NCS000452_Ramseur Plant Additional Information_20180726

CULPEPER OF RAMSEUR, LLC
RANDOLPH COUNTY
PERMIT # NCS000452
SIGNIFICANT CHANGES
There have been no significant changes to our process or chemicals.
BEST MANAGEMENT PRACTICES
The purpose of the SWPPP is to identify potential sources of pollution or contamination that originate at
this facility, and to select and implement actions which prevent or minimize the release of pollutants
into the storm water. The storm water management controls included in the SWPPP focus on providing
adequate control of pollutant discharges with practical approaches that utilize readily available
techniques, expertise, material and equipment.
The SWPPP is intended to be a flexible, active operations plan to allow incorporation of changes and
management practices. As the plan is implemented and methods to improve the plan are found, or as
regulations change, revisions to the plan must be made. Revisions to the plan must be approved by
management and recorded in all copies of the plan in order to meet the requirements of the storm
water permit.
This is a wood preservation facility. Untreated lumber is brought on site for treatment using a copper
based (micronized) amine formula. All chemicals used in the treatment process are kept inside
containment areas. Waters accumulated inside these containment areas are used back in the process.
All freshly treated lumber is kept under cover, on a RCRA Subpart W drip pad until drippage has ceased.
There are several storage sheds where we store as much of the treated lumber as possible. Any
remaining lumber is kept on the yard until sold.
Forklifts and other vehicles are regularly inspected and maintained by an outside contractor. All
maintenance work is done under cover, if possible. Now work is performed outdoors during a rain
event. Any oil or chemicals used at the maintenance department are kept inside the maintenance
building or under cover. All bulk oil tanks have secondary containment along with drip pans under the
nozzles. Any water accumulated within this containment, if contaminated with oil, is shipped for
recycling or the oil removed prior to releasing.
At this time, based upon a review of our current procedures for reducing or eliminating exposure of
materials to storm water, we have determined that it is not economically feasible to modify our
program. We have our maintenance area inside a building, all oil tanks under cover and in secondary
containment, all chemicals in secondary containment or under cover and numerous sheds to store
treated lumber in. The lumber stored outdoors is dry, stacked to minimize exposure and inventory
controlled to reduce potential exposure to a rain event. Housekeeping procedures are in place to
regularly remove debris in the yard and inspect around our maintenance and treating plant for chemical
contamination.
BEST MANAGEMENT PRACTICES — MEASURES AND CONTROLS
The results of a site assessment indicate that controls are either in place or need to be added to
minimize contaminant releases to storm water runoff. Housekeeping is one area that can be readily
controlled to limit the discharge of wood debris and minimize the generation of dust.

Best Management Practices (BMPs) as well as other controls are used to reduce potential contaminant
releases. Some of our controls areas simple as ensuring that we maintain vegetation, such as grass on
slopes to prevent soil erosion and keeping outfall areas clean and free of debris.
All chemical bulk storage tanks are within secondary containment. None of our secondary containment
structures have any type of drainage system. Only personnel placing a pump into the diesel and
gasoline containment area can remove liquid. This method prevents any release of oil from our
containment system due to rain. Our chemical storage containment areas that are not located inside a
building have automatic pumps that will pick up liquid and place it into a bulk storage tank located
within a containment area. This liquid is then used in our treating processes.
Most hose connections at the tanks for bulk loading or unloading are inside the bulk storage
containment area. Any tank or hose connections outside the contained area have buckets underneath
to catch drips and minor leaks. A qualified employee with access to the proper safety equipment
approves the hook up to our tank prior to unloading and monitors the loading and unloading process.
All non -bulk containers, such as drums, are stored either indoors or within a contained area.
Finished lumber products are stored under sheds or in the yard until shipment. The trucks are loaded
over asphalt areas. Prior to storing any treated lumber outdoors, verification that there is no drippage
has been documented (see drip pad logs).
The drip pad is under roof and bermed/sloped to prevent any release. Any liquid generated from
drippage or a rain event flows to a sump and then is automatically picked up and place into an effluent
tank. Visual, as well as some documented Inspections are regularly performed on the drip pad and
maintenance, such as sealing or cracks and coating replacement, is performed as needed.
All cutting of lumber on site is performed under roof. The sawdust and particles are then loaded into a
drum or onto the dump truck. The truck is kept under roof unless loading.
Various types of equipment associated with this wood preserving facility include but are not limited to
pressure retorts, mechanical pumps, fueling trucks, maintenance equipment, freight transfer vehicles,
construction equipment and fork lifts.
Trucks, trailers, and forklifts are cleaned in an enclosed, roofed area designed for this purpose. The
water is reclaimed through an oil water separator.
It is recognized that maintenance of vehicles can be a significant source of storm water pollutants.
Materials associated with vehicle maintenance include waste oil, solvents and other degreasers, brake
fluid, anti -freeze, battery acids, radiator flush, and sludge. The following vehicle maintenance practices
are utilized:
Maintenance is completed in an enclosed area protected from runoff and precipitation
whenever possible. If maintenance has to be performed outside of the enclosed area, all
possible means are used to prevent spillage and approved cleaning methods (oil dry, etc)
are used if any spillage occurs.
All used products are properly stored until they are sent for recycling or disposal.
Batteries, used tired, and used solvents are collected and recycled through the appropriate
vendors (Typically batteries are recycled immediately, so there is minimal to no storage).

A feasibility review to determine if there is a way to modify or change our operating procedures or
install controls to further reduce chemical exposure indicates the following:
o Bulk Chemical containment (Including Diesel) — All bulk chemicals are currently stored in
secondary containment systems and some are under roof. We do not have any secondary
containment systems that can release without manual pumping.
o Non -bulk chemical containment— All non -bulk chemicals are currently stored in secondary
containment areas or under roof.
o Particulate containment— Generation of sawdust is currently performed under roof in the saw
area. There is a general cleanup performed after the cutting is complete.
o Diesel/Gasoline storage —The diesel/gasoline tanks used to fuel the lifts and trucks are located
within a secondary containment system that cannot release without manual pumping. Filling
the tank and fueling procedures are performed just outside the containment area, but under
roof. Maintenance personnel or supervisors are the only employees that fuel the lifts.
o Treated wood storage — Treated lumber is stored in sheds or outdoors. Prior to placing the
treated lumber outdoors, the material is documented that all drippage has ceased. This
procedure should ensure that there is minimal release of chemicals during a rain event from the
treated lumber. The lumber is also not placed directly on the ground, but stored 2-6" above to
prevent contact.
o Chemical unloading — Chemical unloading is performed on paved areas. Most hose connections
at the tanks for bulk loading or unloading are inside the bulk storage containment area. Any
tank or hose connections outside the contained area have buckets underneath to catch drips
and minor leaks. A qualified employee with access to the proper safety equipment approves the
hook up to our tank prior to unloading and monitors the loading and unloading process. In the
future, as monies permit, we will review the installation of containment areas for the bulk
chemical trucks to be located during unloading.
To ensure that the BMPs and other controls are in use and working, employees are taught about
controls in use and periodic inspections are performed.
The measures currently in use or to be implemented at our facility to control contaminant releases are
found under section 4.a.

STRUCTURAL WOOD
S = Stacker F = Fuel Storage P = Propane
K = Kiln
Untreated and treated lumber is handled
throughout the yard area P
h
Hazardous Waste is stored at Treating Plant -
Oils stored at Maintenance Shop
K
OUTFALL LOCATION FLOW':;
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35.658776 N 79.617483 W
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mg/I
Oct -09
BDL
100
BDL
0.007
12
120
BDL
30
5.62
Mar -10
14
100
0.007
BDL
120
6.5
30
5.30
Sep -10
BDL
100
0.0020
0.007
BDL
120
BDL
30
7.56
Mar -11
1.4
100
0.0025
0.007
BDL
120
2.2
30
5.49
Dec -11
BDL
100
BDL
0.007
BDL
120
BDL
30
5.84
Apr -12
3.9
100
0.0028
0.007
BDL
120
BDL
30
5.67
Nov -12
28
100
0.0085
0.007
51
120
8.4
30
5.85
May -13
3.7
100
BDL
0.007
BDL
120
BDL
30
6.95
Oct -13
BDL
100
BDL
0.007
BDL
120
BDL
30
6.75
Mar -14
1
100
BDL
0.007
BDL
120
BDL
30
5.67
Nov -14
BDL
100
BDL
0.007
BDL
120
BDL
30
3.80
16
Mar -15
1.4
100
BDL
0.007
BDL
120
BDL
1 30
4.17
jBDL
Oct -15
1.7
100
BDL
0.007
BDL
120
BDL
30
5.70
BDL
May -16
BDL
100
BDL
0.007
BDL
120
BDL
30
4.62
19
Sep -16
BDL
100
BDL
0.007
BDL
120
BDL
30
4.63
BDL
Apr -17
1.2
100
BDL
0.007
11
120
BDL
30
5.43
BDL
Nov -17
11
100
BDL
0.007
21
120
3.1
30
5.97

4.a. Effective Pollutant Control Options for Timber Product Facilities
Activity
Associated BMPs
In Use
Remarks
Log, Lumber, and
Divert Storm water around storage areas with ditches, swales
X
other Wood
and/or berms
Product Storage
Areas
Locate storage areas on stable, well -drained soils with slope of
X
(Untreated)
2-5 percent
Line storage areas with crushed rock, gravel or porous
X
pavement to promote infiltration, minimize discharge and
provide sediment and erosion control
Stack materials to minimize surface area of materials exposed
X
to precipitation
Frequent removal of debris
X
Use of silt fence and rip rap check dams in drainage ways
X
Activity
Associated BMPs
In Use
Remarks
Residue Storage
Divert Storm water around storage areas with ditches, swales
X
Areas
and/or berms
(such as
Locate storage residues away from drainage pathways and
X
untreated
surface waters
sawdust, chips)
Avoid contamination of residues with oil, solvents, chemically
X
treated wood, trash, etc.
Assemble piles to minimize surface area of materials exposed
X
to precipitation
Limit storage time of residues to prevent degradation and
X
generation of leachates
Cover and/or enclose stored residues to prevent contact with
X
precipitation using silos, van trailers, sheds, roofs, buildings or
tarps
Limit slopes of storage areas to minimize velocities of runoff
X
which may transport residues
Activity
Associated BMPs
In Use
Remarks
Loading and
Provide diversion berms and dikes to limit runon
X
Unloading,
Material
Cover loading and unloading areas (chemicals, diesel, gasoline,
X
Only small gas
Handling Areas
etc)
and diesel tanks
Enclose material handling systems for wood wastes
X
Cover materials entering and leaving areas
X

Provide good housekeeping measures to limit debris and to
X
provide dust control
Provide paved areas to enable easy collection of spilled
X
materials
Activity
Associated BMPs
In Use
Remarks
Wood
Extend drip time on drip pad (process area) before moving to
X
Preservation
storage
Activities
Pave and berm areas used by equipment that has come in
X
contact with treatment chemicals
Locate treatment chemical loading and unloading areas away
X
from high traffic areas where tracking of the chemical may
occur.
Provide frequent visual inspections of loading and unloading
X
areas during and after activities occur to identify any spills or
leaks needing clean-up
Cover and/or enclose treatment areas
X
Cover storage areas to prevent contact of treated wood
X
Partially done with
products with precipitation
sheds available
Elevate stored, treated wood products to prevent contact with
X
runon/runoff
Activity
Associated BMPs
In Use
Remarks
Chemical
Provide secondary containment around chemical storage areas
X
Storage Areas
Provide level gages
X
Inventory fluids to identify leakage
X
Locate storage areas away from high traffic areas and surface waters
X
Cover and/or enclose chemical storage areas
X
Provide containment to allow for recycling of spill and leaks
X
Activity
Associated BMPs
In Use
Remarks
Equipment
Provide diversion berms and dikes to limit run on
X
and/or vehicle
Preventative maintenance program (cleaning oil/water separators,
X
maintenance
catch basins, vehicle mounted drip containment devices)
and cleaning
Minimizing storm water runon and runoff at fueling areas.
X
Perform all maintenance activities indoors
X
Cover and/or enclose chemical storage areas (used oil, oil filters,
X
used solvents, etc.)

Locate storage areas away from high traffic areas
X
Provide containment to allow for recycling of spill and leaks
X
Oil/water separator used on water from cleaning equipment
X
Activity
Associated BMPs
In Use
Remarks
Erosion and
Sediment
Grassed areas to prevent soil erosion
X
Controls
Shubbery/brush/tree areas to prevent soil erosion
X
Use of vegetation on sloped areas to prevent sediment run-off
X
Use of earth dikes, etc. to prevent water run on to your
property
X
Sediment Trap (Such as rock, vegetation, etc.)
X

CULPEPER OF RAMSEUR, LLC
RAMSEUR, NC
PERMIT # NCS000452
INDUSTRIAL ACTIVITY SIGNIFICANT CHANGES
This facility is still operating with no significant changes from the previous
permit application. They are still using the same wood preservative and have
not added any new equipment.