NCS000566_Additional information_20240109

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Environmental Solutions and Strategi 5;14It 4
P. 0. Box 4244 fivraterProara,,
Martinsville Virginia 24115
January 5, 2024
Certified Mail—Return Receipt Requested
70210350 0000 97201889
Ms. Brianna Young
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 NCS 000566
Dear Ms. Young,
As you may recall, Fortress Wood Products LLC, located at 3874 Bethel Drive Extension,
High Point, North Carolina, 27260,filed for a rescission of NPDES Permit Number NCS000566 on
October 14, 2023. An inspector from the Winston Salem Regional office, Mr. Robby Deans, visited
the facility site and after a thorough inspection, filed a report, although denying the rescission of
the permit,two items were nevertheless of particular interest.
In an email sent to me on November 9, 2023, a copy attached for your convenience, he
stated "The current sampling location is incorrect, the outfall should be where water exits the
(retention)pond. We agree with Mr. Deans, as the current sampling location is where the water
enters the retention pond and not exits. We would like to change the current sampling location to
the location proposed by Mr. Deans. The new sampling location would have a Latitude and a
Longitude of 35°91' 44.6" N, -80 °04' S5.6" W.
Secondly, Mr. Deans initial "back of the napkin" calculations indicated that the retention
pond did not appear to be large enough to meet the North Carolina requirement to be able to
capture a 24 hour, 25 year storm event, which, in part, disqualified the rescission. Currently,
Fortress Wood Products, LLC is trying to locate the original grading company and subsequent
drawings which would have been provided to the original owners of the property, to determine
the precise amount of water the large retention pond was constructed to hold, in order to see if
the facility qualifies for permit rescission based on the ability to capture the 24 hour, 25 year
storm event as mentioned by Mr. Deans.
Should you have any questions, concerns, or comments, with the aforementioned or
require additional information to process the request to relocate the facility's sampling outfall

Page -2-
Certified Mail—Return Receipt Requested
70210350 0000 97201889
Ms. Brianna Young
Industrial Individual Permits Coordinator
DEMLR Storm Water Permitting Program
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
as requested herein, please contact me by telephone at [phone], by e-mail at
[e-mail], or by facsimile at [phone].
Again, thank you for your help and assistance in these matters.
rrcere4y.
P. 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

Ir
Zach Crews<[e-mail]> 11/30/2023 9:54 AM
Fwd: Fortress Wood Products
To DAVID P MADDOX<[e-mail]>
From: DAVID P MADDOX<[e-mail]>
Sent:Thursday, November 9,2023 3:33:01 PM
To: Deans, Robby<[e-mail]>
Subject:Re: Fortress Wood Products
Robby,
First of all, let me sincerely thank you for taking the time to visit the property and engaging in
the multiple conversations which we had while you were there. Your insights and perspectives
were most helpful and valuable.
Additionally, thanks for taking the time to expedite your inspection report and the information
provided below. I will take this information to Fortress Wood and we will review it thoroughly
along with the information we are trying to locate relevant to the original grading/construction
of the property.
I am sure we will be in contact with you as soon as were are able to answer the questions
which remain.
Again, it was a pleasure meeting you and I look forward to working with you to provide some
kind of closure to the issue(s) at hand.
Enjoy your day off tomorrow and thanks for the remembrance.
Dave
ES2
Environmental Solutions and Strategies, LLC
P. 4. Box 4244
Martinsville, Virginia 24115
276-806-0178 (telephone)
276-632-6137 (fax)
[e-mail]
On 11/09/2023 10:42 AM PST Deans, Robby<robbydeans@dtc roc gov>wrote:
Hi Dave,
I have attached an inspection report and an explanatory image based on yesterday's meeting. In the image,
the green area represents the places I was able to see, and anything outside that is inferred.

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I do have a few answers to some of the questions that were raised during our inspection:
1.The current sampling location is incorrect;the outfall should be where water exits the pond.
2. Regarding the ability to certify and submit eDMR data,those with eDMR access should be able to log
onto eDMR to see which personnel have access to the permit and who has permission to view only vs.
certify and submit data. I don't seem to have eDMR access,so I cannot confirm this or explain further.
3.The dry streambed would very likely count as a"surface water"or wetland connected to a surface water.
4.We still do grant rescissions if stormwater is collected in a pond large enough to capture the rainfall from
a 24-hr,25-year storm. I was able to find the info on the NOAA website for calculating this here:
ht-tps://hdsc.nws.noaa.gov/pfds/. The relevant rainfall amount for the Fortress site is 5.85 inches.
Based on my cursory calculations,the pond would currently not be large enough to capture this amount of
rainfall, but it likely would be if the riser was plugged. I did not receive any guidance on whether permittees can
alter basins for the purpose of rescission, but I fail to see how it would be a problem as long as the basin is
maintained. - --- - - - -- - - - -
My back of the napkin calculations:
Watershed of pond(asphalt wood storage area):240,000 square feet
25-year storm rain total:5.85 inches/12 inches per foot=0.488 feet
Total volume of rain =240,000 square feet*0.488 feet= 117,000 cubic feet of water
Current basin dimensions: 19,000 square feet*4 foot riser=76,000 cubic feet
If riser was sealed: 19,000 square feet*7 foot freeboard= 133,000 cubic feet
Again,these calculations are very rough estimates. If you are able to find any of the design specifications for
the basin,that would be very helpful. Sill, I think that if the riser was plugged,the basin would likely be large
enough. And in any case,the proper sampling location is the basin outlet,which should greatly reduce sample
processing costs even if the permit is not rescinded.
Let me know if you have any questions or concerns, and what the plan might be going forward.
Have a good weekend,and happy Veteran's Day!
Robby Deans
Environmental Specialist
Land Quality Section,Winston-Salem Regional Office
Division of Energy, Mineral and Land Resources
North Carolina Department of Environmental Quality
[phone] office [phone] direct
[e-mail]
450 West Hanes Mill Road, Suite 300
Winston-Salem, NC 27105-7407