NCG210000_Katesville Pallet Mill Inspection Letter_20081231

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Ms. Ellen Kemp, Owner
Katesville Pallet Mill, Inc.
8367 NC Hwy 56
Louisburg, NC 27549
Michael F. Easley, Governor
�� William Co. Russ, Jr., secretary
3 j fir} v North Carolina Dcparlment of Environment and Naturnl Resources
I I� Colcen H. Sullins, Director
Division of water Quality
December 3 I, 2008
Subject: Evaluation of Timber Industry Site for Stormwater Permit
Katesville Pallet Mill, Inc.
7119 NC Hwy 56
Louisburg, NC 27525
Franklin County
Dear Ms. Kemp:
On December-18, 2008 Mr. Ken Pickle of the Stormwater Permitting Unit, Central Office and
Mr. Myrl Nisely of the Raleigh Regional Office of the Division of Water Quality carried out an
appraisal of the stormwater flow patterns around the above manufacturing site. This evaluation
was made at the invitation of Mr. Erwin Crucy to establish whether or not the facility has a
point -source discharge of stormwater runoff that would require the facility to apply for the
Division's NCG210000 stormwater discharge permit for the timber products industry.
Introduction
Katesville Pallets, Inc. manufactures hardwood pallets on the north side ,of' Hwy 56 between
Louisburg and Franklinton, NC. On the south side, the same company manufactures mulch.
There is no composting by the company.
Conclusion
As suggested by Mr. Crucy, we agree that operating practices and site configuration do not result
in a point -source discharge of stormwater from the areas of industrial activity. Further, it
appears that the natural site topography and minor grading features cause stormwater to leave the
areas ol'industrial activity as sheet flow through well vegetated zones in such a way that no
harmful environmental impact is anticipated, On these two bases, the facility will not be
required to apply for a stormwater permit,
Observations
The sawmill, north of the highway, handles ordinary and partially trimmed fogs (cants) from
which pallet wood is cut. Sawdust is controlled by a cyclone air handler and delivered into semi-
trailers, then is sold as boiler fuel. Unusable lengths of wood produced from sawing pallet
material are put through a chipper at the west end of the sawmill, conveyed into semi -trailers,
and sold as boiler fuel, as well. The lay -down areas for the logs and cants, as well as the staging
for the chipper, slope in two directions, toward Hwy 56 and to the western end of the site.
Stormwater runoff enters into a DOT swale that runs along Phelps Road. There was no visible
NC Division or Water Quality Raleigh Regional Oil ice Surface Water Protection Phone [phone] Customer service 577.623-6M
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Katesville Pallet Mill, Inc. December 22, 2008
point discharge into this swale.
Page 2 of 2
Evidence from grasses flattened at the entrance of the culvert indicated a recent significant
stormwater flow into the culvert, but it appeared that most of the flow would be coming from
along the roadway and areas near this facility, riot from the pallet site. A culvert under Phelps
Road carries the water from that swale through an overgrown channel to another culvert under
Hwy 56. There was a channel in a wooded area for about 75 feet that was reported by Mr. Cruey
to spread out onto a plane in the woods. We did not enter that area to verify a spreading of the
water into sheet flow because it was behind an electrified fence.
The mulching operation on the south side of Hwy 56 is spread over a large area. All three sides
that are down gradient from the mulch piles are grassy areas that change into wooded zones on
property owned by the company. The woods are several hundred feet deep. Any mulch runoff
travels as sheet flow toward and into the woods. No point discharges of stormwater were
observed during this assessment.
There were two locations where modest erosion had occurred. One of these, down slope froln
some mulch piles was in the process of being regraded to correct the erosion. Silt fences were in
place. Mulch has been removed, and the area was reworked to plant grass for better
stabilization. The other location was in a fenced area used by a herd of cows. This, too, will be
regraded and planted to stop the erosion. The sediment from both sites traveled less than 15 feet
before spreading and coming to a stop.
Walking the complete perimeter of the property, we determined that no points of concentrated
stormwater flow could be located. No stressed vegetation was observed. This site can be
considered to have no point -source discharge of stormwater from the industrial activity areas,
and consequently is not required to have coverage Linder general permit NCG210000.
Please understand that industrial sites are often dynamic. As such, the need for a permit may be
revisited/reopened by DWQ or Katesville Pallet Mill, Inc. Note that if site conditions change
whereby stormwater discharges do occur, a permit is required. The failure to have the proper
permit is subject to civil penalties.
If you have questions about our site visit, please contact Ken Pickle at 919-807-6376 or Myri
Nisely at 919-791-4255.
Ken Pickle
Environmental Engineer II
Stormwater Permitting Unit
DWQ Central Office
cc: Central Files
QRMSWP files
Bradley Bennett, Central Office
Sincerely,
YO,
Myri A. Nisely
Environmental Chemist
Surface Water Protection Section
Raleigh Regional Office

December 18, 2008
Recon Visit to Katesville Pallets & Mulch Facility
Hwy 56
Louisburg, NC 27549
Inspectors: Ken Pickle and Myrl Nisely
Interviewed Erwin Cruey
See Pictures in SAPictures 20081Mulch Field TriplKatesvillePalets
Introduction
Katesville Pallets, Inc. manufactures hardwood pallets on the North side of Hwy 56
between Louisburg and Franklinton, NC. On the South side the same company
manufactures mulch.
This site evaluation was made at the invitation of Mr. Cruey to establish whether or not
the facility met a definition of stormwater runoff that would require them to apply for
NCG210000 timber products permit. He contended that the site has no point discharge,
so does not require the permit.
Conclusion
We agree that operating practices and site configurations cause stormwater to leave as
sheet flow through well vegetated zones in such a was that no environmental impact is
occurring. The company will not be required to apply for a stormwater permit.
Observations
The sawmill, North of the highway, handles ordinary and partially trimmed logs (cants)
from which pallet wood is cut. Sawdust is controlled by a cyclone air handler and
delivered into semi -trailers, then is sold as boiler fuel. Unusable lengths of wood
produced from sawing pallet material is put through a chipper at the west end of the
sawmill, conveyed into semi -trailers, and sold as boiler fuel, as well. The lay -down areas
for the logs and cants, as well as the staging for the chipper slope both toward Hwy 56
and to the western end of the site, into a DOT swale that runs along Phelps Road. There
was no point of discharge to this swale, however. Evidence from grasses at the entrance
of the culvert indicated a significant flow of water into the culvert, but it appeared that
most of the flow would be coming from along the roadway and areas away from this
facility, not from the pallet site. A culvert under Phelps Road carries the water from that
swale through a tree -lined channel to another culvert under Hwy 56. There was a channel
for about 75 feet that was reported by Mr. Cruey to spread out onto a plane in the woods.
We did not enter that area to verify a spreading of the water into sheet flow because it
was behind an electrified fence.

Corroboration came from another source, however. Martin Richmond and Keith Larick
had earlier walked that area to observe the impact of a spill of enzyme residuals at the
intersection of Hwy 56 and Phelps Rd. Martin confirmed that there is no continuing
stream, just as Mr. Cruey claimed.
The mulching operation on the South side of Hwy 56 is spread over a large area. On all
sides, though, are grassy areas that change into wooded zones quite deep on property
owned by the company. Any runoff travels as sheet flow toward the woods, and in many
places encounters berms. On all sides, there were no point discharges of stormwater.
There is no composting by the company.
There were two locations where modest erosion had occurred. One of these, down slope
from some mulch piles was in the process of being regraded to correct the erosion. Silt
fences were in place. Mulch has been removed, and the area was reworked to plant grass
for better stabilization. The other location was in a fenced area used by a herd of cows.
This, too, will be regraded and planted to stop the erosion. The sediment from both sites
only traveled a few feet before spreading and coming to a stop.
Walking the complete perimeter of the property, we determined that there clearly were no
points of concentrated stormwater flow. No stressed vegetation was observed. This site
can be characterized as a non -discharge location exempt from the need for permit
NCG210000.