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Home My WebLink AboutNCS000566_Fact sheet binder_20230622 DEQ / DEMLR FACT SHEET FOR NPDES INDUSTRIAL INDIVIDUAL STORMWATER PERMIT DEVELOPMENT Basic Information for Permit Issuance and Renewals: Permit Writer/Date Brianna Young 6/16/2023 Permit Number NCS000566 Owner/Facility Name The Lester Group—Fortress Wood Products/ Fortress Wood Products,Inc. SIC AICS Code/Category 2491 /Wood preserving for lumber Basin Name/Sub-basin number Yadkin Pee-Dee/03-07-07 Receiving Stream/HUC UT to Kennedy Mill Creek/030401030203 Stream Classification/Stream Segment C/ 12-119-7-2 Is the stream impaired on 303 d list]? No Any TMDLs? No Any threatened and/or endangered species? No Any compliance concerns? See Section 2 below Any permit mods since lastpermit? No New expiration date 9/30/2028 Comments on Draft Permit? See Section 6 below Section 1. Facility Activities and Process: The Lester Group—Fortress Wood Products facility is a lumber treatment operation. Untreated lumber is received on trucks or rail then treated in pressure vessels with C1eanWood 46+AF mold inhibitor, Stabil CB, MicroPro 200A, CleanWood AC (nitrate compounds), and Sodium Nitrite. Per the previous permit fact sheet, alkaline copper quaternary (AQC)was used. Treated lumber remains in the covered treatment area until the drippage of free liquid from the treatment process is considered to have stopped, then placed on raised bolsters in the outdoor storage yard, in warehouses, or the shipping area. The process system reclaims and recycles as much of the dripping as possible of treatment chemicals from the pads. Hazardous waste materials are placed into hazardous waste drums and put in secure storage until removal. All site stormwater discharges to one retention pond. Per the previous permit fact sheet, arsenic and chromium are not part of the manufacturing process. Per the November 2022 inspection report, analytical monitoring was conducted but at the inlet to the pond with high results for copper. The site drains to a 2-acre pond that does not appear to discharge. If the pond were to discharge, the facility owns at least 20 acres of woods where the flow would sheet flow and eventually infiltrate into the ground. Outfall SW001: Drainage area includes the treated lumber storage areas, railroad unloading pad, loading and unloading areas, fuel AST, a treatment building, detention pond, and forested area. Potential pollutants include TSS, treatment chemical traces, and copper. Why Industrial Sites with Stormwater are Subject to a Permit: Federal NPDES regulations define stormwater discharge associated with industrial activity in 40 CFR §122.26 (b)(14) as: "the discharge from any conveyance that is used for collecting and conveying storm water and that is directly related to manufacturing,processing or raw materials storage areas at an industrial plant. The term does not include discharges from facilities or activities excluded from the NPDES program under this part 122. Page 1 of 7 For the categories of industries identified in this section, the term includes, but is not limited to, storm water [sic] discharges from industrial plant yards; immediate access roads and rail lines used or traveled by carriers of raw materials, manufactured products, waste material, or byproducts used or created by the facility; material handling sites; refuse sites; sites used for the application or disposal of process waste waters (as defined at part 401 of this chapter); sites used for the storage and maintenance of material handling equipment; sites used for residual treatment, storage, or disposal; shipping and receiving areas; manufacturing buildings; storage areas (including tank farms) for raw materials, and intermediate and final products; and areas where industrial activity has taken place in the past and significant materials remain and are exposed to storm water. For the purposes of this paragraph, material handling activities include storage, loading and unloading, transportation, or conveyance of any raw material, intermediate product, final product, byproduct or waste product. The term excludes areas located on plant lands separate from the plant's industrial activities, such as office buildings and accompanying parking lots as long as the drainage from the excluded areas is not mixed with storm water [sic] drained from the above described areas." Section 2. Monitoring Information and Compliance History: • June 2013 to February 2023, benchmarks exceeded for: o COD 3x o Copper 25x o pH min not reached 8x • Facility was in Tier 11 and Tier III status during the previous permit cycle Section 3. Proposed Monitoring for Stormwater Discharges: The Division considered potential pollutants from past and present industrial activities and data was submitted for June 2013 to February 2023. Quantitative sampling included pH, TSS, COD, copper, chloride, nitrate+nitrite, and ammonia nitrogen. Parameters are based on potential pollutants in the drainage area, sampling results, and in some cases, dependent upon future activities (e.g., ash removal through the drainage area). Below is a table of the proposed monitoring for each outfall at the Fortress Wood Products site. Page 2 of 7 Outfall SW001 Quarterly monitoring Total Suspended Solids BASIS: Potential pollutant from drainage area and BMP effectiveness (TSS) indicator. Quarterly monitoring pH BASIS: Pollutant indicator Quarterly monitoring Total Rainfall BASIS: Discharge potential indicator Quarterly monitoring Non-Polar Oil &Grease BASIS: Potential pollutant from lubricants; Method 1664 SGT-HEM targets petroleum-based O&G Quarterly monitoring Monthly Oil Usage BASIS: Potential pollutant from drainage area Quarterly monitoring BOD BASIS: Discharge potential indicator Quarterly monitoring COD BASIS: Discharge potential indicator Quarterly monitoring Ammonia Nitrogen BASIS: Potential pollutant from drainage area Quarterly monitoring Total Nitrogen BASIS: Potential pollutant from drainage area Quarterly monitoring Total Copper BASIS: Potential pollutant from drainage area Quarterly monitoring Total Hardness BASIS: Monitoring for hardness dependent metals present Stormwater Benchmarks and Tiered Response: Rather than limits,North Carolina NPDES Stormwater permits contain benchmark concentrations. Stormwater benchmarks are numerical action levels for stormwater monitoring. Benchmarks are not effluent limits, and benchmark exceedances are not permit violations. Benchmarks provide facilities a tool for assessing the significance of pollutants in stormwater discharges and the effectiveness of best management practices (BMPs). Benchmark concentrations are intended as guidelines for the facility's development and implementation of the Stormwater Pollution Prevention Plan (SWPPP). Benchmark exceedances require the permittee to increase monitoring, increase management actions, increase record keeping, and/or install stormwater BMPs in a tiered program. The permit establishes a tiered approach to specify actions the permittee must take in response to analytical results above Page 3 of 7 benchmark concentrations. The tiered structure of the permit provides the permittee and DEMLR wide flexibility to address issues that may arise with one or more parameters and/or outfalls. Metals benchmarks are calculated to mimic acute water quality standards and with the guidance of DWR. NC DWR follows established federal procedures for calculating acute standards when developing the benchmarks. Just like the acute standards, metals benchmarks normally reflect one half of the calculated Final Acute Value (the "1/2 FAV"). In most cases, translation into total recoverable values is based on an assumed hardness of 25 mg/L and a total suspended solids (TSS) concentration of 10 mg/L. Acute standards protect aquatic life from negative impacts of short-term exposure to higher levels of chemicals where the discharge enters a waterbody. The Stormwater Permitting Program applies this approach because of the ephemeral nature of rainfall events. The Division may evaluate results to determine if a smaller suite of parameters for some outfalls is adequate to characterize potential pollution or BMP effectiveness. For example, one or more metals or other parameters may serve as an adequate tracer for the presence of ash pollution during disturbance or ash removal in specific drainage areas at this site. For parameters that do not have a stormwater benchmark, the Division may develop a benchmark value if appropriate toxicity data become available or if rising trends in concentrations suggest a persistent source. A summary of the benchmarks in the draft permit, and their basis, is below: Parameter Benchmark Basis Total Suspended 100 mg/L National Urban Runoff Program(NURP) Study, 1983 Solids TSS H 6 s.u. —9 s.u. NC Water Quality Standard(Range) Non-Polar Oil & Review of other state's daily maximum benchmark Grease 15 mg/L concentration for this more targeted O&G;NC WQS that EPA Method 1664 does not allow oil sheen in waters SGT-HEM BOD 30 mg/L BPJ; Based on Secondary Treatment Regulation(40 CFR g 133.03 COD 120 mg/L BPJ; Generally found at levels 4x BOD5 in domestic wastewaters Total Nitrogen 30 mg/L TKN +Nitrate +Nitrite Benchmarks (Expressed in mg/L of N Ammonia Nitrogen At 7.5 s.u. pH and summer(26°C) temperature from (summer) 5.6 mg/L Wasteload Allocation document for the coastal plain region worst-case scenario Ammonia Nitrogen At 7.5 s.u. pH and winter(14°C) temperature from Wasteload (winter) 15 mg/L Allocation document for the coastal plain region(worst-case scenario Copper Total 10 /L I Acute Aquatic Criterion, '/2 FAV Stormwater Pollution Prevention Plan: The proposed permit conditions reflect the EPA and NC's pollution prevention approach to stormwater permitting. The Division's maintains that implementation of Best Management Practices (BMPs) and traditional stormwater management practices that control the source of pollutants meets the definition of Best Available Technology(BAT) and Best Conventional Pollutant Control Technology(BCT). The permit conditions are not numeric effluent limitations but are designed to be flexible requirements for implementing site-specific plans to minimize and control Page 4 of 7 pollutants in stormwater discharges associated with the industrial activity. Title 40 Code of Federal Regulations (CFR) §122.44(k)(2) authorizes the use of BMPs in lieu of numeric effluent limitations in NPDES permits when the agency finds numeric effluent limitations to be infeasible. The agency may also impose BMP requirements which are "reasonably necessary" to carry out the purposes of the Act under the authority of 40 CFR 122.44(k)(3). The conditions proposed in this draft permit are included under the authority of both of these regulatory provisions. In essence, the pollution prevention and BMP requirements operate as limitations on effluent discharges that reflect the application of BAT/BCT. Flexibility in Tier Responses: Tier Two actions provide an opportunity for the permittee to propose an alternative monitoring plan for approval by the Region: • Alternatively, in lieu of steps 2 and 3, the permittee may, after two consecutive exceedances, exercise the option of contacting the DEMLR Regional Engineer as provided below in Tier Three. The Regional Engineer may direct the response actions on the part of the permittee as provided in Tier Three, including reduced or additional sampling parameters or frequency. • If pursuing the alternative above after two consecutive exceedances, the permittee may propose an alternative monitoring plan for approval by the Regional Engineer. The permit therefore allows the permittee to petition the Regional Office for monitoring changes sooner than Tier Three (upon any four benchmark exceedances) and gives guidance on one option to take. For example, the permittee may request that mercury only be monitored semi-annually under the tiers, or that only parameters over the benchmark be monitored more frequently. In this way, changes to the monitoring scheme for any outfall could be handled outside of a permit modification. Other Proposed Requirements: • It is standard for Stormwater Pollution Prevention Plan(SWPPP)requirements to include an annual certification that stormwater outfalls have been evaluated for the presence of non- stormwater discharges, and if any are identified, how those discharges are permitted or otherwise authorized. • Requirement to submit a request for permit modification if the facility identifies or creates any new outfalls, removes outfalls, or alters any drainage area that changes potential pollutants. • The Division expects the permittee to apply best professional judgment and consider the safety of its personnel in fulfilling sampling obligations under the permit. • Federal regulations require electronic submittal of all discharge monitoring reports (DMRs). If a state does not establish a system to receive such submittals, then permittees must submit DMRs electronically to the EPA. • Quarterly QualitativeNisual Monitoring to assure regular observation of outfalls throughout year. Section 4. Changes from previous permit to draft: • Monitoring increased from semi-annually to quarterly for all parameters (qualitative and quantitative) • "No discharge" clarifications made • Feasibility study removed from Part B due to SW program change • eDMR requirement added • Boilerplate language moved into body of the permit; boilerplate no longer attached • Monitoring added for BOD due to information provided during renewal Page 5 of 7 • Monitoring removed for total chloride as reported values were well below benchmarks and they do not appear present in materials onsite • Monitoring for nitrate+nitrite replaced by total nitrogen per current SW practices • Monitoring for total hardness added for all outfalls as monitoring for hardness dependent metals is required • Benchmarks updated for parameters per guidance from DWR Standards group on stormwater benchmarks Section 5. Changes from draft to final: • Receiving stream updated to UT to Kennedy Mill Creek o Removed mention of impairment as Kennedy Mill Creek stream segment is not impaired • SW001 drainage area description updated Section 6. Discussions with the Facility and Regional Office: • Initial contact with facility: l l/l/2022 • Initial contact with Regional Office: 11/l/2022 • Draft sent to CO peer review: 3/30/2023 • Draft sent to Regional Office: 4/26/2023 • Final permit sent for supervisor signature: 6/21/2023 Section 7. Comments received on draft permit: • Lily Kay (DEMLR; via email 5/10/2023): This looks good. • David Maddox (Environmental Solutions and Strategies, LLC on behalf of permittee; received 5/9/2023) (summarized below): o Can NC DEMLR provide ES2 evidentiary proof that an "unnamed tributary" exists that directly provides the conduit which water actually travels from the site property to Hunts Fork? ■ DEMLR response: The reference to Hunts Fork is an error. Per information provided with the permit renewal application, the facility discharges to an unnamed tributary to Kennedy Mill Creek. The permit will be updated to reflect the correct receiving stream. o The description of SW001 should reference only 1 treatment building and the "forested area" should be more descriptive. ■ DEMLR response: The description of SW001 will be updated to reflect one treatment building. The reference to "forested area"will remain the same as that is what the ground cover of the area represents, and the outfall description is meant to give a general picture idea of what is present onsite. o Does the facility site discharge to impaired waters exceeding criteria for benthos? The reference to impaired waters says Rich Fork, not Hunts Fork. ■ DEMLR Response: The reference to Rich Fork as an impaired stream was an error. Per information provided with the permit renewal application, the facility discharges to an unnamed tributary to Kennedy Mill Creek, which is not listed as Page 6 of 7 impaired in the 2022 303(d) list. The permit will be updated to reflect the correct receiving stream and the reference to impairment removed. • Dave Maddox submitted additional comments on behalf of the permittee after the comment period closed Page 7 of 7 Winston-Salem Journal Advertising Affidavit Account Number 4018953 RECEIVED Date MtY ] 0 202:3 April 28,2023 ,;,v&R-Stormwater program NC DEPT OF ENVIRONMENT&NATURAL RESOURCES NC DIVISION OF ENERGY,MINERAL&LAND RESOURCES- 512 N SALISBURY STREET RALEIGH,NC 27604 PO Number Order Category Description 0000832577 Legal Notices NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION INTENT T, Publisher of the Winston-Salem Journal Before the undersigned, a Notary Public duly commissioned, qualified, and authorized by law to administer oaths, personally appeared the Publisher's Representative who by being duly sworn deposes and says:that he/she is authorized to make this affidavit and sworn statement;that the notice or other legal advertisement,a copy of which is attached hereto,was published in the Winston-Salem Journal on the following dates: 0412812023 and that the said newspaper in which such notice, paper document,or legal advertisement was published,was at the time of each and every such publication,a newspaper meeting all the requirements and qualifications of Section 1-597 of the General Statutes of North Carolina. (signature ojperson making affidavit) Sworn to and subscribed before me the 28th y of April,20 3 ` 0 oN„R,,,,,,,,/ PQ. ..........;9'QS (Notary Public) rJ State of Virginia r`r,,• . NOTARY R` County of Hanover PUBLIC i Z 0 S REG.N329549 My commission expire$:Q . MY rpp� i Q �+ EXPIRES r 1iO'•.• July 31,2025 U' 'SLTH CF,0 THIS IS NOT A BILL. PLEASE PAY FROM INVOICE. THANK YOU NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION INTENT TO ISSUE NPDES STORMWATER DISCHARGE PERMITS The North Carolina Environmental Management Commission proposes to issue NPDES stormwater dis- charge permit(s) to the person(s) listed below.Public comment or ob- jection to the draft permits is invit- ed. Written comments regarding the proposed permit will be accepted until 30 days after the publish date of this notice and considered in the final determination regarding permit Issuance and permit provisions.The Director of the NC Division of Ener- gy, Mineral, and Land Resources (DEMLR) may hold a public hearing should there be a significant degree of public interest Please mail com- ments and/or information requests to DEMLR at 1612 Mail Service Cen- ter,Raleigh,NC 27699-1612. •The Lester Group-Fortress Wood Products[PO Box 4991,Martinsville, VA 24115-4991] has requested re- newal of permit NCS000566 for For- tress Wood Products, Inc. in Ran- dolph County.This facility discharg- es to an unnamed tributary to Hunts Fork in the Yadkin Pee-Dee River Ba- sin. Interested persons may visit DEMLR at 512 N. Salisbury street, Raleigh, NC 27604 to review information on file. Additional information on NPDES permits and this notice may be found on our website: https://deq.nc-gov/about/divisions/ energy-mineral-and-land-resources/ stormwater/stormwater-program/ stormwater-public-notices,or by contacting Brianna Young at brianna.young@ncdenr.gov or 919-707-3647. W51:April 20,2023. Young, Brianna A From: DAVID P MADDOX <dmaddox@comcast.net> Sent: Friday, May 26, 2023 8:31 AM To: Young, Brianna A Subject: [External] Recent Supreme Court Ruling on Clean Water Act CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message button located on your Outlook menu bar on the Home tab. Good morning Ms.Young, Considering the recent ruling last week by the U. S. Supreme Court rebuking the U.S. EPA's continuous manipulation of legal definitions and Congressional Original mandate of the Clean Water Act (CWA) , in that, the Supreme Court has unanimously ruled U.S.EPA has continuously over stepped it's legal authority for years and ruled that the CWA CAN ONLY ALLOW the U.S.EPA to regulate discharges of water into wetlands that are indistinguishable from protected waters. Under this decision, other wetlands ARE NO longer protected under the CWA in the way U.S.EPA was mandating. The Supreme Court decision has very broad and wider reaching ramifications for federal and state regulators on water quality management in general and STORMWATER management specifically. By U.S. EPA's own admission to the Court, their interpretation of NAVAGATABLE WATERS, as set forth by Congress in the CWA, makes nearly all waters and wetlands in the United States susceptible to their many years of unchallenged rules and written regulations. This gross and bureaucratic interpretive over reach of the CWA by U.S. EPA literally risks criminal prosecutions for such mundane things as moving dirt. The CWA extends to ONLY streams, oceans, rivers and lakes and those wetlands with a "continuous SURFACE connection to those bodies", " a continuous surface connection to bodies of the United States in their own right. In both Draft Permits for NCS000008 and NCS000566, the wording of discharge to receiving waters DESIGNATED as an UNNAMED TRIBUTARY appear. Also, in NCS000566, the receiving stream is listed "as impaired for benthos on the 1 North Carolina 2022 303 (d) Impaired Water List. Addressing Impaired waters is a high priority with the Division, and INSTREAM data will continue to be evaluated" . Unnamed tributary is defined as a little creek, or seep,or spring,or bog,or wetland without a name that begins life as surface water, e.g. "stormwater". When it seeps into the ground and later emerges, most times from places other than entry, it makes up more than 60% of unnamed tributaries in the United States. The Supreme Court has ruled that the NAVAGATABLE water section of the CWA, must show "A CONTINUOUS SURFACE CONNECTION TO THOSE BODIES" in order for U.S. EPA to have legal jurisdiction in matters to which they assumed they had. Since EPA uses delegated authority to the states and legal experts recognize the mess U.S EPA has made of the CWA along with the fact that this ruling will certainly have an affect on stormwater Discharge and Permitting, can you please provide me with an update as to where NC DEMLR is currently at with Stormwater Permitting considering the actions of the Supreme Court last week. Thanking you in advance for your response to this matter, I remain, Sincerely, Dave Maddox ES2 Environmental Solutions & Strategies P.O.Box 4244 Martinsville, Virginia 24115 Telephone (276) 806-0178 Fax (276) 632-6137 2 Young, Brianna A From: DAVID P MADDOX <dmaddox@comcast.net> Sent: Thursday, May 18, 2023 5:40 PM To: Young, Brianna A; Pete Haskins Subject: [External] Re:The Lester Group - Fortress Wood Products stormwater permit NCS000566 CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message button located on your Outlook menu bar on the Home tab. Ms.Young The aerial photo sent you with the SW application shows three structures.The treatment building runs parallel to 185/70/29 and has a small abutment on the northern side which is a roof that covers a diked AST for fuel.The structure to the left is a railroad unloading pad.The two side by side structures near the outfall are both dry and treated Lumber Storage covers.They are merely metal roofs with steel supports used to cover and protect the wood from weather. If you remain unclear as to the aerial photos, let me know. If you continue to need another aerial photo, please let me know and another will be provided. Thanks Dave On 05/17/2023 1:21 PM EDT Young, Brianna A<brianna.young@ncdenr.gov>wrote: Good afternoon, I am reviewing the comments submitted on the draft stormwater permit for The Lester Group- Fortress Wood Products facility (NCS000566) and have one follow-up question.You stated there is only one (1) treatment building, however, aerial photographs show multiple buildings onsite. Can you please provide an updated aerial map indicating what the purpose of each building is for? Thank you, Brianna Young, MS(she/her/hers) Industrial Individual Permits Coordinator i Stormwater Permitting Program NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Young@ncdenr.gov(e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 DEQ�� NORTH CAROLINA Department of Environmental Quality Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public during this challenging time. ES2 Environmental Solutions & Strategies P.O.Box 4244 Martinsville, Virginia 24115 Telephone (276) 806-0178 Fax (276) 632-6137 2 C'S2 RE-CF-'_\'E0 ��ML�.$�ormwatet program Environmental Solutions and Strategies, LLC P. O. Box 4244 Martinsville Virginia 24115 May 3, 2023 Certified Mail—Return Receipt Requested 70210350 0000 97201704 Ms. Brianna Young Industrial Individual Permits Coordinator DEMLR Storm Water Permitting Program 1612 Mail Service Center Raleigh, North Carolina 27699-1612 RE:The Lester Group-Fortress Wood Products, COMMENTS, Draft NPDES Permit NCS 000566 Dear Ms. Young, Please find the following written comments pertaining to the Draft NPDES Permit NCS000566 as dated April 26, 2023. a. Page 1 of 35. "to receiving waters designated as an unnamed tributary to Hunts Fork, a Class C stream, in the Yadkin Pee-Dee River Basin, in accordance with the discharge limitations, monitoring requirements, and other conditions, set forth in Parts A through 1 hereof." The facility and all adjoining property were originally constructed, and have remained the same without change, for stormwater discharges from the facility and property, in that, stormwater discharges were designed to be captured into two retention ponds, known as the upper pond and the lower pond. The upper pond is a small retention pond located to the east of the main retention pond and collects water from a ditch running from the asphalt access road to the facility along Bethel Drive and along the eastern side of the property line, as shown in the satellite photos submitted with the permit application. The coinciding purpose of the upper retention pond is to provide a means for protection from unwanted property erosion, since the entire area the ditch transverses is to the east and significantly up gradient from all facility operations and storage areas, making this area of facility property subject to significant erosion over time. For these reasons,this ditch does not collect any water(s) from facility operations but stormwater runoff from the asphalt road to the facility. Any water(s) not contained by the upper retention pond drains slowly down gradient into the large lower retention pond. All undrained water collected in the small upper retention pond is left to evaporate back to the atmosphere. All stormwater from operational and storage parts of the facility is directed to, and, exits these areas though Outfall SW001 into the large lower retention pond, also shown in the satellite photos submitted with the permit application. If a stormwater event, or Page-2-of 4 May 3,2023 Ms.Brianna Young Industrial Individual Permits Coordinator DEMLR Storm Water Permitting Program 1612 Mail Service Center Raleigh,North Carolina 27699-1612 Certified Mail—Retum Receipt Requested 70210350 0000 97201704 multiple stormwater events overwhelm the containment ability of the lower retention pond,the excess water overflows this retention pond directly onto the owner's property where waters from stormwater events are fully contained and allowed to sheet across the forested topography of the facility property. As shown in the satellite photos,the stormwater discharge system for the facility and all adjoining properties of the facility, are designed to mitigate damage to the property from stormwater events, direct the stormwater in a manner where the stormwater can be managed and to provide allowances for excessive stormwater to either be retained on property by retention ponds whereby the water can naturally evaporate, or released onto the property where it is completely contained and allowed to naturally sheet and evaporate across the forested property.The satellite photos clearly show the sheeting area is fully contained on site by an elevated rail system to the west of the property line and elevated paved access roads to the east of the property line.The topography of the site property does not allow for any migration of stormwater from the property via the north or south due to continuous increases in land elevations. Additionally, ES' has closely examined available information available on the internet and topographical maps and cannot find nor determine any unnamed tributary which NC DEMLR can connect the stormwater from this property site to Hunts Fork COMMENT:Can NC DEMLR provide ES2 evidentiary proof that an "unnamed tributary" exists that directly provides the conduit which water actually travels from the site property to Hunts Fork? b. Page 6 of 35. "Site Map Descriptive—Receiving Stream: UT to Hunts Fork" COMMENT:Can NC DEMLR provide ES2 evidentiary proof that an"unnamed tributary" exists that directly provides the conduit which water actually travels from the site property to Hunts Fork? c. Page 14 of 35. Outfall SW001:Drainage area includes the treated lumber storage area, loading and unloading areas,fuel AST, treatment buildings, detention pond and forested area." • COMMENT:The above should read, "Outfall SW001:Drainage area includes the treated lumber storage area, loading and unloading areas,fuel AST, treatment buildings building,detention pond and fe-res ed-yea."The site has one treatment building, not multiple buildings. Page-3 of 4 May 3,2023 Ms.Brianna Young Industrial Individual Permits Coordinator DEMLR Storm Water Permitting Program 1612 Mail Service Center Raleigh,North Carolina 27699-1612 Certified Mail—Retum Receipt Requested 70210350 0000 97201704 Forested area should be more descriptive as the eastern portion and parts of the southern portions of the property have the potential to provide vagrant stormwater drainage, dependent upon the volume and velocity of the stormwater event, otherwise,stormwater will sheet over these areas. If the "drainage area................and forested area."remains as written,then the Outfall SW001 current descriptive of forested area should be far more descriptive as outlined in Section a.above, as the forested area, north of the large retention pond associated with SW001, is actually a stormwater sheeting area. d. Page 17 of 35: 'The site discharges to impaired waters which exceed criteria for benthos. if the Division institutes further actions, which may include the development of a Total Maximum Daily Load(TMDL)for this segment of Rich Fork, then the Division will consider your monitoring results in determining whether additional SCMs and/or BMPs are needed to control pollutant(s)of concern to the maximum extent practicable." • COMMENT:As aforementioned in Section a., E52 has asked NC DEMLR for an actual stormwater discharge determination to Hunts Fork. • COMMENT:The second sentence reads in part, "The site discharges to impaired waters which exceed criteria for benthos. !f the Division institutes further actions, which may include the development of a Total Maximum Daily Load(TMDL)for this segment of Rich Fork,"However, page 1 of 35. Reads "to receiving waters designated as an unnamed tributary to Hunts Fork,a Class C stream,in the Yadkin Pee-Dee River Basin,in accordance with the discharge limitations, monitoring requirements, and other conditions, set forth in Parts A through J hereof."Why does page 1 of 35 designate stormwater discharge to Hunts Fork when page 17 of 35 references a possible inclusion of conditions based on the(TMDL)for a segment of Rich Fork? Is this a typo, Hunts Fork and Rich Fork? If not, how are Hunts Fork and Rich Fork physically connected that would potentially cause additional permitting conditions on this facility? Page 17 of 35.Reads "The site discharges to impaired waters which exceed criteria for benthos."Does The Lester Group—Fortress Wood Products, High Point facility site discharge to impaired waters exceeding criteria for benthos? Page -4 of 4 May 3,2023 Ms.Brianna Young Industrial Individual Permits Coordinator DEMLR Storrs Water Permitting Program 1612 Mail Service Center Raleigh,North Carolina 27699-1612 Certified Mail—Return Receipt Requested 702103SO OW 97201704 The above represent the written comments, of and by ES', with regard to the DRAFT of the NPDES PERMIT to discharge Stormwater from The Lester Group - Fortress Wood Products, permit NCS000566. Should you have any questions with regard to any of the aforementioned, please call me at (276) 806-0178, email me at dmaddox@comcast.net, or fax me at (276) 632-6137. Thanking you in advance for clarity to the issues raised in these written comments, I remain Sincerely, avi dox President & CEO Environmental Solutions and Strategies, LLC P. O. Box 4244 Martinsville,Virginia 24115 276-806-0178 (telephone) 276-632-6137 (fax) C: ES2 Files The Lester Group- Fortress Wood Products—High Point Stormwater Files Young, Brianna A From: Kay, Lily C Sent: Wednesday, May 10, 2023 3:49 PM To: Young, Brianna A Cc: Eplin, Tamera Subject: RE: Draft NPDES permit NCS000566 This looks good to me. Good job. Z4 lacy Environmental Program Consultant Land Quality Division Division of Energy, Mineral, and Land Resources North Carolina Department of Environmental Quality Phone: (336) 776-9655 Email: Lily.Kay@ncdenr.gov Physical and Mailing Address: 450 W. Hanes Mill Rd. Winston-Salem, North Carolina 27105 D,E Op�}�nnir�i a1 Eny,ronniraiial gk.alikv Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties From:Young, Brianna A<Brianna.Young@ncdenr.gov> Sent: Wednesday,April 26, 2023 8:25 AM To: Kay, Lily C<lily.kay@ncdenr.gov> Cc: Eplin,Tamera <tamera.eplin@ncdenr.gov> Subject: Draft NPDES permit NCS000566 Good morning, The draft stormwater permit NCS000566 for the Fortress Wood products facility has been submitted to public notice. Please provide any comments on the draft permit by May 26, 2023. Thank you, Brianna Young, MS(she/her/hers) Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR) Brlanna.Young@ncdenr.gov(e-mail preferred) 919-707-3647 (office) 1 Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 ,�: D E '�7'` NORTH CAROLINA IQ ; Department of Environmental Quality Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public during this challenging time. 2 Young, Brianna A From: DAVID P MADDOX <dmaddox@comcast.net> Sent: Monday, March 27, 2023 4:50 PM To: Young, Brianna A Subject: RE: [External] RE: Fortress Wood Products stormwater permit NCS000566 CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to Report Spam. Ms. Young, Thank you for your email. 1.The chemicals currently used to treat the wood and on site are; -Cleanwood 46+AF mold inhibitor, contains no reportable compounds. -Cleanwood AC -contains nitrate compounds. -Sodium Nitrite -Stabil CB-contains no reportable compounds. -MicroPro 200A-contains copper compounds. 2.The BMP contains a typo. My sincere apologies. The facility only has ONE outfall as shown by photographs in section 2 of the submittal which shows all site stormwater discharging to one on-site retention pond. Again, my apologies for the typo and confusion. If you need additional clarifications, please let me know. Dave On 03/27/2023 10:07 AM Young, Brianna A<brianna.young@ncdenr.gov>wrote: Hello David, After reviewing all the information submitted, I have a few follow-up questions. 1. Can you confirm what chemical(s) are used to treat the wood as well as what is present onsite? 1 2.The BMP states there are 5 outfalls, however, only 1 outfall is documented in the application and historical permit files.. Can you provide descriptions of activity in each drainage area, and where each outfall discharges to? Thank you, Brianna Young, MS(she/her/hers) Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Young@ncdenr.gov(e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public during this challenging time. From: DAVID P MADDOX<dmaddox@comcast.net> Sent: Friday, March 24, 2023 11:45 PM To:Young, Brianna A<Brianna.Young@ncdenr.gov> Subject: RE: [External] RE: Fortress Wood Products stormwater permit NCS000566 2 CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to Report Spam. Thanks for the update....Dave On 03/24/2023 3:13 PM Young, Brianna A<brianna.young@ncdenr.gov>wrote: Good afternoon David, We received the information for NCS000566 in our office today. I will reach out with any questions once I've had a chance to review everything. Thank you, Brianna Young, MS(she/her/hers) Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Young@ncdenr.gov(e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 3 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public during this challenging time. From:Young, Brianna A Sent: Wednesday, March 22, 2023 8:50 AM To: DAVID P MADDOX<dmaddox@comcast.net> Subject: RE: [External] RE: Fortress Wood Products stormwater permit NCS000566 Thank you for this update. Brianna Young, MS(she/her/hers) Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Young@ncdenr.gov(e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. 4 Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public during this challenging time. From: DAVID P MADDOX<dmaddox@comcast.net> Sent:Tuesday, March 21, 2023 1:56 PM To:Young, Brianna A<Brianna.Young@ncdenr.gov> Subject: RE: [External] RE: Fortress Wood Products stormwater permit NCS000566 CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to Report Spam. Ms. Young, As a courtesy communication, I wanted you to know that the Stormwater Permit Renewal Application for source NCS000566 has been sent to your attention via Certified Priority Mail. Am currently working on source NCS000008 and will be sending that application soon. Dave Maddox On 03/15/2023 9:40 AM Young, Brianna A <brianna.young@ncdenr.gov>wrote: Good morning David, To confirm,you used the Permit Contact Update Request Form to submit the requests? I do not see in our internal database that you have been added as a permit contact to each permit. If you did use the online form and it has not been processed, it is likely due to a shortage of staff 5 resources. Our staff that handle those requests have limited capacity to process these requests right now, so it may be taking additional time. Thank you, Brianna Young, MS(she/her/hers) Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Young@ncdenr.gov(e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public during this challenging time. From: DAVID P MADDOX<dmaddox@comcast.net> Sent:Tuesday, March 14, 2023 11:35 PM To:Young, Brianna A<Brianna.Young@ncdenr.gov> Subject: RE: [External] RE: Fortress Wood Products stormwater permit NCS000566 6 CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to Report Spam. Ms. Young, Thank you for your instructions on helping me register as an additional permit contact for Fortress Wood. However, after updating the two forms, one each for permit NCS000008 and NCS000566, I cannot find where the updates were validated. Could you confirm that I have been added to your record base as an additional permit contact. Secondly, is their a fee required to be sent when these permit renewals are filed. Again, thanks for your help and assistance. Dave Maddox ES2 Environmental Solutions and Strategies, LLC P. O. Box 4244 Martinsville, Virginia 24115 (276-806-0178)Telephone (276-632-6137) Fax 7 On 03/06/2023 10:14 AM Young, Brianna A <brianna.young@ncdenr.gov>wrote: Good morning, I will include Mr. Maddox on future correspondence. Please note Mr. Maddox is not in our database as a permit contact. If permit contacts need to be updated, please follow the below instructions: Enter your stormwater permit number into the Stormwater Permit Summary Report and you will see a form that includes the address of the facility, contact information for the permit, and the regulated stormwater outfall(s) for the facility. To update the: • Facility/Company name or ownership, complete the Name/Ownership Change Form. • Legally responsible person (Owner Affiliation), complete the Permit Contact Update Request Form. • Delegation of Signature Authority (DOSA), complete the Permit Contact Update Request Form. • Billing contact, complete the Permit Contact Update Request Form. • Permit contact, complete the Permit Contact Update Request Form. • Facility contact, complete the Permit Contact Update Request Form. • Facility address only, email Bethany Geor oulias. 8 • Stormwater outfall information, email Bethany Georgoulias. Thank you, Brianna Young, MS(she/her/hers) Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Young@ncdenr.gov(e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public during this challenging time. 9 From: Pete Haskins<phaskins@fortresswood.com> Sent: Monday, March 6, 2023 9:00 AM To:Young, Brianna A<Brianna.Young@ncdenr.gov> Cc: Dave Maddox(dmaddox@comcast.net) <dmaddox@comcast.net>; Zach Crews <zcrews@fortresswood.com> Subject: [External] RE: Fortress Wood Products stormwater permit NCS000566 CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to Report Spam. Good Morning Ms.,Young, I apologize for not responding sooner. I overlooked the email from January 24th thinking that all correspondence also included our consultant( Mr. Dave Maddox). I have forwarded your email from the 24th and we are working on this matter as I write this. Would ask that in the future please include Mr. Maddox on all emails going forward. Have included him on this response so you have his email address on file. Thank you, Pete Haskins Fortress Wood Products 3874 Bethel Drive Extension High Point, NC 27260 From:Young, Brianna A<Brianna.Young@ncdenr.gov> Sent: Friday, March 3, 2023 11:20 AM To: Pete Haskins<phaskins@fortresswood.com> Subject: RE: Fortress Wood Products stormwater permit 10 NCS000566 Importance: High Good morning, I am following up on our previous correspondence.To date I have not received the requested information. Please note this information is required in order to proceed with reviewing the individual industrial stormwater permit application. Please let me know if you have any questions concerning this request. Thank you, Brianna Young, MS(she/her/hers) Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Young@ncdenr.gov(e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. 11 Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public during this challenging time. From:Young, Brianna A Sent:Tuesday,January 24, 2023 9:11 AM To: 'phaskins@fortresswood.com' <phaskins@fortresswood.com> Subject: RE: Fortress Wood Products stormwater permit NCS000566 Good morning, After further review and discussion, it has come to the Stormwater Permitting Program's attention that this facility does not qualify for coverage under a General Permit. Previous communication I sent indicated this was a possibility, however,the NCG210000 does not provide coverage for wood preserving facilities. I apologize for the confusion. As the Fortress Wood Products facility does not qualify for General Permit coverage, an individual permit is still required.Therefore, I will continue reviewing the permit renewal application that was submitted. In order to do so, I will need the information I previously requested (see in this email chain). Please let me know if you have any questions as you work to gather this information. Thank you, Brianna Young, MS(she/her/hers) 12 Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Young@ncdenr.gov(e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public during this challenging time. From:Young, Brianna A Sent:Wednesday, November 16, 2022 3:05 PM To: phaskins@fortresswood.com Subject: RE: Fortress Wood Products stormwater permit NCS000566 Importance: High Good afternoon, 13 It has recently come to our attention that the Fortress Wood Products facility, currently permitted under stormwater permit NCS000566, may be eligible for different permit coverage. Per the inspection report dated November 9, 2022 (see attached),the DEMLR inspector felt the permit type could change from an Individual Permit to a General Permit. If you wish to explore coverage under a General Permit, please contact Brittany Carson at Brittany.carson@ncdenr.gov or via phone at 919-707-3648. If you wish to continue with permit coverage under the existing Individual Permit, please provide the information previously requested (see below). We request an initial response on this by December 16, 2022. Thank you, Brianna Young, MS(she/her/hers) Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Young@ncdenr.gov(e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. 14 Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public during this challenging time. From: Young, Brianna A Sent:Tuesday, November 1, 2022 2:26 PM To: phaskins@fortresswood.com Subject: Fortress Wood Products stormwater permit NCS000566 Good afternoon, I am working on renewing the individual stormwater permit for the Fortress Wood Products facility(NCS000566). I need additional information in order to 1) confirm that the information I have is correct and 2)make sure the permit adequately serves the needs of the facility. Please provide the following: • Supplemental information required with the permit renewal application was not submitted. Please visit our website here, fill out the SPPP Certification Form and Supplemental Information Form and provide all required attachments. • Description of industrial activity occurring onsite; • Confirmation on the number of outfalls and associated coordinates; • Description of industrial activity in each drainage area; • SIC (NAICS) code; • An electronic spreadsheet summarizing all of the monitoring data that has been collected since the effective date of the current permit; 15 • Verification that the information in the renewal application is still complete and correct; and • An explanation of any operational changes since the renewal application was submitted. Enter your stormwater permit number into the Stormwater Permit Summary Report and you will see a form that includes the address of the facility, contact information for the permit, and the regulated stormwater outfall(s) for the facility. Please review the facility information to make sure it is correct. Information can be updated using the links provided below,where applicable: • Facility/Company name or ownership: Name/Ownership Change Form • Owner Affiliation(Legally responsible person; i.e., someone with the company who is designated to represent the company per signatory requirements or another authorized representative): Permit Contact Update Request Form • Delegation of Signature Authority (DOSA): Permit Contact Update Request Form • Billing contact: Permit Contact Update Request Form • Permit contact: Permit Contact Update Request Form • Facility contact: Permit Contact Update Request Form • Facility address only: Email Bethany Georgoulias • Stormwater outfall information: Email Bethany Georgoulias • Visit the eDMR Six Steps website and complete Steps 1 and 2. • Pay outstanding permit fees: Stormwater 0gyment website 16 Once I have the above listed information, I can continue my review. You will receive a draft permit for a 30-day comment period. During this time we will be able to address any comments or concerns you have. During the same 30-day period, the draft will be sent to a Regional Office staff member for review as well as out to public notice. Once all comments and concerns are addressed, you may be issued a final permit. Please contact me if you have any questions. Thank you, Brianna Young, MS (she/her/hers) Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ/ Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Young@ncdenr.gov(e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 17 NORTH CAROLINA Q � Department of Environmental Quality Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public during this challenging time. ES2 Environmental Solutions & Strategies P.O.Box 4244 Martinsville, Virginia 24115 Telephone (276) 806-0178 Fax (276) 632-6137 ES2 Environmental Solutions & Strategies P.O.Box 4244 Martinsville, Virginia 24115 Telephone (276) 806-0178 Fax (276) 632-6137 ES2 Environmental Solutions & Strategies P.O.Box 4244 Martinsville, Virginia 24115 Telephone (276) 806-0178 Fax (276) 632-6137 ES2 Environmental Solutions & Strategies P.O.Box 4244 Martinsville, Virginia 24115 Telephone (276) 806-0178 Fax (276) 632-6137 18 Young, Brianna A From: Young, Brianna A Sent: Tuesday, January 24, 2023 9:11 AM To: phaskins@fortresswood.com' Subject: RE: Fortress Wood Products stormwater permit NCS000566 Good morning, After further review and discussion, it has come to the Stormwater Permitting Program's attention that this facility does not qualify for coverage under a General Permit. Previous communication I sent indicated this was a possibility, however,the NCG210000 does not provide coverage for wood preserving facilities. I apologize for the confusion. As the Fortress Wood Products facility does not qualify for General Permit coverage, an individual permit is still required. Therefore, I will continue reviewing the permit renewal application that was submitted. In order to do so, I will need the information I previously requested (see in this email chain). Please let me know if you have any questions as you work to gather this information. Thank you, Brianna Young, MS(she/her/hers) Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Young@ncdenr.gov(e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public during this challenging time. From:Young, Brianna A Sent:Wednesday, November 16, 2022 3:05 PM To: phaskins@fortresswood.com Subject: RE: Fortress Wood Products stormwater permit NCS000566 Importance: High Good afternoon, It has recently come to our attention that the Fortress Wood Products facility, currently permitted under stormwater permit NCS000566, may be eligible for different permit coverage. Per the inspection report dated November 9, 2022 (see attached),the DEMLR inspector felt the permit type could change from an Individual Permit to a General Permit. If you wish to explore coverage under a General Permit, please contact Brittany Carson at Brittany.carson@ncdenr.Rov or 1 via phone at 919-707-3648. If you wish to continue with permit coverage under the existing Individual Permit, please provide the information previously requested (see below). We request an initial response on this by December 16, 2022. Thank you, Brianna Young, MS(she/her/hers) Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Young@ncdenr.gov(e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public during this challenging time. From:Young, Brianna A Sent:Tuesday, November 1, 2022 2:26 PM To: phaskins@fortresswood.com Subject: Fortress Wood Products stormwater permit NCS000566 Good afternoon, I am working on renewing the individual stormwater permit for the Fortress Wood Products facility (NCS000566). I need additional information in order to 1) confirm that the information I have is correct and 2) make sure the permit adequately serves the needs of the facility. Please provide the following: • Supplemental information required with the permit renewal application was not submitted. Please visit our website here, fill out the SPPP Certification Form and Supplemental Information Form and provide all required attachments. • Description of industrial activity occurring onsite; • Confirmation on the number of outfalls and associated coordinates; • Description of industrial activity in each drainage area; • SIC (NAICS) code; • An electronic spreadsheet summarizing all of the monitoring data that has been collected since the effective date of the current permit; • Verification that the information in the renewal application is still complete and correct; and • An explanation of any operational changes since the renewal application was submitted. Enter your stormwater permit number into the Stormwater Permit Summary Report and you will see a form that includes the address of the facility, contact information for the permit, and the regulated stormwater outfall(s)for the facility. Please review the facility information to make sure it is correct. Information can be updated using the links provided below,where applicable: 2 • Facility/Company name or ownership: Name/Ownership Change Form • Owner Affiliation (Legally responsible person; i.e., someone with the company who is designated to represent the company per signatory requirements or another authorized representative): Permit Contact Update Request Form • Delegation of Signature Authority (DOSA): Permit Contact Update Request Form • Billing contact: Permit Contact Update Request Form • Permit contact: Permit Contact Update Request Form • Facility contact: Permit Contact Update Request Form • Facility address only: Email Bethanyy og ulias • Stormwater outfall information: Email Bethany Georgoulias • Visit the eDMR Six Steps website and complete Steps 1 and 2. • Pay outstanding permit fees: Stormwater ePgMent website Once I have the above listed information, I can continue my review. You will receive a draft permit for a 30-day comment period. During this time we will be able to address any comments or concerns you have. During the same 30-day period, the draft will be sent to a Regional Office staff member for review as well as out to public notice. Once all comments and concerns are addressed, you may be issued a final permit. Please contact me if you have any questions. Thank you, Brianna Young, MS (she/her/hers) Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ/ Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Young@ncdenr.gov(e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 t�: D E '�:`A� kl ; NORTH CAROLINA Department of Environmental Quality Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public during this challenging time. 3 Young, Brianna A From: Kay, Lily C Sent: Monday, December 19, 2022 11:08 AM To: Young, Brianna A Subject: RE: Fortress Wood Products (NCS000566) Sorry, Britany. I was looking for another permit, but can't find another general permit that would fit, so I guess they'll have to stick with the individual. Z4 lacy Environmental Program Consultant Land Quality Division Division of Energy, Mineral, and Land Resources North Carolina Department of Environmental Quality Phone: (336) 776-9655 Email: Lily.Kay@ncdenr.gov Physical and Mailing Address: 450 W. Hanes Mill Rd. Winston-Salem, North Carolina 27105 D,E 6p�s�eln�rii1 a1Enyrannirail�l{killiYy Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties From:Young, Brianna A<Brianna.Young@ncdenr.gov> Sent:Tuesday, December 13, 2022 2:59 PM To: Kay, Lily C<lily.kay@ncdenr.gov>; Carson, Brittany<brittany.carson@ncdenr.gov> Cc: Eplin,Tamera <tamera.eplin@ncdenr.gov> Subject: RE: Fortress Wood Products (NCS000566) Hey Lily, Brittany and I just talked. Dave Maddox reached out to her wanting to switch from the individual to general permit(it sounds like he was also insistent I was the one who did the inspection). However,there might be a problem with this. Brittany pointed out that the NCG21 excludes wood preserving (see below), which is the industrial activity of this facility. We weren't sure if you had another general permit in mind that they could switch to. 1 Coverage u1nder this General Permit is applicable to: * All owners 0r operators of storm water point source discharges associated with establishments primarily engaged in activities classified as Lumber and Wood Products, Except Furniture [Standard Jndustrial Classification (S IC} 4],i ncluding Wood Chip MiIls; + Storm water point source discharges from like industrial activities deerned by the Division of Energy, Mineral, and Land Resources(DEMLR) to be similar to these operations in the process, or the discharges, or the exposure afraw materials, intermediate products,by-products,products, yr waste products. Except upon DEQ determination of similarity as provided immediately above,the following activities and associated discharges are excluded from coverage under this General Permit: Establishments primarily engaged in: Logging[SIC 2411], or manufacturing Wood Kitchen Cabinets ISIC 24 4]; or Wood preserving[5]C 2491]. If you were thinking they could switch to the NCG21,then we'll need to keep them under the individual permit as they don't qualify and we will need to inform Mr. Maddox. Thank you, Brianna Young, MS(she/her/hers) Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR) Brlanna.Young@ncdenr.gov(e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public during this challenging time. From:Young, Brianna A Sent: Wednesday, November 16, 2022 2:58 PM To: Kay, Lily C<lily.kay@ncdenr.gov>; Carson, Brittany<brittany.carson@ncdenr.gov> Cc: Eplin,Tamera <tamera.eplin@ncdenr.gov> Subject: RE: Fortress Wood Products (NCS000566) Thanks, Lily! I'll try reaching out to them to let them know and see if they want to change permit coverage. Brianna Young, MS(she/her/hers) Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR) 2 Brianna.Young@ncdenr.gov(e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public during this challenging time. From: Kay, Lily C<lily.kay@ncdenr.gov> Sent:Tuesday, November 15, 2022 6:27 PM To:Young, Brianna A<Brianna.Young@ncdenr.gov>; Carson, Brittany<brittany.carson@ncdenr.gov> Cc: Eplin,Tamera <tamera.eplin@ncdenr.gov> Subject: RE: Fortress Wood Products (NCS000566) Ladies, Please see the email correspondence below. Thanks, Lily From:Young, Brianna A<Brianna.Young@ncdenr.gov> Sent: Monday, November 14, 2022 8:34 AM To: Kay, Lily C<lily.kay@ncdenr.gov> Subject: RE: Fortress Wood Products (NCS000566) Okay—if you want to write up the inspection report and tell them they can apply for a general permit, I'm fine with that. Let Brittany and I know when you send that out.Thanks! Brianna Young, MS(she/her/hers) Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Young@ncdenr.gov(e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public during this challenging time. 3 From: Kay, Lily C<lily.kay@ncdenr.Bov> Sent:Thursday, November 10, 2022 3:56 PM To:Young, Brianna A<Brianna.Young@ncdenr.gov> Subject: RE: Fortress Wood Products (NCS000566) I don't think they ever have, but I told the plant manager to document it with photos at the next rain event. I just don't see where the pond would overtop and if it did, it would stay on their property. Even the SPPP,written by a consultant, stated that the discharge would not make it to a stream and would eventually infiltrate. So, since they technically don't have to sample until it leave the property, I just don't see it making it that far. From:Young, Brianna A<Brianna.Young@ncdenr.gov> Sent:Thursday, November 10, 2022 3:51 PM To: Kay, Lily C<lily.kay@ncdenr.gov> Subject: RE: Fortress Wood Products (NCS000566) If you feel comfortable with them going to a general permit, I'm fine with that. Have they ever had a discharge? If they did, would the general permit be adequate enough for it? Brianna Young, MS(she/her/hers) Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Young@ncdenr.gov(e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public during this challenging time. From: Kay, Lily C<lily.kay@ncdenr.gov> Sent:Thursday, November 10, 2022 3:48 PM To:Young, Brianna A<Brianna.Young@ncdenr.gov> Subject: RE: Fortress Wood Products (NCS000566) Hey Brianna, I inspected them yesterday and they don't actually have a discharge. They have a 6-7 asphalt yard with yard inlets that lead to a 2-acre pond and there was no evidence of overtopping. They also own about 30 acres past the pond. I believe it infiltrates in the pond bottom. They had taken samples from the inlet pipe of the pond, and they are over the benchmark limitations for Copper, but considering they don't have a discharge, I think they could go to a general permit. Tell me what you think, and I'll write the report accordingly. Thanks, Lily 4 From:Young, Brianna A<Brianna.Young@ncdenr.gov> Sent:Tuesday, November 1, 2022 2:22 PM To: Eplin,Tamera <tamera.eplin@ncdenr.gov>; Kay, Lily C<lily.kay@ncdenr.gov> Subject: Fortress Wood Products (NCS000566) Hello, I have started reviewing the Fortress Wood Products stormwater renewal application (NCS000566). Please let me know if there are any concerns that need to be addressed during this renewal. Please perform an inspection as well as I don't see any history of one having been done in BIMS. Thanks! Brianna Young, MS(she/her/hers) Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Young@ncdenr.gov(e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 D_ E � NORTH CAROLINA kJ /) Department of Environmental Duality Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public during this challenging time. 5 Young, Brianna A From: Young, Brianna A Sent: Monday, November 14, 2022 8:34 AM To: Kay, Lily C Subject: RE: Fortress Wood Products (NCS000566) Okay—if you want to write up the inspection report and tell them they can apply for a general permit, I'm fine with that. Let Brittany and I know when you send that out.Thanks! Brianna Young, MS(she/her/hers) Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Young@ncdenr.gov(e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public during this challenging time. From: Kay, Lily C<lily.kay@ncdenr.gov> Sent:Thursday, November 10, 2022 3:56 PM To:Young, Brianna A<Brianna.Young@ncdenr.gov> Subject: RE: Fortress Wood Products (NCS000566) I don't think they ever have, but I told the plant manager to document it with photos at the next rain event. I just don't see where the pond would overtop and if it did, it would stay on their property. Even the SPPP,written by a consultant, stated that the discharge would not make it to a stream and would eventually infiltrate. So, since they technically don't have to sample until it leave the property, I just don't see it making it that far. From:Young, Brianna A<Brianna.Young@ncdenr.gov> Sent:Thursday, November 10, 2022 3:51 PM To: Kay, Lily C<lily.kay@ncdenr.gov> Subject: RE: Fortress Wood Products (NCS000566) If you feel comfortable with them going to a general permit, I'm fine with that. Have they ever had a discharge? If they did, would the general permit be adequate enough for it? Brianna Young, MS(she/her/hers) Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR) 1 Brianna.Young@ncdenr.gov(e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public during this challenging time. From: Kay, Lily C<lily.kay@ncdenr.gov> Sent:Thursday, November 10, 2022 3:48 PM To:Young, Brianna A<Brianna.Young@ncdenr.gov> Subject: RE: Fortress Wood Products (NCS000566) Hey Brianna, I inspected them yesterday and they don't actually have a discharge. They have a 6-7 asphalt yard with yard inlets that lead to a 2-acre pond and there was no evidence of overtopping. They also own about 30 acres past the pond. I believe it infiltrates in the pond bottom. They had taken samples from the inlet pipe of the pond, and they are over the benchmark limitations for Copper, but considering they don't have a discharge, I think they could go to a general permit. Tell me what you think, and I'll write the report accordingly. Thanks, Lily From:Young, Brianna A<Brianna.Young@ncdenr.Bov> Sent:Tuesday, November 1, 2022 2:22 PM To: Eplin,Tamera <tamera.eplin@ncdenr.gov>; Kay, Lily C<lily.kay@ncdenr.gov> Subject: Fortress Wood Products (NCS000566) Hello, I have started reviewing the Fortress Wood Products stormwater renewal application (NCS000566). Please let me know if there are any concerns that need to be addressed during this renewal. Please perform an inspection as well as I don't see any history of one having been done in BIMS. Thanks! Brianna Young, MS(she/her/hers) Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Young@ncdenr.gov(e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 2 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 D E NORTH CAROLINA - Department of Environmental Quality Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public during this challenging time. 3 Compliance Inspection Report Permit:NCS000566 Effective: 04/09/13 Expiration: 03/31/18 Owner: The Lester Group- Fortress Wood Products SOC: Effective: Expiration: Facility: Fortress Wood Products Inc County: Randolph 3874 Bethel Dr Extention Region: Winston-Salem High Point NC 27260 Contact Person:Pete Haskins Title: Phone: 336-854-9585 Directions to Facility: System Classifications: SWNC, Primary ORC: Certification: Phone: Secondary ORC(s): On-Site Representative(s): Related Permits: Inspection Date: 11/09/2022 Entry Time 01:OOPM Exit Time: 01:50PM Primary Inspector:Lily C Kay Phone: 704-663-1699 Secondary Inspector(s): Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Stormwater Discharge, Individual Facility Status: ❑ Compliant Not Compliant Question Areas: Storm Water (See attachment summary) Page 1 of 3 Permit: NCS000566 Owner-Facility:The Lester Group-Fortress Wood Products Inspection Date: 11/09/2022 Inspection Type:Compliance Evaluation Reason for Visit: Routine Inspection Summary: The Stormwater Pollution Prevention Plan (SWPPP) and related documentation was complete including employee training records, inspection records, and the annual certification. Analytical monitoring has been conducted but at the inlet to the pond with high results for copper. The pond does not appear to discharge. Documentation of"No Flow" needs to be taken by the permittee and submitted to the Winston-Salem office. The 6.2-acre site drains to a 2-acre pond that does not appear to discharge. If the pond were to discharge, the facility owns at least 20 acres of woods where the flow would sheet flow and eventually infiltrate into the ground. Considering these factors, this permit can be changed to a general permit. If you have questions, contact me at Lily.Kay@ncdenr.gov or by phone at(336) 776-9655. Page 2 of 3 Permit: NCS000566 Owner-Facility:The Lester Group-Fortress Wood Products Inspection Date: 11/09/2022 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? ❑ ❑ ❑ #Does the Plan include a General Location (USGS) map? ❑ ❑ ❑ #Does the Plan include a"Narrative Description of Practices"? ❑ ❑ ❑ #Does the Plan include a detailed site map including outfall locations and drainage areas? ❑ ❑ ❑ #Does the Plan include a list of significant spills occurring during the past 3 years? ❑ ❑ ❑ #Has the facility evaluated feasible alternatives to current practices? ❑ ❑ ❑ #Does the facility provide all necessary secondary containment? ❑ ❑ ❑ #Does the Plan include a BMP summary? ❑ ❑ ❑ #Does the Plan include a Spill Prevention and Response Plan (SPRP)? ❑ ❑ ❑ #Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ❑ ❑ ❑ #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? 0 ❑ ❑ ❑ #Does the Plan include a Stormwater Facility Inspection Program? 0 ❑ ❑ ❑ Has the Stormwater Pollution Prevention Plan been implemented? 0 ❑ ❑ ❑ Comment: The Stormwater Pollution Prevention Plan (SWPPP) and related documentation was complete including employee training records, inspection records, and the annual certification. Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring? ❑ 0 ❑ ❑ Comment: Qualitative monitoring can not be conducted due to the lack of flow. 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? 0 ❑ ❑ ❑ Comment: Analytical monitoring has been conducted but at the inlet to the pond with high results for copper. The pond does not appear to discharge. Documentation of"No Flow" needs to be taken by the permittee and submitted to the Winston-Salem office. Permit and Outfalls Yes No NA NE # 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? ❑ ❑ 0 ❑ Comment: The 6.2-acre site drains to a 2-acre pond that does not appear to discharge. If the pond were to discharge, the facility owns at least 20 acres of woods where the flow would sheet flow and eventually infiltrate into the ground. Page 3 of 3 10/31/22,2:27 PM North Carolina Secretary of State Search Results • File an Annual Report/Amend an Annual Report • Upload a PDF Filing • Order a Document Online - Add Entity to My Email Notification List • View Filings • Print a Pre-Populated Annual Report form • Print an Amended a Annual Report form Business Corporation Legal Name The Lester Group, Inc. Information Sosld: 0301510 Status: Active-On Notice O Date Formed: 2/20/1992 Citizenship: Foreign State of Incorporation: VA Fiscal Month: December Annual Report Due Date: April 15th Delinquentgnnual Report Status: Registered Agent: Boles, Harry a Addresses Principal Office Reg Office Reg Mailing 101 E Commonwealth Blvd 115 S Main Street 115 S Main Street Martinsville, VA 24112 Kernersville, NC 27284 Kernersville, NC 27284 Mailing PO Drawer 4991 Martinsville, VA 24112 Officers Chief Executive Officer Chief Financial Officer Chairman of the Board George Dickens , Jr Timothy Joyce George W Lester , II 101 EAST COMMONWEALTH BLVD 101 E Commonwealth Blvd 101 E Commonwealth Blvd MARTINSVILLE VA 24112-0000 Martinsville VA 24112 Martinsville VA 24112 https://www.sosnc.gov/online_services/search/Business_Registration_ResuIts 1/2 10/31/22,2:27 PM North Carolina Secretary of State Search Results Vice President Vice President Secretary Donna Morrison Nancy Overton Terri Richardson 101 E Commonwealth Blvd 101 EAST COMMONWEALTH BLVD 101 E Commonwealth Blvd Martinsville VA 24112 MARTINSVILLE VA 24112-0000 Martinsville VA 24112 Stock Class: 99 SEE CERT Shares: 0 Par Value 0 https://www.sosnc.gov/online_services/search/Business_Registration_ResuIts 2/2 Young, Brianna A From: Young, Brianna A Sent: Friday, March 24, 2023 3:13 PM To: 'DAVID P MADDOX' Subject: RE: [External] RE: Fortress Wood Products stormwater permit NCS000566 Good afternoon David, We received the information for NCS000566 in our office today. I will reach out with any questions once I've had a chance to review everything. Thank you, Brianna Young, MS(she/her/hers) Industrial Individual Permits Coordinator Stormwater Permitting Program INC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Young@ncdenr.gov(e-mail preferred) 919-707-3647(office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public during this challenging time. From:Young, Brianna A Sent:Wednesday, March 22, 2023 8:50 AM To: DAVID P MADDOX<dmaddox@comcast.net> Subject: RE: [External] RE: Fortress Wood Products stormwater permit NCS000566 Thank you for this update. Brianna Young, MS(she/her/hers) Industrial Individual Permits Coordinator Stormwater Permitting Program INC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Young@ncdenr.gov(e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 Email correspondence to and from this address is subject to the North Carolina 1 Public Records Law and may be disclosed to third parties. Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public during this challenging time. From: DAVID P MADDOX<dmaddox@comcast.net> Sent:Tuesday, March 21, 2023 1:56 PM To:Young, Brianna A<Brianna.YounR@ncdenr.gov> Subject: RE: [External] RE: Fortress Wood Products stormwater permit NCS000566 CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to Report Spam. Ms. Young, As a courtesy communication, I wanted you to know that the Stormwater Permit Renewal Application for source NCS000566 has been sent to your attention via Certified Priority Mail. Am currently working on source NCS000008 and will be sending that application soon. Dave Maddox On 03/15/2023 9:40 AM Young, Brianna A<brianna.young@ncdenr.gov>wrote: Good morning David, To confirm,you used the Permit Contact Update Request Form to submit the requests? I do not see in our internal database that you have been added as a permit contact to each permit. If you did use the online form and it has not been processed, it is likely due to a shortage of staff resources. Our staff that handle those requests have limited capacity to process these requests right now, so it may be taking additional time. Thank you, Brianna Young, MS(she/her/hers) Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR) 2 Brianna.Young@ncdenr.gov(e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public during this challenging time. From: DAVID P MADDOX<dmaddox@comcast.net> Sent:Tuesday, March 14, 2023 11:35 PM To:Young, Brianna A<Brianna.Young@ncdenr.gov> Subject: RE: [External] RE: Fortress Wood Products stormwater permit NCS000566 CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to Report Spam. Ms. Young, Thank you for your instructions on helping me register as an additional permit contact for Fortress Wood. However, after updating the two forms, one each for permit NCS000008 and NCS000566, I cannot find where the updates were validated. Could you confirm that I have been added to your record base as an additional permit contact. 3 Secondly, is their a fee required to be sent when these permit renewals are filed. Again, thanks for your help and assistance. Dave Maddox ES2 Environmental Solutions and Strategies, LLC P. O. Box 4244 Martinsville, Virginia 24115 (276-806-0178)Telephone (276-632-6137) Fax On 03/06/2023 10:14 AM Young, Brianna A<brianna.young@ncdenr.gov>wrote: Good morning, I will include Mr. Maddox on future correspondence. Please note Mr. Maddox is not in our database as a permit contact. If permit contacts need to be updated, please follow the below instructions: Enter your stormwater permit number into the Stormwater Permit Summary Report and you will see a form that includes the address of the facility, contact information for the permit, and the regulated stormwater outfall(s) for the facility. To update the: 4 • Facility/Company name or ownership, complete the Name/Ownership Change Form. • Legally responsible person (Owner Affiliation), complete the Permit Contact Update Request Form. • Delegation of Signature Authority (DOSA), complete the Permit Contact Update Request Form. • Billing contact, complete the Permit Contact Update Request Form. • Permit contact, complete the Permit Contact Update Request Form. • Facility contact, complete the Permit Contact Update Request Form. • Facility address only, email Bethany Georgoulias. • Stormwater outfall information, email Bethany Geor oulias. Thank you, Brianna Young, MS(she/her/hers) Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Young@ncdenr.gov(e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. 5 Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public during this challenging time. From: Pete Haskins<phaskins@fortresswood.com> Sent: Monday, March 6, 2023 9:00 AM To:Young, Brianna A<Brianna.Young@ncdenr.gov> Cc: Dave Maddox(dmaddox@comcast.net)<dmaddox@com cast.net>;Zach Crews <zcrews@fortresswood.com> Subject: [External] RE: Fortress Wood Products stormwater permit NCS000566 CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to Report Spam. Good Morning Ms.,Young, I apologize for not responding sooner. I overlooked the email from January 241h thinking that all correspondence also included our consultant ( Mr. Dave Maddox). I have forwarded your email from the 24' and we are working on this matter as I write this. Would ask that in the future please include Mr. Maddox on all emails going forward. Have included him on this response so you have his email address on file. Thank you, Pete Haskins Fortress Wood Products 3874 Bethel Drive Extension High Point, NC 27260 From: Young, Brianna A<Brianna.Young@ncdenr.gov> Sent: Friday, March 3, 2023 11:20 AM To: Pete Haskins<phaskins@fortresswood.com> 6 Subject: RE: Fortress Wood Products stormwater permit NCS000566 Importance: High Good morning, I am following up on our previous correspondence.To date I have not received the requested information. Please note this information is required in order to proceed with reviewing the individual industrial stormwater permit application. Please let me know if you have any questions concerning this request. Thank you, Brianna Young, MS(she/her/hers) Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Young@ncdenr.gov(e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public during this challenging time. 7 From: Young, Brianna A Sent:Tuesday,January 24, 2023 9:11 AM To: 'phaskins@fortresswood.com'<phaskins@fortresswood.com> Subject: RE: Fortress Wood Products stormwater permit NCS000566 Good morning, After further review and discussion, it has come to the Stormwater Permitting Program's attention that this facility does not qualify for coverage under a General Permit. Previous communication I sent indicated this was a possibility, however,the NCG210000 does not provide coverage for wood preserving facilities. I apologize for the confusion. As the Fortress Wood Products facility does not qualify for General Permit coverage, an individual permit is still required.Therefore, I will continue reviewing the permit renewal application that was submitted. In order to do so, I will need the information I previously requested (see in this email chain). Please let me know if you have any questions as you work to gather this information. Thank you, Brianna Young, MS(she/her/hers) Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Young@ncdenr.gov(e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 8 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public during this challenging time. From:Young, Brianna A Sent:Wednesday, November 16, 2022 3:05 PM To: phaskins@fortresswood.com Subject: RE: Fortress Wood Products stormwater permit NCS000566 Importance: High Good afternoon, It has recently come to our attention that the Fortress Wood Products facility, currently permitted under stormwater permit NCS000566, may be eligible for different permit coverage. Per the inspection report dated November 9, 2022 (see attached),the DEMLR inspector felt the permit type could change from an Individual Permit to a General Permit. If you wish to explore coverage under a General Permit, please contact Brittany Carson at Brittany.carson@ncdenr.gov or via phone at 919-707-3648. If you wish to continue with permit coverage under the existing Individual Permit, please provide the information previously requested (see below). We request an initial response on this by December 16, 2022. Thank you, Brianna Young, MS(she/her/hers) Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR) 9 Brianna.Young@ncdenr.gov(e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public during this challenging time. From:Young, Brianna A Sent:Tuesday, November 1, 2022 2:26 PM To: phaskins@fortresswood.com Subject: Fortress Wood Products stormwater permit NCS000566 Good afternoon, I am working on renewing the individual stormwater permit for the Fortress Wood Products facility (NCS0OO566). I need additional information in order to 1) confirm that the information I have is correct and 2) make sure the permit adequately serves the needs of the facility. Please provide the following: • Supplemental information required with the permit renewal application was not submitted. Please visit our website here, fill out the SPPP Certification Form and Supplemental Information Form and provide all required attachments. • Description of industrial activity occurring onsite; • Confirmation on the number of outfalls and associated coordinates; 10 • Description of industrial activity in each drainage area; • SIC (NAICS) code; • An electronic spreadsheet summarizing all of the monitoring data that has been collected since the effective date of the current permit; • Verification that the information in the renewal application is still complete and correct; and • An explanation of any operational changes since the renewal application was submitted. Enter your stormwater permit number into the Stormwater Permit Summary Report and you will see a form that includes the address of the facility, contact information for the permit, and the regulated stormwater outfall(s) for the facility. Please review the facility information to make sure it is correct. Information can be updated using the links provided below, where applicable: • Facility/Company name or ownership: Name/Ownership Change Form • Owner Affiliation(Legally responsible person; i.e., someone with the company who is designated to represent the company per signatory requirements or another authorized representative): Permit Contact Update Request Form • Delegation of Signature Authority (DOSA): Permit Contact Update Request Form • Billing contact: Permit Contact Update Request Form • Permit contact: Permit Contact Update Request Form • Facility contact: Permit Contact Update Request Form • Facility address only: Email Bethany Georgoulias • Stormwater outfall information: Email Georgoulias o • Visit the eDMR Six Steps website and complete Steps 1 and 2. • Pay outstanding permit fees: Stormwater ePayment website Once I have the above listed information, I can continue my review. You will receive a draft permit for a 30-day comment period. During this time we will be able to address any comments or concerns you have. During the same 30-day period, the draft will be sent to a Regional Office staff member for review as well as out to public notice. Once all comments and concerns are addressed,you may be issued a final permit. li Please contact me if you have any questions. Thank you, Brianna Young, MS(she/her/hers) Industrial Individual Permits Coordinator Stormwater Permitting Program NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR) Brianna.Young@ncdenr.gov(e-mail preferred) 919-707-3647 (office) Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612 Physical address: 512 North Salisbury Street, Raleigh, NC 27604 D E NORTH CAROLINA - Department of Environmental Quality Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public during this challenging time. 12 ES2 Environmental Solutions & Strategies P.O.Box 4244 Martinsville, Virginia 24115 Telephone (276) 806-0178 Fax (276) 632-6137 ES2 Environmental Solutions & Strategies P.O.Box 4244 Martinsville, Virginia 24115 Telephone (276) 806-0178 Fax (276) 632-6137 13 ES2 Environmental Solutions and Strategies, LLC P. O. Box 4244 Martinsville Virginia 24115 March 20, 2023 Certified Mail--Return Receipt Requested RECEIVED 70210350 0000 97201667 , R Ms. Brianna Young 2 4 2023 Industrial Individual Permits Coordinator DEMLR Storm Water Permitting Program 1612 Mail Service Center Raleigh, North Carolina 27699-1612 RE_ Fortress Wood Products, Storm Water Permit Renewal Application, NCS 000566 Dear Ms. Young, Per your a-mails to Pete Haskins and our recent telephone conversations, please find enclosed the completed Storm Water Permit Renewal Application, and one additional copy thereof, for source NCS 000566, Fortress Wood Products, located at 3874 Bethel Drive Extension, High Point, North Carolina, 27260 Thank you for your patience in this matter as we are still trying to determine why my name and contact information was left off the original e-mail notifications to Fortress Wood Products. Also thank you for taking the time in providing directions to correct this issue and for your helpful guidance in getting this renewal application prepared. Should you have any questions, concerns, or comments, with the aforementioned or the permit renewal application(s) submitted herein, please contact me by telephone at (276) 806- 0178, by e-mail at dmaddox@comcast.net or by facsimile at (276) 632-6137. Again, thank you so much for your help and assistance in getting these matters moving. Sincerel a " President & CEO Environmental Solutions and Strategies, LLC P. O. Box 4244 Martinsville,Virginia 24115 / 276-806-0178 (telephone) 276-632-6137 (fax) C: ES2 Files Fortress Wood Products—High Point Stormwater Files FORTRESS WOOD PRODUCTS 3874 BETHEL DRIVE EXTENSION HIGH POINT, NORTH CARO LI NA 27260 STORM WATER PERMIT NCS 000566 RECEIVED MAI? 2 A. 2023 ?EMLR•Stormwater Program STORM WATER PERMIT APPLICATION North Carolina Division of Energy, Mineral, and Land Resources - Stormwater Program MARCH 17, 2023 TABLE OF CONTENTS Supplemental Information Required for Renewal of 1 Individual NPDES Stormwater Permit --------------------------------------------------------------------------------------------- Site Map From the Stormwater Pollution Plan with 2 Stormwater Outfalls Identified ----------------------------------------------------------------------------------------------- Description of Industrial Activity Occurring Onsite and SIC 3 ----------------------------------------------------------------------------------------------- Summary of Analytical Monitoring Results During the Term 4 Of the Existing Permit ----------------------------------------------------------------------------------------------- r` Summary of the Visual Monitoring Results During the Term 5 Of the Existing Permit ----------------------------------------------------------------------------------------------- Summary of the Best Management Practices Utilized at 6 Permitted Facility ----------------------------------------------------------------------------------------------- Short Narrative Describing any Significant Changes in 7 Industrial Activity at the Permitted Facility ----------------------------------------------------------------------------------------------- Certification of the Development and Implementation of a 8 Stormwater Pollution Prevention Plan for the Permitted Facility ----------------------------------------------------------------------------------------------- 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 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. 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. 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. 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. 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. 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) Exhibit A2 Supplemental Information ` EPA Form I Section Xl -Aerial map with Property Lines - 3874 Bethel Drive Extension High Point, North Carolina 27260 (All Al IJ �y '; i' .... .....r. Fage 1 ot'1 blflg Maps Olt r a' 47 �., 3874 Bethel Dr Ext, High Point, NC 27260 My Notes 7 Exhibit BI and B2 fyd-a k. y :.k Supplemental Information I EPA Form 2F NPDE Section III—Site Drainage Map `�• - On the go?Use m.bing.som to find maps. directions,businesses,and more y!�i'fi h".RSG 3a Fa a 3 Popp— WOW e � l s a . b ` 0 r D Branch- _ ( 70 29 •��Jf ��•� �nv,311,� �' clla"n� t�oi_•c C7_ OD ]rtar. •"v'r' - s. Bird's eye view maps can't be printed, so another map view has been substituted. http://www.bing.com/maps/print.aspx?mkt=en-us&z=17&s=b&cp=3 5.914103.-80.04484... 11/27/2012 bird Maps 3874 Bethel Dr Ext, High Point, NC 27260 I My NotesN, ry Exhibit D Supplemental Information , EPA Form 2F NPDES , Large Aerial Lower Detention `, 7 Pond and Location OutfaI1001 . y ' 01,11 fYti l Y_ Ln€ �0 UsC m.bing.COM Lc f:-!a t•-,- 25 '* �F Elf c-e:(;ors. tx,smesses,ar.7 m:w-� •�' �'s � '� ; a�,.� � h �' •ter'- -' b.3" r•.y R S' t.�F3�'^ r t .Y1 1 ' , Y..L,- 1 -7 1 , i Bird's eye view maps can't be printed, so another map view has been substituted. http://vvvv-,Ar.bing.com/maps/print.aspx?mkt=en-us&z=19.630867309455436&s=b&cp=35... 11/27/2012 Fortress Wood Products 3874 Bethel Drive Extension High Point, North Carolina 27260 Description of Industrial Activity Occurring Onsite The major activity at the plant is the treatment of lumber products. Untreated lumber is received from vendors on trucks or rail whereby it is unloaded, stored,and introduced into the treatment process where each piece of wood is chemically treated to be resistant to rot and decay. Lumber remains on the treatment area drip-pad until the dripping of free liquid from the treatment process is considered to have stopped. Once dripping has been determined stopped,the treated lumber is removed to the storage yard, warehouses,or shipping area The process system reclaims and recycles as much of the dripping as possible of treatment chemicals from the pads. Currently,all chemicals used in the treatment process are stored inside the treatment process area in totes and above ground storage tanks. The entire treatment area is covered by roof and is built in such a manner whereby the treatment area would contain any catastrophic accident which could cause the release of all the chemicals being stored. The constant movement and storage of unprocessed and processed lumber does,during very dry periods of time,causes the formation of fine dust on the surface of areas traversed on unpaved areas. The formation of fine dust is kept to a minimum by rotating storage strategies. �. The potential pollutants which could be expected to be present in the storm water discharge at each outfall would be TSS from the dust accumulated on the yard,traces of treatment chemicals, COPPER and their natural reactive chemistry,resultant a storm event washing over the surface of treated wood that has been staged on the yard awaiting shipment to customers,and COD and BOD from the interaction of oxygen with suspended solids and treatment chemicals An above ground double walled storage tank containing fuel for on-site vehicle operation resides on a concrete pad that is covered and diked in order to contain a sufficient quantity of the contents of the tank in the event of a spill. The handling of waste by the facility is dependent upon the characterization of the waste. Normally,the majority of waste generated at the facility is considered to be non-hazardous and is therefore placed into appropriate dumpsters strategically located throughout the facility. These wastes are removed from the facility on an as need basis and delivered to local landfills by contracted waste carriers. Hazardous waste materials are placed into hazardous waste satellite containers whereby they are accumulated for subsequent transfer into hazardous waste drums which are dated, labeled as to contents,and placed into secure storage awaiting removal from the premises by a licensed hazardous waste carrier. Due to vehicle maintenance being contracted off-site, there is little waste oil, lubricants,or law&, maintenance fluids with respect to vehicle maintenance. Universal wastes are treated according to regulation and frequency of occurrence. Fortress Wood Products 3874 Bethel Drive Extension High Point, North Carolina 27260 SIC (NAILS) Code SIC - 2491 FORTRESS WOOD PRODUCTS STORMWATER PERMIT NUMBER -NCS 000566 ANALYTICAL SUMMARIES Total Copper Total Nitrate- Ammonia TSS COD Chloride Nitrite Rainfall Recoverable Chloride pH Inches mg/I mg/I mg/l mg/I Nitrogen mg/I Sampling Date Sample Parameter Sampling Period mg/I Benchmarks >0.1 100 120 0.007 860 10 5.6 6.9 OUTFALL#1 6/5/2013 Semi-Annual Year 1-Period 1 0.10 76.0 146.0 1.410 8.30 0.985 1.290 6.09 12/10/2013 Semi-Annual Year 1-Period 2 0.25 94.0 56.0 0.874 7.50 0.212 0.147 5.80 January 2014 Tier II No Flow rebruary 2014 Tier II No Flow March 2014 Tier II No Flow 4/7/2014 Semi-Annual Year 2-Period 1 0.50 66.0 65.0 0.409 <1.0 0.239 0.320 6.03 May 2014 Tier II No Flow June 2014 Tier II No Flow July 2014 Tier II No Flow 8/1/2014 Semi-Annual Year 2-Period 2 1.30 70.0 66.0 0.602 2.80 0.293 0.170 6.05 August 2014 Tier II No Flow 10/15/2014 Tier II 0.25 38.4 66.0 0.589 2.85 0.208 <0.010 5.41 11/14/2014 Tier II 0.25 66.2 73.0 0.640 <1.0 0.264 0.120 6.81 12/29/2014 Tier 11 0.30 24.0 49.0 0.533 3.32 0.213 <0.100 6.31 1/23/2015 Tier 11 0.40 31.0 48.0 0.419 2.38 0.223 0.140 N February 2015 Tier II No Flow 3/27/2015 Tier II 0.30 20.0 24.0 0.316 1.42 0.776 0.100 N April 2015 Tier 11 No Flaw May 2015 Tier II No Flow June 2015 Tier II No Flow July 2015 Tier II No Flow August 2015 Tier 11 No Flow 9-25-2015 Semi-Annual Year 3-Period 1 0.60 33.0 71.0 0.601 12.00 <1.000 <0.100 5.99 10/27/2015 Tier 11 0.25 49.5 106.0 1.080 1.40 0.572 0.127 5.74 11/02/2015 Tier II 1.52 23.0 64.0 0.852 0.94 0.138 <0.100 5.95 12/17/2015 Semi-Annual Year 3-Period 2 1.23 38.0 70.0 0.798 1.40 0.200 <0.100 6.11 January 2016 Tier II No Flow 2/16/2016 Semi-Annual Year 4-Period 1 1.07 26.0 44.0 0.445 2.81 1.030 0.190 6.03 March 2016 Tier 11 No Flow FORTRESS WOOD PRODUCTS STORMWATER PERMIT NUMBER -NCS 000S66 ANALYTICAL SUMMARIES Total Copper Total Nitrate- Ammonia TS5 COD Chloride Nitrite Rainfall Recoverable Nitrogen pH Inches mg/l mg/I mg/l mg/1 Nitrogen mg/1 Sampling Date Sample Parameter Sampling Period mg/I Benchmarks >0.1 100 1 120 0.007 860 10 5.6 6.9 OUTFALL#1 4/12/2016 Tier II 0.12 50.8 99.0 0.848 <1.000 0.350 <0.10 5.67 5/5/2016 Tier ll 1.44 29.3 74.0 0.597 <1.000 <0.050 <0.10 5.15 April 2016 Tier II No Flow May 2016 Tier II No Flow June 2016 Tier II No Flow July 2016 Tier II No Flow August 2016 Tier II No Flow 9/22/16 Semi-Annual Year 4-Period 2 0.21 66.2 87.0 0.98 1.96 0.236 <0.10 5,34 October 2016 Tier it No Flow November 2016 Tier II No Flow December 2016 Tier ll No Flow 01/23/2017 Semi-Annual Year 5-Period 1 0.89 20.0 40.0 0.885 1.88 0.128 2.10 6.87 February 2017 Tier II No Flow March 14,2017 Tier II >.100 0.168 7.18 April 24,2017 Tier II >.100 0.127 6,40 May 23,2017 Tier II >.100 0.124 6.45 June 2017 Tier II - July 2017 Tier II - August 2017 Tler II - 09/6/2017 Semi-Annual Year 5-Period 2 0.84 18.7 38.0 0.984 1.00 0.063 <0.10 6.32 October 2017 Tier II No Flow November 2017 Tier II No Flow December 2017 Tier II No Flow January 2018 Tier II No Flow February 2018 Tier II No Flow March 2018 Tier II No Flow April 2018 Tier II No Flow May 2018 Tier II No Flow 6/2/2018 Semi-Annual Year 6-Period 1 1.90 19.0 47.0 0.61$ 1 2.44 0.436 1 <0.10 1 7.40 FORTRESS WOOD PRODUCTS STORMWATER PERMIT NUMBER -NCS 000566 ANALYTICAL SUMMARIES Total Copper Total Nitrate- Ammonia Rainfall TSS COD Recoverable Chloride Nitrite Nitrogen pH Inches mg/I mg/l mg/I mg/1 Nitrogen mg/l Sampling Date Sample Parameter Sampling Period mg/1 Benchmarks >0.1 1 100 1 120 1 0.007 1 860 1 10 1 5.6 1 6-9 QUTFALL#1 February 2021 Tier 11 No Flow March 2021 Tier 11 No Flow April 2021 Tier II No Flow May 2021 Tier II No Flow June 2021 Tier II No Flow 07/08/2021 Semi-Annual Year 9-Period 2 0.6 20.3 133.0 2.690 1.20 0.580 ND 6.6€) August 2021 Tier 11 No Flow September 2021 Tier II No Flow October 2021 Tier II No Flow November 2021 Tier 11 No Flow December 2021 Tier 11 No Flow January 2022 Tier II No Flow February 2022 Tier 11 No Flow March 2022 Tier 11 No Flow April 2022 Tier 11 No Flow May 2022 Tier II No Flow June 2022 Semi-Annual Year 10-Period 1 No Flow No measurable rainfall during work hours January 2022 through June 2022 July 2022 Tier 11 No Flow August 2022 Tier 11 No Flow September 2022 Tier II No Flow October 2022 Tier II No Flow November 2022 Semi-Annual Year 10-Period 2 1.2 29.6 163.0 6.630 3.00 0.530 r.]1) 6.60 January 2023 Tier 11 No Flow February 2023 Tier 11 No Flow FORTRESS WOOD PROUCTS STORMWATER PERMIT NUMBER - NCS 000566 STORMWATER DISCHARGE OUTFALL (SDO) QUALITATIVE MONITORING REPORTS Floating Suspended Solids Solids Clarity 1 1 Other 1 no solids no solids Erosion or Obvious Total Event very clear 5 5 Foam Oil Sheen Deposition lndicatlons of Precipitation Discharge Discharge 5 surface extremely Observed Observed Observed Yes Pollution Sampling Date Sampling Period (inches) Discharge Color Tint Odor very cloudy covered muddy Yes or No Yes or No or No Observed Outfall#1 6/5/2013 Year 1-Period 1 0.10 Brown Light None 3 3 3 No No No None 12/10/2013 Year 1- Period 2 0.25 Gray Light None 2 1 1 No No No None 4/7/2014 Year 2-Period 1 1.64 Blue/Gray Light None 2 1 1 No No No None 8/1/2014 Year 2-Period 2 1.30 Greay Light None 3 2 2 No No No None 9/25/2015 Year 3-Period 1 0.60 Gray/Brown light None 3 2 2 No No No None 12/17/2015 Year 3-Period 2 1.23 Blue/Gray Light None 2 1 2 No No No None 2/16/2016 Year 4-Period 1 1.07 Gray Light None 3 1 2 No No No None 9/22/2016 Year 4-Period 2 0.21 Gray/Brown Medium None 4 2 2 No No No None 1/23/2017 Year 5-Period 1 0.89 Gray/Brown Light None 2 2 2 No No No None 9/6/2017 Year 5-Period 2 0.94 Gray Light None 2 2 2 No No No None 6/2/2018 Year 6-Period 1 1.90 Gray Light None 2 2 2 No No No None 11/15/2018 Year 6-Period 2 1.35 Gray Light None 2 2 2 No No No None 2/22/2019 Year 7 -Period 1 0.50 Gray Light None 2 2 2 No No No None 12/6/2019 Year 7-Period 2 0.70 Blue/Gray Medium None 4 2 2 No No No None 6/30/2020 Year 8-Period 1 0.50 Gray Light None 2 2 2 No No No None 11/12/2020 Year 8-Period 2 0.50 Gray Light None 2 2 2 No No No None 1/26/2021 Year 9- Period 1 0.75 Gray Light None 3 3 3 No No No None 7/8/2021 Year 9-Period 2 0.50 Gray Light None 3 3 3 No No No None Year 10-Period 1 No measurable rainfall during work hours January 2022 through June 2022 None 11/11/2022 Year 10-Period 2 0.82 Gray Light None 3 3 3 No No No None Fortress Wood Products 3874 Bethel Drive Extension Nigh Point, North Carolina 27260 Best Management Practices Best Management Practices(BMPs)are measures used to prevent or mitigate pollution from any type of activity. BMPs may include processes,procedures, schedules of activity,restrictions on practices, and other management practices to prevent or reduce water pollution. Baseline BMPs are general common sense practices which are inexpensive,relatively simple and applicable to a wide variety of industries and activities. The facility has implemented the following baseline BMPs with emphasis on management practices that ensure continued vigilance of proper facility operations and a methodology of inspections and oversight that continually reviews the program to facilitate effective pollution prevention. Good Housekeeping Those areas of the facility which may contribute pollutants to stormwater discharges are maintained in a clean and orderly manner. All employees are trained in basic clean up procedures. Waste media are collected for disposal on a regular basis. The floors of the kiln, stacker building, and treatment area, as well as the ground surfaces are swept/cleaned on a regular basis. Material storage areas are properly maintained and all containers are labeled in accordance with applicable regulatory requirements. This BMW is addressed in more detail in Section 5. Preventative Maintenance Preventative maintenance inspections of facility equipment are conducted on a monthly basis to ensure that all systems are working properly and to identify conditions(e.g. cracks,leaks,and corrosion)which may cause breakdowns or failures. The most important areas for inspection are the aboveground storage tanks and associated above ground piping. Defective equipment, found during inspections,is promptly repaired or replaced. The completed"Monthly Maintenance Inspection"forms are maintained on-site in this plan. This BMP is addressed in more detail in Section 5. Visual Inspections In addition to the"Monthly Maintenance Inspections"of plant systems and equipment,outdoor storage areas to include loading/unloading and the storm water drainage system(including the drainage swales and outfalls)are conducted semi annually. "Facility Semi-Annual Stormwater Inspection"forms are included in page 58 and copies of the completed forms are also maintained on-site. The goal of these regular semi-annual inspections is to confirm that chosen Best Management Practices for storm water pollution prevention are in place and working properly. This BMP is addressed in more detail in Section 9. Spill Prevention and Response The area with the highest spill potential is the fuel deck which facilitates vehicle fueling. The preventative maintenance/inspection programs outlined above are one of the most important methods for spill prevention. They ensure that faulty equipment and deteriorating storage containers are detected before a leak/release occurs. Good housekeeping practices also reduce the potential for accidental pollutant releases, as it ensures that containers are properly stored and maintained.Employees have also been trained in proper materials handling methods. Finally,in order to prevent spills during loading/uploading, care is taken to ensure that all drums/containers are tightly closed and handled appropriately. Any spills which occur at this facility is documented and records are maintained on-site.This BMP is addressed in more detail in Section 4. Sediment and Erosion Control All undeveloped areas surrounding the plant,including the stormwater drainage swales,are either planted with agricultural crops or grassed to prevent soil erosion. These areas are inspected semi- annually(Facility Sena-Annual Stormwater Inspection)to ensure that erosion is kept at a minimum and grass and/or appropriate vegetation is replanted if bare spots are observed developing. Management of Stormwater Runoff Management of Stormwater runoff is accomplished through practices that control and divert ,MIN stormwater in such a manner that natural filtration of stormwater runoff occurs which reduces the concentration and amount of pollutants in stormwater discharge from the site. This is accomplished through management practices which minimize outside inventory storage of treated lumber,management of areas which provide exposure of other materials and operations,and vigilance as to the healthy integrity of vegetation in and around stormwater swales and outfalls. In this manner,exposure of pollutants is minimized and stormwater runoff can be managed in each of the five stormwater outfalls to reduce flow velocity of the water. Reduction of flow velocity combined with the flow of the water through large areas of vegetation provides the opportunity for pollutants to disperse,dilute, and be naturally captured on site. Employee Training An employee training program is provided to inform personnel at all levels as to their responsibility for assuring that the components and goals.of this SWPPP are upheld and complied with.Employee training addresses each component of the SWPPP, including how and why tasks are to be implemented. This BMP is addresses in detail in Section 6. Recordkeeping and Reporting Recordkeeping and reporting procedures are defined in various sections of this SWPPP and Summarized in Section 9. The inspection,recordkeeping,and reporting program is established to monitor pollution prevention practices,maintain storm water drainage areas,prevent spills and leaks from reaching navigable waters, identify and document needed improvements,and define responsibilities and communications in the event of a related emergency. Activity-Based and Site-Specific Best Management Practice Specific Best Management Practices(BMPs)for industrial activities which may contaminate storm water include fueling, storage of treatment materials, outside storage for treated product,and by-products of activities. Other site-specific BMPs consider storm water flow diversion,exposure minimization practices,mitigation practices,and sedimentation and erosion prevention practices. Type of activity specific BMP Activity specific BMP employed 1.Tank stored in a bermed area. Fueling 2.Dry sorbent material used to clean-up small spills. 3. Topping off of fuel tanks is discouraged. 1.Liquids and chemicals stored in tanks inside of the treatment building where entire contents are contained by the architectural construction of the building. Treatment material storage 2. Tanker off-load area slanted to capture tanker leaks, spills,and catastrophic events. 3. A mechanical dam/gate has been constructed on Stormwater Outfall#2 as a secondary containment strategy in the event of a catastrophic spill which migrates outside the treatment area. 1. Treated product inventory is minimized. 2. Treated material is dead packed and stacked in such a Outside storage of treated product manner to minimize stormwater contact. 3. Treated material is placed on bolsters thereby avoiding direct contact with the ground and stormwater. 1. Water condensate from drying operations is collected Activity by-products I and recycled back into the treatment process. Site-Specific BMPs Activity to mitigate pollution exposure 1. Fuel oil stored in closed tanks. Exposure Minimization Practices 2.Fuel oil stoxuge tanks cleaned as necessary. Mitigation Practices 1. Fueling performed under supervision. Sedimentation and Erosion Prevention 1. Drainage swales are grassed. Practices 2. Sedimentation basin employed BMP Assessment Impacted Area Activity to address assessment Training Liquid Storage Training is part of this S WPPP 1. Swales have been dressed and planted with vegetation. Additionally, rip-rap (stone)has been placed in the swales.All Drainage swales and swale manicuring has been done to assist Stormwater Flow Control property egress in the filtering of the stormwater, control of stormwater flow,and to assist in the prevention of stormwater erosion. Signage added at the fuel deck to remind Signs Liquid Storage Fueling employees of housekeeping and pollution prevention policies. Fortress Wood Products 3874 Bethel Drive Extension High Point ., North Carolina 27260 Short Narrative Describing Any Significant Changes at the Permitted Facility There have been no significant changes made at the permitted facility since the last permit was issued. STORMWATER POLLUTION PREVENTION PLAN DEVELOPMENT AND IMPLEMENTATION CERTIFICATION North Carolina Division of Energy, Mineral, and Land Resources—Stormwater Program Facility Name: Fortress Wood Products Permit Number: NCS000566 Location Address: 3874 Beuworw Extension High Point,North Carolina 27260 County: Randolph "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 to permit g tory requirements)and return this Certification. DO NOT SEND STORMWATE O UTION PREVENTION PLAN WITH THIS CERTIFICATION. Signature date 2- 13 George M.Dickens,Jr. President&CEO.The Lester Group Print or type name of person signing above Title SPPP Certification 10113 ES2 Environmental Solutions and Strategies, LLC P. 0. Box 4244 Martinsville Virginia 24115 March 20, 2023 Certified Mail— Return Receipt Requested RECEIVED 70210350 0000 97201667 Ms. Brianna Young 2 4 2023 Industrial individual Permits Coordinator 1 Eo; crier P.n DEMLR Storm Water Permitting Program 1612 Mail Service Center Raleigh, North Carolina 27699-1612 RE: Fortress Wood Products, Storm Water Permit Renewal Application, NCS 000566 Dear Ms. Young, Per your a-mails to Pete Haskins and our recent telephone conversations, please find enclosed the completed Storm Water Permit Renewal Application, and one additional copy thereof, for source NCS 000566, Fortress Wood Products, located at 3874 Bethel Drive Extension, High Point, North Carolina, 27260 Thank you for your patience in this matter as we are still trying to determine why my name and contact information was left off the original e-mail notifications to Fortress Wood Products. Also thank you for taking the time in providing directions to correct this issue and for your helpful guidance in getting this renewal application prepared. Should you have any questions, concerns, or comments, with the aforementioned or the permit renewal application(s) submitted herein, please contact me by telephone at (276) 806- 0178, by e-mail at dmaddox@comcast.net, or by facsimile at (276) 632-6137. Again, thank you so much for your help and assistance in getting these matters moving. Sincerel a ' x President & CEO Environmental Solutions and Strategies, LLC P. O. Box 4244 Martinsville,Virginia 24115 276-806-0178 (telephone) 276-632-6137 (fax) C: ES' Files Fortress Wood Products—High Point Stormwater Files T FORTRESS WOOD PRODUCTS 3874 BETHEL DRIVE EXTENSION HIGH POINT, NORTH CAROLINA 27260 STORM WATER PERMIT NCS 000566 RECcIVED 0EM R-Stormwater program STORM WATER PERMIT APPLICATION North Carolina Division of Energy, Mineral, and Land Resources - Stormwater Program MARCH 17, 2023 A TABLE OF CONTENTS Supplemental Information Required for Renewal of 1 Individual NPDES Stormwater Permit --------------------------------------------------------------------------------------------- Site Map From the Stormwater Pollution Plan with 2 Stormwater Outfalls Identified ----------------------------------------------------------------------------------------------- Description of Industrial Activity Occurring Onsite and SIC 3 ----------------------------------------------------------------------------------------------- Summary of Analytical Monitoring Results During the Term 4 Of the Existing Permit ----------------------------------------------------------------------------------------------- Summary of the Visual Monitoring Results During the Term 5 Of the Existing Permit ----------------------------------------------------------------------------------------------- Summary of the Best Management Practices Utilized at 6 Permitted Facility ----------------------------------------------------------------------------------------------- Short Narrative Describing any Significant Changes in 7 Industrial Activity at the Permitted Facility ----------------------------------------------------------------------------------------------- Certification of the Development and Implementation of a 8 Stormwater Pollution Prevention Plan for the Permitted Facility ----------------------------------------------------------------------------------------------- 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 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 Iocations and impervious surfaces should be clearly noted. 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, ff parameters sampled, lab results, date sampled,and storm event data. t, 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. 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. S. 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 t practices,and/or changes in the raw materials used by the facility. 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) Exhibit A2 Supplemental Information EPA Form 1 Section XI -Aerial map with Property Lines a _ 3874 Bethel Drive Extension " High Point, North Carolina 27260 • 1 T + { f I' -'fir �(''}yi< qr_ :�• ,� ` "'/� # �w M. isw . ' r •� 1 _ -,... .. ..�. Page 1 of I b+ng Maps 3874 Bethel Dr Ext, High Point, NC 27260 _ ? , a •o My Notes Exhibit B I and B2 LLy�'yy "r•,' .�r{� : Supplemental Information EPA Form 2F NPDES r y � • a: _ Section III—Site Drainage Map On the go?Use m.bing.com to find maps, ;24;� 1 �•. directions,businesses,and more WX a o C 0 Q r D 29 ( 70 OR Bird's eye view maps can't be printed, so another map view has been substituted. http://www.bing.com/maps/print.aspx?mkt=en-us&z=17&s=b&cp=35.914103,-80.04484... 11/27/2012 Maps ' � 3874 Bethel Dr East, l°l[gh Point, hIG 27260 �+ �. EViy Notes 77 L ,; Exhibit Supplementalormation Inf "�. ��' �•,- - � �'�. ��i�:��` fir. EPA Form 2F NPDES Large,Aerial Lower Detention Pond and Location Qutfall 001 '. M On We yz Use m.bingxom!s fr:_ G"E�li�nS,businesses.an-I mere - 5 yy. r ti t i Bird's eye view maps can't be printed, so another map view has been substituted. http://www.bing.com/maps/print.aspx?mkt=en-us&�19.630867309455436&s=b&cp=35... I 1/27/2012 Fortress Wood Products 3874 Bethel Drive Extension High Point, North Carolina 27260 Description of Industrial Activity Occurring Onsite The major activity at the plant is the treatment of lumber products. Untreated lumber is received from vendors on trucks or rail whereby it is unloaded, stored, and introduced into the treatment process where each piece of wood is chemically treated to be resistant to.rot and decay. Lumber remains on the treatment area drip-pad until the dripping of free liquid from the treatment process is considered to have stopped. Once dripping has been determined stopped,the treated lumber is removed to the storage yard, warehouses, or shipping area. The process system reclaims and recycles as much of the dripping as possible of treatment chemicals from the pads. Currently,all chemicals used in the treatment process are stored inside the treatment process area in totes and above ground storage tanks. The entire treatment area is covered by roof and is built in such a manner whereby the treatment area would contain any catastrophic accident which could cause the release of all the chemicals being stored. The constant movement and storage of unprocessed and processed lumber does,during very dry periods of time, causes the formation of fine dust on the surface of areas traversed on unpaved areas.The formation of fine dust is kept to a minimum by rotating storage strategies. The potential pollutants which could be expected to be present in the storm water discharge at each outfall would be TSS from the dust accumulated on the yard,traces of treatment chemicals, COPPER and their natural reactive chemistry,resultant a storm event washing over the surface of treated wood that has been staged on the yard awaiting shipment to customers,and COD and BOD from the interaction of oxygen with suspended solids and treatment chemicals An above ground double walled storage tank containing fuel for on-site vehicle operation resides on a concrete pad that is covered and diked in order to contain a sufficient quantity of the contents of the tank in the event of a spill. The handling of waste by the facility is dependent upon the characterization of the waste. Normally,the majority of waste generated at the facility is considered to be non-hazardous and is therefore placed into appropriate dumpsters strategically located throughout the facility. These wastes are removed from the facility on an as need basis and delivered to local landfills by contracted waste carriers. Hazardous waste materials are placed into hazardous waste satellite containers whereby they are accumulated for subsequent transfer into hazardous waste drums which are dated, labeled as to contents,and placed into secure storage awaiting removal from the premises by a licensed hazardous waste carrier. Due to vehicle maintenance being contracted off-site,there is little waste oil, lubricants,or /AMI, maintenance fluids with respect to vehicle maintenance. Universal wastes are treated according to regulation and frequency of occurrence. Fortress Wood Products 3874 Bethel Drive Extension High Point, North Carolina 27260 SIC (NAILS) Code SIC - 2491 FORTRESS WOOD PRODUCTS STORMWATER PERMIT NUMBER -NCS 000566 ANALYTICAL SUMMARIES Total Copper Total Nitrate- Ammonia TSS COD Chloride Nitrite Rainfall Recoverable Nitrogen pH Inches mg/I mg/I mg/I mg/I Nitrogen mg/I Sampling Date Sample Parameter Sampling Period mg/I Benchmarks >0.1 100 120 0.007 860 10 5.6 6-9 OUTFALL#1 6/5/2013 Semi-Annual Year 1-Period 1 0.10 76.0 146.0 1.410 8.30 0.985 1.290 6.09 12/10/2013 Semi-Annual Year 1-Period 2 0.25 94.0 56.0 0.874 7.50 0.212 0.147 5.80 January 2014 Tier II No Flow February 2014 Tier 11 No Flow March 2014 Tier II No Flow 4/7/2014 Semi-Annual Year 2-Period 1 0.50 66.0 65.0 0.408 <1.0 0.239 0.320 6.03 May 2014 Tier II No Flow June 2014 Tier Il No Flow July 2014 Tier II No Flow 8/1/2014 Semi-Annual Year 2-Period 2 1.30 70.0 66.0 0.602 2.80 0.293 0.170 6.05 August 2014 Tier II No Flow 10/15/2014 Tier Il 0.25 38.4 66.0 0.589 2.85 0.208 <0.010 5.41 11/14/2014 Tier II 0.25 66.2 73.0 0.640 <1.0 0.264 0.120 6.81 12/29/2014 Tier 11 0.30 24.0 49.0 0.533 3.32 0.213 <0.100 6.31 1/23/2015 Tier II 0.40 31.0 48.0 0.419 2.38 0.223 0.140 N February 2015 Tier II No Flow 3/27/2015 Tier It 0.30 20.0 24.0 0.316 1.42 0.776 0.100 N April 2015 Tier II No Flow May 2015 Tier II No Flow June 2015 Tier II No Flow July 2015 Tier 11 No Flow August 2015 Tier 11 No Flow 9-25-2015 Semi-Annual Year 3-Period 1 0.60 33.0 71.0 0.601 12.00 <1.000 <0.100 5.99 10/27/2015 Tier It 0.25 49.5 106.0 1.080 1.40 0.572 0.127 5.74 11/02/2015 Tier II 1.52 23.0 64.0 0.852 0.94 0.138 <0.100 5.95 12/17/2015 Semi-Annual Year 3-Period 2 1.23 38.0 70.0 0.798 1.40 0.200 <0.100 6.11 January 2016 Tier II No Flow 2/16/2016 Semi-Annual Year 4-Period 1 1.07 26.0 44.0 0.445 2.81 1.030 0.190 6.03 March 2016 Tier 11 1 No Flow FORTRESS WOOD PRODUCTS STORMWATER PERMIT NUMBER -NCS 000566 ANALYTICAL SUMMARIES Total Copper Total Nitrate- Ammonia TS5 COD Chloride Nitrite Rainfall Recoverable Nitrogen pH mg/I mg/I mg/I Nitrogen inches mg/I mg/I Sampling Date Sample Parameter Sampling Period mg/l Benchmarks >0.1 1 100 1 120 1 0.007 1 860 10 1 5.6 5 - 9 OUTFALL#1 4/12/2016 Tier II 0.12 50.8 99.0 0.948 <1.000 0.350 <0.10 5.67 5/5/2016 Tier II 1.44 29.3 74.0 0597 <1.000 <0.050 <0.10 5.15 April 2016 Tier II No Flow May 2016 Tier II No Flow June 2016 Tier II No Flow July 2016 Tier II No Flow August 2016 Tier II No Flow 9/22/16 Semi-Annual Year 4-Period 2 s; 0.98 .96 0.236 <0.10 October 2016 Tier II No Flow November 2016 Tier 11 No Flow December 2016 Tier II No Flow 01/23/2017 Semi-Annual Year 5-Period 1 U,89 40.0 0.885 0.12, <0.10 6.87 February 2017 Tier II No Flaw March 14, 2017 Tier 11 >.100 0.168 7.18 April 24, 2017 Tier 11 >.100 0.127 6.40 May 23,2017 Tier 11 >.100 0.124 6.45 June 2017 Tier 11 - July 2017 Tier 11 August 2017 Tier 11 - 09/6/2017 Semi-Annual Year 5-Period 2 18.7 _ 0,9V 0.063 October 2017 Tier 11 No Flow November 2017 Tier II No Flow December 2017 Tier 11 No Flow January 2018 Tier 11 No Flow February 2018 Tier 11 No Flow March 2018 Tier 11 No Flow April 2018 Tier 11 No Flow May 2018 Tier 11 No Flow 6/2/2018 Semi-Annual Year 6-Period 1 1.90 19.0 47.0 0.615 :,'.44 0.436 FORTRESS WOOD PRODUCTS STORMWATER PERMIT NUMBER -NCS 000566 ANALYTICAL SUMMARIES Total Copper Total Nitrate- Ammonia Rainfall TS5 COD Recoverable Chloride Nitrite Nitrogen pH Inches mg/I mg/I mg/1 mg/I Nitrogen mg/l Sampling Date sample Parameter Sampling Period mg/I Benchmarks >0.1 1 100 1 120 1 0.007 1 860 1 10 1 5.6 1 6-9 OUTFALL#1 February 2021 Tier II No Flow March 2021 Tier II No Flow April 2021 Tier II No Flow May 2021 Tier II No Flow June 2021 Tier II No Flow 07/08/2021 Semi-Annual Year 9-Period 2 0.6 20.3 133.0 2.690 1.20 0.580 i,,1D 6.60 August 2021 Tier II No Flow September 2021 Tier II No Flow October 2021 Tier II No Flow November 2021 Tier II No Flow December 2021 Tier II No Flow January 2022 Tier II No Flow February 2022 Tier 11 No Flow March 2022 Tier 11 No Flow April 2022 Tier II No Flow May 2022 Tier 11 No Flow June 2022 Semi-Annual Year 10-Period 1 No Flow No measurable rainfall during work hours January 2022 through June 2022 July 2022 Tier II No Flow August 2022 Tier II No Flow September 2022 Tier II No Flow October 2022 Tier 11 No Flow November 2022 Semi-Annual Year 10-Period 2 1.2 29.6 163.0 6.630 3.00 0.530 ND 6.60 January 2023 Tier II No Flow February 2023 Tier 11 No Flow FORTRESS WOOD PROUCTS STORMWATER PERMIT NUMBER - NCS 000565 STORMWATER DISCHARGE OUTFALL (SDO) QUALITATIVE MONITORING REPORTS Floating Suspended Solids Solids Clarity 1 1 Other 1 no solids no solids Erosion or Obvious Total Event very clear 5 5 Foam Olt Sheen Deposltlon Indications of Precipitation Discharge Discharge 5 surface extremely Observed Observed Observed Yes Pollution Sampling Date Sampling Period (inches) Discharge Color Tint Odor I very cloudy covered muddy Yes or No Yes or No or No Observed Outfall#i 1 6/5/2013 Year 1-Period 1 0.10 Brown Light None 3 3 3 No No No None 12/10/2013 Year 1-Period 2 0.25 Gray Light None 2 1 No No No None 4/7/2014 Year 2- Period 1 1.64 Blue/Gray Light None 2 1 1 No No No None 8/1/7-014 Year 2-Period 2 1.30 Greay Light None 3 2 2 No No No None 9/25/2015 Year 3-Period 1 0,60 Gray/Brown Light None 3 2 2 No No No None 12/17/2015 Year 3-Period 2 1,7.3 Blue/Gray Light None 2 1 2 No No No None 2/16/2016 Year 4-Period 1 1.07 Gray Light None 3 1 2 No No No None 9/22/2016 Year 4-Period 2 0.21 Gray/Brown Medium None 4 2 2 No No No None 1/23/2017 Year 5-Period 1 0.89 Gray/Brown Light None 2 2 2 No No No None 9/6/2017 Year 5-Period 2 0.84 Gray Light None 2 2 2 No No No None 6/2/2018 Year 6-Period 1 1.90 Gray Light None 2 2 2 No No No None 11/15/2018 Year 6-Period 2 1.35 Gray Light None 2 2 2 No No No None 2/22/2019 Year 7-Period 1 0.50 Gray Light None 2 2 2 No No No None 12/6/2019 Year 7-Period 2 0.70 Blue/Gray Medium None 4 2 2 No No No None 6/30/2020 Year 8- Period 1 0.50 Gray Light None 2 2 1 2 No No No None 11/12/2020 Year 8- Period 2 0.50 Gray Light None 2 2 2 No No No None 1/26/2021 Year 9-Period 1 0.75 Gray Light None 3 3 3 No No No None 7/8/2021 Year 9-Period 2 0.50 Gray Light None 3 3 3 No No No None Year 10-Period 1 No measurable rainfall during work hours January 2022 through June 2022 None 11/11/202.2 Year 10-Period 2 0.82 Gray I Light None 3 3 3 No No No None Fortress Wood Products 3874 Bethel Drive Extension High Point, North Carolina 27260 Best Management Practices Best Management Practices(BMPs)are measures used to prevent or mitigate pollution from any type of activity. BMPs may include processes,procedures, schedules of activity,restrictions on practices, and other management practices to prevent or reduce water pollution_ Baseline BMPs are general common sense practices which are inexpensive,relatively simple and applicable to a wide variety of industries and activities. The facility has implemented the following baseline BMPs with emphasis on management practices that ensure continued vigilance of proper facility operations and a methodology of inspections and oversight that continually reviews the program to facilitate effective pollution prevention. Good Housekeeping Those areas of the facility which may contribute pollutants to stormwater discharges are maintnined in a clean and orderly manner.All employees are trained in basic clean up procedures. Waste media are collected for disposal on a regular basis.The floors of the kiln,stacker building, and treatment area, as well as the ground surfaces are swept/cleaned on a regular basis. Material storage areas are properly maintained and all containers are labeled in accordance with applicable regulatory requirements.This BMP is addressed in more detail in Section 5. Preventative Maintenance Preventative maintenance inspections of facility equipment are conducted on a monthly basis to ensure that all systems are working properly and to identify conditions(e.g. cracks, leaks, and corrosion)which may cause breakdowns or failures. The most important areas for inspection are the aboveground storage tanks.and associated above ground piping_ Defective equipment, found during inspections,is promptly repaired or replaced. The completed"Monthly Maintenance Inspection"forms are maintained on-site in this plan. This BMP is addressed in more detail in Section 5. Visual Inspections In addition to the"Monthly Maintenance Inspections"of plant systems and equipment,outdoor storage areas to include loading/unloading and the storm water drainage system(including the drainage swales and outfalls)are conducted semi annually."Facility Semi-Annual Stormwater Inspection"forms are included in page 58 and copies of the completed forms are also maintained on-site. The goal of these regular semi-annual inspections is to confirm that chosen Best Management Practices for storm water pollution prevention are in place and working properly. n�, This BMP is addressed in more detail in Section 9. Spill Prevention and Response The area with the highest spill potential is the fuel deck which facilitates vehicle fueling. The preventative maintenance/inspection programs outlined above are one of the most important methods for spill prevention. They ensure that faulty equipment and deteriorating storage containers are detected before a leak/release occurs. Good housekeeping practices also reduce the potential for accidental pollutant releases, as it ensures that containers are properly stored and maintained. Employees have also been trained in proper materials handling methods. Finally,in order to prevent spills during loading/uploading,care is taken to ensure that all drums/containers are tightly closed and handled appropriately. Any spills which occur at this facility is documented and records are maintained on-site. This BMP is addressed in more detail in Section 4. Sediment and Erosion Control All undeveloped areas surrounding the plant, including the stormwater drainage swales, are either planted with agricultural crops or grassed to prevent soil erosion. These areas are inspected semi- annually(Facility Semi-Annual Stormwater Inspection)to ensure that erosion is kept at a minimum and grass and/or appropriate vegetation is replanted if bare spots are observed developing. Management of Stormwater Runoff Management of stormwater runoff is accomplished through practices that control and divert stormwater in such a manner that natural filtration of stormwater runoff occurs which reduces the concentration and amount of pollutants in stormwater discharge from the site. This is accomplished through management practices which minimize outside inventory storage of treated lumber,management of areas which provide exposure of other materials and operations, and vigilance as to the healthy integrity of vegetation in and around stormwater swales and outfalls. In this manner,exposure of pollutants is minimized and stormwater runoff can be managed in each of the five stormwater outfalls to reduce flow velocity of the water. Reduction of flow velocity combined with the flow of the water through large areas of vegetation provides the opportunity for pollutants to disperse, dilute, and be naturally captured on site. Employee Training An employee training program is provided to inform personnel at all levels as to their responsibility for assuring that the components and goals.of this SWPPP are upheld and complied with. Employee training addresses each component of the SWPPP, including how and why tasks are to be implemented. This BMP is addresses in detail in Section 6. Recordkeeping and Reporting Recordkeeping and reporting procedures are defined in various sections of this SWPPP and Summarized in Section 9. The inspection, recordkeeping, and reporting program is established to monitor pollution prevention practices,maintain storm water drainage areas,prevent spills and leaks from reaching navigable waters, identify and document needed improvements,and define responsibilities and communications in the event of a related emergency. Activity-Based and Site-Specific Best Management Practice Specific Best Management Practices(BMPs)for industrial activities which may contaminate ,goal, storm water include fueling, storage of treatment materials, outside storage for treated product,and by-products of activities. Other site-specific BMPs consider storm water flow diversion,exposure minimization practices,mitigation practices,and sedimentation and erosion prevention practices. Type of activity s ecific BMP Activity specific BMP employed 1.Tank stored in a bermed area. Fueling 2. Dry sorbent material used to clean-up small spills. 3. Topping off of fuel tanks is discouraged. 1.Liquids and chemicals stored in tanks inside of the treatment building where entire contents are contained by the architectural construction of the building. Treatment material storage 2. Tanker off-load area slanted to capture tanker leaks, spills,and catastrophic events. 3.A mechanical dam/gate has been constructed on Stormwater Outfall#2 as a secondary containment strategy in the event of a catastrophic spill which migrates outside the treatment area. 1. Treated product inventory is minimized. 2. Treated material is dead packed and stacked in such a Outside storage of treated product manner to minimize stormwater contact. 3. Treated material is placed on bolsters thereby avoiding direct contact with the ground and stormwater. 1. Water condensate from drying operations is collected Activity by-products and recycled back into the treatment process. Site-Specific BMPs Activity to mitigate pollution exposure 1. Fuel oil stored in closed tanks. Exposure Minimization Practices 2.Fuel oil storage tanks cleaned as necessary. Mitigation Practices 1. Fueling performed under supervision. Sedimentation and Erosion Prevention 1. Drainage swales are grassed. Practices 2. Sedimentation basin employed BMP Assessment Impacted Area Activity to address assessment Training Liquid Storage Training is part of this SWPPP 1. Swales have been dressed and planted with vegetation. Additionally, rip-rap (stone)has been placed in the swales. All Drainage swales and swale manicuring has been done to assist Stormwater Flow Control property egress in the filtering of the stormwater, control of stormwater flow,and to assist in the prevention of stormwater erosion. Signage added at the fuel deck to remind Signs Liquid Storage Fueling employees of housekeeping and pollution ,••" prevention policies. Fortress Wood Products / -4, 3874 Bethel Drive Extension High Point .. North Carolina 27260 Short Narrative Describing Any Significant Changes at the Permitted Facility There have been no significant changes made at the permitted facility since the last permit was issued. STORMWATER POLLUTION PREVENTION PLAN DEVELOPMENT AND IMPLEMENTATION CERTIFICATION North Carolina Division of Energy, Mineral, and Land Resources---Stormwater Program Facility Name: Fortress wood Products Permit Number: NC5000566 Location Address: 3874 Bethel Dane Extension High PoK North CarD[ha 27260 County: Randolph "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 to permit g tory requirements)and return this Certification. DO NOT SEND STORIVIWATE O UTION PREVENTION PLAN WITH THIS CERTIFICATION. Signature Date —2G• l 3 George M.Dickens,Jr President&CEO,The Lester Group Print or type name of person signing above Title SPPP Certification 10/13