NCS000122_Signed NOV_20191007

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ROY COOPER
Governor
MICHAEL S. REGAN
Secretory
S. DANIEL SMITH
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NORTH CAROLINA
Environmental Quality
October 07, 2019
CERTIFIED MAIL 7016 3560 0000 4428 6154
RETURN RECEIPT REQUESTED
General Timber, Inc.
Attn. Clement Williams, Owner
625 Farmville Coal Mine Road
Sanford, NC 27330
Subject: NOTICE OF VIOLATION (NOV-2019-PC-0622)
General Timber, Inc.
NPDES Individual Industrial Stormwater Permit No. NCS000122
Chatham County
Dear Mr. Williams,
On May 15, 2019, Alaina Morman and Lauren Garcia from the Raleigh Central Office of the
Division of Energy, Mineral and Land Resources (DEMLR), conducted a compliance
inspection for the General Timber, Inc facility located at 625 Farmville Coal Mine Road, in
Chatham County, North Carolina. For your reference, a copy of the inspection report is
enclosed with this notice. The subject facility is covered by NPDES Individual Industrial
Stormwater Permit NCS000122. Permit coverage authorizes the discharge of stormwater
from the facility to receiving waters designated as Georges Creek, a class WS-IV stream in
the Cape Fear River Basin.
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As a result of the compliance inspection, the following permit violations are noted:
1) Failure to include a site map in the Stormwater Pollution Prevention Plan (SWPPP). [Part II, Sec.
A, Item 1C]
2) Failure to review and update the SWPPP on an annual basis, or when there is a change in
design, construction, operation, or maintenance that has a significant effect on the potential for
the discharge of pollutants to surface waters. [Part II, Sec. A, Item 71
a. There were no records that the SWPPP had been updated since at least 2009.
b. The facility underwent changes in gradient between 2009 and 2019 due to the mass
storage of woodchip/mill in the northeastern section of the site. It was reported that the
natural stormwater flow towards outfall 002 was altered and as a result the facility had
not attempted to sample from the outfall since at least 2010.
3) Failure to conduct analytical monitoring over the term of the permit at each stormwater
discharge outfall. [Part II, Sec. B]
a. During the site visit, a new outfall was observed flowing from the base of the woodchip
pile towards Georges Creek.
b. There were no records or indications that the facility had investigated the source of Cu
in stormwater discharges in response to benchmark value exceedances since at least
2014. No records of improvements through site modifications and stormwater controls
were available after 2014.
4) Failure to conduct qualitative monitoring at each stormwater discharge outfall. [Part II, Sec. C]
5) Failure to design, install, and monitor a BMP at outfall 001 that has been shown to remove or
reduce copper in stormwater discharges (such as a bioretention cell). [Part .II, Sec. A, Item 2d]"
a. A copper BMP had not been maintained at Outfall 001 and was not present during the
site visit. DEQ records indicate, from 2011-2014, the chosen BMP consisted of applying
agricultural lime to the soils in the Outfall 001 drainage area. This BMP was not proven
to decrease copper concentrations in the manner intended by the permit. No records of
installation or maintenance of the copper BMP discussed above, or another copper BMP,
exist after 2014. During the site visit, Greg Williams stated that in recent years the
facility placed straw bales around outfall 001.
Required Response:
You are directed to respond to this office, in writing, within 30 calendar days from the
receipt of this notice. Your response shall include, at minimum:
1) A reasonable explanation as to why the aforementioned violations occurred.
2) A detailed account of all response actions taken to address the aforementioned
violations.

Thank you for your attention to this matter. Your above -mentioned response to this notice
will be considered in any enforcement proceedings. This office requires that the
violations, as detailed above, be properly resolved. These violations and any future
violations are subject to a civil penalty assessment of up to $25,000 per day for each
violation. Should you have any questions regarding this matter, please contact Lauren
Garcia at [phone] or lauren.garciaOncdenr.gov.
Sincerely,
�a' f L are
William H. Denton, IV, PE
Regional Engineering Supervisor
Division of Energy, Mineral and Land Resources
North Carolina Department of Environmental
Quality
Enclosure: May 15, 2019 Inspection Report
ex: Alaina Morman, Environmental Specialist alaina.morman @ ncdenr.gov
Annette Lucas, Stormwater Program Supervisor annette.lucas((Tncdenr.gov
Thad Valentine, Environmental Specialist thad.valentine @,ncdenr.goy
Bethany Georgoulias, Environmental Engineer betbany.geor og ulias@ncdenrgov
Toby Vinson, Section Chief tobv.vinsonOncdenr.gov
Bill Denton, Engineering Regional Supervisor bill.dentongncdenr.gov
Rick Bolich, Assistant Regional Supervisor Ricl.BolichPncdenr.gov
Ray Milosh, Hydrogeologist [e-mail]

Compliance Inspection Report
Permit: NCS000122 Effective: 09/01/08 Expiration: 08/31/13 owner: General Timber Inc
SOC: Effective: Expiration: Facility: General Timber Incorporated-Sr#2148
County: Chatham 625 Farmville Mine Rd
Region: Raleigh
Sanford NC 27330
Contact Person: William Art Williams Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 05/15/2019
Primary Inspector: Alaina Morman
Secondary Inspector(s):
EntryTime: 10:OOAM
Lauren Garcia
Reason for Inspection: Routine
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Certification:
Phone:
Exit Time: 12:OOPM
Phone: [phone]
Inspection Type: Compliance Evaluation
Page 1 of 5

Permit: NCS000122 Owner - Facility: General Timber Inc
Inspection Date: 05/15/2019 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary
Records/Reports:
This facility is required to develop and maintain a SWPPP in accordance with Part 11, Section A of the permit.
• A site map was not included in the SWPPP.
The facility is required to review and update the SWPPP on an annual basis in accordance with Part II, Section A, Item 7 of
the permit. The permittee is also required to amend the SWPPP when there is a change in design, construction, operation,
or maintenance that has a significant effect of the potential for the discharge of pollutants to surface waters in accordance
with Part 11 Section A, Item 7 of the permit.
• There were no records that the SWPPP had been updated since at least 2009.
• The facility has undergone changes in gradient between 2009 and 2019 due to the mass storage of woodchip/mill in the
northeastern section of the site. It was reported the natural stormwater flow towards outfall 002 was altered and as a result
the facility has not attempted to sample from the outfall since at least 2010.
• During the site visit, a new outfall was observed flowing from the base of the wood shavings pile towards Georges Creek
Greg Williams was unaware of its presence. The new outfall has never been identified or sampled by General Timber. Aerial
photographs show the outfall has been visible since at least 2013.
The facility is required to design, install, and monitor a BMP at outfall 001 that has been shown to remove or reduce copper
in stormwater discharges (such as a bioretention cell), in accordance with Part 11, Section A, Item 2.d.
• A copper BMP had not been maintained at Outfall 001 and was not present during the site visit. DEQ records indicate,
from 2011-2014, the chosen BMP consisted of applying agricultural lime to the soils in the Outfall 001 drainage area. The
lime was expected to raise the pH of the soils, thereby minimizing the mobilization of copper in stormwater. This BMP was
not proven to decrease copper concentrations in the manner intended by the permit. No records of installation or
maintenance of the copper BMP discussed above, or another copper BMP, exist after 2014. During the site visit, Greg
Williams stated that in recent years the facility placed straw bales around outfall 001. Straw bales may be considered a
good housekeeping measure, but do not meet the qualifications of the copper BMP outlined in Part II, Section A, Item 2.d.
The facility is required to investigate the source of Cu in stormwater discharges from the facility, in accordance with Part II,
Section B, page 6. In addition, the site is required to continue to make improvements through site modifications and
stormwater controls in order to reduce the Cu in stormwater discharges, as per Part II, Section A, Item 2.d.
• There were no records or indications that the facility has investigated the source of Cu in stormwater discharges from
the facility since at least 2014. Preceding 2014, the facility claimed the copper exceedances were caused by naturally
occurring copper in the site soils. Agricultural lime was used to address said claim. This BMP was not proven to decrease
copper concentrations in the manner intended by the permit. No records of investigation or improvements through site
modifications and stormwater controls were available after 2014. Outfall 001 is located in the drainage basin of a storage
yard, where treated creosote and CCA product are stored, uncovered, for up to 6 months.
Facility Site Review:
This facility operates as a fence post production facility. The facility receives raw wood, the bark is removed and then cut to
size. Either CCA or Creosote are used as treatments. During the debarking process, chip/mill is a by-product.
• The 2008 Staff Report states chromium and arsenic were removed from the monitoring parameters as the facility was
planning to transition to a C2 treatment in place of CCA. The facility did not make this transition and has not been required
to monitor for chromium or arsenic during the current permit term.
Offices are located in a central section of the Property. Chipping/milling occurs in the northeastern corner of the Property.
Wood treatment occurs in buildings located in the north-northwest corner of the Property. Freshly treated wood is stored on
covered drip pads until wood is dry. Dry, treated wood is stored in storage yards that cover the entire southern half of the
Property, which encompasses at least 10 acres. The wood -treatment buildings appeared to be well maintained. Bulk storage
tanks and process piping in the wood -treatment buildings were located within secondary containment. Bulk storage tanks
and dispensers for fuel products were located under canopy roofs or within secondary containment structures.
Chip/mill is stored in large piles in the same area. The chip/mill pile was observed to be approximately one-story high and
covered an area of approximately 0.48 acres. Older wood, mulch material, and wood scraps are stored in a large pile in the
eastern section of the Property. There is a significant elevation change leading away from the site and towards the receiving
body of water, Georges Creek. The older wood pile extends down the elevation and appeared to be approximately
two -stories high at the back and covers an area of approximately 1 acre. It is stated in the SWPPP:
Page 2 of 5

Permit: NCS000122 Owner - Facility: General Timber Inc
Inspection Date: 05/15/2019 Inspection Type : Compliance Evaluation Reason for Visit: Routine
"Wood residues, including bark, chips, and sawdust, are managed on -site in a manner that is intended to lessen impact on
stormwater quality. In fact, suspended solids that are present in the sheet flow from some areas of the facility are filtered out
in the piled wood residues which is beneficial to stormwater quality" -
"Due to their volume and location, the large piles of wood residues serve as a buffer against the introduction of suspended
solids into stormwater that falls directly into the process area. Fine sawdust and particles become trapped within the piles
that act both as a filter and a sponge during storm events. The locations of the piles are remote from the major drainage
channels and permitted outfalls at the facility."
• While the piles may act as an obstacle for larger wood products, the piles do more damage to stormwater than good.
The wood piles act as large composts. Greg Williams even stated the temperature of the pile has become so hot in the past
that it caught fire. The decomposing wood produces Ieachate that is carried directly into Georges Creek by stormwater. Rain
will also infiltrate the piles and the small particles will be the first to migrate through and out of the pile.
• During the site visit, it was observed that a new outfall had formed at the base of the chip/mill wood pile. Aerial
photographs show this outfall has been visible since at least 2013. It was very apparent that dust, small wood particulates,
and residues are actively being carried through the channel. A significant amount of product was observed in the channel,
moving towards Georges Creek, for approximately 100-feet, before vegetation and elevation obscured our view of the outfall.
• It should be noted that the Individual Industrial Stormwater Permit, Permit No. NCS000122, encompasses the whole
facility property and applies to any and all outfalls onsite. It is the responsibility of the facility to update the SWPPP and
document the closure of old outfalls and the addition of new outfalls. It is the responsibility of the facility to implement the
conditions of the permit across the site and at all outfalls. All stormwater discharges must be in accordance with the
conditions of the permit. Any other point source discharge to surface waters of the state is prohibited unless it is an
allowable non-stormwater discharge or is covered by another permit, authorization, or approval, in accordance with Part I,
Section B, page 1, of the permit. Until the facility returns to compliance with the conditions of the permit, the product leaving
the site through this new outfall is considered an unpermitted discharge.
There are three sampled outfalls located at the facility. Outfall 001, the facility's main outfall, is located in the southeastern
corner of the site and the 10-acre storage yard drains to this point. As discussed above, due to reoccurring exceedances of
copper, a copper BMP was required to be installed and maintained at Outfall 001. Outfall 002 was located in the area that is
now occupied by the large chip/mill and older wood piles and has not been sampled since at least 2010. Outfall 003 is
located in the northernmost corner of the property. Waste lagoons used to be located in the northernmost section of the
site; however, these lagoons have since been filled in and vegetated as part of a corrective action management unit. The only
industrial activity remaining in the area that drains to Outfall 003 is the storage of older abandoned and/or reusable
equipment. An additional, undocumented outfall has formed at the base of the chip/mill and old wood piles.
• Outfall accesses at the site were overgrown and difficult to get to.
• Outfall locations were not clearly identified at the site.
• As stated above, a copper BMP did not exist at Outfall 001. A copper BMP is required in accordance with Part II,
Section A, Item 2.d. of the permit.
• As stated above, it is the responsibility of the facility to update the SWPPP and document the closure of old outfalls and
the addition of new outfalls. It is the responsibility of the facility to implement the conditions of the permit across the site and
at all outfalls.
Receiving Waters:
Stormwater at the site discharges to Georges Creek, a Class C stream in the Cape Fear River Basin. Georges Creek is an
impaired waters experiencing problems with benthos. During the site visit, Georges Creek was observed to be a bright red
color.
Self -Monitoring Program:
The facility is required to provide qualitative and analytical monitoring data twice annually. There were several disparities
identified during the site visit and through email, regarding monitoring.
• All outfalls at the site have not been monitored in accordance with the conditions of the permit.
• Hunt Environmental Associates, the attending environmental consultants contracted by the facility to maintain the
conditions of the stormwater permit, is based out of Lumberton, NC.
• During the site visit, it was difficult to quickly determine outfall locations. There was some question as to their specific
locations. They were difficult to get to and were not highly visible.
Corrective Actions:
• Carefully review the new permit and all associated components. Make sure the permit and all associated components
are properly implemented at the facility.
Page 3 of 5

Permit: NCS000122 Owner - Facility: General Timber Inc
Inspection Date: 05/15/2019 Inspection Type : Compliance Evaluation Reason for Visit: Routine
• Update the SWPPP in accordance with permit requirements. The SWPPP should be amended whenever there is a
change in design, construction, operation, or maintenance that has a significant effect on the potential for the discharge of
pollutants to surface waters. In accordance with Part II, Section A, Item 7 of the permit. The SWPPP shall also be reviewed
and updated on an annual basis.
• If the facility is unable to independently determine outfalls at the site, the facility shall work with a DEQ-DEMLR
Regional Office contact to determine outfall locations. Outfall locations should be updated in the SWPPP and all outfalls
must be maintained under the conditions of the permit. As stated above, it is the responsibility of the facility to update the
SWPPP and document the closure of old outfalls and the addition of new outfalls. It is the responsibility of the facility to
implement the conditions of the permit across the site and at all outfalls.
• Grab samples shall be collected within the first 30 minutes of discharge. When physical separation between outfalls
prevents collecting all samples within the first 30 minutes, sampling shall begin within the first 30 minutes, and shall
continue until completed. Outfalls shall be clearly marked and numbered. It is recommended that clear access to the
outfalls be maintained as a good housekeeping measure.
• Install a copper BMP at Outfall 001, in accordance with the qualifications of the copper BMP outlined in Part II, Section
A, Item 2.d. of the permit.
Page 4 of 5

Permit: NCS000122
Owner - Facility: General Timber Inc
Inspection Date: 05/15/2019
Inspection Type : Compliance Evaluation
Stormwater Pollution Prevention Plan
Does the site have a Stormwater Pollution Prevention Plan?
# Does the Plan include a General Location (USGS) map?
# Does the Plan include a "Narrative Description of Practices"?
# Does the Plan include a detailed site map including outfall locations and drainage areas?
# Does the Plan include a list of significant spills occurring during the past 3 years?
# Has the facility evaluated feasible alternatives to current practices?
# Does the facility provide all necessary secondary containment?
# Does the Plan include a BMP summary?
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
# Does the facility provide and document Employee Training?
# Does the Plan include a list of Responsible Party(s)?
# Is the Plan reviewed and updated annually?
# Does the Plan include a Stormwater Facility Inspection Program?
Has the Stormwater Pollution Prevention Plan been implemented?
Comment: There were no records that the SWPPP had been updated since at least 2009.
There were no records that the SWPPP had been updated since at least 2009.
Analytical Monitoring
Has the facility conducted its Analytical monitoring?
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
Reason for Visit: Routine
Yes No NA NE
■❑❑❑
❑■❑❑
■❑❑❑
❑■❑❑
Yes No NA NE
❑■❑❑
❑❑■❑
Comment: The facilitv is reauired to Drovide aualitative and analvtical monitorina data twice annuallv. There
were several disparities identified during the site visit and through email, regarding monitoring.
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? ❑ ❑ ❑
# Were all outfalls observed during the inspection? ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ❑
# Has the facility evaluated all illicit (non stormwater) discharges? ❑ ❑ ❑
Comment: The facility is required to design, install, and monitor a BMP at outfall 001 that has been shown to
remove or reduce copper in stormwater discharges (such as a bioretention cell), in accordance
with Part II, Section A, Item 2.d.
The facility is required to investigate the source of Cu in stormwater discharges from the facility,
in accordance with Part II, Section B, page 6. In addition, the site is required to continue to make
improvements through site modifications and stormwater controls in order to reduce the Cu in
stormwater discharges, as per Part II, Section A, Item 2.d.
Page 5 of 5