NCS000222_Renewal Application_20210316

Permit Coverage
Renewal Application Form
National Pollutant Discharge Elimination System NPDES Permit Number
Environmental Stormwater Individual Permit NCS 000222
Quality
lease provide your permit number in box in the upper right hand corner, complete the information in the space provided
below and return the completed renewal form along with the required supplemental information to the address indicated.
Owner Information
* Address to which permit correspondence will be mailed
Owner / Organization Name:
Leland Land
Owner Contact:
Jim Healey
Mailing Address:
Orangeburg, SC 29116
Orangeburg, SC 29116
Phone Number:
803-747-0044
Fax Number:
E-mail address:
healeyj @koppers.com
Facility Information
Facility Name:
Carolina Pole Leland, Inc.
Facility Physical Address:
1901 Wood Treatment Road NE
Leland, NC 28451
Facility Contact:
Mike Rouse
Mailing Address:
P. o. Box 370
Leland, NC 28451
Phone Number:
910-371-3131
Fax Number:
910-371-3137
E-mail address:
[e-mail]
Permit Information
Permit Contact:
Jane House
Mailing Address:
P. o. Box 124
Orangeburg, SC 29116
''hone Number:
803-664-4014
(/
`. .ix Number:
NA
E-mail address:
[e-mail]
Discharge Information
Receiving Stream:
Sturgeon Creek
Stream Class:
C
Basin:
Cape Fear River Basein
Sub -Basin:
Number of Outfalls:
1
Facility/Activity Changes Please describe below any changes to your facility or activities since issuance of your permit. Attached a
separate sheet if necessary.
See attached
CERTIFICATION A
I certify that I am f miliar %7theVnfor ton contained in the application and that to the best of my knowledge and belief
such information true, cte e.
Jane House
Print or type nam f person signing above
Please return this completed application form
and requested supplemental information to:
Corporate EHS
Title
DEMLR - Stormwater Program
Dept. of Environmental Quality
1612 Mail Service Center
Raleigh, North Carolina 27699-1612

Sarah Jane House
Director, SHE
March 1, 2021
PRIORITY MAIL 9405 5036 9930 0290 2104 92
DEMLR — Stormwater Program
Dept. of Environmental quality
1612 Mail Service Center
Raleigh, NC 27699-1612
KOPPERS
Koppers Utility and Industrial Products
P. O. Box 1124
Orangeburg, SC 29116
Tel [phone]
Fax [phone]
[e-mail]
www.koppers.com
RECEIVED
Subject: Carolina Pole Leland, Inc. MAR 16 2D21
Stormwater NPDES Permit NCS 000222 Renewal OENR-LAND QUALIN
STORMWWER PERN11-1-TING
Dear Sir:
Enclosed are two copies of the renewal application for the above referenced permit. This
submittal constitutes a timely application for renewal.
"I certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate,
and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fines and imprisonment for knowing violations."
This a li ation is seeking some minor changes in the permit. If you have questions or require
more i fo mation, please contact me at [phone] or by email at housesi(d-)koppers.com.
Sin
NA PONE{ LFLAND, I
�J�e House, CM
</ Director, SHE
Enclosure
cc: H. M. Rollins Company, Inc.

STORMWATER POLLUTION PREVENTION PLAN
DEVELOPMENT AND IMPLEMENTATION
CERTIFICATION
North Carolina Division of Energy, Mineral, and Land Resources — Stormwater Program
Facility Name:
Carolina Pole Leland, Inc.
Permit Number:
NCS000222
Location ;address:
1901 Wood Treatment Road NE
Leland. NC 28451
County:
Brunswick
"I certify, under penalty of law, that the Stormwater Pollution Prevention Plan (SPPP) document and all
attachments were developed and implemented under my direction or supervision in accordance with a system
designed to assure that qualified personnel properly gather and evaluate the information required by the SPPP.
Based on my inquiry of the person or persons who manage the system, or those persons directly responsible
for gathering the information, the information gathered is, to the best of my knowledge and belief, true,
accurate and complete."
And
"I certify that the SPPP has been developed, signed and retained at the named facility location, and the SPPP
has been fully implemented at this facility location in accordance with the terms and conditions of the
Stormwater discharge permit."
And
"I am aware that there are significant penalties for falsifying information, including the possibility of fines and
imprisonment for knowing violations."
Sign (according t"ermit signatory requirements) and return this Certification. DO NOT
SEND STORM TER POLLUTION PREVU TION PLAN WITH THIS CERTIFICATION.
Signature
Jane'Rouse
Print or type name of
[Date March 1, 2021
Corporate EHS
n signing above title
SPPP Certification 10/13

SUPPLEMENTAL INFORMATION REQUIRED FOR RENEWAL OF INDIVIDUAL
NPDES STORMWATER PERMIT
Two copies of each of the following shall accompany this submittal in order for the application
to be considered complete:
(Do not submit the site Stormwater Pollution Prevention Plan)
Initials
J H 1. A current Site Map from the Stormwater Pollution Prevention Plan. The location of
industrial activities (including storage of materials, disposal areas, process areas and
loading and unloading areas), drainage structures, drainage areas for each outfall,
building locations and impervious surfaces should be clearly noted.
JH 2. A summary of Analytical Monitoring results during the term of the existing permit
(if your permit required analytical sampling). Do not submit individual lab reports.
The summary can consist of a table including such items as outfall number,
parameters sampled, lab results, date sampled, and storm event data.
J H 3. A summary of the Visual Monitoring results. Do not submit individual monitoring
reports. The summary can consist of a table including such items as outfall number,
parameters surveyed, observations, and date monitoring conducted.
J H 4. A summary of the Best Management Practices utilized at the permitted facility.
Summary should consist of a short narrative description of each BMP's in place at
the facility. If the implementation of any BMP's is planned, please include
information on these BMP's.
J H 5. A short narrative describing any significant changes in industrial activities at the
permitted facility. Significant changes could include the addition or deletion of
work processes, changes in material handling practices, changes in material storage
practices, and/or changes in the raw materials used by the facility.
JH 6. Certification of the development and implementation of a Stormwater Pollution
Prevention Plan for the permitted facility (Sign and return attached form).
If the final year analytical monitoring of the existing permit term has not been completed
prior to filing the renewal submittal, then the last years monitoring results should be submitted
within 30 days of receipt of the laboratory reports. (i.e. do not withhold renewal submittal
waiting on lab results)

CAROLINA POLE LELAND, INC.
LELAND, NORTH CAROLINA
Stormwater NPDES Permit Renewal
NCS 000222
Prepared By:
H. M. Rollins Company, Inc.
P. O. Box 3471
Gulfport, Mississippi 39505
[phone]
RECF I K 'i
MAR 16 2021
DENR-1-AND QUAUT`;'
STORwPq'/JER PERMITTING
February 26, 2021

CAROLINA POLE LELAND, INC.
Stormwater NPDES Permit Renewal - NCS 000222 February 26, 2021
TABLE OF CONTENTS
1.0 INTRODUCTION ................................................. 1
2.0 PERMIT RENEWAL APPLICATION NARRATIVE AND
SUPPLEMENTAL INFORMATION ................................. 1
2.1 Special Provisions in the Existing Permit ........................... 2
2.2 Supplemental Information Items ................................. 3
2.3 Requested Changes in the NPDES Stormwater Permit Conditions ....... 4
3.0 SUMMARY ...................................................... 8
Prepared by: H. M. Rollins Company, Inc.
Gulfport, MS Page i

C AROLINA POLE LELAND, INC.
Stormwater NPDES Permit Renewal - NCS 000222 February 26, 2021
LIST OF EXHIBITS
EXHIBIT 1 Stormwater Permit Renewal Forms
EXHIBIT 2 Supplemental Information Item 2, Table of Stormwater
Monitoring Results
EXHIBIT 3 Dioxin Reduction Feasibility Study
EXHIBIT 4 Supplement Information Item 1, Site Aerial Photograph
EXHIBIT 5 Supplement Information Item 3, Summary of Qualitative
Monitoring Results
EXHIBIT 6 Supplement Information Item 4, Summary of Best
Management Practices
EXHIBIT 7 Table of Dioxin Solubilities
Prepared by: H. M. Rollins Company, Inc.
Gulfport, MS Page ii

CAROLINA POLE LELAND, INC.
Stormwater NPDES Permit Renewal - NCS 000222 February 26, 2021
1.0 INTRODUCTION
Carolina Pole Leland, Inc. (Carolina Pole) operates a wood treatment facility at 1901
Wood Treatment Road NE in Leland, Brunswick County, North Carolina. The facility
operates under a stormwater NPDES Permit #NCS 000222. That permit expires on
August 31, 2021, and this submittal constitutes a timely submittal for renewal of this
permit.
The Carolina Pole facility treats utility poles utilizing either a water borne preservative
known as chromated copper arsenate (CCA) or an oil borne preservative known as
pentachlorophenol (penta).
The manufacturer of penta has announced that they will cease production no later than
December 31, 2021, so Carolina Pole will have to change its present production to a
different preservative system soon after this permit is renewed. Carolina Pole will seek
some changes to its required monitoring parameters in the renewal permit as a result of
the cessation of the use of penta.
2.0 PERMIT RENEWAL APPLICATION NARRATIVE AND
SUPPLEMENTAL INFORMATION
The renewal process in North Carolina consists of the completion of the required forms
and the provision of certain supplemental information found on a separate checklist. The
Renewal Application Form, the Stormwater Pollution Prevention Plan Development and
Certification, and the Supplemental Information Required for Renewal of Individual
NPDES Stormwater Permit Checklist (Checklist) are found in Exhibit 1 of this
application.
Prepared by: H. M. Rollins Company, Inc.
Gulfport, MS Page 1

CAROLINA POLE LELAND, INC.
Stormwater NPDES Permit Renewal - NCS 000222 February 26, 2021
This renewal application has been discussed with Ms. Aana Gamble of the North
Carolina Department of Environmental Quality (NCDEQ), and the information in this
application reflects her guidance. The balance of this narrative will discuss some specific
requirements in the present permit, some changes being requested by Carolina Pole, and
the Checklist information requested with all stormwater renewal applications.
2.1 Special Provisions in the Existinfz Permit
The existing permit contains two special provisions. One provision required
monitoring for the gasoline constituents, benzene, toluene, and total xylene, in the
monitoring conducted in 2020. That sampling was conducted and the results were
ND for all constituents at both sampling events. The results are included in the
Table in Exhibit 2, which also contains the monitoring results required by Item 2
of the Checklist.
The second special provision was the requirement to conduct a feasibility study
for pollution reduction methods for chlorinated dioxins and dioxin -like
compounds (dioxins). This study was previously provided to the NCDEQ, but a
copy is found in Exhibit 3 of this renewal application at the request of Ms.
Gamble. This study confirmed, as expected, that other anthropogenic sources of
dioxins existed and that significant levels of dioxins were contained in stormwater
that entered the Carolina Pole stormwater conveyance system from off -site
stormwater conveyance systems. Virtually all dioxins found in stormwater are in
particulate form due to the very low water solubilities of dioxins, as confirmed by
the data that shows some of the congeners present at orders of magnitude higher
than their aqueous solubilities. Therefore, best management practices that reduce
particulate loading in stormwater are the best practices for reducing the dioxin
Prepared by: H. M. Rollins Company, Inc.
Gulfport, MS Page 2

CAROLINA POLE LELAND, INC.
Stormwater NPDES Permit Renewal - NCS 000222 February 26 2021
f
concentration in stormwater. The Carolina Pole SWPPP already focuses on
methods to reduce suspended solids in its discharge. Carolina Pole will discuss its
request to remove dioxins from the list of required monitoring parameters in a
later section of this renewal application.
2.2 Supplemental Information Items
An overhead photograph of the site showing the information requested in Item 1
of the Checklist is found in Exhibit 4.
A summary of the analytical monitoring results requested in Item 2 of the
Checklist is found in Exhibit 2.
A summary of the Visual Monitoring results requested by Item 3 of the Checklist
is found in Exhibit 5.
A summary of Best Management Practices requested by Item 4 of the Checklist is
found in Exhibit 6.
Item 5 of the Checklist requests a narrative description of any significant changes
that have taken place at the facility. There have been no significant changes of
processes, work practices, material handling practices, material storage practices,
or raw materials used by the facility during the previous permit cycle. However,
there will be some possible changes during the next permit cycle due to the
removal of pentachlorophenol from the marketplace. Carolina Pole will either
change to another oil borne preservative, such as copper naphthenate or dichloro-
octyl-isothiazolin-one (DCOI), or will simply increase its production with CCA to
Prepared by: H. M. Rollins Company, Inc.
Gulfport, MS Page 3

CAROLINA POLE LELAND, INC.
Stonnwater NPDES Permit Renewal - NCS 000222 February 26, 2021
meet the market demand. Neither of these options would represent a significant
change in facility operations.
Item 6 of the Checklist concerns certification of the development and
implementation of a Storm Water Pollution Prevention Plan (SWPPP). Carolina
Pole has a detailed and effective SWPPP and the signed certification form is
found in Exhibit 1.
2.3 Requested Changes in the NPDES Stormwater Permit Conditions
As mentioned earlier in this application narrative, Carolina Pole is requesting the
removal of dioxins as a required monitoring parameter. This request and the
supporting reasons have been discussed with NCDEQ representative Aana
Gamble. This request is supported by the following points.
1. Very few Stormwater NPDES Permits have monitoring
requirements for dioxins because the very low aqueous solubility of
the dioxin congeners is such that most of the dioxins found in
stormwater are in the particulate form, so the monitoring would not
actually reflect a water concentration. This can be confirmed by
looking at the analytical results in the feasibility study in Exhibit 3
which in many cases report dioxin levels orders of magnitude higher
than the aqueous solubility limits found in Exhibit 7.
2. North Carolina has no published surface water quality standards for
dioxins.
Prepared by: H. M. Rollins Company, Inc.
Gulfport, MS Page 4

CAROLINA POLE LELAND, INC.
Stormwater NPDES Permit Renewal - NCS 000222 February 26, 2021
3. All stormwater runoff from both urban and rural areas contains
dioxins due to atmospheric deposition.
4. Urban runoff contains elevated levels of dioxins due to
anthropogenic sources such as automobile exhaust, boilers,
manufacturing heat sources, and residential combustion sources.
The dioxin study in Exhibit 3 shows that significant levels of
dioxins are found in stormwater from off -site sources that enters the
Carolina Pole stormwater conveyance system on the west side of the
facility.
5. The microcontaminant dioxins associated with pentachlorophenol
are not the human health and environmental risk drivers from the
use of the product. The primary dioxins associated with penta are
the highly chlorinated congeners which have low toxicity. When
EPA published the F032 hazardous waste listing, it specifically
considered the microcontaminants in penta and determined that
penta itself was the primary risk driver and that regulatory actions
that protected human health and the environment from the potential
effects of penta would provide protection from the
microcontaminants with a higher margin of safety. Based on this,
monitoring for pentachlorophenol should be adequate to assess the
potential environmental impact from the use of penta, including its
microcontaminants.
Prepared by: H. M. Rollins Company, Inc.
Gulfport, MS Page 5

CAROLINA POLE LELAND, INC.
Stormwater NPDES Permit Renewal - NCS 000222 February 26, 2021
6. Carolina Pole must transition to another preservative system in 2021
or 2022, and the need to monitor for penta should no longer be
required.
Carolina Pole requests that the requirement to monitor for dioxins be removed
from the permit when it is renewed and that the requirement to monitor for
pentachlorophenol only be continued for calendar year 2022.
Carolina Pole would like to discuss one other permit condition that is problematic
for the facility and that is the screening value for copper of 0.010 mg/l, or 10 parts
per billion. Carolina Pole suspects that any facility having a permit that contains
that copper benchmark has frequent reported exceedances of the benchmark.
These exceedances can lead to additional monitoring requirements and additional
response actions. For the reasons discussed below, Carolina Pole would request
the substitution of chromium III as a routine monitoring parameter in place of
copper. Chromium contained in stormwater that contacts CCA-treated wood is
dominantly in the tri-valent state.
Of the three constituents of CCA, copper is by far the least toxic to
vertebrate species. In CCA formulations, copper represents only
approximately 26% of the total metal mass while chromium and
arsenic represent the balance.
2. Stormwater from off -site flows that enter the Carolina Pole
stormwater conveyance system already contain copper at levels
exceeding the benchmark of 10 ppb as indicated by sampling
Prepared by: H. M. Rollins Company, Inc.
Gulfport, MS Page 6

�AROLINA POLE LELAND, INC.
Stormwater NPDES Permit Renewal - NCS 000222 February 26, 2021
conducted in conjunction with the dioxin feasibility study found in
Exhibit 3.
3. Copper is a ubiquitous metal. It can be present in drinking water in
houses with copper piping at levels exceeding 1,000 ppb.
Information available on the internet indicates that copper levels in
runoff from parking lots and streets can be as high as 280 ppb, in
urban creeks as high as 50 ppb, and from retention ponds, over 40
ppb.
4. The National Stormwater Quality Database, available at
www.bmpdatabase.org/nsq-d.html contains data on copper levels in
stormwater runoff. This database contains data from 5,179 samples
for copper from locations across the U.S., and reports an average
value of 33.16 ppb and a maximum value of 7,270 ppb. For the
1,002 samples for which both total recoverable copper and soluble
copper were analyzed, the total recoverable to soluble ratio for
copper was 3.329. The copper benchmark of 10 ppb is based on
toxicity for soluble copper not total recoverable copper, yet site
monitoring is required for total recoverable copper.
5. Monitoring for arsenic and chromium III provides more useful and
meaningful data for evaluation of the effectiveness of the facility's
SWPPP than monitoring for copper which is found at levels
exceeding the 10 ppb screening value in stormwater flow from off -
site drainage where it enters the Carolina Pole stormwater
conveyance system.
Prepared by: H. M. Rollins Company, Inc.
Gulfport, MS Page 7

CAROLINA POLE LELAND, INC.
Stormwater NPDES Permit Renewal - NCS 000222 February 26, 2021
3.0 SUMMARY
This application for renewal of the Carolina Pole Stormwater NPDES Permit, NCS
000222, reflects the fact that there have been no significant changes in facility
operations. However, the application does seek to make some changes in monitoring
parameters in order to eliminate data production that is of limited value in terms of
protection of surface water quality and assessment of the effectiveness of the facility
S WPPP.
Prepared by: H. M. Rollins Company, Inc.
Gulfport, MS Page 8