NCS000291_Response to NOV_20221031

Lawyer, Mike
From: [e-mail]
Sent: Monday, October 31, 2022 5:00 PM
To: Lawyer, Mike
Subject: [External] Response to notice of violation (NOV-2022-PC-0583)
Attachments: stormreply.docx; 2022 Feasibility of Reducing Contaminants to Stormwater Runoff.docx;
Stormwater Pollution Prevention Plan (2022 revision).docx; Scan2022-10-31_163138.pdf
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Good Afternoon,
Thank you for taking my call earlier today. I have attached our written response to the Notice of
Violation referenced by (NOV-2022-PC-0583) regarding our Stormwater Permit
NCS000291. Included in this response you will find an amended copy of our SPP, a feasibility review
to reduce Stormwater contamination for 2022, the written response to the violations labeled
stormreply and a pdf file with our documentation for the corrective steps we have taken. As stated
earlier, we are having issues with our email, so I will also duplicate this from another email address.
Sincerely,
Rodney McRae
McRae Woodtreating Inc.

McRae Woodtreating Inc.
105 National St
Mount Gilead, NC 27306
It has never been our intention to be out of compliance in any way with regards to
our stormwater permit. I believe our lack of compliance largely rests upon my
shoulders due in part to my misinterpretation and the combined added pressure of
the pandemic and associated challenges. With regards to my misinterpretation, I
had asked a question many years ago regarding a drought period and the ability to
get a stormwater sample. The intent of the question was regarding to what lengths
I should go to obtain a sample. A paraphrase of that question would have been, "It
seems like the only time it has rained lately is either at night or on the weekend
and I have not seen any significant rain that would meet the definition of a
representative stormwater event to get a sample, is this ok or should I be more
determined to get a sample by coming in the middle of the night, etc?" A
paraphrase of the answer was that "We are more concerned with you following
BMP to prevent stormwater contamination than you collecting the sample exactly
before the specified monitoring period ends." As a result, I interpreted that to
place more emphasis on making sure we were doing our part not to contaminate
than I did documenting what had been done. I am not in any way trying to shift
blame or skirt my responsibility, but rather acknowledge that I misunderstood. As
we have always strived to be responsible and minimize our risk of stormwater
contamination, the majority of the issues Mr. Lawyer pointed out were regarding
documentation. Per Mr. Lawyer's evaluation and corrective guidance, I recognize
that the documentation is equally important.
Secondly, with any small business, managers are often required to wear many hats.
As a result of the pandemic and all the new challenges it created to keep the
business going and employees safe (including my father who is 82), 1 let all those
pressures affect my remembrance to document what we were already doing. Mr.
Lawyer pointed out that I may be doing all of the requirements with excellence, but
the burden of proof is to document what we are doing. Similarly, Mr. Lawyer

reminded me that even during a drought as in my above -mentioned example, we
are to document that no representative stormwater event occurred during the
monitoring period per the requirements of the stormwater permit. As a result of
Mr. Lawyer's site inspection, we have addressed each of the noted violations and
made changes to the Stormwater Prevention Plan to correct this going forward and
prevent any further violations. Similarly, we are already in the habit of
documenting more information than is required for our third -party inspection and
assays of our treated lumber. I have taken corrective action to apply this same type
of diligence to the documentation required of our permit. As a result, I have
addressed the documentation issue with our employees and assigned
documentation procedures for the required tasks. I do not take any of these
requirements lightly, we ask for the opportunity to correct the violations and
welcome any feedback to ensure all the necessary corrections have been made.
I would also like to add that we do currently have a stormwater analysis kit waiting
on site for a representative stormwater event to occur. The kit has been on site
since before Mr. Lawyers visit. I had hoped that the remnants of Hurricane Ian
would produce opportunity to gather a sample, but it did not produce enough flow
to collect a sample at the Outfall site. At the time of this writing, there is a 60%/90%
chance of rain Monday day/evening October 31st. In the event that .we do see a
representative stormwater event on that day, that sample will be expediently sent
for analysis along with the proper documentation.
We appreciate your understanding and assistance in bringing McRae Woodtreating
back to compliance with the Stormwater Permit.
Sincerely,
Rodney McRae
McRae Woodtreating Inc.

Stormwater Pollution Prevention Plan
1. This plans covers the physical facility known as McRae Woodtreating Inc. which has a
physical address of 105 National Street (we were formerly referenced at.Julius
Street is the name of our private drive. The 455, Julius Chambers Avenue is still the
primary highway in front of the Iplant which is also known as NC Hwy 10.9 except as
designated inside of the city limits.: This facility currently pressure treats southern
yellow pine with the preservatives CA-C which is branded under the trade name
Preserve, and EL-2 which is branded under the trade name Ecolife both by the Viance
Corporation.
a. Please see the following attached map labeled Al-A5 showing the facilities` general
location including Outfall site.
b. All major bulk storage tanks are positioned on the facility such that spills would be
contained in a concrete bulk storage area located at the base of a sloping concrete
drip pad and under the primary and secondary work tanks. In other words, this
facility was built with concrete bulk storage as secondary containment in the event
of a major spill such that there is enough storage space to contain all of the
chemicals stored in the bulk storage tanks. All employees are instructed about safe
handling practices of the bulk storage chemicals and what to do in the event of a
spill. The facility is set up so that lumber is loaded and unloaded from the same
tram for the treatment cylinder with one side designated as the loading side and the
other designated as the unloading side. The tram is located at the base of the slope
of the drip pad such that any chemical that drips off the lumber would return to a
storage trough. From the storage trough it would eventually be pumped back into
the primary work tank where the solution strength is constantly monitored so that
the recaptured solution strength can be factored and diluted accordingly. After the
wood has been unloaded from the tram, it is required to stay on the drip pad until
there is no longer any visible dripping. Furthermore, because of the treatment
process, the chemical actually binds to the wood and when combined with a long
final vacuum there is very little residual left to drip. Trace amounts that remain
would be derived from the principal components of CA-C, EL-2, Supatimber H.E.,
Moldex 45 and ACQ-AF. In their respective order the list refers to the preservatives,
mold deterrents and an anti -foam solution with the primary chemicals coming from

the preservative in the form of copper. A full list of chemical composition is
available from the msds sheets which are on file in our CA-C and Ecolife Operators'
Manual stored on the premises or is also available from the Viance corporation.
Other possible contaminants to storm water would be any fluids leaking from
shipping machinery (forklifts, trucks, etc.) in the form of gasoline, diesel, antifreeze,
hydraulic fluid and oil. All of our sludge/hazardous waste is handled by our chemical
supplier (Viance) through Terra Storage Facility. This waste is typically generated
from mud which accumulates in our collection trough over time. None of this waste
comes into contact with any outside stormwater runoff as this trough is at the base
of the slope of the drip pad.
c. Please refer to the attached site map labeled 61-63.
d. We have had no significant spills or leaks over the past seven years.
e. We are currently using Waypoint Analytical (Formerly Prism Laboratories, Inc.) at
449 Springbrook Road in Charlotte, NC to monitor the presence of contaminants in
the stormwater and we have implemented a plan to monitor the stormwater as per
the requirements of the permit on a semi-annual basis.
f. Documentation policy regarding analytical reporting has been amended to include
first available date of arepresentative stormwater event during business hours for
each of the required monitoring periods. As well as documentation for a lack of a
representative stormwater event during a; monitoring period.
2. From day one of initial start-up this plant has been designed to receive and store
materials necessary for the treatment process such that any exposure to stormwater
runoff would be minimized. Even the off loading of bulk chemicals is done with the
tanker parked on the drip pad such that in the event of a spill the material would be
contained.
a. Refer to the following attached photographs for illustrative purposes of material
handling and storage. With the exception of fueling, which meets the exception
requirements due to the size of the tanks, all other contaminant risks to stormwater
runoff have been minimized.
b. All materials used to pressure treat the southern yellow pine are stored such that
they have secondary containment. Refer to the attached pictures for illustration of
this secondary containment.
c. 1 Lumber is not permitted to be removed from the drip pad area until all visible
signs of dripping have ceased.
2 Filling of the bulk storage tank for CA-C from the tanker must be done with the
tanker parked on the drip pad.

3 Refueling of trucks and forklifts from the 2 (500 gallon) above ground tanks
(below threshold for secondary containment) must be done with someone
present at pump.
4 All bulk storage totes (EL-2) must be stored in their designated covered location
which channels to the secondary containment trough.
5 Spill kits and absorbent pads must be kept near their respective chemicals to
facilitate quick clean up in the event of a spill.
6 All machinery is to be maintained and inspected for leaks which could impact the
stormwater runoff.
7 Currently, monitoring of the stormwater for contaminants is to be done 'semi-
annually, in accordance, with the, Storm awater Runoff Permit. If the requirements
of the permit require the frequency to be increased the SPP is to. be updated'.
with amended requirements:
3. With regard to spill prevention, all employees are trained as to the requirements to
properly handle all chemicals used in the treatment process. This facility utilizes
basically four main chemicals. The CA-C (preservative) is brought in by tanker and the
tanker is required to be off loaded while parked on the drip pad. All hose connections
thereby also run across the drip pad so that any leaks would end up in the containment
trough. The CA-C is stored in a steel tank above concrete secondary containment and is
pumped and handled by mechanical means to the work tanks where all of the process is
located over the concrete containment area. EL-2 is handled in totes (250 gallon) and
once unloaded from the truck is transported on the drip pad to its storage room where
any spill would run to the containment trough. Supatimber H.E. and Moldex 45 (mold
preventative) is handled in totes and is positioned near the containment area such that
spills would also end up in the concrete containment area. This chemical is acidic and a
spill kit / neutralizer is on site beside the mold preventative to neutralize the acid. The
fourth chemical is diesel fuel and it is stored in 2 (500 gallon) tanks (one tank is for on
road use and the other is for off road use). The diesel fuel tanks are below the threshold
for secondary containment requirement but we have spill pads on site in the event of a
spill and all refueling is to be done with an employee present to prevent unmanned
emptying of the tanks if the hose were to become dislodged or ruptured. We also have
a contingency plan in place with contact information posted on entryways in the event
of major spill that is on file as well.
4. All plant machinery necessary for the treatment process is maintained and inspected
per the manufacturer requirements and recorded maintenance is kept on file. This also
includes the lift trucks and flatbed trucks. Furthermore, each flatbed truck and lift truck
is given a walk around inspection on a daily basis with documentation. If the machinery

is currently in service, any leaks or repairs needed are performed on a timely basis.. We
also inform any owner/operator which presents in a third party vehicle for loading if we
notice any obvious leaks to their equipment. Routine sweeping and inspection of the
drip pad is done on a monthly basis. All employees are encouraged to maintain overall
appearance of the yard and premises with cleanliness, trash pick-up and yard
maintenance .
5. Team member training with regard to spill response, preventative maintenance, safety
and stormwater runoff is recorded in Table A.
6. All employees are responsible to ensure that all equipment is properly maintained and
that stormwater pollution prevention protocol is followed. Rodney McRae is
responsible for the coordination, development and implementation of the plan.
7. As of October2022, this document is considered to be our stormwater pollution
prevention plan and any revisions/amendments will be documented as such to
reference this current plan.
8. Refer to Table B for a record of facility inspections.
9. Refer to the written NC Stormwater Reporting Form for a record of stormwater runoff
monitoring and qualitativeobservations. As the electronic reporting service becomes
fully operational results are to be recorded electronically.. Also, refer to attached
documentation from the analyzing lab. All plant and vehicle maintenance is recorded in
our plant maintenance log and is kept on file in the office.
10. Refer to Table C for a record of lift truck inspections.
11. Refer to Table D for'a record of flatbed truck inspections.

Table A
Team Member Training
Date Topic Team Members

Table B
Facility Inspections
Date I Area Inspected I Team Member

Table C
Lift Truck Inspections
Date All Clear Problem Team
Observed Member

Table D
Flatbed Truck Inspections (Tandems)
Date All Clear Problem Team
Observed Member

Table D2
Flatbed Truck Inspections (Eagle and 2 ton)
Date All Clear Problem Team
Observed Member

Pictures of Material Handling, Storage and Secondary Containment

Map Table of Contents
Map A1- Topographical Location Map for Permit NCS000291
Map A2 - Street Map with Relative Land Marks
Map A3 - Satellite View of Site
Map A4 - Outfall Location and Water Flow.
Map A5 - Property Lines Over Satellite View
Map B1- Geological Survey
Map B1A - Localized Topography
Map B2 - Site Property Boundary Overlay
Map B2A - Boundary Without Overlay
Map B3 - Main Building

JON C: LOCATION MAP
Map A-1
Part 1 Page 2 of 2
Permit No. NCS000291

Map A-2
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Map A4
Outfall Location and Water
Flow Direction

A = Main Gate = Outfall Area (339)
B = 1st Gate (340)
C = Outer Wood Line (348)
D = Lower Wood Line (345)
E = Unloading Area (346)
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Map A5
1"=186'

Map B-1
Permit No. NCS000291
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Map B-IA
Topographical Representation

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2022 Feasibility of Reducing Contaminants to Stormwater Runoff
As has been the case for many years, we have discussed the possibility of adding
additional shelters to house treated lumber. Based upon BMP we are already
following, we believe the most logical and best step to reducing any significant
rain contact would be to add additional shelters until all of our treated lumber is
stored under shed. Housing treated lumber under a shed not only prevents direct
rain contact but also reduces direct sunlight exposure which can facilitate warping
in the top layers of packed lumber. This would be a value added benefit as well as
reducing possible contamination. We have added, a 40x70 lumber shed to our
facility since our last inspection in 2011. This shed houses our 2x4 through 2x10.
Currently, our top three options we have considered are as follows.
The first option would be to construct a removeable roof that is slightly larger
than each length of lumber. This removeable roof would be set to the side with a
forklift and then placed back on the remaining stack after the desired pack had
been obtained. This option is often used as additional cover where covered
storage is limited. However, this option does dramatically affect the time
required to load trucks and runoff reduction would be dependent on correct
placement of the removeable roof by the lift driver. While this option may be the
least expensive, we believe this option it not an efficient choice at the present
time, as we handle so many different grades and sizes of lumber and the
reduction to contamination would not be as significant as a permanent structure.
A second option would be to add a continuous line of pole sheds that span the
perimeter of our current lot. This option would allow us to keep our same basic
configuration with a minimal amount of disruption of our daily workflow to
construct. Based on a current estimate (October 2022), construction cost would
exceed $100,000. However, due to the narrowness of this option, we do not
believe exposure to blowing rain would be as effective as a larger consolidated
structure.
A third option would be to add two more sheds including asphalt or concrete at
the 40x70 size. We believe this option would be the most efficient to virtually
eliminate our stormwater contamination risk. This is the option we hope to be
able to construct at some point. Using a current estimate (October 2022) from a

local contractor that constructed similar storage at a nearby lumber facility, the
cost would exceed $140,000.
We do not list the above three options as being all inclusive, but we believe they
are some of the most cost effective solutions. As stated above, due to the
addition of our most recent shed which does contain some of our fastest moving
items, we have seen a reduction in damaged and warped lumber. Because we are
a small family owned company, we do believe in investing for our future as our
finances will allow. Reducing our stormwater contamination risk and increasing
the shelf life as well as protection of our lumber are things worth investing in. We
are hopeful that we will be able to add more storage space in the near future such
as the third option or something similar that may be more financially achievable.
Rodney McRae
McRae Woodtreating Inc.
October 2022

Table A
Team Member Training
Date
Topic
Team Members

Facility Inspections
Date
Area Inspected
Team Member
G'��.

Lift Truck Inspections
Date All Clear Problem Team
Observed Member
y

Table D
Flatbed Truck Inspections (Tandems)
Date
All dear
Problem
Observed
Team
Member
41 4.
N
i

Table D2
Flatbed Truck Inspections (Eagle and 2 ton)
Date
All Clear
Problem
Observed
Team
Member
i
I