NCS000122_Response to NOV_20200306

HUNT
ENVIRONMENTAL ASSOCIATES
3330 Saddletree Road
PO Box 390
Lumberton, NC 28359
Phone: [phone]
Fax: [phone]
March 6, 2020
Mrs. Lauren Garcia
Environmental Specialist II
Stormwater Program
Division of Energy, Mineral, and Land Resources
North Carolina Department of Environmental Quality
RE: Response to General Timber NOV
Mrs. Garcia,
Please see the responses to the NOV issued on October 7, 2019.
Failure to include a site map in the Stormwater Pollution Prevention Plan (SWPPP). [Part
II, Sec. A, Item I C] A site map must have been removed from the hard copy but the
SWPP does include a site map. To resolve this HEA will include the site map that should
accompany the SWPP.
2. Failure to review and update the SWPPP on an annual basis, or when these 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 7]
a. There were no records that the SWPPP had been updated since least 2009. The
SWPP was updated in 2014 and was being updated at the time of the NCDEQ
visit. There should have been a record on file.
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
result the facility has not attempted to sample the outfall since at least 2010.
Outfall 002 should be removed from the permit since it is no longer receiving
water. Outfall 002 will be removed from the SWPP for monitoring and stated why
it was removed from monitoring.

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
wood chip pile towards Georges Creek. This outfall was not part of the original
permit, so no sampling was conducted. After NCDEQs visit it was made clear that
this area would be added the new permit and would require sampling. This outfall
will be added to the SWPP once the new permit has been issued.
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. Hay Bales are installed near
Outfall 001
4. Failure to conduct qualitative monitoring at each stormwater discharge outfall. [Part II,
Sec. C] Outfall 001 is the only outfall in the current permit that receives any flow to it.
Outfall 002 was removed from the sampling regimen and due to the closure of the
CAW on -site Outfall 003 no longer flows.
5. Failure to design, install, and monitor a BMP at Outfall that has shown to remove or
reduce copper in the stormwater discharges (such as a bioretention cell). [Part II, Sec. A,
Item 2d]
a. A copper BMP had been maintained at Outfall 011 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. Hay Bales are installed near Outfall 001. Over time these most likely have
deteriorated if they were not visible. Additionally, due to the fact that the CCA
product is most likely producing the issue on -site the product was moved out of
the low-lying areas. In our email dated 5/16/2019 we discussed this and offered to
change the BMPs based on your recommendations.
Sincerely,
Jordan Davis
Environmental Scientist