NCS000456_Review Document_20181001

NC Division of Energy, Mineral and Land Resources
Review for Permit Renewal — NCS000456
Culpeper of Cove City, LLC
Cove City, NC
Facility Activities and Process - SIC 2491— Wood Treatment. Untreated lumber is treated using either an inorganic
arsenical (CCA) or a copper based (copper azole) amine formula. All chemicals are kept inside containment areas and
waters accumulated used back in the process. All freshly treated lumber is kept under cover, on a RCRA Subpart W
drip pad until drippage has ceased. Facility supplied a plant overview that explains onsite activities.
Monitoring — The facility has been monitoring for TSS, Ar, Cr, Cu, BOD, COD, 0&G, TP, TKN, nitrate -nitrite and pH.
Previous permit did have tier system.
o Data from 2005 — 2017 shows multiple benchmark exceedances for TSS and Cu along with one for TP. TSS,
Ar, Cr and Cu values have been consistently higher starting in 2015.
o TSS and Cu values have been over the benchmark at essentially all events starting in 2015. The facility did
not instate monthly monitoring as required. Also no information on actions to address. Email to Josh
Adkins (7/25/2018) to ask about this.
o COD, BOD, pH, 0&G and nutrient values were almost all well below the benchmark or BDL. Should be okay
to remove all of these parameters, except pH which should stay as a base for evaluation.
o Parameters remaining in the permit — TSS, Ar, Cr, Cu, and pH.
o Tier structure adjusted to have the three levels as in current permits.
o Parameter codes added to permit.
o The facility has two drainage areas that come together in a ditch and they monitor at the discharge of the
ditch. It may be useful for them to monitor the drainage areas separate to try and get a better feel for
where the main problem areas are on the site. One of the drainage areas goes through an onsite detention
pond (covered by SW permit) and it may be useful to see it's effectiveness on the parameters that are
showing concerns.
Discussions with Facility — Started with email to Jane House on 3/12/18 but found the facility was sold to Culpeper.
New contacts pointed to consultant for discussions (Tom Houston). One conference call with Tom and other
consultants (3/20/18), apparent they were confused by the fact the facility also was in the process of a state
stormwater permit renewal. Emailed information on both procedures 3/21/2018. Multiple emails from April
through July (4/3, 6/4, 7/10) to Tom, but never got any additional response. Facility did follow through and get the
state stormwater permit renewed. Emailed multiple company contacts and got new contact with the company —
Josh Adkins on 3/10/18. Got additional info requested from Josh on 7/11/18. See emails in file.
Surface Water Information - Facility drains to a UT to Core Creek in the Neuse River Basin, 27-90, a class C; Sw; NSW
stream. 2016 Assessment Report lists this segment of Core Creek as impaired due to a sever swamp
bioclassification. Impact is listed as from agriculture and Salt Wood Products waste site. Looking at DWM online
records it is confusing whether Cove City is the former Salt Wood or if World Wood is actually the former Salt Wood?
Basin plans indicate that some activities in the watershed have resulted in portions of the watershed being delisted
and no longer impaired. Activates were agricultural BMPs, etc. Note impairment in the permit.
NC National Heritage review — NHP report shows no aquatic resources within project area. Within one mile there is
one species —banded sunfish — is shown as significantly rare but the ranks are very low and it does not appear to be
an issue.
Regional Office Information - WaRO — Draft to region on July 30, 2018 by email. Region was not able to set up site
visit during time period of the notice, but approved moving forward with the renewal (email Sept 24, 2018). WaRO
will schedule a site visit to access the facility and their efforts under the permit at their earliest convenience.