NCS000291_NOV_20220928

ROY COOPER
Governor
ELIZABETH S. BISER
Secretory
BRIAN WRENN
Director
CERTIFIED MAIL: 7018 0040 0000 4771 9619
RETURN RECEIPT REQUESTED
McRae Woodtreating, Inc.
Attn: Stimpson McRae, President
PO Box 8
Mount Gilead, NC 27306
NORTH CAROLINA
Environmental Quality
September 28, 2022
Subject: NOTICE OF VIOLATION (NOV-2022-PC-0583)
NPDES Individual Stormwater Permit NCS000291
McRae Woodtreating, Inc.
Montgomery County
Dear Mr. McRae:
On September 22, 2022, Mike Lawyer, Environmental Program Consultant with the Fayetteville Regional Office of the
Division of Energy, Mineral and Land Resources (DEMLR), conducted a site inspection for the McRae Woodtreating, Inc.
facility located at 455 Julius Chambers Avenue (105 National Street) in Montgomery County, North Carolina. A copy of the
Compliance Inspection Report is enclosed for your review. Mr. Rodney McRae, Plant Manager, and Mrs. Lanna McRae,
Office Manager, were also present during the inspection and their time and assistance is greatly appreciated. The site visit
and file review revealed that the subject facility is covered by NPDES Individual Stormwater Permit NCS000291. Permit
coverage authorizes the discharge of stormwater from the facility to receiving waters designated as an unnamed tributary
to Big Branch, a class C stream in the Yadkin -Pee Dee River Basin.
As a result of the site inspection, the following permit conditions violations are noted:
1) Stormwater Pollution Prevention Plan (SPPP)
Per Part II, Section A, item 1(c)... The site map included with the Stormwater Pollution Prevention Plan does not show all of
the required information as detailed in the permit.
Per Part II, Section A, item 1(e)... There is no documentation that the stormwater outfalls have been evaluated or re -certified
annually for the presence of non-stormwater discharges.
Per Part II, Section A, item 2(a)... There is no documentation of a feasibility study.
Per Part 11, Section A, item 5...There is no documentation of annual employee training.
Per Part II, Section A, item 7...There is no documentation of an annual review/update, which would include an updated list
of significant spills or notation that none have occurred, re -certification that the stormwater outfalls have been evaluated for
the presence of non-stormwater discharges, and re-evaluation of the effectiveness of the BMPs.
Per Part II, Section A, item 8... There is no documentation regarding facility inspections, which are different from and in
addition to the stormwater discharge monitoring requirements.
Per Part II, Section A, item 9... Based on the lack of documentation as detailed above, the Stormwater Pollution Prevention
Plan has not been properly implemented.
North Carolina Department of Environmental Quality (Division of Energy, Mineral and Land Resources
Fayetteville Regional Office 1 225 Green Street. Suite 714 ( Fayetteville, North. Carolina 28301
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Upml-dal Em(runmenUl Que11tY 910.433.3300

2) Analytical Monitoring Requirements
Per Part 11, Section B... Analytical monitoring has not been conducted and/or recorded in accordance with permit conditions.
3) Qualitative Monitoring Requirements
Per Part 11, Section C... Qualitative monitoring has not been conducted and/or recorded in accordance with permit conditions.
Other Observations
Please refer to the enclosed Compliance Inspection Report for additional comments and observations made during the
inspection.
Requested Response
You are asked to respond to this office, in writing, within 30 calendar days from receipt of this notice. Your written response
should include a reasonable explanation as to why the aforementioned violations have occurred as well as a Plan of Action
to prevent these violations from recurring.
Action Items
Immediately review and amend the facility's Stormwater Pollution Prevention Plan as needed and begin incorporating
documentation pertaining to the annual update requirements of the permit. Conduct and record monitoring per the conditions
of the permit.
Thank you for your attention to this matter. This office requires that the violations, as detailed above and summarized
in the enclosed inspection report, 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 these
matters, please contact Mike Lawyer at [phone] or [e-mail].
Sincerely,
imothy L. LaB y, PE
Regional Engineer
DEMLR
TL/ml
Enclosure: Compliance Inspection Report
ec: Rodney McRae, Plant Manager — McRae Woodtreating, Inc.
Toby Vinson, Jr., PE, CPESC, CPM, Chief of Program Operations — DEMLR
Brad Cole, PE, Chief of Regional Operations — DEMLR
Danny Smith, Supervisor— DEMLR, Stormwater Program
Brianna Young, Industrial Individual Permits Coordinator — DEMLR, Stormwater Program
DEMLR NPDES Stormwater Permit Laserfiche File
cc: FRO — DEMLR, Stormwater Files

Compliance Inspection Report
Permit: NCS000291 Effective: 04/01/11 Expiration: 03/31/16 Owner: McRae Woodtreating Inc
SOC: Effective: Expiration: Facility: McRae Woodtreating Inc
County: Montgomery 455 Julius Chambers Ave
Region: Fayetteville
Mount Gilead NC 27306
Contact Person: Rodney McRae Title: Plant Manager Phone: [phone]
Directions to Facility:
System Classifications: SWNC,
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
On -site representative
Related Permits:
Certification: Phone:
Rodney McRae 910-439-6281
Inspection Date: 09/22/2022 Entry
Time 10: 5AM
Primary Inspector: Mike Lawyer
Secondary Inspector(s):
Reason for Inspection: Routine
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ❑ Compliant Not Compliant
Question Areas:
N Storm Water
(See attachment summary)
Exit Time: 12:35PM
Phone: [phone]
Inspection Type: Compliance Evaluation
Page 1 of 3

Permit: NCS000291 Owner - Facility: McRae Woodtreating Inc
Inspection Date: 09/22/2022 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Inspection conducted as part of the permit renewal process. Permit renewal application submitted in early 2018. Reviewed
facility's current Stormwater Pollution Prevention Plan (SWPPP), which is dated March 2018. The SWPPP contains the
major components, however there is no documentation pertaining to the annual review and update requirements for
employee training, listing of significant spills or notation that none have occurred, non-stormwater certification, etc.
Additionally, there is no documentation of a feasibility study or facility inspections. The site map needs more detail to show
the location of the stormwater outfall(s), material storage areas, disposal areas, loading/unloading areas, site topography,
drainage features, drainage areas for each outfall, direction of stormwater flow, etc. In reviewing the facility's available
monitoring records, it appeared that several monitoring periods have been missed. The monitoring frequency under the
current/expired permit is semi-annual, however monitoring was only conducted and recorded during the following periods;
May 2011, May 2012, August 2012, February 2014, February 2015, December 2016, December 2018 and November 2021.
The monitoring results indicate exceedances of the benchmark value for Copper with all other parameters below the
respective benchmark values. Vehicle maintenance is conducted onsite, but less than 55 gallons of new motor oil is used
per month. After the SWPPP/records review, observations were made of site conditions including the covered loading area
and drip pad, sheltered product storage area, ASTs with secondary containment, and stormwater outfall.
Based on the information provided in the permit renewal application and onsite discussion with Mr. Rodney McRae, facility is
currently using a preservative called CA type C, which does not contain Chromium or Arsenic like the preservative previously
used (ACQ). The current preservative contains Copper and Azole, which is a binding agent to keep the Copper in solution.
Based on this change in preservative as well as the available monitoring records indicating results well below the benchmark
values for Chromium and Arsenic, the removal of Chromium and Arsenic from the monitoring parameters in the renewed
permit should be considered.
Page 2 of 3

Permit: NCS000291 Owner - Facility: McRae Woodtreating Inc
Inspection Date: 09/22/2022 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Stormwater Pollution Prevention Plan
Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan?
0 ❑ ❑ ❑
# Does the Plan include a General Location (USGS) map?
0 ❑ ❑ ❑
# Does the Plan include a "Narrative Description of Practices"?
0 ❑ ❑ ❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
❑ M ❑ ❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
0 ❑ ❑ ❑
# Has the facility evaluated feasible alternatives to current practices?
❑ 0 ❑ ❑
# Does the facility provide all necessary secondary containment?
M ❑ ❑ ❑
# Does the Plan include a BMP summary?
M ❑ ❑ ❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
0 ❑ ❑ ❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
M ❑ ❑ ❑
# Does the facility provide and document Employee Training?
❑ 0 ❑ ❑
# Does the Plan include a list of Responsible Party(s)?
0 ❑ ❑ ❑
# Is the Plan reviewed and updated annually?
❑ M ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
❑ 0 ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
❑ 0 ❑ ❑
Comment: Site map does not contain the necessary details as required by the permit. A feasibility
study is
not incorporated into the SWPPP. There is no documentation of an annual review/update to
include employee training, spill history, non-stormwater certification, etc.
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring? ❑ 0 ❑ ❑
Comment: Monitoring has not been conducted/recorded per the frequency in the permit. See Inspection
Summary for details.
Analytical Monitoring
Yes No NA NE
Has the facility conducted its Analytical monitoring? ❑ 0 ❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ ❑
Comment: Monitoring has not been conducted/recorded per the frequency in the permit. See Inspection
Summary for details.
Permit and Outfalls
# 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:
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
❑❑■❑
❑■❑❑
Page 3 of 3