regional Supervisor

Enclosures
cc: Central files
WiRO/DWQ Stormwater Compliance Files (Linda Willis)
Stormwater Permitting Unit/ Raleigh
NPS and Compliance Oversight/Raleigh

August 9, 2007
Certified Mail
Return Receipt Requested 7006 0810 0004 4480 9360
Mike Rouse
Operations Manager
P.O. Box 370
Leland, North Carolina 28451
Certified Mail
Return Receipt Requested 7006 0810 0004 4480 9377
Mr. R. Michael Johnson
President
P.O. Box 1124
Orangeburg, South Carolina 29116
SUBJECT: Compliance Evaluation Inspection
Carolina Pole
Permit Number NCS000222
County Brunswick
Dear Mr. Rouse:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
On August 8, 2007, Linda Willis, of the Division of Water Quality, Wilmington Regional Office,
performed an inspection of the subject facility. As part of the inspection, a tour of your facility was
conducted. All observations and recommendations are noted in the (Summary of findings/Action Items)
of this inspection report. Please respond to these action items in an expedient manner to prevent any
future problems. Remember, it is our goal to insure the quality of the surface waters of this State.
Please review the attached report. If you or your staff have any questions, do not hesitate to
contact Linda Willis or myself at 910-796-7215.
Sincerely,
Edward Beck
Surface Water Protection Section
Water Quality Regional Supervisor
Enclosures
cc: Central files
WiRO/DWQ Stormwater Compliance Files (Linda Willis)
Stormwater Permitting Unit/ Raleigh
NPS and Compliance Oversight/Raleigh
Noy Carolina
dvWura/!y
North Carolina Division of Water Quality 127 Cardinal Drive Extension Wilmington, NC 28405 Phone [phone] Customer Service
Internet www.ncwateraualitv.ore Fax [phone]
An Equal Opportunity/AHlrmative Action Employer— 50% Recycled/10% Post Consumer Paper

Mr. Mike Rouse
Operations Manager
P.O. Box 370
Leland, NC 28451
Dear Mr. Rouse,
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
October 1, 2007
Re: Compliance Evaluation Inspection
Carolina Pole
NPDES Permit No. NCS000222
Brunswick County
The Division is in receipt of your response to the recent NPDES stormwater inspection conducted at the
Carolina Pole facility on August 8, 2007. The updated Stormwater Pollution Prevention Plan appears to
thoroughly address all of the items listed in the inspection report. The plan appears to also address each
of the itemized requirements listed in Sections A through D of the NPDES Permit. The ownership
change form is awaiting signatures. Once the form is complete, please forward that form to the
Stormwater Permitting Unit at 1617 Mail Service Center, Raleigh North Carolina 27699-1617.
When you receive your renewed NPDES permit, please carefully review the qualitative and quantitative
monitoring requirements specified in the new permit versus those outlined in your Stormwater Pollution
Prevention Plan and make any necessary amendments to your Plan accordingly. This will prevent any
discrepancies in the implementation of your current plan versus the requirements of the renewed NPDES
Permit.
Thank you for your timely response and your attention to this matter. Should you have any questions
regarding this correspondence or your permit renewal, please do not hesitate to contact me at 910-796-
7343.
Sincerely,
Linda Willis
Environmental Engineer I
Surface Water Protection Section
CC: Edward Beck, Regional Supervisor, SWPS, WiRO
Central Files
Kelly Johnson, Central Office, Stormwater Permitting Unit
WiRO NPDES Permit File NCS000222, Brunswick County
Nos` Carolina
raW irally
North Carolina Division of Water Quality 127 Cardinal Drive Extension Wilmington, NC 28405 Phone [phone] Customer Service
Internet: www.ncwateroualitv.om Fax [phone]
An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper