NCS000222_HISTORICAL WITH APPLICATION_20180910

STORMWATER DIVISION CODING SHEET
PERMIT NO. /\j CSppO
DOC TYPE
FINAL PERMIT
j. MONITORING INFO
?� APPLICATION
❑ COMPLIANCE
❑ OTHER
DOC DATE n D-D1$ Uq I U
j YYYYMMDD

Bennett, Bradley
From:
Sent:
To:
Cc:
Subject:
Bradley,
House, Sarah J <[e-mail]>
Monday, September 10, 2018 10:22 AM
Bennett, Bradley
Rouse, Michael T
RE: [External] Carolina Pole Leland (Leland Land), Permit #NCS000222 Draft SW Permit
I believe we can all work with that. Thanks so much.
Sarah "Jane" House
Safety, Health & Environmental
Koppers Utility and Industrial Products
P O Box 130 1 North. SC 29112 1 United States
M 803-664-4014
HouseSJ(&koppers corn
KOPPERS
Responsible Care I A member of the American Chemistry Council
Learn more about Koppers: http I/i koppers corn
0
4011,11 S
„^ ►
CP
411
The Conlent5 of thi$ 0-map[ are intended for the use of the intentletl addressei only and may be oonfitlenlial H you are not an intended addressee. note that any disUos;.ae copying. JsSUii M uSS
of INS a -mail n*SS&ge or the Contents nereof is prohibited
From: Bennett, Bradley <[e-mail]>
Sent: Monday, September 10, 2018 9:04 AM
To: House, Sarah J <[e-mail]>
Subject: RE: [External] Carolina Pole Leland (Leland Land), Permit #NCS000222 Draft SW Permit
WARNING: External Sender
Hi Sarah,
I know with the storm headed our way you guys are busy and probably aren't thinking too much about this permit, but I
did want to get back with you an your comments. I have included responses in your email below in blue text. Take a
look at these and let me know your thoughts.
Thanks
::
From: House, Sarah J <[e-mail]>
Sent: Tuesday, August 21, 2018 8:44 AM
To: Bennett, Bradley <bradley. ben [e-mail]>
1

Cc: Rouse, Michael T <[e-mail]>
Subject: RE: [External] Carolina Pole Leland (Leland Land), Permit #NCS000222 Draft SW Permit
Thank you.
Sarah "Jane" House
Safety, Heafth & Environmental
Koppers Utility and Industrial Products
P O Box 130 1 North, SC 291121 United States
M 803-664-4014
HouseSJ(dkoppers. com
KOPPERS
Responsible Care I A member of the American Chemistry Council
Learn more about Koppers: http Ilwww koppers com
The contents of this e-mail are intended for the use of the intended addresseetC only and may be confidential If you are not an intended addressee note that any disclosure. cepyng distnbut�on or use
of this e-mail message of the contents hereof rs prohibited
From: Bennett, Bradley <[e-mail]>
Sent: Tuesday, August 21, 2018 7:18 AM
To: House, Sarah J <[e-mail]>
Cc: Rouse, Michael T <[e-mail]>
Subject: RE: [External] Carolina Pale Leland (Leland Land), Permit #NCS000222 Draft SW Permit
WARNING: External Sender
Email is fine. I'll look at the comments and talk with our regional staff. We will be back with you on this soon.
Thanks
::
From: House, Sarah J [mailto:[e-mail]]
Sent: Monday, August 20, 2018 6:37 PM
To: Bennett, Bradley <[e-mail]>
Cc: Rouse, Michael T <[e-mail]>
Subject: [External] Carolina Pole Leland (Leland Land), Permit #NCS000222 Draft SW Permit
Bradley,
Please see my comments concerning the draft permit you sent. I hope it is ok to do this by email.
• Section 2(a) — Feasibility Study — When we talked by phone I understood that you wanted this feasibility study
to be completed on the Dioxin. The section under the permit is "generic".

jr
I think we can address your concern by including language under either Part II E. Special Conditions or Part III
A. Compliance and Liability that outlines a requirement to develop a feasibility study for dioxin with 18
months of the effective date of the permit.
• Tier One, Tier two, Tier Three Requirements — I know this is an addition that was placed in your "General"
permits for benchmark exceedances. Not that I have a particular problem with it except for:
o We have already discussed the fact that very few rainfalls generate a discharge.
o The Dioxin benchmark is "any", which leaves us with no room for improvement
o This gives us no time in which to complete a good feasibility study on dioxin and see if there is a way to
reduce this without the potential for going into monthly sampling, which will result in excess costs (The
cost for one dioxin sample is at $625. That does not include any other constituents. We currently pay
around $1,300 per sampling event), and a lot of "No Discharge" DMRs submitted
I would propose that we address this issue by just removing the benchmark value for Dioxin, It will be
monitoring only for this permit cycle. Other benchmarks will remain in the permit as would
the tier system.
Since this permit is only for 3 years, it would work better if the "Tier section" could be removed so we can spend our
time and monies on performing a good feasibility study, which is going to take a minimum of one year to 18 months to
complete and cost an estimated $15,000, which does not include any BMP modifications. Once this has been completed
and any modifications put in place to reduce the dioxin level in our storm water, everyone will know what level we can
reach and the new permit can beset up properly. We would be happy for you to request that our feasibility study be
submitted to you for review.
If you have any questions or require more information, please let me know. I appreciate all of the time you have put
into this and hope we can work together to improve this site's storm water, Thanks so much.
Sarah "Jane" House
Safety. Health $ Environmental
Koppers Utility and Industrial Products
P.O Box 130 1 North. SC 29112 1 United States
M 803-664-4014
HouseSJAkoj2pers com
KOPPERS
Responsible Care I A member of the American Chemistry Council
Learn more about Koppers: http://www koppers com
The contents of this e-mail are intended for the use of the intended addressee($) only and may be confidential "you are not an intended addressee, note that any disUosure, copying. distnbuuon or use
Of this e-mail message or the contents hereof is prohibited

Last Updated — 9117118
NC Division of Energy, Mineral and Land Resources
Review of Permit Renewal — NC5000222
Leland Land, LLC —Carolina Pole Leland, Inc.
SIC 2491— Wood Preserving — facility manufactures wooden poles and pole cross -arms.
Monitoring —The facility has been monitoring for Ar, Cu, Cr, Pentachlorophenol(PCP), Phenol, Zn, Benzene, Toluene,
Napthalene, Anthracene, NH3, Total Xylenes, Oil and Grease, BOD, TSS, COD, TP, TKN, Dioxin and pH. Previous
permit did not have tier system.
— Data reviewed from 2008 — 2010 and 2013 - 2017.
— Cu, COD, PCP and Dioxin had multiple numbers over the benchmark during the permit cycle. These
parameters are related to materials or processes on site so maintain in this permit.
— TSS was only exceeded ones, but this is a base parameter that should be maintained in the permit. pH is
also a base parameter that should be maintained to help gauge any problem areas.
— Ar and Cr did not have benchmark exceedances but given materials used at this facility these parameters
should remain in the permit to assess any potential problems associated with the process. Did talk with
staff in wastewater about possible hexavalent chromium issues but they indicated their reviews showed
that with numbers off 11 or below there is no issue. All of the Cr numbers for this facility are less than0.10.
— Dioxin results continue to show detection in the monitoring results. In discussions with DWR standards
staff the results show levels that are well above the instream water quality standard. This is based on the
WQ5 for 2,3,7,8-TCDD. Discussions with Chris Ventaloro and Connie Brower provided information on the
process to assess the "equivalent toxicity" of the various dioxin compounds compared to 2,3,7,8-TCDD.
Review of information about the materials used on site for wood treatment indicate that dioxin may be in
the material used (PCP) or produced with some of the treatment activities (heating of PCP). It is also
possible that this is a result of historical dioxin due to past activities at the site. This facility is under a
brownfields agreement and our permit has dioxin monitoring at the request of DWM staff at the last permit
renewal (2007). Had discussions with Sam Watson — DWM WIRO about the facility and sent draft permit for
their review (3/26). Phone call with Sam (4/17) no major issues with the draft, discussed the process with
our permit and he checked their results with soil testing for dioxin. Their monitoring results have been
meeting the targets. He noted that there wasn't much interaction with the facility, they send a report every
five years. He advised to talk with Sandy Mort in CO. Email to Sandy 4/23 and also left voicemail a few
weeks later. No response.
Need to address dioxin numbers in the permit with more than just monitoring (see notes below from 7/18
call with the facility staff). Propose to require site to follow the feasibility study requirements in the SPPP to
look at alternatives that would address the dioxin numbers including monitoring along the ditch and
assessing BMPs to install, etc. Language added in the cover letter for the draft. Also add in tier 3 the ability
for the Division to require additional monitoring in the form on instream fish tissue monitoring.
— Benzene, Toluene, Xylene —These parameters have not been shown as an issue, but the permit will
maintain monitoring for one year due to material use onsite_ The facility does apparently utilize diesel fuel
as a component in the treatment process and they have solvent use that may include some of these
components.
— Other parameters —Zn, BOD, oil and grease, TP, Phenols, NH3, anthracene, naphthalene and TKN have been
below benchmarks and are proposed to be removed.
— Parameters remaining in the permit — TSS, COD, pH, Ar, Cu, Cr, PCP, Dioxin —annually and Benzene,
Toluene, and Xylene — annually during one year only.
— Tier structure added to the permit and adjusted to have the three levels as in current permits.
— Parameter codes added to permit.
Discussion with Facility Contacts —
2/14/2018 — Conference call with Jane House — facility does have a new kiln, new boiler and a new saw location but
processes and materials used are the same. She indicated that there were no other activities — no log wetting on

site but they did use a minimal amount of spray at tog cutting but not all year. One question she had was why they
had dioxin monitoring and other facilities didn't. Discussed adding tier system and they were familiar with this.
2/23 and 3/28 — emails from Jane providing more information on process, parameters and monitoring methods/lab
results.
7/16 — call with lane and Mike Rouse — main discussion was on the issue of the dioxin levels in their sampling results.
They indicated this could be coming from a number of different sources. Again mentioned that other facilities were
not monitoring for dioxion. Noted that we understood this but that their results were thousands of times higher
than the instream water quality standard so we needed to address the issue at their site. They indicated they
worked to keep the ditch clean regularly so they had some troubie maintaining vegetation but they could add check
dams. They proposed sampling at various areas around the ditch to try nd target protential problem areas. They
will see if lab can do this, they want a third party to sample. Mentioned need to do a feasibility study as noted in the
permit for alternatives to address the dioxin issue. Cover letter to note this.
• Receiving Stream — the previous permit indicated drainage to Alligator Branch and Sturgeon Creek, but it appears
that the facility all flows to Sturgeon Creek. The facility indicates that there is only one outfaii point from a ditch the
surrounds the site. From the site map it appears that this outfall point drains to Sturgeon Creek. Sturgeon Creek -
18-77-1 is a C, SW stream in the Cape Fear River Basin. Facility drains to Stewart Creek in the Catawba River Basin, a
class C stream. 2016 Integrated Report 18-77-1 shows no impairment of concern for this facility in this area.
• NC National Heritage review — NHP report shows no aquatic resources of concern in the project area. In a one mile
area around the site there are a few species noted in the report, eastern chicken turtle and northern pinesnake.
But, these occurrences are Listed as old and not found in recent surveys. In addition, the project site does not
appear to be draining to the areas of these occurrences.
• WiRO — Brian Lambe conducted a site visit on 7/10/2018. Inspection report shows the facility in compliance and
notes ditch around site, regular maintenance, etc. Brian noted in email the dioxin numbers. Talked with Brian on
7/18 about call with lane and Mike. He was okay with the feasibility study and monitoring the ditch. Brian had
mentioned more monitoring along the ditch at the site visit. Draft permit to permrttee, Regional Office on July 23,
2018. Permit to public notice July 27, 2018 — Wilmington Star News.
• Comments and Response — The permitee provided comments on the draft permit through an email on August 20,
2018. Two major issues were raised:
The permitee was concerned that the feasibility study requirements of the permit were too generic and
applied to all parameters rather than just dioxin. They wanted to focus their time and resources on dioxin.
To address this concern the final permit includes a new paragraph in Part II E. Special Conditions that
specifies the study for dioxin discharges.
The permitee expressed concerns for the benchmark of "any" for dioxin during their study time. They felt
this gave no room for improvement and would result in monthly monitoring that would take resources
away from their efforts to complete the study and put BMPs in place. They requested removal of the tier
system in the permit. To address these concerns the permit was modified to remove the benchmark for
dioxin and make it a monitoring only parameter during this cycle. The tier system remains in the permit
and all other parameters maintain the benchmark values and tier requirements if exceeded.

AFFIDAVIT OF PUBLICATION
STATE OF NORTH CAROLINA
COUNTY OF NEW HANOVER
NC DIV- OF ENERGY. MINERAL AND
LANs) RESOURCES'
INTENT TO ISSUE A N d id th f
Beore e undersigned, a Notary Public oaount
570RMWATER DISCHARGE PERMIT �' f)` f Said County and State,
Public comment or objection to the
draft permit Is Invsted. Submit
written comments to DEMLR at the Jarimy Springer
address below. All comments
received through August 26, 2018
will be considered In the final
determination regarding permit Who, being duly sworn or affirmed, according to the law, says that he/she is
issuance and permit provssmrns.
A9p0pticaftn: Carolina Pole,
Inc.,
ent Rd NE,
Leland, NCC 28451a hhaass oppUed for Accounting Specialist
an NPDES permit renewal
to
discharge stormwater from
an
industrial facility at this address in
of THE STAR -NEWS, a corporation organized and doing business under the Laws of the State of
Brunswick
aTeS to Sturg n CCrreek in the
Cape Fear River Basin.
North Carolina, and publishing a newspaper known as STAR -NEWS in the City of Wilmington
Permit
NCSs ormdwat2er Program Contact:
NC DI a . OF ENERGY} MINERAL AND LAND RESOURCES INTENT TO ISSUE A
Bradley Bennett
I919) 07-36a6
R Public comment or objection to the drat permit is
STORMWATEDISCHARGE PERMIT Pblit b 1
bradley_bennettoncdenr.gov
invited Submit written comments to DEMLR at the address below. All comments received
A copy of the draft permit is
available at: https,f/btt.ty/2fSfSls.
through Aut!►ust 26, 2018 wi
Additional permit documents are
available for the reproduction cost
at:
DEMLR Stormwater Program
512 N. Salisbury Street
1612 Mail Service Center
Raleigh, NC 27699-1612
was inserted in the aforesaid newspaper in space, and on dates as follows:
7127 Ix
And at the time of such publication Star -News was a newspaper meeting all the requirements and
qualifications prescribed by Sec. No. 1-597 G.S. of N.C.
Title: Accounting Specialist
Swa or affirmed to, and subscribed before me this —blday of
de
A.D.,Q
Testimony Whereof, 1 have hereunto set my hand an affixed my official seal. the day and
TNAZ MATURANA
�Dm
New Hanover County t Notary Public
M,v ComM1s_icn EXQires Dec 14 2022
c 4 _ day ofOeA 20�2
Upon reading the aforegoing affidavit with the advertisement thereto annexed it is adjudged by the Court that the said
publication was duly and properly made and that the summons has been duly and legally served on the defendant(s).
This day of
RECEIVED Clerk of Superior Court
MAIL TO:
AUG 0 7 2018
DENR-LAND QUALITY
STQRMWATER FERNIII-I ING

e _%k
ROY UOOPER
N-11CIIALL S. RFGAN
%V 11.1.1ANA 1-.. l 1'0BY1 VINS0N..1R.
Encryy, Mineral
and Land Resources
=f,y igi]r1Mf ry7Fl Ali �l lrti
July 23, 2018
Ms. Jane House
Leland Land LLC - Carolina Pole Leland, Inc.
PO Box 1124
Orangeburg, SC 24116-1124
Subject: Draft NPDES Stormwater Permit
Permit No. NCS000222
Leland Land LLC -- Carolina Pole Leland, Inc.
Brunswick County
Dear Ms. House:
Enclosed with this letter is a copy of the draft stormwater permit for your facility. Please review
the draft carefully to ensure thorough understanding of the conditions and requirements it
contains.
The draft permit contains the following significant changes from the facility's current permit:
1. You are required to collect analytical and qualitative monitoring samples during
"measurable storm events" as defined in Part II, Section B. This term is different from the
"representative storm event" in earlier permits.
2. Requirements for the Stormwater Pollution Plan (SPPP) have been updated in Part 11,
Section A.
3. Monitoring requirements in the draft permit have changed slightly. Monitoring is
required semi-annually for COD, TSS, pH, Ar, Cr, Cu, PCP and Dioxin. We feel that these
parameters remain base parameters in assessing potential issues at your facility. In
addition, the draft permit requires monitoring for benzene, toluene, and xylene just during
one year of the permit term. After review of monitoring data from the past 10 years the
results for the other parameters (zinc, BOD, TP, NH3, phenols, anthracene, naphthalene,
ethylbenzene and TKN) have remained well below benchmark levels and it does not
appear that your operations have potential sources of those parameters. The draft permit
proposes to remove these parameters. Comments from our regional staff or other
State orNwh Carolina I Ervirontnemal Qualls Flwn". Mineral and Land Resowccs
1612 Mail Senice Center 1 512 North SalisbLay SU W I Raleigh NC 27699.1612
919 707 9200 T

0' - 1
NCS000222 Draft Permit
Page 2
information may result in maintaining these if it is apparent that your activities in some
way have the potential to release these pollutants.
Stormwater benchmarks remain in the permit as before. Keep in mind that benchmarks
are not permit limits, but rather guidelines for implementing the Stormwater Pollution
Prevention Plan (SPPP). A benchmark exceedance is not a permit violation; however, the
permittee must respond to exceedances. The draft permit has added a tiered response
process for benchmark exceedances consistent with other permits in our program. Please
become familiar with the tiered process as proper response under the tiers may be
enforceable items under your permit. Response to the tiered process may include review
of onsite conditions, installation of BMPs or requirements for more frequent monitoring.
In a conference call on July 18, 2018 we discussed concerns with the consistent
benchmark exceedances for dioxin. As discussed, under the renewed permit you will be
required to specifically respond under the Feasibility Study component [Part II Section A.
2.(a)] to look at technical approaches to address these pollutant discharges. These efforts
should include additional monitoring within the ditch system to assess problem areas,
along with assessment and implementation of BMPs for improved management. Please
note that the tier system added to this permit will also require specific responses to
continued exceedance of benchmarks.
4. Vehicle maintenance (Tables 4 & 5) monitoring parameters have been revised. Non -Polar
Oil & Grease [EPA Method 1664 (SGT-HEM)] replaces Oil & Grease/TPH. The benchmark
for Non -polar Oil & Grease using this method is 15 mg/L. This requirement appears in all
individual stormwater permits; however, it only applies to facilities that perform onsite
vehicle maintenance activities. If the facility begins vehicle maintenance during the permit
cycle, the requirements shall apply. Also, pH monitoring is no longer required for
discharges only associated with vehicle maintenance activities.
The vehicle maintenance language in the permit has also been modified to clarify that
these activities include not just vehicles, but also other similar equipment maintenance
activities that may be exposed to stormwater. This has always been the Division's
implementation of this requirement, but hopefully the adjusted language is a little clearer
about this process.
5. Language has been added under Part II Section D to address potential responses to
qualitative monitoring issues.
6. A new section on Special Conditions has been added in Part II, Section E to comply with
federal regulations requiring electronic submittal of discharge monitoring reports. Our
electronic submittal process is not available for use at this time, but we will continue to
provide feedback on when this process will be available.
7. Civil and administrative penalty amounts have been updated to reflect current federal
law in Part III, Section A, 2(b) and (g).
8. The definition of Bulk Storage of Liquid Materials was revised in Part IV Definitions to
omit the language "located in close proximity to each other" as it applies to multiple
above ground storage containers having a combined storage of 1,320 gallons.

t -'t
NCS000222 Draft Permit
Page 2
9. To address workload issues in the Stormwater Program we are working to have similar
numbers of individual permits for renewal over each of the next five years. In order to
accomplish this some of our permit renewals will be issued for time periods shorter than
the usual five year cycle. Your permit renewal is proposed to expire in 2021.
Please review the draft permit and submit any comments to me no later than 30 days following
your receipt of the draft. Comments may be emailed to me at brad [e-mail] or
mailed to my attention at INC DEMLR, Stormwater Permitting Program, 1612 Mail Service Center,
Raleigh, NC 27699-1612. With this notification the Division will solicit comment on this draft by
publishing a notice in a local newspaper. Following the 30 day public comment period, the
Division will review comments and take appropriate action prior to issuance of the final permit.
If you have any questions, please email me or call me at [phone].
Sincerely,
Bradley Bennett
Stormwater Permitting Program
Attachment: Draft Permit NCS00022
cc: Dan Sams, DEMLR Wilmington Regional Office — via email
Stormwater Permitting Program Files

100_

V
North Carolina Department of Natural and Cultural Resources
Natural Heritage Program
Govemor Roy Cooper Secretary Susi H Hamilton
May 17. 2018
Bradley Bennett
NCDEQ
512 N. Salisbury Street
Raieigh. NC 27604
RE: Carolina Pole Leland Inc.; NCS000222
Dear Bradley Bennett:
NCNHDE-6069
The North Carolina Natural Heritage Program (NCNHP) appreciates the opportunity to provide information
about natural heritage resources for the project referenced above.
Based on the project area mapped with your request, a query of the NCNHP database, indicates that there are
no records for rare species, important natural communities, natural areas. and/or conservation/managed areas
within the proposed project boundary. Please note that although there may be no documentation of natural
heritage elements within the project boundary, it does not imply or confirm their absence; the area may not have
been surveyed. The results of this query should not be substituted for field surveys where suitable habitat exists
In the event that rare species are found within the project area, please contact the NCNHP so that we may
update our records.
The attached 'Potential Occurrences' table summarizes rare species and natural communities that have been
documented within a one -mile radius of the property boundary. The proximity of these records suggests that
these natural heritage elements may potentially be present in the project area if suitable habitat exists. Tables of
natural areas and cons ervationlmanaged areas within a one -mile radius of the project area, if any, are also
included in this report.
If a Federally -listed species is found within the project area or is indicated within a one -mile radius of the project
area, the NCNHP recommends contacting the US Fish and Wildlife Service (USFWS) for guidance. Contact
information for USFWS offices in North Carolina is found here:
https //www.fws.gov/offices/Direg! r /List a .cfm7 t t ode-�7.
Please note that natural heritage element data are maintained for the purposes of conservation planning, project
review, and scientific research, and are not intended for use as the primary criteria for regulatory decisions.
Information provided by the NCNHP database may not be published without prior written notification to the
NCNHP, and the NCNHP must be credited as an information source in these publications. Maps of NCNHP
data may not be redistributed without permission.
The NC Natural Heritage Program may follow this letter with additional correspondence if a Dedicated Nature
Preserve, Registered Heritage Area, Clean Water Management Trust Fund easement, or Federally -listed
species are documented near the project area.
If you have questions regarding the information provided in this letter or need additional assistance, please
contact Rodney A. Butler at rodney.butler ncdcr.aov or 919-707-8603.
Sincerely,
NC Natural Heritage Program
MAILING ADDRESS Telephone [phone] LOCATION
1651 Mail Service Center www ncnhp org 121 West Jones Street
Raleigh, NC 27695-1651 Raleigh, NC 27603

Natural Heritage Element Occurrences, Natural Areas, and Managed Areas Within a One -mile Radius of the Project Area
Carolina Pole Leland Inc.
Project No. NCS000222
May 17, 2018
NCNHDE-6069
Element Occurrences Documented Within a One -mile Radius of the Project Area
Taxonomic
EO ID
Scientific Name
Common Name
last
Element
Group
Observation
Occurrence
Date
Rank
Amphibian
35559
Pseudacris nigrita
Southern Chorus Frog
1968-03-17
H
Bird
19896
Picoides borealis
Red -cockaded
1999-Pre
H
Woodpecker
Dragonfly or
33738
Somatochlora georgiana
Coppery Emerald
2004-Pre
H?
Damselfly
Natural
1240
Pine/Scrub Oak Sandhill
---
2012
C
Community
(Mixed Oak Subtype)
Natural
9287
Wet Pine Flatwoods
---
2012
C
Community
(Typic Subtype)
Reptile
3506
Deirocheiys reticularia
Eastern Chicken Turtle
1967-07
H
reticularia
Reptile
19176
Pituophis melanoleucus
Northern Pinesnake
1926-Spring
H
melanoleucus
Vascular Plant
13635
Amorpha confusa
Savanna Indigo -bush
2002-08-05
D
Vascular Plant
22455
Dichanthelium
Hidden -flowered
1937-06-02
H
cryptanthum
Witchgrass
Vascular Plant
15773
Dionaea muscipula
Venus Flytrap
2002-06-26
D
Vascular Plant
2724
Lysimachia asperulifolia
Rough -leaf Loosestrife
2002-08-02
C
Natural Areas Documented Within a One -mile Radius of the Project Area
Site Name Representational Rating
Alligator Branch Sandhill and Flatwoods R5 (General)
Managed Areas Documented Within a One -mile Radius of the Project Area
Managed Area Name Owner
NC Department of Transportation Mitigation Site NC Department of Transportation
Page 2 of 4
Accuracy
Federal
State
Global
State
Status
Status
Rank
Rank
2-High
---
Significantly
G5
S2
Rare
3-Medium
Endangered
Endangered
G3
S2
5-Very
-
Significantly
G3G4
S2?
Low
Rare
3-Medium
---
---
G3?
S3
2-High
---
---
G3
S3
4-Low
---
Spec
G5T5
S3
4-Low
Species of
Threatened
G4T4
S2
Concern
3-Medium
Species of
Threatened
G3T3
S3
Concern
4-Low
---
Significantly
G3G4Q
S2
Rare
Throughout
2-High
Species of
Special
G3
S2
Concern
Concern
Vulnerable
3-Medium
Endangered
Endangered
G3
S3
Collective Rating
C5 (General)
Owner Type
State

Managed Areas Documented Within a One -mile Radius of the Project Area
Managed Area Name Owner Owner Type -
NC Division of Mitigation Services Easement NC DEQ, Division of Mitigation Services State
North American Land Trust Easement North American Land Trust Private
Brunswick County Open Space Brunswick County: multiple local government Local Government
North Carolina Agricultural Foundation Preserve North American Agricultural Foundation Private
Definitions and an explanation of status designations and codes can be found at httos:llncn de natureserve_orfllcontenYhelo. Data query generated on May 17, 2018, source: NCNHP, 02 April 2018. Please resubmit your
information request if more than one year elapses before project initiation as new information is continually added to the NCNHP database
Page 3 of 4

NCNHDE-6069: Carolina Pole Leland Inc.
May 17. 2018
Project Boundary Managed Area (MARL A)
❑ Buffered Project Boundary
0 Naturat Heritage Element Occurrence (NHEO)
® NHP Natural Area (NHNA)
Page 4 of 4
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Bennett, Bradley
From: Bennett, Bradley
Sent: Monday, April 23, 2018 7:23 AM
To: Mort, Sandra L
Subject: Question an Carolina Pole in Leland
Hi Sandy,
I was wondering if you could give me a call when you get back in the office. I have been working with Sam Watson in
your Wilmington Regional Office on a site in their region. It is Carolina Pole in Leland, NC. We are reviewing their
stormwater NPDES permit for reissuance. The site is also a brownfietds site. The last time we issued the Stormwater
permit DWM asked that we add dioxin monitoring as part of their stormwater monitoring requirements. In the
reissuance process we have looked at the collected data and have some questions about how to respond to their
numbers. I have talked with Connie Brower and Chris Ventaloro in our Standards Unit here and they suggested I also
talk with you guys about this. If you can give me a call maybe we can talk a little about this issue. I work part time so I'm
not in the office every day. Most often I'm in Monday- Wednesday but I can be available for a call other days as
well. Look forward to talking with you.
Thanks
Bradley Bennett
Stormwater Program Phone: [phone]
NC Division of Energy, Mineral & Land Resources Fax: [phone]
1612 Mail Service Center Email: b_radle_y.be_nnet_t@n_cdenr.gov
Raleigh, NC 27699-1612
Email correspondence to and from this address may be subject to public records laws

Bennett, Bradley
From:
Bennett, Bradley
Sent:
Monday, April 16, 2018 4:20 PM
To:
Watson, Samuel
Subject:
RE: Permit Renewal - NCS000222 - Carolina Pole Leland
Thanks Sam, that would be great. I should be in the office tomorrow and also on Thursday.
BB
From: Watson, Samuel
Sent: Monday, April 16, 2018 4:16 PM
To: Bennett, Bradley <[e-mail]>
Subject: RE: Permit Renewal - NCS000222 - Carolina Pole Leland
Not yet.
I'll jump on it and get back to you tomorrow.
Thanks,
Samuel P. Watson, P.G.
Project Manager
Division of Waste Management - Brownfields
NC Department of Environmental Quality
910 796 7408 office
910 350 2004 fax
samuel watson &ncdenr gov
127 Cardinal Drive Ext.
Wilmington. NC 28405
X=�`�caath�q Camp�r�s .x..�
Errrail correspondence to and from this address is subjectto the
North Carolina Public Records Law and may be disclosed to third paRies.
From: Bennett, Bradley
Sent: Monday, April 16, 2018 10:47 AM
To: Watson, Samuel <[e-mail]>
Subject: RE: Permit Renewal - NCS000222 - Carolina Pole Leland
Hi Sam,

r-J
Just wanted to check in with you on this permit and see if you had time to look at the issues yet?
Thanks
M.
From: Watson, Samuel
Sent: Wednesday, March 28, 2018 10:54 AM
To: Bennett, Bradley <bradley.bennett@ncdenr,gov>
Subject: RE: Permit Renewal - NCS000222 - Carolina Pole Leland
Thanks.
I have been out of the office for a couple days. Give me a day to get caught up and look at this, and I will give you a call
as soon as I can.
Thanks,
Samuel P. Watson, P.G.
Project Manager
Division of Waste Management - Brownfields
NC Department of Environmental Quality
910 796 7408 office
910 350 2004 fax
samuel.watson[cDncdenr gov
127 Cardinal Drive Ext
Wilmington, NC 28405
Ok --voNething Cwnparft -
man
Email correspondence to and from this address is scbfecl to the
North Carolxla Public Records Law and may be disclosed to third parties.
From: Bennett, Bradley
Sent: Tuesday, March 27, 2018 8:48 AM
To: Watson, Samuel <[e-mail]>
Subject: Re: Permit Renewal - NCS000222 - Carolina Pole Leland
Sam,
Sorry, I meant to also send you the monitoring data for the last few years that Carolina Pale reported. All
numbers in the table are mg/L. In particular, you guys had asked that we include dioxin monitoring in the
2

- - V&
permit so you might want to look at this data. With regard to that I think you had mentioned to me
before that you had some methods (model, etc.) for looking at the dioxin numbers and evaluating
risk. Maybe you, or staff there, could look at the numbers and evaluate in this way. Keep in mind that these
numbers are from runoff from rain events and not continuous. In fact, the facility reports that with the soils
on site they get a lot of infiltration and only have discharge after larger events or when small events come
back to back. They estimate they only have discharge 6 to 8 times a year.
Thanks for looking at the permit and the numbers. Let me know when you have time to discuss.
1:�7
Bradley Bennett
Stormwater Program Phone- [phone]
NC Division of Energy, Mineral & Land Resources Fax: [phone]
1612 Mail Service Center Email: bradley bennett(@ncdenr gov
Raleigh, NC 27699.1612
Email correspondence to and from this address may be subject to public records laws
From: Bennett, Bradley
Sent: Monday, March 26, 2018 2:13 PM
To: Watson, Samuel
Subject: Re: Permit Renewal - NC5000222 - Carolina Pole Leland
Sam,
Here is a copy of the draft permit for Carolina Pole - Leland. We discussed this one a while back. Once you get
this, please give me a call I need to talk with you about monitoring data that your office requested in the last
permit renewal. You can reach me at [phone]. 1 work part time, so I'm not in the office every day. This
week I'll be in the office Monday, Tuesday and Wednesday.
Thanks
W.
3

�p _ .
Bradley Bennett
Stormwater Program Phone: [phone]
NC Division of Energy, Mineral & Land Resources Fax: [phone]
1612 Mail Service Center Email: bradley bennett @ncdenr.goov
Raleigh, NC 27699-1612
Email correspondence to and from this address may be subject to public records laws
From: Bennett, Bradley
Sent: Monday, March 12, 2018 10:16 AM
To: Watson, Samuel
Subject: Permit Renewal - NCS000222 - Carolina Pole Leland
Hi Sam,
Sorry it has been a few weeks since I got back in touch on this one. I'm close to being able to send you a draft
permit for review as we discussed. However, we are working with some issues related to monitoring results
reported and as soon as we sort through that I'll be able to send you something. Just wanted to touch base
and let you know I haven't forgotten about sending you the draft.
Thanks
JIM
Bradley Bennett Phone: [phone]
Stormwater Permitting Program Fax: [phone]
NC Division of Energy, Mineral and Land Resources Email: [e-mail]
1612 Mail Service Center
Raleigh, NC 27699-1612
4

Bennett, Bradley
From:
Jane House <[e-mail]>
Sent:
Friday, February 23, 2018 10:14 AM
To:
Bennett, Bradley
Cc:
Michael Rouse
Subject:
RE: [External] RE: Question for Permit Renewal
ITTICI Mau, External email. Do not cl pen attachments unless verified. Send all suspicious email as an attachment to
No problem. Let me explain a little bit about our chemicals and maybe that will help.
Pentachlorophenol —The concentrate (which we dilute before using) contains what they tali "micro -contaminants" of
hexachlorobenzene (HCB), polychlorinated phenols, CDDs, and CDFs.
Diesel Fuel— We dilute the pentachlorophenol concentrate from 40% down to between 5-9% pentachlorophenol using
diesel fuel. This is the solution we treat with. According to diesel SDSs naphthalene is in diesel anywhere from 0.1% up
to around 2.6%.
Other than CCA, all of our other products are smaller quantity, such as maintenance solvents, hydraulic oils. Some of
those may contain toluene, benzene, and xyiene. Most of these, other than hydraulic oils, come in spray or one to 5-
gallon containers. We also have boiler chemicals, but that is mainly sodium hydroxide and we do not discharge.
To the best of my knowledge, I do not know of anything that would generate the other chemicals on your list. Hope this
helps.
lane House
jhouse(c�coxwood com
Cox Industries - Orangeburg Plant
I nis mind_hs c_, v_treq g1 the Elecirwic Communecation Prlvavy Act. t$ U 5_C 25 i 0-2521 and =ray be
Iectaily pr .leaed The information contained in this Email is intended anly fo; t`ie use of the ir:divnttuat or
entity names! ancre. If the r4ugQer of this me"age is not the intended recipient. P1he employee ar agent
responsible to deliver it to the intended recipient you are hereby notified that any dissemination.
distrburion or copying of this communication is strictly ProWMed if yoij have receive thfs communication
n ^rr�j'ii ia3SN -nirnaclietc�notify us by ?!et7hon? and destroy the crigindl mess8 e- -
From: Bennett, Bradley[mailto:brad ley. [e-mail]
Sent: Friday, February 23, 2018 9:17 AM
To: Jane House <[e-mail]>
Cc: Michael Rouse <[e-mail]>
Subject: Re: [External] RE: Question for Permit Renewal
,lane

Sorry to keep sending questions. Some of the information we may have had in files in the past has been
archived over time. We are trying now to save more information digitally. Anyway, here is the question. Do
you in your industrial process potential sources for the following parameters:
Phosphorous
Phenols
Ammonia
Benzene
Toluene
Anthracene
Xylene
Napthalene
T'KN
All sample results for these appear to be very low so we are considering adjustments to permit monitoring.
Thanks for your help!
Bradley Bennett
Stormwater Program Phone: [phone]
NC Division of Energy, Mineral & Land Resources Fax: [phone]
1612 Mail Service Center Email: bradlev.bennettCc_Dncdenr.gov
Raleigh, NC 27699-1612
Email correspondence to and from this address may be subject to public records laws
From: Jane House <lhouse [e-mail]>
Sent: Wednesday, February 21, 2018 7:09 AM
To: Bennett, Bradley
Cc: Michael Rouse
Subject: (External] RE: Question for Permit Renewal
2

We have not changed any chemicals used for wood preservation. I have attached the SDS for these. The
penta (Dura-Treat) is mixed with diesel to make the treating solution and CCA (Wolmanac) is mixed with
water.
Let me know if you need anything else. Thanks.
Jane House
ihouseAcoxwood-corn
Cox Industries - Orangeburg Plant
From: Bennett, Bradley [mailto:bradley.bennett ncdenr.gov]
Sent: Tuesday, February 20, 2018 9:07 PM
To: Jane House < th [e-mail]>
Cc: Michael Rouse <[e-mail]>
Subject: Question for Permit Renewal
I just had a question as I work to finalize the draft permit. As we are looking at the monitoring parameters and
considering ones that we may be able to lessen the frequency on it is important to know what chemicals are still
part of your treatment process. Could you send me a list of those specific chemicals.
Thanks
Bradley Bennett
Slormwater Program Phone: [phone]
NC Division of Energy, Mineral & Land Resources Fax: [phone]
1612 Mail Service Center Email: bradley.bennettna.ncdenr.gov
Raleigh. NC 27699-1612

Email correspondence to and from this address may be subject to public records laws

� 5, bete (t
Permit No. NCS000222 DRAFT
SECTION B: ANALYTICAL MONITORING REQUIREMENTS
Analytical monitoring of stormwater discharges shall be performed as specified in Table 1.
All analytical monitoring shall be performed during a measureable storm event at each
stormwater discharge outfall (SDO). Only SDOs discharging stormwater associated with
industrial activity must be sampled (See Definitions).
A measurable storm event is a storm event that results in an actual discharge from the
permitted site outfall. The previous measurable storm event must have been at least 72 hours
prior. The 72-hour storm interval does not apply if the permittee is able to document that a shorter
interval is representative for local storm events during the sampling period, and the permittee
obtains approval from the local DEMLR Regional Engineer. See Definitions.
Table 1. Analytical Monitoring Requirements
Parameter
Code
Discharge
Characteristics
Units
Measurement
Frequencyl
Sample
Type2
Sample
Location3
340
Chemical Oxygen Demand COD
m L
semi-annual
Grab
SDO
C0530
Total Suspended Solids (TSS)
m L
semi-annual
Grab
SDO
400
pH
standard
semi-annual
Grab
SDO
1002
Arsenic Ar , of Recoverable
m L
semi-annual
Grab
SDO
1034
Chromium Cr , of Recoverable
m L
semi-annual
Grab
SDO
1042
Copper (Cu), Total Recoverable
m L
semi-annual
Grab
SDO
39032
Pentachloro phenol PCP
m L
semi-annual
Grab
SDO
84103
Dioxin 34G75
m L
semi-annual
Grab
SDO
46529
Total Rainfa114
inches
semi-annual
Rain Gauge
-
One Time Monitoring
Add parameters below for4th year monitorin
34030
Benzene
mg/L
41n Year -
semi-annual
Grab
SDO
34030
Toluene
mg/L
41n Year -
semi-annual
Grab
SDO
81551
Xylene, Total
m L
g/
4rn Year -
semi-annual
Grab
SDO
henal
4Ln Year -
semi-annua
SDO
Footnotes:
1 Measurement Frequency: Twice per year (unless other provisions of this permit prompt monthly
sampling) during a measureable storm event, until either another permit is issued for this facility or until
this permit is revoked or rescinded. If the facility is monitoring monthly because of Tier Two or Three
response actions under the previous permit, the facility shall continue a monthly monitoring and
reporting schedule in Tier Two or Tier Three status until relieved by the provisions of this permit or
the Division.
2 Grab samples shall be collected within the first 30 minutes of discharge. When physical separation between
outfalls prevents collecting all samples within the first 30 minutes, sampling shall begin within the first 30
minutes, and shall continue until completed.
Part 11 Page 5 of 14

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QAJ

Permit No. NCS000369 DRAFT
Footnotes:
1 Monitoring Frequency: Twice per year during a measureable storm event unless other provisions of this
permit prompt monthly monitoring. See Table 2 for schedule of monitoring periods. The permittee must
continue qualitative monitoring throughout the permit renewal process until a new permit is issued.
2 Monitoring location: Qualitative monitoring shall be performed at each stormwater discharge outfall
(SDO) regardless of representative outfall status.
A minimum of 60 days must separate monitoring dates, unless additional sampling has
been instituted as part of other analytical monitoring requirements in this permit.
If the permittee's qualitative monitoring indicates that existing stormwater BMPs are
ineffective, or that significant stormwater contamination is present, the permittee shall
investigate potential causes, evaluate the feasibility of corrective actions, and implement
those corrective actions within 60 days, per the Qualitative Monitoring Response, below.
A written record of the permittee's investigation, evaluation, and response actions shall be
kept in the Stormwater Pollution Prevention Plan.
ve Monitorine Res
Qualitative monitoring is for the purposes of evaluating SPPP effectiveness, identifying new
potential sources of stormwater pollution, and prompting the permittee's response to pollution. If
the permittee repeatedly fails to respond effectively to correct problems identified by qualitative
monitoring, or if the discharge causes or contributes to a water quality standard violation, the
Division may but is not limited to:
• require that the permittee revise, increase, or decrease the monitoring frequency for some
or all parameters (analytical or qualitative)
• require the permittee to install structural stormwater controls;
require the permittee to implement other stormwater control measures;
require the permittee to perform upstream and downstream monitoring to characterize
impacts on receiving waters; or
require the permittee implement site modifications to qualify for a No Exposure Exclusion.
SECTION E: SPECIAL CONDITIONS
A (1.) ELECTRONIC REPORTING OF MONITORING REPORTS [G.S. 143-215.1(b)]
Federal regulations require electronic submittal of all discharge monitoring reports
(DMRs) and program reports. The final NPDES Electronic Reporting Rule was adopted and
became effective on December 21, 2015.
NOTE: This special condition supplements or supersedes the following sections within
Part III of this permit (Standard Conditions for NPDES Permits):
• Section B. (3.)
• Section D. (6.)
• Section E. (1.)
• Section E. (2.)
Signatory Requirements
Records Retention
Discharge Monitoring Reports
Submitting Reports
Part If Page 10 of U

l 1 16 (�2 061
r1)I9 /I r7
Dioxin Compound
Reported
value
Units
TEF
(WHO 2005)
TEF
Adjusted
1
1,2,3,4,7,8-HxCDD
94.7
pg/L
0.1
9.47
2
1,2,3,6,7,8-HxCDD
199
pg/L
0.1
19.9
3
1,2,3,7,8,9-HxCDD
190
pg/L
0.1
19
4
1,2,3,4,7,8-HxCDF
82.3
pg/L
0.1
8.23
5
1,2,3,6,7,8-HxCDF
119
pg/L
0.1
11.9
6
2,3,4,6,7,8-HxCDF
207
pg/L
0.1
20.7
7
1,2,3,4,6,7,8-HpCDD
7430
pg/L
0.01
74.3
'
8
1,2,3,4,6,7,8-HpCDF
3840
pg/L
0.01
38.4
`
9
1,2,3,4,7,8,9-HpCDF
215
pg/L
0.01
2.15
10
1,2,3,4,6,7,8,9-0CDF
10500
pg/L
0.0003
3.15
TEQ =
Adjusted to 2,3,7,8-TCDD toxicity =
207.2
pg/L
0,2072
ng/L
0.021
ng/L
Narrative:
Current 2,3,7,8-TCDD =1 0.0000051ng/L
*adjust for two highest TEFs in this list (from rows 1 & 2)
The toxicity of this mixture of dioxin compounds is equivalent to 0.021 ng/L of 2,3,7,8-TCDD.
This concentration Iexceeds Ithe current surface water quality standard of 0.000005 ng/L for 2,3,7,8-TCDD.
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�e�

North Carolina
Beverly Eaves Perdue
Governor
Mr. Mike Rouse
Leland Land LLC
1901 Wood Treatment Rd NE
Leland, NC 28451
Dear Mr. Rouse:
��
Flo
NCDENR
Department of Environment and
Division of Water Quality
Charles Wakild, P.E.
Director
October 15, 2012
Natural Resources
Dee Freeman
Secretary
Subject: NPDES Permit Renewal Application
Carolina Pole Leland Inc
Permit Number NCS000222
Individual Stormwater Permit
Brunswick County
The Division of Water Quality's Stormwater Permitting Unit (SPU) acknowledges receipt of
your renewal application for coverage under NPDES Permit Number NCS000222 on June 15, 2012.
We currently have a backlog of individual permit renewals in-house and are working to get to these as
quickly as we can- Please continue to comply with all conditions and monitoring requirements in
your current or expired NPDES stormwater permit. As long as you have submitted a complete
renewal request package and maintain compliance with those permit conditions, stormwater discharges
from this facility are authorized by that permit until the Division issues a renewal permit or notifies you
of an alternative action.
No additional information is required at this time, but we may contact you in the future. PIease
notify us if any significant changes have taken place at this facility since you submitted the renewal
package. If you have any questions about this matter, please contact me at [phone],
bradley.bennett@b,ncdenr.gov.
cc: Stormwater Permitting Unit Files
Central Files
Wetlands and Stormwater Branch
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location 512 N Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] k FAX 9IM07-6494
Internet: www ncwaterquality.org
An Fn,,,J C1nmrl,,nav � Affim*liva Arhnn Fmrmn
Sincerely,
Bradley Bennett
Stormwater Permitting Unit
ode NCarolina
atumlly

C
2012 STORM WATER PERMIT
RENEWAL APPLICATION
for
CAROLINA POLE LELAND, INC.
SW PERMIT # NCS000222
� 1901 WOOD TREATMENT RD
LELAND., NC,, 28451
BRUNSWICK COUNTY
Questions? Please contact Jane House at
[phone] or by email at
ihouse gcoxwoo .com
DENR - Wf.,TEl� ptJr.L1TY
Wflikand5

r
Permit Coverage
Renewal Application Form
National Pollutant Discharge Elimination System Permit Number
Stormwater Discharge Permit I NCS000222
e following is the information currently in our database for your facility. Please review this information carefully and make all
corrections/additions as necessary in the space provided to the right of the current information.
Owner Affiliation Information *Reissued Permit will be mailed to the owner address
Owner / Organization Name: Leland Land LLC
Owner Contact: n
Mailing Address: PO Sox 1124 _
Orangeburg SC, 29116
52R_ J21e4-4,3)4-
Phone Number:
Fax Number:
Email address:
Facility/Permit Contact Information
Facility Name: Carolina Pole Leland Inc
Facility Physical Address: 1901 Wood Treatment Rd NE
Leland NC, 28451
Facility Contact:
Mailing Address:
Phone Number:
Fax Number:
E-mail address:
char a Information
eceiving Stream
Stream Class:
Basin:
Sub -Basin:
Plumber of Outfatts:
Alligator Branch
C: SW
Cape Fear River Basin
03-06-17
Impaired Waters/TMDL
Does this facility discharge to waters listed as impaired or waters with a finalized TMDL? ❑ Yes 'lad No v Don't Know
( for information on these waters refer to http:llh2o.enr.state.nc.us/sallmpaired_Woters_TMDLI )
CERTIFICATION
I certify that I am familiar with the information contained in the application and that to the best of my knowledge and belief such
information is true, complete and accurate.
Signature
� �Y�e I roue
Print or type name of person signing above
Date *-C, mba
C90
Title
�se return this completed renewal application form to: Stormwater Permitting Unit
Attn: Brian Lowther
1617 Mail Service Center
Raleigh, North Carolina 27699.1617

0
El
0
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:
9
1
(Do not submit the site Stormw-ater Pollution Prevention Plan)
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. H
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.
EA
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.
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.
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)

WATER SUPPLY WELL
CpU�cQ �L ! 1 r� S
- Q-A
X 4.'2rY,� �-n) ou ►-�
GRAPHIC SCALE - IN FEET
mew
0 400 800
SITE MAP (:69,�)rA A-IOIQ, L
GENERAL WOOD FACILIT,�(
LELAND, NORTH CAROLINA
us,,,u,. —
MACTEC
n
i
I
I
DRAWN-
W8M
JOB:
6470-03-0500
APPROVAL:
JCP
DATE
6/29/04
SCALE:
AS SHOWN
FIG
2

•
•
0
CAROLINA POLE LELAND
Stormwater Results
Date m IL
Fed
Benchmarks
Jul-08
Au -08
Oct-09
Sep-10
H
6.0 - 9.0
7.86
8.01
7.27
6.89
Arsenic
0.3600
0.22
0.099
0.047
0.045
Copper
0.0070
0.014
0.069
0.005
0.015
Zinc
0.0670
ND
0.048
ND
ND
Chromium
1.000
0.013
0.13
0.0082
0.021
O & G
30.00
ND
ND
ND
ND
SOD5
30.00
16
4.6
ND
2.8
COD
120.00
180
280
731
70
TSS
100.00
32
230
3.4
30
Phenols
4.50
ND
ND
ND
ND
Pentachloro henol
0.019
0.017
0.020
0.00054
0.047
Benzene
6.70
ND
ND
ND
ND
Toluene
0.055
ND
ND
ND
ND
Anthracene
0.005
0.0014
ND
ND
ND
7C lene
6.70
ND
ND
ND
ND
TKN
20.00
3.2
3.1
ND
0.52
Tot Phosphorus
2.00
0.37
0.47
0.024
0.12
Ammonia
7.20
NS
0.210
0.280
0.1
Dioxin
Any
NS
1.650E-07
ND
1.85E-07
Eth I benzene
ND
Determining when to take sample - This facility is fairly unique in that a ditch
encompasses the entire 120+ acre site. The soil is very sandy. Normal rain
events will absorb into the ground. Until the ground is saturated there will be no
run off from the production area. if the weather has been dry for several days, it
may take up to a 6+" rain before enough water is generated to have any run off.
Sampling may take place within 72 hours of a previous event as long as the
previous event did not generate any run off, but was absorbed. Estimation of
run off for this site has been reduced by 50% per inch due to this occurrence.

ft
STORM WATER POLLUTION PREVENTION
SEMI-ANNUAL VISUAL (QUALITATIVE) INSPECTION REPORTS
OUTFALL
2007
2007
2008
2008
2009
2009
NUMBER
APRIL-JUNE
SEPT-NOV
APRIL-JUNE
SEPT-NOV
APRIL-JUNE
SEPT-NOV
OUTFALL 001
OUTFALL 001 _
OUTFALL 001
OUTFALL 001
OUTFALL 001
OUTFAL 001
INSPECTOR
�
DATE1TIME
Cam} /__1
�J �
�/G`
I 13)0%
�J
COLOR
/
�f
ODOR
✓
�'
CLARITY
r
FLOATING
SOLIDS
SUSPENDED
SOLIDS
r`
FOAM
✓'�
'OIL SHEEN
fir'" J
\j
OTHER
OBVIOUS
INDICATORS OF
/6�
U
10
POLLUTION
l d
ndicates•no problems k = Indicates contamination (Note probable sources of any observed storm water contamination)
`Observations to note: Color, odor, turbidity, floating solids, foam, oil sheen, or any other InWeition6 of storm water pollution. Note the probable sources of any observed
storm.water contamination.
"Observations should be marls within first 3D minutes of precipitation, but no later than 80 minutes in daylight and when sufficient runoff occurs.
SWPPP 2006 Page'_3 ol'23

� s �
STORM WATER POLLUTION PREVENTION
SEMI-ANNUAL VISUAL (QUALITATIVE) INSPECTION REPORTS
e�DI0 _,?010 '0701 r -1e)ZI 0?0/9 �DIo2
OUTFALL
7t
1`
44AB"'
-
-ii`9Q9r- .49ft
NUMBER
APRIL-JUNE
SEPT-NOV
APRIL- JUNE
SEPT-NOV
APRIL-JUNE SEPT-NOV
OUTFALL 001
OUTFALL 001
OUTFALL 001
OUTFALL 001
OUTFALL 001 4 OUTFALL 001
INSPECTOR
--
- -
DAT FJTI M E
. ..............
I COLOR
�jal
62
ODOR
€
CLARITY
0
FLOATING
SOURS
SUSPENDED
SOLIDS
FOAM
f
OIL SHEEN
OTHER
OBVIOUS
INDICATORS OF
f/
POLLUTION
J = Indicates no problems X - Indicates contamination Watt probable sources of any observed storm water contantlnatlool
'Observations to note: Color, odor, turbidity, floating solids, foam, di sheen, or any other Indleations of storm water pollution. Note the probable sources of any observed
storm water contamination.
"attservations should be made within first ]a minutes of precipitation, but no later than 60 minutes in daylight and when sufficient runoff occurs,
SVVPPP 2006 Page 21 of 23,

•
0
CAROLINA POLE LELAND
LELAND, NC
BEST MANAGEMENT PRACTICES
4.a. Effective Pollutant control Options for Timber Product Facilities
Activity_Associated
BMPs
In Use
j Remarks
Log, Lumber,
Divert Storm water around storage areas with ditches,
X
and other Wood
swales and/or berms
Product Storage
Locate storage areas on stable, well -drained soils with
X
80% of yard
Areas
slope of 2-5 percent
(Untreated)
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
X
exposed to precipitation
Frequent removal of debris
X
Activit
Associated BMPs
In Use
Remarks
Residue Storage
Areas
Locate storage residues away from drainage pathways
and surface waters
X
(such as
untreated
Avoid contamination of residues with oil, solvents,
chemically treated wood, trash, etc.
X
sawdust, chips)
Assemble plies to minimize surface area of materials
exposed to precipitation
X
X
Limit storage time of residues to prevent degradation
and generation of leachates
_
Limit slopes of storage areas to minimize velocities of
runoff which may transport residues
X
Activity
Associated BlYIPs
In Use
Remarks
Loading and
Provide diversion berms and dikes to limit run on
X
Unloading,
Material
Provide good housekeeping measures to limit debris and
X
Handling Areas
to provide dust control
Activity
Associated BMPs
In Use
Remarks
Wood
Extend drip time on drip pad (process area) before
X
Preservation
moving to 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
X
away from high traffic areas where tracking of the
chemical may occur.
Provide frequent visual inspections of loading and
X
unloading areas during and after activities occur to
identify any spills or leaks needing clean-up
Cover and/or enclose treatment areas
X
Elevate stored, treated wood products to prevent contact
X
with runon/runoff

•
1]
Activity
Associated BMPs
In Use
Remarks
Chemical
Storage Areas
Provide secondary containment around chemical storage
areas
X
Provide level gages
X
Inventory fluids to identify leakage
X
Locate storage areas away from high traffic areas and
surface waters
X
Develop spill prevention, containment and
countermeasure SPCC plans and implement
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
maintenance
Preventative maintenance program (cleaning oil/water
X
and cleaning
separators, catch basins, vehicle mounted drip
containment devices
Minimizing storm water run on and runoff at fueling
X
areas.
Perform all maintenance activities indoors
X
Cover and/or enclose chemical storage areas (used oil,
X
oil filters, used solvents, etc.
Locate storage areas away from high traffic areas
X
Activity
Associated BMPs
In Use
Remarks
Erosion and
Sediment
Grassed areas to prevent soil erosion
X
Controls
Use of vegetation on sloped areas to prevent sediment
run-off
X
Ditches around property to prevent water run on from
neighboring locations
X
Sediment Trap (Such as rock, vegetation, etc.)
X
This is a wood preservation facility. Logs and some untreated poles/lumber are brought on site for treatment
using either an inorganic arsenical (CCA) or pentachlorophenol. Prior to treatment, the logs are peeled on site,
graded, and cut to length. All chemicals used in the treatment process are kept inside containment areas. The
containment systems do not have manual drain valves. Any liquids removed from the containment areas must
be pumped out. Waters accumulated inside these containment areas are used back in the CCA process. All
freshly treated poles/lumber are kept under cover, on a RCRA Subpart W drip pad until drippage has ceased.
The production facility is entirely surrounded by a ditch that eventually leads to the only outfall (at Sunny Point).
Loaders and other vehicles are regularly inspected and maintained by the maintenance department. Most of the
maintenance work is done under cover. 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 and roofed.
Chemical bulk unloading for the treating plant is within a truck containment system.
Diesel unloading is performed in two areas, at the treating plant within a containment area and also a smaller
tank for truck fueling located near the scale house. The diesel tanks at the treating plant are located inside
secondary containment and the smaller tank is double walled. Any water contaminated with oil is run through
our wastewater treatment unit. The water is used in our CCA process and any residual oils are used in our
pentachlorophenol process.

s
3.a Risk Identification and Summary of Potential Pollutant Sources
Chemical or
Loading,
Operations
Outdoor
Outdoor
Particulate
On -site Waste Disposal
Pollutant Source
Unloading­_Stora
a
Mfg.
Generation
CCA
X
X
X
Cardboard containers/drums, stored under roof in containment
containment
roof and inside
Treated
area. Shipped as hazardous waste.
containment
Poles/Lumber
Pentachlorophenol
X
X
X
Cardboard containers/drums, stored under roof in containment
containment
roof and inside
Treated
area. Shipped as hazardous waste.
containment
Poles/Lumber
Diesel Fuel for
X
X
roof and inside
Non -liquid placed in bulk roll -off (general trash)
treatment
containment
containment
Any liquid is drummed and recycled or shipped as haz. Waste.
Diesel/Gasoline
Double Wall
Tanks
Oils, hydraulic, etc.
X
Non -liquid placed in bulk roll -off, used oil stored bulk under
roof and on concrete for recycling, used filters drummed and
inside bld
Pole Peeling
X
Area cleaned regularly. Chips/bark used in boiler as fuel.
Stored in plies near boiler.
Framing
X
Minimal Sawdust
generation
Material Handling
X
Pole/Lumber damage during handling in yard
Swept up and kept in containers until shipped out as non-haz
I
Activities
Damaged Ibr
I
trash).
Loading/Unloading — There are several locations where loading/unloading are performed. In the yard untreated logs/poles/lumber are unloaded and trailers
are then reloaded with treated lumber. The pole and lumber storage areas have minimal potential for pollution since the lumber is packaged and strapped for
loading. Logs can generate bark in their storage location. Logs generally are stored in one area of the facility. Bulk diesel for treatment use with
pentachlorophenol, along with treatment chemicals, while unloading, is in a concreted containment area. No tank truck is allowed to hook up without
management approval and a tank level check. The driver must remain at the truck during unloading.
Operations — At the treatment location, the poles/lumber is treated in a roofed containment area. Once the poles/lumber is removed from the cylinder, it is
placed on a drip pad, which is contained, until drippage has ceased. Poles/Lumber may then be stored under in the yard. Any water from a rain event that is
captured on the drip pad or tank farm area is picked up and reused in the CCA operation. All chemical bulk storage is located under roof and inside
containment. Any accumulation of water from a rain event into the containment area is picked up and reused in that operation.
Outdoor ProcesslParticu late Generation — Log peeling is performed outdoors, near the boiler area. The bark and chips are sent through a conveyor pipe
and blown out onto the ground next to the boiler. The bark and chips are then used as fuel for our boiler. Bark and chips are piled to minimize blowing or
contamination to the waterways.
Outdoor Storage —Treated poles/lumber is stored outdoors until used or sold.
Waste Disposal —
• Treating Plant— Waste generated is boxed, stored under roof and disposed of as a hazardous waste. All liquid is reused in the process
• Maint. Shop — Used oil generated is stored in 55 gallon drums or bulk tank until recycled. The drums are kept indoors or under shed.
• Yard Debris — Any broken pieces of lumber or general trash found in the yard is placed into the trash container and disposed of as a non -hazardous
waste
• Diesel Storage — The diesel tanks are inside containment. Rainwater cannot be released without manual pumping of the containment.

. CAROLINA POLE LELAND
LELAND, NC
SIGNIFICANT CHANGES IN INDUSTRIAL ACTIVITIES
This facility has not changed processes or chemicals used in their process. The
only significant change will be during 2012 as an upgrade to our pole mill
operation is underway. This will eliminate the use of air to "blow" our chips to
the boiler house area for use in our boiler. We will be using a conveyor system.
With this modification we hope to reduce the amount of loose chips around the
pole mill and boiler house areas, which should help our storm water by reducing
solid pieces in the ditch area near the boiler house.
•
:7

•
STORMWATER POLLUTION PREVENTION PLAN
DEVELOPMENT AND IMPLEMENTATION
CERTIFICATION
North Carolina Division of Water quality - Stormwater Permitting Unit
Facility Name: Carolina Pole Leland Inc
Permit Number: NC5000222
Location Address: 1901 Wood Treatment Rd NE
Leland NC, 28451
County: Brunswick
"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 property 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 signatory requirements) and return this Certification. DO NOT
SEND STORMWATER POLLUTION PREVENTION PLAN WITH THIS CERTIFICATION.
Signature L' ,
P or type name of person signing above
Date
C�cT� Z7
Title
SPPP Certification 5/09

ALIT,"• ►C
NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Robert Michael Johnson
Leland Land LLC
PO Box 1124
Orangeburg SC, 29116
Dear Permittee:
Division of Water Quality
Chuck Wakild, P.E.
Director
May 10, 2012
Subject: NPDES Stormwater Permit Coverage Renewal
Carolina Pole Leland Inc
Permit Number NCS000222
Brunswick County
Dee Freeman
Secretary
Your facility is currently covered for stormwater discharge under NPDES Permit NCS000222. This permit expires on
December 31, 2012. To assure consideration for continued coverage under your individual permit, you must apply
to the Division of Water Quality (DWQ) for renewal of your permit. Enclosed you will find an individual permit
Renewal Application Form, Supplemental Information request, and stormwater Pollution Prevention Plan
Certification for your facility.
Filing the application form along with the requested supplemental information will constitute your application for
renewal of this permit. Until your permit renewal is completed and you receive a new permit, please continue to
comply with all conditions and monitoring requirements in your expired NPDES stormwater permit.
The application and supplement must be completed and returned to DWQ by July 4, 2012. Failure to request
renewal within this time period will result in delay of your permit renewal and may result in a civil assessment.
Discharge of stormwater from your facility without coverage under a valid stormwater NPDES permit would
constitute a violation of NCGS 143-215.1 and could result in assessments of civil penalties of up to $25,000 per
day.
If you have any questions regarding permit renewal procedures please contact Brian Lowther of the Stormwater
Permitting Unit at (919)-807-6368 or [e-mail].
Sincerely,
II
Bradley Bennett, Supervisor
Stormwater Permitting Unit
Cc: Central Files
SPU Files
Wilmington Regional Office
1617 Mail Service Center, Raleigh, North Carolina 27699.1617
Location: 512 N. Salisbury S1, Raleigh, North Carolina 27604
Phone: [phone] FAX! 919-807-6492
Internet www.ncwatergt�ality.org
An Equal Opportunity i Affirmative Aclion Employer
i3Y•.
One
NorthCarolina
Naturallrf

J�OF yl��FRUL Permit Coverage
Renewal Application Form
Y National Pollutant Discharge Elimination System Permit Number
Stormwater Discharge Permit NCSUoo222
The following is the information currently in our database for your facility. Please review this information carefully and make all
corrections/additions as necessary in the space provided to the right of the current information.
Owner Affiliation Information ` Reissued Permit will be mailed to the owner address
Owner / Organization Name: Leland Land LLC
Owner Contact: Robert Michael Johnson
Mailing Address: PO Box 1124
Orangeburg SC, 29116
Phone Number:
Fax Number:
E-mail address:
Facility/Permit Contact Information
Facility Name: Carolina Pole Leland Inc
Facility Physical Address:
Facility Contact:
Mailing Address:
Phone Number:
Fax Number:
E-mail address:
1901 Wood Treatment Rd NE
Leland NC, 28451
Discharge Information
Receiving Stream Alligator Branch
Stream Class:
Basin:
Sub -Basin:
Number of Outfalls:
C; Sw
Cape Fear River Basin
03-06-17
Impaired Waters/TMDL
Does this facility discharge to waters listed as impaired or waters with a finalized TMDL? ❑ Yes ❑ No © Don't Know
( for information on these waters refer to http://h2o.enr.state,nc.uslsu/Impaired Waters_TMDLI )
CERTIFICATION
I certify that I am familiar with the information contained in the application and that to the best of my knowledge and belief such
information is true, complete and accurate.
Signature
Print or type name of person signing above
Date
Title
Please return this completed renewal application farm to: Stormwater Permitting UnitAttn: Brian Lowther
1617 Mail Service Center
Raleigh, North Carolina 27699-1617

Re: General Wood/Leland Site I�r'ji! �D�l(YLI $ f:�0XIY1?VV�.Y
Subject: Re: General Wood/Leland Site ( NW. I
From: Connie Brower <[e-mail]> fal l r �0 Pit' & � �
Date� : Thu, 02 Oct 2008 12-55:16 -0400 tx 5e
To: Sandra Moore Sandra.Moore@ncmaif. net> Pdy YUt 0(.' e Ylit•iyt SPe-c-
t�1[
CC: Bethany Georgoulias [e-mail]>, Nikki Remington YLR>< i ►'U-�
Nikki. [e-mail]> lv� JvtS{-Z.,Zyiyl�
Id/Z409 Ad J', S-Lc4 C.,tiyv m A1 p-X
Hi Bethany -- J?,V • Se- L`Qj07 • �(o� . ` 01 t �7� �
DG , G �{ .0 IV e4,L � . VIIIti-Z4,x S�-�
I� rNl l M cIrt - 'I �
I agree with Sandra th t t� he use of the total congeners is required and is appropriate for '
adequate assessment of the waters. The US Environmental Protection Agency; Office of C kACLe�
Water/Office of Science and Technology document entitled "National Recommended Water
Quality Criteria: 2002" (# EPA-822-R-02-047) concurs and has the following —in
support of the listed 304(a) criteria:
Dioxin
The section 304(a) water quality criteria for dioxin contained in this compilation is
expressed in terms of 2,3,7,8-Tetrachloro-dibenzo-p-dioxin (2,3,7,8-TCDD) and should be
used
in conjunction with the national/international convention of toxicity equivalence factors
(TEF/TEQs) to account for the additive effects of other dioxin -like compounds (dioxins).
EPA
supports the use of either the 1989 interim procedures or the 1998 World Health
Organization
(WHO) TEF scheme, but prefers the 1998 WHO TEF scheme because it is based on more
recent
+t)
+vy �
t`5t -} 2 �uCA
ITT''
" '' ylne j�toc.
data and is internationally accepted. (See: Update to the Interim Procedures for Estimating
Risks Associated with Exposures to Mixtures of Chlorinated Dibenzo p-dioxins and
-dibenzofurans,
EPA/625/3-89/016, March 1989 and Van den Berg M., 1998). By applying the TEF/TEQ
approach, the other highly toxic dioxins will be properly taken into account.
As for analytical methodology, the approved 40 CFR method for congener
identification is Method 1613 B.
If 2,3,7,8 TCDD is the only congener that is detected by Method 1613B,- then the
applicant could use Method 613 for further testing. Sandra and I believe that the
applicant likely has data available that could answer these questions (now). I would
offer that a note to Liz Cannon may be helpful. She can provide information with,
respect to the assigned project manager for the site.
(Elizabeth.cannon(a-),ncmail.net)
] of4 l0/2/2008 1:10 PM

Ede: General Wood/Leland Site
call us if you need any additional information.
connie and sandra
Sandra Moore wrote:
Bethany,
Sorry, but at this point I can't remember the specifics.at the General Wood
facility. My main involvenmht-was performing a risk assessment on the
contaminants in the soil --which included dioxins. However, just analyzing for
2,3,7,8-TCDD is not usually sufficient. Usually a facility must analyze for 17
dioxin and dioxin -like compounds (see list below) and using TEFs calculate a
total 2,3,7,8-TCDD. If General Wood has already analyzed for the 17
compounds and can show that the only congener present is 2,3,7,8-TCDD then
could see just looking for that one). I'm pretty sure that General Wood did
analyze for the 17 congeners in soil but l don't remember what they found at this
point.
However, with that said I need to check with Connie to see how the surface
water standard was calculated --based on just 2,3,7,8-TCDD or based on the 17
congeners.
I'll get back with you ASAP.
Sandra
r
2 of 4 10/2/2008 1:10 PM

ood/Leland Site
IN
Dioxins*
Toxic
EquivalencyFactor
(TEF)
2, 3, 7, 8-TCDD
1
1,2,3,7,8-PnCDD
1
1,2,3,4,7,8-HxCDD
0.1
1,2,3,6,7,8-HxCDD
0.1
1,2, 3, 7, 8, 9-HxCDD
0.1
1,2,3,4,6, 7, 8-HpCDD
0.01
OCDD
0.0001
2, 3, 7, 8-TCDF
0.1
1, 2, 3, 7, 8-PnCDF
0.05
2,3,4, 7, 8-PnCDF
0.5
1,2,3,4,7,8-HxCDF
0.1
1,2,3,6,7,8-HxCDF
0.1
1,2,3,7,8,9-HxCDF
0.1
2,3,4,6,7,8-HxCDF
0.1
1,2,3,4,6,7,8-HpCDF
0.01
1,2, 3, 4, 7, 8, 9-HpCDF
0.01
OCDF
0.0001
* The term "Dioxins" here refers to 7 dioxin
and 10 furan chemical compounds.
** Developed 6y van den Berg, et al., 1998
A 4 10/2/200$ H 0 PM

Re: General Wood/Leland Site
Bethany Georgoulias wrote:
Sandra,
This is one from your past, but it's a question that would go to you all
anyway. I just got a call from Jane House about this site's stormwater permit
that Kelly Johnson did, and she's asking about what test method to use for
dioxin testing of their stormwater samples. The lab is telling her that (okay,
this is what she told me -- not sure if I'm getting this right) running the
2,3,7,8-TCDD is sufficient and what most states want as far.as testing for
detection of dioxin. However, she needed to verify whether we would them
to run the test that gives all 17 derivatives, which the lab said would be the
case -if we were wanting dioxin, furans, etc.
You probably know that history and lab methods well enough to answer this
off the top of your head, but I'm attaching Kelly's staff report on this permit
for reference. I wasn't sure what to tell Jane. Any idea or advice? In the
permit, Kelly wrote the "benchmark" in as "any detection," since this is dioxin
we're dealing with ... but I suppose that will be dictated by which method. If
you can help me out, I'll get back to her.
Thankslll
Bethany G.
SANDRA MDQRE
State Standards Co -coordinator
Division of Water Quality
NC Department of Environment and Natural Resources
Archdale Building, Room 711 K
512 N SALISBURY ST, RALEIGH NC 27604-1170
919,807.6417 [e-mail] '
Connie Brower <Connie.Brower ncmail.net>
Industrial Hygiene Consultant
NC DENR
( Division of Water Quality
s
4 of 4
i nM I'nno 1.1A Dr.r

v� WAT�c . Michael F. Easley, Governor
O �QG 0 State of North Carolina
b William G. Ross, Jr., Secretary
F Department of environment and Natural Resources
Cohen H Sullins, Director
Division of Water QuatitY
December 7, 2007
Mr. R. Michael Johnson
President
Leland Land, LLC
PO Box 1124
Orangeburg, SC 29116
Subject: Final NPDES Stormwater Permit
Permit NCS000222
Leland Land, LLC
Brunswick County
Dear Mr. Johnson:
In response to your renewal application for continued coverage under NPDES stormwater permit
NCS000222, the Division of Water Quality (Division) is forwarding herewith the subject state - NPDES
permit. This permit is 'issued pursuant to the requirements of North Carolina General Statute 143-215 .1
and the Memorandum of Agreement between North Carolina and the US Environmental Protection
agency dated May 9, 1994 (or as subsequently amended).
This final permit includes no major changes from the draft permit sent to you on September 28, 2007.
The qualitative monitoring strategy remains the same (semi-annual) as the previous term of the permit.
Please note that analytical monitoring is also required in this permit. Failure to complete the monitoring
as required is a violation of the permit and any permit noncompliance constitutes a violation of the Clean
Water Act. Reference Part III, Section A, Item 2 "Duty to Comply", Item 9 "Penalties for Tampering " and
Item 10 'Penalties for Falsification of Reports" of your permit for further information.
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty
(30) days following receipt of this letter. This request must be in the form of a written petition,
conforming to Chapter 150E of the North Carolina General Statutes, and filed with the Office of
Administrative Hearings, Post Office Drawer 27447, Raleigh, North Carolina 27611 -7447. Unless such
demand is made, this decision shall be final and binding.
Please take notice this permit is not transferable. Part III, B.2. addresses the requirements to be followed
in case of change in ownership or control of this discharge. This permit does not affect the legal
requirements to obtain other permits which may be required by the Division of Water Quality or
permits required by the Division of Land Resources, Coastal Area Management Act or any other
Federal or Local governmental permit that may be required.
If you have any questions or comments concerning this permit, contact Kelly Johnson at [phone] x
376 or [e-mail]
ItECEIVEID
DEC 1 1 2007
BY: -
North Carolina Division of Wader Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Sincerely,
for Coleen H. Sullins, Director
[phone]
FAX [phone]
On the Internet at http://h2o.enr.state.nc-us/

Mr. K Michael Johnson 40
Leland Land, LLC
Permit No. NCS000222
Page 2.
•
cc: Wilmington -Regional Office, Linda -Willis
Mr. Michael Rouse, Carolina Pole Leland, Inc., 1901 Wood 'Treatment Rd., Leland, NC 28451
Storznwater Permitting Unit files
Central Files
Attachments
2

•
0 NCS000222
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE STORMWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Leland Land, LLC
is hereby authorized to discharge stormwater from a facility located at
Carolina Pole Leland, Inc.
1901 Wood Treatment Road
Leland, NC
Brunswick County
to receiving waters designated as Alligator Branch and Sturgeon Creek, both are class C, SW
streams in the Cape Fear River Basin, in accordance with the discharge limitations, monitoring
requirements, and other conditions set forth in Parts 1, 11,111, IV, V and VI hereof.
This permit shall become effective January 1, 2008.
This permit and the authorization to discharge shall expire at midnight on December 31, 2012.
Signed this 7t` day of December 2007.
for Coleen H. Sullins., Director
Division of Water Quality
By the Authority of the Environmental Management Commission

0 0 Permit No, NCS000222
PART
Section A:
Section B:
Section C:
PART II
TABLE OF CONTENTS
INTRODUCTION
Individual Permit Coverage
Permitted Activities
Location Map
MONITORING, CONTROLS, AND LIMITATIONS FOR PERMITTED
DISCHARGES
Section A:
Stormwater Pollution Prevention Plan
Section B:
Analytical Monitoring Requirements
Section C:
Qualitative Monitoring Requirements
Section D:
On -Site Vehicle Maintenance Monitoring Requirements
PART III STANDARD CONDITIONS FOR NPDES STORMWATER INDIVIDUAL
PERMITS
Section A: Compliance and Liability
1. Compliance Schedule
2. Duty to Comply
3. Duty to Mitigate
4. Civil and Criminal Liability
S. Oil and Hazardous Substance Liability
6. Property Rights
7. Severability
8. Duty to Provide Information
9. Penalties for Tampering
10. Penalties for Falsification of Reports
Section B: General Conditions
1. Individual Permit Expiration
2. Transfers
8

Permit No. NCS000222
3. Signatory Requirements
4. Individual Permit Modification, Revocation and Reissuance, or
Termination
5. Permit Actions
Section C: Operation and Maintenance of Pollution Controls
1. Proper Operation and Maintenance
2. Need to Halt or Reduce Not a Defense
3. Bypassing of Stormwater Control Facilities
Section D: Monitoring and Records
1.
Representative Sampling
2.
Recording Results
3.
Flow Measurements
4.
Test Procedures
5.
Representative Outfall
6.
Records Retention
7.
Inspection and Entry
Section E: Reporting Requirements
1.
Discharge Monitoring Reports
2.
Submitting Reports
3.
Availability of Reports
4.
Non-Stormwater Discharges
5.
Planned Changes
6.
Anticipated Noncompliance
7.
Bypass
8.
Twenty-four Hour Reporting
9.
Other Noncompliance
10.
Other Information
PART N LIMITATIONS REOPENER
PART V ADMINISTERING AND COMPLIANCE MONITORING FEE
REQUIREMENTS
PART VI DEFINITIONS
ii

•
0 Permit No. NCS000222
PART I INTRODUCTION
During the period beginning on the effective date of the permit and lasting until expiration, the
permittee is authorized to discharge stormwater associated with industrial activity. Such
discharges shall be controlled, limited and monitored as specified in this permit.
SECTION B: PERMITTED ACTIVITIES
Until this permit expires or is modified or revoked, the permittee is authorized to discharge
stormwater to the surface waters of North Carolina or separate storm sewer system that has been
adequately treated and managed in accordance with the terms and conditions of this individual
permit. All discharges shall be in accordance with the conditions of this permit.
Any other point source discharge to surface waters of the state is prohibited unless it is an
allowable non-stormwater discharge or is covered by another permit, authorization or approval.
The discharges allowed by this individual permit shall not cause or contribute to violations of
Water Quality Standards.
This permit does not relieve the permittee from responsibility for compliance with any other
applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or decree.
Part I Page I of 2

SECTION C: LOCATION MAP* Permit No. NCS000222
'N.
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I biooh er
Y
7--
Carolina Pole 4, -7,
Leland, Inc.
t
as so
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;TNAW IVA
Ni:_ t
PW
t
IMPA
Cb
Flat
Latitude. 341"15'25" N NCS000222 Facili
Longitude: 78104'31"W ty
County: Brunswick Leland Land, LLC Location
Stream Class: C, SW (both streams)
Receiving Stream: Alligator Branch and Sturgeon Creek
Sub -basin. 03-06-17 (CapeFearRiver Basin) dvatt/1 NOT TOICAU
Part I Page 2 of 2

•
• Permit No. NCS000222
PART II MONITORING, CONTROLS, AND LIMITATIONS FOR
PERMITTED DISCHARGES
SECTION A: STORMWATER POLLUTION PREVENTION PLAN
The permittee shall develop a Stormwater Pollution Prevention Plan, herein after referred to as
the Plan. This Plan shall be considered public information in accordance with Part III, Standard
Conditions, Section E, Paragraph 3 of this individual permit. The Plan shall include, at a
minimum, the following items:
l . Site Plan. The site plan shall provide a description of the physical facility and the
potential pollutant sources that may be expected to contribute to contamination of
stormwater discharges. The site plan shall contain the following:
a. A general location map (USGS quadrangle map or appropriately drafted
equivalent map), showing the facility's location in relation to transportation
routes and surface waters, the name of the receiving water(s) to which the
stormwater outfall(s) discharges, or if the discharge is to a municipal separate
storm sewer system, the name of the municipality and the ultimate receiving
waters; and accurate latitude and longitude of the point(s) of discharge.
b. A narrative description of storage practices, loading and unloading activities,
outdoor, process areas, dust or particulate generating or control processes, and
waste disposal practices.
A site map drawn to scale with the following items:
(1) Distance legend and north arrow
(2) Location of industrial activities (including storage of materials,
disposal areas, process areas and loading and unloading areas)
(3) Drainage structures
(4) Delineated drainage areas for each outfall
(5) Drainage area for each outfall in acres and percentage of
each drainage area that is impervious
(6) Building locations
(7) Existing BMPs and impervious surfaces
(8) For each outfall, a narrative description of the potential pollutants that
could be expected to be present in the stormwater discharge.
d. A list of significant spills or leaks of pollutants that have occurred at the facility
during the 3 previous years and any corrective actions taken to mitigate spill
impacts.
e. Certification that the stormwater outfalls have been evaluated for the presence of
non-stormwater discharges. The certification statement will be signed in
accordance with the requirements found in Part III, Standard Conditions, Section
B, Paragraph 3.
Part iI Page 1 of 8

•
0 Permit No. NCS000222
2. Stormwater Management Plan. The stormwater management plan shall contain a
narrative description of the materials management practices employed which control or
minimize the exposure of significant materials to stormwater, including structural and
nonstructural measures. The stormwater management plan, at a minimum, shall
incorporate the following:
Feasibility Study. A review of the technical and economic feasibility of changing
the methods of operations and/or storage practices to eliminate or reduce exposure
of materials and processes to stormwater. Wherever practical, the permittee shall
prevent exposure of all storage areas, material handling operations, and
manufacturing or fueling operations. In areas where elimination of exposure is
not practical, the stormwater management plan shall document the feasibility of
diverting the stormwater runoff away from areas of potential contamination.
b. Secondary Containment Schedule. A schedule to provide secondary containment
for bulk storage of liquid materials, storage of Section 313 of Title III of the
Superfund Amendments and Reauthorization Act (SARA) water priority
chemicals, or storage of hazardous substances to prevent leaks and spills from
contaminating stormwater runoff. If the secondary containment devices are
connected directly to stormwater conveyance systems, the connection shall be
controlled by manually activated valves or other similar devices [which shall be
secured with a locking mechanism] and any stormwater that accumulates in the
containment area shall be at a minimum visually observed for color, foam, outfall
staining, visible sheens and dry weather flow, prior to release of the accumulated
stormwater. Accumulated stormwater shall be released if found to be
uncontaminated by the material stored within the containment area. Records
documenting the individual making the observation, the description of the
accumulated stormwater and the date and time of the release shall be kept for a
period of five years.
C. BMP Summary. A narrative description shall be provided of Best Management
Practices (BMPs) to be considered such as, but not limited to, oil and grease
separation, debris control, vegetative filter strips, infiltration and stormwater
detention or retention, where necessary. The need for structural BMPs shall be
based on the assessment of potential of sources to contribute significant quantities
of pollutants to stormwater discharges and data collected through monitoring of
stormwater discharges.
3. Spill Prevention and Response Plan. The Spill Prevention and Response PIan (SPRP)
shall incorporate an assessment of potential pollutant sources based on a materials
inventory of the facility. Facility personnel (or team) responsible for implementing the
SPRP shall be identified. A responsible person shall be on -site at all times during facility
operations that have the potential to contaminate stormwater runoff through spills or
exposure of materials associated with the facility operations. The SPRP must be site
stormwater specific. Therefore, a SPCC plan may be a component of the SPRP, but may
not be sufficient to completely address the stormwater aspects of the SPRP. The common
elements of the SPCC with the SPRP may be incorporated by reference into the SPRP.
Part II Page 2 of 8

• Permit No. NCS000222
4. Preventative Maintenance and Good Housekeeping Program. A preventative
maintenance program shall be developed. The program shall document schedules of
inspections and maintenance activities of stormwater control systems, plant equipment
and systems. Inspection of material handling areas and regular cleaning schedules of
these areas shall be incorporated into the program.
Employee Training. Training schedules shall be developed and training provided at a
minimum on an annual basis on proper spill response and cleanup procedures and
preventative maintenance activities for all personnel involved in any of the facility's
operations that have the potential to contaminate stormwater runoff. Facility personnel
(or team) responsible for implementing the training shall be identified.
6. Responsible Party. The Stormwater Pollution Prevention Plan shall identify a specific
position(s) responsible for the overall coordination, development, implementation, and
revision to the Plan. Responsibilities for all components of the Plan shall be documented
and position assignments provided.
T Plan Amendment. The permittee shall amend the Plan whenever there is a change in
design, construction, operation, or maintenance that has a significant effect on the
potential for the discharge of pollutants to surface waters. The Stormwater Pollution
Prevention Plan shall be reviewed and updated on an annual basis.
The Director may notify the permittee when the Plan does not meet one or more of the
minimum requirements of the permit. Within 30 days of such notice, the permittee shall
submit a time schedule to the Director for modifying the Plan to meet minimum
requirements. The permittee shall provide certification in writing (in accordance with
Part ID, Standard Conditions, Section B, Paragraph 3) to the Director that the changes
have been made.
8. Facility Inspection Program. Facilities are required to inspect all stormwater systems on
at least a semiannual schedule, once in the fall (September -November) and once in the
spring (April - June). The inspection and any subsequent maintenance activities
performed shall be documented, recording date and time of inspection, individual(s)
making the inspection and a narrative description of the facility's stormwater control
systems, plant equipment and systems. Records of these inspections shall be incorporated
into the Stormwater Pollution Prevention PIan.
Stormwater discharge characteristic monitoring as required in Part II of this permit shall
be performed in addition to facility inspections.
9. Implementation. The permittee shall document all monitoring, measurements,
inspections and maintenance activities and training provided to employees, including the
log of the sampling data and of activities taken to implement BMPs associated with the
industrial activities, including vehicle maintenance activities. Such documentation shall
be kept on -site for a period of five years and made available to the Director or his
authorized representative immediately upon request.
Part II Page 3 of 8

•
• Permit No. NCS000222
SECTION B: ANALYTICAL MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until expiration, the
permittee is authorized to discharge stormwater subject to the provisions of this permit.
Analytical monitoring of stormwater discharges shall be performed as specified below in Table
All analytical monitoring shall be performed during a representative storm event. The required
monitoring will result in a minimum of ten analytical samplings being conducted over the term of
the permit at each stormwater discharge outfall (SDO). The permittee shall complete the
minimum ten analytical samplings in accordance with the schedule specified below in Table 2.
Monitoring results shall be compared to the benchmark values in Table 3. The benchmark
values in Table 3 are not permit limits but should be used as guidelines for the permittee's
Stormwater Pollution Prevention Plan (SPPP). The permittee shall evaluate the sources of any
benchmark exceedances and evaluate the effectiveness of any site BMPs. The permittee shall
review and/or update the SPPP and document any efforts to address stormwater contamination.
Table 1. Analytical Monitoring Requirements
Discharge
Characteristics
Units
Measurement
Fre uenc 1
Sample
Type2
Sample
Locatlon3
Arsenic, total recoverable
m
Semi-annually
Grab
SDO
Copper, total recoverable
m
Semi-annually
Grab
SDO
Chromium, total recoverable
m
Semi-annually
Grab
SDO
Perttachloro henol
m
Semi-annually
Grab
SDO
Phenol
m
Semi-annually
Grab
SDO
Zinc, total recoverable
m
Semi-annually
Grab
SDO
Benzene
m
Semi-annually
Grab
SDO
Toluene
m
Semi-annually
Grab
SDO
Na thalene
m
Semi-annually
Grab
SDO
Anthracene
m
Semi-annually
Grab
SDO
Total Ammonia
m
Semi-annually
Grab
SDO
Total X lenes
Mal
Semi-annually
Grab
SDO
Oil and Grease
m
Semi-annually
Grab
SDO
Biological Oxygen Demand,
5-da BODS)
mg/L
Semi-annually
Grab
SDO
Chemical Oxygen Demand
(COD)
mg/L
Semi-annually
Grab
SDO
Total Phosphorus
mgfL
Semi-annually
Grab
SDO
Total Suspended Solids (TSS)
m
Semi-annually
Grab
SDO
Part II Page 4 of 8

•
• Permit No, NCS000222
Total Kjeldahl Nitrogen
T
mg/L
Semi-annually
Grab
SDO
Dioxin
m
Semi-annually
Grab
SDO
H
Standard
Semi-annually
Grab
SDO
Total Rainfall
inches
Semi -Annually
Rainfall Event Duration
minutes
Semi -Annually
Footnotes:
t Measurement Frequency: All monitoring will be performed two times per year for each year until either another
permit is issued for this facility or until this permit is revoked or rescinded. If at the end of this permitting cycle,
the permittee has submitted the appropriate paperwork for a renewal permit before the submittal deadline, the
permittee will be considered for a renewal permit. The applicant must continue semi-annual monitoring until the
renewed permit is issued. See Table 2 for schedule of monitoring periods through the end of this permitting cycle.
2 If the stormwater runoff is controlled by a stormwater detention pond, a grab sample of the discharge from the
pond shall be collected within the first 30 minutes of discharge. If the detention pond discharges only in response
to a storm event exceeding a ten year design storm, then no analytical monitoring is required and only qualitative
monitoring shall be performed.
3 Sample Location: Samples shall be collected at each stormwater discharge outfall (SDO) unless representative
outfall status has been granted.
Table 2. Monitoring Schedule
Monitoring period
Sample Number
Start
End
Year 1 - Spring
1
April 1, 2008
June 30, 2008
Year l --- Fall
2
September 1, 2008
November 30, 2008
Year 2 — Spring
3
April 1, 2009
June 30, 2009
Year 2 — Fall
4
September 1, 2009
November 30, 2009
Year 3 — Spring
5
April 1, 2010
June 30, 2010
Year 3 — Fall
6
September 1, 2010
November 30, 2010
Year 4 — Spring
7
April 1, 2011
June 30, 2011
Year 4 — Fall
8
September 1, 2011
November 30, 2011
Year 5 — Spring
9
April 1, 2012
June 30, 2012
Year 5 — Fall
10
September 1, 2012
November 30, 2012
Footnotes:
I Maintain semi-annual monitoring during permit renewal process.
Part If Page 5 of 8

0 Permit No. NCS000222
Table 3. Benchmark Values for Analytical Monitoring
Discharge Characteristics
Units
Benchmark
Arsenic, total recoverable
mg/L
0.36
Copper, total recoverable
mg/L
0.007
Chromium, total recoverable
mg/L
1
Pentachlorophenol
mg/L
0.019
Phenol
mg/L
4.5
Zinc, total recoverable
mg/L
0.067
Benzene
mg/L
6.7
Toluene
mg/L
0.055
Napthalene
mg/L
1
Anthracene
mg/L
0.005
Ammonia, total as nitrogen
mg/L
7•2
Xylenes, total
mg/L
6.7
Oil and Grease
mg/L
30
Biological Oxygen Demand, 5-
day OD
mg/L
30
Chemical Oxygen Demand
mg/L
120
Phosphorus, total
mg/L
2
Total Suspended Solids (TSS)
mg/L
100
Total Kjeldahl Nitrogen (TKN)
mg/L
20
Dioxin
mg/L
Any Detection
pH
Standard
-6-9
ra
If additional BMPs are needed to achieve the required level of control, the Permittee will be
required to (1) develop a strategy for implementing appropriate BMPs, and (2) submit a timetable
for incorporation of those BMPs into the permitted Stormwater Pollution Prevention Plan_
SECTION C: QUALITATIVE MONITORING REQUIREMENTS
Qualitative monitoring requires a visual inspection of each stormwater outfall regardless of
representative outfall status and shall be performed as specified below in Table 4. Qualitative
monitoring is for the purpose of evaluating the effectiveness of the Stormwater Pollution
Prevention Plan (SPPP) and assessing new sources of stormwater pollution. No analytical tests
are required. Qualitative monitoring of stormwater outfalls is performed when stormwater
discharge occurs but does not need to be performed during a representative storm event.
Part U Page 6 of 8

•
• Permit No. NCS000222
In the event an atypical condition is noted at a stormwater discharge outfall, the Permittee shall
document the suspected cause of the condition and any actions taken in response to the
discovery. This documentation will be maintained with the Stormwater Pollution Prevention
PIan.
All qualitative monitoring will be performed twice per year, once in the spring (April - June) and
once in the fall (September - November).
Table 4. Qualitative Monitoring Requirements
Discharge Characteristics
Frequency
Monitoring
Locationt
Color
Semi-annually
SDO
Odor
Semi-annually
SDO
Clarity
Semi-annually
SDO
Floating Solids
Semi-annually
SDO
Suspended Solids
Semi-annually
SDO
Foam
Semi-annually
SDO
Oil Sheen
Semi-annual)
SDO
Other obvious indicators
of stormwater ollution
Semi-annually
SDO
Footnotes:
1 Measurement Frequency: All monitoring will be performed two times per year for each year until either another
permit is issued for this facility or until this permit is revoked or rescinded. If at the end of this permitting cycle,
the permittee has submitted the appropriate paperwork for a renewal permit before the submittal deadline, the
permittee will be considered for a renewal permit. The applicant must continue semi-annual monitoring until the
renewed permit is issued. See Table 2 for schedule of monitoring periods through the end of this permitting cycle.
SECTION D: ON -SITE VEHICLE MAINTENANCE MONITORING REQUIREMENTS
Facilities which have any vehicle maintenance activity occurring on -site which uses more than 55
gallons of new motor oil per month when averaged over the calendar year shall perform
analytical monitoring as specified below in Table 5. This monitoring shall be performed at all
outfalls which discharge stormwater runoff from vehicle maintenance areas.
All analytical monitoring shall be performed during a representative storm event. The required
monitoring will result in a minimum of ten analytical samplings being conducted over the term of
the permit at each stormwater discharge outfall (SDO) which discharges stormwater runoff from
vehicle maintenance areas. The permittee shall complete the minimum ten analytical samplings
in accordance with the schedule specified in Table 2 (Section B).
Monitoring results shall be compared to the benchmark values in Table 6. The benchmark
values in Table 6 are not permit limits but should be used as guidelines for the permittee's
Stormwater Pollution Prevention Plan (SPPP). The permittee shall evaluate the sources of any
Part II Page 7 of 8

0 Permit No. NCS000222
benchmark exceedances and evaluate the effectiveness of any site BMPs. The permittee shall
review and/or update the SPPP and document any efforts to address stormwater contamination.
Table 5. Analytical Monitoring Requirements for On -Site Vehicle Maintenance
Discharge Characteristics
Units
Measurement
Frequencyl
Sample
Type2
Sample
Location
H
standard
Semi-annually
Grab
SDO
Oil and Grease
m
Semi-annually
Grab
SDO
Total suspended Solids
mg/L
Semi-annually
Grab
SDO
New Motor Oil Usagegallons/month
Semi-annually
Estimate
-
Total Rainfall
inches
Semi-annually
Rainfall Event Duration
minutes
Semi-annually
Footnotes:
I Measurement Frequency: All monitoring will be performed two times per year for each year until either another
permit is issued for this facility or until this permit is revoked or rescinded. If at the end of this permitting cycle,
the permittee has submitted the appropriate paperwork for a renewal permit before the submittal deadline, the
permittee will be considered for a renewal permit. The applicant must continue semi-annual monitoring until the
renewed permit is issued. See Table 2 for schedule of monitoring periods through the end of this permitting cycle.
2 If the stormwater runoff is controlled by a stormwater detention pond, a grab sample of the discharge from the
pond shall be collected within the first 30 minutes of discharge. If the detention pond discharges only in response
to a storm event exceeding a ten year design storm, then no analytical monitoring is required and only qualitative
monitoring shall be performed.
3 Sample Location. Samples shall be collected at each stormwater discharge outfall (SDO) that discharges
stormwater runoff from area(s) where vehicle maintenance activities occur.
Table 6. Benchmark Values for Vehicle Maintenance Analytical Monitoring
Discharge Characteristics
Units
Benchmark
pH
standard
6-9
Oil and Grease
mg/L
.30
Total Suspended Solids
mg/L
100
Part II Page 8 of 8

•
0 Permit No. NCS000222
PART Ill STANDARD CONDITIONS FOR NPDES STORMWATER INDIVIDUAL PERMITS
SECTION A: COMPLIANCE AND LIABILITY
Compliance Schedule
The permittee shall comply with Limitations and Controls specified for sormwater discharges in
accordance with the following schedule.
Existing Facilities: The Stormwater Pollution Prevention Plan shall be developed and implemented within
12 months of the effective date of the initial permit and updated thereafter on an annual basis. Secondary
containment, as specified in Part 11, Section A, Paragraph 2(b) of this permit, shall be accomplished within
12 months of the effective date of the initial permit issuance.
Proposed Facilities: The Stormwater Pollution Prevention Plan shall be developed and implemented prior to
the beginning of discharges from the operation of the industrial activity and be updated thereafter on an
annual basis. Secondary containment, as specified in Part I1, Section A, Paragraph 2(b) of this permit shall
be accomplished prior to the beginning of discharges from the operation of the industrial activity.
2. Duly to Comaty
The permittee must comply with all conditions of this individual permit. Any permit noncompliance
constitutes a violation of the Clean Water Act and is grounds for enforcement action; for permit
termination, revocation and reissuance, or modification; or denial of a permit upon renewal application.
a. The permittee shall comply with standards or prohibitions established under section 307(a) of the
Clean Water Act for toxic pollutants within the time provided in the regulations that establish these
standards or prohibitions, even if the permit has not yet been modified to incorporate the
requirement.
The Clean Water Act provides that any person who violates a permit condition is subject to a civil
penalty not to exceed $27,500 per day for each violation. Any person who negligently violates any
permit condition is subject to criminal penalties of $2,500 to $25,000 per day of violation, or
imprisonment for not more than I year, or both. Any person who knowingly violates permit
conditions is subject to criminal penalties of$5,000 to $50,000 per day of violation, or
imprisonment for not more than 3 years, or both. Also, any person who violates a permit condition
may be assessed an administrative penalty not to exceed $11,000 per violation with the maximum
amount not to exceed $137,500. [Ref: Section 309 of the Federal Act 33 USC 1319 and 40 CFR
122.4 t (a).]
C. Under state law, a daily civil penalty of not more than twenty-five thousand dollars ($25,000) per
violation may be assessed against any person who violates or fails to act in accordance with the
terms, conditions, or requirements of a permit. [Ref: North Carolina General Statutes 143-
215.6A]
d. Any person may be assessed an administrative penalty by the Director for violating section 301,
302, 306, 307, 308, 318, or 405 of the Act, or any permit condition or limitation implementing any
of such sections in a permit issued under section 402 of the Act. Administrative penalties for Class
1 violations are not to exceed $11,000 per violation, with the maximum amount of any Class 1
penalty assessed not to exceed $27,500. Penalties for Class 11 violations are not to exceed $11,000
per day for each day during which the violation continues, with the maximum amount of any Class
lI penalty not to exceed $137,500.
Part Ill Page 1 of 8

•
0 Permit No. NCS000222
Duty to Mitigate
The permittee shall take all reasonable steps to minimize or prevent any discharge in violation of this
individual permit which has a reasonable likelihood of adversely affecting human health or the environment.
4. Civil and Criminal Liability
Except as provided in Part III, Section C of this permit regarding bypassing of stormwater control facilities,
nothing in this individual permit shall be construed to relieve the permittee from any responsibilities,
liabilities, or penalties for noncompliance pursuant to NCGS 143-215.3, 143-215,6A, 143-215.613, 143-
215.6C or Section 309 of the Federal Act, 33 USC 1319. Furthermore, the permittee is responsible for
consequential damages, such as fish kills, even though the responsibility for effective compliance may be
temporarily suspended.
5. Oil and Hazardous Substance Liability
Nothing in this individual permit shall be construed to preclude the institution of any legal action or relieve
the permittee from any responsibilities, liabilities, or penalties to which the permittee is or may be subject to
under NCGS 143-215.75 et seq: or Section 311 of the Federal Act, 33 USC 1321.
6. Propelly Rights
The issuance of this individual permit does not convey any property rights in either real or personal
property, or any exclusive privileges, nor does it authorize any injury to private property or any invasion of
personal rights, nor any infringement of Federal, Stale or local laws or regulations.
7. Severability
The provisions of this individual permit are severable, and if any provision of this individual permit, or the
application of any provision of this individual permit to any circumstances, is held invalid, the application
of such provision to other circumstances, and the remainder of this individual permit, shall not be affected
thereby.
S. Duty to Provide Information
The permittee shall furnish to the Director, within a reasonable time, any information which the Director
may request to determine whether cause exists for modifying, revoking and reissuing, or terminating the
permit issued pursuant to this individual permit or to determine compliance with this individual permit. The
permittee shall also furnish to the Director upon request, copies of records required to be kept by this
individual permit.
9. Penalties for Tampering
The Clean Water Act provides that any person who falsifies, tampers with, or knowingly renders inaccurate,
any monitoring device or method required to be maintained under this individual permit shall, upon
conviction, be punished by a fine of not more than $10,000 per violation, or by imprisonment for not more
than two years per violation, or by both. If a conviction of a person is for a violation committed after a first
conviction of such person under this paragraph, punishment is a fine of not more that $20,000 per day of
violation, or by imprisonment of not more than 4 years, or both.
10. Penalties for Falsification of Reports
The Clean Water Act provides that any person who knowingly makes any false statement, representation, or
certification in any record or other document submitted or required to be maintained under this individual
Part III Page 2 of 8

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0 Permit No. NCS000222
permit, including monitoring reports or reports of compliance or noncompliance shall, upon conviction, be
punished by a fine of not more than $10,000 per violation, or by imprisonment for not more than two years
per violation, or by both.
SECTION B: GENERAL CONDITIONS
Individual Permit Expiration
The permittee is not authorized to discharge after the expiration date. In order to receive automatic
authorization to discharge beyond the expiration date, the permittee shall submit forms and fees as are
required by the agency authorized to issue permits no later than 180 days prior to the expiration date. Any
permittee that has not requested renewal at least 180 days prior to expiration, or any permittee that does not
have a permit after the expiration and has not requested renewal at least 180 days prior to expiration, will be
subjected to enforcement procedures as provided in NCGS § 143-2153.6 and 33 USC 1251 et. seq.
2. Transfers
This permit is not transferable to any person except after notice to and approval by the Director. The
Director may require modification or revocation and reissuance of the permit to change the name and
incorporate such other requirements as may be necessary under the Clean Water Act. Permittee is required
to notify the Division in writing in the event the permitted facility is sold or closed.
Signatory Requirements
All applications, reports, or information submitted to the Director shall be signed and certified.
a. All applications to be covered under this individual permit shall be signed as follows:
(1) Fora Corporation: by a responsible corporate officer. For the purpose of this Section, a
responsible corporate officer means: (a) a president, secretary, treasurer or vice president
of the corporation in charge of a principal business function, or any other person who
performs similar policy or decision making functions for the corporation, or (b) the
manager of one or more manufacturing production or operating facilities employing more
than 250 persons or having gross annual sales or expenditures exceeding 25 million (in
second quarter 1980 dollars), if authority to sign documents has been assigned or
delegated to the manager in accordance with corporate procedures.
(2) For a partnership or sole proprietorship: by a general partner or the proprietor,
respectively; or
(3) For a municipality, State, Federal, or other public agency: by either a principal executive
officer or ranking elected official.
b. All reports required by the individual permit and other information requested by the Director shall
be signed by a person described above or by a duly authorized representative of that person. A
person is a duly authorized representative only if:
(1) The authorization is made in writing by a person described above;
(2) The authorization specified either an individual or a position having responsibility for the
overall operation of the regulated facility or activity, such as the position of plant
manager, operator of a well or well field, superintendent, a position of equivalent
responsibility, or an individual or position having overall responsibility for environmental
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0 Permit No. NCS000222
matters for the company. (A duly authorized representative may thus be either a named
individual or any individual occupying a named position.); and
(3) The written authorization is submitted to the Director.
Any person signing a document under paragraphs a. or b. of this section shall make the following
certification:
"1 certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate,
and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fines and imprisonment for knowing violations."
4. Individual Permit Modification, Revocation and Reissuance, or Termination
The issuance of this individual permit does not prohibit the Director from reopening and modifying the
individual permit, revoking and reissuing the individual permit, or terminating the individual permit as
allowed by the laws, rules, and regulations contained in Title 40, Code of Federal Regulations, Parts 122
and 123; Title 15A of the North Carolina Administrative Code, Subchapter 2H .0100; and North Carolina
General Statute 143-215.1 et. al.
Permit Actions
The permit may be modified, revoked and reissued, or terminated for cause. The notification of planned
changes or anticipated noncompliance does not stay any individual permit condition.
SECTION C: OPERATION AND MAINTENANCE OF POLLUTION CONTROLS
Proper Operation and Maintenance
The permittee shall at all times properly operate and maintain all facilities and systems of treatment and
control (and related appurtenances) which are installed or used by the permittee to achieve compliance with
the conditions of this individual permit. Proper operation and maintenance also includes adequate
laboratory controls and appropriate quality assurance procedures. This provision requires the operation of
back-up or auxiliary facilities or similar systems which are installed by a permittee only when the operation
is necessary to achieve compliance with the conditions of this individual permit.
2. Need to Halt or Reduce Not a Defense
It shall not be a defense for a permittee in an en€orcement action that it would have been necessary to halt or
reduce the permitted activity in order to maintain compliance with the condition of this individual permit.
3. Bwassinyoof Stormwater Control Facilities
Bypass is prohibited and the Director may take enforcement action against a permittee for bypass unless:
a. Bypass was unavoidable to prevent loss of life, personal injury or severe property damage; and
b. There were no feasible alternatives to the bypass, such as the use of auxiliary control facilities,
retention of stormwater or maintenance during normal periods of equipment downtime or dry
Part III Page 4 of 8

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0 Permit No. NCSO00222
weather. This condition is not satisfied if adequate backup controls should have been installed in
the exercise of reasonable engineering judgment to prevent a bypass which occurred during normal
periods of equipment downtime or preventive maintenance; and
C. The permittce submitted notices as required under, Part III, Section E of this permit.
if the Director determines that it will meet the three conditions listed above, the Director may approve an
anticipated bypass after considering its adverse effects.
SECTION D: MONITORING AND RECORDS
Representative Sampling
Samples collected and measurements taken, as required herein, shall be characteristic of the volume and
nature of the permitted discharge. Analytical sampling shall be performed during a representative storm
event. Samples shall be taken on a day and time that is characteristic of the discharge. All samples shall be
taken before the discharge joins or is diluted by any other waste stream, body of water, or substance.
Monitoring points as specified in this permit shall not be changed without notification to and approval of
the Director.
Recording Results
For each measurement, sample, inspection or maintenance activity performed or collected pursuant to the
requirements of this individual permit, the permittee shall record the following information:
a. The date, exact place, and time of sampling, measurements, inspection or maintenance activity;
b. The individual(s) who performed the sampling, measurements, inspection or maintenance activity;
c. The date(s) analyses were performed;
d. The individual(s) who performed the analyses;
C. The analytical techniques or methods used; and
The results of such analyses.
3. Flow Measurements
Where required, appropriate flow measurement devices and methods consistent with accepted scientific
practices shalt be selected and used to ensure the accuracy and reliability of measurements of the volume of
monitored discharges.
4. Test Procedures
Test procedures for the analysis of pollutants shall conform to the EMC regulations published pursuant to
NCGS 143-215.63 et. seq, the Water and Air Quality Reporting Acts, and to regulations published pursuant
to Section 304(g), 33 USC 1314, of the Federal Water Pollution Control Act, as Amended, and Regulation
40 CFR 136.
To meet the intent of the monitoring required by this individual permit, all test procedures must produce
minimum detection and reporting levels and all data generated must be reported down to the minimum
detection or lower reporting level of the procedure.
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0 Permit No, NCS000222
Representative Outfall
If a facility has multiple discharge locations with substantially identical stormwater discharges that are
required to be sampled, the permittee may petition the Director for representative outfall status. If it is
established that the stormwater discharges are substantially identical and the permittee is granted
representative outfall status, then sampling requirements may be performed at a reduced number of outfalis.
6. Records Retention
Visual monitoring shall be documented and records maintained at the facility along with the Stormwater
Pollution Prevention Plan. Copies of analytical monitoring results shall also be maintained on -site. The
permittee shall retain records of all monitoring information, including all calibration and maintenance
records and all original strip chart recordings for continuous monitoring instrumentation, and copies of all
reports required by this individual permit for a period of at least 5 years from the date of the sample,
measurement, report or application. This period may be extended by request of the Director at any time.
Inspection and Entev
The permittee shall allow the Director, or an authorized representative (including an authorized contractor
acting as a representative of the Director), or in the case of a facility which discharges through a municipal
separate storm sewer system, an authorized representative of a municipal operator or the separate storm
sewer system receiving the discharge, upon the presentation of credentials and other documents as may be
required by law, to;
a. Enter upon the permittee's premises where a regulated facility or activity is located or conducted,
or where records must be kept under the conditions of this individual permit;
b. Have access to and copy, at reasonable times, any records that must be kept under the conditions of
this individual permit;
C. Inspect at reasonable times any facilities, equipment (including monitoring and control equipment),
practices, or operations regulated or required under this individual permit; and
d. Sample or monitor at reasonable times, for the purposes of assuring individual permit compliance
or as othcrwise authorized by the Clean Water Act, any substances or parameters at any location.
SECTION E: REPORTING REQUMEMENTS
1. Discharge Monitoring Reports
Samples analyzed in accordance with the terms of this permit shall be submitted to the Division on
Discharge Monitoring Report forms provided by the Director. Submittals shall be received by the Division
no later than 30 days from the date the facility receives the sampling results from the laboratory.
Submitting -Reports
Duplicate signed copies of all reports required herein, shall be submitted to the following address:
Division of Water Quality
Surface Water Protection Section
ATTENTION: Central Piles
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Part Ill Page 6 of 8

E
Permit No. NCSOD0222
Availabili of Rgports
Except for data determined to be confidential under NCGS 143-215.3(a)(2) or Section 308 of the Federal
Act, 33 USC 1318, all reports prepared in accordance with the terms shall be available for public inspection
at the offices of the Division of Water Quality. As required by the Act, analytical data shall not be
considered confidential. Knowingly making any false statement on any such report may result in the
imposition of criminal penalties as provided for in NCGS 143-215.613 or in Section 309 of the Federal Act.
4. Non-Stormwater Discharges
If the storm event monitored in accordance with this individual permit coincides with a non-stormwater
discharge, the permittee shall separately monitor all parameters as required under the non-stormwater
discharge permit and provide this information with the stormwater discharge monitoring report.
Planned Changes
The permittee shall give notice to the Director as soon as possible of any planned changes at the permitted
facility which could significantly alter the nature or quantity of pollutants discharged. This notification
requirement includes pollutants which are not specifically listed in the individual permit or subject to
notification requirements under 40 CFR Part 122.42 (a).
Anticipated Noncompliance
The perrittee shall give notice to the Director as soon as possible of any planned changes at the permitted
facility which may result in noncompliance with the individual permit requirements.
7. Bypass
a. Anticipated bypass. If the permittee knows in advance of the need for a bypass, it shall submit
prior notice, if possible at least ten days before the date of the bypass; including an evaluation of
the anticipated quality and affect of the bypass.
b. Unanticipated bypass. The permittee shall submit notice within 24 hours of becoming aware of an
unanticipated bypass.
8. Twenty-four Hour Reporting
The permittee shall report to the central office or the appropriate regional office any noncompliance which
may endanger health or the environment. Any information shall be provided orally within 24 hours from
the time the permittee became aware of the circumstances. A written submission shall also be provided
within 5 days of the time the permittee becomes aware of the circumstances.
The written submission shall contain a description of the noncompliance, and its causes; the period of
noncompliance, including exact dates and times, and if the noncompliance has not been corrected, the
anticipated time compliance is expected to continue; and steps taken or planned to reduce, eliminate, and
prevent reoccurrence of the noncompliance.
The Director may waive the written report on a case -by -case basis if the oral report has been received
within 24 hours.
Other Noncompliance
The permittee shall report all instances of noncompliance not reported under 24 hour reporting at the time
monitoring reports are submitted.
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0 Permit No. NCS000222
10. Other Information
Where the permittee becomes aware that it failed to submit any relevant facts in an application for an
individual permit or in any report to the Director, it shall promptly submit such facts or information.
Part III Page 8 of 8

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0 NCS000222
PART IV LIMITATIONS REOPENER
This individual permit shall be modified or alternatively, revoked and reissued, to comply with any applicable
effluent guideline or water quality standard issued or approved under Sections 302(b) (2) (c), and (d), 304(b) (2) and
307(a) of the Clean Water Act, if the effluent guideline or water quality standard so issued or approved:
Contains different conditions or is otherwise more stringent than any effluent limitation in the individual
permit; or
b. Controls any pollutant not limited in the individual permit.
The individual permit as modified or reissued under this paragraph shall also contain any other requirements in the
Act then applicable.
PART V ADMINISTERING AND COMPLIANCE MONITORING FEE
REQUMEMENTS
The permittee must pay the administering and compliance monitoring fee within 30 (thirty) days after being billed by
the Division. Failure to pay the fee in timely manner in accordance with 15A NCAC 2H .0105(b)(4) may cause this
Division to initiate action to revoke the Individual Permit.
PART VI DEFINITIONS
Act
See Clean Water Act.
2. Arithmetic Mean
The arithmetic mean of any set of values is the summation of the individual values divided by the number of
individual values.
3. Allowable Non-Stormwater Discharges
This permit regulates stormwater discharges. Non-stormwater discharges which shall be allowed in the
stormwater conveyance system are:
(a) All other discharges that are authorized by a non-stormwater NPDES permit.
(b) Uncontaminated groundwater, foundation drains, air -conditioner condensate without added
chemicals, springs, discharges of uncontaminated potable water, waterline and fire hydrant
flushings, water from footing drains, flows from riparian habitats and wetlands.
(c) Discharges resulting from fire -fighting or fire -fighting training.
4. Best Mana-gement Practices (BMPs)
Measures or practices used to reduce the amount of pollution entering surface waters. BMPs may take the
form of a process, activity, or physical structure.
Parts 1V, V and Vl Page 1 of 5

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0 Permit No. NCS000222
Bypass
A bypass is the known diversion of stormwater from any portion of a stormwater control facility including
the collection system, which is not a designed or established operating mode for the facility.
Bulk Storage of Liquid Products
Liquid raw materials, manufactured products, waste materials or by-products with a single above ground
storage container having a capacity of greater than 660 gallons or with multiple above ground storage
containers located in close proximity to each other having a total combined storage capacity of greater than
1,320 gallons.
7. Clean Water Act
The Federal Water Pollution Control Act, also known as the Clean Water Act (CWA), as amended, 33
USC 1251, et. seq.
Division or DW
The Division of Water Quality, Department of Environment and Natural Resources.
Director
The Director of the Division of Water Quality, the permit issuing authority.
10. EMC
The North Carolina Environmental Management Commission.
11. Grab Sample
An individual sample collected instantaneously. Grab samples that will be directly analyzed or qualitatively
monitored must be taken within the first 30 minutes of discharge-
12. Hazardous Substance
Any substance designated under 40 CFR Part 116 pursuant to Section 311 of the Clean Water Act.
13, Landfill
A disposal facility or part of a disposal facility where waste is placed in or on land and which is not a land
treatment facility, a surface impoundment, an injection well, a hazardous waste long-term storage facility or
a surface storage facility.
14. Municipal Separate Storm Sewer System
A storniwater collection system within an incorporated area of local self-government such as a city or town.
is, Overburden
Any material of any nature, consolidated or unconsolidated, that overlies a mineral deposit, excluding
topsoil or similar naturally -occurring surface materials that are not disturbed by mining operations.
Part VI Page 2 of 5 Pages

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0 Permit No. NCS000222
16. Permittee
The owner or operator issued a permit pursuant to this individual permit.
17. Point Source. Discharge of Storrn_water
Any discernible, confined and discrete conveyance including, but not specifically limited to, any pipe, ditch,
channel, tunnel, conduit, well, or discrete fissure from which stormwater is or may be discharged to waters
of the state.
18. Representative Storm Event
A storm event that measures greater than 0.1 inches of rainfall and that is preceded by at least 72 hours in which no
storm event measuring greater than 0.1 inches has occurred. A single storm event may contain up to 10 consecutive
hours of no precipitation. For example, if it rains for 2 hours without producing any collectable discharge, and then
stops, a sample may be collected if a rain producing a discharge begins again within the next 10 hours.
19. Representative ©utfall Status
When it is established that the discharge of stormwater runoff from a single outfall is representative of the
discharges at multiple outfalls, the DWQ may grant representative outfall status. Representative outfall
status allows the permittee to perform analytical monitoring at a reduced number of outfalls.
20. Rinse Water Discharge
The discharge of rinse water from equipment cleaning areas associated with industrial activity. Rinse
waters from vehicle and equipment cleaning areas are process wastewaters and do not include washwaters
utilizing any type of detergent or cleaning agent.
21. Secondary Containment
Spill containment for the contents of the single largest tank within the containment structure plus sufficient
freeboard to allow for the 25-year, 24-hour storm event.
22. Section 313 Water Priority Chemical
A chemical or chemical category which:
a. Is listed in 40 CFR 372.65 pursuant to Section 313 of Title III of the Superfund Amendments and
Reauthorization Act (SARA) of 1986, also titled the Emergency Planning and Community Right -
to -Know Act of 1986;
b. Is present at or above threshold levels at a facility subject to SARA Title III, Section 313 reporting
requirements; and
C. That meet at least one of the following criteria:
(1) Is listed in Appendix D of 40 CFR part 122 on either Table II (organic priority
pollutants), Table III (certain metals, cyanides, and phenols) or Table IV (certain toxic
pollutants and hazardous substances);
(2) . Is listed as a hazardous substance pursuant to section 31 t (b)(2)(A) of the CWA at 40
CFR 1 I6.4; or
(3) Is a pollutant for which EPA has published acute or chronic water quality criteria.
Part VI Page 3 of 5 Pages

M
• Permit No. NCS000222
23. Severe Property Damage
Means substantial physical damage to property, damage to the control facilities which causes them to
become inoperable, or substantial and permanent loss of natural resources which can reasonably be
expected to occur in the absence of a bypass. Severe property damage does not mean economic loss caused
by delays in production.
24. Significant Materials
Includes, but is not limited to; raw materials; fuels; materials such as solvents, detergents, and plastic
pellets; finished materials such as metallic products; raw materials used in food processing or production;
hazardous substances designated under section 101(14) of CERCLA; any chemical the facility is required to
report pursuant to section 313 of Title IN of SARA; fertilizers; pesticides; and waste products such as ashes,
slag and sludge that have the potential to be released with stormwater discharges.
25. Significant Spills
Includes, but is not limited to: releases of oil or hazardous substances in excess of reportable quantities
under section 311 of the Clean Water Act (Ref: 40 CFR 110.10 and CFR 117.21) or section 102 of
CERCLA (Ref: 40 CFR 302.4).
26. Stormwater Runoff
The flow of water which results from precipitation and which occurs immediately following rainfall or as a
result of snowmelt.
27. Stormwater Associated with Industrial Activity
The discharge from any point source which is used for collecting and conveying stormwater and which is
-- directly related to manufacturing, processing or raw material storage areas at an industrial site. Facilities
considered to be engaged in "industrial activities" include those activities defined in 40 CFR 122.26(b)(14).
The term does not include discharges from facilities or activities excluded from the NPDES program.
28. Stormwater Pollution Prevention Plan
A comprehensive site -specific plan which details measures and practices to reduce stormwater pollution and
is based on an evaluation of the pollution potential of the site.
29. Ten Year Design Storm
The maximum 24 hour precipitation event expected to be equaled or exceeded on the average once in ten
years. Design storm information can be found in the State of North Carolina Erosion and Sediment Control
Planning and Design Manual.
30. Total Flow
The flow corresponding to the time period over which the entire storm event occurs. Total flow shall be
either; (a) measured continuously, (b) calculated based on the amount of area draining to the outfall, the
amount of built -upon (impervious) area, and the total amount of rainfall, or (c) estimated by the
measurement of flow at 20 minute intervals during the rainfall event.
Part VI Page 4 of 5 Pages

Permit No. NCS000222
31. Total Maximum Daily Load TMDi.
A TMDL is a calculation of the maximum amount of a pollutant that a waterbody can receive and still meet
water duality standards, and an allocation of that amount to the pollutant's sources. A TMDL is a detailed
water quality assessment that provides the scientific foundation for an implementation plan. The
implementation plan outlines the steps necessary to reduce pollutant loads in a certain body of water to
restore and maintain water quality standards in all seasons. The Clean Water Act, section 303, establishes
the water quality standards and TMDL programs.
32. Toxic Pollutant
Any pollutant listed as toxic under Section 307(a)(1) of the Clean Water Act.
33. Upset
Means an exceptional incident in which there is unintentional and temporary noncompliance with
technology based permit effluent limitations because of factors beyond the reasonable control of the
permittee. An upset does not include noncompliance to the extent caused by operational error, improperly
designed treatment or control facilities, inadequate treatment or control facilities, lack of preventive
maintenance, or careless or improper operation.
34. Vehicle Maintenance Activity
Vehicle rehabilitation, mechanical repairs, painting, fueling, lubrication, vehicle cleaning operations, or
airport deicing operations.
35. Visible Sedimentation
Solid particulate matter, both mineral and organic, that has been or is being transported by water, air,
gravity, or ice from its site of origin which can be seen with the unaided eye.
36. 25-year, 24 hour storm event
The maximum 24-hour precipitation event expected to be equaled or exceeded, on the average, once in 25
years.
Part VI Page 5 of 5 Pages

O� WATF,9 Michael F. Easley, Govemor
William G. Ross Jr., Secretary
co � North Carolina Department of Environment and Natural Resources
-� Colecn H. Sullins, Director
Division of !Pater Quality
October 1, 2007
Mr. Mike Rouse
Operations Manager
P.O. Box 370
Leland, NC 28451 Re: Compliance Evaluation Inspection
Carolina Pole
NPDES Permit No. NCS000222
Brunswick County
Dear Mr. Rouse,
The Division is in receipt of your response to the recent NPDES stormwater inspection conducted at the
Carolina Pole facility on August 8, 2007. The updated Stormwater Pollution Prevention Plan appears to
thoroughly address all of the items listed in the inspection report. The plan appears to also address each
of the itemized requirements listed in Sections A through D of the NPDES Permit. The ownership
change form is awaiting signatures. Once the form is complete, please forward that fonn to the
Stormwater Permitting Unit at 1617 Mail Service Center, Raleigh North Carolina 27699-1617.
When you receive your renewed NPDES permit, please carefully review the qualitative and quantitative
monitoring requirements specified in the new permit versus those outlined in your Stormwater Pollution
Prevention Plan and make any necessary amendments to your Plan accordingly. This will prevent any
discrepancies in the implementation of your current plan versus the requirements of the renewed NPDES
Permit.
Thank you for your timely response and your attention to this matter. Should you have any questions
regarding this correspondence or your permit renewal, please do not hesitate to contact me at 910-796-
7343.
Sincerely,
7�7't-V�
Linda Willis
Environmental Engineer I
Surface Water Protection Section
CC: Edward Beck, Regional Supervisor, SWPS, WiRO
Central Files
Kelly Johnson, Central Office, Stonnwater Permitting Unit
WiRO NPDES Permit -File NCS000222,-Brunswick County ;
Onc
NorthCarolina
Allafura!!y
North Carolina Division of water Quality 127 Cardinal Drive Extension Wilmington, NC 28405 Phone [phone] Customer Service
Internet: www.ncwaterguality.org Fax [phone]
An Equal opportunity/Affirmative Action Employer — 50% Recycled110% Post Consumer Paper

1•sCS 000222
of WArF9 Michael F. Easley, Governor
�O� QG William G. Ross Jr., Secretary
r North Carolina Department of Environment and Natural Resources
Coieen H. Sullins. Director
Division of Water Quality
STAFF REVIEW AND EVALUATION
NPDES Stormwater Permit c
Facility Name:
General Wood Preserving Company
NPDES Permit Number:
NCS000222
Facility Location:
Leland, NC (Brunswick County)
Type of Activity:
Wood Preservings w�
Receiving Streams:
Alligator Branch/Sturgeon Creek, See Figure 1 z (pL(. "j-ikVf'
River Basin:
Cape Fear River Basin, Sub -basin 03-06-17 O&. f cm S ae_-
Stream Classification:
C, SW/ C, SW
Proposed Permit Requirements:
See attached draft permit.
Monitoring Data:
See Table 1
Facility Location:
See Figure 1
Response Requested by (Date):
C9(G "D5 T
Central Office Staff Contact:
Kelly Johnson, [phone], ext. 376
Documents Reviewed:
• NPDES Stormwater Permit Application Materials
• Stormwater Permit File
• Cape Fear River Basinwide Plan
• Draft 2006 303(d) List
• EPA Sector -Specific Permit, 2006 draft
• Check 40 CFR Subchapter N, Stormwater Effluent Guidelines
Summary of Industrial Activity:
• Manufactures treated wooden poles and pole cross -arms; logging
History:
• l February 1995. Permit originally issued. The following analytical monitoring was required annually, Ar,
Cu, Cr, pentachlorophenol, phenol, Zn, benzene, toluene, naphthalene, anthracene, total ammonia, total
xylenes, oil and grease, BOD, COD, P, TSS, TKN, and pH. No cut-off concentrations were included.
Visual monitoring was required semi-annually. Vehicle maintenance monitoring was required annually.
• 1 March 2000: Permit was re -issued. Phosphorus monitoring was replaced with total phosphorus.
Monitoring was required annually for years 1-3, and quarterly in year 4.
• 30 July 2004: Permit application received.
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 [phone] Customer Service
1-877-623-6748
,46A•

NCS000922
• 10 May 2005: Email from Daphne Olszewski (Brownfields Program Manager) on file. Dioxins have been
discovered onsite and two areas will be capped. A prospective purchaser of the site tested for dioxins
downstream and the results showed that the levels were below both environmental and human exposure risk
levels. She requests that we add dioxin as an analytical monitoring requirement when the permit is re -issued
in order to simplify RCRA regulation of this site.
0 16 May 2007: Email with Sandra Moore (Brownfields Program) (Daphne has left the position). She
recommended that in addition to testing for dioxin, to also test for arsenic, copper and chromium because
these parameters were detected in an outfall sample at the site, and samples were above the surface water
standards.
0 21 May 2007: Attempted to call General Wood's President, Karl Boatwright, 910.371.3131 with general
questions. This phone number is for Cox Industries. The receptionist said that Cox is not associated with
General Wood and that Mr. Boatwright did not work there. Yellowpages.com has the same number. EPA
has the same number. Called receptionist twice. Sent Mr. Boatwright a lette_r_requesting_updated_contact
information.
0 20 July 2007: Talked to the new contact, Mike Rouse.
Central Office Review Summary:
General Observations:
o This is a brownfield site.
o All required analytical monitoring was not conducted.
a The following detection limits need to be altered for the upcoming cycle. They are not sufficient to detect
the compound. (Compound: Detection limit/benchmark):
1. Pentachlorophenol: 30 mg/L: 0.019 mg/L
2. Toluene: 1.0 mg/L: 0.055 mg/L
3. Napthalene: 10 mg/L: 1 mg/L
4. Anthracene: 10 mg/L: 0.005 mg/L
2. Impairment:
o Alligator Branch: Not addressed in the Basinwide Plan. No TMDL.

NCS000222
o Sturgeon Creek: Not addressed in the Basinwide Plan. No TMDL.
3. Threatened and Endangered Species: None found. This facility drains to Alligator Branch and Sturgeon Creek.
Both of these animals appear near this area of the State (as 1 have learned for permits nearby), but not near this
facility. The American Alligator and the Short Nosed Sturgeon are both endangered, but have not been
identified in the Natural Heritage database as existing in the area near this facility (despite the fact that the
receiving streams are named for these animals.)
4. Changes Since Previous Permit: No significant changes
5. Analytical Monitoring:
o All of the required samples were not collected.
o Ar, Cu, Cr, and Zn were not specified in the previous permit to sample for "total recoverable". Need to
specify this for the upcoming permit.
o Copper was high 50% of the time.
Tabled: Analytical Monitoring, Previous Cycle
Sampling Dates & Re uired Sam ling Date Ranges
Sample
Sample Sample
Sample
Date:
No
Date: Date:
No
No
No
Date:
12 Feb 01
Sample
lose 02 16 Fab 03
Sample
Sample
Sample
12 Feb 04
Parameter
Benchmark
Reported Units
Notes
Required
Required
Required
Required
Required
Required
1
54�
Date:
Date:
Required Date:
Date:
Date:
Date:
Date:
l
1 Mar 00 -
1 Mar 01 -
1 Mar 02 - 28 Feb 03
1 Mar 03 -
1 Jun 03 -
1 Sep 03 -
1 Dec 03-
28 Feb 01
28 Feb 02
30 May 03
31 Aug 03130
Nov 03
29 Feb 04
Total Recoverable.
Arsenic
0.
0.073
0.106
0.03
0.01
ppm
"Total Recoverable
not in permit
Total Recoverable
Copper
0.00
0.0
0.00
0.01
0,00
ppm
"Total Recoverable
not in permit
Total Recoverable.
Chromium
1
0.119
0.01
0.042
0.01
ppm
"Total Recoverable
not in permit
Pentachlorophenol
0.019
BQL
<30
<301
<3
ppm
Phenol
4.5
<0.010
0.007
<0.005
<0.00
ppm
Total Recoverable.
Zinc
0.067
0.045
<.005
0.009
0.00
ppm
'Total Recoverable
not in permi
Benzene
6.7
<1.0
,
0.0
<0.50
<1.
ppm
Toluene
0.05
<1.0
<1.0
<0.50
<1.4
ppm
Naphthalene
1
BOL
<10
1 - <10
<1
ppm
CIL too hig
Anthracene
0,005
BQL
<10
<10
<1
ppm
OL too hig
Total Ammonia
7,2
0.2
<0.20
<0.10
0.1 t
ppm
Total xylenes
6.
<1.0
<1.0
<0.50
<1.
ppm
Oil & Grease
3
2
6.6
<5
<
ppm
BOD
3
6
<
ppm
5-Day? "5-Day" not i
permit
COD
12
87
6
54
ppm
TP
0.49
O.ON
0.12
0.0
ppm
TSS
10
�53
5
17
4
ppm
TKN
2
1.03
<0.25
<0.10
0.
ppm
pH
6-
7.5
7.52
7.01
7.1
standard
Over
Current
Benchmark
No Sample
Collected
�Pm^' my IL
3

NCS000222
Revised Permit Recommendations: Analytical Monitoring:
1. Dioxin has been added per the Brownfields Program's recommendations.
2. Brownfields Program also recommended the following analytical requirements: Arsenic, Copper, and
Chromium. These were already in the facility's testing parameters from the previous permit. "Total
Recoverable" has been specified for these parameters. `Total recoverable" was also specified for Zinc.
3. pH has been added to the analytical monitoring requirements per DWQ's revised strategy.
4. Due to a potential lag time between the expiration of this permit and its renewal, I have specified in the permit
that the permittee is responsible for all monitoring until the renewal permit is issued. See Footnote I of Tables
1, 4, and 5. This approach is recommended because there has been a significant lag time since the expiration of
the previous cycle. This will provide testing if there is a lag in future timeframes. "Measurement Frequency: All
analytical monitoring will be performed two times per year for each year until either another permit is issued for
this facility or until this permit is revoked or rescinded. If at the end of this permitting cycle, the permittee has
submitted the appropriate paperwork for a renewal application before the submittal deadline, the permittee will
be considered for a renewal application. The applicant must continue semi-annual analytical monitoring until
the renewed permit is issued. See Table 2 for schedule of monitoring periods through the end of this permitting
cycle."
5. Benchmarks have been added to this draft permit.
6. All analytical monitoring has been set to semi-annually.
7. The flow reporting requirement has been removed per DWQ revised strategy. (The total rainfall and event
duration parameters are in this permit, however.) (There was no flow requirement in the previous permit.)
8. The permittee is required to collect all of the analytical monitoring samples during representative storm events as
defined in this permit. Qualitative monitoring does not have to be performed during a representative storm
event.
Other Proposed Changes to the Previous Permit:
I . I will include in the cover letter that the detection limits for pentachlorophenol, toluene, naphthalene, and
anthracene are not sufficient to detect the compound at the benchmark level. All benchmarks should be
analytically detectable.
2. Part II Section A has been revised. It now specifies all of the items to include on the site map.
3. Vehicle maintenance has been revised to semi-annually in order to coincide with analytical and qualitative
monitoring.
Discussions with permittee: Mike Rouse, 910.371.3131, 20 July 2007
1. Are you under new ownership? If so, will need an ownership change form. When did the change occur?
a. ANSWER: Yes, "Cox Industries" now owns their company, which is "Carolina Pole".
2. What does your company manufacture? Have there been any changes in industrial activity?
a. ANSWER: No changes.
3. Do you do wet -decking at your facility'?
a. ANSWER: No wet decking.
4

NCS000222
Recommendations: Based on the documents reviewed, the application information submitted on 30 July 2004
sufficient to issue an Individu 5to water Permit.
q,' R",
Prepared by (Signature) Date b
Stormwater Permitting Unit Supe Esor j / 'Te Date �%u 2 tra
Concurrence by Regional
Water Quality Supervisor
Regional Office Staff Comments
Date
Date

o� WAr
Michael F. Easley, Governor
Q
State of North Carolina
William G. Ross, Jr., Secretary
Department Environment
of and Natural Resources
0
Coleen H Sulilns, Director
Division of Water Quality
December 7, 2007
Mr. R. Michael Johnson
President
Leland Land, LLC
PO Box 1124
Orangeburg, SC 29116
Subject: Final NPDES Stormwater Permit
i Permit NCS00022-2
` Leland Land, LLC
4 Brunswick County
Dear Mr. Johnson:
In response to your renewal application for continued coverage under NPDES stormwater permit
NCS000222,-the Division of Water Quality (Division) is forwarding herewith the subject state - NPDES
permit. This permit is issued pursuant to the requirements of North Carolina General Statute 143-215 .1
and the Memorandum of Agreement between North Carolina and the US Environmental Protection
agency dated May 9,1994 (or as subsequently amended).
This final permit includes no major changes from the draft permit sent to you on September 28, 2007.
The qualitative monitoring strategy remains the same (semi-annual) as the previous term of the permit.
Please note that analytical monitoring is also required in this permit. Failure to complete the monitoring
as required is a violation of the permit and any permit noncompliance constitutes a violation of the Clean
Water Act. Reference Part III, Section A, Item 2 "Duty to Comply", Item 9 "Penalties for Tampering " and
Item 10 "Penalties for Falsification of Reports" of your permit for further information.
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty
(30) days following receipt of this letter. This request must be in the form of a written petition,
conforming to Chapter 150E of the North Carolina General Statutes, and filed with the Office of
Administrative Hearings, Post Office Drawer 27447, Raleigh, North Carolina 27611 -7447. Unless such
demand is made, this decision shall be final and binding.
Please take notice this permit is not transferable. Part Ill, B.2. addresses the requirements to be followed
in case of change in ownership or -control of this discharge. This permit does not affect the legal
requirements to obtain other perrrtits which may be required by the Division of Water Quality or
permits required by the Division of Land Resources, Coastal Area Management Act or any other
Federal or Local governmental permit that may be required.
If you have any questions or comments concerning this permit, contact Kelly Johnson at [phone] x
376 or [e-mail]
Sincerely,
for Coleen H. Sullins, Director
North Carolina Division of Water Quality [phone]
1617 Mail Service Center FAX [phone]
Raleigh, North Carolina 27699-1617 On the Internet at http://h2o.enr.stft.nc.us/

Mr. R. Michael Johnson
Leland Land, LLC
Permit No. NCS000222
Page 2 .
cc: Wilmington Regional Office, Linda Willis
Mr. Michael Rouse, Carolina Pole Leland, Inc., 1901 Wood Treatment Rd., Leland, NC 28451
Storinwater Permitting Unit files .
Central Files
Attachments
2

NCS000222
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE STORMWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Leland Land, LLC
is hereby authorized to discharge stormwater from a facility located at
Carolina Pole Leland, Inc.
1901 Wood Treatment Road
Leland, NC
Brunswick County
to receiving waters designated as Alligator Branch and Sturgeon Creek, both are class C, SW
streams in the Cape Fear River Basin, in accordance with the discharge limitations, monitoring
requirements, and other conditions set forth in Parts 1, 11,111, IV, V and VI hereof.
This permit shall become effective January 1, 2008
This permit and the authorization to discharge shall expire at midnight on December 31, 2012.
Signed this 7u' day of December 2007.
for Coleen H. Sullins., Director
Division of Water Quality
By the Authority of the Environmental Management Commission

Permit No. NCS000222
TABLE OF CONTENTS
PART I INTRODUCTION
Section A: Individual Permit Coverage
Section B: Permitted Activities
Section C: Location Map
PART H MONITORING, CONTROLS, AND LIMITATIONS FOR PERMITTED
DISCHARGES
Section A:
Stormwater Pollution Prevention Plan
Section B:
Analytical Monitoring Requirements
Section C:
Qualitative Monitoring Requirements
Section D.
On -Site Vehicle Maintenance Monitoring Requirements
PART III STANDARD CONDITIONS FOR NPDES STORMWATER INDIVIDUAL
PERMITS
Section A: Compliance
and Liability
1.
Compliance Schedule
2.
Duty to Comply
3.
Duty to Mitigate
4..
Civil and Criminal Liability
5.
Oil and Hazardous Substance Liability
6.
Property Rights
7.
Severability
8.
Duty to Provide Information
9.
Penalties for Tampering
10.
Penalties for Falsification of Reports
Section B: General Conditions
1.
Individual Permit Expiration
2.
Transfers
i

Permit No. NCS000222
3. Signatory Requirements
4. individual Permit Modification, Revocation and Reissuance, or
Termination
5. Permit Actions
Section C: Operation and Maintenance of Pollution Controls
1. Proper Operation and Maintenance
2. Need to Halt or Reduce Not a Defense
3. Bypassing of Stormwater Control Facilities
Section D: Monitoring and Records
1.
Representative Sampling
2.
Recording Results
3.
FIow Measurements
4.
Test Procedures
5.
Representative Outfall
6.
Records Retention
7.
Inspection and Entry
Section E: Reporting Requirements
1.
Discharge Monitoring Reports
2.
Submitting Reports
3.
Availability of Reports
4.
Non-Stormwater Discharges
5.
Planned Changes
6.
Anticipated Noncompliance
7.
Bypass
8.
Twenty-four Hour Reporting
9.
Other Noncompliance
10.
Other Information
PART IV LIMITATIONS REOPENER
PART V ADMINISTERING AND COMPLIANCE MONITORING FEE
REQUIREMENTS
PART VI DEFINITIONS
ii

Permit No. NCS000222
PART I INTRODUCTION
SECTION A: INDIVIDUAL PERMIT COVERAGE
During the period beginning on the effective date of the permit and lasting until expiration, the
permittee is authorized to discharge stormwater associated with industrial activity. Such
discharges shall be controlled, limited and monitored as specified in this permit.
SECTION B: PERMITTED ACTIVITIES
Until this permit expires or is modified or revoked, the permittee is authorized to discharge
stormwater to the surface waters of North Carolina or separate storm sewer system that has been
adequately treated and managed in accordance with the terms and conditions of this individual
permit. All discharges shall be in accordance with the conditions of this permit.
Any other point source discharge to surface waters of the state is prohibited unless it is an
allowable non-stormwater discharge or is covered by another permit, authorization or approval.
The discharges allowed by this individual permit shall not cause or contribute to violations of
Water Quality Standards.
This permit does not relieve the permittee from responsibility for compliance with any other
applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or decree.
Part 1 Page 1 of 2

SECTION C: LOCATION MAP Permit No. NCS000222
f• f ��
Carolina Pole s
Leland, Inc.
i`1�.
Iamb
Sams
. •, - J ,, 1 j ~ �_ twl'. w� 1,, f � � .�� �='b �i:1 ���Cy}l �,/�`��'�;' .�ti�
do
Flat
M.
..,' bTi.� �. ` - - _,rya �ew, 1 ',,•���� i- ;'1. �,.� .sE+�
�i , •r� a i1 .F t .,,� � _� ; � r--�-�� `i'..•. •, r � � . •-�i r.'�M7.i r'r. � S
� r f• .r ; .-'. M1 �. `•ti ��,� ` •,� - �_��`; spy ` •��`
Latitude: W15'25" N C O Q 2
Longitude:78104'31"W i�i Q 2 2 Facility
County: Brunswick Leland Land, LLC Location
Steam Class: C, SW (both streams)
Receiving Stream: Alligator Bunch and Sturgeon Creek
Sub -basin: 03-06-17 (Cape Fear River Basin) cffOt%t NOT TO STALE
Part I Page 2 of 2

Permit No. NCS000222
PART II MONITORING, CONTROLS, AND LIMITATIONS FOR
PERMITTED DISCHARGES
SECTION A': STORMWATER POLLUTION PREVENTION PLAN
The permittee shall develop a Stormwater Pollution Prevention PIan, herein after referred to as
the Plan. This Plan shall be considered public information in accordance with Part III, Standard
Conditions, Section E, Paragraph 3 of this individual permit. The Plan shall include, at a
minimum, the following items:
I . Site Plan. The site plan shall provide a description of the physical facility and the
potential pollutant sources that may be expected to contribute to contamination of
stormwater discharges. The site plan shall contain the following:
a. A general location map (USGS quadrangle map or appropriately drafted
equivalent map), showing the facility's location in relation to transportation
routes and surface waters, the name of the receiving water(s) to which the
stormwater outfall(s) discharges, or if the discharge is to a municipal separate
storm sewer system, the name of the municipality and the ultimate receiving
waters; and accurate latitude and longitude of the point(s) of discharge.
b. A narrative description of storage practices, loading and unloading activities,
outdoor process areas, dust or particulate generating or control processes, and
waste disposal practices.
A site map drawn to scale with the following items:
(1) Distance legend and north arrow
(2) Location of industrial activities (including storage of materials,
disposal areas, process areas and loading and unloading areas)
(3) Drainage structures
(4) Delineated drainage areas for each outfall
(5) Drainage area for each outfall in acres and percentage of
each drainage area that is impervious
(6) Building locations
(7) Existing BMPs and impervious surfaces
(8) For each outfall, a narrative description of the potential pollutants that
could be expected to be present in the stormwater discharge.
d. A list of significant spills or leaks of pollutants that have occurred at the facility
during the 3 previous years and any corrective actions taken to mitigate spill
impacts.
C. Certification that the stormwater outfalls have been evaluated for the presence of
non-stormwater discharges. The certification statement will be signed in
accordance with the requirements found in Part III, Standard Conditions, Section
B, Paragraph 3.
Part 1I Page 1 of 8

Permit No. NCS000222
2. Stormwater Management Plan. The stormwater management plan shall contain a
narrative description of the materials management practices employed which control or
minimize the exposure of significant materials to stormwater, including structural and
nonstructural measures. The stormwater management plan, at a minimum, shall
incorporate the following:
a. Feasibility Study. A review of the technical and economic feasibility of changing
the methods of operations and/or storage practices to eliminate or reduce exposure
of materials and processes to stormwater. Wherever practical, the permittee shall
prevent exposure of all storage areas, material handling operations, and
manufacturing or fueling operations. In areas where elimination of exposure is
not practical, the stormwater management plan shall document the feasibility of
diverting the stormwater runoff away from areas of potential contamination.
b. Secondary Containment Schedule. A schedule to provide secondary containment
for bulk storage of liquid materials, storage of Section 313 of Title III of the
Superfund Amendments and Reauthorization Act (SARA) water priority
chemicals, or storage of hazardous substances to prevent leaks and spills from
contaminating stormwater runoff. If the secondary containment devices are
connected directly to stormwater conveyance systems, the connection shall be
controlled by manually activated valves or other similar devices [which shall be
secured with a locking mechanism] and any stormwater that accumulates in the
containment area shall be at a minimum visually observed for color, foam, outfall
staining, visible sheens and dry weather flow, prior to release of the accumulated
stormwater. Accumulated stonnwater shall be released if found to be
uncontaminated by the material stored within the containment area. Records
documenting the individual making the observation, the description of the
accumulated stormwater and the date and time of the release shall be kept for a
period of five years.
C. BMP Summary. A narrative description shall be provided of Best Management
Practices (BMPs) to be considered such as, but not limited to, oil and grease
separation, debris control, vegetative filter strips, infiltration and stormwater
detention or retention, where necessary. The need for structural BMPs shall be
based on the assessment of potential of sources to contribute significant quantities
of pollutants to stormwater discharges and data collected through monitoring of
stormwater discharges.
3. Spill Prevention and Response Plan. The Spill Prevention and Response Plan (SPRP)
shall incorporate an assessment of potential pollutant sources based on a materials
inventory of the facility. Facility personnel (or team) responsible for implementing the
SPRP shall be identified. A responsible person shall be on -site at all times during facility
operations that have the potential to contaminate stormwater runoff through spills or
exposure of materials associated with the facility operations. The SPRP must be site
stormwater specific. Therefore, a SPCC plan may be a component of the SPRP, but may
not be sufficient to completely address the stormwater aspects of the SPRP. The common
elements of the SPCC with the SPRP may be incorporated by reference into the SPRP.
Part 11 Page 2 of 8

Permit No. NCS000222
4. Preventative Maintenance and Good Housekeeping Program. A preventative
maintenance program shall be developed. The program shall document schedules of
inspections and maintenance activities of stormwater control systems, plant equipment
and systems. Inspection of material handling areas and regular cleaning schedules of
these areas shall be incorporated into the program.
5. Employee Training. Training schedules shall be developed and training provided at a
minimum on an annual basis on proper spill response and cleanup procedures and
preventative maintenance activities for all personnel involved in any of the facility's
operations that have the potential to contaminate stormwater runoff. Facility personnel
(or team) responsible for implementing the training shall be identified.
6. Responsible Party. The Stormwater Pollution Prevention Plan shall identify a specific
position(s) responsible for the overall coordination, development, implementation, and
revision to the Plan. Responsibilities for all components of. the Plan shall be documented
and position assignments provided.
7. Plan Amendment. The permittee shall amend the Plan whenever there is a change in
design, construction, operation, or maintenance that has a significant effect bn the
potential for the discharge of pollutants to surface waters. The Stormwater Pollution
Prevention Plan shall be reviewed and updated on an annual basis.
The Director may notify the permittee when the Plan does not meet one or more of the
minimum requirements of the permit. Within 30 days of such notice, the permittee shall
submit a time schedule to the Director for modifying the Plan to meet minimum
requirements. The permittee shall provide certification in writing (in accordance with
Part III, Standard Conditions, Section B, Paragraph 3) to the Director that the changes
have been made.
8. Facility Inspection Program. Facilities are required to inspect all stormwater systems on
at least a semiannual schedule, once in the fall (September -November) and once in the
spring (April - June). The inspection and any subsequent maintenance activities
performed shall be documented, recording date and time of inspection, individual(s)
making the inspection and a narrative description of the facility's stormwater control
systems, plant equipment and systems. Records of these inspections shall be incorporated
into the Stormwater Pollution Prevention Plan.
Stormwater discharge characteristic monitoring as required in Part II of this permit shall
be performed in addition to facility inspections.
9. Implementation. The permittee shall document all monitoring, measurements,
inspections and maintenance activities and training provided to employees, including the
log of the sampling data and of activities taken to implement BMPs associated with the
industrial activities, including vehicle maintenance activities. Such documentation shall
be kept on -site for a period of five years and made available to the Director or his
authorized representative immediately upon request.
Part 11 Page 3 of 8

Permit No. NCS000222
SECTION B: ANALYTICAL MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until expiration, the
permittee is authorized to discharge stormwater subject to the provisions of this permit.
Analytical monitoring of stormwater discharges shall be performed as specified below in Table
All analytical monitoring shall be performed during a representative storm event. The required
monitoring will result in a minimum of ten analytical samplings being conducted over the term of
the permit at each stormwater discharge outfall (SDO). The permittee shall complete the
minimum ten analytical samplings in accordance with the schedule specified below in Table 2.
Monitoring results shall be compared to the benchmark values in Table 3. The benchmark
values in Table 3 are not permit limits but should be used as guidelines for the permittee's
Stormwater Pollution Prevention Plan (SPPP). The permittee shall evaluate the Sources of any
benchmark exceedances and evaluate the effectiveness of any site BMPs. The permittee shall
review and/or update the SPPP and document any efforts to address stormwater contamination.
Table 1. Analytical Monitoring Requirements
Discharge
Characteristics
Units
Measurement
Fre uenc 1
Sample
Tylee2
Sample
Location3
Arsenic, total recoverable
ME&
Semi --annually
Grab
SDO
Copper, total recoverable
m
Semi-annually
Grab
SDO
Chromium, total recoverable
ME&
Semi-annually
Grab
SDO
Pentachloro henol
m
Semi-annually
Grab
SDO
Phenol
m
Semi-annually
Grab
SDO
Zinc, total recoverable
m
Semi-annually
Grab
SDO
Benzene
rn
Semi-annually
Grab
SDO
Toluene
m
Semi-annually
Grab
SDO
Na thalene
mgjt
Semi-annually
Grab
SDO
Anthracene
m
Semi-annually
Grab
SDO
Total Ammonia
m
Serni-annually
Grab
SDO
Total X lenes
m
Semi-annually
Grab
SDO
Oil and Grease
mgfL
Semi-annually
Grab
SDO
Biological Oxygen Demand,
5-da (BODS
mg/L
Semi-annually
Grab
SDO
Chemical Oxygen Demand
COD
mg/L
Semi-annually
Grab
SDO
Total Phosphorus
m
Semi-annually
Grab
SDO
Total Suspended Solids (TSS)J
m
Semi-annually
Grab
SDO
Part II Page 4 of 8

Permit No. NCS000222
Total Kjeldahl Nitrogen
(T
mg/L
Semi-annually
Grab
SDO
Dioxin
ME&
Semi-annually
Grab
SDO
H
Standard
Semi-annually
Grab
SDO
Total Rainfall
inches
Serni-Annually
Rainfall Event Duration
minutes
Semi -Annually
Footnotes:
I Measurement frequency: All monitoring will be performed two times per year for each year until either another
permit is issued for this facility or until this permit is revoked or rescinded. If at the end of this permitting cycle,
the permittee has submitted the appropriate paperwork for a renewal permit before the submittal deadline, the
permittee will be considered for a renewal permit. The applicant must continue semi-annual monitoring until the
renewed permit is issued. See Table 2 for schedule of monitoring periods through the end of this permitting cycle.
2 If the stormwater runoff is controlled by a stormwater detention pond, a grab sample of the discharge from the
pond shall be collected within the first 30 minutes of discharge. If the detention pond discharges only in response
to a storm event exceeding a ten year design storm, then no analytical monitoring is required and only qualitative
monitoring shall be performed.
3 Sample Location: Samples shall be collected at each stormwater discharge outfall (SDO) unless representative
outfall status has been granted.
Table 2. Monitoring Schedule
Monitoring period
Sample Number
Start
End
Year 1 - Spring
1
April 1, 2008
June 30, 2008
Year 1 —Fall
2
September 1, 2008
November 30, 2008
Year 2 — Spring
3
April 1, 2009
June 30, 2009
Year 2 — Fall
4
September 1, 2009
November 30, 2009
Year 3 - Spring
5
April 1, 2010
June 30, 2010
Year 3 — Fall
6
September 1, 2010
November 30, 2010
Year 4 — Spring
7
April 1, 2011
June 30, 2011
Year 4 — Fall
8
September 1, 2011
November 30, 2011
Year 5 — Spring
9
April 1, 2012
June 30, 2012
Year 5 — Fall
10
September 1, 2012
November 30, 2012
Footnotes:
I Maintain semi-annual monitoring during permit renewal process.
Part lI Page 5 of 9

Permit No. NCS000222
Table 3. Benchmark Values for Analytical Monitoring
Discharge Characteristics
Units
Benchmark
Arsenic, total recoverable
mg/L
0.36
Copper, total recoverable
mg/L
0.007
Chromium, total recoverable
mg/L
1
Pentachlorophenol
mg/L
0.019
Phenol
mg/L
4.5
Zinc, total recoverable
mg/L
0.067
Benzene
mg/L
6.7
Toluene
mg/L
0.055
Napthalene
mg/L
1
Anthracene
mg/L
0.005
Ammonia, total as nitrogen
mg/L
7.2
Xylenes, total
mg/L
6.7
Oil and Grease
mg/L
30
Biological Oxygen Demand, 5-
BOD
mg/L
30
-day-
Chemical Oxygen Demand
mg/L
120
Phosphorus, total
mg/L
2
Total Suspended Solids (TSS)
mg/L
100
Total Kjeldahl Nitrogen (TKN)
mg/L
20
Dioxin
mg/L
Any Detection
pH
Standard.
6-9
If additional BMPs are needed to achieve the required level of control, the Permittee will be
required to (1) develop a strategy for implementing appropriate BMPs, and (2) submit a timetable
for incorporation of those BMPs into the permitted Stormwater Pollution Prevention Plan.
SECTION C: QUALITATIVE MONITORING REQUIREMENTS
Qualitative monitoring requires a visual inspection of each stormwater outfall regardless of
representative outfall status and shall be performed as specified below in Table 4. Qualitative
monitoring is for the purpose of evaluating the effectiveness of the Stormwater Pollution
Prevention Plan (SPPP) and assessing new sources of stormwater pollution. No analytical tests
are required. Qualitative monitoring of stormwater outfalls is performed when stormwater
discharge occurs but does not need to be performed during a representative storm event.
Part H Page 6 of 8

Permit No. NCS000222
In the event an atypical condition is noted at a stormwater discharge outfall, the Permittee shall
document the suspected cause of the condition and any actions taken in response to the
discovery. This documentation will be maintained with the Stormwater Pollution Prevention
Plan.
All qualitative monitoring will be performed twice per year, once in the spring (April - June) and
once in the fall (September - November).
Table 4. Qualitative Monitoring Requirements
Discharge Characteristics
Frequency
Monitoring
Locationl
Color
Semi-annually
SDO
Odor
Semi-annually
SDO
Clarity
Semi-aanually
SDO
Floating Solids
Semi-annually
SDO
Suspended Solids
Semi-annually
SDO
Foam
Semi-annually
SDO
Oil Sheen
Semi-annually
SDO
Other obvious indicators
of stormwater pollution
Semi-annually
SDO
Footnotes:
L Measurement Frequency: All monitoring will be performed two times per year for each year until either another
permit is issued for this facility or until this permit is revoked or rescinded. If at the end of this permitting cycle,
the permittee has submitted the appropriate paperwork for a renewal permit before the submittal deadline, the
permittee will be considered for a renewal permit. The applicant must continue semi-annual monitoring until the
renewed permit is issued. See Table 2 for schedule of monitoring periods through the end of this permitting cycle.
SECTION D: ON -SITE VEHICLE MAINTENANCE MONITORING REQUIREMENTS
Facilities which have any vehicle maintenance activity occurring on -site which uses more than 55
gallons of new motor oil per month when averaged over the calendar -year shall perform
analytical monitoring as specified below in Table S. This monitoring shall be performed at all
outfalls which discharge stormwater runoff from vehicle maintenance areas.
All analytical monitoring shall be performed during a representative storm event. The required
monitoring will result in a minimum of ten analytical samplings being conducted over the term of
the permit at each stormwater discharge outfall (SDO) which discharges stormwater runoff from
vehicle maintenance areas. The permittee shall complete the minimum ten analytical samplings
in accordance with the schedule specified in Table 2 (Section B).
Monitoring results shall be compared to the benchmark values in Table 6. The benchmark
values in Table 6 are not permit limits but should be used as guidelines for the permittee's
Stormwater Pollution Prevention Plan (SPPP). The permittee shall evaluate the sources of any
Part Il Page 7 of &

Permit No. NCS000222
benchmark exceedances and evaluate the effectiveness of any site BMPs. The permittee shall
review and/or update the SPPP and document any efforts to address stormwater contamination.
Table 5. Analytical Monitoring Re uirements for On -Site Vehicle Maintenance
Discharge Characteristics
Units
Measurement
Fre uenc 1
Sample
Type2
Sample
Location3
H
standard I
Semi-annually
Grab
SDO
Oil and Grease
m
Semi-annually
Grab
SDO
Total suspended Solids
mg/L
Semi-annually
Grab
SDO
New Motor Oil Usagegallons/month
Semi-annually
Estimate
-
Total Rainfall
inches
Semi-annually
Rainfall Event Duration
minutes
Serni-annually
Footnotes:
I Measurement Frequency: All monitoring will be performed two times per year for each year until either another
permit is issued for this facility or until this permit is revoked or rescinded. If at the end of this permitting cycle,
the permitee has submitted the appropriate paperwork for a renewal permit before the submittal deadline, the
permiee will be considered for a renewal permit. The applicant must continue semi-annual monitoring until the
renewed permit is issued. See Table 2 for schedule of monitoring periods through the end of this permitting cycle.
2 If the stormwater runoff is controlled by a stormwater detention pond, a grab sample of the discharge from the
pond shall be collected within the first 30 minutes of discharge. if the detention pond discharges only in response
to a storm event exceeding a ten year design storm, then no analytical monitoring is required and only qualitative
monitoring shall be performed.
3 Sample Location: Samples shall be collected at each stormwater discharge outfall (SDO) that discharges
stormwater runoff from area(s) where vehicle maintenance activities occur.
Table 6.
Benchmark Values for Vehicle Maintenance Analytical Monitoring
Discharge Characteristics
Units
Benchmark
PH
standard
6-9
Oil and Grease
mg/L
.30
Total Suspended Solids
mg/L
100
Part II Page 8 of 8

Permit No. NCS000222
PART III STANDARD CONDITIONS FOR NPDES STORMWATER INDIVIDUAL PERMITS
SECTION A. COMPLIANCE AND LIABILITY
Compliance Schedule
The permittee shall comply with limitations and Controls specified for stormwater discharges in
accordance with the following schedule:
Existing Facilities: The Stormwater Pollution Prevention Plan shall be developed and implemented within
12 months of the effective date of the initial permit and updated thereafter on an annual basis. Secondary
containment, as specified in Part I1, Section A, Paragraph 2(b) of this permit, shall be accomplished within
12 months of the effective date of the initial permit issuance.
Proposed Facilities: The Stormwater Pollution Prevention Plan shall be developed and implemented prior to
the beginning of discharges from the operation of the industrial activity and be updated thereafter on an
annual basis. Secondary containment, as specified in Part 11, Section A, Paragraph 2(b) of this permit shall
be accomplished prior to the beginning of discharges from the operation of the industrial activity.
Dutv to Com
The permittee must comply with all conditions of this individual permit. Any permit noncompliance
constitutes a violation of the Clean Water Act and is grounds for enforcement action; for permit
termination, revocation and reissuance, or modification; or denial of a permit upon renewal application.
a. The permittee shall comply with standards or prohibitions established under section 307(a) of the
Clean Water Act for toxic pollutants within the time provided in the regulations that establish these
standards or prohibitions, even if the permit has not yet been modified to incorporate the
requirement.
b. The Clean Water Act provides that any person who violates a permit condition is subject to a civil
penalty not to exceed $27,500 per day for each violation. Any person who negligently violates any
permit condition is subject to criminal penalties of $2,500 to $25,000 per day of violation, or
imprisonment for not more than I year, or both. Any person who knowingly violates permit
conditions is subject to criminal penalties of $5,000 to $50,000 per day of violation, or
imprisonment for not more than 3 years, or both. Also, any person who violates a permit condition
may be assessed an administrative penalty not to exceed $11,000 per violation with the maximum
amount not to exceed $137,500. [Ref: Section 309 of the Federal Act 33 USC 1319 and 40 CFR
122.41(a).]
c. Under state law, a daily civil penalty of not more than twenty-five thousand dollars ($25,000) per
violation may be assessed against any person who violates or fails to act in accordance with the
terms, conditions, or requirements of a permit. [Ref: North Carolina General Statutes 143-
215.6A]
d. Any person may be assessed an administrative penalty by the Director for violating section 301,
302, 306, 307, 308, 3I8, or 405 of the Act, or any permit condition or limitation implementing any
of such sections in a permit issued under section 402 of the Act. Administrative penalties for Class
I violations are not to exceed $11,000 per violation, with the maximum amount of any Class I
penalty assessed not to exceed $27,500. Penalties for Class 11 violations are not to exceed $11,000
per day for each day during which the violation continues, with the maximum amount of any Class
11 penalty not to exceed M37,500.
Part Hl Page 1 of 8

Permit No. NCS000222
Duty to Mitigate
The permittec shall take all reasonable steps to minimize or prevent any discharge in violation of this
individual permit which has a reasonable likelihood of adversely affecting human health or the environment.
4. Civil and Criminal Liability
Except as provided in Part 111, Section C of this permit regarding bypassing of stormwater control facilities,
nothing in this individual permit shall be construed to relieve the permittee from any responsibilities,
liabilities, or penalties for noncompliance pursuant to NCGS 143-215.3, 143-215.6A, 143-215.6B, 143-
215.6C or Section 309 of the Federal Act, 33 USG 1319. Furthermore, the permittee is responsible for
consequential damages, such as fish kills, even though the responsibility for effective compliance may be
temporarily suspended.
5. Oil and Hazardous Substance Liability
Nothing in this individual permit shall be construed to preclude the institution of any legal action or relieve
the pennaittee from any responsibilities, liabilities, or penalties to which the permittee is or may be subject to
under NCGS 143-215.75 et seq. or Section 311 of the Federal Act, 33 USC 1321.
6. Prope!gy Rights
The issuance of this individual permit does not convey any property rights in either real or personal
property, or any exclusive privileges, nor does it authorize any injury to private property or any invasion of
personal rights, nor any infringement of Federal, State or local laws or regulations.
7. Severabi&
The provisions of this individual permit are severable, and if any provision of this individual permit, or the
application of any provision of this individual permit to any circumstances, is held invalid, the application
of such provision to other circumstances, and the remainder of this individual permit, shall not be affected
thereby.
8. Duty to Provide Information
The permittee shall furnish to the Director, within a reasonable time, any information which the Director
may request to determine whether cause exists for modifying, revoking and reissuing, or terminating the
permit issued pursuant to this individual permit or to determine compliance with this individual permit. The
permittee shall also furnish to the Director upon request, copies of records required to be kept by this
individual permit.
9. Penalties for Tampering
The Clean Water Act provides that any person who falsifies, tampers with, or knowingly renders inaccurate,
any monitoring device or method required to be maintained under this individual permit shall, upon
conviction, be punished by a fine of not more than $10,000 per violation, or by imprisonment for not more
than two years per violation, or by both. If a conviction of a person is for a violation committed after a first
conviction, of such person under this paragraph, punishment is a fine of not more that $20,000 per day of
violation, or by imprisonment of not more than 4 years, or both.
10. Penalties for Falsification of R orts
The Clean Water Act provides that any person who knowingly makes any false statement, representation, or
certification in any record or other document submitted or required to be maintained under this individual
Part III Page 2 of 8

Permit No. NCS000222
permit, including monitoring reports or reports of compliance or noncompliance shall, upon conviction, be
punished by a fine of not more than $10,000 per violation, or by imprisonment for not more than two years
per violation, or by both.
SECTION B: GENERAJ. CONDITIONS
1. Individual Permit Expiration
The permittee is not authorized to discharge after the expiration date. In order to receive automatic
authorization to discharge beyond the expiration date, the permittee shall submit forms and fees as are
required by the agency authorized to issue permits no later than 180 days prior to the expiration date. Any
permittee that has not requested renewal at least 180 days prior to expiration, or any permittee that does not
have a permit after the expiration and has not requested renewal at least 180 days prior to expiration, will be
subjected to enforcement procedures as provided in NCGS § 143-2153.6 and 33 USC 1251 et. seq.
2. Transfers
This permit is not transferable to any person except after notice to and approval by the Director. The
Director may require modification or revocation and reissuance of the permit to change the name and
incorporate such other requirements as may be necessary under the Clean Water Act. Permittee is required
to notify the Division in writing in the event the permitted facility is sold or closed.
3. Signatory Requirements
All applications, reports, or information submitted to the Director shall be signed and certified.
a. All applications to be covered under this individual permit shall be signed as follows:
(1) For a corporation: by a responsible corporate officer. For the purpose of this Section, a
responsible corporate officer means: (a) a president, secretary, treasurer or vice president
of the corporation in charge of a principal business function, or any other person who
performs similar policy or decision making functions for the corporation, or (b) the
manager of one or more manufacturing production or operating facilities employing more
than 250 persons or having gross annual sales or expenditures exceeding 25 million (in
second quarter 1980 dollars), if authority to sign documents has been assigned or
delegated to the manager in accordance with corporate procedures.
(2) For a partnership or sole proprietorship: by a general partner or the proprietor,
respectively; or
(3) For a municipality, State, Federal, or other public agency: by either a principal executive
officer or ranking elected official.
All reports required by the individual permit and other information requested by the Director shall
be signed by a person described above or by a duly authorized representative of that person. A
person is a duly authorized representative only if:
(1) The authorization is made in writing by a person described above;
(2) The authorization specified either an individual or a position having responsibility for the
overall operation of the regulated facility or activity, such as the position of plant
manager, operator of a well or well field, superintendent, a position of equivalent
responsibility, or an individual or position having overall responsibility for environmental
Part III Page 3 of 8

Permit No. NCS000222
matters for the company. (A duly authorized representative may thus be either a named
individual or any individual occupying a named position.); and
(3) The written authorization is submitted to the Director.
C. Any person signing a document under paragraphs a. or b. of this section shall make the following
certification:
1.1 certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate,
and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fines and imprisonment for knowing violations."
4. Individual Permit Modification, Revocation and Reissuance, or Termination
The issuance of this individual permit does not prohibit the Director from reopening and modifying the
individual permit, revoking and reissuing the individual permit, or terminating the individual permit as
allowed by the laws, rules, and regulations contained in Title 40, Code of Federal Regulations, Parts 122
and 123; Title 15A of the North Carolina Administrative Code, Subchapter 2H .0100; and North Carolina
General Statute 143-215.1 et. al.
Permit Actions
The permit may be modified, revoked and reissued, or terminated for cause. The notification of planned
changes or anticipated noncompliance does not stay any individual permit condition.
SECTION C: OPERATION AND MAINTENANCE OF POLLUTION CONTROLS
Proper Operation and Maintenance
The permittee shall at all times property operate and maintain all facilities and systems of treatment and
control (and related appurtenances) which are installed or used by the permittee to achieve compliance with
the conditions of this individual permit. Proper operation and maintenance also includes adequate
laboratory controls and appropriate quality assurance procedures. This provision requires the operation of
back-up or auxiliary facilities or similar systems which are installed by a permittee only when the operation
is necessary to achieve compliance with the conditions of this individual permit.
2. Need to Halt or Reduce Not a Defense
It shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt or
reduce the permitted activity in order to maintain compliance with the condition of this individual permit.
Bypassin-rof Stormwater Control Facilities
Bypass is prohibited and the Director may take enforcement action against a permittee for bypass unless:
a. Bypass was unavoidable to prevent loss of life, personal injury or severe property damage; and
b. There were no feasible alternatives to the bypass, such as the use of auxiliary control facilities,
retention of stormwater or maintenance during normal periods of equipment downtime or dry
Part III Page 4 of 8

Permit No. NCS000222
weather. This condition is not satisfied if adequate backup controls should have been installed in
the exercise of reasonable engineering judgment to prevent a bypass which occurred during normal
periods of equipment downtime or preventive maintenance; and
C. The permittee submitted notices as required under, Part III, Section E of this permit.
If the Director determines that it will meet the three conditions listed above, the Director may approve an
anticipated bypass after considering its adverse effects.
SECTION D: MONITORING AND RECORDS
Representative Sampling
Samples collected and measurements taken, as required herein, shall be characteristic of the volume and
nature of the permitted discharge. Analytical sampling shall be performed during a representative storm
event. Samples shall be taken on a day and time that is characteristic of the discharge. AlI samples shall be
taken before the discharge joins or is diluted by any other waste stream, body of water, or substance.
Monitoring points as specified in this permit shall not be changed without notification to and approval of
the Director.
2. Recording Results
For each measurement, sample, inspection or maintenance activity performed or collected pursuant to the
requirements of this individual permit, the permittee shall record the following information:
a. The date, exact place, and time of sampling, measurements, inspection or maintenance activity;
b. The individual(s) who performed the sampling, measurements, inspection or maintenance activity;
C. The date(s) analyses were performed;
d. The individual(s) who performed the analyses;
e. The analytical techniques or methods used; and
f. The results of such analyses.
3. Flow Measurements
Where required, appropriate flow measurement devices and methods consistent with accepted scientific
practices shall be selected and used to ensure the accuracy and reliability of measurements of the volume of
monitored discharges.
4. Test Procedures
Test procedures for the analysis of pollutants shall conform to the EMC regulations published pursuant to
NCGS 143-215.63 et. seq, the Water and Air Quality Reporting Acts, and to regulations published pursuant
to Section 304(g), 33 USC 1314, of the Federal Water Pollution Control Act, as Amended, and Regulation
40 CFR 136.
To meet the intent of the monitoring required by this individual permit, all test procedures must produce
minimum detection and reporting Ievels and all data generated must be reported down to the minimum
detection or lower reporting level of the procedure.
Part III Page 5 of &

Permit No. NCS000222
Representative Outfali
If a facility has multiple discharge locations with substantially identical stormwater discharges that are
required to be sampled, the permittee may petition the Director for representative outfall status. if it is
established that the stormwater discharges are substantially identical and the permittee is granted
representative outfall status, then sampling requirements may be performed at a reduced number of outfalls.
6. Records Retention
Visual monitoring shall be documented and records maintained at the facility along with the Stormwater
Pollution Prevention Plan. Copies of analytical monitoring results shall also be maintained on -site. The
permittee shall retain records of all monitoring information, including all calibration and maintenance
records and all original strip chart recordings for continuous monitoring instrumentation, and copies of all
reports required by this individual permit for a period of at least S years from the date of the sample,
measurement, report or application. This period may be extended by request of the Director at any time.
Inspection and Entry
The permittee shall allow the Director, or an authorized representative (including an authorized contractor
acting as a representative of the Director), or in the case of a facility which discharges through a municipal
separate storm sewer system, an authorized representative of a municipal operator or the separate storm
sewer system receiving the discharge, upon the presentation of credentials and other documents as may be
required by law, to;
a. Enter upon the permittee's premises where a regulated facility or activity is located or conducted,
or where records must be kept under the conditions of this individual permit;
Have access to and copy, at reasonable. times, any records that must be kept under the conditions of
this individual permit;
C. Inspect at reasonable times any facilities, equipment (including monitoring and control equipment),
practices, or operations regulated or required under this individual permit; and
d. Sample or monitor at reasonable times, for the purposes of assuring individual permit compliance
or as otherwise authorized by the Clean Water Act, any substances or parameters at any location.
SECTION E: REPORTING REQUIREMENTS
Discharge Monitoring Reports
Samples analyzed in accordance with the terms of this permit shall be submitted to the Division on
Discharge Monitoring Report forms provided by the Director. Submittals shall be received by the Division
no later than 30 days from the date the facility receives the sampling results from the laboratory.
Submitting Reports
Duplicate signed copies of all reports required herein, shall be submitted to the following address:
Division of Water Quality
Surface Water Protection Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Part III Page 6 of 8

Permit No. NCS000222
3. Availability of Reports
Except for data determined to be confidential under NCGS 143-215.3(a)(2) or Section 308 of the Federal
Act, 33 USC 1318, all reports prepared in accordance with the terms shall be available for public inspection
at the offices of the Division of Water Quality. As required by the Act, analytical data shall not be
considered confidential, Knowingly making any false statement on any such report may result in the
imposition of criminal penalties as provided for in NCGS 143-215.6E or in Section 304 of the Federal Act.
4. Non-Stormwater Discharges
If the storm event monitored in accordance with this individual permit coincides with a non-stormwater
discharge, the permittee shall separately monitor all parameters as required under the non-stormwater
discharge permit and provide this information with the stormwater discharge monitoring report.
5. Planned Changes
The permittee shall give notice to the Director as soon as possible of any planned changes at the permitted
facility which could significantly alter the nature or quantity of pollutants discharged. This notification
requirement includes pollutants which are not specifically listed in the individual permit or subject to
notification requirements under 40 CFR Part 122.42 (a).
6. Anticipated Noncompliance
The permittee shall give notice to the Director as soon as possible of any planned changes at the permitted
facility which may result in noncompliance with the individual permit requirements.
7. Buss
a. Anticipated bypass. If the permittee knows in advance of the need for a bypass, it shall submit
prior notice, if possible at least ten days before the date of the bypass; including an evaluation of
the anticipated quality and affect of the bypass.
b. Unanticipated bypass. The permittee shall submit notice within 24 hours of becoming aware of an
unanticipated bypass.
8. Twenty-four Hour Reporting
The permittee shall report to the central office or the appropriate regional office any noncompliance which
may endanger health or the environment. Any information shall be provided orally within 24 hours from
the time the permittee became aware of the circumstances. A written submission shall also be provided
within 5 days of the time the permittee becomes aware of the circumstances.
The written submission shall contain a description of the noncompliance, and its causes; the period of
noncompliance, including exact dates and times, and if the noncompliance has not been corrected, the
anticipated time compliance is expected to continue; and steps taken or planned to reduce, eliminate, and
prevent reoccurrence of the noncompliance.
The Director may waive the written report on a case -by -case basis if the oral report has been received
within 24 hours.
Other Noncompliance
The permittee shall report all instances of noncompliance not reported under 24 hour reporting at the time
monitoring reports are submitted.
Part III Page 7 of 8

Permit No. NCS000222
10. Other Information
Where the permittee becomes aware that it failed to submit any relevant facts in an application for an
individual permit or in any report to the Director, it shall promptly submit such facts or information.
Part III Page 8 of 8

NCS000222
PART IV LIMITATIONS REOPENER
This individual permit shall be modified or alternatively, revoked and reissued, to comply with any applicable
effluent guideline or water quality standard issued or approved under Sections 302(b) (2) (c), and (d), 304(b) (2) and
307(a) of the Clean Water Act, if the effluent guideline or water quality standard so issued or approved:
a. Contains different conditions or is otherwise more stringent than any effluent limitation in the individual
permit; or
b. Controls any pollutant not limited in the individual permit.
The individual permit as modified or reissued under this paragraph shall also contain any other requirements in the
Act then applicable.
PART V ADMINISTERING AND COMPLIANCE MONITORING FEE
REQUIREMENTS
The permittee must pay the administering and compliance monitoring fee within 30 (thirty) days after being billed by
the Division. Failure to pay the fee in timely manner in accordance with 15A NCAC 2H .0105(b)(4) may cause this
Division to initiate action to revoke the Individual Permit,
PART VI DEFINITIONS
Act
See Clean Water Act.
Arithmetic Mean
The arithmetic mean of any set of values is the summation of the individual values divided by the number of
individual values.
Allowable Non-Stormwater Discharges
This permit regulates stormwater discharges. Nan-stormwater discharges which shall be allowed in the
stormwater conveyance system are:
(a) All other discharges that are authorized by a non-stormwater NPDES permit.
(b) Uncontaminated groundwater, foundation drains, air -conditioner condensate without added
chemicals, springs, discharges of uncontaminated potable water, waterline and fire hydrant
flushings, water from footing drains, flows from riparian habitats and wetlands.
(c) Discharges resulting from fire -fighting or fire -fighting training.
4. Best Management Practices (BMPs)
Measures or practices used to reduce the amount of pollution entering surface waters. BMPs may take the
form of a process, activity, or physical structure.
Parts IV, V and VI Page 1 of 5

Permit No. NCS000222
5. Bypass
A bypass is the known diversion of stormwater from any portion of a stormwater control facility including
the collection system, which is not a designed or established operating mode for the facility.
6. Bulk Storage of Liquid Products
Liquid raw materials, manufactured products, waste materials or by-products with a single above ground
storage container having a capacity of greater than 660 gallons or with multiple above ground storage
containers located in close proximity to each other having a total combined storage capacity of greater than
1,320 gallons.
Clean Water Act
The Federal Water Pollution Control Act, also known as the Clean Water Act (CWA), as amended, 33
USC 1251, et. seq.
Division or DW
The Division of Water Quality, Department of Environment and Natural Resources.
9. Director
The Director of the Division of Water Quality, the permit issuing authority.
10. EMC
The North Carolina Environmental Management Commission.
1 L Grab Sample
An individual sample collected instantaneously. Grab samples that will be directly analyzed or qualitatively
monitored must be taken within the first 30 minutes of discharge.
12. Hazardous Substance
Any substance designated under 40 CFR Part 116 pursuant to Section 311 of the Clean Water Act.
13. Landfill
A disposal facility or part of a disposal facility where waste is placed in or on land and which is not a land
treatment facility, a surface impoundment, an injection well, a hazardous waste long-term storage facility or
a surface storage facility.
14. Municipal Separate Storm Sewer System
A stormwater collection system within an incorporated area of local self-government such as a city or town.
15. Overburden
Any material of any nature, consolidated or unconsolidated, that overlies a mineral deposit, excluding
topsoil or similar naturally -occurring surface materials that are not disturbed by mining operations.
Part VI Page 2 of 5 Pages

Permit No. NCS000222
16. Permittee
The owner or operator issued a permit pursuant to this individual permit.
17. Point Source Discharge of Stormwater
Any discernible, confined and discrete conveyance including, but not specifically limited to, any pipe, ditch,
channel, tunnel, conduit, well, or discrete fissure from which stormwater is or may be discharged to waters
of the state.
18. Representative Storm Event
A storm event that measures greater than 0.1 inches of rainfall and that is preceded by at least 72 hours in which no
storm event measuring greater than 0.1 inches has occurred. A single storm event may contain up to 10 consecutive
hours of no precipitation. For example, if it rains for 2 hours without producing any collectable discharge, and then
stops, a sample may be collected if a rain producing a discharge begins again within the next 10 hours.
19. Representative Outfall Status
When it is established that the discharge of stormwater runoff from a single outfall is representative of the
discharges at multiple outfaIls, the DWQ may grant representative outfall status. Representative outfall
status allows the permittee to perform analytical monitoring at a reduced number of outfalls.
20. Rinse Water Discharge
The discharge of rinse water from equipment cleaning areas associated with industrial activity. Rinse
waters from vehicle and equipment cleaning areas are process wastewaters and do not include washwaters
utilizing any type of detergent or cleaning agent.
21. SecondarContainment
Spill containment for the contents of the single largest tank within the containment structure plus sufficient
freeboard to allow for the 25-year, 24-hour storm event.
22. Section 313 Water Priority Chemical
A chemical or chemical category which:
a. is listed in 40 CFR 372.65 pursuant to Section 313 of Title 111 of the Superfund Amendments and
Reauthorization Act (SARA) of 1986, also titled the Emergency Planning and Community Right -
to -Know Act of 1986;
b. Is present at or above threshold levels at a facility subject to SARA Title III, Section 313 reporting
requirements; and
C. That meet at least one of the following criteria:
(1) Is listed in Appendix D of 40 CFR part 122 on either Table II (organic priority
pollutants), Table Ill (certain metals, cyanides, and phenols) or Table IV (certain toxic
pollutants and hazardous substances);
(2) _ Is listed as a hazardous substance pursuant to section 3 l 1(b)(2)(A) of the CWA at 40
CFR 116.4; or
(3) Is a pollutant for which EPA has published acute or chronic water quality criteria.
Part VI Page 3 of 5 Pages

Permit No. NCS000222
23. Severe Property Damage
Means substantial physical damage to property, damage to the control facilities which causes them to
become inoperable, or substantial and permanent loss of natural resources which can reasonably be
expected to occur in the absence of a bypass. Severe property damage does not mean economic loss caused
by delays in production.
24. Sianificant Materials
Includes, but is not limited to: raw materials; fuels; materials such as solvents, detergents, and plastic
pellets; finished materials such as metallic products; raw materials used in food processing or production;
hazardous substances designated under section 101(14) of CERCLA; any chemical the facility is required to
report pursuant to section 313 of Title Ill of SARA; fertilizers; pesticides; and waste products such as ashes,
slag and sludge that have the potential to be released with stormwater discharges.
25. Significant Spills
Includes, but is not limited to: releases of oil or hazardous substances in excess of reportable quantities
under section 311 of the Clean Water Act (Ref: 40 CFR 110.10 and CFR 117.21) or section 102 of
CERCLA (Ref: 40 CFR 302.4).
26. Stormwater Runoff
The flow of water which results from precipitation and which occurs immediately following rainfall or as a
result of snowmelt.
27. Stonnwater Associated with Industrial Activity
The discharge from any point source which is used for collecting and conveying stormwater and which is
directly related to manufacturing, processing or raw material storage areas at an industrial site. Facilities
considered to be engaged in "industrial activities" include those activities defined in 40 CFR 122.26(b)(14).
The term does not include discharges from facilities or activities excluded from the NPDES program.
28. Stormwater Pollution Prevention Plan
A comprehensive site -specific plan which details measures and practices to reduce stormwater pollution and
is based on an evaluation of the pollution potential of the site.
29. Ten Year Design Storm
The maximum 24 hour precipitation event expected to be equaled or exceeded on the average once in ten
years. Design storm information can be found in the State of North Carolina Erosion and Sediment Control
Planning and Design Manual.
30. Total Flow
The flow corresponding to the time period over which the entire storm event occurs. Total flow shall be
either; (a) measured continuously, (b) calculated based on the amount of area draining to the outfall, the
amount of built -upon (impervious) area, and the total amount of rainfall, or (c) estimated by the
measurement of flow at 20 minute intervals during the rainfall event.
Part VI Page 4 of 5 Pages

Permit No. NCS000222
31. Total Maximum Daily Load (TMDL)
A TMDL is a calculation of the maximum amount of a pollutant that a waterbody can receive and still meet
water quality standards, and an allocation of that amount to the pollutant's sources. A TMDL is a detailed
water quality assessment that provides the scientific foundation for an implementation plan. The
implementation plan outlines the steps necessary to reduce pollutant loads in a certain body of water to
restore and maintain water quality standards in all seasons. The Clean Water Act, section 303, establishes
the water quality standards and TMDL programs.
32, Toxic Pollutant
Any pollutant listed as toxic under Section 307(a)(1) of the Clean Water Act.
33. Upset
Means an exceptional incident in which there is unintentional and temporary noncompliance with
technology based permit effluent limitations because of factors beyond the reasonable control of the
permittee. An upset does not include noncompliance to the extent caused by operational error, improperly
designed treatment or control facilities, inadequate treatment or control facilities, lack of preventive
maintenance, or careless or improper operation.
34. Vehicle Maintenance Activity
Vehicle rehabilitation, mechanical repairs, painting, fueling, lubrication, vehicle cleaning operations, or
airport deicing operations.
35. Visible Sedimentation
Solid particulate matter, both mineral and organic, that has been or is being transported by water, air,
gravity, or ice from its site of origin which can be seen with the unaided eye.
36. 25-year 24 hour storm event
The maximum 24-hour precipitation event expected to be equaled or exceeded, on the average, once in 25
years.
Part VI Page 5 of 5 Pages

Michael F. Easley Governor
State of North Carolina
William G. Floss, Jr., Secretary
Department of Environment and Natural Resources
^` Coleen H Sullins, Director
Division of Water Quality
September 28, 2007
Mr. Mike Rouse
Cox Industries, Carolina Pole
1901 Wood Treatment Road
Leland, North Carolina 28451
Subject: Draft NPDES Stormwater Permit
Permit No. NCS000222
Cox Industries, Carolina Pole
Brunswick County
Dear Mr. Rouse:
Enclosed with this letter is a copy of the draft stormwater permit for your facility. Please review the draft
very carefully to ensure thorough understanding of the conditions and requirements it contains.
The draft permit contains the following significant changes from this facility's current ,permit:
All analytical monitoring has changed from annual to semi-annual (once in the spring and once
in the fall). This change is based on the Division's revised strategy for stormwater monitoring in
renewal permits and makes stormwater discharge sampling frequency consistent with qualitative
monitoring. Please note that analytical monitoring must still be performed during a
representative storm event (whereas qualitative does not).
Instead of "cut-off concentrations," the Division has incorporated benchmark values into the
permit. These benchmarks are not permit limits but should be used as guidelines for your
facility's Stormwater Pollution Prevention Plan (SPPP). If any measurements exceed benchmark
values, your facility should evaluate the effectiveness of its Best Management Practices (BMPs),
review and/or update its SPPP, and document any efforts to address stormwater contamination
(see Part II, Sections B and D).
Total Flow monitoring has been removed. The permit still requires Total Rainfall amount and
Rainfall Event Duration be recorded for each sampling event. This change is also based on the
Division's revised strategy for stormwater monitoring, in renewal permits. Please note that the
Stornzwater Pollution Prevention Plan (SPPP) site map must include drainage area for each
outfall in acres and the percentage of each drainage area that is impervious (see Part II, Sec. A).
• Dioxin, and pH have been added to your facility's analytical monitoring requirements.
• "Total recoverable" has been specified for the following analytical monitoring parameters that
were already required for facility: Arsenic, Copper, Chromium, and Time.
The footnote of tables 1, 4, and 5 now specify that you are responsible for all monitoring until the
permit is re -issued -
Please submit any comments to me no later than thirty (30) days following your receipt of the draft.
Comments should be sent to my attention at the address listed at the bottom of this page. If no adverse
comments are received from the public or from you, this permit will likely be issued in about two
months.
North Carolina Division of Water Quality [phone]
1617 Mail Service Ceram M [phone]
Raleigh, North Carolina 27699.1617 On the Intemet at http://h2o.enr.state.nc.us/

Mr. Mike Rouse
Cox Industries, Carolina Pole
Permit No. NCS000222
Page 2
If you have any questions or comments concerning this draft permit, contact me at [phone] x 376 or
Kelly.p.johnsonOncmail_net
Sincerely,
Kelly j son
Environmental Engineer
Stormwater Permitting Unit
cc: Wilmington Regional Office, Linda Wiilis (w/attachment)
Stormwater Permitting Unit Files
Attachments
01

ALIT,
kA
NCDENR
North Carolina Department of Environment and
Division of Water Quality
Beverly Eaves Perdue Chuck Wakild, P.E.
Governor Director
May 10, 2012
Robert Michael Johnson
Leland Land LLC
PO Box 1124
Orangeburg SC, 29116
Natural Resources
Subject: NPDES Stormwater Permit Coverage Renewal
Carolina Pole Leland Inc
Permit Number NCS00022Z
Brunswick County
Dear Permittee:
Dee Freeman
Secretary
Your facility is currently covered for stormwater discharge under NPDE5 Permit NCS000222, This permit expires on
December 31, 2012. To assure consideration for continued coverage under your individual permit, you must apply
to the Division of Water Quality (DWQ) for renewal of your permit. Enclosed you will find an individual permit
Renewal Application Form, Supplemental Information request, and Stormwater Pollution Prevention Plan
Certification for your facility.
Filing the application form along with the requested supplemental information will constitute your application for
renewal of this permit. Until your permit renewal is completed and you receive a new permit, please continue to
comply with all conditions and monitoring requirements in your expired NPDES Stormwater permit.
The application and supplement must be completed and returned to DWQ by July 4. 2012. Failure to request
renewal within this time period will result in delay of your permit renewal and may result in a civil assessment.
Discharge of Stormwater from your facility without coverage under a valid Stormwater NPDES permit would
constitute a violation of NCGS 143-215.1 and could result in assessments of civil penalties of up to $25,000 per
day.
If you have any questions regarding permit renewal procedures please contact Brian Lowther of the Stormwater
Permitting Unit at (919)-807-6368 or brian,[e-mail].
Sincerely,
Bradley Bennett, Supervisor
Stormwater Permitting Unit
Cc: Central Files
SPU files
Wilmington Regional Office
1617 Mail Service Center, Raleigh, North Carolina 27699.1617
Location: 512 N. Salisbury St Raleigh, North Carolina 27604
Phone: [phone] t FAX 9IM07-6492
Internet. www.ncwaterquality.org
An Equal Cpportuni;y 1 AfFrmahve Action Employer
One
NonhCarolina
Naturally

c�uF,I,rfgc Permit Coverage
°r Renewal Application Form
National Pollutant Discharge Elimination System Permit Number
Stormwater Discharge Permit NCS000222
The following is the information currently in our database for your facility. Please review this information carefully and make all
corrections/additions as necessary in the space provided to the right of the current information.
Owner Affiliation Information " Reissued Permit will be mailed to the owner address
Owner / Organization Name: Leland Land LLC
Owner Contact: Robert Michael Johnson
Mailing Address: PO Box 1124
Orangeburg SC,29116
Phone Number:
Fax Number:
E-mail address:
Facility/Permit Contact Information
Facility Name: Carolina Pole Leland Inc
Facility Physical Address: 1901 Wood Treatment Rd NE
Ireland NC, 28451
Facility Contact:
Mailing Address:
Phone Number:
Fax Number:
E-mail address:
Discharge Information
Receiving Stream Alligator Branch
Stream Class:
Basin -
Sub -Basin:
Number of Outfails:
C, Sw
Cape Fear River Basin
03-06.17
Impaired Waters/TMDL
Does this facility discharge to waters listed as impaired or waters with a finalized TMDL? ❑ Yes 0 No 0 Don't Know
( for information on these waters refer to http://h2o.enr.state.nc.us/su/lmpoired_Waters_TMDLI )
CERTIFICATION
certify that I am familiar with the information contained in the application and that to the best of my knowledge and belief such
information is true, complete and accurate.
Signature
Print or type name of person signing above
Date
Title
Please return this completed renewal application form to: Stormwater Permitting Unit
Attn: Brian Lowther
1617 Mail Service Center
Raleigh, North Carolina 27699-1617

axe Cares about People, Products and Practices
August 26, 2007
Mr. Edward Beck
Surface Water Protection Section
Water Quality Regional Supervisor
NC Division of Water Quality
127 Cardinal Drive Extension
Wilmington, NC 28405
Dear Mr. Beck:
C-.IVF-,p
A� G 3 0 Z007
RE: Carolina Pole Leland (Formerly General Wood)
Leland, NC — Brunswick County
Storm Water Permit ## NCS000222
Compliance Evaluation Inspection, August 8, 2007
This letter is sent, with attachments, to respond to the results of our August 8, 2007 storm water
inspection. We have reviewed the results of the inspection and made modifications to our storm water
plan. We have pictures of the site, an updated site map, TOPO map, our contingency plan, which serves
as our Spill Prevention and Response Procedures, and an updated Storm Water Pollution Prevention Plan.
The application has been completed and we are waiting on the previous owner's signature. Once
complete, we will forward the application.
Mr. Johnson has signed the Storm Water Plan, but since he resides in South Carolina, Michael Rouse, the
facility manager, is authorized to manage and sign the plan as he oversees this site.
If you have any questions, or require more information, please feel free to contact myself at (803) 928-
5046 or Mike Rouse at [phone],
Sincerely,
A OLINA PAH
D, INC.
ane House,/ 2002 0T d33
Corporate Safety, Health, and Environmental O�IM
cc: R. Michael Johnson, President, Leland Land, LLC
Mike Rouse, Facility Manager, Carolina Pole Leland
Enclosure
4ea INDUSTRIES, INC. • P.O. Box 1124.Orangeburg, SC 29116 • Phone [phone] or 800.476.4401

�U' , tjA A - KU3,5
26 July 2007
Linda,
I have enclosed an individual permit stormwater permit application for General Wood in
Leland. I have summarized the current situation in the attached staff report. Here are a
couple of things:
1.) This is a brownfield.
2.) Both the application and their 1999 permit say that there are two receiving
streams (Alligator Branch and Sturgeon Creek, see other side of this paper), but
the site plan says that there is only one outfall. One set of data was provided. I
think what happened is that the site may actually drain to Flat Bay, but for some
reason that isn't in BIMS. Flat Bay looks like it drains to Sturgeon Creek. The
outfall appears to be at the south, and so Sturgeon Creek is probably the best
outfal I to list. I left both for now. If you do a site visit, please see if you agree
with this assessment.
3.) This permittee did not do all of their required monitoring (see the staff report for
more info.) They were required to do annual monitoring in the first 3 years, and
then quarterly monitoring in the 4`h year. We see a lot of individual permits in
this situation. I haven't issued an NOV for an individual permit, and I don't think
we have specific guidelines on when we do that. But, I think that the fact that this
facility is a brownfield and that they haven't taken appropriate protective
measures constitutes a problem. Maybe we can talk about some options for
encouraging their future sampling efforts.
4.) If you do decide to visit the site, I won't be able to go along this time. I am
pregnant! So, I would like to steer clear of high -chemical sites for a while.
If you would review this info and then sign and return the staff report to me, I would
appreciate it.
Thanks,
Kelly
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Re: GeneralWoj'J' facility mean Wilmington
Subject: Re: General Wood facility mear Wilmington
From: Sandra Moore <Sandra.Moore@ncmai 1. net>
Date: Wed, 09 May 2007 14:52:26 -0500
To: Kelly Johnson <kelly.p [e-mail]>
CC: Sandra Moore <[e-mail]>, Bruce Nicholson <bruce.nicholson@ncmai 1. net>
Kelly,
At the General wood brownfields site dioxins were found to be one of the primary
constituents of concern in soil. Because they are present in the surface soil, we
recommend that you include them in your required storm water analytical sampling. In
addition to dioxins, you.may also want to consider having them analyze for arsenic,
copper and chromium since these constituents were detected in an outfall sample at the
site above surface water standards. Your .requirements of permittees as discussed in
your email below would address our concerns for dioxins moving off the site via
stormwater. If you have any questions, don't hesitate to contact me.
Sandra
Kelly Johnson wrote_
Sandra,
I got your name from Connie Brower as a possible contact for this.brownfield
facility_ I am with the stormwater Permitting Unit, and we have received an
application for a permit renewal from General Wood. We actually received it quite
some time ago and have had significant turnover so we are just getting to their
July 2004 application. There is a note in the file from Daphne Olszewski to my
co-worker (attached) requesting that we add dioxin to the analytical requirements
when the permit is renewed. I just wanted to touch base with you about this issue
and also to see what other concerns may have come up more recently.
I talked to Connie about the appropriate benchmark for dioxin, as we do not
currently have one. (You may know this already, but stormwater benchmarks are not
limits, but they are specified in the permit so that if the permittee's sampling is
above benchmark values then the permittee must take action to address the
situation.) She recommended that any detection be considered as the benchmark. We
typically require permittees of this sort to do stormwater analytical sampling
every six months over the five-year permit and to continue sampling until a renewal
permit is issued. Would this address your group's concerns for dioxin at this
site?
Do you have any other concerns for parameters to test at this site?
Thanks,
Kelly Johnson
I of 1 5/16/2007 11:35 AM

r
General Wo%d, Leland NC
Subject: General Wood, Leland NC
From: Kelly Johnson <kelly.p.johnson rr ncmail.net>
Date: Tue, 03 Apr 2007 14:56:47 -0400
To: [e-mail]
Daphne,
I am with the Division of Water Quality 5tormwater Permitting Unit, and we are
reviewing a permit application for this facility. I found a hard -copy of the attached
email from you in our file. (Unfortunately we have had significant staff turn over,
and are working through a backlog of work so this email is quite old). I see that you
would like to add dioxin to the analytical monitoring for this facility. That would
make sense to me, given the RCRA concerns. I will work with our Standards Unit to
determine an appropriate benchmark for dioxin, as we do not currently have one. (You
may know this already, but benchmarks are not limits, but they are specified in the
permit so that if the permittee's sampling is above benchmark values then the
permittee must take action to address the situation.) You also asked whether or not
we specify testing for sediment or just water. Typically we just require the
permittee to sample the water. I am not sure if we have required sediment testing for
a .facility in the past (or if we have the authority to do so). Is there a reason why
sediment testing would be necessary? If so, I would like to talk with you more about
exactly what type of test you are referring to. Are there any additional concerns
that I need to be aware of for this facility?
Thanks,
Kell
NCS 000222_General Wood_Brownfield Email.pdf Content -Type: application/pdf
Content -Encoding: base64
Efq% _ �ol qzv� -
I of 1 4/3/2007 2:57 PM

i
General Wed - Leland, Brunswick County
Subject: General Wood - Leland, Brunswick County
From: Daphne Olszewski <Daphne. 01 szewski@ncmail. net>
Date: Tue, 10 May 2005 11:17:30 -0400
To: Aisha Lau <[e-mail]>
CC: BRUCE NICHOLSON <[e-mail]>
Aisha - It has been a long time since I contacted you on the NPDES Stormwater Permit for General
Wood in Leland, Brunswick County. At that time (August 23, 2003), you faxed me the analytical
monitoring requirements for the stormwater discharge at this facility (Permit No. NCS000222). This site
is a RCRA TSD as well as a generator for wood treatment, but a new potential owner has applied for a
brownfields agreement (BFA).
During assessment sampling to determine that the site was safe for wood treatment as far as worker risk,
we discovered dioxins were in the surficial soil. Two areas of relatively high levels of dioxin
(TCDD-TEQ) will be capped, and the average for the site will be reduced well below the worker risk
level. However, RCRA wants to test for surface water and sediment at the NPDES outfaIl. We had
requested that the prospective purchaser test for dioxin in sediment further downstream, closer to the
potential receptors in Sturgeon Creek. The results from that sediment sample for total dioxin (TEQ) were
below both environmental and human exposure risk levels. Due to the fact that these dioxins have now
been discovered at the site and the fact that the entire General Wood site is diked and has ditches that
drain it through the NPDES stormwater permitted outfall, we were providing you this information so that
you could consider adding dioxin as an analytical monitoring requirement when the permit is re -issued.
Is that a possibility? RCRA is struggling a bit with what to do with the surface water issue from a
regulation standpoint and having this under the NPDES permit would greatly simplify matters for them.
This in turn would make the brownfields agreement process more straightforward. Query also if this is
done, whether your sampling regime would include sediment or just water?
Thanks so much, Daphne
---------------------------------------------
Daphne J. Olszewski
Brownfields Program Project Manager
North Carolina Division of Waste Management
401 Oberlin Road, Suite 150
Raleigh, NC 27605
[phone] (direct dial)
[phone] (main number)
[phone] (fax)
[e-mail]
http://www.ncbrownfields.org
1 of 1 9/13/2005 10:38 AM

OF WAT�c�
Michael F. Easley, Governor
QG
State of North Carolina
William G. Ross, Jr., Secretary
Natural
F—
Department of Environment and Resources
pAlan
W. Klimek, P.E., Director
Division of Water Oualitv
May 21, 2007
Mr. Karl Boatwright
President
General Wood Preserving Co.
1901 Wood Treatment Road
Leland, NC 28451
Subject: Draft NPDES Stormwater Permit
Permit No. NCS000222
General Wood Preserving Co.
Brunswick County, North Carolina
Dear Mr. Boatwright:
The Division is processing your renewal application for your National Pollutant Discharge Elimination
System (NPDES) Stormwater Permit. Due to a significant backlog of permits, we have been unable to
process it since receiving it July 30, 2004. I have tried to contact you at the phone number we have on
file, 910.371.3131, though I have been unable to reach you. The receptionist answering this number has
instructed me that we must have an incorrect phone number on file. Would you please contact me to
update your contact information and to discuss the questions listed below? You can reach me at (919)
733-5083 x 376 or [e-mail]. I have the following general questions about your
facility:
1.) It appears from your file that your facility manufactures treated telephone poles. Is this correct?
Have there been any significant changes in your operation -since your permit application? If so,
what are those changes?
2.) Does your facility do log wet -decking (intentional wetting or spraying of logs)?
Your permit review and renewal should take approximately three months. I will draft your renewal
permit, and forward it to our Regional Office for review. The Regional Office may contact you with
additional questions during this time. After the Region approves the draft, I will send you a draft copy for
review, and we will simultaneously submit it for a 30-day public comment period. Your permit will be
issued at the end of this time.
Sincerely,
Kelly hnson
Environmental Engineer
Cc: Central Files
Wilmington Regional Office, DWQ
SPU: Files
North Carolina Division of Water Quality [phone]
1617 Mail Service Center FAX [phone]
Raleigh, North Carolina 27699.1617 On the Intemet at httpl/h2o.enr.state.nc.us/

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1 of 1 4/4/2007 9:47 AM'

E
NCS 000222
OF WArF9 Michael F. Easley, Governor
�O" �G William G. Ross Jr., Secretary
ro Dua
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins. Director
Division of Water Quality
STAFF REVIEW AND EVALUATION
NPDES Stormwater Permit
Facility Name:
General Wood Preserving Company
NPDES Permit Number:
NCS000222
Facility Location:
Leland, NC (Brunswick County)
Type of Activity:
Wood Preserving
Receiving Streams:
Alligator Branch/Sturgeon Creek, See Figure l
River Basin:
Cape Fear River Basin, Sub -basin 03-06� 17
Stream Classification:
C, SW/ C, SW
Proposed Permit Requirements:
See attached draft permit.
Monitoring Data:
See Table 1
Facility Location:
See Figure 1
Response Requested by (Date):
Central Office Staff Contact:
Kelly Johnson, [phone], ext. 376
Documents Reviewed:
• NPDES Stormwater Permit Application Materials
• Stormwater Permit File
• Cape Fear River•Basinwide Plan
• Draft 2006 303(d) List
• EPA Sector -Specific Permit, 2006 draft
• Check 40 CPR Subchapter N, Stormwater Effluent Guidelines
Summary of Industrial Activity:
Manufactures treated wooden poles and pole cross -arms; logging
History:
• 1 February 1995: Permit originally issued. The following analytical monitoring was required annually, Ar,
Cu, Cr, pentachlorophenol, phenol, Zn, benzene, toluene, naphthalene, anthracene, total ammonia, total
xylenes, oil and grease, BOD, COD,.P, TSS, TKN, and pH. No cut-off concentrations were included.
Visual monitoring was required semi-annually. Vehicle maintenance monitoring was required annually.
• 1 March 2000: Permit was re -issued. Phosphorus monitoring was replaced with total phosphorus.
Monitoring was required annually for years 1-3, and quarterly in year 4.
• 30 July 2004: Permit application received.
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 [phone] Customer service
1-877-623-6748

NCS000222
+ 10 May 2005: Email from Daphne Olszewski (Brownfields Program Manager) on file. Dioxins have been
discovered onsite and two areas will be capped. A prospective purchaser of the site tested for dioxins
downstream and the results showed that the levels were below both environmental and human exposure risk
levels. She requests that we add dioxin as an analytical monitoring requirement when the permit is re -issued
in order to simplify RCRA regulation of this site.
0 16 May 2007: Email with Sandra Moore (Brownfields Program) (Daphne has left the position). She
recommended that in addition to testing for dioxin, to also test for arsenic, copper and chromium because
these parameters were detected in an outfall sample at the site, and samples were above the surface water
standards.
91 21 May 2007: Attempted to call General Wood's President, Karl Boatwright, 910.371.3131 with general
questions. This phone number is for Cox Industries. The receptionist said that Cox is not associated with
General Wood and that Mr. Boatwright did not work there. Yellowpages.com has the same number. EPA
has the same number. Called receptionist twice. Sent Mr. Boatwright a letter requesting updated contact
information.
a 20 July 2007: Talked to the new contact, Mike Rouse.
Central Office Review Summary:
L General Observations:
o This is a brownfield site.
o All required analytical monitoring was not conducted.
o The following detection limits need to be altered for the upcoming cycle. They are not sufficient to detect
the compound. (Compound: Detection limit/benchmark):
1. Pentachlorophenol: 30 mg{L: 0.019 mg/L
2. Toluene: 1.0 mg/L: 0.055 mg/L
3. Napthalene: 10 mg/L: I mg/L
4. Anthracene: 10 mg/L: 0.005 mg/L
2. Impairment:
o Alligator Branch: Not addressed in the Basinwide Plan. No TMDL.

NCS0OO222
o Sturgeon Creek: Not addressed in the Basinwidc Plan, No TMDL.
3. Threatened and Endangered Species: None found. This facility drains to Alligator Branch and Sturgeon Creek.
Both of these animals appear near this area of the State (as I have learned for permits nearby), but not near this
facility. The American Alligator and the Short Nosed Sturgeon are both endangered, but have not been
identified in the Natural Heritage database as existing in the area near this facility (despite the fact that the
receiving streams are named for these animals.)
4. Changes Since Previous Permit: No significant changes
5. Analytical Monitoring:
o All of the required samples were not collected.
o Ar, Cu, Cr, and Zn were not specified.in the previous permit to sample for "total recoverable". Need to
specify this for the upcoming permit.
o Copper was high 50% of the time.
Table 1: Analytical Monitoring, Previous Cycle
Sam ling pates & Re trued Sam ling Date Ranges
Sample
No
Sample
Sample
No
No
No
sample
Date:
12 Fab 01
Sample
Date:
10 se 02
Date:
16 Feb 03
Sample
Sample
Sample
Date:
12 Feb D4
Benchmark
Parameter
Reported Units
Notes
Required
Required
Required
Required
Required
Required
Date.
Date:
Required Date:
Date:
Date:
Date:
Date:
1 Mar 00 •
1 Mar 01 -
1 Mar 02 - 28 Feb 03
1 Mar 03 -
1 Jun 03 -
1 Sep 03 -
1 pec 03
28 Feb 01
28 Feb 02
30 May 03
31 Aug 03
30 Nov 03
29 Feb 04
Total Recoverable
Arsenic
0.3
0.073
9106
0.032
0.012
ppm
-Total Recoverable
not in permill
Total Recoverable
Copper
0,00WO-Ow
0-00
D.01
0.00
ppm
'Total Recoverable
not in permil
Total Recoverable.
Chromium
1
0 119
0.01
0.042
0.01
ppm
"Total Recoverable
not in permit
Pentachlorophenol
0.019
sQq
<30
<30
<3
ppm
Phenol
4.5
<0.0101
0.00
<0.00
<0.00
ppm
Total Recoverable
Zinc
0.067
0,045
<.005
0,009
0.0
ppm
'Total Recoverable
not in permi
Benzene
6.7
<1.0
<1,0
<0.50
<1.
ppm
Toluene
0,055.<1.0
<1.0
<0-50
<1.
ppm
Naphthalene
1
BQL
<10
<10
<1
ppm
QL too high
Anthracene
0.005
BQL
<10
<1
ppm
QL too high
Total Ammonia
7.2
0.2
<0.20
<0.10
0.11
ppm
Total xyienes
6.7
<1.0
<1,0
<0.50
<1.
ppm
Oil & Grease
3
2
6.
<5
ppm
BOO
3
<
g
ppm
5-Day? "5-Day" not i
permit
COD
12
87
6
54
ppm
TP
0,49
0.08
0.12
0.04
ppm
TSS
10C
EEEKJ5-3117
ppm
TKN
21
1.03
<0.250
<0.1D
0A,
ppm
pH
6-91
7.5
7.52
7.01
1.21
standard
Over
Current
Benchmark
No Sample
Collected

NCS000222
Revised Permit Recommendations: Analytical Monitoring:
1. Dioxin has been added per the Brown fields Program's recommendations.
2. Brownfields Program also recommended the following analytical requirements: Arsenic, Copper, and
Chromium. These were already in the facility's testing parameters from the previous permit. "Total
Recoverable" has been specified for these parameters. "Total recoverable" was also specified for Zinc.
3. pH has been added to the analytical monitoring requirements per DWQ's revised strategy.
4. Due to a potential lag time between the expiration of this permit and its renewal, I have specified in the permit
that the permittee is responsible for all monitoring until the renewal permit is issued. See Footnote 1 of Tables
1, 4, and 5. This approach is recommended because there has been a significant lag time since the expiration of
the previous cycle. This will provide testing if there is a lag in future timeframes. "Measurement Frequency: All
analytical monitoring will be performed two times per year for each year until either another permit is issued for
this facility or until this permit is revoked or rescinded. If at the end of this permitting cycle, the permittee has
submitted the appropriate paperwork for a renewal application before the submittal deadline, the permittee will
be considered for a renewal application. The applicant must continue semi-annual analytical monitoring until
the renewed permit is issued. See Table 2 for schedule of monitoring periods through the end of this permitting
cycle."
5. Benchmarks have been added to this draft permit.
6. All analytical monitoring has been set to semi-annually.
T The flow reporting requirement has been removed per DWQ revised strategy. (The total rainfall and event
duration parameters are in this permit, however.) (There was no flow requirement in the previous permit.)
8. The permittee is required to collect all of the analytical monitoring samples during representative storm events as
defined in this permit. Qualitative monitoring does not have to be performed during a representative storm
event.
Other Proposed Changes to the Previous Permit:
I will include in the cover letter that the detection limits for pentachlorophenol, toluene, naphthalene, and
anthracene are not sufficient to detect the compound at the benchmark level. All benchmarks should be
analytically detectable.
Part 11 Section A has been revised. It now specifics all of the items to include on the site map.
Vehicle maintenance has been revised to semi-annually in order to coincide with analytical and qualitative
monitoring.
Discussions with permittee: Mike Rouse, 910.371.3131, 20 July 2007
1. Are you under new ownership? If so, will need an ownership change form. When did the change occur?
a. ANSWER: Yes, "Cox Industries" now owns their company, which is "Carolina Pole".
2. What does your company manufacture? Have there been any changes in industrial activity?
a. ANSWER: No changes.
3. Do you do wet -decking at your facility?
a. ANSWER: No wet decking.
4

NCS000222
Recommendations: Based on the documents reviewed, the application information submitted on 30 July 2004
sufficient to issue an Individual Stormwater Permit.
Prepared by (Signature) Date
P
Stormwater Permitting Unit SupervisorO%,%M t. 16N(.b & Date_ -clan
Concurrence by Regional Office 4 NMI.. NLET ?K11-. Date
%Water Quality Supervisor A�'x , . pCeli 3%e Date
Regional Office Staff' Comments

Re; [Fwd: NCS000222]
Subject: Re: [Fwd. NCS000222]
From: Linda Willis <[e-mail]>
Date: Mon, 19 Nov 2007 09:56:50 -0500
To: Kelly Johnson <[e-mail]>
How's this? not the signed copies, but you can see our comments. I'm not sure where
that inspection report went. . let me know if you need a signed copy. The signed
copy also went to central files for the record.
Have a great Tgiving week and holiday Kelly,
Hest regards,
Linda
Kelly Johnson wrote:
ILinda - I didn't get
so maybe that is why
it.
Thanks,
Kelly
the report in the mail. (Of course we also moved last week
) I just wanted to touch base with you in case you still had
Linda Willis wrote:
II'll drop the signed copy of
today.
Have a great day.
Linda
Kelly Johnson wrote:
Linda,
Would you mind forwarding
put it in the file?
Thanks,
Kelly
Linda Willis wrote:
No issue at will.
Thanks
Linda
the inspection report in interoffice mail to you
the signed staff report back to me so that I can
Kelly Johnson wrote:
Great, thanks. Did you have any comments about the permit text in
your staff report? If not, I'll send it to notice this week (so that
it will be issued as far as possible from my due date). If so, then
I'll just wait for your staff report and send it next month_ Either
way is fine. I'am just trying to anticipate what I'll have done
before he is born!
Thanks,
KJ
Linda Willis wrote:
Sorry so late,
It was good! They have a nasty operation there that is handled
quite effectively. I gave them a thorough inspection and they have
responded in writing to us with an updated SP3 plan that is really
I of 3 11 / ] 9/2007 11:01 AM

Re: CFwd: NCS0002221
r
good. They had implemented good BMPs, but their plan needed some
work. I noted their lack of adequate monitoring, but the people on
site are new owners. As a result, they are getting their plan in
the proper names with proper signatures and they should have sent
in or are working on getting you all a change of ownership form.
No problem with these folks. Let me know if you have any specific
questions.
Linda
Kelly Johnson wrote:
Linda,
How was the inspection at General Wood
KJ
(NCS000222)?
---------------------------------------------------------
Subject:
NCS000222
From:
Kelly Johnson <kelly,[e-mail]>
Date:
Wed, 08 Aug 2007 10:28:32 -0400
To:
Linda Willis <[e-mail]>
To.
Linda Willis <[e-mail]>
2000 permit attached.
KJ
Linda Willis <[e-mail]>
Environmental Engineer 1
Surface Water Protection Section
Division Of Water Quality
Carolina Pole Inspection Report Aug 07.doc
Content -Type: application/msword
Content -Encoding: base64
Content -Type: application/rnsword
C000222 Carolina Pole (Timber Treating) Aug 07.doc
Content -Encoding: base64
Response to NCO00222 from 08 07 inspection.doc Content -Type:
application/msword
2 of 3 11/19/2007 11.01 AM

NC DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
®gin INDUSTRIAL, STORM WATER INSPECTION FORM
WILMINGTON REGIONAL OFFICE
Facility:
Carolina Pole
Date: August 8, 2007
Location Address:
1901 Wood Treatment Road, Leland North Carolina
COC #:
Contact Name:
Mike Rouse, Operations Manager
Phone Number: 910-371-3131
Contact Mailing Address:
P.O. Box 370, Leland North Carolina 28451
County: Brunswick
Directions: I On the left on US 74/76 pproximately 4 miles west of Hwy 17 intersection. Located just past last Leland exit.
x
Routine Compliance Inspection
Rescission Request
Complaint Investigation
x
Other — Permit renewal inspection
A.
STORM WATER POLLUTION PREVENTION PLAN
Yes
No
NIA
Comments
1.
is a copy of the signed and certified SWPPP at the facility?
x
Ownership change form
The permittee had sent in a change ownership form to DWQ for the state
needs to be sent in to the
stormwater permit and thought that would suffice for the ownership
Central Office (form
change notification to DWQ for all permits including the NPDES permit.
enclosed). SWPPP
needs to be updated and
signed by Mr. Johnson
The plan should be
reviewed and updated to
2.
Does the facility's SWPPP address the minimum BMP requirements?
x
3.
Are amendments to the SWPPP clearly documented?
x
4.
Is the current SWPPP complete?
x
A yearly review of the plan is required with amendments clearly defined
include the information
at the front of the SWP3. A signature and date on which the review and
requested (see left). The
amendments.were made is required. The site transcends two USGS
current site maps require
quadrants. The map provided is not adequate. A map showing the
updating with better
location of tanks, drums, treatment systems, and operating equipment
detail_
under the covered area should be provided. The possible contents for
each should be clearly identified. The volume of each tank should be
identified and total volume in drum storage areas identified. The areas
where hazardous waste and raw materials are stored should be clearly
indicated. Include storage volume of secondary containment. The
Stormwater Management Plan did not contain a feasibility study section.
B.
VEHICLE EQUIPMENT
Yes
No
NIA
I.
Were the vehicle/equipment maintenance areas inspected?
x
2.
Are vehicle/machinery leaks and drips properly managed?
x
3.
Is vehicle/equipment washing done in a designed area so that wash water
x
can be properly managed?
Maintenance is conducted within a containment area. The Spill
Response Plan identified actions required to quickly eliminate and clean
up a petroleum spill.
4.
Was the vehicle fueling area inspected?
x
5.
Are vehicle maintenance activities kept indoors?
x
6.
Were the vehicle/equipment storage areas inspected?
x
7.
Are current BM -Ps in vehicle/equipment/fueling areas adequate?
x
C.
WASTE MANAGEMENT
Yes
No
NIA

I .
Are containers for temporary storage of wastes labeled?
No containers were
observed.
Facility utilizes Safety
2.
Are waste materials recycled?
x
Kleen
Facility utilizes Clean
3.
Are hazardous wastes properly handled and disposed of?
x
Harbors
Raw materials, products
4.
Is processed debris removed regularly?
x
5.
Is there secondary containment for liquid wastes?
x
6.
Are current waste management BMPs adequate?
x
D.
MAT ERL&L STORAGE
Yes
No
N/A
1.
Are there appropriate BMPs for outdoor storage of raw materials,
x
products, and byproducts?
and byproducts are
stored under roof with
secondary containment
with the exception of
dried treated and
untreated timber.
2.
Are containers for chemical substances labeled?
x
3.
Is there secondary containment for liquid storage?
x
4.
Are current BMPs in material storage areas adequate?
x
E.
SPILL CONTROL
Yes
No
NIA
Comments
1.
Are there procedures for spill response and cleanup?
x
2.
Are appropriate spill containment and cleanup materials kept on -site and
x
in convenient locations?
Did not check disposal
3.
Are used absorbent materials disposed of in a timely manner?
x
records or manifests.
Given the nature of the
4.
Are current spill BMPs adequate?
x
F.
EROSION
Yes
No
NIA
1.
Are unpaved outdoor areas protected from water/wind erosion?
x
site, water and wind
erosion is possible,
however it did not
appear to be a significant
problem.
A perimeter ditch
2.
Are drainage ditches or the areas around the outfalls free of erosion?
x
surrounds the 130 acre
site. The ditch shows
signs of some erosion. It
appears the grading at
the site is maintained to
reduce erosion as much
as practical_
The plan indicated no
3.
Do implemented BMPs appear effective in controlling erosion?
x
G.
NON -STORM WATER MANAGEMENT
Yes
No
NIA
1.
Have all illicit water discharges been eliminated or permitted?
x
illicit water discharges
have occurred.
The site has no other
2.
Are BMPs for authorized non -storm water discharges properly
x
discharge than

implemented'!
stormwater.
3.
Are current BMPs adequate for management of authorized non -storm
x
water discharges?
There is a wastewater
H.
PROCESS WASTEWATER CONTROLS AND MONITORING
Yes
No
N/A
1.
Are wastewater treatment facilities properly maintained?
x
treatment facility, it is
The site utilizes a biological activated sludge system to reduce organics
not permitted through
the NPDES permit
in the treatment water. Flocculation and a filter belt press is used to
system and therefore it's
handle solids which are stored in a I cubic yard box for disposal by
proper operation was not
Clean Harbors. This system is a non discharge reuse/recycle treatment
commented on by the
system.
inspector.
Access to the discharge
2.
Has monitoring been done?
x
1.
STREAM OBSERVATIONAMPACTS
Yes
No
NIA
I.
Were there any stream impacts?
x
is not accessible since it
is on MOTSU property.
2.
Were field parameters taken for pH or DO?
x
3.
Were there any stream standard violations/
x
4.
Were there excessive solids in the stream?
x
5.
Were pictures taken?
x
6.
Were samples taken?
x
J.
SUMMARY 1 ACTION ITEMS
In general, all of the operations/activities of concern involving raw material storage, treatment operations, and storage of bulk
materials is under a roof minimizing/eliminating stormwater contact. The site appeared to be very clean, no evidence of spills on
the grounds outside of the containment areas. The site is surrounded by a deep ditch (approximately 4-5 foot deep). It serves as a
collection system and conveyance for stormwater runoff to outfall 001. Storrnwater collects in the perimeter ditch and exits the site
at one outfall located on the northeast corner of the property. The analytical monitoring required during the past permit cycle has
not been conducted according to the permit. Annual monitoring was missed during year 2 and the first, second and third quarters of
the fourth year of the permit cycle. Both semi annual qualitative monitoring was missed for year five of the permit cycle. It appears
the facility was sold to Carolina Pole Leland, Inc. (president R. Michael Johnson) in 2006. The permit expired February 28, 2005
and was not renewed. The SWP3 and SPRP is quite thorough in addressing any potential on site stormwater contamination and
regular and frequent inspections of all processes and storage areas as well as the entire site is conducted and documented. The
operations manager has been conducting qualitative monitoring even though the permit was not transferred to the new owner by the
Division. The permitee had sent in a DWQ Coastal Stormwater Permit Ownership Change Form (twice, registered receipt) to
request the change in ownership for NCS000222 in May of 2006. The request was (likely) not acknowledged since it was on the
wrong form.
The SWP3 plan needs to incorporate the changes/updates mentioned in the text of the inspection report (above). The Ownership
Change Form is required (enclosed). Updated maps need to be sent to the Wilmington Regional Office (WiRO) (to the attention of
Linda Willis). The bark and wood debris should be cleaned out from the stormwater conveyance ditch in the vicinity of the outfall
or any other area within the stormwater conveyance ditch where woody debris may collect. Please update the site maps (with
details identified in sections L. and M. of this inspection report) for inclusion in the SWP3 and forward a copy of each to Linda
Willis at WiRO.
K.
RATING LEVEL (CIRCLE ONE: 1-6)
1Q
Indusry in substantial compliance
Minor deficiencies noted. Revist will be scheduled within 6 months. (date).
3.
Major deficiencies or discharges noted and require prompt correction. Revisit scheduled for (date).

4. ICritical deficiencies or discharges noted and require immediate correctioin. Revisit scheduled (date).
for
5. 1 Rescission is appropriate.
Rescission is not appropriate.
Logged by:
Inspected by: Linda Willis
L. Include a Map of the facility. This drawing should depict the building, parking, process, and storage areas.
If you do not have a map, draw one or request that the facility provide you one in your written
correspondence.
A more detailed vicinity map is required including ALL: buildings, storage areas, vehicle maintenance
buildings or areas, heavy equipment maintenance buildings or areas, hazardous waste storage area for
drums and/or bulk waste, wastewater treatment system including storage for treatment chemicals (polymers
for flocculation and/or pH control), settling tanks, aeration basin, storage basins, belt filter press, bulk
storage tanks, storage areas for drums or pails, loading and unloading areas, autoclaves, drip pads, fire
suppression equipment, drying kilns etc. etc. utilize shading where secondary containment is provided and
processes are under roof. Please make sure an arrow depicting North is provided on both maps. Ensure
both maps are to scale and the scale is identified on the maps.
M. Develop a Vicinity Map for the file.
A non cartoon topographical map (USGS) is required with the overlay of the entire site on the
topographical map. The map should include any surface waters in close proximity to the site.
Provide lattitude and longitude for the outfall 001.
N. Identify all records that were reviewed.
Permit file. SWP3 Plan and spill response plan. Inspection records for the outfall and facility operations.
Employee training records. Qualitative and quantitative monitoring records.
O. Explain how Secondary Containment is being used and whether these measures are being properly
maintained. [Did you observe that the secondary containment had release valves (were they open, locked
etc.), was there water, waste product, sheen, etc observed within the secondary containment area? Explain
your observations]
There were no drains in the areas inspected. The contents of secondary containment areas are pumped to
the wastewater treatment facility for treatment. The water in the secondary containment area is not released
to the environment.
P. House keeping and best management practices (maintenance of BMPs) status.
Housekeeping was good. No litter, no excessive junk lying around the property, no evidences of spills of
chemicals or petroleum products to the ground were evident.
Q. Identify outfalls and receiving waters. List any observation or concerns.
Outfall 001 is the only outfall from the site that conveys stormwater to surface waters of the state. The area
around the outfall had an excessive build up of bark and wood debris that should be removed on a regular
basis. It might be prudent to exercize some type of debris control prior to the outfall pipe, but regular
removal of debris may suffice.
R. Take digital photographs to support staff report observations and to provide assistance to future inspectors).
Digital photos available of some of the process area and outfall.
Logged by: Inspector: Linda Willis

August 9, 2007
Mike Rouse
Operations Manager
P.O. Box 370
Leland, North Carolina 28451
SUBJECT: Compliance Evaluation Inspection,
Carolina Pole
Permit Number NC000222
County Brunswick
Dear Mr. Rouse:
On August 8, 2007, Linda Willis, of the Division of Water Quality, Wilmington Regional Office, performed an
inspection of the subject facility. As part of the inspection, a tour of your facility was conducted. All observations and
recommendations are noted in the (Summary of findings/Action Items) of this inspection report. Please respond to these
action items in an expedient manner to prevent any future problems. Remember, it is our goal to insure the quality of
the surface waters of this State.
Please review the attached report. If you or your staff have any questions, do not hesitate to contact Linda Willis
or myself at 910-796-7215.
Sincerely,
Edward Beck
Surface Water Protection Section
Water Quality Regional Supervisor

Enclosures
cc: Central files
WiRO1DWQ Stormwater Compliance Files (Linda Willis)
Stormwater Permitting Unit/ Raleigh
NPS and Compliance Oversight/Raleigh

O�aF wAr ,, Michael F. Easley, Governor
William G. Ross Jr., Secretary
co 7
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
August 9, 2007
Certi'fied Mail
Return Receipt Requested 7006 0810 0004 4480 9360
Mike Rouse
Operations Manager
P.Q. Box 370
Leland, North Carolina 28451
Certified Mail
Return Receipt Requested 7006 0810 0004 4480 9377
Mr. R. Michael Johnson
President
P.O. Box 1124
Orangeburg, South Carolina 29116
SUBJECT: Compliance Evaluation Inspection
Carolina Pole
Permit Number NCS000222
County Brunswick
Dear Mr. Rouse:
On August 8, 2007, Linda Willis, of the Division of Water Quality, Wilmington Regional Office,
performed an inspection of the subject facility. As part of the inspection, a tour of your facility was
conducted. Ail observations and recommendations are noted in the (Summary of findings/Action Items)
of this inspection report. Please respond to these action items in an expedient manner to prevent any
future problems. Remember, it is our goal to insure the quality of the surface waters of this State.
Please review the attached report. If you or your staff have any questions, do not hesitate to
contact Linda Willis or myself at 910-796-7215.
Sincerely,
Edward Beck
Surface Water Protection Section
Water Quality Regional Supervisor
Enclosures
CC' Central files
WiRO/DWQ Stormwater Compliance Files (Linda Willis)
Stormwater Permitting Unit/ Raleigh
NPS and Compliance Oversight/Raleigh
NCurat!;aro ina �M
North Carolina Division of Water Quality 127 Cardinal Drive Extension Wilmington, NC 28405 Phone [phone] Customer Service
Intemet: wwwmcwateruuality. Fax [phone]
An Equal opportun4lAsnrmative Action Employer-- 500% Recycledl10% Post Consumer Paper

Q of WA74 qpMichael F. Easley, Governor
William G. Ross Jr., Secretary
QYImo— North Carolina Department of Environment and Natural Resources
-� Coleen H. Sullins, Director
Division of Water Quality
October 1, 2007
Mr_ Mike Rouse
Operations Manager
P.O. Box 370
Leland, NC 28451 Re: Compliance Evaluation Inspection
Carolina Pole
NPDES Permit No. NCS000222
Brunswick County
Dear Mr. Rouse,
The Division is in receipt of your response to the recent NPDES stormwater inspection conducted at the
Carolina Pole facility on August 8, 2007, The updated Stormwater Pollution Prevention Plan appears to
thoroughly address all of the items listed in the inspection report. The plan appears to also address each
of the itemized requirements listed in Sections A through D of the NPDES Permit. The ownership
change form is awaiting signatures. Once the form is complete, please forward that form to the
Stormwater Permitting Unit at 1617 Mail Service Center, Raleigh North Carolina 27699-1617.
When you receive your renewed NPDES permit, please carefully review the qualitative and quantitative
monitoring requirements specified in the new permit versus those outlined in your Stormwater Pollution
Prevention Plan and make any necessary amendments to your Plan accordingly. This will prevent any
discrepancies in the implementation of your current plan versus the requirements of the renewed NPDES
Permit.
Thank you for your timely response and your attention to this matter. Should you have any questions
regarding this correspondence or your permit renewal, please do not hesitate to contact me at 910-796-
7343.
Sincerely,
Linda Willis
Environmental Engineer I
Surface Water Protection Section
CC: Edward Beck, Regional Supervisor, SWPS, WiRO
Central Files
Kelly Johnson, Central Office, Stormwater Permitting Unit
WiRO NPDES Permit File NCS000222, Brunswick County
at ra!!y
North Carolina Division of Water Quality 127 Cardinal Drive Extension Wilmington, NC 28405 Phone [phone] Customer Service
Internet: www.ncwatMgglity.org Fax [phone]
An Equal Oppartun4tAtfirmaM Action Employer— 50% RecycledJid% Post Consumer Paper

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Alan W. Klimek, P.E., Director
July 1, 2004
GENERAL WOOD PRESERVING CO-BRU
ATFN: KARL A BOATRIGHT. OR SUCCESSOR
PO BOX 370
LELAND. NC 28451
Dear Permittee:
NCDENR
NORTH CAROLtNA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Sub.iect: NPDES Stormwater Permit Renewal
General Wood Preserving Co-Bru
Permit Number NCS000222
Brunswick County
Your facility is currently covered for stormwater discharge under NPDES Permit NCS000222. This permit expires
on February 28, 2005. North Carolina Administrative Code (15A NCAC 2H.0105(e)) requires that an application
for permit renewal be filed at least ISO days prior to expiration of the current permit. In order to assure your
continued coverage under your permit. you must apply to the Division of Water Quality (DWQ) for renewal of
your permit. To make this renewal process easier, we are informing you in advance that your permit will be
expiring. Enclosed you will Find an individual permit renewal application form, supplemental information request.
and Stormwater Pollution Prevention Plan certification.
Filing the application form along with the requested supplimental information will constitute your application for
renewal of your permit. As stated above, the application form must be completed and returned along with all
requested information by July 31. 2004 in order for the permit to be renewed by February 28, 2005_
Failure to request renewal'by July 31. 2004 may result in a civil assessment of at least $500.00. Larger penalties
may be assessed depending on the delinquency of the request. Discharge of stormwater from your facility without
coverage under a valid stormwater NPDES permit would constitute a violation of NCGS 143-215.1 and could
result in assessments of civil penalties of up to $25.000 per day.
If you have any questions regarding the permit renewal procedures please contact Bill Mills of the Stormwater and
General Permits Unit at [phone], ext. 548.
Sincerely,
Bradley Bennett, Supervisor
Stormwater and General Permits Unit
cc: Central Files
Stormwater and General Permits Unit Files
Wilmington Regional Office
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] Fax [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper