NCS000456_Cove City Plant Overview 2018_20180713

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.
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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
X
Stack materials to minimize surface area of materials
X
Sheds are in
exposed to precipitation
X
use also
Frequent removal of debris
X
Provide collection of runoff with containment basins,
X
sedimentation ponds and infiltration basins
X
Heavy retention
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
X
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
X
Heavy retention
Activity
Associated BMPs
In Use
Remarks
Loading and
Provide diversion berms and dikes to limit runon
X
Unloading,
moving to storage
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
under shed
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
Storage Areas
Provide secondary containment around chemical storage
areas
X
maintenance
and cleaning
Provide level gages
X
Inventory fluids to identify leakage
X
Locate storage areas away from high traffic areas and
surface waters
X
Develop spill prevention, containment and
countermeasure SPCC plans and implement
X
Cover and/or enclose chemical storage areas
X
Provide containment to allow for recycling of spill and
leaks
X
Activity
Associated BMPs
In Use
Remarks
Equipment
and/or vehicle
Provide diversion berms and dikes to limit runon
X
maintenance
and cleaning
Preventative maintenance program (cleaning oil/water
separators, catch basins, vehicle mounted drip
containment devices
X
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,
oil filters, used solvents, etc.
X
Locate storage areas away from high traffic areas
X
Activity
Associated BMPs
In Use
Remarks
Erosion and
Sediment
Grassed areas to prevent soil erosion
X
Controls
Use of vegetation on sloped areas to prevent sediment
run-off
X
Ditches around property to prevent water run on from
neighboring locations
X
Sediment Trap (Such as rock, vegetation, etc.)
X
Culpeper of Cove City, LLC — Craven County Page 5 of 5
Permit # NCS000456