NCS000452_Review Document_20181008

Last update: 10/8/2018
NC Division of Energy, Mineral and Land Resources
Review for Permit Renewal — NCS000452
Culpeper of Ramseur, LLC
Ramseur, NC— Randolph County
• Facility Activities and Process - SIC 2491— Wood Preserving. Appears to just use a copper treating process.
• Monitoring — The facility has been monitoring for TSS, BOD, COD, Cu, and pH. Previous permit did have tier system.
o Data from 2009 — 2017 (in renewal app and supplemental information)
o COD and BOD never above the benchmark
o Cu exceeded benchmark value four times
o pH below 6 on twenty results including the last 8 samples. No indication in information submitted on how
or if the facility responded to these exceedances to investigate the reasons or try and mitigate.
o TSS values never above benchmark, but this is a base parameter that should be maintained.
o Maintain TSS, Cu and pH in the permit
o Tier structure adjusted to have the three levels as in current permits.
o Parameter codes added to permit.
Discussions with Facility — Discussions with current facility staff indicate that there is little onsite knowledge about
past activities. Often referenced back to previous health and safety staff with the old owner for feedback? Facility
submitted an Ownership change request with the last add info. This change will be handled in the renewal (this is
already updated in BIMS).
Surface Water Information - Facility drains to UT to Deep River in the Cape Fear River Basin, 17-(10.5) , a class C
stream. 2016 Integrated Report indicates a listed impairment for Copper in segment 17-(10.5)d2 of the Deep River.
Include language about impairment in the permit. Previous permit noted impairment problems with turbidity and
Chlorophyll A, but these are not listed in the 2016 Integrated report for this segment. Checked with DWR Planning
Branch (Cam McNutt) on the Cu listing and it appears that this impairment is an old listing based in 2007 data (5e).
This needs to be reassessed. Still listed as impaired because EPA will not allow removal at this time. Most reviews of
this type have resulted in de -listing when more data available and compared to updated Cu standards. Will include
more generic language in the impaired section of the permit.
NC National Heritage review — NHP report shows no aquatic resources within project area or within one mile
boundary of the facility.
Regional Office Information — W -SRO — Draft to region on 08/20/2018 by email. Previous staff report and other
information in the file indicate there were two outfalls, but most recent information from the facility and the facility
monitoring is only for one outfall. Need to verify this with site visit. Brandon visited the site on August 31, 2018 —
see email in LF. Brandon verified only one outfall. Facility regraded in the past and eliminated the second outfall.
He also verified that they continue to use the copper based treatment chemical. Brandon discussed the pH issues an
the facility feels that their pH meter has issues and they will replace and calibrate. WSRO okay with reissuance.